oversight

Forest Service Decision-Making: Greater Clarity Needed on Mission Priorities

Published by the Government Accountability Office on 1997-02-25.

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

                          United States General Accounting Office

GAO                       Testimony
                          Before the Subcommittee on Forests and Public Lands
                          Management, Committee on Energy and Natural
                          Resources, U. S. Senate


For Release on Delivery
Expected at
2:30 p.m. EST
                          FOREST SERVICE
Tuesday
February 25, 1997         DECISION-MAKING

                          Greater Clarity Needed on
                          Mission Priorities
                          Statement of Barry T. Hill, Associate Director,
                          Energy, Resources, and Science Issues,
                          Resources, Community, and Economic,
                          Development Division




GAO/T-RCED-97-81
Mr. Chairman and Members of the
Subcommittee:

                 We are pleased to be here today to discuss the preliminary results of our
                 work for you and other requesters on the decision-making process used by
                 the Department of Agriculture’s Forest Service in carrying out its mission.
                 Your draft bill—entitled the Public Land Management Responsibility and
                 Accountability Restoration Act—is designed to provide the Forest Service
                 and the Department of the Interior’s Bureau of Land Management with the
                 authority and ability to effectively manage their lands in accordance with
                 the principles of multiple use and sustained yield and for other purposes.
                 It does this by supplementing the agencies’ planning statutes and other
                 laws that apply to lands managed by the two agencies. As agreed, to help
                 frame the discussion on your draft bill, we will present our preliminary
                 views on the underlying causes of inefficiencies and ineffectiveness in the
                 Forest Service’s decision-making process.

                 During hearings held during the 104th Congress, we and others testified1
                 that the Forest Service’s decision-making process is costly and
                 time-consuming and that the agency often fails to achieve its planned
                 objectives. The agency has spent over 20 years and over $250 million
                 developing multiyear plans for managing timber production, livestock
                 grazing, recreation, wildlife and fish habitat, and other legislatively
                 mandated uses on national forests. It also spends about $250 million a year
                 for environmental studies to support individual projects. However,
                 according to an internal Forest Service report, inefficiencies within this
                 process cost up to $100 million a year at the project level alone. In
                 addition, by the time the agency has completed its decision-making, it
                 often finds that it is unable to achieve the plans’ objectives or implement
                 planned projects because of changes in natural conditions and funding, as
                 well as new information and events.

                 In summary, Mr. Chairman, our ongoing work has identified three
                 underlying causes of inefficiency and ineffectiveness in the Forest
                 Service’s decision-making process:

             •   First, the agency has not given adequate attention to improving its
                 decision-making process, including improving its accountability for
                 expenditures and performance. As a result, long-standing deficiencies
                 within its decision-making process that have contributed to increased
                 costs and time and/or the inability to achieve planned objectives have not
                 been corrected.


                 1
                  See, for example, Forest Service: Issues Relating to Its Decisionmaking Process (GAO/T-RCED-96-66,
                 Jan. 25, 1996) and Forest Service: Issues Related to Managing National Forests for Multiple Uses
                 (GAO/T-RCED-96-111, Mar. 26, 1996).



                 Page 1                                                                         GAO/T-RCED-97-81
                            Mr. Chairman and Members of the
                            Subcommittee:




                        •   Second, issues that transcend the agency’s administrative boundaries and
                            jurisdiction have not been adequately addressed. In particular, the Forest
                            Service and other federal agencies have had difficulty reconciling the
                            administrative boundaries of national forests, parks, and other federal land
                            management units with the boundaries of natural systems, such as
                            watersheds and vegetative and animal communities, both in planning and
                            in assessing the cumulative impact of federal and nonfederal activities on
                            the environment.
                        •   Third, the requirements of numerous planning and environmental laws,
                            enacted primarily during the 1960s and 1970s, have not been harmonized.
                            As a result, differences among the requirements of different laws and their
                            differing judicial interpretations require some issues to be analyzed or
                            reanalyzed at different stages in the different decision-making processes of
                            the Forest Service and other federal agencies without any clear sequence
                            leading to their timely resolution. Additional differences among the
                            statutory requirements for protecting resources—such as endangered and
                            threatened species, water, air, diverse plant and animal communities, and
                            wilderness—have also sometimes been difficult to reconcile.

