oversight

Tongass National Forest: Lack of Accountability for Time and Costs Has Delayed Forest Plan Revision

Published by the Government Accountability Office on 1997-04-29.

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

                    United States General Accounting Office

GAO                 Testimony
                    Before the Committee on Energy and Natural Resources,
                    U. S. Senate




For Release
on Delivery
Expected at
                    TONGASS NATIONAL
10:00 a.m. EDT
Tuesday             FOREST
April 29, 1997



                    Lack of Accountability for
                    Time and Costs Has
                    Delayed Forest Plan
                    Revision
                    Statement by Barry T. Hill, Associate Director
                    Energy, Resources, and Science Issues
                    Resources, Community and Economic
                    Development Division




GAO/T-RCED-97-153
    Mr. Chairman and Members of the Committee:

    We are pleased to be here today to discuss the decision-making process
    being used by the Department of Agriculture’s Forest Service to revise the
    land management plan for the Tongass National Forest in southeastern
    Alaska.1 As requested, we will compare the results of our work for you and
    Chairmen Stevens and Young on the agency’s process for revising the
    Tongass forest plan with the findings in the report2 we are issuing today to
    you and other requesters on the causes of inefficiency and ineffectiveness
    throughout the Forest Service’s decision-making process.

    Our work on the Forest Service’s process for revising the Tongass forest
    plan showed the following:

•   The Forest Service originally planned to spend 3 years revising the plan. At
    the end of 3 years, the agency had spent about $4 million. However, the
    Forest Service has spent another 7 years and $9 million3 (1) studying and
    restudying issues without establishing a clear sequence or schedule for
    their timely resolution; (2) attempting to reconcile its older emphasis on
    producing timber with its more recent emphasis on sustaining wildlife and
    fish; and (3) attempting to reach agreement with federal regulatory
    agencies on an acceptable level of risk to individual natural resources,
    such as endangered and threatened species, water, and air. Our Forest
    Service-wide work identified that these factors have contributed to
    inefficiency in decision-making throughout the agency.
•   In revising the Tongass forest plan, the Forest Service has incurred
    unexpected delays and high costs to better ensure that the new plan is
    legally defensible, scientifically credible, and able to sustain the forest’s
    resources. Here, as elsewhere, developing a forest plan to avoid or prevail
    against legal challenges has become increasingly time-consuming and
    costly. On the Tongass, insufficient data and scientific uncertainty have
    hindered the development of a plan that can ensure the maintenance of
    viable populations of animals. As an option to further study and planning
    without resolution, the Forest Service may be able to move forward with a
    decision conditioned on an adequate monitoring component and modify
    the decision when new information is uncovered or when preexisting
    monitoring thresholds are crossed. However, as our report states, the

    1
     The process used by the Forest Service to revise the Tongass land management plan is discussed in
    detail in app. I.
    2
      Forest Service Decision-Making: A Framework for Improving Performance (GAO/RCED-97-71,
    Apr. 29, 1997).
    3
     The Forest Service’s costs to revise the Tongass plan are detailed in app. II.



    Page 1                                                                            GAO/T-RCED-97-153
                            Forest Service has historically failed to live up to its own monitoring
                            requirements. As a result, federal regulatory agencies and other
                            stakeholders continue to insist that the Forest Service prepare
                            increasingly time-consuming and costly detailed environmental analyses
                            and documentation before making a decision—effectively front-loading
                            the process and perpetuating the cycle of inefficiency.
                        •   While the agency is being held accountable for developing a plan that may
                            be legally defensible, scientifically credible, and able to sustain the forest’s
                            resources, it is not being held accountable for making a timely, orderly,
                            and cost-effective decision. Accountability fixes responsibility and implies
                            a consequence for making—or, in the case of revising the Tongass plan,
                            not making—a certain decision. However, the costs of the Forest Service’s
                            indecision in revising the Tongass plan are being borne, not by the
                            decisionmakers, but rather by the American taxpayer and by the members
                            of the public who are concerned about maintaining the forest’s diverse
                            species but are precluded from forming reasonable expectations about the
                            forest’s health over time and/or are economically dependent on the
                            Tongass but are uncertain about the future availability of its uses.

                            Mr. Chairman, our report identifies a framework for breaking the cycle of
                            inefficiency by improving the Forest Service’s decision-making. In
                            particular, we believe that the Government Performance and Results Act
                            of 1993, if implemented successfully, will strengthen accountability for
                            performance and results within the Forest Service and improve the
                            efficiency and effectiveness of its decision-making.


                            Among its findings, our report notes that inefficiency in the Forest
Delays and Increased        Service’s decision-making process can result when (1) the agency
Costs in Revising the       identifies issues but then conducts continual and/or multiple studies to
Tongass Plan Can Be         address them without establishing any clear sequence for their timely
                            resolution; (2) stakeholders, both inside and outside the agency, cannot
Traced Primarily to         agree on how the Forest Service is to resolve conflicts among competing
Three Factors               uses on its lands and needed improvements are delayed; and (3) the Forest
                            Service and federal regulatory agencies cannot agree on an acceptable
                            level of risk to endangered and threatened species, water, air, and other
                            individual natural resources. The Forest Service’s process for revising the
                            Tongass forest plan illustrates how each of these factors affects the
                            efficiency of the agency’s decision-making.




                            Page 2                                                        GAO/T-RCED-97-153
Issues Have Been          On the Tongass, as elsewhere, the Forest Service tends to study and
Identified but Not        restudy issues without reaching closure. For example, a scoping process
Resolved                  begun in 1987 identified wildlife and fish habitats as two issues needing
                          special attention in revising the Tongass plan. The Forest Service team
                          revising the plan established a committee—the “viable population”
                          committee—to study the viability of various old-growth-dependent
                          species. In 1992, this committee produced a draft strategy for preserving
                          wildlife, which was reviewed twice—first by a wildlife ecologist from the
                          Forest Service’s Pacific Northwest Research Station (a research arm of the
                          agency) and later in a report by the research station, which contained 18
                          individual scientific reviews and a legal review. Also in 1992, the Forest
                          Service team revising the plan performed its own study of the viability of
                          wildlife and fish. This study, which included an examination of the viable
                          population committee’s strategy, was also reviewed by the research
                          station.

                          In 1994, a new regional forester expanded the team revising the plan by
                          adding research scientists from the research station and tasked them with
                          gathering information on five issues, including wildlife viability. The
                          agency then convened six panels of experts and scientists to assess the
                          risk each of the nine alternatives presented in a third draft of a revised
                          Tongass plan could pose to particular species of wildlife. Three more
                          panels were convened to assess the potential risks posed by these
                          alternatives to terrestrial mammals, fish and riparian areas, and old-growth
                          forests. In March 1997, the Forest Service reconvened the panels to assess
                          (1) the alternatives, some of which had been modified since the third draft
                          was released for public comment in April 1996, and (2) the potential risks
                          to certain species of fish and wildlife posed by a new preferred alternative.
                          Today, the issue of wildlife viability has still not been resolved.


Agreement on Which Uses   The Forest Service also has had difficulty reconciling its older emphasis
to Emphasize Has Been     on producing timber with its more recent emphasis on sustaining wildlife
Difficult to Reach        and fish under its broad multiple-use and sustained-yield mandate.
                          Resolving disagreements over this issue within the agency delayed the
                          Tongass forest plan’s revision.

                          Our report shows that during the last 10 years, the Forest Service has
                          increasingly shifted the emphasis under its broad multiple-use and
                          sustained-yield mandate from consumption (primarily producing timber)
                          to conservation (primarily sustaining wildlife and fish). This shift is taking
                          place in reaction to requirements in planning and environmental laws and



                          Page 3                                                       GAO/T-RCED-97-153
their judicial interpretations—reflecting changing public values and
concerns—together with social, ecological, and other factors. The
increasing emphasis on sustaining wildlife and fish sometimes conflicts
with the agency’s older emphasis on producing timber and underlies the
Forest Service’s inability to achieve the goals and objectives for timber
production in many of the first forest plans, including the 1979 Tongass
plan.

When the Forest Service began to revise the Tongass plan in 1987, it was
just beginning, as an agency, to shift its emphasis from producing timber
to sustaining wildlife and fish. This shift has not been smooth and has
contributed significantly to the delays and costs incurred in revising the
plan.

For example, 3 years after the Forest Service began to revise the Tongass
forest plan, the Congress enacted the Tongass Timber Reform Act of 1990.
Among its provisions, the act (1) eliminated a special funding provision in
a 1980 act (the Alaska National Interests Lands Conservation Act)
intended to maintain the timber supply from the Tongass to the dependent
industry; (2) directed the agency to maintain buffers of standing timber
between designated streams and timber harvest areas to protect fish and
wildlife habitat, such as spawning ground for salmon; (3) designated
additional wilderness areas within the forest; and (4) designated 12
additional special management areas in which harvesting timber and
building roads are generally prohibited. The 1990 act also unilaterally
made nine modifications to long-term timber sale contracts held by two
companies—the Alaska Pulp Corporation and the Ketchikan Pulp
Company—that harvested large amounts of timber in the forest. Among
other things, the act modified the contracts to eliminate disproportionately
high harvests of old-growth timber.4

Other events reflecting the Forest Service’s increasing emphasis on
sustaining wildlife and fish also delayed the agency’s revision of the
Tongass forest plan. For example, in a 1988 decision on an appeal of the
approved forest plan for the Flathead National Forest in northwestern
Montana, the Associate Chief of the Forest Service directed the regional
forester to leave 10 percent of certain watersheds in old-growth areas
large enough to provide habitat for certain species until the regional
forester completed additional analyses of these species’ habitat
requirements. In 1990, an interagency scientific committee—established to

4
 Tongass National Forest: Contractual Modification Requirements of the Tongass Timber Reform Act
(GAO/RCED-91-133, Mar. 28, 1991) and Tongass Timber Reform Act: Implementation of the Act’s
Contract Modification Requirements (GAO/RCED-95-2, Jan. 31, 1995).



