National Forests
Information on the Process and Data Used to revise the Chugach Forest Plan Gao ID: GAO-02-855 July 26, 2002The Chugach National Forest in Alaska is the second largest of the 155 forests in the National Forest System and stretches across an immensely varied and scenic area. The Forest Service revised the Chugach National Forest Plan in accordance with planning regulations that require the Forest Service to solicit and respond to public concerns in (1) identifying issues to be considered in revising the plans, (2) developing alternative plans for evaluation, (3) selecting a draft preferred alternative plan, and (4) adopting a final revised plan. Forest Service officials actively solicited key public concerns about revising the Chugach forest plan by distributing frequent newsletters; maintaining a Web site to allow the public access to key documents; and holding over 100 public meetings on the plan, including ones to solicit potential alternatives, and later, to discuss its draft preferred alternative plan. In developing its draft revised plan, issued in September 2000, the Forest Service obtained and analyzed a vast amount of data on various potential uses of the lands and resources within the Chugach. These data and analysis provided information for decisions on difficult and sometimes controversial trade-offs among competing forest uses, such as timber harvesting, mineral mining, commercial fishing, recreation and tourism, forest vegetation, and fish and wildlife habitats. GAO's review showed that the data and analysis that the Forest Service used to make some decisions had limitations that were not disclosed in the draft revised plan.
GAO-02-855, National Forests: Information on the Process and Data Used to revise the Chugach Forest Plan
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Report to Congressional Requesters:
United States General Accounting Office:
GAO:
July 2002:
National ForestS:
Information on the Process and Data Used to Revise the Chugach Forest
Plan:
Chugach National Forest Plan Revision:
GAO-02-855:
Contents:
Letter:
Results in Brief:
Background:
Agency Regulations Prescribed the Process Used to Revise the Chugach
Forest Plan:
The Chugach Used Innovative Techniques to Solicit and Respond to Public
Concerns:
Some Decisions Contained in the Agency‘s Draft Plan Were Based on
Limited Data, but These Limitations Were Addressed in the Final Plan:
Agency Comments:
Appendix I: Forest Service Authority to Study or Recommend for
Designation as Wilderness Chugach National Forest Lands:
Figure:
Figure 1: The Four Major Areas of the Chugach National Forest:
Letter:
July 26, 2002:
The Honorable Frank H. Murkowski
Ranking Minority Member
Committee on Energy and Natural Resources
United States Senate:
The Honorable Don Young
House of Representatives:
Located on the south-central Alaska coast, the Chugach National Forest
(Chugach) is the second largest of the 155 forests in the National
Forest System and stretches across an immensely varied and scenic area
about the size of New Jersey. The Forest Service is required by law to
develop a comprehensive, long-range management plan for each national
forest. These plans, commonly called forest plans, must provide for
multiple, and sometimes competing, public uses in each forest, such as
fishing, mining, timbering, and preserving wildlife. The plans must be
revised at least every 15 years. Forest plans reflect difficult and
often controversial trade-offs among competing forest uses. In
developing a forest plan, the Forest Service analyzes data on various
potential uses of the forest‘s lands and resources in order to
determine the most appropriate combination of the potential uses.
Forest Service officials began revising the Chugach forest plan in
1997. The agency issued a draft revised plan for public comment in
September 2000 and a final revised plan in May 2002.
In this report, we discuss the (1) process the Forest Service used to
revise the Chugach forest plan, (2) actions it took to solicit and
respond to key public concerns about the plan‘s revision, and (3) data
and analyses it used to develop the draft revised plan and whether any
limitations in these data and analyses were appropriately disclosed in
the final plan. In addition, in appendix I, we discuss differing views
on whether the Forest Service has the legal authority to recommend
lands within the Chugach for wilderness designation as part of its
forest plan revision process. Some interested parties believe that the
Alaska National Interest Lands Conservation Act (ANILCA) prohibits the
Forest Service from making any such recommendations. On the other hand,
the Forest Service maintains that it may do so without violating the
act.
Results in Brief:
The Forest Service revised the Chugach National Forest Plan in
accordance with the agency‘s planning regulations. These regulations
required that the Forest Service solicit and respond to public concerns
in (1) identifying issues to be considered in revising the plan, (2)
developing alternative plans for evaluation, (3) selecting a draft
preferred alternative plan, and (4) adopting a final revised plan.