                            However, on the basis of our work to date, we believe that statutory
                            changes to improve the efficiency and effectiveness of the Forest Service’s
                            decision-making process cannot be identified until agreement is first
                            reached on which uses the agency is to 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. Disagreement over
                            which uses should receive priority, both inside and outside the agency, has
                            also inhibited the Forest Service in establishing the goals and performance
                            measures needed to ensure its accountability.


                            Reducing the costs and time of its decision-making and improving its
The Forest Service          ability to deliver what is expected or promised have not been given
Has Not Given               adequate attention throughout the Forest Service. As a result, deficiencies
Adequate Attention to       within the decision-making process that have been known to the agency
                            for a decade or more have not been corrected. To compensate for the
Improving Its               increased costs and time of decision-making and the inability to
Decision-Making             implement planned projects, the Forest Service must request more annual
                            appropriations to achieve fewer planning objectives.
Process
                            The Chief Financial Officers Act of 1990 requires the agency to be more
                            accountable for its expenditures of appropriated funds by requiring it to
                            develop integrated accounting and financial management systems that are



                            Page 2                                                      GAO/T-RCED-97-81
Mr. Chairman and Members of the
Subcommittee:




to provide complete, reliable, consistent, and timely financial information.
However, the Forest Service has made little progress in implementing the
act’s provisions. An audit of the agency’s financial statements for fiscal
year 1995 by Agriculture’s Inspector General resulted in an adverse
opinion because of “pervasive errors, material or potentially material
misstatements, and/or departures from applicable Government accounting
principles affecting several Financial Statement accounts.”2 Among the
audit’s findings, the Inspector General reported that the Forest Service
could not account for expenditures of $215 million in fiscal year 1995. As a
result, Forest Service managers are unable to adequately monitor and
control spending levels for various programs and activities relating to
decision-making or to measure the extent to which changes affect costs
and efficiency. Corrective actions to address accounting and financial
reporting problems identified by the Inspector General are not scheduled
to be implemented until the end of fiscal year 1998.

Similarly, the Forest Service has not been successful in achieving the
objectives in its forest plans or implementing planned projects. For
example, in response to congressional concerns about the Forest Service
not being able to deliver what is expected or promised, the Chief, in the
fall of 1991, formed a task force of employees from throughout the agency
to review the issue of accountability. The task force’s February 1994 report
set forth a seven-step process to strengthen accountability. Steps in the
process include (1) establishing work agreements that include measures
and standards with customer involvement, (2) assessing performance, and
(3) communicating results to customers. However, the task force’s
recommendations were never implemented. Rather, they were identified
as actions that the agency plans to implement over the next decade.

The task force’s recommendations, as well as those in other studies, are
intended to address some of the long-standing deficiencies within the
Forest Service’s decision-making process that have driven up costs and
time and/or driven down the ability to achieve planned objectives. These
deficiencies include (1) not adequately monitoring the effects of past
management decisions, (2) not maintaining a centralized system of
comparable environmental and socioeconomic data, and (3) not
adequately involving the public throughout the decision-making process.

For example, adequate monitoring of the effects of past management
decisions is critical to accurately estimate the effects of similar future


2
  Audit of Forest Service’s Fiscal Year 1995 Financial Statements (Audit Report No. 08401-4-At, Office
of Inspector General, Department of Agriculture).



Page 3                                                                            GAO/T-RCED-97-81
Mr. Chairman and Members of the
Subcommittee:




decisions, including their cumulative impact. Moreover, monitoring can be
used as an effective tool when the effects of a decision may be difficult to
determine in advance because of uncertainty or costs. However, the Forest
Service (1) has historically given low priority to monitoring during the
annual competition for scarce resources, (2) continues to approve projects
without an adequate monitoring component, and (3) does not require its
managers to report on the results of monitoring, as its current regulations
require.

Because of the inefficiencies in its decision-making process, the Forest
Service must request more funds to accomplish fewer objectives during
the yearly budget and appropriation process. For example, in fiscal year
1991, the Congress asked the Forest Service to develop a multiyear
program to reduce the costs of its timber program by not less than 5
percent per year. The Forest Service responded to these and other
concerns by undertaking three major cost-efficiency studies and is
preparing to undertake a fourth. However, with no incentive to act, the
agency has not implemented any of the recommended improvements
agencywide. In the interim, the costs associated with preparing and
administering timber sales have continued to rise. As a result, for fiscal
year 1998, the agency is requesting $12 million, or 6 percent, more for
timber sales management than was appropriated for fiscal year 1997 while
proposing to offer 0.4 billion board feet, or 10 percent, less timber for sale.

