oversight

Ecosystem Planning: Northwest Forest and Interior Columbia River Basin Plans Demonstrate Improvements in Land-Use Planning

Published by the Government Accountability Office on 1999-05-26.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to Congressional Requesters




May 1999
                 ECOSYSTEM
                 PLANNING
                 Northwest Forest and
                 Interior Columbia
                 River Basin Plans
                 Demonstrate
                 Improvements in
                 Land-Use Planning




GAO/RCED-99-64
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Resources, Community, and
      Economic Development Division

      B-281830

      May 26, 1999

      The Honorable Frank Murkowski
      Chairman, Committee on Energy
        and Natural Resources
      United States Senate

      The Honorable Don Young
      Chairman, Committee on Resources
      House of Representatives

      The Honorable Larry Combest
      Chairman, Committee on Agriculture
      House of Representatives

      The decision-making process used by the Department of Agriculture’s
      Forest Service in carrying out its mission is costly and time-consuming,
      and the agency has often failed to achieve its planned objectives.1
      Inefficiency and waste within the process have already cost taxpayers
      hundreds of millions of dollars.2 Difficulties in addressing ecological issues
      that transcend the Forest Service’s administrative boundaries and
      jurisdiction have contributed to the inefficiency in developing, and
      ineffectiveness in implementing, forest as well as other federal land
      management plans.3

      Traditionally, the Forest Service, the Department of the Interior’s Bureau
      of Land management (BLM), and other federal land management agencies
      developed plans to manage federal resources independently and focused
      mainly on the resources within the administrative boundaries of individual
      national forests, parks, and other federal land management units. These
      planning efforts often failed to adequately consider ecological issues that
      transcend administrative boundaries—such as issues concerning
      watersheds4 or the habitats of wide-ranging species, including migratory

      1
       Forest Service Decision-Making: A Framework for Improving Performance (GAO/RCED-97-71, Apr.
      29, 1997) and Tongass National Forest: Lack of Accountability for Time and Costs Has Delayed Forest
      Plan Revision (GAO/T-RCED-97-153, Apr. 29, 1997).
      2
       See, for example, Forest Service: Lack of Financial and Performance Accountability Has Resulted in
      Inefficiency and Waste (GAO/T-RCED/AIMD-98-135, Mar. 26, 1998).
      3
      Forest Service Decision-Making: A Framework for Improving Performance (GAO/RCED-97-71,
      Apr. 29, 1997).
      4
       A watershed is an area of land in which all surface water drains to a common point. A watershed can
      range from less than 100 acres drained by a single stream to many thousands of acres drained by
      hundreds of smaller streams that ultimately form one stream or river.



      Page 1                                                      GAO/RCED-99-64 Ecosystem Planning
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                   birds, bear, and salmon. The agencies’ past planning efforts also suffered
                   from other long-standing deficiencies, including (1) inadequate
                   involvement by other federal agencies and the public, (2) a lack of
                   comparable environmental and socioeconomic data, (3) inadequate
                   monitoring to determine the effects of past management decisions, and
                   (4) a lack of accountability for time and costs.

                   In the early 1990s, the Forest Service and BLM both announced that they
                   would adopt a management approach that focuses on ecosystems. We
                   have reported on ecosystem management as an approach and have
                   concluded that specific steps are necessary for its successful
                   implementation. These include (1) delineating ecosystems,
                   (2) understanding the ecology of ecosystems, (3) making management
                   choices, and (4) adapting management to new information.

                   Recently, the Forest Service and BLM have begun testing the efficiency and
                   effectiveness of using broad-scoped, ecosystem-based studies to analyze
                   ecological issues that transcend their jurisdictions and to collaborate on
                   plans for federal land management units throughout large ecological
                   regions defined by geophysical features, such as watersheds, or the
                   habitats of wide-ranging species, such as the northern spotted owl. Two of
                   the largest of the agencies’ ecosystem-based studies—a July 1993 plan,5
                   the Northwest Forest Plan (see app. I), and an ongoing planning effort, the
                   Interior Columbia Basin Ecosystem Management Project (see app. II)—are
                   intended to provide direction for managing about 90 million acres of
                   federal land in all or parts of eight northwestern states.

                   Concerned about the potential costs, timeliness, and effectiveness of
                   broad-scoped, ecosystem-based studies, you asked us to examine the two
                   planning efforts. In this report, we discuss (1) the extent to which each
                   effort has addressed long-standing planning deficiencies, (2) whether the
                   agencies encountered the delays and significant costs that have been
                   characteristic of previous planning efforts, and (3) the effect that the plans
                   have had, or are expected to have, on the quantity and quality of timber
                   sold from federal lands covered by the plans.


                   Both the process used to develop and implement the Northwest Forest
Results in Brief   Plan and the process being used to develop a plan to manage federal lands
                   in the interior Columbia River basin address many of the long-standing

                   5
                   W. Clinton and A. Gore, Jr., The Forest Plan for a Sustainable Economy and a Sustainable
                   Environment (July 1, 1993).



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planning deficiencies that have contributed to delays, increased costs, and
unmet objectives in other land management plans. For example,
(1) federal interagency coordination has improved; (2) opportunities for
public involvement have improved; (3) scientific assessments and analyses
have generated better environmental and socioeconomic data for more
informed management decisions, and (4) processes have been or will be
established to monitor the effects of decisions and adapt management to
new information.

The Forest Service and BLM completed the Northwest Forest Plan
expeditiously and at a relatively low cost, while the interior Columbia
River basin plan has taken much longer and cost much more than
originally expected and has not yet been approved. The Northwest Forest
Plan was developed in 1 year at a cost of about $3.5 million. This was a
timely and cost-effective effort compared with past national forest
planning efforts that took from 3 to 10 years to complete and, in the
Pacific Northwest, cost between $5 million and $8 million even though
they covered much smaller areas. The timeliness of the plan was, in part, a
function of the fact that the agencies had been gathering data on the
old-growth forest habitat of the northern spotted owl for many years. In
addition, the federal court injunctions on timber sales created a sense of
urgency and focus. The result was a plan that provides the agencies’ field
managers with direction for implementation and sets standards for holding
them accountable. Although the agencies’ 5-year effort to develop a plan
for the interior Columbia River basin has overcome some long-standing
deficiencies, it has not yet led to a final plan. The ongoing project has
already taken 2-1/2 years longer and, at $41 million, cost $10 million more
than anticipated. Some of the delays and higher costs to date have
occurred because the agencies underestimated the time and effort
required to address the ecological diversity and broad array of land
management issues that exist in the interior Columbia River basin.
Additional delays and costs are being incurred because the agencies are
developing one or more new management alternatives in response to
public and congressional criticism of their originally proposed draft
management alternatives—including their preferred alternative. We also
believe that their originally proposed alternatives did not give adequate
information to stakeholders on how and with what effect the alternatives
would be implemented.

Timber harvests have declined significantly since the 1980s and will likely
remain at current levels under the Northwest Forest Plan. Existing laws,
including the Endangered Species Act, and their implementing regulations



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             and judicial interpretations, have resulted in less federal land being
             available for timber production and less timber being produced from the
             land that is available. Moreover, the Forest Service and BLM overestimated
             the volume of timber to be harvested under their original preferred
             management alternative for federal lands in the interior Columbia River
             basin. As a result, the agencies created unrealistic expectations for
             relatively high timber harvests that would probably not have occurred,
             largely because of regulatory agencies’ concerns over the impact of
             harvests on natural resources and shortfalls in funding to implement the
             plan.


             The federal government owns about 30 percent (650 million acres) of the
Background   nation’s total surface area. Together, the Forest Service and BLM manage
             about 70 percent of all federal lands. The Forest Service manages about
             192 million acres of land, including about one-fifth of the nation’s
             forestlands, through three levels of field management—9 regional offices,
             123 forest offices, and about 600 district offices. Laws guiding the
             management of the national forests require the agency to manage its lands
             under the principles of multiple use and sustained yield to meet the
             diverse needs of the American people. Under the multiple-use principle,
             the agency is required to plan for six renewable surface uses—outdoor
             recreation, rangeland, timber, watersheds and water flows, wilderness,
             and wildlife and fish. Under the sustained-yield principle, the agency is
             required to manage its lands to provide high levels of all of these uses to
             current users while sustaining undiminished the lands’ ability to produce
             these uses for future generations. In addition, the Forest Service is
             required by its guidance and regulations to consider the production of
             nonrenewable subsurface resources—such as oil, gas, and hardrock
             minerals6—in its planning.

             BLM manages almost 264 million acres of land, including about 177 million
             acres located mainly in the western United States and about 87 million
             acres in Alaska, through three levels of field management—12 state offices
             that oversee district and resource area offices.7 BLM also manages the
             mineral estate that underlies almost 300 million acres managed by other
             agencies, including the Forest Service. The Federal Land Policy and
             Management Act of 1976 requires the agency to manage its lands for
             multiple uses and sustained yield. Under the act, multiple uses include

             6
              Hardrock minerals include gold, silver, lead, iron, and copper.
             7
              During 1999, BLM is planning to streamline its organizational structure by combining its district and
             resource area offices into field offices.



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recreation; range; timber; minerals; watersheds; fish and wildlife; and
natural scenic, scientific, and historic values.

The Forest Service and BLM must comply with the requirements of the
National Environmental Policy Act of 1969. This act and its implementing
regulations specify the procedures for integrating environmental
considerations through environmental analyses and for incorporating
public input into the agencies’ decision-making processes. The act requires
that a federal agency prepare a detailed environmental impact statement
for every major federal action that may significantly affect the quality of
the human environment. Environmental impact statements are designed to
ensure that important effects on the environment will not be overlooked
or understated before the government makes a commitment to a proposed
action.

In developing plans and making decisions to implement projects,8 the
Forest Service and BLM must also comply with the requirements of other
environmental statutes, including the Endangered Species Act, the Clean
Water Act, the Clean Air Act, the Wilderness Act, and the Migratory Bird
Treaty Act, as well as other laws, such as the National Historic
Preservation Act. In particular, section 7 of the Endangered Species Act
generally prohibits federal agencies from taking actions in pursuit of their
primary missions, such as timber production, if those actions would put
threatened or endangered species at risk. When proposing a project, a
federal agency is prohibited from taking an action that would jeopardize
the existence of threatened or endangered species or adversely modify
designated critical habitat.

Several federal regulatory agencies are responsible for enforcing
environmental laws and regulations. For example, the Department of the
Interior’s Fish and Wildlife Service and the Department of Commerce’s
National Marine Fisheries Service share responsibility for ensuring the
protection and recovery of plant and animal species listed as threatened or
endangered under the Endangered Species Act. The Environmental
Protection Agency has authorities and responsibilities to implement major
environmental statutes, including those to protect and enhance air quality
(the Clean Air Act) and to restore and maintain the chemical, physical, and
biological integrity of the nation’s waters (the Clean Water Act).




8
 Projects are on-the-ground activities, such as harvesting timber, restoring species’ habitats, and
constructing campsites.



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In April and July 1993, the President directed the development of what
would become, respectively, the Northwest Forest Plan and the Interior
Columbia Basin Ecosystem Management Project. The Northwest Forest
Plan was developed in response to court injunctions that barred the Forest
Service and BLM from selling timber harvested in the range of the northern
spotted owl, which was listed as a threatened species in 1990. The
Northwest Forest Plan includes two components that focus on forest
management and economic development. The first component includes a
regional land management plan that provides management direction for
the 22.3 million acres of land managed by the Forest Service and BLM in the
range of the northern spotted owl. (See fig. 1.) The land management
plan’s development began with a scientific assessment by six federal
agencies that described current and desired ecological conditions within
the owl’s range.9 The plan was completed when the Secretaries of
Agriculture and the Interior approved it in April 1994. The plan is currently
being implemented. The second component of the Northwest Forest Plan,
an economic assistance program aimed at helping the region adjust to
changes in federal forest management, is not discussed in this report.




9
 The six federal agencies were the Forest Service, BLM, the Fish and Wildlife Service, the National
Park Service, the National Marine Fisheries Service, and the Environmental Protection Agency.



Page 6                                                       GAO/RCED-99-64 Ecosystem Planning
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Figure 1: The Geographical
Boundaries of the Northwest Forest                                                 Eastside
Plan and of the Interior Columbia                                                  planning          Upper Columbia
                                                                                   area              River Basin
Basin Ecosystem Management Project                                                                   planning area

                                                                      Washington




                                                                                                            Montana




                                                                Oregon
                                                                                     Idaho




                                                                                                              Wyoming




                                                                       Nevada


                                                                                              Utah
                                                 California




                                              Northwest Forest Plan

                                              Interior Columbia River Basin Plan



                                     Sources: Forest Service and BLM.




                                     In July 1993, the President also directed the Forest Service to develop a
                                     regional land management plan for national forests in Oregon and




                                     Page 7                                                     GAO/RCED-99-64 Ecosystem Planning
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                           Washington east of the crest of the Cascade Mountains. The plan is being
                           developed to avoid conflicts of the sort that prompted the Northwest
                           Forest Plan. In January 1994, the Forest Service and BLM agreed to expand
                           the scope of the plan to include all lands managed by BLM in eastern
                           Oregon and Washington. (See the Eastside Planning area in fig. 1.) In July
                           1994, the two agencies further expanded the project to include their lands
                           in much of Idaho, western Montana, and small portions of Nevada,
                           Wyoming, and Utah. (See the Upper Columbia River Basin planning area in
                           fig. 1.) The total planning effort encompasses about 72 million acres of
                           federal land and is known as the Interior Columbia Basin Ecosystem
                           Management Project. In June 1997, the agencies released a set of draft
                           management alternatives, including their preferred alternative, for public
                           comment. In October 1998, responding to congressional and public
                           criticisms, the Secretaries of Agriculture and the Interior announced their
                           decision to develop one or more new draft alternatives.


                           During the past 5 fiscal years, we have issued reports identifying
The Forest Service         long-standing deficiencies in federal land management decision-making
and BLM Have               generally and in the Forest Service’s decision-making particularly.10 These
Addressed Many             deficiencies include a lack of (1) adequate involvement in the
                           decision-making process by other federal agencies and the public,
Long-Standing              (2) comparable environmental and socioeconomic data among agencies,
Planning Deficiencies      and (3) monitoring to determine the effects of past management decisions.
                           These deficiencies have increased, and could continue to increase, the
                           time and costs needed for any federal land management agency to reach a
                           decision at any organizational level. The processes used to develop and
                           implement the Northwest Forest Plan and to develop a plan for managing
                           federal lands in the interior Columbia River basin address these
                           deficiencies.


Interagency Coordination   Involving federal regulatory agencies, such as the Fish and Wildlife
Has Improved               Service, the National Marine Fisheries Service, and the Environmental
                           Protection Agency, at the beginning of the planning process and
                           maintaining their involvement throughout the process can expedite
                           decision-making. However, federal land management agencies have not


                           10
                            Forest Service Decision-Making: A Framework for Improving Performance (GAO/RCED-97-71, Apr.
                           29, 1997); Tongass National Forest: Lack of Accountability for Time and Costs Has Delayed Forest
                           Plan Revision (GAO/T-RCED-97-153, Apr. 29, 1997); Forest Service: Lack of Financial and Performance
                           Accountability Has Resulted in Inefficiency and Waste (GAO/T-RCED/AIMD-98-135, Mar. 26, 1998); and
                           Ecosystem Management: Additional Actions Needed to Adequately Test a Promising Approach
                           (GAO/RCED-94-111, Aug. 16, 1994).



                           Page 8                                                    GAO/RCED-99-64 Ecosystem Planning
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                           always sought the regulatory agencies’ early involvement. For example,
                           before the Northwest Forest Plan was developed, a lack of coordination
                           among federal agencies was identified as a major cause of the impasse that
                           existed in the region.

                           In developing and implementing the Northwest Forest Plan, federal
                           agencies have worked together to improve coordination and
                           communication with positive results. For instance, according to agency
                           officials, the time and resources required for federal land management
                           agencies to consult with federal regulatory agencies as required under the
                           Endangered Species Act has generally declined. However, agency officials
                           believe additional improvements are warranted.

                           The development of a plan to manage federal lands in the interior
                           Columbia River basin has been an interdisciplinary and interagency effort
                           from the beginning. While the Forest Service and BLM have led the effort,
                           other federal agencies have provided both staff and funding to support the
                           project.


Opportunities for Public   The public has expressed its desire to become more involved in federal
Participation Have         land management decision-making and has demonstrated its preference
Improved                   for presenting its concerns, positions, and supporting documentation
                           during, rather than after, an agency’s development of proposed plans. It
                           has also signaled its intent to challenge through administrative appeals
                           and lawsuits decisions that it has not been involved in reaching. The
                           Forest Service has often not, however, adequately involved the public
                           throughout the decision-making process, and efforts to address ecosystem
                           issues and concerns have occasionally excluded key nonfederal
                           landowners.11

                           Because the court injunctions that had enjoined the Forest Service and
                           BLM from selling timber until they addressed issues related to protecting
                           the threatened northern spotted owl and its habitat necessitated quick
                           action, the public was not involved in the scientific assessment that started
                           the development of the Northwest Forest Plan. However, public comments
                           were requested, and over 100,000 were received, on the draft plan.
                           Moreover, since the plan was approved, federal agencies have shown their
                           willingness to involve nonfederal parties in their decision-making. For
                           example, the agencies have established advisory committees that include

                           11
                            See, for example, Oregon Watersheds: Many Activities Contribute to Increased Turbidity During
                           Large Storms (GAO/RCED-98-220, July 29, 1998).



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                           the general public, local governments, and other groups. Among other
                           things, these committees helped to determine whether agencies’ activities
                           were in compliance with the plan’s requirements.

                           The public has had many opportunities to participate in the development
                           of a plan to manage federal lands in the interior Columbia River basin. For
                           example, the agencies (1) held meetings with the public in dozens of
                           locations to identify people’s concerns about federal land management;
                           (2) held over 200 meetings, briefings, and consultations to keep the public
                           and other interested parties informed during the development of
                           alternatives to manage federal lands in the basin; and (3) requested,
                           received, analyzed, and are considering comments from nearly 83,000
                           parties on the seven different land management alternatives included in
                           the original draft plan issued in June 1997.


Efforts Are Under Way to   Effective interagency coordination is dependent on, among other things,
Collect and Use            comparable environmental and socioeconomic data that are useful and
Comparable Data            easily accessible to decisionmakers. However, data gathered by federal
                           agencies are often not comparable, large gaps in the available information
                           exist, and agencies may not know who has what information or how
                           existing information can be made available within agencies, across
                           agencies, and to the public. These data limitations continue to hinder the
                           development of federal land management plans, result in legal challenges
                           to the plans, and limit the implementation of efforts to expedite
                           decision-making.

                           Since the Northwest Forest Plan was approved, federal agencies have
                           made some progress in standardizing the data to be collected and in
                           mapping the region on a consistent scale. In addition, the Forest Service
                           and BLM are accumulating comparable data on, for example, forest cover
                           and landowners’ behavior, across large areas within the region and are
                           testing the data to see if they are useful to field managers for
                           decision-making.

                           The scientific assessment of ecological and socioeconomic systems and
                           conditions in the interior Columbia River basin has contributed greatly to
                           data comparability. For example, maps of particular variables, such as
                           vegetation types, grizzly bear range, and household income, are stored in
                           geographic information systems that can be retrieved not only by federal
                           agencies but also by the public and can be used for decision-making by
                           many levels of government.