Beginning in July 1997, the agency worked with the public to develop 30
alternative plans, each of which proposed a different combination of
recreation, wildlife, mining, timber, subsistence, wilderness, and
other uses of the Chugach. The Forest Service then combined alternative
plans having similar features to reduce the number down to six. The
agency then performed a detailed comparative analysis of these six
alternative plans and a preferred agency alternative that the Forest
Service developed based on the combined features of the six alternative
plans. In September 2000, the Forest Service issued for public comment
the results of its comparative analysis together with its draft
preferred alternative. In May 2002, the Forest Service issued a final
revised plan based on its draft preferred alternative as modified by
the public comments it received.
Forest Service officials actively solicited key public concerns about
revising the Chugach forest plan by distributing frequent newsletters;
maintaining a Web site to allow the public access to key documents; and
holding over 100 public meetings on the plan, including ones to solicit
potential alternative revisions to the plan and, later, discuss
concerns about its draft preferred alternative plan. As a result, over
the entire planning period, the agency received more than 36,000
comments from the public. These comments generally addressed concerns
about the trade-offs among competing uses of the Chugach, such as
conflicts between motorized and non-motorized recreation or habitat
protection. Most suggested that the revised plan should place emphasis
on preserving, rather than developing, the forest‘s lands and
resources. Most comments also suggested that the revised plan include a
recommendation that the Congress designate additional portions of the
forest as wilderness areas. Interested and affected parties told us
that, while they would have preferred that the agency‘s draft revised
plan had emphasized more of the forest uses that they preferred, they
believed that Forest Service officials included important elements of
their views.
In developing its draft revised plan, issued in September 2000, the
Forest Service obtained and analyzed a vast amount of data on various
potential uses of the lands and resources within the Chugach. These
data and analyses focused largely on timber harvesting, mineral mining,
commercial fishing, recreation and tourism, forest vegetation, and fish
and wildlife habitats, and were used to guide various decisions on
difficult and sometimes controversial trade-offs among competing forest
uses. Our review showed that the data and analyses that the Forest
Service used to make some decisions had limitations that were not
disclosed in the draft revised plan. These decisions involved (1)
possible commercial harvesting of timber, (2) potential mining for
minerals, and (3) protection of a potentially at-risk brown bear
population on the Kenai Peninsula of the Chugach. For example, in
making decisions on uses of the Kenai Peninsula, the Forest Service did
not have sufficient data to determine whether a stable brown bear
population existed in the peninsula and the measures necessary to
ensure the population‘s viability in the presence of human uses of the
peninsula. The draft plan did not disclose these data limitations or
any actions being considered by the Forest Service to fill data gaps
and make appropriate adjustments to the plan. However, our review of
the final revised forest plan, issued in May 2002, and discussions with
agency officials, indicate that the agency has addressed our concerns
about data limitations and how the Forest Service plans to fill data
gaps and consider, where appropriate, amending the plan.
Background:
The Chugach National Forest was established in 1907 and is the second
largest forest in the National Forest System. The forest extends for
over 200 miles along the Alaska coastline southeast of Anchorage,
encompasses over 5 million acres, and is bordered by two national
parks, a state park, and a national wildlife refuge. A forest
supervisor located in Anchorage manages the Chugach, and a regional
forester located in Juneau has overall responsibility for the Chugach
and the other national forest in Alaska.
The Chugach Comprises Four Major Geographic Areas:
As shown in figure 1, the Chugach covers four major areas, each of
which presents agency planners and the public with significantly
different issues.
Figure 1: The Four Major Areas of the Chugach National Forest:
[See PDF for image]
Source: Adapted from Forest Service data.
[End of figure]
As shown in figure 1, the westernmost major area of the Chugach is the
Kenai Peninsula area. This area--the nearest to Alaska‘s largest urban
population center, Anchorage--is a growing recreation area, especially
for motorized recreation such as snowmobiles and all-terrain vehicles.
It also has a significant population of Alaska Brown Bears that the
State of Alaska has designated as being of special concern because of
vulnerability to human impacts.