Page 4                                                                      GAO/T-RCED-97-153
                            develop a strategy for conserving the northern spotted owl in the Pacific
                            Northwest—also advocated the retention of large blocks of old-growth
                            forests to ensure the viability of populations of old-growth-dependent
                            species. Finally, in 1992, the Chief of the Forest Service announced plans
                            to reduce the amount of timber harvested by clearcutting by as much as
                            70 percent from fiscal year 1988 levels. Forest Service officials revising the
                            Tongass forest plan believed that this new information and these events
                            could have a significant impact on managing a forest that, up until then,
                            had relied primarily on even-age management (clearcutting). These
                            officials therefore believed that the new information and events needed to
                            be considered in finalizing the revised forest plan. By this time, the process
                            to revise the Tongass forest plan had entered its fifth year.

                            The Forest Service’s response to this new information and these events
                            was slowed, however, by internal disagreements concerning which
                            use—producing timber or sustaining wildlife and fish—should be
                            emphasized and how the forest should resolve conflicts or make choices
                            between these competing uses on its lands. For example, the Forest
                            Service team revising the forest plan disagreed with the viable population
                            committee’s proposed strategy for preserving certain species of wildlife on
                            the forest. The committee’s proposed strategy would have given more
                            emphasis to sustaining wildlife than the team’s preferred alternative. In
                            our view, this disagreement permeated other decision-making levels as
                            well, extending to the forest supervisors and regional foresters. The
                            friction on the Tongass over mission priorities is characteristic of an
                            agency in transition and mirrors conflicts within the Forest Service as a
                            whole—some Forest Service personnel support the agency’s shift in
                            emphasis while others continue to believe that timber should receive the
                            same priority it did in the past.


Disagreements With          Our report on the Forest Service’s decision-making process states that
Federal Regulatory          interagency disagreements have delayed forest plans and projects.
Agencies Have Also          Disagreements between the Forest Service and federal regulatory
                            agencies—including Interior’s Fish and Wildlife Service, Commerce’s
Delayed the Approval of a   National Marine Fisheries Service, and the Environmental Protection
Revised Tongass Forest      Agency (EPA)—over the best approaches to achieving environmental
Plan                        objectives and implementing laws and regulations often stem from the
                            agencies’ differing evaluations of environmental effects and risks, which in
                            turn reflect the agencies’ disparate missions and responsibilities. We found
                            that such disagreements had delayed planning for the Tongass.




                            Page 5                                                      GAO/T-RCED-97-153
                    The Forest Service’s April 1996 draft plan and preferred alternative
                    represent the intermediate results of almost 9 years of planning. Not only
                    the preferred alternative for managing the Tongass, selected by the forest’s
                    three supervisors, but also the majority of the other nine alternatives
                    presented in the April 1996 draft plan would increase the forest’s emphasis
                    on sustaining wildlife and fish and decrease the annual timber-offering
                    goal, compared with the current plan. According to the forest supervisors,
                    the preferred alternative is consistent with the Forest Service’s broad
                    multiple-use and sustained-yield mandate.

                    However, according to the federal regulatory agencies that are charged
                    with implementing and enforcing environmental laws and
                    regulations—including those to conserve and protect individual natural
                    resources, such as endangered and threatened species, water, and air—the
                    preferred alternative poses a high level of risk to wildlife and their habitat.
                    Even though the Forest Service established an interagency policy group in
                    mid-1994, which included program managers from the three regulatory
                    agencies, to advise the team revising the Tongass forest plan, all three
                    regulatory agencies criticized the April 1996 preferred alternative and
                    suggested changes to reduce the level of risk to wildlife and their habitat.

                    In particular, the Fish and Wildlife Service was concerned about the
                    preferred alternative’s guidelines for habitat management as they apply to
                    old-growth-dependent species on the Tongass, including two species that
                    have been proposed for listing under the Endangered Species Act (the
                    Alexander Archipelago wolf and the Queen Charlotte goshawk). If these
                    species are listed after a revised forest plan is approved, the Forest Service
                    could be required to reinitiate formal consultations with the Fish and
                    Wildlife Service to again amend or revise the plan. This interagency
                    disagreement has further delayed the approval of a revised Tongass forest
                    plan.


                    In the end, the Forest Service hopes to approve a revised Tongass plan
Underlying Issues   that is legally defensible, scientifically credible, and able to sustain the
Contribute to       forest’s resources. However, as its experience in revising the Tongass
Inefficiency        forest plan has shown, developing a forest plan to avoid or prevail against
                    legal challenges has become increasingly costly and time-consuming. On
                    the Tongass, insufficient data and scientific uncertainty have hampered
                    the development of a plan that can ensure the maintenance of viable
                    populations of wildlife. As an option to move beyond inclusive studies, the
                    Forest Service may be able to move forward with a decision conditioned



                    Page 6                                                       GAO/T-RCED-97-153
                            on an adequate monitoring component. However, the Forest Service has
                            historically failed to live up to its own monitoring requirements, and
                            federal regulatory agencies and other stakeholders continue to insist that
                            the Forest Service front-load the process. This preparation of increasingly
                            time-consuming and costly detailed environmental analyses and
                            documentation before making a decision has helped perpetuate the cycle
                            of inefficiency.


Developing a Legally        In a March 10, 1997, letter to you, Mr. Chairman, the Secretary of
Defensible Plan Is Costly   Agriculture stated that the Forest Service is completing a final legal review
and Time-Consuming          of its most recent preferred alternative to revising the Tongass plan to
                            ensure that it is legally defensible. In our report, we state that, according
                            to the Forest Service, it spends more than $250 million a year conducting
                            extensive, complex environmental analyses and preparing environmental
                            documents in order to comply with the requirements of the National
                            Environmental Policy Act and other environmental laws and to avoid or
                            prevail against challenges to its compliance with these laws.

                            In 1995, the Forest Service reported that it prepared about 20,000
                            environmental documents annually—more than any other federal agency.
                            In 1994 (the last year for which data are available) the agency issued
                            almost 20 percent of all the final environmental impact statements
                            prepared by federal agencies (50 out of a total of 253).

                            According to an internal Forest Service report, conducting environmental
                            analyses and preparing environmental documents consumes about
                            18 percent of the funds available to manage the national forests and
                            approximately 30 percent of the agency’s field resources. Preparing timber
                            sales on the basis of an approved forest plan usually takes another 3 to 8
                            years.

                            In March 1989, the Forest Service initiated a comprehensive review of its
                            land management process and completed a critique in May 1990. On the
                            basis of the critique, the agency proposed revisions to its planning
                            regulations5 in April 1995. These revisions were intended to, among other
                            things, clarify the nature of forest plan decisions and define the
                            appropriate scope of environmental analyses. After 2 years, the Forest
                            Service has still not finalized these revisions.



                            5
                             60 Fed. Reg. 18886 (Apr. 13, 1995).



                            Page 7                                                      GAO/T-RCED-97-153
The Forest Service’s         In his March 10th letter to you, the Secretary of Agriculture also stated that
Viability Requirement May    the Forest Service is completing a final substantive review of its most
Not Be Met                   recent preferred alternative to revising the Tongass plan to ensure that it is
                             scientifically credible and will sustain the resources of the forest. Toward
                             this end, the Forest Service has devoted substantial resources and time to
                             ensure that the revised forest plan meets a requirement in its regulations
                             relating to maintaining the diversity of animal communities. However, the
                             Forest Service has asserted that this requirement, if interpreted literally,
                             envisions an outcome that is sometimes impossible to be guaranteed by
                             any agency, regardless of the analytical resources marshalled.

                             The Forest Service’s biological diversity requirement for fish and wildlife
                             habitat—found in its regulations implementing the National Forest
                             Management Act of 1976—requires the agency to maintain well-distributed
                             viable populations of existing native and desired non-native vertebrate
                             species in the planning area. However, in the revisions proposed to its
                             planning regulations in April 1995, the Forest Service states that the
                             scientific expertise, data, and technology currently needed to conduct the
                             required assessments of species’ viability far exceed the resources
                             envisioned by the agency when the planning rule was developed, as well as
                             the resources available to any agency or scientific institution. Therefore,
                             according to the Forest Service, the viable populations requirement no
                             longer meets its expectations.

                             The proposed revisions include an option for sustaining diversity preferred
                             by the Forest Service. This option would protect the habitats of most
                             species and use the Endangered Species Act as a “fine filter” to catch and
                             support the special needs of species that otherwise would go unmet.
                             However, since the Forest Service has not finalized the proposed revisions
                             to its planning regulations, the revised Tongass forest plan must satisfy a
                             requirement that the agency asserts is sometimes impossible to meet.