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The Plans Require, or Will   Once a plan is approved, agencies must move toward monitoring its
Require, Regional            implementation to meet long-term and annual goals and objectives and to
Monitoring and Adaptive      adapting the plan’s management when new information becomes
                             available. Historically, the Forest Service has failed to live up to its own
Management                   monitoring requirements, particularly those for monitoring the effects of
                             past management decisions. Not monitoring and evaluating its decisions
                             could expose the Forest Service to further litigation.

                             The Northwest Forest Plan requires an extensive monitoring program. The
                             Forest Service and BLM have completed 4 years of monitoring to determine
                             whether the plan’s requirements are being implemented, and the agencies
                             are beginning to evaluate whether the plan is achieving its desired results.

                             A plan to manage federal lands in the interior Columbia River basin has
                             not been approved. However, the agencies have acknowledged the
                             importance of adaptive management and their original proposal identified
                             steps for monitoring the plan’s implementation.


                             The Northwest Forest Plan was developed and approved in about 1 year,
In Contrast to the           at a cost of about $3.5 million. By contrast, after spending over 5 years and
Northwest Forest             about $41 million through the end of fiscal year 1998, the Forest Service
Plan, the Draft              and BLM have exceeded time and cost estimates but have still not made the
                             necessary management choices and finalized a plan to manage federal
Management Plan for          lands in the interior Columbia River basin. The agencies estimate that they
the Interior Columbia        will need another $10.9 million to reach a decision in March 2000.
River Basin Has Been         Key factors that contributed to the timely and cost-effective development
Subject to Delays and        of the Northwest Forest Plan included (1) the sense of urgency created by
Increased Costs              the court injunctions, (2) the strong leadership displayed by the
                             administration in developing the plan, and (3) clear objectives focusing the
                             effort primarily on the minimum habitat needs of the northern spotted owl
                             and other species that depend on old-growth forests for their habitat.
                             Moreover, the plan provides the agencies’ land managers with adequate
                             direction for implementation and sets standards for holding them
                             accountable. For instance, federal lands in the plan area are divided into
                             seven categories. The lands in some categories are set aside or withdrawn
                             for specific uses, such as recreation, or reserved to protect habitat for
                             owls and other species. The lands in other categories are available for
                             multiple uses. The lands in each category are to be managed in accordance
                             with requirements that include allowable and prohibited activities and
                             other guidance. For example, timber harvesting to reduce the density of



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trees is allowed on lands reserved to protect owl habitat, but generally not
in stands over 80 years old.

There are two major reasons why the planning effort for the interior
Columbia River basin has taken longer and cost more than anticipated.
First, the agencies underestimated how much time it would take to
address the multitude of ecological and socioeconomic issues in the
basin—a region encompassing about 8 percent of the surface area of the
United States. The ecology of the interior Columbia basin is a diverse
mixture of forest and range types that support many species, produce a
wide array of goods and services, and have varied requirements for
restoration and conservation.

The second reason for the effort’s additional time and costs is that the
agencies chose to develop one or more new alternatives in response to
widespread criticism of their original draft alternatives from the public
and the Congress. A final decision on a plan to manage federal lands in the
basin is now not expected until March 2000. The fiscal year 1999 budget
for the project is $5.7 million, and the agencies estimate that they will need
$5.2 million in fiscal year 2000.

While much of the criticism reflected differences in opinion over how the
federal lands should be managed, some of it related to how successful the
agencies were in taking the steps necessary to implement ecosystem
management. One of the necessary steps is to delineate ecosystem
boundaries for consistent management. Although the agencies did this
when they selected the basin as their planning area, they have
acknowledged that their original proposal addressed issues that are not
appropriately dealt with at the scale of the basin. These include plant and
animal species with limited ranges whose management requires
site-specific information that cannot be provided at the scale of the basin.
The agencies have pledged to focus their revision on critical broad-scale
issues related to landscape health, aquatic habitats, human needs,
products and services, and terrestrial habitats.

In announcing their intent to supplement their draft proposal with a new
alternative or alternatives that focus on basinwide issues, the agencies
made it clear that the choice of a preferred alternative or alternatives for
the interior Columbia River basin project is the first in a series of decisions
that will affect federal land management. It is also clear that if more issues
are resolved at the basinwide scale, fewer issues will have to be resolved
at smaller scales. Conversely, if more broad-scale issues are deferred, the



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agencies will later need more planning resources and time to complete a
comprehensive plan for the basin.

We believe that for the issues addressed by the draft proposal, the
agencies also failed to complete one of the essential steps in ecosystem
management—making management choices. In our past work, we
concluded that this step includes identifying (1) desired future ecological
conditions; (2) the types, levels, and mixes of activities to meet these
conditions; and (3) the distribution of activities among land units over
time.12 Because the agencies did not complete this step, we believe that it
is difficult to determine how and where management activities would be
implemented in specific locations under the different alternatives.
Stakeholders therefore, had to base their analyses of the alternatives on
the intent of each alternative—such as aggressively restoring degraded
lands through active management, emphasizing the production of goods
and services, or promoting restoration by establishing a system of reserves
where management activities are limited—rather than on specific
expected results.

For example, rather than allocate the estimated potential timber harvest
among administrative land units, such as national forests, as they did for
the Northwest Forest Plan, the Forest Service and BLM allocated the
estimated potential timber harvests and other activities to noncontiguous
but ecologically similar groupings of land—called “clusters”—that are
scattered throughout the basin. These clusters do not correspond to the
borders of administrative land units. (Fig. 2 shows the boundaries of forest
clusters in the basin.) Therefore, this approach did not indicate what level
of economic activity could be expected for individual national forests or
BLM management units. Hence, those economically dependent on these
units, such as timber industry employees, did not have an adequate
understanding of the economic impact of the different land management
alternatives and could not make informed choices among them.




12
 Ecosystem Management: Additional Actions Needed to Adequately Test a Promising Approach
(GAO/RCED-94-111, Aug. 16, 1994).



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Figure 2: Forest Clusters in Lands Within the Boundaries of the Interior Columbia River Basin Project Area


                                                    C A N A D A
                                            WASHINGTON         IDAHO      MONTANA




                                               WASHINGTON
                                                  OREGON




                                                                                                         WYOMING




                                              OREGON                      IDAHO
                                                                         NEVADA
         CALIFORNIA                                                                    UTAH




      Cluster 1

      Cluster 2       Boundary of area covered by the environmental impact statement

      Cluster 3       Cluster boundary

      Cluster 4

      Cluster 5

      Cluster 6


                                                                                                        (Figure notes on next page)



                                                 Page 14                                      GAO/RCED-99-64 Ecosystem Planning
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                       Note: The lands in the project area that are not shaded are dominated by range ecosystems
                       rather than forests. The agencies also divided these areas into noncontiguous range clusters.

                       Source: Interior Columbia Basin Ecosystem Management Project.




                       When the agencies announced that they would prepare an additional
                       alternative or alternatives for managing the basin and that they would
                       improve their proposal by focusing on basinwide issues, they also
                       indicated that the revision would provide only general guidance on some
                       of those issues. We are concerned that general guidance will not complete
                       the step of making management decisions and all that that step entails.
                       General guidance alone will not provide stakeholders with the clear and
                       well-defined management alternatives they need to make informed
                       choices, nor will it provide the Congress and the public with the standards
                       they need to hold federal land managers accountable.


                       The process used to develop the Northwest Forest Plan was timely and
The Quantity and       cost-effective and successfully addressed many of the long-standing
Quality of Timber      deficiencies associated with federal land management planning. Moreover,
From Western Federal   the broad-scale, ecosystem-based approach used to develop the plan was
                       sufficient for the courts to lift the injunctions related to the spotted owl
Lands Will Remain      controversy. The plan has not, however, reversed the sharp decline caused
Low                    by the injunctions in the quantity and quality of timber sold from federal
                       lands in the Pacific Northwest. As a result, the consequences of this
                       decline—higher per-unit costs for agencies to provide the timber and for
                       loggers to harvest it—have also not been reversed. Significant changes in
                       this situation are unlikely to occur under current planning and
                       environmental laws.

                       The Forest Service and BLM overestimated the volume of timber to be
                       harvested under their original preferred management alternative for
                       federal lands in the interior Columbia River basin. As a result, the agencies
                       created unrealistic expectations for relatively high timber harvests that
                       would probably not have occurred, largely because of regulatory agencies’
                       concerns and shortfalls in funding to implement the plan.




                       Page 15                                                    GAO/RCED-99-64 Ecosystem Planning
                            B-281830




The Northwest Forest Plan   The volume of timber sold from federal lands covered by the Northwest
Calls for Significantly     Forest Plan declined from a yearly average of about 5.0 billion board feet13
Lower Timber Sales          in the 1980s to a low of 297 million board feet in 1994 following the
                            injunctions barring federal timber sales in northern spotted owl habitat.
                            (See app. I, fig. I.3.) After the plan was approved, the injunctions were
                            lifted, but timber sales were not substantially increased. In the first 4 full
                            fiscal years of the plan, sales averaged about 687 million board feet per
                            year, largely because of restrictions imposed by the plan on how and
                            where timber can be commercially harvested. This level of sales is roughly
                            consistent with the plan’s projections for the first 4 years of
                            implementation.

                            The quality of the timber sold from the plan area has also declined, in part
                            because of the plan’s restrictions on the location and age of trees that can
                            be harvested. For example, the plan restricts the harvest of older trees to
                            protect the habitat of the northern spotted owl and other species. Older
                            trees are commercially valuable because they yield relatively higher-grade
                            timber that can be manufactured into a broad array of wood products,
                            including lumber. As a result of the plan’s restrictions, the proportion of
                            this high-grade timber harvested from national forests in the plan area has
                            decreased from an average of about 86 percent during the 1980s to an
                            average of less than 75 percent during fiscal years 1995 through 1998. (See
                            app. I, fig. I.4.)

                            As the quantity and quality of timber have declined, the per-unit costs to
                            the federal government and logging companies have increased
                            dramatically. For example, the Forest Service’s per-unit costs of operating
                            the timber program almost doubled from $126 per thousand board feet in
                            fiscal year 1992 to $243 per thousand board feet in fiscal year 1997. (See
                            app. I, fig. I.6.) This increase is largely attributable to the proportionally
                            higher fixed costs, such as expenses associated with depreciation on
                            existing facilities and roads, and inefficiencies inherent in smaller
                            harvests. The agencies have also significantly reduced the use of
                            clear-cutting—the removal of all trees from a timber-harvesting site at one
                            time—as the preferred harvesting method. The substitution of more
                            environmentally sensitive, but costlier harvesting methods has almost
                            doubled the per-unit costs to private companies of logging on federal lands
                            in the Pacific Northwest. (See app. I, fig. I.7.)


                            13
                              A board foot is a measure of wood volume equal to an unfinished board 1 foot long, 1 foot wide, and
                            1 inch thick. Different methods for estimating board feet yield different estimates. To account for these
                            differences, we have converted all board feet volumes into a standard measure using the method of
                            estimation employed by the Forest Service’s Northwest Region.



                            Page 16                                                       GAO/RCED-99-64 Ecosystem Planning
                               B-281830




Timber Sales Are Unlikely to   The overall decline in the quantity and quality of timber from federal lands
Substantially Increase Over    covered by the Northwest Forest Plan is unlikely to be reversed, given
Current Levels                 existing laws, including the Endangered Species Act, and their
                               implementing regulations and judicial interpretations. Restrictions
                               imposed by the plan to comply with these laws resulted in the injunctions
                               being lifted but also resulted in lower timber sales relative to the 1980s.
                               The plan initially projected that the agencies would be able to sell an
                               average of about 958 million board feet per year during the plan’s first
                               decade. While this level represents a decline of more than 80 percent from
                               sale levels during the 1980s, subsequent analyses of the ecological
                               conditions of the land by the Forest Service and BLM reduced the annual
                               projected sale volume to 840 million board feet for the first decade. Since
                               then, the Forest Service has announced that it will further reduce its
                               portion of the projected sale volume—thereby reducing the total for the
                               plan area. According to the Forest Service, the new projected sale volume
                               will most likely be 746 million board feet per year.

                               Although an annual timber sale level of 746 million board feet is more than
                               double the lowest level reached as a result of the federal court injunctions,
                               it is just a small fraction of the sale levels experienced during the 1980s.
                               (See app. I, fig. I.3.) Timber sales reached their lowest level as a result of
                               the injunctions in fiscal year 1994, when the agencies sold about
                               300 million board feet, or about 6 percent of the 5.0 billion board feet sold,
                               on average, each year during the 1980s. In comparison, the average annual
                               sale level of 746 million board feet projected by the Forest Service under
                               the plan equals about 15 percent of the average level sold during the 1980s.
                               Thus, there is less than a 9-percent difference between the predicted
                               annual sale level under the plan and the lowest level sold under the
                               injunctions when compared with the average level of timber sold during
                               the 1980s.

                               Furthermore, although the agencies do not believe timber sales will fall
                               below the projected annual average of 746 million board feet, they are
                               unlikely to increase. Since the plan was approved in 1994, 18 additional
                               species have been listed under the Endangered Species Act as endangered
                               or threatened in the area covered by the plan. In addition, recent policy
                               initiatives mean that federal lands are more likely to assume additional
                               responsibility for protecting threatened and endangered species. For
                               example, in exchange for commitments by nonfederal land owners to
                               protect threatened and endangered species, the Fish and Wildlife Service
                               and the National Marine Fisheries Service agreed that if measures beyond




                               Page 17                                       GAO/RCED-99-64 Ecosystem Planning
                             B-281830




                             those in the commitment were needed, they would be implemented first
                             on federal lands.


The Forest Service and       The volume of timber harvested from federal lands in the interior
BLM Have Overestimated       Columbia River basin declined from a peak of 3.3 billion board feet in
the Volume of Timber to Be   fiscal year 1987 to about 900 million board feet in fiscal year 1997.
                             According to the Forest Service and BLM, their preferred management
Harvested in the Interior    alternative in the original draft plan would have reversed this trend and led
Columbia River Basin         to average yearly harvests of about 1.7 billion board feet, thus providing
                             economic support for local communities. However, our review indicated
                             that for this plan, as for the Northwest Forest Plan, the agencies
                             overestimated the volume of timber to be harvested under the preferred
                             management alternative.

                             In estimating the volume of timber to be harvested under this alternative,
                             the Forest Service and BLM did not adequately take into account the
                             concerns of federal regulatory agencies, budgetary constraints, and the
                             potential impact of new information and events. For this, as for other
                             planning efforts, the Fish and Wildlife Service, the National Marine
                             Fisheries Service, and the Environmental Protection Agency expressed
                             concern that the original preferred alternative’s emphasis on active
                             management, including timber harvesting, would cause unacceptable
                             environmental consequences. In addition, as the Forest Service did in
                             developing some of the first forest plans, the two agencies developed the
                             plan’s management alternatives without reference to likely funding levels.
                             The agencies’ preferred alternative and estimate of timber output assumed
                             a significant increase in appropriated funds, which the agencies are not
                             likely to receive. Finally, new information and events, similar to those
                             likely to affect timber sales in the Pacific Northwest, could further reduce
                             timber sales. For instance, additional species could be listed; federal lands
                             in the basin could assume more responsibility for protecting wildlife and
                             fish and their habitats; additional federal lands could be set aside for
                             conservation; and the results of additional analyses could limit the acreage
                             available for multiple uses, including timber harvesting. For all of these
                             reasons, the volume of federal timber available for sale is likely to be
                             smaller than estimated under the agencies’ preferred management
                             alternative.


                             The Northwest Forest Plan is one of the first broad-scoped,
Conclusions                  ecosystem-based plans to be developed and implemented. Experience



                             Page 18                                      GAO/RCED-99-64 Ecosystem Planning
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with it has shown that an ecological approach to planning, coupled with
urgency, strong leadership, and clear objectives, can address many of the
long-standing deficiencies associated with planning for and managing
federal lands. The plan was developed in a timely and cost-effective
manner compared to other Forest Service planning efforts, and it contains
direction to be implemented by line managers. In addition, processes were
established to, among other things, (1) involve federal regulatory agencies
and the public in land management decision-making, (2) monitor the
effects of management decisions, (3) collect and use comparable
environmental data, and (4) adapt management to new information
obtained through monitoring and research.

However, the Northwest Forest Plan’s implementation has also shown that
correcting long-standing management deficiencies will not necessarily
lead to increases in the volume or quality of timber produced.
Requirements in federal land planning and environmental laws and their
judicial interpretations have sharply reduced federal timber sales from
their average level during the 1980s and are likely to keep them at about
the current level. These requirements have also reduced the quality of the
federal timber available for sale and have increased the costs for federal
agencies to operate the timber program and for private companies to
harvest the timber.

In developing a plan to manage federal lands in the interior Columbia
River basin, the Forest Service and BLM have also worked to overcome
some long-standing planning deficiencies. However, without the sense of
urgency that focused efforts to develop the Northwest Forest Plan, they
have not demonstrated the discipline and accountability for time and costs
needed to produce a timely decision on the management of a large and
complex region. Nor have the agencies focused their plan on those issues
that should be addressed at such a large scale. Finally, the agencies have
not provided enough detail about the possible outcomes of alternatives.

Ultimately, the Forest Service, BLM, the Congress, and other interested
parties must make some difficult decisions about managing federal lands
in the interior Columbia River basin. To do this, the agencies will need to
determine what issues are appropriately addressed in the interior
Columbia River basin plan and what issues are appropriately addressed at
smaller geographic scales. To complete the interior Columbia River basin
plan, the agencies will then need to (1) decide what steps land managers
must take to reach clearly defined objectives that they can be held
accountable for accomplishing, (2) determine how the distribution of



Page 19                                      GAO/RCED-99-64 Ecosystem Planning
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                      management activities over time among the various federal land units,
                      including those activities that produce goods and services such as timber,
                      will be affected by basinwide management decisions, and (3) ensure that
                      basinwide management decisions and estimates of outputs such as timber
                      fully take into account environmental laws and regulations, budgetary
                      constraints, and other variables.


                      We recommend that the Secretaries of Agriculture and the Interior provide
Recommendations to    additional direction to the interagency team responsible for developing the
the Secretaries of    plan for managing federal lands in the interior Columbia River basin.
Agriculture and the   Specifically, the Secretaries should direct that in revising the draft plan to
                      focus on those issues that are appropriately addressed basinwide, the
Interior              team should, (1) identify the ecological and socioeconomic trade-offs
                      among the different land management alternatives proposed to address
                      basinwide issues, including the likely effects of those alternatives on
                      ouputs such as timber across federal land units within the basin;
                      (2) provide land managers with clear direction for implementation along
                      with performance standards for holding them accountable; and (3) make
                      basinwide management decisions and estimates for outputs such as timber
                      taking full account of existing environmental laws and regulations,
                      budgetary constraints, and other variables.

                      Given that the agencies intend the interior Columbia River basin plan to
                      make management decisions for a limited number of basinwide issues and
                      that additional management plans focused on smaller geographic scales
                      will therefore be needed to provide additional management direction, we
                      also recommend that the Secretaries direct the the interagency team to
                      prepare for the Congress and the public details on how the additional
                      plans will be integrated with the interior Columbia River basin plan and to
                      estimate the time and resources that will be needed.