The Government Performance and Results Act of 1993 is designed to hold
federal agencies more accountable for their performance by requiring
them to establish performance goals, measures, and reports that provide a
system of accountability for results. In addition, the Clinger-Cohen Act of
1996 (formerly entitled the Information Technology Management Reform
Act of 1996) and the Paperwork Reduction Act of 1995 are intended to
hold federal agencies more accountable for the adequacy of their
information systems and data by providing that they shall establish goals,
measure performance, and report on how well their information
technology and data are supporting their mission-related programs.
Although it is still too early to tell what impact these laws, together with
the Chief Financial Officers Act, will have on the Forest Service, they
provide a useful framework for strengthening accountability within the
agency and improving the efficiency and effectiveness of its
decision-making.




Page 4                                                        GAO/T-RCED-97-81
                     Mr. Chairman and Members of the
                     Subcommittee:




                     Issues that transcend the agency’s administrative boundaries and
Interagency Issues   jurisdiction also affect the efficiency and effectiveness of the Forest
Affect the Forest    Service’s decision-making process. These issues include reconciling
Service’s            differences in the geographic areas that must be considered in reaching
                     decisions under different planning and environmental laws.
Decision-Making
                     The Forest Service and other federal land management agencies are
                     authorized to plan primarily along administrative boundaries, such as
                     those defining national forests and parks. Conversely, environmental
                     statutes and regulations require the agencies to analyze environmental
                     issues and concerns along the boundaries of natural systems, such as
                     watersheds and vegetative and animal communities. For example,
                     regulations implementing the National Environmental Policy Act require
                     the agencies to assess the cumulative impact of federal and nonfederal
                     activities on the environment.

                     Because the boundaries of administrative units and natural systems are
                     frequently inconsistent, federal land management plans have often
                     considered effects only on portions of natural systems or portions of the
                     habitats of wide-ranging species, such as migratory birds, bears, and
                     anadromous fish (including salmon). For example, the Interior Columbia
                     River Basin contains 74 separate federal land units, including 35 national
                     forests and 17 Bureau of Land Management districts, each with its own
                     plan. Not analyzing effects on natural systems and their components at the
                     appropriate ecological scale results in duplicative environmental
                     analyses—in individual plans and projects—increasing the costs and time
                     required for analysis and reducing the effectiveness of federal land
                     management decision-making.

                     Addressing issues that transcend the administrative boundaries and
                     jurisdictions of the Forest Service and of other federal agencies will, at a
                     minimum, require unparalleled coordination and cooperation among
                     federal agencies. However, federal land management and regulatory
                     agencies sometimes do not work efficiently and effectively together to
                     address issues that transcend their boundaries and jurisdictions.
                     Disagreements often stem from differing evaluations of environmental
                     effects and risks, which in turn reflect the agencies’ disparate missions and
                     responsibilities.

                     Effective interagency coordination, in turn, requires comparable
                     environmental and socioeconomic data. However, the data gathered by




                     Page 5                                                      GAO/T-RCED-97-81
                      Mr. Chairman and Members of the
                      Subcommittee:




                      federal agencies are often not comparable, large gaps in the information
                      exist, and federal agencies lack awareness of who has what information.

                      Over the past few years, several major studies have examined the need to
                      reconcile the differences in the geographic areas that federal agencies
                      must consider when reaching decisions.3 Among the options that have
                      been suggested are changes to the Council on Environmental Quality’s
                      regulations and guidance implementing the procedural provisions of the
                      National Environmental Policy Act. According to Council officials,
                      changes to the act’s regulations and guidance are not being considered at
                      this time. Instead, the Council plans to rely primarily on less binding
                      interagency agreements. However, since federal agencies sometimes do
                      not work efficiently and effectively together to address issues that
                      transcend their boundaries and jurisdictions and often lack the
                      environmental and socioeconomic data required to make informed
                      decisions, strong leadership by the Council would help to ensure that
                      interagency agreements accomplish their intended objectives.


                      Finally, differences in the requirements of numerous planning and
Differences in Laws   environmental laws, enacted primarily during the 1960s and 1970s,
Affect the Forest     produce inefficiency and ineffectiveness in the Forest Service’s
Service’s             decision-making. Differences among their requirements and differing
                      judicial interpretations of their requirements have caused some issues to
Decision-Making       be analyzed or reanalyzed at various stages in the Forest Service’s
                      decision-making process, as well as in the decision-making processes of
                      other federal agencies, without their timely resolution, increasing the costs
                      and time of decision-making and reducing the ability of the Forest Service
                      and other land management agencies to achieve the objectives in their
                      plans.