The Forest Service Has Not   An option to avoid the growing delays and increasing costs incurred in
Adequately Monitored the     attempting to ensure that a decision is scientifically credible and legally
Effects of Its Decisions     defensible may be for the Forest Service to move forward with a decision
                             using the best information available. According to an interagency task
                             force chaired by the Council on Environmental Quality, an agency can
                             condition a decision—the effects of which may be difficult to determine in
                             advance because of uncertainty or costs—on the monitoring of
                             uncertainties, indicate how the decision will be modified when new
                             information is uncovered or when preexisting monitoring thresholds are



                             Page 8                                                      GAO/T-RCED-97-153
                        crossed, and reexamine the decision in light of its results or when a
                        threshold is crossed.

                        However, the Forest Service (1) has historically given a low priority to
                        monitoring, (2) continues to approve projects without an adequate
                        monitoring component, and (3) has not generally monitored the
                        implementation of forest plans as required by its current regulations. As a
                        result, federal regulatory agencies and other stakeholders will likely
                        continue to insist that the Forest Service prepare detailed environmental
                        analyses and documentation—which have become increasingly costly and
                        time-consuming—before making decisions rather than support what many
                        Forest Service officials believe to be the more efficient and effective
                        option of monitoring and evaluation.

                        Both the Fish and Wildlife Service and EPA have already expressed
                        reservations about the adequacy of the monitoring component in the
                        Forest Service’s April 1996 draft Tongass plan. In commenting on the draft
                        plan, the Fish and Wildlife Service stated that the proposed standards and
                        guidelines are too vague and will not provide for the intended
                        accountability because compliance will be difficult or impossible to
                        measure. EPA commented that the plan did not provide sufficient
                        information to clearly indicate how monitoring would be integrated into
                        the management strategy.


                        Inefficiencies within the Forest Service’s decision-making process on the
The Forest Service Is   Tongass and on other national forests lead to the inevitable
Not Accountable for     question—why? Why does an agency study and restudy issues without
the Time and Costs of   reaching closure? Why does this same agency attempt to do what it says
                        sometimes cannot be done regardless of the time and money invested?
Its Decision-Making     And why does it spend a significant portion of its limited resources on
                        conducting environmental analyses and preparing environmental
                        documents rather than on the apparently more efficient and effective
                        option of monitoring the environmental effects of its decisions?

                        Although the Forest Service is held accountable for developing forest
                        plans that may be scientifically credible and legally defensible, it is not
                        held accountable for developing them in a timely, orderly, and
                        cost-effective manner. The agency itself pays for the time and costs
                        associated with legal challenges to the scientific credibility and legal
                        defensibility of its decisions, but others bear the costs of its indecision and
                        delays. The American taxpayer bears the financial costs, while the costs



                        Page 9                                                       GAO/T-RCED-97-153
                      associated with the uncertainty of not having an approved forest plan are
                      borne by members of the public who are concerned about maintaining
                      biological diversity but are precluded from forming reasonable
                      expectations about the forest’s health over time as well as those who are
                      economically dependent on the Tongass but are precluded from forming
                      reasonable expectations about the future availability of the forest’s uses.

                      Although the Forest Service has been shifting its emphasis from
                      consumption to conservation on the Tongass as well as nationwide, the
                      Tongass continues to play an important role in the economy of
                      southeastern Alaska, and the Forest Service retains a responsibility under
                      its multiple-use and sustained-yield mandate to manage the Tongass for
                      other uses, including timber. While one long-term contract was terminated
                      and the remaining long-term contract was recently modified to terminate
                      no later than October 2000, the agency has sold, and will continue to sell,
                      timber from the forest to other companies.

                      Moreover, according to the Forest Service, many communities in
                      southeastern Alaska also depend on the Tongass to provide natural
                      resources for uses such as fishing, recreation, tourism, mining, and
                      customary and traditional subsistence. However, without an approved
                      revised plan, the communities and companies that are economically
                      dependent on the Tongass for goods and services cannot form the
                      reasonable expectations about the future availability of forest uses that
                      they need to plan or to develop long-range investment strategies.


                      Mr. Chairman, the inefficiency that is occurring in the process to revise the
The Government        Tongass plan is occurring at every decision-making level within the Forest
Performance and       Service. An internal Forest Service report estimates that inefficiencies
Results Act Could     within the agency’s decision-making process cost up to $100 million a year
                      at the project level alone. Delays in finalizing forest plans, coupled with
Provide a Framework   delays in finalizing agencywide regulations and reaching individual project
for Improving         decisions, can total a decade or longer.
Performance           Our report identifies a framework for breaking the existing cycle of
                      inefficiency by improving the Forest Service’s decision-making. We
                      identify the need to provide the agency with clearer guidance on (1) which
                      uses it should emphasize under its broad multiple-use and sustained-yield
                      mandate and how it is to resolve conflicts or make choices among
                      competing uses on its lands and (2) how to resolve environmental issues
                      that transcend its administrative boundaries and jurisdiction. Our report



                      Page 10                                                    GAO/T-RCED-97-153
also identifies the need for a systematic and comprehensive analysis of the
laws affecting the Forest Service’s decision-making to adequately address
the differences in their requirements. We believe that the Government
Performance and Results Act of 1993, if implemented successfully,
provides a framework for addressing many of these issues and will
strengthen accountability for performance and results within the Forest
Service and improve the efficiency and effectiveness of its
decision-making.

In addition, our report identifies the need to hold the Forest Service more
accountable for its performance. In the near future, the Forest Service is
required by the Government Performance and Results Act to consult with
you and to consider your views in developing a strategic plan. According
to the agency, one of the long-term strategic goals that it will discuss is
ensuring organizational effectiveness. On the basis of our report and
hearings held during the 104th and 105th Congresses, including the one
held here today, we believe that you should expect to see (1) performance
goals and measures based on improving the efficiency and effectiveness of
the agency’s decision-making process and (2) individual performance
management, career development programs, and pay and promotion
standards tied to this strategic goal.

When accountability for the efficiency and effectiveness of
decision-making is fixed, performance and results should be improved. We
believe that you should expect to see schedules for implementing
improvements to the decision-making process, including one to finalize
the proposed revisions to the agency’s planning regulations, as well as a
plan to closely monitor progress and periodically report on
performance—both of which are needed to break the cycle of studying
and restudying issues without timely resolution.

Forest Service managers should then seek out best practices that could
enhance efficiency and effectiveness. In particular, they should begin to
monitor the effects of their decisions, as they are currently required to do.
Federal regulatory agencies may then be more willing to accept a higher
level of risk to wildlife and their habitat in forest plans then they are
willing to do now.


In summary, Mr. Chairman, forest planning is, by its very nature, a
complex and difficult process involving a multitude of resources, statutory
responsibilities, and stakeholders. Moreover, solutions to some issues that



Page 11                                                     GAO/T-RCED-97-153
affect the efficiency and effectiveness of the Forest Service’s
decision-making will require the involvement of other stakeholders,
including the Congress and other federal agencies. However, we have
observed a cascading series of factors and issues resulting in inefficiencies
within the Forest Service’s decision-making process that can be traced
back to a lack of accountability for time and costs. Without being held
accountable for the efficiency of its decision-making process, the Forest
Service has allowed complexities and difficulties to become excuses for
delays and increased costs rather than challenges that must be overcome
in making timely decisions. One result has been that the agency has taken
a reactive, rather than a proactive, approach to addressing these
challenges.

As the Forest Service’s efforts to revise the Tongass plan and its planning
regulations have shown, the most likely outcomes of the Forest Service’s
current decision-making process are indecision and delay. We believe that
successful implementation of the Government Performance and Results
Act should strengthen accountability for performance and results within
the Forest Service and improve the efficiency and effectiveness of its
decision-making. However, as evidenced by the agency’s efforts to revise
the Tongass forest plan, sustained management attention within the Forest
Service and sustained oversight by the Congress will be required to ensure
the full and effective implementation of the act’s legislative mandates.

Mr. Chairman, this concludes my prepared statement. We will be pleased
to answer any questions that you or Members of the Committee may have.




Page 12                                                     GAO/T-RCED-97-153
Page 13   GAO/T-RCED-97-153
Appendix I

Process Used to Revise the Tongass Forest
Plan

                                          The U.S. Department of Agriculture’s (USDA) Forest Service has spent
                                          almost 10 years revising a land management plan, commonly called a
                                          forest plan, for the Tongass National Forest. During this time, the Alaska
                                          Region released three drafts of the plan for public comment—a June 1990
                                          draft, a September 1991 supplement to the draft, and an April 1996 revision
                                          to the supplement. As of April 1997, the Forest Service had not approved a
                                          revised forest plan for the Tongass. Figure I.1 summarizes the major
                                          events in developing a revision to the Tongass forest plan.