                      We provided copies of a draft of this report to the Forest Service, BLM, the
Agency Comments       Northwest Forest Plan’s Regional Interagency Executive Committee, and
                      the Interior Columbia Basin Ecosystem Management Project Executive
                      Steering Committee for review and comment. Because the two ecosystem
                      management plans are interagency efforts, the Regional Interagency
                      Executive Committee and the Executive Steering Committee provided
                      comments with the concurrence of the Forest Service and BLM.




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For those sections of the report dealing with the Northwest Forest Plan,
the Regional Interagency Executive Committee generally agreed with our
findings and conclusions. However, in its comments, the Committee
emphasized a point that merits further discussion and analysis. The
Committee commented that our emphasis on the timber program should
be matched with an equal emphasis on other components of the plan, such
as interagency cooperation and the strategy intended to restore and
maintain the ecological health of watersheds. We discussed in detail many
aspects of the Northwest Forest Plan, including its correction of
long-standing management deficiencies that we previously identified, such
as a lack of interagency cooperation. However, many of the intended
benefits of the plan—especially those associated with the long-term and
overall health of federal lands and resources—will not be realized for
many years, and accurate measures to gauge longer-term improvements
have yet to be developed. Therefore, we did not make any changes to the
report.

The Committee’s comments and our responses to them are found in
appendix III of this report. The Committee also provided several
clarifications to the report, which we incorporated where appropriate.

For those sections of the report dealing with the Interior Columbia Basin
Ecosystem Management Project, the Executive Steering Committee
generally agreed with our findings and recommendations. However, in its
comments, the Committee emphasized several points. First, the
Committee said that we did not adequately present differences in the
scope and approaches of the interior Columbia River basin project and the
Northwest Forest Plan that contributed to the relative differences in the
time and costs to develop them. We agree that these differences are
important, and we revised the draft to highlight them. More importantly, it
was not our intent to compare the costs of the interior Columbia River
basin project and of the Northwest Forest Plan, but to compare the actual
time and costs of the project to initial estimates made by the agencies.
Second, the Committee provided us with a time line for completing the
project. As a result, we updated the report and deleted the first part of our
draft recommendation that the agencies develop a time line for completing
the project. Third, with respect to our recommendation that the agencies
identify trade-offs between management alternatives, the Committee
emphasized that there are limits to how specific they can be about the
effects of management decisions at the basinwide scale. We acknowledge
these limits and revised our recommendation to emphasize that it applies
only to those issues that the agencies determine should be addressed at



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the basinwide scale. Fourth, the Committee said that the supplemental
draft environmental impact statement would address our draft
recommendation that the agencies clearly state the impact of
environmental laws, regulations, budgetary constraints, and other
variables on timber sales volumes. However, because actions related to
this recommendation are not yet complete, we did not make any changes
to it.

We added our second recommendation on the time and resources needed
to complete the planning process for federal lands in the basin after the
agencies reviewed our draft report. We believe that the recommendation is
warranted, given the limits on a basinwide decision and the need for
additional decisions at a smaller scale.

The Committee’s other comments and our responses to them are found in
appendix IV of this report. The Committee also provided several
clarifications to the report, which we incorporated where appropriate.

We conducted our work from September 1997 through March 1999 in
accordance with generally accepted government auditing standards.
Appendix V explains our methodology in detail.

We are sending copies of this report to Senator Bingaman, Ranking
Minority Member, Senate Committee on Energy and Natural Resources;
Representative George Miller, Ranking Minority Member, House
Committee on Resources; and Representative Charles Stenholm, Ranking
Minority Member, House Committee on Agriculture. We are also sending
copies of this report to the Honorable Dan Glickman, Secretary of
Agriculture; the Honorable Bruce Babbitt, Secretary of the Interior; the
Honorable Mike Dombeck, Chief of the Forest Service; the Honorable Tom
Fry, Acting Director of the Bureau of Land Management; and other
interested parties. We will make copies available to others on request.




Page 22                                    GAO/RCED-99-64 Ecosystem Planning
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If you or your staff have any questions about this report, please call me at
(202) 512-3841. Major contributors to this report are listed in appendix VI.




Barry T. Hill
Associate Director, Energy,
  Resources, and Science Issues




Page 23                                      GAO/RCED-99-64 Ecosystem Planning
Contents



Letter                                                                                            1


Appendix I                                                                                       28
                        The Northwest Forest Plan Was Developed to Resolve a Conflict            29
Implementation of the     Between Consumption and Conservation
Northwest Forest Plan   Development and Implementation of the Northwest Forest Plan              31
                          Has Addressed Many Long-Standing Planning Deficiencies
Addresses Many          The Northwest Forest Plan Provides a Wide Range of Ecosystem             40
Long-Standing             Benefits
Deficiencies but        Timber Volume and Quality Have Declined and Costs Have                   42
                          Increased Under the Northwest Forest Plan
Cannot Provide          The Quantity and Quality of Federal Timber From the Pacific              49
Historic Levels of        Northwest Will Remain Low and Unit Costs Will Remain High
Timber
Appendix II                                                                                      56
                        A Multistep Process Is Being Used to Develop a Management                57
Deficiencies in           Plan for the Interior Columbia River Basin
Developing a            Development of the Plan Has Addressed Some Long-Standing                 62
                          Decision-Making Deficiencies and Accomplished Some of the
Management Plan for       Steps Necessary for Ecosystem Management
the Interior Columbia   Delays and Increased Costs Can Be Traced Primarily to the                66
River Basin Have          Magnitude of the Effort and the Failure to Present an Adequate
                          Draft Plan
Resulted in Delays      The Quantity and Quality of Federal Timber in the Interior               74
and Unfulfilled           Columbia River Basin Will Continue to Decline
Promises
Appendix III                                                                                     81

Comments From the
Northwest Forest
Plan’s Regional
Interagency Executive
Committee




                        Page 24                                    GAO/RCED-99-64 Ecosystem Planning
                        Contents




Appendix IV                                                                                     84

Comments From the
Interior Columbia
Basin Ecosystem
Management Project’s
Executive Steering
Committee
Appendix V                                                                                      89

Objectives, Scope,
and Methodology
Appendix VI                                                                                     91

Major Contributors to
This Report
Table                   Table II.1: Time Line of Major Events in Developing a                   58
                         Management Plan for the Interior Columbia River Basin

Figures                 Figure 1: The Geographical Boundaries of the Northwest Forest            7
                          Plan and of the Interior Columbia Basin Ecosystem Management
                          Project
                        Figure 2: Forest Clusters in Lands Within the Boundaries of the         14
                          Interior Columbia River Basin Project Area
                        Figure I.1: Practical Steps to Implement Ecosystem Management           33
                        Figure I.2: Adaptive Management Cycle                                   39
                        Figure I.3: Volume of Timber Sold From Federal Lands in the             43
                          Northwest Forest Plan Area, Fiscal Years 1980-98
                        Figure I.4: Sawtimber as a Percentage of Total Volume of Timber         45
                          Harvested From Forest Service Lands in the Pacific Northwest,
                          Fiscal Years 1980-98
                        Figure I.5: Percentage of High-Grade Douglas Fir Sold on Federal        46
                          Lands in Western Oregon and Western Washington, Fiscal Years
                          1980-97




                        Page 25                                   GAO/RCED-99-64 Ecosystem Planning
Contents




Figure I.6: Cost Per Thousand Board Feet to Operate the Forest           47
  Service’s Timber Program in the Pacific Northwest, Fiscal Years
  1992-97
Figure I.7: Cost Per Thousand Board Feet to Log in National              48
  Forests in Western Washington and Western Oregon, Fiscal Years
  1980-97
Figure I.8: Timber Volumes Harvested From Forest Service Lands           52
  in the Pacific Northwest to Meet Commodity and Stewardship
  Objectives, Fiscal Years 1992-98
Figure II.1: Forest Clusters in Lands Within the Boundaries of the       71
  Interior Columbia River Basin Project Area
Figure II.2: Volume of Timber Harvested From Forest Service and          75
  BLM Units Entirely Within the Interior Columbia River Basin,
  Fiscal Years 1985-97




Abbreviations

BLM        Bureau of Land Management
GAO        General Accounting Office


Page 26                                    GAO/RCED-99-64 Ecosystem Planning
Page 27   GAO/RCED-99-64 Ecosystem Planning
Appendix I

Implementation of the Northwest Forest
Plan Addresses Many Long-Standing
Deficiencies but Cannot Provide Historic
Levels of Timber
               Experience with the Northwest Forest Plan14 has shown that an ecological
               approach to planning, coupled with a sense of urgency, strong leadership,
               and clear objectives, can address many of the long-standing deficiencies
               we have found associated with planning for and managing federal lands.
               Compared to other Forest Service plans, this one was developed
               expeditiously and cost-effectively—it took about a year and cost about
               $3.5 million—and contains clear direction to field managers. In addition,
               processes were established to, among other things, (1) involve federal
               regulatory agencies and the public in land management decision-making,
               (2) collect and use comparable environmental data, and (3) adapt
               management to new information obtained through monitoring and
               research.

               The Northwest Forest Plan satisfied the courts so that they were willing to
               lift the injunctions that had barred the Forest Service and BLM from selling
               timber in northern spotted owl habitat. However, the plan called for an
               81-percent reduction in the volume of timber sold, compared with the
               volume sold in the 1980s, and the agencies have subsequently reduced this
               estimate. Additionally, the quality of the timber sold relative to what was
               sold in the 1980s has declined, and the agencies’ costs of providing timber
               and loggers’ costs of harvesting it have increased significantly on a
               per-unit basis.15 Moreover, the overall decline in the volume and quality of
               timber sold from federal lands in the Pacific Northwest is unlikely to be
               reversed, given existing laws, including the Endangered Species Act, and
               their implementing regulations and judicial interpretations. As a result, the
               increases in the agencies’ and loggers’ per-unit costs that were linked to
               this decline will also not be reversed.




               14
                 We use the term “Northwest Forest Plan” to include a group of documents that led to a formal
               interagency plan to manage federal lands in the Pacific Northwest.
               15
                Costs are measured in dollars per board foot. A board foot is a measure of wood volume equal to an
               unfinished board 1 foot long, 1 foot wide, and 1 inch thick.



               Page 28                                                     GAO/RCED-99-64 Ecosystem Planning
                        Appendix I
                        Implementation of the Northwest Forest
                        Plan Addresses Many Long-Standing
                        Deficiencies but Cannot Provide Historic
                        Levels of Timber




                        In the late 1980s and early 1990s, timber sales on lands in northern spotted
The Northwest Forest    owl habitat managed by the Forest Service and BLM in the Pacific
Plan Was Developed      Northwest were brought to a virtual halt by federal court injunctions. In
to Resolve a Conflict   various rulings, the federal courts enjoined the agencies from selling
                        timber until they addressed issues related to protecting the habitat of this
Between                 owl,16 which was listed as threatened under the Endangered Species Act.
Consumption and         In response, the President directed his administration to develop a plan
                        that would (1) satisfy the courts so they would lift the injunctions,
Conservation            (2) protect the environment, and (3) help stabilize the regional economy.
                        The result was the Northwest Forest Plan.

                        The Northwest Forest Plan includes two components that focus on forest
                        management and economic development. The first component includes a
                        regional land management plan that provides management direction for
                        the 22.3 million acres of land managed by the Forest Service and BLM in the
                        range of the northern spotted owl.17 The regional plan’s development
                        began with a scientific assessment by six federal agencies that described
                        current and desired ecological conditions within the owl’s range.18 The
                        assessment also included 10 alternatives for managing the federal lands.
                        Each alternative depicted a different mix of management guidance to
                        protect habitat for owls and other species while also providing for other
                        uses of the forests, including timber harvesting. The potential
                        environmental and economic effects of each alternative were examined
                        and compared in a draft supplemental environmental impact statement,19
                        and a preferred alternative was chosen by the President for further
                        examination in a final supplemental environmental impact statement.20 A



                        16
                         See, for example, Seattle Audubon Society v. Evans, 771 F. Supp. 1081 (W.D. Wash.), aff’d, 952 F.2d
                        297 (9th Cir. 1991) and Seattle Audubon Society v. Moseley, 798 F. Supp. 1484 (W.D. Wash. 1992), aff’d
                        sub nom., Seattle Audubon Society v. Espy, 998 F.2d 699 (9th Cir. 1993).
                        17
                          An additional 2.2 million acres of federal land within the range of the northern spotted owl are
                        managed primarily by the National Park Service and are not subject to the management direction of
                        the Northwest Forest Plan.
                        18
                          Forest Ecosystem Management: An Ecological, Economic, and Social Assessment, Report of the
                        Forest Ecosystem Management Assessment Team (FEMAT)(July 1993). The six federal agencies were
                        the Forest Service, BLM, the Fish and Wildlife Service, the National Park Service, the National Marine
                        Fisheries Service, and the Environmental Protection Agency.
                        19
                         Draft Supplemental Environmental Impact Statement on Management of Habitat for
                        Late-Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted
                        Owl, Forest Service and BLM (July 1993).
                        20
                         Final Supplemental Environmental Impact Statement on Management of Habitat for
                        Late-Successional and Old-Growth Forest Related Species Within the Range of the Northern Spotted
                        Owl, Vols. I and II, Forest Service and BLM (Feb. 1994).



                        Page 29                                                      GAO/RCED-99-64 Ecosystem Planning
Appendix I
Implementation of the Northwest Forest
Plan Addresses Many Long-Standing
Deficiencies but Cannot Provide Historic
Levels of Timber




record of decision,21 signed by the Secretaries of Agriculture and the
Interior in April 1994, selected one land management option and amended
the land management plans for 19 national forests and 7 BLM districts in
the Pacific Northwest22 on the basis of the option.

The land management plan allocated federal lands into seven categories,
including lands set aside by the agencies or withdrawn by the Congress for
specific uses, such as recreation and wilderness; lands reserved to protect
habitat for owls and other species; and “matrix lands” (those available for
multiple uses, including timber harvesting). Lands in each category are to
be managed in accordance with requirements (standards and guidelines)
established by the record of decision. These include allowable and
prohibited activities and other guidance. For example, timber harvesting
to reduce the density of trees is allowed on lands reserved to protect owl
habitat, but generally not in stands over 80 years old. Of the 24.5 million
acres of land covered by the Northwest Forest Plan, 78 percent were
either set aside for specific uses, such as recreation, or reserved to protect
habitat for owls and other species. The remaining 22 percent were
available for multiple uses, including timber harvesting.

In addition, the regional plan recognizes that a one-size-fits-all approach
may not be appropriate and allows for the requirements to be tailored to
fit the ecological conditions specific to each of 12 geographic provinces
(e.g., old-growth rain forests in western Washington and drier forests in
northern California). The plan also includes an aquatic conservation
strategy intended to restore and maintain the ecological health of
watersheds and the aquatic ecosystems within them. The strategy, among
other things, requires the Forest Service and BLM to (1) analyze conditions
in watersheds identified as key to protecting fish at risk of becoming
extinct and to providing high-quality water before beginning management
activities, such as timber harvesting, on either reserved or matrix lands
and (2) eventually conduct an analysis of conditions in all watersheds on
federal lands as a basis for ecosystem planning and management.

The second component of the Northwest Forest Plan is an economic
assistance program aimed at helping the region adjust to changes in
federal forest management. The Environmental Protection Agency, the
Small Business Administration, and agencies within five federal

21
 Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning
Documents Within the Range of the Northern Spotted Owl and Standards and Guidelines for
Management of Habitat for Late-Successional and Old-Growth Forest Related Species Within the
Range of the Northern Spotted Owl, Forest Service and BLM (Apr. 1994).
22
 GAO uses the term Pacific Northwest to describe lands in northern California, western Oregon, and
western Washington.


Page 30                                                    GAO/RCED-99-64 Ecosystem Planning
                           Appendix I
                           Implementation of the Northwest Forest
                           Plan Addresses Many Long-Standing
                           Deficiencies but Cannot Provide Historic
                           Levels of Timber




                           departments—Agriculture, Housing and Urban Development, Labor,
                           Commerce, and the Interior—are to provide $1.2 billion in funding to
                           communities, tribes, businesses, and individuals to help them make the
                           transition from dependency on federal timber to other employment
                           opportunities.23 Additionally, the Corps of Engineers participated in both
                           the ecological and economic components of the Northwest Forest Plan.


                           An ecosystem-based regional land management plan has helped federal
Development and            land management agencies reconcile differences in the geographic areas
Implementation of the      that must be considered in reaching decisions under different planning
Northwest Forest Plan      and environmental laws. Additionally, in developing and implementing the
                           plan, the agencies addressed long-standing deficiencies in, and barriers to,
Has Addressed Many         timely, orderly, and cost-effective land management planning. These
Long-Standing              deficiencies include a lack of (1) accountability for the time and costs in
                           developing plans, (2) adequate involvement in the decision-making
Planning Deficiencies      process by other federal agencies and the public, (3) comparable
                           environmental and scientific data among agencies, and (4) monitoring to
                           determine the effects of past management decisions.24


Development of the         Because the boundaries of administrative units and natural systems are
Northwest Forest Plan      frequently different, federal land management plans have often considered
Followed the Practical     effects only on those portions of natural systems or portions of their
                           components—such as the habitats of threatened and endangered
Steps in Implementing an   species—that exist within the boundaries of the administrative units
Ecosystem Approach to      covered by the plans. Because the habitat of the northern spotted owl
Federal Land Management    extends over many Forest Service and BLM administrative units, a new
                           approach was needed. The agencies developed the Northwest Forest Plan
                           using an approach consistent with the practical steps we identified to
                           implement ecosystem management.25 (See fig. I.1).

                           The agencies accomplished the first step when they delineated an
                           ecosystem that matched the geographic scope of the issue at hand, namely
                           the habitat range of the northern spotted owl, without regard to

                           23
                             The economic assistance program is not evaluated in this report.
                           24
                             Ecosystem Management: Additional Actions Needed to Adequately Test a Promising Approach
                           (GAO/RCED-94-111, Aug. 16, 1994), Forest Service Decision-Making: A Framework for Improving
                           Performance (GAO/RCED-97-71, Apr. 29, 1997), and Tongass National Forest: Lack of Accountability
                           for Time and Costs Has Delayed Forest Plan Revision (GAO/T-RCED-97-153, Apr. 29, 1997).
                           25
                            See, for example, Ecosystem Management: Additional Actions Needed to Adequately Test a
                           Promising Approach (GAO/RCED-94-111, Aug. 16, 1994) and Forest Service Decision-Making: A
                           Framework for Improving Performance (GAO/RCED-97-71, Apr. 29, 1997).



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administrative boundaries. This allowed the agencies to analyze ecological
issues at an appropriate geographic scale, and the resulting plan
establishes a consistent boundary for management. Other issues, such as
providing high-quality water, are addressed at smaller, more appropriate,
geographic scales.




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Figure I.1: Practical Steps to
Implement Ecosystem Management




                                 Source: Ecosystem Management: Additional Actions Needed to Adequately Test a Promising
                                 Approach (GAO/RCED-94-111, Aug. 16, 1994).




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                              Under the second step, six federal agencies performed a scientific
                              assessment and also described current and desired ecological conditions
                              within the owl’s range. The desired ecological conditions represent the
                              minimum level of integrity and functioning—or threshold—needed to
                              maintain or restore a healthy ecosystem.

                              Under the third step, the agencies identified in the plan the types of
                              activities that are prohibited in each of the seven land categories. They
                              also described the conditions—sometimes referred to as desired future
                              conditions—that should occur in each category.