The Nellie Juan-College Fiord Wilderness Study Area is a greatly
glaciated, remote area lacking roads. The Forest Service had
recommended that the Congress designate much of this area as wilderness
where human activities would be significantly limited. Pending this
designation, or its rejection, it is being managed as such.
The Prince William Sound area contains large offshore islands, such as
Montague Island, where timber has been harvested in the past. The city
of Valdez, located on the Sound, is the southern terminus of the Trans-
Alaska Pipeline. In 1989, the oil tanker Exxon Valdez spilled millions
of gallons of oil into the sound, significantly damaging marine and
shore animals and their habitat and requiring a multiyear,
multibillion-dollar federal clean-up effort.
The Copper River Delta area, located at the forest‘s eastern edge, is
dominated by one of North America‘s most significant rivers for salmon
production. The city of Cordova contains major fish-processing
facilities. At around 2 million acres, the Delta is the most extensive
wetlands complex on the Pacific coast of North America and is a highly
productive ecosystem for shorebirds, waterfowl, and fish. Portions of
the Delta may contain commercial oil and gas.
The Original Chugach Forest Plan:
The original Chugach forest plan was adopted in July 1984, but several
environmental groups appealed the plan through the Forest Service‘s
appeal procedures, arguing that the plan was based on an analysis that
had been done at too large a geographical scale to identify many actual
effects in specific areas on the ground. As a result, they contended,
the plan allowed too much development and was likely to damage fish and
wildlife resources. The Forest Service and the appellants negotiated a
settlement agreement in 1985. In January 1986, Forest Service officials
amended the 1984 plan to incorporate the requirements of the agreement.
Among other things, the 1986 amendment limited timber sales on the
Chugach to an average of about 8 million board feet per year over the
next decade, or about half the originally approved plan‘s level of over
16 million board feet.[Footnote 1] The amendment also committed the
Chugach to conduct further studies at smaller geographic scales, which
might result in additional amendments to the plan.
Agency Regulations Prescribed the Process Used to Revise the Chugach
Forest Plan:
The National Forest Management Act (NFMA) of 1976 requires the Forest
Service to, among other things, (1) develop a plan to manage the lands
and resources of each national forest in coordination with the land
management planning processes of other federal agencies, states, and
localities and (2) revise each plan at least every 15 years. The Forest
Service‘s planning regulations in effect during the Chugach revision
process established detailed procedures for developing a forest plan.
These procedures required the agency to develop several alternatives
for managing a forest and to make these alternatives available for
public comment.[Footnote 2] Furthermore, the regulations required the
agency to develop an environmental impact statement in accordance with
the National Environmental Policy Act of 1969 (NEPA) to accompany each
forest plan. An environmental impact statement assesses the effects of
a major federal action that may significantly affect the quality of the
human environment.
In accordance with the process specified in the agency‘s then-existing
planning regulations, the Chugach Forest Supervisor appointed an
interdisciplinary team that began revising the forest plan in April
1997. Agency regulations encouraged the public to participate
throughout the planning process in order to (1) broaden the agency‘s
information base; (2) ensure that the agency understands the needs,
concerns, and values of the public; (3) inform the public of the
agency‘s planning activities; and
(4) provide the public with an understanding of the agency‘s programs
and proposed actions.
The interdisciplinary team, working with the public, developed 30
alternative plans. Each alternative proposed a different combination of
recreation, wildlife, mining, timber, subsistence, wilderness, and
other uses in the Chugach. The team then combined similar alternatives
to reduce the number of alternatives down to six. It then conducted a
detailed comparative analysis of these six alternatives together with a
required ’no action“ (i.e., no change) alternative, and a preferred
agency alternative developed by the Forest Supervisor that combined
features from all six alternative plans. In September 2000, the
Supervisor of the Chugach National Forest issued for public comment the
agency‘s draft preferred alternative together with the detailed
comparative analysis of all these alternatives.
Forest Service officials reviewed public comments received on the
preferred alternative and, in response to these comments as well as
further study, made changes to its preferred alternative for the Forest
Supervisor‘s approval. Upon approval, the Forest Supervisor forwarded
the proposed final plan and an accompanying environmental impact
statement to the Regional Forester for approval. In May 2002, the
Regional Forester approved the final revised plan.