Figure I.1: Timeline of Major Events in
Tongass Forest Plan’s Revision
                                            1987     July        - Forest plan revision begins

                                            1990     June     - Draft forest plan released for public comment
                                                     November - Tongass Timber Reform Act enacted

                                            1991     February  - First draft of viable population (VPOP) report sent to Forest Service
                                                     September - Supplement to draft forest plan released for public comment

                                            1992     April       - Draft VPOP report published for public review

                                            1993     December - Fish and Wildlife Service receives petition to list wolf as threatened

                                            1994     March     - Pacific Northwest Research Station peer review of VPOP report published
                                                     April     - Alaska Pulp Corporation contract terminated
                                                     May       - Phil Janik becomes Alaska Region's regional forester
                                                               - Tongass land management plan team reorganized
                                                               - Fish and Wildlife Service receives petition to list goshawk as endangered
                                                     September - Environmental assessment on interim guidelines issued for public
                                                                  comment
                                                     December - Memorandum of understanding signed by Forest Service, Fish and
                                                                 Wildlife Service, and State of Alaska to prevent listings of species

                                            1995     July         - Congress passes rider prohibiting implementation of environmental
                                                                    assessment's guidelines

                                            1996     April     - Revised supplement to draft forest plan released for public comment
                                                     September - Court remands Fish and Wildlife Service decision not to list goshawk
                                                     October   - Court remands Fish and Wildlife Service decision not to list wolf

                                            1997     February    - Agreement reached between administration and Ketchikan Pulp Company
                                                                   on closure of pulp mill and termination of contract
                                                     May         - Fish and Wildlife Service must decide by May 31 whether to list subspecies




                                          At 16.8 million acres, the Tongass is the largest forest in the United States,
Background                                roughly equal in size to West Virginia (see fig. I.2). The Forest Service
                                          manages the Tongass to sustain various multiple uses, including timber,




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outdoor recreation, and fish and wildlife. The Forest Service’s Alaska
Region, headquartered in Juneau, Alaska, is responsible for managing the
forest. The Tongass is the only national forest with more than one forest
supervisor. Because of its size, the Tongass is divided into three
administrative areas—Chatham, Stikine, and Ketchikan—each of which
has an area office headed by a forest supervisor.




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                                      Process Used to Revise the Tongass Forest
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Figure I.2: Tongass National Forest




                                          Yakutat
                                                                                       Skagway
                                                                                                                                  Canada

                                                                                      Haines




                                                             Glacier Bay
                                                                National Park
                                                                 and Preserve
                                                                                                     Juneau




                                                                                                                Un
                                                                                                                ited
                                                                                                                     Sta
                                                                                                                       tes
                                                                                                   Admiralty
                                                                                                     Island
                                                                                                    National
                                                                                                   Monument
                                                          Tongass                                  Wilderness

                                                          National
                                                           Forest                          Sitka


                                                                                                                            Petersburg

                                                                                                                                         Wrangell

                                                    Pacific Ocean
                                                                                                                                                        Misty Fiords
                                                                                                                                                            National
                                                                                                                                                           Monument
                                                                                                                                                           Wilderness



                                                                                                                     Craig




                                                               Alaska
                                                                                                                                            Ketchikan
                                                                                                                           Proposed International Boundary

                                                                           Map Area
                                                                                                                                                     Prince Rupert




                                      Source: Forest Service’s Alaska Region.




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                        Also unique to the Tongass has been its use of timber contracts valid for
                        up to 50 years. In the 1950s, the Forest Service awarded three such
                        long-term contracts to timber companies to harvest timber in the Tongass.
                        A fourth contract was awarded in the l960s but was cancelled before
                        operations began. When initiated, the contracts required that each of the
                        companies construct and operate pulp mills to provide steady employment
                        in southeastern Alaska. The companies also used timber supplied under
                        contracts to operate sawmills in the region. In return, the companies were
                        to receive a guaranteed supply of timber. Federal law now generally limits
                        the duration of timber sale contracts to 10 years or less.

                        One of the three contracts awarded in the 1950s was completed in 1982. In
                        April 1994, the Forest Service terminated one of the long-term timber sale
                        contracts, asserting that the contract holder—the Alaska Pulp
                        Corporation—had breached the contract by closing its pulp mill in Sitka.
                        The contract holder in turn filed an action for breach of contract and
                        unconstitutional taking of property against the Forest Service. Litigation is
                        still pending.

                        In February 1997, the Clinton administration reached an agreement with
                        the company holding the remaining long-term timber sale contract to
                        terminate the contract on December 31, 1999, with a possible extension to
                        October 31, 2000. This agreement requires the company—the Ketchikan
                        Pulp Company—to continue operating two sawmills in southeastern
                        Alaska, and to clean up specified environmental damage resulting from its
                        operations in southeastern Alaska. In exchange, the administration will
                        supply enough timber to operate the sawmills for 3 years and will make
                        certain cash payments to the company. Each side agreed to release
                        existing or potential contract claims against the other arising out of the
                        long-term contract. In addition, the company agreed to release existing or
                        potential claims against the United States for the unconstitutional taking
                        of property related to the long-term contract.


                        The National Forest Management Act of 1976 (NFMA) requires the Forest
Federal Laws and        Service to (1) develop a land and resource management plan for each
Regulations Provide a   national forest in coordination with the land and resource management
Framework for           planning processes of other federal agencies, states, and localities and
                        (2) revise the plan at least every 15 years. A forest plan must sustain
Developing Forest       multiple uses on the forest and maintain diverse plant and animal
Plans                   communities (biological diversity). NFMA’s regulations, issued in 1979 and
                        revised in 1982, require the Forest Service to estimate the physical,



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                       Plan




                       biological, social, and economic effects of each forest management
                       alternative that the agency considers in detail in developing, amending, or
                       revising a forest plan. Economic effects include the impact on total
                       receipts to the federal government, direct benefits to forest users, and
                       employment in affected areas.

                       In accordance with the National Environmental Policy Act (NEPA), the
                       Forest Service must prepare an environmental impact statement to
                       accompany a forest plan. In preparing the statement, the agency is to seek
                       and consider public comments on the potential environmental and other
                       effects of the proposed forest plan. NEPA’s regulations require the agency
                       to discuss the direct and indirect effects of the proposed plan’s various
                       alternatives in the statement, including economic and social effects. NFMA
                       requires the Forest Service to make draft plans available to the public for
                       comment for at least 3 months prior to the plan’s adoption.

                       NFMA’s regulations also specify roles and responsibilities for developing
                       forest plans. The regulations state that the regional forester shall establish
                       regional policy for forest planning and approve all forest plans in the
                       region. The forest supervisor has overall responsibility for, among other
                       things, preparing the forest plan. The forest supervisor also appoints and
                       supervises an interdisciplinary team that is charged with developing the
                       forest plan and its accompanying environmental impact statement. The
                       team may consist of whatever combination of Forest Service staff and
                       other federal personnel is necessary to integrate knowledge of the
                       physical, biological, economic, and social sciences, as well as the
                       environment, in the planning process.


                       The Tongass was the first national forest to have an approved forest plan
The First Tongass      under NFMA. The Tongass’s 1979 forest plan designated certain areas of the
Plan Was Approved in   forest off-limits to timber harvesting and scheduled about 1.7 million of the
1979                   forest’s 5.7 million acres of commercial forest land as harvestable. This
                       land was to support an average annual allowable sale quantity of
                       450 million board feet.6

                       In 1980, the Congress passed the Alaska National Interests Lands
                       Conservation Act (ANILCA), which created 14 wilderness areas in the
                       Tongass and designated Admiralty Island and the Misty Fiords as national
                       monuments. Following ANILCA’s enactment, the Tongass’s commercial

                       6
                        The allowable sale quantity is the maximum quantity of timber that may be sold from an area of
                       suitable land covered by a forest plan over a decade. The quantity is usually expressed on an annual
                       basis as the “average annual allowable sale quantity”.



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                       forest land was further reduced by about 1.7 million acres, from 5.7 million
                       acres to about 4 million acres. ANILCA directed that at least $40 million
                       derived from timber and other receipts be made available to the Forest
                       Service to maintain the timber supply from the Tongass to the dependent
                       forest products industry at a rate of 4.5 billion board feet per decade. The
                       Forest Service amended its 1979 Tongass forest plan in 1986 to reflect
                       ANILCA’s provisions.



                       In 1987, the Forest Service began to revise the forest plan for the Tongass.
The Forest Service     The agency started by involving the public in a scoping process to identify
Began to Revise the    issues that would need special attention by the interdisciplinary team
Existing Forest Plan   developing the new forest plan. The team also started developing a
                       computer database of information about the resources on the Tongass,
in 1987                such as the location of streams and timber stands, to provide information
                       on the potential effects of a revised plan.

                       Although the Forest Service’s planning regulations specifically authorize
                       the agency to develop one plan for the entire Tongass, they do not discuss
                       the planning process in the context of a forest that is under the jurisdiction
                       of multiple supervisors. The organizational structure for the planning
                       effort from 1987 to August 1994 is identified in figure I.3.