                              To accomplish the fourth step, the plan requires a continuous monitoring
                              program, the results of which could lead to changes in management
                              direction. In addition, the plan allocated 6 percent of the lands to 10
                              adaptive management areas where the agencies can develop and test
                              innovative land management approaches to achieve ecological and
                              economic goals and revise or amend the plan accordingly. For example,
                              one area is developing and testing approaches to integrate timber
                              production with the restoration and maintenance of riparian habitat.


After an Initial Delay, the   Initially, even after federal courts enjoined the agencies from selling
Regional Plan Was             timber, the Forest Service and BLM were slow to develop plans adequate to
Developed in a Timely and     protect the owl until the President became involved. Fueled by a sense of
                              urgency related to the court injunctions, as well as strong leadership
Cost-Effective Manner         within the administration and clear objectives, six federal agencies
                              developed a regional land management plan in a timely and cost-effective
                              manner.

                              In October 1989, the Congress directed the Forest Service to develop a
                              plan to conserve the species by September 30, 1990.26 The agency failed to
                              produce a plan by the deadline. In May 1991, a federal district court judge
                              enjoined the Forest Service from selling timber in owl habitat, noting that
                              the agency’s failure to develop a conservation plan exemplified a
                              “deliberate and systematic” refusal by the Forest Service and the Fish
                              and Wildlife Service to comply with the laws protecting wildlife. The court
                              ordered that a plan be completed by March 1992. In July 1992, the judge
                              rejected the plan developed by the Forest Service and issued another
                              injunction barring the agency from selling timber in owl habitat until it
                              made changes to the plan to address, among other things, the viability of

                              26
                               Department of the Interior and Related Agencies Appropriations Act for Fiscal Year 1990, P.L.
                              101-121, 103 Stat. 747.



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                           other old-growth-dependent species. The court ordered that a plan be
                           completed by August 1993. Similarly, in February 1992, another federal
                           district court judge enjoined BLM from selling timber in owl habitat until it
                           analyzed the effects of logging in the species’ habitat.27

                           To end the impasse, the President convened a forest conference in
                           Portland, Oregon, in April 1993, at which he directed his cabinet to
                           develop the required plan. The scientific assessment by the six federal
                           agencies that described current and desired ecological conditions within
                           the owl’s range was completed in about 3 months. In April 1994, the
                           departments of Agriculture and the Interior approved the Northwest
                           Forest Plan, completing their efforts a year after the forest conference, at a
                           cost of about $3.5 million. In comparison, the Forest Service spent about
                           10 years and $13 million revising the land management plan for the
                           Tongass National Forest in southeastern Alaska.28

                           Key differences between the process used to develop the Northwest
                           Forest Plan and the process previously used by the Forest Service to
                           amend or revise forest plans such as the one for the Tongass National
                           Forest contributed to the plan’s timely and cost-effective development.
                           These differences include (1) the sense of urgency related to the court
                           injunctions, (2) the strong leadership displayed by the President and the
                           involvement of high-ranking administration officials in developing the
                           plan, and (3) clear objectives based in part on the need to preserve the
                           habitat of the northern spotted owl and other old-growth-dependent
                           species.


Interagency Coordination   Before the Northwest Forest Plan was developed, a lack of coordination
Has Improved Under the     among federal agencies had been identified as a major cause of the
Plan                       impasse that existed in the region. Virtually all parties involved in the
                           conflict over the use of late-successional forests29 agreed that federal
                           agencies would need to work together to improve coordination and
                           communication.

                           Interagency coordination in the development of the land management plan
                           began with the scientific assessment by the Forest Service, BLM, the Fish

                           27
                             Portland Audubon Society v. Lujan, 784 F. Supp 786 (D. Or. 1992).
                           28
                            Tongass National Forest: Lack of Accountability for Time and Costs Has Delayed Forest Plan
                           Revision (GAO/T-RCED-97-153, Apr. 29, 1997).
                           29
                             Late-successional forests contain trees that are at least 80 years old and can include old-growth
                           forests made up of trees that are at least 180 to 220 years old.



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                           and Wildlife Service, the National Park Service, the National Marine
                           Fisheries Service, and the Environmental Protection Agency. Additionally,
                           these six agencies—together with the U.S. Army Corps of Engineers;
                           Agriculture’s Natural Resources Conservation Service; and Interior’s
                           Bureau of Indian Affairs, U.S. Geological Survey, and National Biological
                           Service30—developed a guide intended to standardize the process for
                           conducting watershed analyses under the plan’s aquatic conservation
                           strategy.31 The guide provides a systematic way to understand and
                           organize ecosystem information and to estimate the effects of
                           management activities. The guide has been credited with increasing the
                           consistency with which a watershed’s condition is assessed.

                           Also, in 1995, four agencies—the Forest Service, BLM, the Fish and Wildlife
                           Service, and the National Marine Fisheries Service—developed a
                           streamlined Endangered Species Act consultation process. According to
                           agency officials, the process has generally decreased the time and
                           resources needed for consultation on a project in the area covered by the
                           plan. However, they noted that further improvements are still needed.

                           Finally, the Northwest Forest Plan created interagency committees and an
                           office to bring together officials from various agencies to help establish
                           policy and to provide scientific and research information to line managers.
                           For example, the Regional Ecosystem Office was established to support a
                           group of senior regional officials—the Regional Interagency Executive
                           Committee—in implementing the Northwest Forest Plan. Members of the
                           Regional Ecosystem Office are detailed from each of the federal agencies
                           responsible for forest management in the region. The office is a focal point
                           for scientific, technical, administrative, and policy expertise. According to
                           the National Marine Fisheries Service, the Northwest Forest Plan’s
                           interagency agreements have resulted in “substantial staff efficiencies” and
                           have helped to defuse “the friction that previously resulted from
                           conflicting agency mandates.”


Opportunities for Public   Virtually all parties involved in the conflict agreed that states, tribes, local
Participation Have         governments, and the public should have a better opportunity to share
Improved Under the Plan    their concerns, issues, and ideas directly with federal decisionmakers on
                           how the forests should be managed. Because of the urgent need to resolve

                           30
                            In 1996, the National Biological Service became the Biological Resources Division of the U.S.
                           Geological Survey.
                           31
                             Ecosystem Analysis at the Watershed Scale: Federal Guide for Watershed Analysis, the Regional
                           Interagency Executive Committee and the Intergovernmental Advisory Committee, Portland, Ore.
                           (Aug. 1995). In addition to federal agencies, tribal governments, and the states of California, Oregon,
                           and Washington and associated counties helped develop the guide.


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                           the court injunctions, the public was not directly involved in the scientific
                           assessment that began the process to develop the Northwest Forest Plan.
                           However, public comments were requested, and over 100,000 were
                           received, on the draft supplemental environmental impact statement that
                           compared the potential environmental and economic impact of each of the
                           10 management alternatives included in the assessment.

                           Since the plan was approved, federal agencies have shown a willingness to
                           involve nonfederal parties in their decision-making and to come together
                           with these parties to discuss, understand, and address their concerns.
                           Toward this end, 12 Provincial Advisory Committees were created—one
                           for each of the geographic provinces identified in the plan—to involve
                           local governments, tribes, and the public in managing the region’s forests.
                           Members of these committees may include representatives from state,
                           county, and tribal governments; the timber industry; environmental
                           groups; recreation and tourism organizations; and the public at large, as
                           well as officials from the federal agencies. Among other things, these
                           committees participated in areawide reviews in fiscal years 1996, 1997, and
                           1998 to determine whether timber sales, forest roads, and restoration
                           activities were in compliance with the plan’s requirements
                           (implementation monitoring).

                           Nonfederal parties have also been involved in analyzing watershed
                           conditions on Forest Service and BLM lands. For example, the municipal
                           watershed for the city of Sandy, Oregon, was included in a watershed
                           analysis conducted by the Forest Service in conjunction with BLM, the Fish
                           and Wildlife Service, and the city of Sandy. After completing the watershed
                           analysis, the Forest Service and BLM entered into a formal memorandum of
                           understanding with the city to maintain or improve the quality and
                           quantity of water from the watershed.


Efforts Are Under Way to   According to a recent Council on Environmental Quality report,32 the team
Collect and Use            that prepared the scientific assessment found that the agencies’ history of
Comparable                 dealing with environmental issues on a small scale, such as individual
                           sites, left the agencies with data for the region that were inconsistent from
Environmental Data         place to place and difficult to use with precision for analyzing natural
                           resource issues at larger scales. Since the Northwest Forest Plan was
                           approved, progress has been made in standardizing the data to be
                           collected and in mapping federal lands on a consistent scale across the

                           32
                              J. Pipkin, The Northwest Forest Plan Revisited (Sept. 1998). Mr. Pipkin is the Director of the Office of
                           Policy Analysis at the Department of the Interior. The report was commissioned by the Council on
                           Environmental Quality.



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                            region. For example, Forest Service and BLM data on vegetation across the
                            region are being combined into one map. Once the map is completed, the
                            agencies will be able to update the map with new information as the
                            vegetation changes over time. According to a BLM official, the agencies will
                            also use the map as a basis for other maps, such as a map of northern
                            spotted owl habitat.

                            In addition, both the Forest Service and BLM are accumulating data across
                            large areas within the region and testing the data to see if they are useful
                            to land managers for decision-making. For example, the Forest Service is
                            developing a data set for an area in the Coast mountain range in Oregon
                            that includes information on forest cover and landowners’ behavior for
                            both federal and nonfederal lands. Using the data set, the agency can
                            project the effect of proposed land management decisions over time to
                            predict what the landscape will look like up to 100 years in the future.

                            BLM  has compiled a data set for the Umpqua River basin in Oregon and
                            may use it for long-term planning in the area. Agency officials showed us
                            how the data can be used to identify locations where land management
                            activities, such as timber harvesting, will produce the smallest impact on
                            the landscape. Officials from the Fish and Wildlife Service, the National
                            Marine Fisheries Service, and the Environmental Protection Agency
                            support BLM’s use of the data set for the long-term planning of projects,
                            stating that planning based on data across a large area will help them in
                            reaching decisions about the impact of BLM’s projects on threatened and
                            endangered species and on water quality.


The Northwest Forest Plan   Monitoring is an essential component of natural resource management
Requires Regional           because it provides information on the relative success of management
Monitoring and Adaptive     strategies in achieving desired ecological conditions and management
                            objectives. Monitoring is linked to the process of adaptive management—a
Management                  continuous cycle of planning, acting, monitoring, and evaluating—that can
                            lead to continuous improvement in land management. (See fig. I.2.)




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Figure I.2: Adaptive Management Cycle




                                        Source: Adapted from Forest Ecosystem Management: An Ecological, Economic, and Social
                                        Assessment, Report of the Forest Ecosystem Management Assessment Team (July 1993).




                                        The Northwest Forest Plan requires the agencies to monitor their land
                                        management activities to determine whether (1) the plan’s standards and
                                        guidelines are being followed (implementation monitoring), (2) they are
                                        achieving the plan’s desired results (effectiveness monitoring), and (3) the
                                        plan’s underlying assumptions about the activities are sound (validation
                                        monitoring). The agencies have completed 3 years of implementation
                                        monitoring and are beginning to do effectiveness monitoring. They have
                                        not developed a plan for validation monitoring, but agency officials told us
                                        that some validation monitoring is being performed.




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                            The Northwest Forest Plan was the first broad-scale attempt to apply an
The Northwest Forest        ecosystem approach to resolving natural resource issues. It not only
Plan Provides a Wide        caused the injunctions against federal timber sales to be lifted but also
Range of Ecosystem          provided guidance on protecting the environment across the ecosystem,
                            including areas critical to water quality. As a result, the plan benefits other
Benefits                    federal agencies—such as the National Marine Fisheries Service, the
                            Environmental Protection Agency, and the National Park Service—that are
                            not bound by the plan’s standards and guidelines.


The Northwest Forest Plan   According to a federal judge, the agencies creating the Northwest Forest
Provides Management         Plan could not comply with environmental laws without planning on an
Direction for More Than     ecosystem basis. Although the original controversy focused on protecting
                            northern spotted owl habitat, the plan contains provisions to protect other
Protecting Northern         species and to restore and maintain watersheds because these activities
Spotted Owl Habitat         are important to the overall health of the ecosystem.

                            To meet the agencies’ obligations under the Endangered Species Act, the
                            plan designated over 10 million acres, or more than 40 percent of the
                            federal land in the plan area, as reserves to conserve and create habitat for
                            listed species. This area also provides habitat for many other species that
                            are not listed. The plan also requires the agencies to gather data on the
                            habitat and location of over 400 species in the plan area that are not listed
                            but about which little is known. If the agencies find rare and sensitive
                            species among this group, they may decide that management actions are
                            needed to keep them from becoming threatened or endangered.

                            To maintain and restore the ecological health of watersheds and the
                            aquatic environment, the plan established an aquatic conservation
                            strategy. The strategy contains four components: (1) creating reserves to
                            protect lands along streams; (2) designating “key” watersheds that
                            provide high-quality water and habitat for at-risk fish species;
                            (3) performing ecological analyses of key and other watersheds to aid in
                            planning management activities; and (4) restoring the health of watersheds
                            and the aquatic environment.

                            To implement the aquatic conservation strategy, the Northwest Forest
                            Plan set aside over 2.6 million acres as riparian reserves. The plan also
                            designated over 9 million acres as key watersheds in which no major
                            activity—such as timber harvesting—can take place until an ecological
                            analysis of the watershed has been completed. The agencies have made
                            progress in completing watershed analyses for both key and other



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                             watersheds. As of 1997, the Forest Service had completed 234 watershed
                             analyses of the 480 it planned to complete and BLM had completed 70
                             analyses, covering about 70 percent of its lands in the plan area. Finally,
                             the agencies have performed watershed restoration activities. For
                             example, from 1994 to 1997, the Forest Service completed riparian
                             restoration projects, such as planting vegetation, on almost 16,000 acres.


The Northwest Forest Plan    Although the Northwest Forest Plan’s management direction is specific to
Provides Benefits to Other   the Forest Service’s and BLM’s land management activities, other federal
Agencies Not Directly        agencies report that they have benefited from the plan in ways that will
                             help them accomplish their missions. For example, according to the
Affected by the Plan’s       National Marine Fisheries Service, it has successfully applied the science
Management Direction         from the plan’s scientific assessment in a variety of nonfederal habitat
                             conservation efforts in various parts of the country. The National Park
                             Service pointed out that four of its parks are adjacent to late-successional
                             reserves designated by the plan and that the reserves will contribute to the
                             parks’ biological diversity, wildlife viability, and ecological integrity.
                             Officials from the Environmental Protection Agency have also identified
                             ways in which the plan has helped the agency carry out its environmental
                             protection missions. For example, riparian reserve stream buffers created
                             by the plan have enhanced source water protection—a responsibility for
                             the agency under the Safe Drinking Water Act. The Environmental
                             Protection Agency has also been able to share watershed data gathered
                             under the plan, thereby reducing the burden of acquiring and managing it.

                             All three agencies have indicated that the interagency collaboration that
                             occurred during the development of the Northwest Forest Plan has
                             continued beyond the plan’s implementation. For example, according to
                             the National Marine Fisheries Service, the agency has colocated a field
                             office with other federal agencies, resulting in improved working
                             relationships and enhanced resource protection. An Environmental
                             Protection Agency official noted that the success of the interagency
                             collaboration on the Northwest Forest Plan contributed to collaboration
                             on other efforts, such as the interior Columbia River basin planning effort.




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                            The Northwest Forest Plan satisfied the courts so that they were willing to
Timber Volume and           lift the injunctions barring the Forest Service and BLM from selling timber
Quality Have Declined       in northern spotted owl habitat. The plan satisfied the requirements of the
and Costs Have              Endangered Species Act and the National Forest Management Act and its
                            implementing regulations. It also provided assurance that the processes
Increased Under the         and functions of late-successional and old-growth forest ecosystems, as
Northwest Forest Plan       well as of the riparian habitat essential for many aquatic and terrestrial
                            species, would be maintained and restored. In addition, the plan provided
                            guidance to federal agencies on protecting the environment.

                            However, to comply with the statutory requirements incorporated in the
                            plan, the Forest Service and BLM have had to, among other things,
                            (1) significantly reduce the volume and commercial quality of the timber
                            sold and (2) significantly reduce the use of clear-cutting as the preferred
                            method to harvest timber.33 As a result, the agencies’ costs to provide
                            timber and loggers’ costs to harvest it have significantly increased on a
                            per-unit basis.


The Volume of Timber Sold   The fertile soils of the Pacific Northwest provide some of the best
Has Decreased               conditions in the United States for growing trees, and federal lands in the
Significantly               region are recognized as some of the nation’s most productive and
                            valuable commercial forest properties. From fiscal year 1980 through
                            fiscal year 1989—the last year before federal timber sales in northern
                            spotted owl habitat were barred by court-ordered injunctions—the Forest
                            Service and BLM sold an average of 5 billion board feet of timber per year
                            from the lands bounded by the plan.34 During the first 4 full fiscal years of
                            the plan—fiscal years 1995-98—timber sales from federal lands bound by
                            the plan averaged about 687 million board feet per year, or less than
                            14 percent of the volume sold during the 1980s. (See fig. I.3.)




                            33
                              Clear-cutting is a harvesting method that removes all trees from a timber-harvesting site at one time.
                            34
                             Different methods for estimating board feet yield different estimates. To account for these
                            differences, we have converted all board feet volumes into a standard measure using the method of
                            estimation employed by the Forest Service’s Northwest Region.



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Figure I.3: Volume of Timber Sold
From Federal Lands in the Northwest
Forest Plan Area, Fiscal Years 1980-98




                                         Sources: Forest Service and BLM.




                                         The authors of the Northwest Forest Plan concluded in an environmental
                                         impact statement that the volume of timber sold from federal lands in the
                                         Pacific Northwest during the 1980s could not be sustained. The plan’s
                                         scientific assessment concluded that the situation in the Pacific Northwest
                                         had reached a point where satisfying the requirements of the Endangered
                                         Species Act and other applicable laws required a course of action that
                                         would substantially reduce the availability of timber from federal forests in
                                         the region inhabited by the northern spotted owl. As a result, the
                                         Northwest Forest Plan imposes management restrictions on
                                         late-successional timber stands and other ecologically important areas,
                                         resulting in a sharp decline in the projected volume of timber available for
                                         sale from federal lands in the Pacific Northwest. The plan anticipated that
                                         the volume of timber available for sale over the first 10 years of the




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                         plan—called the probable sales quantity—would be about 9.58 billion
                         board feet, or an average of about 958 million board feet per year.35


The Quality of Timber    Not only has the volume of timber sold from federal lands in the Pacific
Harvested From Federal   Northwest declined but so also has the quality of the timber harvested.
Lands in the Pacific     Restrictions on the location and age of trees that can be harvested are
                         intended to protect and enhance the habitat of the northern spotted owl
Northwest Has Declined   and other species that depend on the region’s late-successional and
                         old-growth forests. However, these restrictions also limit the harvesting of
                         some of the most commercially valuable trees. For instance, restrictions
                         on harvesting older trees have contributed to the decline in timber
                         available to produce lumber and other commercially valuable
                         products—known as sawtimber.36 As a proportion of timber harvested
                         from Forest Service lands, sawtimber fell from an average of almost
                         86 percent during the 1980s to an average of less than 75 percent during
                         fiscal years 1995-98. (See fig. I.4.)