According to Forest Service officials, the vast majority of forest
plans, since the first one adopted in 1982, have been administratively
appealed, and many have subsequently have been litigated in federal
courts.
The Forest Service Took Extensive Actions to Solicit and Respond to
Public Concerns:
The Forest Service undertook sustained actions to solicit and respond
to key public concerns about the revision to the Chugach forest plan.
These actions included (1) distributing frequent newsletters on the
planning process and its progress, (2) maintaining a Web site on the
Internet with links to key planning documents and making available
compact discs containing these documents, and (3) holding over 100
meetings in which the public was invited to define key issues and
formulate alternatives. These extensive actions went beyond those
required under the agency‘s planning process and those used in previous
forest planning exercises. Also unique to this plan was the intensive
work of the Chugach‘s interdisciplinary team in what the agency termed
a ’collaborative learning process“ to help members of the public
fashion their own varied alternatives.
As a result of this outreach, the agency received thousands of comments
on its draft preferred alternative. These comments generally reflected
differing viewpoints about desirable trade-offs among competing uses of
the Chugach. For example, many interested parties expressed concern
that too much land was being allocated for motorized versus
nonmotorized recreation, while others believed that too much land was
being proposed for wilderness designations versus more intensive uses.
Forest Service officials told us that, in general, nearly all parties
agreed that they did not want the Chugach to change from its generally
undisturbed character and existing usages, but that they disagreed over
what posed the biggest threat to existing conditions and uses. Some
thought the greatest threat came from increased development while
others felt it came from increased restrictions on existing uses. Most
suggested that the revised plan should place emphasis on preserving,
rather than developing, the forest‘s lands and resources.
To respond to these concerns, the agency (1) obtained additional
information, (2) held additional meetings with the public, and
(3) considered specific changes to its preferred alternative.
Throughout the planning process all parties were provided numerous
opportunities to place on the record their concerns about forest
issues. Some members of the public told us that they felt there were
times during the planning process that some Forest Service staff
inappropriately expressed personal views on issues but that, during the
long planning process, those staff transferred to other agency
assignments and their replacements did not seem to share those views.
Although some interested and affected parties still had concerns about
the results of the revision process and the agency‘s draft preferred
alternative, virtually all parties told us they believed the Forest
Service had included important elements of their views in the draft
revised plan.
Some Decisions Contained in the Agency‘s Draft Plan Were Based on
Limited Data, but These Limitations Were Addressed in the Final Plan:
In developing the draft revised plan, the Forest Service obtained and
analyzed a vast amount of data on timber harvesting, mineral mining,
commercial fishing, recreation and tourism, forest vegetation, and fish
and wildlife habitats. These data and analyses were used to make
various decisions on difficult and sometimes controversial trade-offs
among competing forest uses. In three areas, we found that the data and
analyses used for making some decisions had limitations that were not
disclosed in the draft revised plan. These decisions involved (1)
possible commercial harvesting of timber, (2) potential mining for
minerals, and (3) protection of a potentially at-risk brown bear
population.
* Possible commercial harvesting of timber. The Forest Service did not
calculate the maximum quantity of timber that might be sold over a
decade from the area of suitable land covered by the forest plan. The
agency did not perform such an analysis because officials believed (1)
they were not legally required to do so, (2) commercial timber
harvesting was not economically feasible in the Chugach because of the
generally low quality of timber in the forest, low market prices, and
the lack of nearby large markets, and (3) gathering and analyzing the
data needed to calculate the maximum quantity was not worth the time,
expense, and difficulty of doing so. However, the agency‘s draft
revision did not discuss the limitations of the analysis on which this
decision was based.
* Potential mining for minerals. In order to make decisions about areas
in the Chugach where mining would be permitted, the Forest Service
analyzed a substantial body of data that it had gathered on past mining
activities in the forest. However, such past activities were conducted
in only a small portion of the forest, typically in areas accessible
from existing forest roads. Forest Service officials told us that the
Department of the Interior had estimated that it would cost
approximately $8 million to survey the entire forest to determine the
full potential for mineral mining activities. They believed that such
costs were not warranted in view of other priorities of the forest
competing for limited funds and that they were justified in basing
decisions on the information that they had gathered on the past mining
activities. However, the agency‘s draft revised plan did not discuss
the limitations of the analysis on which it based its decisions on
mining activities within the forest.