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Figure I.3: Organizational Chart for Planning Team From 1987 to Mid-1994




                                                      Regional forester




                                                      Forest supervisors




                                                    Lead forest supervisor




                                                 Interdisciplinary team leader
                                                     Assistant team leader



            Alaska region program                    Interdisciplinary team           Area planners, specialists
                  directors



              Advisory role




                                          The organizational structure for planning consisted of a core
                                          interdisciplinary team headed by a team leader and an assistant team
                                          leader. Team members included a wildlife biologist, a lands specialist, a
                                          recreation planner, and a timber resource specialist, among others. The
                                          team leader reported directly to the Chatham Forest Supervisor, who
                                          represented all three forest supervisors and exercised day-to-day
                                          responsibilities for the plan’s development. The Alaska Region’s Director
                                          of Ecosystem Planning and Budget offered planning advice to the
                                          interdisciplinary team leader. In addition, two groups advised the team.
                                          The first group included the Forest Service’s regional directors for timber,
                                          wildlife and fish, recreation, engineering, lands, minerals, and fish and
                                          watersheds. The second group consisted of the area planners from each of



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                      the forest’s three administrative areas. This organizational structure
                      provided the interdisciplinary team with input from each of the three
                      administrative areas of the forest as well as from the regional directors
                      who are considered to be the technical experts within the Forest Service’s
                      regional office.

                      In June 1990, the Forest Service issued a draft forest plan for public
                      comment.7 The draft’s analysis centered around 11 issues identified during
                      scoping: scenic quality, recreation, fish habitat, wildlife habitat,
                      subsistence, timber harvest, roads, minerals, roadless areas, local
                      economy, and wild and scenic rivers. The draft presented seven
                      alternatives that the Forest Service could adopt to manage the Tongass but
                      did not include a preferred alternative.


                      The wildlife strategy contained in the 1990 draft of the forest plan was
A Viable Population   questioned. For example, some Forest Service staff from the three
Committee Was         Tongass administrative areas considered the approach too difficult to
Established to        implement and not scientifically supportable. Moreover, the Forest
                      Service’s approach to maintaining diverse wildlife populations was
Examine Wildlife      changing during this time. For example, in a 1988 decision on the appeal of
Species on the        the approved forest plan for the Flathead National Forest in northwestern
                      Montana, the Associate Chief of the Forest Service directed the regional
Tongass               forester to leave 10 percent of certain watersheds in old-growth areas
                      large enough to provide habitat for certain species until its regional
                      forester completed additional analyses of species’ habitat requirements. In
                      addition, in 1990 an interagency scientific committee released a
                      conservation strategy for the northern spotted owl in the Pacific
                      Northwest that advocated retaining large blocks of old-growth forests as a
                      way of ensuring population viability.8

                      In response to concerns regarding the viability of certain old-growth
                      dependent species on the Tongass, in October 1990 the interdisciplinary
                      team revising the Tongass’s forest plan established a committee to study
                      the viability of populations of various old-growth species—the “viable
                      population” committee. This committee’s principal mission was to identify
                      species whose viability might be impaired by some forest management


                      7
                       Tongass Land Management Plan Revision: Draft Environmental Impact Statement and Tongass Land
                      Management Revision: Draft Environmental Impact Statement, Proposed Revised Forest Plan, USDA,
                      Forest Service, (June 1990).
                      8
                       Thomas, et al., A Conservation Strategy for the Northern Spotted Owl: Report of the Interagency
                      Scientific Committee to Address the Conservation of the Northern Spotted Owl (1990).



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                       activities and to develop recommendations to maintain viable populations
                       for each such species. The committee was not part of the interdisciplinary
                       team.

                       Shortly after the committee was established and during the 6-month
                       period for commenting on the draft Tongass forest plan, the Congress
                       passed the Tongass Timber Reform Act of 1990. Among other things, this
                       act eliminated ANILCA’s special funding provision for maintaining the
                       timber supply from the Tongass, limited timber harvesting near certain
                       streams, designated additional wilderness areas within the Tongass, and
                       designated 12 additional special management areas in which harvesting
                       timber and building roads is generally prohibited. The act also made nine
                       modifications to the long-term timber sale contracts, including adding
                       provisions to the contracts to prohibit the disproportionate harvest of
                       old-growth timber. The Forest Service amended its 1979 Tongass forest
                       plan in February 1991 to reflect the act’s requirements.


                       To respond to the Tongass Timber Reform Act and comments received on
The Forest Service     the 1990 draft forest plan, which included questions raised about the
Decided to Prepare a   adequacy of the wildlife viability analysis in the 1990 draft forest plan, the
Supplement to the      Forest Service decided to prepare a supplement to the draft plan. In
                       February 1991, the viable population committee submitted a report to the
Draft Plan             leader of the interdisciplinary team containing a proposed strategy for
                       conserving old-growth forest and specific standards for 13 species
                       dependent on old-growth forest as habitat. As foreshadowed by the
                       strategy of the interagency scientific committee for the Pacific Northwest,
                       the report recommended the use of large tracts of old-growth reserves
                       close enough together so that local wildlife populations could interact
                       with each other. According to the report, such a system would promote
                       the interchange of genetic material between populations and maximize the
                       opportunity for recolonization should one of the populations suffer local
                       extinction. The report asserted that this strategy would affect a smaller
                       proportion of the suitable timber base than was affected by the
                       interagency scientific committee’s strategy or even by the standards
                       appearing in the 1990 draft forest plan. The report further indicated that
                       the recommended standards would only “barely assure perpetuation” of
                       certain species on the Tongass.

                       As the interdisciplinary team prepared the supplement to the draft, it
                       rejected the strategy recommended by the viability population committee.
                       The supplement indicated that the interdisciplinary team rejected the



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committee’s habitat protection recommendations because the team
considered the evidence supporting the recommendations to be
insufficient. The draft plan accompanying the supplement provided (1) for
timber sales to be managed so as to maintain large blocks of old-growth
reserves and corridors between the blocks, where compatible with other
resource objectives, and (2) for standards and guidelines to protect any
species that had been identified by the Fish and Wildlife Service, the
National Marine Fisheries Service, or the Forest Service as threatened,
endangered, sensitive, or a candidate for any of these categories.

The supplement,9 issued in September 1991 for public comment, presented
five alternatives, including a preferred alternative. The preferred
alternative was designed, in the Forest Service’s words, to “enhance the
balanced use of resources of the forest and provide a public timber supply
to maintain the Southeast Alaska timber industry.” The alternative
proposed an average annual allowable sale quantity of 418 million board
feet—down from the allowable sale quantity in the 1979 plan of 450 million
board feet. During 1991 and the spring of 1992, the viable population
committee continued to work on refining and developing its proposed
strategy for conserving wildlife in its February 1991 report and produced a
draft report for review in April 1992.10 At the request of an Alaska Region
official, a wildlife ecologist from the Pacific Northwest Research
Station—a Portland, Oregon, research arm of the Forest
Service—reviewed the draft report and concluded in July 1992 that the
report’s wildlife conservation strategy was sound. The ecologist urged
closer cooperation between the interdisciplinary team and the viable
population committee and recommended further peer review of the
committee’s draft report.

In December 1992, an Anchorage newspaper published an article accusing
the Forest Service of covering up the information contained in the viable
population committee’s draft report and of disregarding the report’s
conclusions. Forest Service officials denied the accusations and asserted
that the viable population committee’s report was only a draft, not yet
ready for public distribution, and that not enough information was
available to finalize the report. In January 1993, the Chairman of the House



9
 Tongass Land Management Plan Revision: Supplement to the Draft Environmental Impact Statement
and Tongass Land Management Plan Revision: Supplement to the Draft Environmental Impact
Statement, Proposed Revised Forest Plan, USDA, Forest Service (Aug. 1991).
10
 Suring, et al., A Strategy for Maintaining Well-Distributed, Viable Populations of Wildlife Associated
with Old-Growth Forests in Southeast Alaska, review draft (Apr. 1992).



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                      Committee on Natural Resources asked the Secretary of Agriculture to
                      investigate this matter.

                      After the 1991 supplement to the draft forest plan was released for public
                      comment but before a preferred alternative was selected, the
                      interdisciplinary team carried out another study of fish and wildlife
                      viability. This study was to be included as an appendix—known as
                      “appendix M”—to the final forest plan. Appendix M described three
                      additional risk assessments of wildlife viability performed by the
                      interdisciplinary team, one of which was based on the viable population
                      committee’s strategy. The interdisciplinary team stated in appendix M that
                      these risk assessments amounted only to hypotheses and required
                      additional data and testing. In February 1993, the interdisciplinary team
                      presented a draft of a final revised forest plan—including a record of
                      decision with a preferred alternative selected by the forest
                      supervisors—for the regional forester to sign. The regional forester did not
                      sign the record of decision.

                      Twenty-three conservation biologists and resource scientists sent a letter
                      to the Vice President in March 1993, condemning the Forest Service’s
                      treatment of its scientists and their work on the Tongass and the
                      Clearwater National Forest in Idaho. In June 1993, the House Committee
                      on Appropriations issued a report to accompany the Forest Service’s fiscal
                      year 1994 appropriations bill directing the Alaska Region to (1) assist the
                      viable population committee in completing its report and (2) seek peer
                      review of both the completed report and appendix M. The committee
                      completed a draft of its report in May 1993. By August 1993, the Alaska
                      Region’s regional forester officially requested the Forest Service’s Pacific
                      Northwest Research Station to conduct an independent peer review of
                      these documents.


                      In March 1994, the Pacific Northwest Research Station released its report,
The Strategies for    containing 18 individual scientific reviews, a legal review, and a summary
Protecting Wildlife   of the reviews and recommendations.11 The peer review gave the viable
Were Peer Reviewed    population committee’s draft report generally “high marks,” while
                      concluding that the strategy contained in appendix M was “not as
                      thorough or well motivated.” The peer review indicated that appendix M
                      needed to go further to meet the requirements of the relevant legislation.