                         35
                           This estimate does not include “other wood.” Other wood is wood that is too decayed, crooked,
                         small, or otherwise unsuitable for processing into a saleable product. Historically, other wood has
                         accounted for about 10 percent of the total harvest volume from timber-suitable federal lands in the
                         planning area. The original probable sale quantity of 958 million board feet per year grew to
                         1.054 billion board feet (rounded to 1.1 billion board feet in some instances) when a 10-percent
                         increase was included for other wood.
                         36
                           When trees are harvested and cut into logs, they are graded on the basis of qualities such as the
                         diameter of the log and how clear, or free of knots, the wood is. Sawtimber is typically more valuable
                         than other timber because it can be manufactured into a broader array of wood products and often
                         contains a larger amount of clear, high-grade wood.



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Figure I.4: Sawtimber as a Percentage
of Total Volume of Timber Harvested
From Forest Service Lands in the
Pacific Northwest, Fiscal Years
1980-98




                                        Source: Forest Service.




                                        Moreover, the quality of the sawtimber harvested from federal lands in the
                                        Pacific Northwest has dropped, as illustrated by the decrease in the
                                        percentage of high-quality Douglas fir sold in the area covered by the
                                        Northwest Forest Plan. Douglas fir accounts for about two-thirds of the
                                        timber volume harvested from federal lands in the Pacific Northwest. It is
                                        one of the most commercially valuable tree species because of its size and
                                        quality. The most valuable Douglas fir are often found in late-successional
                                        and old-growth forests. However, the quality of the Douglas fir sawtimber
                                        that is being sold has dropped dramatically, in part because of the
                                        Northwest Forest Plan’s restrictions on harvesting in late-successional and
                                        old-growth areas. During the 1980s, about 22 percent of the Douglas fir
                                        sawtimber sold from federal lands in western Oregon and western




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                                       Washington was graded as the highest quality.37 This figure dropped to
                                       about 9 percent for fiscal years 1995-97. (See fig. I.5.)


Figure I.5: Percentage of High-Grade
Douglas Fir Sold on Federal Lands in
Western Oregon and Western
Washington, Fiscal Years 1980-97




                                       Source: Timber Data Company.




                                       37
                                         The highest-quality sawtimber, logs known as “peelers,” were so named because, historically, they
                                       were “peeled” to make veneer. Species of trees are graded on different scales. Only some species can
                                       produce logs of sufficiently high quality to be graded as peelers. Douglas fir grown west of the Cascade
                                       ridge is of such high quality that it has more than one grade of peeler—it has four grades.



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                                       Levels of Timber




Timber Program’s Per-Unit              While the volume and quality of timber have declined, the unit cost to the
Costs Have Increased for               Forest Service to operate the timber program and the unit cost to private
Land Management                        companies that harvest the timber have risen dramatically. In fiscal year
                                       1992, the Forest Service spent about $126 per thousand board feet to
Agencies and Loggers in                operate the timber program.38 By fiscal year 1997 the cost had almost
the Pacific Northwest                  doubled to $243 per thousand board feet.39 (See fig. I.6.)


Figure I.6: Cost Per Thousand Board
Feet to Operate the Forest Service’s
Timber Program in the Pacific
Northwest, Fiscal Years 1992-97




                                       Source: Forest Service.




                                       The Forest Service reports that nationally, per-unit costs have increased
                                       because the fixed costs of conducting the timber sale program, such as the


                                       38
                                         This includes all direct and indirect costs. Direct costs include the expenses for such activities as
                                       preparing and administering timber sales and reforesting cutover areas. Indirect costs mainly include
                                       the expenses for responding to appeals and litigation, as well as general administrative costs.
                                       39
                                         For fiscal year 1997, the federal government adopted new accounting standards that require the
                                       Forest Service to include the cost of road construction as an annual expense instead of carrying the
                                       cost as an asset on its balance sheet. This change was responsible for an 8.4-percent increase in the
                                       reported cost of the Forest Service’s national timber program for fiscal year 1997.



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                                      Levels of Timber




                                      expenses associated with depreciation on facilities and roads, have not
                                      changed, even though less timber is being sold. Additionally, certain
                                      activities that contribute to the cost of the timber program—such as sale
                                      preparation and harvest administration—are less efficient at lower harvest
                                      levels. As a result, the unit cost of performing these activities has generally
                                      increased as the size of the timber program has decreased.

                                      The unit cost per board foot to loggers to harvest timber on federal lands
                                      in the Pacific Northwest has also increased dramatically, in large part
                                      because of the more environmentally sensitive harvesting methods
                                      required on federal lands. Virtually all of this cost increase can be
                                      attributed to the increase in the stump-to-truck cost, that is, the cost to fell
                                      a tree, prepare it for transportation, and load it on a truck. (See fig. I.7.)


Figure I.7: Cost Per Thousand Board
Feet to Log in National Forests in
Western Washington and Western
Oregon, Fiscal Years 1980-97




                                      Source: Timber Data Company.




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                           Plan Addresses Many Long-Standing
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                           Levels of Timber




                           These costs have increased, in part, because clear-cutting, which is a
                           relatively economical method of harvesting, has been significantly
                           reduced, and more costly and time-consuming timber-harvesting methods
                           are being used. For example, a growing number of federal land managers
                           are requiring environmentally sensitive logging techniques that also
                           increase costs, such as having loggers use helicopters to remove trees
                           from an area instead of having trucks drive to the harvesting site, which
                           could damage the environment.


                           The overall decline in the quantity and quality of timber from federal lands
The Quantity and           covered by the Northwest Forest Plan is unlikely to be reversed, given
Quality of Federal         existing laws, including the Endangered Species Act, and their
Timber From the            implementing regulations and judicial interpretations. Although
                           restrictions imposed by the plan to comply with these laws caused the
Pacific Northwest Will     federal injunctions to be lifted, they also resulted in reduced timber sales,
Remain Low and Unit        lower-quality timber, and increases in per-unit costs for federal agencies to
                           operate the timber program, and for loggers to harvest timber from federal
Costs Will Remain          lands. The Forest Service and BLM estimate that the most likely volume of
High                       timber sold in an average year during the first decade of the plan will be
                           about 746 million board feet. This level of annual sales is not significantly
                           above the lowest level of sales experienced as a result of the
                           injunctions—about 300 million board feet—when compared with the
                           5 billion board feet of timber sold in an average year during the 1980’s. The
                           restrictions imposed by the plan that reduced timber sales to this level are
                           likely to keep them at about this level. Additionally, because these
                           restrictions are also responsible for reducing the timber’s quality and
                           increasing the program’s operating and harvesting costs, the quality and
                           costs are unlikely to change substantially.


Timber’s Declining         Although the sharp decline in the volume of timber sold can be traced to
Quantity and Quality Are   the court injunctions and the quantity and quality of the timber currently
Primarily the Results of   available for sale can be traced to specific components of the plan,
                           cutbacks in the timber program can generally be traced to requirements in
Statutory Requirements     federal planning and environmental laws. These laws include the
                           Endangered Species Act, the National Forest Management Act, the Federal
                           Land Policy and Management Act, the Clean Water Act, and the Clean Air
                           Act. Further requirements are embodied in the laws’ implementing
                           regulations and judicial interpretations.40 These laws define minimum

                           40
                            Forest Service Decision-Making: A Framework for Improving Performance (GAO/RCED-97-71,
                           Apr. 29, 1997).



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levels—or thresholds—to be met to protect individual natural resources or
assign responsibility for defining these levels to executive branch
officials.41

According to the plan, the sharp drop in timber volume from the levels
that prevailed during the 1980s is a consequence of previous high harvest
levels that severely limited the options available to land managers
attempting to comply with the environmental laws. For example, the
alternative options considered during the plan’s development that would
have provided higher probable sale quantities were not adopted because
they were deemed incompatible with the requirements of the Endangered
Species Act or the National Forest Management Act and its implementing
regulations.

The decrease in the quality of federal timber sold in the Pacific Northwest
is also ultimately attributable to the requirements of planning and
environmental laws. For example, the Forest Service believes that legal
requirements—coupled with changes in public attitudes concerning the
most appropriate management priorities for national forest
lands—resulted in a shift toward using timber sales to accomplish
stewardship objectives instead of providing wood.42 The Forest Service
has shifted its management emphasis under its broad multiple-use and
sustained-yield mandate from consumption (primarily producing timber)
to conservation (primarily sustaining wildlife and fish). It has also made
clear that its overriding mission and funding priority is to maintain and
restore the health of the lands entrusted to its care, and it has stated its
intention to limit goods and services—including commercial sawtimber
and other forest products—to the types, levels, and mixes that the lands
are capable of sustaining.43

In the past, the primary purpose of most timber sales was to help meet this
demand for wood products; therefore, these sales included a significant
amount of commercially valuable timber. However, more and more timber
sales are being designed to help attain various stewardship objectives. For
example, sales are being used as a tool to accelerate the development of

41
 Ecosystem Management: Additional Actions Needed to Adequately Test a Promising Approach
(GAO/RCED-94-111, Aug. 16, 1994).
42
   See for example, Forest Management Program Report, Fiscal Year 1997, Forest Service (FS-627,
July 1998) and Changing Economics of the National Forest Timber Sale Program, Forest Service
(1998).
43
 Forest Service: Lack of Financial and Performance Accountability Has Resulted in Inefficiency and
Waste (GAO/T-RCED/AIMD-98-135, Mar. 26, 1998) and Forest Service Management: Little Has Changed
as a Result of the Fiscal Year 1995 Budget Reforms (GAO/RCED-99-2, Dec. 2, 1998).



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Levels of Timber




late-successional conditions in young forest stands. While these sales are
designed to yield a profit whenever circumstances allow, the size, type,
and quality of the timber sold are dictated by the desired stewardship
outcome. As a result, the types of trees being harvested have shifted from
live to dead and dying trees and from large-diameter to small-diameter
trees.

This shift in emphasis is notable in the Pacific Northwest. Between fiscal
year 1992 and fiscal year 1997, the proportion of timber harvested from
Forest Service lands in the Pacific Northwest primarily to help meet the
nation’s demand for wood fell from about 96 percent to about 39 percent
of the harvest’s total volume, while the proportion of timber harvested for
forest stewardship purposes grew from less than 1 percent to about
55 percent.44 (See fig. I.8.)




44
  A third type of timber harvest, personal use sales, remained relatively steady, ranging between about
4 and about 7 percent of the Forest Service’s volume in the Pacific Northwest between fiscal year 1992
and fiscal year 1997. Personal use harvests are intended primarily to supply firewood, Christmas trees,
and other miscellaneous forest products to individuals for their own consumption.



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                                       Implementation of the Northwest Forest
                                       Plan Addresses Many Long-Standing
                                       Deficiencies but Cannot Provide Historic
                                       Levels of Timber




Figure I.8: Timber Volumes Harvested
From Forest Service Lands in the
Pacific Northwest to Meet Commodity
and Stewardship Objectives, Fiscal
Years 1992-98




                                       Source: Forest Service.




The Quantity and Quality               According to the original estimate in the Northwest Forest Plan, the likely
of Timber Sold Are                     amount of timber the Forest Service and BLM would be able to sell during
Unlikely to Increase                   the first decade of the plan—the probable sale quantity—would average
                                       about 958 million board feet per year. However, by August 1995, just 16
Substantially Over Levels              months after the plan was finalized, the Forest Service and BLM had
Experienced During the                 reduced the probable sale quantity to 840 million board feet per year.
Injunctions                            Moreover, the Forest Service expects to further reduce its portion of the
                                       probable sale quantity and estimates that the resulting total probable sale
                                       quantity will fall to an average annual level of 746 million board
                                       feet—22 percent less than the originally estimated probable sale quantity.
                                       The drop in probable sale quantity bears out the plan’s observation that
                                       changes could occur. For example, the plan noted that timber sale levels
                                       could be affected by requirements for conducting additional
                                       environmental analysis or setting aside additional lands to protect




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Levels of Timber




threatened or endangered species or by a change in the acreage allocated
to riparian reserves following an analysis and inventory of intermittent
steams. Officials told us that the probable sale quantity will likely change
yet again.

Even if the probable sale quantity does not drop below an average of
746 million board feet per year, this level of sales is only a small fraction of
the levels common during the 1980s, and, from this perspective, it is not
significantly higher than the levels under the federal court injunctions (see
fig. I.3). Timber sales reached their lowest level as a result of the
injunctions in fiscal year 1994, when the agencies sold 297 million board
feet, or about 6 percent of the 5 billion board feet sold, on average, each
year during the 1980s. The most likely average annual sale level under the
plan is about 746 million board feet, or about 15 percent of the level sold
during the 1980s. There is only a 9-percent difference between the level
predicted under the plan and the lowest level under the injunctions when
compared with the average level during the 1980s.

Furthermore, even if the probable sale quantity does rise, it is unlikely that
timber sales will increase significantly. Since the plan was approved,
additional species have been listed as threatened and endangered, and
agreements have been signed that require federal lands to assume a
growing proportion of the responsibility for protecting wildlife and fish.
These developments suggest that timber sales under the Northwest Forest
Plan may have peaked in fiscal year 1996, when 841 million board feet
were sold.

While the management direction in the Northwest Forest Plan is intended
to support the recovery of the northern spotted owl and conserve other
species dependent on old-growth forests by maintaining the ecological
health of forested and aquatic ecosystems, 18 species in the plan area have
been listed as endangered or threatened under the Endangered Species
Act since the plan was approved—15 fish, 1 frog, and 2 plants. Although 9
of these species were recently listed (March 1999), the new listings are not
expected to affect federal timber sales in the Pacific Northwest because
the listings are for salmon and trout species whose habitat requirements
are similar to those of the salmon and trout species already listed. The
additional listings, however, further reduce the chance that restrictions in
the plan protecting these species’ habitat will be lifted.

In addition, the pressure to maintain habitat on federal lands to protect
threatened and endangered species is expected to grow. The Forest



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Service and BLM are required by the National Environmental Policy Act to
consider activities occurring on nonfederal lands in deciding which
activities may occur on their lands. We believe this requirement, coupled
with recent policy initiatives, means that federal lands will assume a
growing proportion of the responsibility for protecting threatened and
endangered species and that these species’ habitats will increasingly be
concentrated on Forest Service and BLM lands in the Pacific Northwest and
elsewhere.

Additionally, the National Marine Fisheries Service and the Fish and
Wildlife Service have incorporated a “no surprises” policy into habitat
conservation plans under section 10 of the Endangered Species Act.45
Under this policy, nonfederal landowners, in exchange for adopting a
habitat conservation plan to protect threatened and endangered species,
will be exempt from land-use restrictions and other mitigation measures
affecting covered species beyond those restrictions and measures already
addressed in the habitat conservation plan. If the status of the species
unexpectedly worsens because of circumstances not addressed in the
habitat conservation plan, the burden of imposing additional conservation
measures would fall primarily on the federal government and on
nonfederal landowners that have not developed a habitat conservation
plan. There are about 3 million acres of nonfederal land under habitat
conservation plans within the range of the northern spotted owl.

Finally, according to a recent report on the Northwest Forest Plan,46 part
of the administration’s intent in developing a regional land management
plan was to minimize the impact of protecting and recovering threatened
and endangered species on nonfederal lands. Seventy-eight percent of the
lands were either set aside for specific uses, such as recreation, or
reserved to provide habitat for endangered and threatened species and
other species dependent on late-successional forest for habitat. Timber
harvesting on these lands is either prohibited or allowed only for
stewardship purposes. Timber harvests for commercial purposes are
allowed on the remaining 22 percent of the lands but are subject to
management provisions. While these provisions are intended to preserve
late-successional forests for habitat, they also have the effect of limiting
timber harvests. If more late-successional acreage is preserved on federal
lands, less must be preserved on nonfederal lands to provide sufficient
habitat for endangered, threatened, and other species that depend on this
type of forest for habitat. Essentially, the plan established a trade-off,

45
  63 Fed. Reg. 8859 (Feb. 23, 1998).
46
  J. Pipkin, The Northwest Forest Plan Revisited (Sept. 1998).



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increasing habitat protection requirements and timber-harvesting
restrictions on federal lands in order to increase the nonfederal acreage
available for timber harvesting and other nonconservation uses.




Page 55                                      GAO/RCED-99-64 Ecosystem Planning
Appendix II

Deficiencies in Developing a Management
Plan for the Interior Columbia River Basin
Have Resulted in Delays and Unfulfilled
Promises
               The development of a plan to manage about 72 million acres of federal
               land in the interior Columbia River basin is at a critical juncture. From the
               outset, the Forest Service and BLM have stated that a regional ecosystem
               management approach will cut the cost of amending federal land
               management plans in half because decisions will be made once for the
               region rather than for each federal land unit in the basin. However, after
               spending over 5 years and almost $41 million through fiscal year 1998, the
               agencies have still not made the necessary management choices and
               selected a management plan for the basin. The Forest Service and BLM
               estimate that they will need at least another $10.9 million to reach a
               decision in March 2000. One view expressed by both the public and some
               in the Congress is that funding for the effort should be terminated.
               According to some holding this view, the ecological and socioeconomic
               data that have been gathered and the analyses that have been performed
               should be forwarded to local Forest Service and BLM administrative units
               for the agencies to consider and use in revising their land management
               plans.

               In developing a management plan for the interior Columbia River basin,
               the Forest Service and BLM have attempted to address ecological issues
               along the boundaries of natural systems rather than along the boundaries
               of administrative units and have worked to overcome some long-standing
               planning deficiencies. They have (1) worked in collaboration with other
               federal agencies, (2) offered many opportunities for public participation in
               the process, and (3) conducted a scientific assessment that has generated
               greatly improved ecological and socioeconomic data on the basin.
               However, developing the plan has taken far longer and cost far more than
               expected.

               Some of the delays and higher costs occurred because the agencies
               significantly underestimated the time and effort required to address a
               multitude of ecological and socioeconomic issues and human activities at
               such a large geographic scale. Additional time and funds are being
               expended because the agencies decided to develop one or more new
               management alternatives in response to widespread criticism of their
               original draft alternatives from the public and the Congress. We believe
               that this criticism can be attributed, in part, to the failure of the agencies
               to limit their proposal to those issues that are appropriately addressed at
               the scale of the basin and to include for those issues the elements
               necessary for a successful ecosystem management plan. The agencies
               asked for comments on a draft management plan that spelled out the basic
               intent of seven different alternative strategies but that did not provide



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                         Appendix II
                         Deficiencies in Developing a Management
                         Plan for the Interior Columbia River Basin
                         Have Resulted in Delays and Unfulfilled
                         Promises




                         adequate detail to determine how the strategies would be implemented or
                         what effects they would have in particular locations. As a result, the
                         Congress and other interested parties could not make informed choices
                         among the alternatives. Moreover, as they did for the Northwest Forest
                         Plan, the Forest Service and BLM overestimated the volume of federal
                         timber to be harvested under their preferred land management alternative.


                         The plan to manage federal lands in the interior Columbia River basin is
A Multistep Process Is   being developed to avoid a conflict between consumption and
Being Used to            conservation such as the one in the Pacific Northwest that led to
Develop a                injunctions against timber sales on federal lands. Table II.1 summarizes
                         the major events in developing the plan.
Management Plan for
the Interior Columbia
River Basin




                         Page 57                                      GAO/RCED-99-64 Ecosystem Planning
                                           Appendix II
                                           Deficiencies in Developing a Management
                                           Plan for the Interior Columbia River Basin
                                           Have Resulted in Delays and Unfulfilled
                                           Promises




Table II.1: Time Line of Major Events in Developing a Management Plan for the Interior Columbia River Basin


1993            July          The President directs the Forest Service to develop a scientifically sound ecosystem-based strategy
                              for national forests in Oregon and Washington east of the crest of the Cascade mountain range.