* Protection of a potentially at-risk brown bear population. An
interagency study on the size and trends of the brown bear population
on the Kenai Peninsula of the Chugach, which may be at risk from human
activities, was produced while the Forest Service was reviewing public
comments on its draft-revised plan. This study, which the Forest
Service participated in, reported that data are not available to
determine whether a stable brown bear population currently exists in
the peninsula and whether additional measures are needed to maintain
the population‘s viability in the presence of all types of human uses
of the peninsula. The study calls for additional research to help
answer these questions. The Forest Service‘s draft revised plan did not
disclose the findings of this interagency study nor did it identify
steps that the agency would take to obtain additional data. Neither had
the agency included reference to it in changes to the draft made during
the comment period on it while our review was being conducted. Should
evidence suggesting serious problems with the population trends of the
Kenai brown bear become available during the time frame covered by the
Chugach‘s revised forest plan, it may be necessary to make changes to
the plan that could unexpectedly alter planned human uses in some areas
of the forest.
In March 2002, we met with the Forest Supervisor and other Forest
Service officials and told them that our review indicated that
limitations existed in some of the agency‘s data and analyses and that
the draft plan neither disclosed such limitations nor identified
planned actions to address them. In May 2002, the agency issued a final
revised Chugach forest plan. Our review of the final plan and
discussions with agency officials indicate that the agency has
addressed our concerns by
(1) agreeing to augment their analysis of data regarding timber
harvesting in the forest, (2) explaining the limitations of data on
potential mineral deposits in the forest and the agency‘s decision to
not incur costs associated with performing a comprehensive survey to
determine the potential for mining minerals throughout the forest, and
(3) referring to the findings of the interagency brown bear study and
the agency‘s planned monitoring of the brown bear population. In
addressing these concerns, the agency also completed an internal
science consistency evaluation considering data and limitations.
Agency Comments:
We provided a draft of this report to the Supervisor of the Chugach
National Forest for review and comment. He generally concurred with our
findings and made certain technical suggestions that we incorporated as
appropriate.
We conducted our work from August 2001 through July 2002 in accordance
with generally accepted government auditing standards. We visited the
Chugach National Forest and obtained the views of and related
documentation from Forest Service, state, industry, and environmental
group officials located in Alaska and Forest Service headquarters
officials located in Washington, D.C. We are sending copies of this
report to the Secretary of Agriculture and the Chief of the Forest
Service. In addition, the report will be available at no charge on the
GAO Web site at http://www.gao.gov.
If you have any questions about this report, please call me at 202-512-
3841. Key contributors to this report were Charles S. Cotton, Richard
P. Johnson, Chester M. Joy, and Edward A. Kratzer.
Barry T. Hill
Director, Natural Resources
and Environment:
Signed by Barry T. Hill:
[End of section]
Appendix I: Forest Service Authority to Study or Recommend for
Designation as Wilderness Chugach National Forest Lands:
In 1980, after several years of consideration, the Congress passed the
Alaska National Interest Lands Conservation Act (ANILCA), which, among
other things, addressed ongoing land disputes between the federal
government and the state. Specifically, the act set aside millions of
acres in ’conservation system units,“ a statutory term including
national parks, wildlife refuges, wilderness areas, and wild and scenic
rivers. The law also rescinded numerous public land withdrawals within
Alaska by the President and Interior that had occurred in the 1970s.
Section 1326(a) of ANILCA limited future executive branch land
withdrawals of more than 5,000 acres in Alaska.