                      11
                       Kiester, et al., Review of Wildlife Management and Conservation Biology on the Tongass National
                      Forest: A Synthesis with Recommendations (1994).



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                           The legal review concluded that while the viable population committee’s
                           strategy represented “an earnest, if highly cautious” attempt to properly
                           implement the Forest Service’s regulations for ensuring wildlife viability
                           and diversity, the proposed appendix’s strategy did “not appear to
                           implement either the spirit or the letter of these principles.” The legal
                           review also expressed doubt about the consistency of the Forest Service’s
                           proposed alternative with the Tongass Timber Reform Act’s restriction on
                           the disproportionate harvesting of old-growth timber under the long-term
                           contracts. One of the scientific reviewers also raised doubts about the
                           legal validity of the timber harvest plans outlined in the draft revised forest
                           plan, because the plans appeared to be incompatible with the agency’s
                           own proposed wildlife strategy.


                           At the end of April 1994, the Alaska Region’s regional forester retired. In
A New Regional             May 1994, the Chief of the Forest Service appointed a new regional
Forester Redefined         forester to the Alaska Region. The new regional forester requested that the
the Direction of the       1991 supplement to the draft forest plan be revised to take into account
                           new scientific knowledge about wildlife viability and new initiatives within
Forest Plan Revision       the Forest Service, among other things.

                           The regional forester identified five issues on which the revised
                           supplement would focus:

                       •   wildlife viability because of new information available from the viable
                           population committee and other sources;
                       •   caves and karst12 because of the recent discovery of world-class karst in
                           the Ketchikan area;
                       •   fish and riparian management because of new information arising from
                           an—at that time, ongoing—anadromous fish habitat study13 required by
                           the Congress and because of the importance of the fishing industry to
                           southeastern Alaska;
                       •   alternatives to clearcutting because of the Chief’s June 1992 policy to
                           reduce clearcutting in national forests by as much as 70 percent in order to
                           manage forests in a more environmentally sensitive manner; and
                       •   socioeconomic effects because of concern about how changes in
                           managing the Tongass could affect the timber and other industries,


                           12
                             Karst consists of areas underlain by soluble rocks, primarily limestone. Dissolution of the subsurface
                           strata results in areas of well-developed surface drainage that are sinkholes, collapsed channels, or
                           caves.
                           13
                            Report to Congress: Anadromous Fish Habitat Assessment, USDA, Forest Service Pacific Northwest
                           Research Station, Alaska Region (Jan. 1995).



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                                          especially in light of the then-recent shutdown of one of the region’s two
                                          pulp mills.


                                          In mid-1994, the newly appointed regional forester established a new
The New Regional                          planning team structure to revise the 1991 supplement to the draft Tongass
Forester Established a                    forest plan. The restructured planning team consisted of two groups—an
New Planning Team                         interagency policy group and an interdisciplinary team. Figure I.4
                                          identifies the revised organizational structure.
Structure
Figure I.4: Revised Organizational Structure for Tongass Planning Team



                                                                                      Pacific Northwest Research
                Regional forester
                                                 Interagency policy group                    Station director
                                                Forest supervisors, Regional
                                                    forest service officials,
                                               Managers from EPA, Fish and
                                                  Wildlife Service, National
                                               Marine Fisheries Service, State            Pacific Northwest
                Regional planning                          of Alaska                      program manager
                     director
                                                Group was disbanded in April
                                                1996 and replaced by forest
                                                       supervisors




              Co-leader for policy                                                      Co-leader for science
                    branch                                                                    branch




                 Policy branch                                                              Science branch
              (national forest staff)                                                    (research scientists)
                                                    Interdisciplinary team


       Advisory role




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The Interagency Policy       The interagency policy group was composed of Alaska Region officials,
Group Advised the            including the three forest supervisors; program managers from the U.S.
Interdisciplinary Team       Environmental Protection Agency, the Department of the Interior’s Fish
                             and Wildlife Service, and the Department of Commerce’s National Marine
                             Fisheries Service; and personnel from the State of Alaska. The group’s role
                             was to advise the interdisciplinary team on the development of the revised
                             supplement to the draft forest plan and to provide interagency
                             coordination with other federal and State of Alaska agencies. The policy
                             group was disbanded in April 1996 when the revised forest plan was issued
                             for public comment.


The Interdisciplinary Team   The interdisciplinary team is divided into two branches: a policy (also
Was Divided Into Two         called management) branch and a science branch. The regional forester
Branches                     assigned two co-leaders to the interdisciplinary team—a deputy forest
                             supervisor to head the team’s policy branch and a research scientist to
                             head the science branch. The policy and science branches coordinated
                             their efforts to develop alternatives for managing the Tongass.

The Science Branch Advised   Under the reorganized planning team structure, research scientists were
the Policy Branch            appointed to the interdisciplinary team’s science branch between the fall
                             of 1994 and early 1995 by the Director of the Pacific Northwest Research
                             Station with the concurrence of the regional forester. They included
                             scientists with backgrounds in forest ecology, wildlife biology, social
                             science, hydrology, geology, forestry, and statistics. According to Forest
                             Service officials, scientists were appointed because of concerns about the
                             scientific credibility of the wildlife strategy in the 1991 supplement to the
                             draft forest plan.

                             The research scientists gathered information primarily on the five focus
                             issues identified by the regional forester. They (1) gathered existing
                             scientific data pertaining to the Tongass, (2) reviewed various assumptions
                             and strategies used in the plan, and (3) developed estimates of risks to
                             resources that might result from various proposed management activities
                             that were eventually included in the revised supplement to the draft
                             environmental impact statement. In addition, they are developing a
                             “reconciliation” report which examines the extent to which science was
                             considered in developing the Forest Service’s new preferred alternative. In
                             most instances, the scientists did not have the time to develop new data
                             but, rather, relied on information already in existence.




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                              The regional forester and science branch scientists with whom we spoke
                              told us that although the research scientists were part of the
                              interdisciplinary team, they did not participate in developing the
                              alternatives or selecting the preferred alternative in the revised
                              supplement to the draft forest plan. Rather, the research scientists in the
                              science branch were responsible for (1) gathering information on the five
                              focus issues and forwarding it to the policy branch and (2) providing
                              comments and views on related scientific studies and indicating the risks
                              involved in adopting various management options.

                              After the policy branch had developed the alternatives to be included in
                              the revised supplement to the draft forest plan, the science branch
                              convened 11 scientific assessment panels of experts and specialists to
                              evaluate the risk each alternative could pose to the Tongass National
                              Forest’s biological systems, communities, and wildlife. Each panel
                              examined the potential effects of the nine alternatives on one of the
                              following issues: the Alexander Archipelago wolf, the northern goshawk,
                              the Sitka black-tailed deer, the marbled murrelet, the American marten,
                              the brown bear, terrestrial mammals, fish/riparian areas, old-growth
                              forests, subsistence, and socioeconomics. These panels were reconvened
                              in 1997 to assess the alternatives, some of which had been modified since
                              the revised supplement had been released for public comment in
                              April 1996.

The Policy Branch Developed   Many of the policy branch’s members were from the prior interdisciplinary
Alternatives                  team. The policy branch included national forest personnel with
                              backgrounds in fish and wildlife biology, economics, recreation planning,
                              resource information, wildlife ecology, and timber planning.

                              The policy branch was responsible for developing the alternatives in the
                              revised supplement of the draft forest plan, managing the resource
                              database, coordinating public involvement, maintaining documentation of
                              the planning process, and calculating the impact of alternatives on the
                              amount of timber available for harvest. In developing the alternatives,
                              members of the policy branch considered the scientific information
                              gathered by the science group as well as the scientists’ comments and
                              views on the risks involved in adopting various management options. The
                              two branches also worked together to summarize the findings of the 11
                              scientific assessment panels convened by the science branch and present
                              the summary to the forest supervisors to aid them in selecting a preferred
                              alternative for managing the forest. Alaska Region officials told us that
                              members of the policy branch chose the various management options,



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                            such as the size of the beach fringe and extent of wild and scenic rivers,
                            presented in each alternative.


Forest Supervisors Played   Under the planning team structure in effect from 1987 to August 1994, the
New Role in the             Chatham forest supervisor exercised day-to-day responsibility for
Restructured Team           developing the revised Tongass forest plan and directly supervised the
                            interdisciplinary team. However, under the new regional forester’s new
                            planning team structure, the three forest supervisors became members of
                            the interagency policy group whose role was to advise, rather than
                            supervise, the interdisciplinary team in developing the revised supplement
                            to the draft forest plan. This new role of the forest supervisors was
                            controversial both inside and outside the Forest Service.

                            The forest supervisors stated that they were not involved in the decision to
                            restructure the planning team or in appointing its new members, including
                            the research scientists. According to the supervisors, between August 1994
                            and September 1995, this new management structure prevented them from
                            exercising their decision-making responsibilities under NFMA with respect
                            to appointing and supervising the interdisciplinary team.