1994            January       The Forest Service and BLM sign a charter expanding the scope of the strategy to include BLM lands
                              in eastern Oregon and Washington.
                July          The Forest Service and BLM expand the scope of the effort to include the upper Columbia River basin
                              in Idaho, Montana, Wyoming, Utah, and Nevada.


1996            June          The agencies issue a framework for ecosystem management in the project area.
                December      The agencies issue an integrated scientific assessment of the project area.


1997            May           The agencies issue a scientific evaluation of the potential effects of preliminary management
                              alternatives.
                June          The agencies issue a more detailed scientific assessment of the project area.
                June          The agencies release for public comment a draft environmental impact statement for each of the two
                              planning areas: eastern Oregon and Washington and the upper Columbia River basin, which together
                              make up the interior Columbia basin. The comment period is to end October 6, 1997.
                September     The agencies extend the public comment period to February 6, 1998.
                December      The agencies extend the public comment period to April 6, 1998.


1998            March         In response to a congressional mandate, the agencies issue an analysis of the economic and social
                              conditions of communities in the project area.
                March         The public comment period is extended to May 6, 1998, to allow time to review the March 1998
                              analysis of economic and social conditions.
                May 6         The public comment period ends. Nearly 83,000 comments were received.
                October       The agencies issue an analysis of public comments on the draft environmental impact statements.
                October 8     The Secretaries of Agriculture and the Interior announce their decision to present one or more new
                              alternatives in a supplemental draft environmental impact statement sometime in mid-1999.


1999            September     A supplemental draft environmental impact statement is to be released for public comment.


2000            March         A final environmental impact statement and record of decision are to be issued.

                                           In March 1993, environmental groups petitioned the Forest Service’s
                                           Pacific Northwest (Region 6) office to revise its minimum management
                                           requirements for old-growth-dependent wildlife species on national forests
                                           in Oregon and Washington east of the crest of the Cascade mountain range



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Have Resulted in Delays and Unfulfilled
Promises




(the Eastside planning area). The petitioners claimed that the
requirements in effect at the time, which were intended to ensure the
continued viability of certain old-growth-dependent species, (1) lacked
credibility and (2) had not been developed for other old-growth-dependent
species that needed them. The petitioners also contended that the region
had no alternative for the Eastside area but to adopt the type of large-scale
planning done under court order in the range of the northern spotted owl.
They requested a moratorium on timber harvesting and road building in
the Eastside area’s mature and old-growth forests.

In July 1993, the President directed the Forest Service to develop a
scientifically sound ecosystem-based management strategy for the
Eastside area’s national forests. He also directed that the strategy be based
on a forest health study that had been completed in May 1993 by a team of
agency scientists, as well as other studies.

In January 1994, the Forest Service and BLM signed an “Eastside Ecosystem
Management Project” charter that expanded the scope of the strategy to
include all lands managed by BLM in eastern Oregon and Washington. The
charter called for four products: (1) a framework for ecosystem
management, (2) a scientific assessment of the interior Columbia River
basin, (3) an environmental impact statement that presented a preferred
alternative for managing Forest Service and BLM lands in eastern Oregon
and Washington, and (4) a scientific evaluation of the management
alternatives in the environmental impact statement. According to the
agencies, the preferred alternative in the environmental impact statement
should both restore degraded habitats and provide commodities to help
support local communities.

In July 1994, the Forest Service and BLM expanded the scope of the
planning effort to include the development of a strategy for managing
federal lands in much of Idaho, western Montana, and small portions of
Nevada, Wyoming, and Utah (the Upper Columbia River Basin planning
area). The effort to develop management strategies for both the Eastside
planning area and the upper Columbia River basin planning area is known
as the Interior Columbia Basin Ecosystem Management Project.

Between May 1994 and July 1995, the Forest Service issued three interim
management strategies. One established riparian, ecosystem, and wildlife
standards for timber sales in eastern Oregon and Washington (the Eastside




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Promises




Screens).47 Another established requirements for managing anadromous
fish48 in eastern Oregon and Washington, Idaho, and portions of
California.49 The third established requirements for managing inland native
fish.50 The ecosystem management framework called for in the
January 1994 charter was completed in June 1996.51 It described the
principles and the planning and analysis processes for managing
ecosystems in the basin at multiple geographic scales and resolutions of
data.

An integrated scientific assessment of the interior Columbia River basin
was issued in December 1996.52 A scientific evaluation of the seven land
management alternatives contained in a February 1996 internal working
draft of the environmental impact statement was completed in May 1997.53

In June 1997, the agencies released a more detailed version of the
scientific assessment.54 That same month, the Forest Service and BLM also
issued two draft environmental impact statements for public comment
(dated May 1997)—one for the Eastside planning area and another for the
Upper Columbia River Basin planning area.




47
 Interim Management Direction Establishing Riparian, Ecosystem, and Wildlife Standards for Timber
Sales, Forest Service (May 20, 1994; amended on June 5, 1995, and July 31, 1995).
48
  Anadromous fish (e.g., salmon and steelhead) hatch in freshwater, migrate to the ocean, mature
there, and return to freshwater to reproduce.
49
  Implementation of Interim Strategies for Managing Anadromous Fish-producing Watersheds in
Eastern Oregon and Washington, Idaho, and Portions of California, Forest Service (Feb. 24, 1995). This
strategy is known as PACFISH.
50
  Inland Native Fish Strategy, Forest Service (July 28, 1995). This strategy is known as INFISH.
51
 Richard W. Haynes, Russell T. Graham, and Thomas M. Quigley, tech. eds., A Framework for
Ecosystem Management in the Interior Columbia Basin and Portions of the Klamath and Great Basins,
Forest Service, Pacific Northwest Research Station, General Technical Report PNW-GTR-374
(Portland, Ore.: 1996).
52
 Thomas M. Quigley, Richard W. Haynes, and Russell T. Graham, tech. eds., Integrated Scientific
Assessment for Ecosystem Management in the Interior Columbia Basin and Portions of the Klamath
and Great Basins, Forest Service, Pacific Northwest Research Station, General Technical Report
PNW-GTR-382 (Portland, Ore.: 1996).
53
 Thomas M. Quigley, Kristine M. Lee, and Sylvia J. Arbelbide, tech. eds., Evaluation of EIS Alternatives
by the Science Integration Team, Forest Service, Pacific Northwest Research Station, General
Technical Report PNW-GTR-406 (Portland, Ore.: 1997).
54
  Thomas M. Quigley, and Sylvia J. Arbelbide, tech. eds., An Assessment of Ecosystem Components in
the Interior Columbia Basin and Portions of the Klamath and Great Basins (vols. I-IV), Forest Service,
Pacific Northwest Research Station, General Technical Report PNW-GTR-405 (Portland, Ore.: 1997).



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Plan for the Interior Columbia River Basin
Have Resulted in Delays and Unfulfilled
Promises




The draft environmental impact statements are very similar to each other.
Both addressed the environmental, economic, and social effects of seven
different land management alternatives representing a wide range of
management prescriptions. These alternatives included a preferred
alternative to aggressively restore forest, rangeland, and watershed health
through active management as well as alternatives to maintain the status
quo, emphasize the production of goods and services, establish a system of
reserves on federal lands within which management activities would be
limited, and others.

The original closing date for public comments on the draft environmental
impact statements was October 6, 1997. However, in September 1997, the
comment period was extended to February 6, 1998, to give the public more
time to review the voluminous documents. In total, the detailed scientific
assessment, draft environmental impact statements, and associated
documents ran to nearly 6,000 pages. In December 1997, the comment
period was extended to April 6, 1998. Then, in March 1998, it was extended
to May 6, 1998, to give the public time to review a report issued that month
on the economic and social characteristics of the basin and the estimated
effects of the seven different land management alternatives in the
environmental impact statements on communities in the basin.55 The
report was prepared pursuant to the Department of the Interior and
Related Agencies Appropriations Act of 1998 (P.L. 105-83).

In an October 8, 1998, letter to key members of the Congress, the
Secretaries of Agriculture and the Interior announced that, because of
widespread criticism of the June 1997 draft environmental impact
statements by both the public and the Congress, the Forest Service and
BLM would issue one or more new management alternatives in a
supplemental draft environmental impact statement in mid-1999.
According to the Secretaries’ letter, the supplemental draft environmental
impact statement would be followed by another public comment period.
Agency officials have since told us that the supplemental draft
environmental impact statement is to be released for public comment in
September 1999 and a final environmental impact statement and record of
decision are to be issued in March 2000.




55
 Nicholas E. Reyna, Richard H. Phillips, and Gerald W. Williams, Economic and Social Conditions of
Communities: Economic and Social Characteristics of Interior Columbia Basin Communities and an
Estimation of Effects on Communities from the Alternatives of the Eastside and Upper Columbia River
Basin Draft Environmental Impact Statements, Interior Columbia Basin Ecosystem Management
Project (1998).



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                            Deficiencies in Developing a Management
                            Plan for the Interior Columbia River Basin
                            Have Resulted in Delays and Unfulfilled
                            Promises




                            In developing a management plan for the interior Columbia River basin,
Development of the          the Forest Service and BLM have attempted to address ecological issues
Plan Has Addressed          along the boundaries of natural systems and have worked to overcome
Some Long-Standing          some of the long-standing deficiencies that have plagued federal land
                            management decision-making. The agencies have (1) collaborated with
Decision-Making             other federal agencies, (2) involved the public in the decision-making
Deficiencies and            process, and (3) conducted a scientific assessment to develop improved
                            ecological and socioeconomic data on the basin. At the same time, the
Accomplished Some           agencies have also taken some of the steps that we believe are necessary
of the Steps                to implement ecosystem management.
Necessary for
Ecosystem
Management
Federal Agencies Have       The Forest Service and BLM are the lead agencies on the Interior Columbia
Coordinated the Planning    Basin Ecosystem Management Project; however, the project has been a
Effort From the Beginning   multiagency effort from the beginning. An executive steering committee
                            has directed the project. The committee is composed of three Forest
                            Service regional foresters, three BLM state directors, two Forest Service
                            research experimental station directors, a deputy regional director of the
                            Environmental Protection Agency, and regional directors of the National
                            Marine Fisheries Service and the Fish and Wildlife Service.

                            The committee created an ad hoc interagency senior-level team of senior
                            executives from the Forest Service, BLM, and three federal regulatory
                            agencies—the Environmental Protection Agency, the Fish and Wildlife
                            Service, and the National Marine Fisheries Service. This team’s purpose
                            was to ensure that the draft environmental impact statements complied at
                            the basin scale with the requirements of the many relevant land
                            management and environmental protection laws, including the National
                            Forest Management Act, the Federal Land Management and Policy Act, the
                            National Environmental Policy Act, the Endangered Species Act, the Clean
                            Water Act, and the Clean Air Act. The draft environmental impact
                            statements also called for the Forest Service and BLM to develop a
                            memorandum of understanding with the three regulatory agencies that
                            would facilitate collaboration in implementing the project.

                            Two separate groups have carried out the overall planning effort. One
                            group—known as the Science Integration Team—was responsible for
                            developing three of the four products called for in the January 1994
                            charter—the framework for ecosystem management, the scientific



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                         assessment of the interior Columbia River basin, and the scientific
                         evaluation of the management alternatives in the draft environmental
                         impact statements. The other group—known as the Environmental Impact
                         Statement Team—is responsible for developing the two environmental
                         impact statements. Both groups are interdisciplinary and interagency
                         teams of biologists, botanists, geologists, economists, sociologists, and
                         others. They have consisted primarily of Forest Service and BLM staff but
                         have also included representatives from the Environmental Protection
                         Agency; Interior’s U.S. Geological Survey, National Biological Service,56
                         Fish and Wildlife Service, and Bureau of Mines; Commerce’s National
                         Oceanic and Atmospheric Administration and National Marine Fisheries
                         Service; and universities. Other cooperating agencies include the National
                         Park Service, the Bureau of Reclamation, and the Bonneville Power
                         Administration.

                         The vast majority of the project’s costs have been borne by the Forest
                         Service and BLM, but other agencies have also contributed staff and
                         resources. The Forest Service spent about 85 percent and BLM about 15
                         percent of the nearly $41 million spent by those two agencies on the
                         project as of the end of fiscal year 1998. In addition, the Environmental
                         Protection Agency estimates that it spent $487,600 on the project between
                         fiscal year 1994 and January 1998, primarily for salaries. The Fish and
                         Wildlife Service estimates that it has spent about $250,000 per year on
                         developing the plan since fiscal year 1995.


The Public Has           The public has had many opportunities to participate in the planning
Participated Since the   process. Before developing the draft environmental impact statements, the
Planning Effort Began    Environmental Impact Statement Team held scoping meetings in dozens of
                         locations with members of the public to identify issues and concerns
                         associated with the lands managed by the Forest Service and BLM. While
                         developing the draft environmental impact statements, the team held over
                         200 informational meetings, briefings, and consultations. Nearly 83,000
                         citizens; advocacy groups; corporations; and federal, tribal, state, and local
                         agencies commented on one or both of the draft environmental impact
                         statements. An independent team of natural resource professionals from
                         the Forest Service and BLM prepared a content analysis of those




                         56
                          In 1996, the National Biological Service became the Biological Resources Division of the U.S.
                         Geological Survey.



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                           comments,57 and the Environmental Impact Statement Team will consider
                           them in preparing the supplemental draft environmental impact statement.

                           According to the content analysis of the public comments on the draft
                           environmental impact statements, “many are frustrated with the process
                           for public collaboration and suspect their input is not being considered by
                           government decision-makers.” However, as we have observed in
                           reviewing other federal land management planning efforts, while the
                           benefits of working together cooperatively often outweigh the costs of
                           early and continuous public involvement, dissatisfaction with the agencies’
                           process for public involvement often cannot be dissociated from
                           dissatisfaction with the outcome of the process. Thus, some parties
                           opposed to the preferred management alternative in the draft
                           environmental impact statements—which would aggressively restore
                           forest, rangeland, and watershed health through active management but
                           not emphasize the production of goods and services—may be expressing
                           dissatisfaction with the agencies’ process for public involvement. These
                           parties may also be expected to avail themselves of statutory or regulatory
                           opportunities for administrative appeal and judicial review if they are
                           similarly dissatisfied with the management alternative or alternatives
                           scheduled to be presented in the supplemental draft environmental impact
                           statement.


Efforts Are Under Way to   The scientific assessment of ecological and socioeconomic systems and
Collect and Use            conditions in the basin greatly contributed to data comparability for the
Comparable Data            basin. The Science Integration Team assembled over 170 “data layers,” or
                           maps, of particular variables, such as vegetation types, grizzly bear range,
                           employment, and income. These data are stored in geographic information
                           systems and can be retrieved not only by federal land managers at the
                           forest or district level but also by the public. As a result, pertinent
                           information—which is not restricted to the agencies’ administrative
                           boundaries or jurisdictions—can be used for decision-making by many
                           levels of government. Despite these benefits, many of the comments on
                           the draft environmental impact statements criticized the uses of data from
                           the scientific assessment.




                           57
                            Final Analysis of Public Comment for the Eastside and Upper Columbia River Basin Draft
                           Environmental Impact Statements, Content Analysis Enterprise Team (1998).



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Development of a           In addition to addressing several long-standing planning deficiencies, the
Management Plan for the    Forest Service and BLM are using an approach in the interior Columbia
Interior Columbia River    River basin that is consistent with the first two practical steps needed to
                           implement ecosystem management (see fig. I.1). They have (1) delineated
Basin Followed the First   ecosystems at several geographic scales based on watersheds and
Practical Steps in         (2) conducted a scientific assessment to better understand the
Implementing an            ecosystems’ ecologies. The agencies are now in the process of completing
Ecosystem Approach to      the third step—making management choices. They have also
Federal Land Management    acknowledged the importance of the fourth step—adaptive
                           management—and have proposed monitoring steps to determine whether
                           the plan’s management direction is being followed (implementation
                           monitoring) and whether the plan is accomplishing the desired conditions
                           (effectiveness monitoring).

                           In the past, when the Forest Service and BLM developed a separate land
                           management plan for each of their administrative units, they produced 74
                           separate land management plans for the basin. In developing a basinwide
                           plan, the agencies recognized that decision-making at the level of an
                           administrative unit resulted in a fragmented and, perhaps, inconsistent
                           approach to addressing many of the broader-scale ecological issues that
                           transcend the boundaries of national forests and BLM districts. Therefore,
                           as is consistent with the first practical step of ecosystem management,
                           they are using watersheds at three different geographic scales as the plan’s
                           building blocks. The broadest scale is essentially the basin itself, which
                           encompasses about 144 million acres and contains about 75 million acres
                           of federal land managed by the Forest Service or BLM.58 The basin was then
                           divided into 164 subbasins averaging 800,000 to 1,000,000 acres in size,
                           over 2,000 watersheds averaging 50,000 to 100,000 acres, and over 7,000
                           subwatersheds averaging 15,000 to 20,000 acres.

                           Under the second practical step of ecosystem management, the scientific
                           assessment—completed at a cost of about $22.7 million—has provided
                           extensive knowledge of the interior Columbia River basin. The initial
                           integrated assessment examined past and present biophysical (i.e.,
                           aquatic, terrestrial, and landscape), social, and economic systems on all
                           lands in the basin regardless of ownership and discussed the probable
                           outcomes of the agencies’ current management practices and trends. An
                           expanded version of the assessment provided more detail on terrestrial,
                           aquatic, landscape, economic, and social conditions in the basin.



                           58
                             The draft management plans address 72 million of the 75 million acres.



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                            The delays and increased costs that have been and will be incurred to
Delays and Increased        develop a plan to manage federal lands in the interior Columbia River
Costs Can Be Traced         basin can be traced primarily to two factors. First, the Forest Service and
Primarily to the            BLM significantly underestimated the time and effort required to address
                            the multitude of ecological and socioeconomic issues and human activities
Magnitude of the            that they considered for an area encompassing roughly 8 percent of the
Effort and the Failure      United States. Second, the management plan that the agencies proposed in
                            June 1997 was widely criticized, and, as a result, they are spending
to Present an               additional time and money developing a new approach for the basin that
Adequate Draft Plan         will yield one or more new management alternatives.

                            Some criticism of the original proposal focused on the agencies’ decision
                            to address issues that were not basinwide in nature. We also believe that
                            although the agencies presented alternatives in June 1997 that reflected
                            different management strategies, they did not clearly identify how the
                            alternatives would be implemented or what their consequences would be
                            in particular locations. These are elements that we believe are necessary
                            for a successful ecosystem management plan. Without this information,
                            the Congress and other interested parties could not make informed
                            choices among the proposed management alternatives. Moreover, without
                            this specificity, the chosen management alternative would have been
                            difficult, if not impossible, for federal land managers to implement,
                            monitor, evaluate, and be held accountable for.


The Size and Scope of the   The broad geographic scope of the planning area, coupled with the
Project Led to              multitude of issues and activities that the agencies decided to address,
Unanticipated Delays and    presented the agencies with a daunting challenge in developing a plan to
                            manage federal lands in the interior Columbia River basin. Reviewing the
Costs                       draft proposal also posed a challenge to the public that the agencies
                            acknowledged by extending the original 120-day comment period to 330
                            days. As is clear, the Forest Service and BLM underestimated the overall
                            time and effort that would be required to develop a plan.