In addition, section 1326(b) of ANILCA prohibited ’further studies of
federal lands for the single purpose of considering the establishment
of a conservation system unit“ or other similar units unless authorized
by ANILCA or future legislation. The Forest Service and other
interested parties hold differing views on how this section should be
interpreted with regard to the Forest Service‘s legal authority to
recommend to the Congress that portions of the Chugach be managed as
wilderness areas. Some supporters of greater development maintain that
section 1326 (b) prohibits the Forest Service from making any such
recommendations outside the existing Wilderness Study Area in the
forest. On the other hand, the Forest Service maintains that it may do
so without violating ANILCA, as long as the recommendation is not based
upon a study performed for the single purpose of designating an area as
wilderness. Stakeholders also disagree over the proper interpretation
of Section 501(b) of ANILCA. Some supporters of greater development
believe that this section requires that the Copper River Delta within
the Chugach be managed for fish and wildlife conservation and prohibits
the Forest Service from recommending to the Congress that any portion
of delta be designated as a wilderness area. The Forest Service
believes that the delta can contain wilderness designations so long as
the applicable management direction for the delta provides for the
primacy of fish and wildlife conservation.
Only one court has examined section 1326(b) of ANILCA in any detail. In
a recently completed forest plan for Tongass National Forest in
southeast Alaska, the Forest Service recommended certain rivers for
designation under the Wild and Scenic Rivers Act. Opponents of these
recommendations challenged the Forest Service‘s decision in Sierra Club
v. Lyons, contending that ANILCA § 1326(b) prohibited the Forest
Service‘s action. In an unpublished opinion, the court in a brief
discussion rejected the argument. The court stated that:
A review of the record before the Court reveals that the Forest Service
did not study rivers in Alaska for the single purpose of considering
the establishment of a conservation system unit. Rather the Forest
Service conducted a study of the rivers for their eligibility as wild
and scenic for the purposes of a general land management plan. Thus, no
ANILCA violation occurred. Sierra Club v. Lyons, J00-0009 CV (JKS),
Slip. Op. at 31 (March 30, 2001) (citations omitted).
The court in Lyons also held that the Forest Service had violated its
planning regulations by failing to evaluate roadless areas within the
Tongass to determine whether any of these should be recommended for
inclusion in the National Wilderness Preservation System. The court
ordered the Forest Service to carry out such an evaluation, which is
currently being performed.
Supporters of greater development have asserted that section 1326(b) of
ANILCA prohibits the Forest Service from studying national forest lands
in Alaska for the purpose of considering additions to the Wild and
Scenic River and Wilderness systems. Although the court in Lyons
rejected this argument with respect to Wild and Scenic Rivers, these
stakeholders contend that the government did not adequately explain the
provisions of ANILCA to the court, thus leading the court to an
erroneous conclusion. The Record of Decision states that the revised
forest plan does not violate section 1326(b) because the plan is a
general land management plan rather than a single purpose study.
Stakeholders also disagree over the proper management of the Copper
River Delta. The Copper River Delta is a highly productive ecosystem
that may contain commercial oil and gas deposits. A House version of
ANILCA would have designated the area as a National Wildlife Refuge. As
ultimately enacted, section 501(b) retained the Copper River Delta
under the Forest Service‘s jurisdiction, but provided that the primary
purpose of the area was to further fish and wildlife conservation.
Some stakeholders have asserted that section 501(b) of ANILCA prohibits
the Forest Service from recommending any areas within the Copper River
Delta for designation as wilderness because such a designation would
prohibit the Forest Service from undertaking certain actions to
conserve fish and wildlife. These stakeholders have also asserted that
proposed wilderness designation would hinder future oil and gas
development near the town of Katalla. However, others who support
preserving the forest‘s lands and resources argued that some of the
land management prescriptions in the draft plan would violate section
501(b) by failing to prohibit activities that conflict with the area‘s
purpose of conserving fish and wildlife, such as mining, road
construction, and off-road vehicle use, among others.
The revised plan does not recommend any areas for wilderness
designation within the Copper River Delta. The Record of Decision
states that each of the three management prescriptions applied to the
Delta have fish and wildlife conservation as their primary goal.
According to the ROD, each prescription provides for a different mix of
multiple use activities consistent with the conservation of fish and
wildlife and their habitat.
[End of section]
FOOTNOTES
[1] A ’board foot“ is a unit of measurement of timber equaling the
amount of wood contained in a finished board 1 inch thick, 12 inches
long, and 12 inches wide.
[2] See app. I of U.S. General Accounting Office, Forest Service
Decision-Making: A Framework for Improving Performance, GAO/
RCED-97-71, Washington, D.C.: April 29, 1997, for a more detailed
discussion of the agency‘s planning process.
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