                            For example, one forest supervisor told us that the supervisors did not
                            participate in developing the alternatives or establishing the scientific
                            assessment panels. He said that if he had been responsible for supervising
                            the interdisciplinary team, he would not have convened the panels
                            because of their anticipated high costs, the lack of data on which to make
                            informed decisions, and the inadequacy of similar past efforts.

                            According to the deputy forest supervisor assigned by the regional forester
                            to head the interdisciplinary team’s policy branch, he tried to keep the
                            forest supervisors informed about the interdisciplinary team’s work but
                            generally did not ask them for direction. In addition, he told us that the
                            deputy regional manager, rather than the forest supervisors, had been
                            assigned responsibility for hiring, firing, and promoting Tongass planning
                            staff between August 1994 and September 1995.

                            The forest supervisors also believe that they were not invited to
                            participate in some key meetings held by the interagency policy group.
                            Other Forest Service officials note that the interagency policy group was a
                            large, unwieldy body that made few, if any, decisions.




                            Page 29                                                     GAO/T-RCED-97-153
                      Appendix I
                      Process Used to Revise the Tongass Forest
                      Plan




                      According to the regional forester, the forest supervisors informed him of
                      their concerns in the fall of 1995. He concluded that the communication
                      link between the deputy forest supervisor and the forest supervisors was
                      not working. He told us that from that point forward, the supervisors
                      became “reengaged” in the planning process. At about this time, the
                      supervisors began to participate in meetings held by other Forest Service
                      members of the interagency policy group. Subsequently, the forest
                      supervisors crafted the preferred alternative included in the April 1996
                      revised supplement to the draft forest plan.


                      In April 1996, the Forest Service released the revised supplement to the
The Revised           draft plan for public comment.14 The revised supplement differed
Supplement to the     substantively from the two previous versions of the draft plan that had
Draft Plan Was        been issued for public comment. The revised supplement presented nine
                      alternatives and a preferred alternative. Each alternative consisted of
Released for Public   variations of ten components: system and number of old-growth reserves,
Comment               rotation age for timber, old growth and watershed retention, method of
                      timber harvesting, extent of preservation of karst and caves, extent of
                      riparian protection, size of beach fringe, estuary protection, timber harvest
                      in watersheds, and deer winter range.

                      The three forest supervisors considered the initial nine alternatives in the
                      revised supplement before selecting a combination of components from
                      the alternatives to create their preferred alternative. The preferred
                      alternative was published separately from the bound draft plan, but it was
                      presented in the summary of the revised supplement along with the other
                      nine alternatives and was distributed with the rest of the draft plan for
                      comment.

                      The preferred alternative incorporated old-growth reserves, an average
                      100-year rotation age for timber, a combination of harvesting methods, a
                      two-aged timber harvest system, a combination of riparian protection
                      options, and an annual average allowable sale quantity of 357 million
                      board feet per year. Compared to the 1979 forest plan, the preferred
                      alternative and the majority of the other alternatives considered increased
                      the protection of wildlife habitat and decreased the amount of timber
                      available for harvesting.


                      14
                       Tongass Land Management Plan Revision: Revised Supplement to the Draft Environmental Impact
                      Statement and Tongass Land Management Plan Revision: Revised Supplement to the Draft
                      Environmental Impact Statement, Proposed Revised Forest Plan. Forest Service, Alaska Region
                      (Mar. 1996).



                      Page 30                                                                  GAO/T-RCED-97-153
                             Appendix I
                             Process Used to Revise the Tongass Forest
                             Plan




Socioeconomic Effects        The April 1996 revised forest plan and environmental impact statement for
Were Addressed               the Tongass placed heavy emphasis on regional socioeconomic effects.
                             They did not, however, attempt to quantify the economic effects on local
                             communities.

                             For example, the revised supplement examined the effects of reduced
                             timber harvesting on the timber, recreation, and fishing industries, both
                             for the region and for the nation, and expressed these effects in terms of
                             jobs and income created or lost. However, for individual communities, the
                             revised supplement described socioeconomic effects much more generally
                             than it did for the region as a whole. The revised supplement profiled each
                             of southeastern Alaska’s 32 communities separately and discussed the
                             composition of each community’s economy. However, the revised
                             supplement did not quantify the economic impact but simply stated
                             whether a proposed alternative would have a negative, positive, or
                             indifferent effect on the timber, fishing, and recreation sectors of the
                             community’s economy.

                             Forest Service economists told us that community-level effects were not
                             forecast as specifically as were regional economic effects because not
                             enough information was available about the communities and about the
                             location of future timber sales. For example, Forest Service officials told
                             us that without knowing where a timber sale will take place and how the
                             timber will be processed, the Forest Service cannot determine which
                             communities will be affected by timber sales. The 1990 draft
                             environmental impact statement and the 1991 supplement to the draft
                             environmental impact statement also did not attempt to forecast specific
                             effects on individual communities.


Content Analysis on Public   In the fall of 1995, the interdisciplinary team revising the Tongass plan
Comments Was Done by an      realized that, because of the significant media attention and public
In-House Contractor          response to Tongass planning issues, the public comments received on the
                             revised supplement to the draft forest plan would likely be too numerous
                             for them to process effectively. After considering a few outside
                             contractors who had experience in content analysis, the interdisciplinary
                             team hired an in-Service “enterprise team”15 consisting of agency
                             employees working outside of the Alaska Region and specializing in
                             content analysis. The interdisciplinary team estimated that the enterprise
                             team would be more costly to hire than an outside contractor—$160,000

                             15
                              The Forest Service recently instituted an “enterprise team” concept that brings together people with
                             certain skills and experiences in certain areas, such as audio/visual presentation, science assessment,
                             or content analysis, that can be used throughout the National Forest System.



                             Page 31                                                                          GAO/T-RCED-97-153
Appendix I
Process Used to Revise the Tongass Forest
Plan




for the in-Service team compared with $80,000 to $150,000 for an outside
team. However, the interdisciplinary team believed that the advantages of
hiring the in-Service team outweighed the higher cost. These advantages
included (1) a much faster start-up time with less demand on the
interdisciplinary team’s time; (2) a more thorough knowledge of national
forest issues; and (3) a familiarity with forest plans, terms, and concepts.

After the revised supplement to the draft plan was released for public
comment, the Forest Service held open houses and hearings in
southeastern Alaska’s 32 communities, met with interested groups, and
discussed the proposed revised plan on local media. The revised
supplement to the draft also generated public meetings and
demonstrations as well as congressional hearings. In July 1996, the
regional forester granted a 30-day extension (through late Aug. 1996) to
the 90-day comment period after considering the public comments
received to date and the interest shown by the public in extending the
comment period.

About 21,000 respondents submitted comments. In comparison, for the
1990 and 1991 drafts released for public comment, the Forest Service
received comments from about 3,700 and 7,300 respondents, respectively.

Between June 1996 and October 1996, the in-Service team analyzed the
public comments. Substantive issues, concerns, and questions raised by
commenters were identified by the in-Service team and given to the
interdisciplinary team for consideration in developing the revision to the
final plan. The in-Service team, working primarily on the Flathead National
Forest, consisted of about 40 people, including a project coordinator, 2
team leaders, computer support staff, writers/coders, data entry staff, and
editors. In addition, Alaska regional staff assisted the in-Service team.
Prior to working on the Tongass plan, the project coordinator had
performed content analyses for several projects, including NFMA
regulations, national forest plans, and environmental impact statements
and environmental assessments. Most of the coding staff were planners or
resource specialists with the National Forest System. The project
coordinator told us that because the team was not from the Tongass
National Forest, the team provided an objective, third-party view of the
public comments.

In early October 1996, the in-Service team prepared the final draft content
analysis summary displaying demographic information and specific
issue-by-issue analysis in a summary of public comments. According to the



Page 32                                                     GAO/T-RCED-97-153
                       Appendix I
                       Process Used to Revise the Tongass Forest
                       Plan




                       content analysis done by the in-Service team, (1) the majority of the public
                       comments concerned the level of timber harvesting that the preferred
                       alternative allowed, (2) over half the comments supported lowering the
                       amount of timber available for harvesting and suggested terminating or not
                       extending the Tongass’s remaining long-term timber-harvesting contract,
                       and (3) many of the respondents, especially southeastern Alaskans, were
                       worried about the social and economic effects on their communities if the
                       preferred alternative was selected.

                       The Tongass official responsible for overseeing the work done by the
                       in-Service content analysis team considered the team’s work to be
                       accurate and timely, given the large database that the team had to work
                       with and the time constraints placed on the team. The total cost for the
                       in-Service contract was $185,000.


                       As discussed earlier, in mid-1994 the newly appointed regional forester
The New Regional       established a new planning team structure to revise the 1991 supplement
Forester Acted to      to the draft Tongass forest plan. Under the new structure, the regulatory
Involve Regulatory     agencies were members of the interagency policy group established to
                       advise the interdisciplinary team and to improve interagency coordination.
Agencies in Revising
Plan                   Interagency coordination became increasingly important in December
                       1993 when the Fish and Wildlife Service received a petition to list the
                       Alexander Archipelago wolf as threatened under the Endangered Species
                       Act. In addition, in May 1994 the Fish and Wildlife Service received a
                       petition to list the Queen Charlotte goshawk as endangered under the act.
                       Both subspecies occur on the Tongass and are dependent on old-growth
                       forest as habitat. The revised Tongass forest plan, when issued, would
                       impact how these subspecies’ habitat is managed and so could be a
                       determinant in the viability of the species.