                            The scope of the effort has included a multitude of ecological and
                            socioeconomic issues affecting both forests and rangelands. For example,
                            the scientific assessment and draft plan have addressed not just
                            old-growth-dependent species, but other endangered and threatened
                            species—such as anadromous fish (including salmon) and the grizzly
                            bear—with different and/or more extensive habitat requirements. They
                            have also addressed issues such as costly outbreaks of wildfires, insects,
                            and diseases; invasions of exotic weeds; declines in soil fertility and water



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                              and air quality; wilderness preservation; mounting legal challenges; and
                              unpredictable flows of commodities such as timber and livestock forage.

                              As the issues increase, so too do the number of human activities that need
                              to be addressed in developing a management plan to restore the health of
                              forests and rangelands in the basin. The scope of the assessment included
                              not only timber harvesting and road building, but also fire suppression;
                              livestock grazing; mining; damming and water diversions; agricultural,
                              industrial, urban, and residential development; and the deliberate or
                              accidental introduction of nonnative plants, insects, and diseases.

                              Because the basin is so large and so many issues are being addressed, the
                              process is taking much longer and costing much more than anticipated.
                              For instance, in 1994, when the Forest Service and BLM added the Upper
                              Columbia River Basin planning area, they doubled the geographic scope of
                              the planning effort. (See fig. 1.) The charter called for the draft
                              environmental impact statement for the Eastside planning area to be
                              completed by January 1995. In April 1995, after the agencies decided to do
                              an environmental impact statement for the upper Columbia River basin
                              planning area, the Chief of the Forest Service announced that the draft
                              statements would be issued in the fall of 1995. The date for issuing the
                              draft statements was later postponed to August 1996, and the statements
                              were finally released in June 1997. The public comment period for the
                              draft statements was originally 120 days, but the agencies ultimately
                              extended it to 330 days to give people time to review the volumes of
                              scientific data and wide-ranging management alternatives.

                              The budget for the project has also grown since it started. The initial
                              estimated cost for the assessment and the Eastside management plan was
                              $5 million. In 1995, the agencies stated that the 3-year budget (through
                              fiscal year 1996) for the expanded project area was $31 million. As of the
                              end of fiscal year 1998, the Forest Service and BLM had spent nearly
                              $41 million.


Criticism of the Draft Plan   Faced with widespread criticism over the agencies’ preferred alternative in
Led to a Decision to          the draft plan, the Secretaries of Agriculture and the Interior wrote to
Prepare a Supplemental        Members of Congress in October 1998 that they would “pursue alternative
                              proposals to meet the interests and concerns of the public” and present
Draft Environmental           them in a supplemental draft environmental impact statement. This effort
Impact Statement              will add time and costs to the project. The agencies now expect to issue
                              the supplemental statement in September 1999 and anticipate that a final



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plan will be approved in March 2000. The fiscal year 1999 budget for the
project is $5.7 million (some of which would have been needed even
without the decision to prepare new alternatives). According to the project
team, another $5.2 million will be needed in fiscal year 2000 to complete
the plan.

Criticism of the original proposal was, indeed, widespread, coming from
environmental organizations and conservationists, resource-based
industries, local and tribal governments, and federal agencies. The nature
of the criticism was also broad. The public critiqued, among other things,
(1) the feasibility of trying to develop a management plan at the scale of
the basin for the issues that the agencies addressed; (2) the clarity and
specificity of the proposed management direction; (3) the range of the
proposed alternatives; (4) the quantity, quality, and interpretation of
scientific data; (5) the depth of coverage of specific issues; and (6) the
projected outcomes of the preferred alternative.

While much of the criticism could have been anticipated, given the
controversial nature of the issues, the first two categories of criticism
relate to how the agencies handled the first and third steps of ecosystem
management. As shown in fig. I.1, the first step toward ecosystem
management is to delineate the boundaries of ecosystems at several
geographic scales across which consistent management can be applied. As
part of that step, we believe that it is also necessary to identify the issues
that are appropriately addressed at those scales. In their original draft
proposal, the agencies did delineate ecosystems at different scales and
attempted to address both basinwide and subbasin issues. In their
October 8, 1998, letter to key Members of Congress, the Secretaries of
Agriculture and the Interior stated that the new management alternative(s)
in the supplemental draft environmental impact statement and record of
decision would focus on the limited number of issues that must be
resolved at the basin level. Issues that are subbasin in scale will be
addressed through other planning efforts.

The letter stated that the new Interior Columbia Basin Ecosystem
Management Project’s approach would include basinwide direction built
around four basic components: aquatic habitat; terrestrial species habitat;
landscape health; and human needs, products, and services. According to
the letter, the aquatic and terrestrial approach will attempt to protect
wide-ranging species, such as anadromous fish, lynx, and wolverine, by
ensuring that adequate habitat is available across administrative units. The
aquatic strategy will also address basinwide considerations that arise from



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the agencies’ responsibilities under the Clean Water Act. The needs of
plants and animals with smaller ranges will be addressed at the most
appropriate geographic scale. By reducing the number of issues covered
by the proposal, the agencies may either address or make moot some of
the public criticism. For example, criticism of how the original version
addressed a particular sensitive species that has a small range would not
be relevant under a new approach that does not attempt to address that
species’ needs.

As of February 1999, the planning effort’s Environmental Impact
Statement Team was sorting out the issues that should be addressed in the
basinwide supplemental draft environmental impact statement from those
that should be addressed later at the subbasin and watershed scales.
According to these officials, issues that are not basinwide but that extend
beyond the boundaries of national forests or BLM units will be addressed
by adjacent units working together. They had not decided how the
agencies would oversee the plan’s implementation to determine whether
the basinwide management direction was being followed and whether it
was accomplishing the desired conditions.

Some of the public comments, as well as our observations, suggest that the
agencies did not complete the third step of ecosystem management for
certain issues. The third step is to make management choices that identify
(1) the desired future ecological conditions; (2) the type, level, and mix of
activities needed to meet those conditions; and (3) the distribution of
activities among land units over time. While the June 1997 proposal
articulated the broad strategic differences among the proposed
management alternatives, it did not provide detailed information on the
desired future conditions, activities, and distribution of activities for each
one. Without such detailed information for each of the alternatives,
stakeholders cannot readily associate particular ecological outcomes and
economic outputs with each one, and analyses of the alternatives must be
based on their intent, rather than on specific expected results.

For example, the draft environmental impact statements included
“desired ranges of future conditions” that could be expected in 50 to 100
years if the management direction specified in an alternative were
implemented. The draft environmental impact statements specified
management direction through objectives and standards. Objectives are
indicators used to measure progress toward achieving a desired future
condition and are designed to be accomplished in 10 years. Standards are
requirements to act or refrain from acting in a way intended to achieve the



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objectives. Collectively, the objectives and standards should identify the
activities that are required, allowed, or restricted on federal lands in the
basin.

According to one description in the draft environmental impact statements
of a desired range of future economic conditions, “Economic activity is
generated in rural communities, including private sector employment,
government agency employment, income, number of recreation visits, and
revenues shared with local governments.” An indicator to measure
progress toward achieving these conditions states that the agencies’
objective is to “derive social and economic benefits, promote commercial
activity, and foster demand for labor and capital formation through
producing a mix of goods and services.” Most, if not all, of the seven land
management alternatives in the draft environmental impact statements
would have met these desired economic conditions and this objective.
However, the level of economic activity generated in rural communities
under each of the alternatives could have varied significantly.

The level of economic activity generated in rural communities under each
of the alternatives in the draft environmental impact statements could also
have varied significantly with the activities that would have been required,
allowed, or restricted on particular national forests or BLM districts. For
instance, the Northwest Forest Plan allocated the estimated level of
potential timber sales over the first 10 years of the plan among the national
forests and BLM districts covered by the plan. Thus, individuals, companies,
and communities economically dependent on these lands had an
expectation about the future availability of timber from them, and federal
land managers could plan and be held accountable for meeting these
targets. Conversely, the draft environmental impact statements for the
interior Columbia River basin allocated estimated potential timber sales
and other activities to noncontiguous, but ecologically similar, “clusters”
of forests and rangelands scattered throughout the basin. (See fig. II.I for
the boundaries of forest clusters.) The draft environmental impact
statements did not, however, identify where in each cluster an activity
would likely occur. Without knowing the estimated levels of potential
timber sales and other activities on national forests or BLM districts, those
economically dependent on the forests or districts did not have an
adequate understanding of how much economic activity might be
generated at the local level by federal timber sales and other activities.




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Figure II.1: Forest Clusters in Lands Within the Boundaries of the Interior Columbia River Basin Project Area


                                                    C A N A D A
                                            WASHINGTON         IDAHO      MONTANA




                                               WASHINGTON
                                                  OREGON




                                                                                                                WYOMING




                                              OREGON                      IDAHO
                                                                         NEVADA
         CALIFORNIA                                                                           UTAH




      Cluster 1

      Cluster 2       Boundary of area covered by the environmental impact statement

      Cluster 3       Cluster boundary

      Cluster 4

      Cluster 5

      Cluster 6


                                                                                                               (Figure notes on next page)



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Note: The lands in the project area that are not shaded are dominated by range ecosystems
rather than forests. The agencies also divided these areas into noncontiguous range clusters.

Source: Interior Columbia Basin Ecosystem Management Project.




According to the analysis of public comments, many were critical of the
how complete the agencies were in making management decisions about
ecological issues as well. Many commented that the objectives and
standards for management activities were inconsistent, were too vague to
be quantified or measured, or lacked time frames and locations. For
example, one professional society wrote that many contradictory goals
and directions exist and that it was not clear who would decide which way
to go when trade-offs are necessary. The Fish and Wildlife Service wrote
that the restoration direction in the preferred alternative was not clearly
developed into a strategy that included guidelines, time frames, and
measurable objectives. The Service went on to say that much more
information was needed on the actions for carrying out the restoration,
how it would be implemented, and how progress and compliance would
be measured. Another theme of the comments was that watershed
management activities must be more clearly defined so that the public can
understand what activities will result from a decision. According to the
summary, most comments on specific wildlife habitat issues noted that the
public and wildlife would benefit from clearer, more precise, and more
accurate descriptions of the proposed management. With respect to
management for viable populations of wildlife, many commented that
there was little difference among the objectives, standards, and guidelines
for the different alternatives, making it difficult to determine whether the
standards and guidelines could achieve the intended differences.

The agencies announced their intent to limit the focus of the revised
alternatives to issues that are basinwide in scale. However, the Secretaries’
letter to Members of Congress also indicated that the revised alternatives
would contain only general guidance on some of those issues. For
example, the letter said that landscape health issues, such as the rapid
spread of noxious weeds and the potential for costly and dangerous fires,
would be addressed though general objectives and guidance and that the
specific design for on-the-ground activities would be appropriately
addressed at the subbasin or local level. We are concerned that general
guidance will not be adequate to provide the necessary standards of
accountability for land managers, the Congress, or the public.
Furthermore, it is possible that general guidance on basinwide issues will



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not provide these stakeholders with the clear and well-defined
management alternatives they expect. For example, project managers told
us in January 1999 that they had not decided whether the supplemental
environmental impact statement would contain an estimate of commodity
levels under the new alternatives. This was reiterated in the comments on
our draft report made by the Interior Columbia Basin Ecosystem
Management Project’s Executive Steering Committee when it wrote that
specific prescriptions related to such things as timber harvest and grazing
levels would not be appropriate at the scale of the basin.

The public is accustomed to Forest Service and BLM land management
plans that provide a high level of detail on land allocations, project
activities, and commodity outputs. The directors of the interior Columbia
River basin project have told us that it is not possible to provide for the
entire basin the level of detail that one might expect for a national forest.
What is possible, they say, is to make basinwide decisions about
management strategies and then make more refined decisions at a smaller
scale.

Indications from the October 8, 1998, letter, however, are that the revised
proposal will provide less rather than more detail on management steps
and outcomes. If so, to limit criticism such as they received on the original
proposal, the agencies must make it clear that the purpose of the project is
to decide on a broad strategy for management in the basin—whether that
strategy be active management, letting nature take its course (passive
management), or emphasizing commodity production—and that they
cannot produce a plan for this scale that is as detailed as a plan for a single
administrative unit.

If the purpose of the revised proposal is to present broad alternative
strategies, two other observations are relevant. First, the Chief of the
Forest Service has often stated over the last 2 years that the agency’s
primary goal is to maintain or restore the health of the land and that active
management is necessary to achieve this goal. A decision that would not
do much more than adopt active management as the strategy for the
interior Columbia River basin, therefore, would not represent a significant
advancement. Second, if fewer decisions are made at a basinwide level,
more decisions must be made at a subbasin level. As the balance shifts
toward local decision-making, the amount of time and money required to
complete individual unit management plans, as well as to complete the
overall planning process for lands in the basin, will increase.




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                          Besides not providing the specific information decisionmakers needed to
The Quantity and          make informed choices among the seven different land management
Quality of Federal        alternatives, the draft environmental impact statements overestimated the
Timber in the Interior    volume of federal timber to be harvested under the preferred land
                          management alternative. As a result, the Forest Service and BLM created
Columbia River Basin      unrealistic expectations, and the Congress and other interested parties
Will Continue to          were asked to make choices on the basis of incorrect information about
                          the alternative’s ability to generate economic activity within the basin.
Decline
The Volume of Timber      The volume of timber harvested from federal lands in the interior
Harvested Has Decreased   Columbia River basin has declined steeply since fiscal year 1990 following
Significantly             years of high output. Timber harvests on federal lands in the basin reached
                          historically high levels in the late 1980s. The Forest Service and BLM
                          harvested an average of just over 3 billion board feet from fiscal year 1985
                          through fiscal year 1990. Timber harvests on these lands declined steeply
                          starting in fiscal year 1991, averaging just over 1.5 billion board feet from
                          fiscal year 1991 through fiscal year 1997, with the lowest volumes
                          occurring in the most recent years. (See fig. II.2.) This decline can be
                          attributed to the three interim strategies (PACFISH, INFISH, and the
                          Eastside Screens), requirements in planning and environmental laws, and
                          changes in public values and the agencies’ mission and funding priorities.




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Figure II.2: Volume of Timber
Harvested From Forest Service and
BLM Units Entirely Within the Interior
Columbia River Basin, Fiscal Years
1985-97




                                         Source: Interior Columbia Basin Ecosystem Management Project.




The Quality of Timber                    In the draft environmental impact statements, the Forest Service and BLM
Harvested on Federal                     cautioned that trees would have been harvested under their preferred
Lands in the Basin Will                  management alternative primarily to restore the health of forest
                                         ecosystems rather than to produce wood fiber. As a result, the trees would
Decline                                  have been small in diameter and would have had less commercial value.

                                         For example, timber stands would have been selected for harvesting or
                                         thinning to reduce the dense growth that makes small trees susceptible to
                                         insects, diseases, or catastrophic wildfires.59 Or, timber would have been
                                         harvested from the ecologically undesirable even-age tree stands often
                                         planted after clear-cutting. In addition, the preferred alternative would
                                         have required that a specified number of large trees be left standing.



                                         59
                                          See Thomas M. Quigley, Kristine M. Lee, and Sylvia J. Arbelbide, tech. eds., Evaluation of EIS
                                         Alternatives by the Science Integration Team, Vol. 1, Forest Service, Pacific Northwest Research
                                         Station, General Technical Report PNW-GTR-406 (Portland, Ore.: 1997) and Western National Forests:
                                         Catastrophic Wildfires Threaten Resources and Communities (GAO/T-RCED-98-273, Sept. 28, 1998).



                                         Page 75                                                   GAO/RCED-99-64 Ecosystem Planning
                              Appendix II
                              Deficiencies in Developing a Management
                              Plan for the Interior Columbia River Basin
                              Have Resulted in Delays and Unfulfilled
                              Promises




The Forest Service and        According to the Forest Service and BLM, the preferred management
BLM Overestimated the         alternative in the draft environmental impact statements—which, they
Volume of Federal Timber      said, would have aggressively restored forest, rangeland, and watershed
                              health through active management—would have reversed the trend of
to Be Harvested Under         declining timber harvests on federal lands in the basin. Data on recent
Their Preferred Alternative   timber harvests that we obtained from the agencies, which were not
                              included in the draft environmental impact statements, showed that,
                              according to the Forest Service and BLM, the volume of timber that would
                              have been harvested from federal lands in the basin under the preferred
                              alternative would have exceeded by 81 percent the volume harvested in
                              fiscal years 1996 and 1997 under the three interim management strategies.
                              However, our review indicates that the agencies overestimated the volume
                              of federal timber to be sold under their preferred management alternative,
                              just as they did under the Northwest Forest Plan.

                              Under their preferred alternative, the Forest Service and BLM estimated
                              that an average of about 1.7 billion board feet per year would have been
                              harvested over the first 10 years of plan. Other alternatives, including the
                              one that emphasized the production of goods and services, would have
                              yielded even higher volumes of timber. However, federal regulatory
                              agencies have expressed concern, as they have for other planning efforts,
                              that the preferred alternative’s emphasis on active management would
                              have caused unacceptable environmental consequences.60 In addition, as
                              the Forest Service did in developing some of the first forest plans,61 the
                              Forest Service and BLM developed the management alternatives without
                              reference to likely funding levels.62 The agencies’ preferred alternative and
                              their estimate of timber output were predicated on a significant increase in
                              appropriated funds, which they are not likely to receive. The regulatory
                              agencies’ concerns and fiscal constraints would have reduced the volume
                              of federal timber to be harvested under the preferred management
                              alternative.

                              Projections of the volume of timber to be harvested from federal lands in
                              the basin may also be reduced in response to new information and events.
                              Legislative requirements to consider new information and events, such as

                              60
                               See, for example, Tongass National Forest: Lack of Accountability for Time and Costs Has Delayed
                              Forest Plan Revision (GAO/T-RCED-97-153, Apr. 29, 1997) and Forest Service Decision-Making: A
                              Framework for Improving Performance (GAO/RCED-97-71, Apr. 29, 1997).
                              61
                               Forest Service: Issues Related to Managing National Forests for Multiple Uses (GAO/T-RCED-96-111,
                              Mar. 26, 1996).
                              62
                                In their October 8, 1998, letter to Members of Congress, the Secretaries of Agriculture and the
                              Interior said they had asked the regional executives to develop a plan that can accommodate a range
                              of funding levels for Congress and the administration to consider.



                              Page 76                                                     GAO/RCED-99-64 Ecosystem Planning
                                 Appendix II
                                 Deficiencies in Developing a Management
                                 Plan for the Interior Columbia River Basin
                                 Have Resulted in Delays and Unfulfilled
                                 Promises




                                 the listing of a new species under the Endangered Species Act, have made
                                 it difficult for the Forest Service and BLM to predict when any decision can
                                 be considered final and can be implemented, reducing the agencies’ ability
                                 to achieve the objectives in their plans.63

Federal Regulatory Agencies      Although the Forest Service and BLM are responsible for managing their
Were Critical of the Preferred   lands to sustain multiple uses, including timber production, federal
Alternative                      regulatory agencies are responsible for implementing and enforcing
                                 environmental laws and regulations on those lands. Because of their
                                 disparate missions and responsibilities, federal regulatory agencies
                                 sometimes disagree with federal land management agencies on an
                                 acceptable level of risk to individual natural resources and on the best
                                 approaches for achieving environmental objectives.