                      New information and events can affect the outcomes of the Forest
                      Service’s decisions and prevent the agency from achieving the objectives
                      in its forest plans or implementing planned projects. For instance, the
                      listing of a species as endangered or threatened under the Endangered
                      Species Act after a forest plan has been approved requires the Forest
                      Service to reinitiate formal consultations with the Fish and Wildlife
                      Service and/or the National Marine Fisheries Service to amend or revise

                      3
                        See, for example, The Ecosystem Approach: Healthy Ecosystems and Sustainable Economies, Volume
                      II - Implementation Issues, Report of the Interagency Ecosystem Management Task Force (Nov. 1995);
                      Ecosystem Management: Additional Actions Needed to Adequately Test a Promising Approach
                      (GAO/RCED-94-111, Aug. 16, 1994); and Final Report of Recommendations: Project-Level Analysis
                      Re-Engineering Team, Forest Service (Nov. 17, 1995).



                      Page 6                                                                       GAO/T-RCED-97-81
Mr. Chairman and Members of the
Subcommittee:




the plan. The listing may also prohibit the agency from implementing
projects under the plans that may affect the species until the new round of
consultations has been completed. For example, recent federal court
decisions required the Forest Service to reinitiate consultations on several
approved forest plans after a species of salmon in the Pacific Northwest
and a species of owl in the Southwest were listed as threatened under the
Endangered Species Act. The courts’ rulings prohibited the agency from
implementing projects under the plans that might affect the species until
the new rounds of consultations with the Fish and Wildlife Service and/or
the National Marine Fisheries Service had been completed.

Additionally, through differing judicial interpretations of the same
statutory requirements, the courts have established conflicting
requirements. For example, three federal circuit courts of appeals have
held that the approval of a forest plan represents a decision that can be
judicially challenged and prohibited from being implemented. Conversely,
two other federal circuit courts of appeals have held that a forest plan
does not represent a decision and that only a project can be judicially
challenged, at which time the adequacy of the plan’s treatment of
larger-scale environmental issues arising in the project can be
reconsidered.

Requirements to consider new information and events, coupled with
differing judicial interpretations of the same statutory requirements, have
made it difficult for the Forest Service and other federal agencies to
predict when any given decision can be considered final and can be
implemented. Agency officials perceive that the same issues are recycled
under different planning and environmental laws rather than resolved in a
timely manner.

In addition, environmental laws generally address individual resources,
such as endangered and threatened species, water, and air. Conversely,
planning statutes generally establish objectives for multiple resources,
such as sustaining diverse plant and animal communities, securing
favorable water flow conditions, and preserving wilderness. These
different approaches to achieving similar environmental objectives have
sometimes been difficult for the Forest Service and other federal agencies
to reconcile, at least in the short term. For example, prescribed burning to
restore the forests’ health and to sustain diverse plant and animal
communities may be appropriate under the National Forest Management
Act but may be difficult to reconcile in the short term with air quality
standards under the Clean Air Act.



Page 7                                                      GAO/T-RCED-97-81
                     Mr. Chairman and Members of the
                     Subcommittee:




                     In March 1995, the Secretary of Agriculture pledged to work with the
                     Congress to identify statutory changes to improve the processes for
                     implementing the Forest Service’s mission. However, neither his analysis
                     nor options for changing the current statutory framework suggested by the
                     Forest Service in 1995 have been sent to the Congress. Administration
                     officials have said that they are hesitant to suggest changes to the
                     procedural requirements of planning and environmental laws because they
                     believe that the Congress may also make substantive changes to the laws
                     with which they would disagree.


                     On the basis of our work to date, we believe that statutory changes to
The Forest Service   improve the efficiency and effectiveness of the Forest Service’s
Needs Guidance on    decision-making process cannot be identified until after agreement is
How to Resolve       reached on which uses the agency is to emphasize under its broad
                     multiple-use and sustained-yield mandate and how it is to resolve conflicts
Conflicts Among      or make choices among competing uses on its lands.
Competing Uses
                     Our report to you and other requesters, to be issued this spring, will
                     identify the increasing shift in emphasis in the Forest Service’s plans from
                     producing timber to sustaining wildlife and fish. This shift is taking place
                     in reaction to requirements in planning and environmental
                     laws—reflecting changing public values and concerns—and their judicial
                     interpretations, together with social, ecological, and other factors. In
                     particular, section 7 of the Endangered Species Act represents a
                     congressional design to give greater priority to the protection of
                     endangered species than to the current primary missions of the Forest
                     Service and other federal agencies.4 When proposing a project, the Forest
                     Service bears the burden of proof to demonstrate that its actions will not
                     likely jeopardize listed species.