                       Besides involving the Fish and Wildlife Service in the interagency policy
                       group, in December 1994 the Forest Service signed a memorandum of
                       understanding with the Fish and Wildlife Service and the Alaska
                       Department of Fish and Game to prevent the listing of species on the
                       Tongass as endangered or threatened. The memorandum provided that the
                       agencies should assess wildlife habitat, share information about species
                       they manage, and meet regularly to discuss the status of species to reduce
                       the need to list them under federal or state endangered species acts.




                       Page 33                                                    GAO/T-RCED-97-153
    Appendix I
    Process Used to Revise the Tongass Forest
    Plan




    In addition, the Forest Service’s Alaska Region also acted independently to
    prevent the listing of the wolf, the goshawk, and other species:

•   In June 1994, the regional forester deferred timber harvesting in
    old-growth reserves that had been identified by the viable population
    committee as needed to maintain viable populations of
    old-growth-dependent species.

•   In September 1994, the Forest Service issued for comment an
    environmental assessment intended to protect the wildlife habitat of such
    species as the goshawk and the wolf while maintaining a supply of timber
    for local industry. The proposed action in the environmental assessment
    was to provide interim management guidelines to protect the species until
    the revised supplement to the draft forest plan was approved. If
    implemented, the guidelines were intended to protect those areas
    identified by the viable population committee as needed to maintain viable
    populations of old-growth-dependent species. This action was predicted to
    “likely result in measurably lower timber sale offerings to independent
    mills,” as well as defer some timber sale offerings for the Tongass’s
    remaining long-term contract. In July 1995, the Congress passed an act16
    containing a rider effectively prohibiting the Forest Service from
    implementing the management guidelines. Accordingly, the regional
    forester did not sign the environmental assessment or implement the
    guidelines.

    In 1995, the Fish and Wildlife Service found that listing the wolf and the
    goshawk under the Endangered Species Act was not warranted.
    Environmental plaintiffs challenged these decisions. In September 1996, as
    the Forest Service was reviewing public comments on the revised
    supplement to the draft plan and formulating an alternative intended to
    become the final Tongass forest plan, a federal district court remanded the
    Fish and Wildlife Service’s decision on the goshawk to the agency. In
    October 1996, the same court reached the same decision with respect to
    the wolf. In each case, the court ruled that the Fish and Wildlife Service’s
    basis for not listing the subspecies—that the revised Tongass forest plan
    would provide adequate protection for the species’ habitats—was not
    valid, since the plan had not yet been formally approved by the Forest
    Service. Instead, the court held that the Fish and Wildlife Service must
    base its decision on the current (1979, as amended) plan and the current
    status of the subspecies and its habitat.

    16
      Emergency Supplemental Appropriations for Additional Disaster Assistance, for Anti-Terrorism
    Initiatives, for Assistance in the Recovery From the Tragedy That Occurred at Oklahoma City, and
    Rescissions Act, 1995, P.L.-104-19.



    Page 34                                                                       GAO/T-RCED-97-153
Appendix I
Process Used to Revise the Tongass Forest
Plan




As a result of these court decisions, the Fish and Wildlife Service began
negotiations with the Forest Service in an attempt to ensure that the final
forest plan would prevent the need to list the goshawk or the wolf as
endangered. The Fish and Wildlife Service has until May 31, 1997, to reach
a decision on the status of these species.

Despite the involvement of federal regulatory and state agencies in
developing the revised supplement to the draft forest plan, the
Environmental Protection Agency, the Fish and Wildlife Service, and the
National Marine Fisheries Service submitted comments on the draft that
criticized the preferred alternative as posing a high level of risk to wildlife
and habitat. The Fish and Wildlife Service was concerned that harvesting
timber on a 100-year rotation, as proposed in the preferred alternative,
would prevent forests from recovering old-growth stand characteristics,
resulting in the loss of viable populations of species that depend on
old-growth forests for habitat. The Environmental Protection Agency and
the National Marine Fisheries Service favored more expansive riparian
protection than the preferred alternative provided to protect fish habitat
and water quality.




Page 35                                                       GAO/T-RCED-97-153
Appendix II

Estimated Cost of the Tongass Planning
Process

                                             During the 10 years from fiscal year 1987 through fiscal year 1996, the
                                             Forest Service’s Alaska Region spent slightly over $13 million to develop
                                             the revised Tongass land management plan and environmental impact
                                             statement. Tables II.1 and II.2 show the sources of the funds used and the
                                             cost elements charged to develop the forest plan. The tables’ totals for
                                             budgeting and spending may not match because of rounding.


Table II.1: Budget Line Item Categories for Funding the Development of the Tongass Forest Plan for Fiscal Years 1987-96
Dollars in thousands
                                                                             Fiscal year
Expanded budget line item             1987       1988      1989     1990      1991     1992       1993    1994      1995      1996     Total
Ecosystem management                    $0         $0        $0        $0       $0           $0    $0        $0 $2,056 $1,986 $4,042
Minerals                                44             0     30        46       59           32    35        24         0         0         270
Timber management                       29             0     47        93       89       796      790      603          0      135     2,581
Forest vegetation management             0             0      0         0         0          0      0         0         0        20         20
Recreation                              44             0     80      140       118           99   123        90         0         0         694
Wildlife and fish                       29             0     47        78      103           59    55        38         0         0         409
Soil, water, and air                    23             0     78      141       162       105       96        67         0         0         672
Road construction                       21             0     24        47       30           35    58        41      113         90         459
                        a
Tongass timber supply                  102        982       761    1,008       915           0      0         0         0         0    3,769
Anadromous fish habitat assessment       0             0      0         0         0          0      0      100          0        54         154
Total                                 $292       $982 $1,067 $1,553 $1,476 $1,126 $1,157                  $963 $2,169 $2,285 $13,070
                                             Note: Totals may not add because of rounding.
                                          a
                                            The Alaska National Interests Lands Conservation Act (ANILCA) of 1980 directed that at least
                                          $40 million be made available annually to support, among other things, a timber supply from the
                                          Tongass National Forest. This money went into the Tongass timber supply fund. The Tongass
                                          Timber Reform Act of 1990 repealed this ANILCA provision, and the fund ceased to exist at the
                                          end of fiscal year 1991.

                                          Source: Forest Service’s Alaska Region.



                                             As table II.1 shows, during fiscal years 1987-96, $13 million was funded
                                             from numerous Forest Service accounts to develop the plan, including
                                             ecosystem management; minerals; timber management; recreation;
                                             wildlife and fish; soil, water, and air; road construction; and Tongass
                                             timber supply. Forest Service officials were unable to provide us with
                                             information on their rationale for using the various funding accounts for
                                             fiscal years 1987-94. For fiscal years 1995 and 1996, the Forest Service
                                             began budgeting most of the funding for the plan from the ecosystem
                                             management account. An Alaska Region budget officer told us that the




                                             Page 36                                                                   GAO/T-RCED-97-153
                                             Appendix II
                                             Estimated Cost of the Tongass Planning
                                             Process




                                             ecosystem management account was established to finance large-scale
                                             planning efforts such as the Tongass plan.


Table II.2: Cost Category for the Development of the Tongass Forest Plan for Fiscal Years 1987-96
Dollars in thousands
                                                                             Fiscal year
Cost element                          1987       1988      1989     1990      1991     1992       1993      1994    1995      1996      Total
Salary                                $216       $383      $554     $808      $761     $690       $716      $615    $852      $960 $6,555
Vehicle and equipment rental             1             1      0         0         1          0       0         1        0         0            4
Materials and supplies                   5         25        29        16       14           9     31         32       23        21       205
Construction and services                0        495        60      166       186           98    61         39      184       264     1,553
Travel and training                     24         50        84        82      104           66    63         25      132       116       746
Commercial rents/utilities               1             7     20        77       70           82    73         73       82        83       568
Automated data processing                0             6    208      298       295       135       21         19      195       184     1,361
Transfer of station                      2             0      0         0         0          0       0         0        0        62           64
                                                                                                                          a         a
Other                                   44         15       114      103        45           45   191        161      702       594     2,014
Total                                 $293       $982 $1,069 $1,550 $1,476 $1,125 $1,156                    $965 $2,170 $2,284 $13,070
                                             Note: Totals may not add because of rounding.
                                           a
                                             Includes Pacific Northwest Research Station services of $463,000 in 1995 and $570,000 in 1996.
                                           About $515,000 of these costs are for personnel salaries.

                                           Source: GAO’s analysis of data provided by the Forest Service.



                                             As table II.2 shows, slightly more than $13 million was spent for salaries,
                                             travel, training, space leasing/utilities, printing/publishing, computer
                                             workstation leases/computer support services, and other equipment and
                                             supplies. Over $7 million, or 54 percent of the $13 million, was spent for
                                             staff salaries. An Alaska Region budget officer told us that some Tongass
                                             planning costs incurred by the regional forester, forest supervisors, some
                                             regional office administrative personnel, and Forest Service headquarters
                                             personnel are not included in these planning costs and are not readily
                                             available.




(140111)                                     Page 37                                                                    GAO/T-RCED-97-153
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