                                 Failure to reach agreement with the federal regulatory agencies almost
                                 certainly ensures that a plan will not be implemented. In particular, the
                                 Fish and Wildlife Service and the National Marine Fisheries Service will
                                 formally consult with the Forest Service and BLM under section 7 of the
                                 Endangered Species Act before any decision is reached on a basinwide
                                 plan. If the regulatory agencies find that the proposed management
                                 alternative does not meet the requirements of the Endangered Species Act,
                                 they will issue a jeopardy opinion—an opinion that asserts that the
                                 alternative would appreciably reduce the likelihood of a listed species’
                                 survival and recovery. The issuance of a jeopardy opinion would
                                 effectively prevent the plan from being implemented as proposed.

                                 In commenting on the draft environmental impact statements, three
                                 federal regulatory agencies—the National Marine Fisheries Service, the
                                 Fish and Wildlife Service, and the Environmental Protection
                                 Agency—expressed concern that the management alternative preferred by
                                 the Forest Service and BLM would not adequately protect species’ habitat,
                                 water quality, or other natural resources and would therefore not meet the
                                 minimum requirements set by such laws as the Clean Water Act and the
                                 Endangered Species Act. The planning effort’s interdisciplinary and
                                 interagency Science Integration Team, although not possessing the
                                 authority of the regulatory agencies, raised similar concerns about the
                                 preferred alternative.

                                 The three federal regulatory agencies and the Science Integration Team
                                 criticized the assertion by the Forest Service and BLM that active


                                 63
                                  Forest Service Decision-Making: A Framework for Improving Performance (GAO/RCED-97-71,
                                 Apr. 29, 1997).



                                 Page 77                                                GAO/RCED-99-64 Ecosystem Planning
Appendix II
Deficiencies in Developing a Management
Plan for the Interior Columbia River Basin
Have Resulted in Delays and Unfulfilled
Promises




management could continue at current or higher levels. They were
concerned that the high level of activity being proposed, even if done in
the name of ecological restoration, would have unacceptable
consequences on species’ habitat and water quality.

For instance, the Science Integration Team wrote, in discussing the need
for active versus passive restoration, that “there are instances where
long-term benefits [of active restoration] may not exceed short-term
environmental costs or adverse ecosystem impacts, making a passive
restoration approach more appropriate.” One consequence of less
emphasis on active management and more emphasis on passive
management would be less timber sold. (Other consequences, according
to the agencies, would be fewer activities such as prescribed burning and
noxious weed treatment.)

The National Marine Fisheries Service expressed concern that efforts to
restore lands above valley floors and streams (upland areas), which would
include timber harvesting, would further degrade already degraded aquatic
ecosystems and would likely cause further extinction of aquatic species.
The Environmental Protection Agency expressed concern that “aggressive
restoration” under the agencies’ preferred alternative would likely cause
road construction and logging in otherwise roadless areas that provide
habitat for many different species. The agency commented that such
restoration could pose “a significant risk to aquatic and terrestrial
resources—both in the short and long term.” The Fish and Wildlife Service
commented that the alternatives did not “adequately address recovery of
listed species, nor preclude the need for future listings in context with
land management.”

The regulatory agencies proposed specific changes to the preferred
management alternative that would have restricted commodity
production. For example, the Fish and Wildlife Service recommended that
a particular standard be modified to protect additional large-diameter
Douglas fir trees. The National Marine Fisheries Service recommended
that the preferred alternative be amended to restrict timber harvesting in a
larger portion of riparian areas and old-growth forests. The agency also
commented that the preferred alternative attempted to meet only the
minimum requirements for listed and sensitive species and that managing
to these “lower limits” was not acceptable. Reducing the acreage
available for timber harvesting and reducing the risk to listed and sensitive
species would result in less timber being sold.




Page 78                                      GAO/RCED-99-64 Ecosystem Planning
                                Appendix II
                                Deficiencies in Developing a Management
                                Plan for the Interior Columbia River Basin
                                Have Resulted in Delays and Unfulfilled
                                Promises




Budgetary Constraints Will      Because the trees to be harvested under the preferred management
Limit the Volume of Timber to   alternative often would have had low or no commercial value, the revenue
Be Sold or Harvested            generated from them would not have covered the costs of their removal.
                                For instance, while pointing out that small-diameter trees have become
                                much more prevalent in today’s forests, the Science Integration Team
                                observed that the trees would be difficult for the agencies to sell,
                                particularly if the alternative required expensive logging methods, such as
                                removing trees with helicopters rather than trucks, to reduce the impact of
                                logging on the lands. The project team estimated that the agencies would
                                need significant additional appropriations to implement the preferred
                                alternative’s active restoration approach.

                                The Forest Service and BLM estimated in 1997 that fully funding the
                                preferred alternative’s implementation would cost approximately
                                $268 million per year. Funding at this level would require federal land
                                management and regulatory agencies to obtain an increase in current
                                funding levels of about $137 million, or about twice their current levels for
                                the sort of work described in the draft environmental impact statements.

                                We believe that the costs of aggressively restoring forest, rangeland, and
                                watershed health through active management, as the Forest Service and
                                BLM originally proposed, would be likely to require even more appropriated
                                funds than the agencies estimated. For example, agency officials and
                                outside analysts agree that one restoration activity—harvesting
                                small-diameter trees to reduce the risk of catastrophic wildfire—may
                                require hundreds of millions of dollars a year in appropriated funds.64 Our
                                preliminary analysis of the Forest Service’s fuel reduction costs indicates
                                that about $725 million a year may be needed through fiscal year 2015 to
                                treat the 39 million acres in the interior West at high risk of uncontrollable
                                wildfire. The interior Columbia River basin falls completely within the
                                interior West and contains a significant portion of the 39 million acres at
                                high risk.

                                At a May 15, 1997, congressional hearing, the Chairman of the
                                Subcommittee on Interior and Related Agencies, Senate Committee on
                                Appropriations, informed the Forest Service and BLM that it would be
                                virtually impossible to come up with the money needed to implement the
                                preferred management alternative. Other members of the Senate
                                Committee on Appropriations also expressed reservations about the



                                64
                                 Western National Forests: A Cohesive Strategy Is Needed to Address Catastrophic Wildfire Threats
                                (GAO/RCED-99-65, Apr. 2, 1999).



                                Page 79                                                    GAO/RCED-99-64 Ecosystem Planning
                             Appendix II
                             Deficiencies in Developing a Management
                             Plan for the Interior Columbia River Basin
                             Have Resulted in Delays and Unfulfilled
                             Promises




                             future availability of appropriated funds to implement the agencies’
                             preferred alternative.

                             The Fish and Wildlife Service and the Environmental Protection Agency
                             have also raised doubts about the availability of funds. In commenting on
                             the draft environmental impact statements, the Fish and Wildlife Service
                             recommended “that continued effort to define and implement a selected
                             alternative be based on reasonably predictable human and fiscal
                             resources.” The Environmental Protection Agency commented that “given
                             the large increase in projected restoration activities, there is some
                             question as to whether full implementation is possible under current
                             funding levels, as assumed in the [draft environmental impact
                             statements].”

                             The draft environmental impact statements did not assess the impact of
                             lower funding levels on environmental restoration, commodity production,
                             or local economic activity. However, the Forest Service and BLM estimated
                             that about 45 percent of their costs to implement the preferred alternative
                             would have been for timber harvesting. Therefore, less than full funding
                             would probably have reduced the volume of timber sold or harvested.

New Information and Events   As has occurred in the Pacific Northwest, the volume of timber to be sold
May Reduce the Volume of     from federal lands in the basin may also be reduced in response to new
Timber Sold                  information and events. Additional species could be listed as endangered
                             or threatened, or habitat deemed critical to listed species’ protection could
                             be designated, under the Endangered Species Act. Additional agreements
                             with nonfederal landowners could be signed that would require federal
                             lands to assume more responsibility for protecting wildlife and fish.
                             Additional analyses and assessments at the subbasin and watershed levels
                             could reduce the acreage available for multiple uses. Finally, additional
                             lands could be set aside for conservation—as wilderness, wild and scenic
                             rivers, national monuments, and recreational areas. Any one of these
                             events could reduce the agencies’ ability to achieve the commodity
                             objectives in their plan.




                             Page 80                                      GAO/RCED-99-64 Ecosystem Planning
Appendix III

Comments From the Northwest Forest
Plan’s Regional Interagency Executive
Committee
Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.




See comment 1.




                             Page 81   GAO/RCED-99-64 Ecosystem Planning
                 Appendix III
                 Comments From the Northwest Forest
                 Plan’s Regional Interagency Executive
                 Committee




See comment 2.



See comment 3.




                 Page 82                                 GAO/RCED-99-64 Ecosystem Planning
               Appendix III
               Comments From the Northwest Forest
               Plan’s Regional Interagency Executive
               Committee




               The following are GAO’s comments on the Regional Interagency Executive
               Committee’s letter dated April 5, 1999.


               1. We agree that there are many components to the plan besides the timber
GAO Comments   program and many ways to measure the benefits of the Northwest Forest
               Plan besides commodity production. Components of the Northwest Forest
               Plan, such as interagency coordination and monitoring, are discussed in
               detail in the report. The aquatic conservation strategy and the potential
               contribution of the plan to the overall health of the ecosystem are also
               discussed in the report. However, we could not provide more detail
               because many of the plan’s contributions, especially to the overall health
               of the ecosystem and its sustainability, will not be fully realized for many
               years. Additionally, as we noted in March 1998 testimony,65 the Forest
               Service has not developed objective, verifiable accomplishment measures
               and criteria that focus on actual improvements and gauge longer-term (5-
               to 10-year) trends in the condition of specific resources or attributes of
               environmental quality. Therefore, it is not yet possible to accurately
               measure the plan’s contributions to improved ecosystem sustainability,
               healthier forests, and cleaner water. Finally, our review of the Northwest
               Forest Plan was limited to the regional plan developed to provide
               management direction for 22.3 million acres of federal lands in the Pacific
               Northwest and did not include the plan’s other major component—an
               economic adjustment (worker and community assistance) initiative.

               2. In our report, we compare federal timber sale levels for three important
               periods: (1) the 10-year period (fiscal years 1980-89) prior to the federal
               court injunctions that brought timber sales to a virtual halt, (2) the level of
               timber sales under the injunctions (fiscal years 1990-94), and (3) the
               projected level of timber sales during the first decade after the injunctions
               were lifted (fiscal years 1995-2004). Additionally, the graphs in this report
               provide timber sale and other data by year for fiscal years 1980-98.

               3. We recognize that technological improvements have allowed some mills
               in the Pacific Northwest to make better use of smaller-diameter trees.
               However, as stated in our report, the quality, and thus the commercial
               value, of trees harvested from federal lands in the Pacific Northwest has
               declined.




               65
                Forest Service: Lack of Financial and Performance Accountability Has Resulted in Inefficiency and
               Waste (GAO/T-RCED-98-135, Mar. 26, 1998).



               Page 83                                                    GAO/RCED-99-64 Ecosystem Planning
Appendix IV

Comments From the Interior Columbia
Basin Ecosystem Management Project’s
Executive Steering Committee
Note: GAO comments
supplementing those in the
report text appear at the
end of this appendix.




See comment 1.




See comment 2.

See comment 3.

See comment 4.



See comment 3.




                             Page 84   GAO/RCED-99-64 Ecosystem Planning
                 Appendix IV
                 Comments From the Interior Columbia
                 Basin Ecosystem Management Project’s
                 Executive Steering Committee




See comment 5.




                 Page 85                                GAO/RCED-99-64 Ecosystem Planning
Appendix IV
Comments From the Interior Columbia
Basin Ecosystem Management Project’s
Executive Steering Committee




The following are GAO’s comments on the Interior Columbia Basin
Ecosystem Management Project’s Executive Steering Committee’s letter
dated April 6, 1999.

1. We agree that there are important differences in the size and complexity
of the areas addressed by the Interior Columbia Basin Ecosystem
Management Project and the Northwest Forest Plan that have contributed
to the differences in the amount of time and money spent on each. We did
not intend to suggest that the two plans should have been completed over
a similar period of time at a comparable cost. Rather, our point with
respect to the interior Columbia River basin plan was that it has taken
significantly longer and cost much more than the agencies anticipated. We
revised the body of our report to emphasize some of the differences
between the two plans, noting that the interior Columbia River basin plan
covers a larger geographical area and its development included more
opportunities for public participation.

2. We consider the Committees’ commitment to issuing a supplemental
draft environmental impact statement for public comment in September
1999 and to completing the project by March 2000 to be fully responsive to
the recommendation in our draft report that the interagency team be
directed to establish a time line for revising the draft plan. We therefore
updated the time line in the report to reflect these dates (see table
II.1) and deleted this recommendation.

3. It is apparent from the Committee’s comments and from the Secretaries’
October 8, 1998, letter to Members of Congress that the interior Columbia
River basin plan will not provide a comprehensive blueprint for managing
the federal lands in the basin. According to the Committee, the
supplemental draft environmental impact statement will include the best
estimate that science can provide of the effects of their proposed actions
and will give land managers enough direction to make site-specific project
decisions in the context of broad-scale information. Later in their
comments, the Committee wrote that the land management agencies’
plans have traditionally provided specific prescriptions for such things as
timber harvests and grazing levels but that this type of prescription would
be inappropriate for a plan at the scale of the basin.

In a draft of this report, we recommended that the project identify the
ecological and socioeconomic trade-offs among the different land
management alternatives and provide land managers with clear direction
and performance standards for implementation. We acknowledge that the



Page 86                                     GAO/RCED-99-64 Ecosystem Planning
Appendix IV
Comments From the Interior Columbia
Basin Ecosystem Management Project’s
Executive Steering Committee




environmental impact statement and final plan for the interior Columbia
River basin cannot be as specific with respect to trade-offs or performance
standards as the plans for managing national forests or BLM lands. We
therefore revised the recommendation to refer only to those issues that
the agencies determine need to be addressed at a basinwide scale.
Nevertheless, we continue to believe that, for those basinwide issues, the
agencies must thoroughly describe the ecological and socioeconomic
trade-offs of the different management approaches so that the Congress,
the public, and other interested parties can meaningfully evaluate the
different alternatives.

Because a basinwide impact statement or record of decision will not be
able to describe in detail all management activities throughout the basin,
additional management decisions will have to be made at a scale smaller
than the basin. We are reminded of early estimates by the agencies that a
basinwide scientific assessment and decision would cut their planning
costs in half. Therefore, we also revised the recommendation to stress that
it is important for the agencies to tell the public and the Congress how this
decision-making process will unfold, how much it will cost, and how long
it will take.

4. The Committee commented that it has received clear direction from the
Secretaries of Agriculture and the Interior to recognize budget realities
and the requirements of environmental laws in completing the project.
However, because the supplemental statement and subsequent planning
documents have not yet been issued and the team’s actions are not
complete, we made no changes to our recommendation.

5. To avoid the implication that the agencies withdrew any of their original
management alternatives, we revised the report to say that they are
developing one or more new alternatives.

In addition to the agency letter printed in this appendix, the Committee’s
comments included an attachment with several technical observations on,
for example, the estimated budget for the project in fiscal year 2000. We
have revised the report to respond to these comments, where appropriate.

The attachment also included another substantive issue. The Committee
said our report should not evaluate the effectiveness of the strategy solely
on the basis of its impact on timber production. They emphasized the
importance of the plan for other variables, including the habitats of
wildlife such as salmon, bulltrout, grizzly bear, lynx, and 187 other species



Page 87                                       GAO/RCED-99-64 Ecosystem Planning
Appendix IV
Comments From the Interior Columbia
Basin Ecosystem Management Project’s
Executive Steering Committee




of concern. We agree that the interior Columbia River basin plan reviewed
in this report should ultimately be evaluated on the basis of much more
than its impact on timber production. However, the plan is still in the
proposal phase and its ecological benefits have yet to be achieved. While
our discussion of the interior Columbia River basin plan’s potential impact
on timber production is also speculative, one of our three objectives was
to report on the actual or expected effect of the plan on the quantity and
quality of timber sold from federal lands.




Page 88                                     GAO/RCED-99-64 Ecosystem Planning
Appendix V

Objectives, Scope, and Methodology


              Concerned about the potential costs, time, and effectiveness of
              broad-scoped, ecosystem-based analyses and studies, the Chairmen of the
              Senate Committee on Energy and Natural Resources, the House
              Committee on Resources, and the House Committee on Agriculture asked
              us to examine the Northwest Forest Plan and the Interior Columbia Basin
              Ecosystem Management Project.

              In this report, we used as criteria the practical steps in implementing an
              ecosystem approach to federal land management and identified
              deficiencies and barriers within the federal land management agencies’
              decision-making processes to discuss (1) the extent to which each effort
              has addressed long-standing planning deficiencies, (2) the problems
              encountered by the agencies that have contributed to delays and increased
              costs, and (3) the effect that the plans have had, or are expected to have,
              on the quantity and quality of timber sold from federal lands covered by
              the plans.

              Our review of the Northwest Forest Plan was limited to the regional plan
              developed to provide management direction for 22.3 million acres of land
              managed by the Forest Service and BLM in the Pacific Northwest. We did
              not review the plan’s other major component—an economic adjustment
              initiative to assist workers, tribes, and communities affected by reductions
              in federal timber harvests. In addition, in performing our work, we did not
              evaluate any scientific documents or conclusions used or being used in
              either the Northwest Forest Plan or the Interior Columbia Basin
              Ecosystem Management Project.

              For our review of the Northwest Forest Plan, we met with, and examined
              documents provided by, managers and staff from the interagency group
              established to help managers implement the plan. We also contacted
              officials or reviewed documents from (1) the Forest Service’s Pacific
              Northwest (Region 6) and Pacific Southwest (Region 5) offices and its
              Pacific Northwest Research Station, (2) BLM’s California and Oregon state
              offices, and (3) Agriculture’s Office of Forestry and Economic Assistance.
              In addition, we spoke with officials from (1) the Department of the
              Interior’s Fish and Wildlife Service and (2) the Department of Commerce’s
              National Marine Fisheries Service about issues pertaining to the
              Endangered Species Act. We also spoke with officials from (1) the
              Environmental Protection Agency, (2) Interior’s Bureau of Indian Affairs,
              and (3) the Small Business Administration about issues pertaining to
              interagency coordination and cooperation. Finally, we also met with and




              Page 89                                      GAO/RCED-99-64 Ecosystem Planning
Appendix V
Objectives, Scope, and Methodology




obtained information from representatives of environmental groups and
timber industry organizations.

For our review of the Interior Columbia Basin Ecosystem Management
Project, we examined proposed management alternatives in draft
environmental impact statements. In the course of our work, we also met
with and obtained documents provided by project managers and staff,
including the past and current team leaders. We also spoke with and
obtained information relevant to the proposed plan from environmental
groups, industry, county associations, and a Forest Service employee
group.

We performed our work from September 1997 through March 1999 in
accordance with generally accepted government auditing standards. We
obtained comments on a draft of this report from senior regional officials
responsible for the two plans. These comments and our responses are
presented in appendixes III and IV.




Page 90                                     GAO/RCED-99-64 Ecosystem Planning
Appendix VI

Major Contributors to This Report


                        Ross Campbell
Energy, Resources,      Charles S. Cotton
and Science Issues      Charles T. Egan
                        Elizabeth R. Eisenstadt
                        Cheryl Pilatzke


                        Doreen Stolzenberg Feldman
Office of the General
Counsel




(141095)                Page 91                      GAO/RCED-99-64 Ecosystem Planning
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