                     The increasing emphasis on sustaining wildlife and fish conflicts with the
                     older emphasis on producing timber and underlies the Forest Service’s
                     inability to achieve the goals and objectives for timber production set forth
                     in many of the first forest plans. In addition, this attention to sustaining
                     wildlife and fish will likely constrain future uses of the national forests,
                     such as recreation. The demand for recreation is expected to grow and
                     may increasingly conflict with both sustaining wildlife and fish and
                     producing timber on Forest Service lands.



                     4
                      TVA v. Hill, 437 U.S. 153, 185 (1978).



                     Page 8                                                      GAO/T-RCED-97-81
           Mr. Chairman and Members of the
           Subcommittee:




           While the agency continues to increase its emphasis on sustaining wildlife
           and fish, the Congress has never explicitly accepted this shift in emphasis
           or acknowledged its effects on the availability of other uses on national
           forests. Disagreement over the Forest Service’s priorities, both inside and
           outside the agency, has not only hampered efforts to improve the
           efficiency and effectiveness of its decision-making but also inhibited it in
           establishing the goals and performance measures needed to ensure its
           accountability.

           If agreement is to be reached on efforts to improve the Forest Service’s
           decision-making and if the agency is to be held accountable for its
           expenditures and performance, the Forest Service will need to consult
           with the Congress on its strategic long-term goals and desired outcome
           measures, as the Government Performance and Results Act requires. Such
           a consultation would create an opportunity for the Forest Service to gain a
           better understanding of which uses it is to 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.


           In summary, Mr. Chairman, the Forest Service’s decision-making process
           is broken and in need of repair. While much can be done within the
           current statutory framework to improve the efficiency and effectiveness of
           the process, strong leadership, both throughout the Forest Service and
           within the Council on Environmental Quality, will be required. Moreover,
           sustained oversight by the Congress will also be important.

           Differences among the requirements of planning and environmental laws
           also need to be addressed. However, at a June 1996 hearing at which both
           you and we testified,5 you stressed that “form must follow function” and
           that the immediate priority is to clarify the Forest Service’s functions. We
           agreed with you then, and we agree with you now. Clarifying priorities
           within the Forest Service’s multiple-use and sustained-yield mission
           should provide the agency with a better understanding of which uses it is
           to 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. Once this is done, the legislative changes that are needed to
           clarify or modify congressional intentions and expectations can be
           identified.

           5
            See Transcript of Proceedings, U. S. Senate, Committee on Governmental Affairs, Improving
           Management and Organization in Federal Natural Resources and Environmental Functions (June 27,
           1996) and Federal Land Management: Streamlining and Reorganization Issues (GAO/T-RCED-96-209,
           June 27, 1996).



(141031)   Page 9                                                                      GAO/T-RCED-97-81
Ordering Information

The first copy of each GAO report and testimony is free.
Additional copies are $2 each. Orders should be sent to the
following address, accompanied by a check or money order
made out to the Superintendent of Documents, when
necessary. VISA and MasterCard credit cards are accepted, also.
Orders for 100 or more copies to be mailed to a single address
are discounted 25 percent.

Orders by mail:

U.S. General Accounting Office
P.O. Box 6015
Gaithersburg, MD 20884-6015

or visit:

Room 1100
700 4th St. NW (corner of 4th and G Sts. NW)
U.S. General Accounting Office
Washington, DC

Orders may also be placed by calling (202) 512-6000
or by using fax number (301) 258-4066, or TDD (301) 413-0006.

Each day, GAO issues a list of newly available reports and
testimony. To receive facsimile copies of the daily list or any
list from the past 30 days, please call (202) 512-6000 using a
touchtone phone. A recorded menu will provide information on
how to obtain these lists.

For information on how to access GAO reports on the INTERNET,
send an e-mail message with "info" in the body to:

info@www.gao.gov

or visit GAO’s World Wide Web Home Page at:

http://www.gao.gov




PRINTED ON    RECYCLED PAPER
United States                       Bulk Rate
General Accounting Office      Postage & Fees Paid
Washington, D.C. 20548-0001           GAO
                                 Permit No. G100
Official Business
Penalty for Private Use $300

Address Correction Requested