Federal Land Management
Observations on a Possible Move of the Forest Service into the Department of the Interior Gao ID: GAO-09-223 February 11, 2009Growing ecological challenges ranging from wildland fires to climate change have revived interest in moving the Department of Agriculture's (USDA) Forest Service into the Department of the Interior (Interior). The Forest Service manages almost a quarter of the nation's lands but is the only major land management agency outside Interior. GAO was asked to report on the potential effects of moving the Forest Service into Interior and creating a new bureau equal to Interior's other bureaus, such as the Bureau of Land Management (BLM). GAO was also asked to identify factors that should be considered if such a move were legislated and management practices that could facilitate a move. GAO analyzed five historical proposals to reorganize federal land management agencies; interviewed USDA, Interior, and other officials and outside experts; and studied joint Forest Service- BLM programs to assess efforts to integrate the agencies' work.
Moving the Forest Service into Interior could potentially improve federal land management by consolidating into one department key agencies with land management missions and increasing the effectiveness of their programs. At the same time, a move would provide few efficiencies in the short term and could diminish the role the Forest Service plays in state and private land management, a mission the agency has in common with USDA but not with Interior. According to many agency officials and experts, where the Forest Service mission is aligned with Interior's--in particular, the multiple-use mission comparable to BLM's--a move could increase the overall effectiveness of some of the agencies' programs and policies. For example, according to some officials, a move could help harmonize the Forest Service's and BLM's oil and gas, grazing, and other programs and potentially make the agencies' appeals processes similar. Conversely, most agency officials and experts GAO interviewed believed that few short-term efficiencies would be realized from a move, although a number said opportunities would be created for potential long-term efficiencies, such as consolidating information technology systems. Many officials and experts suggested that if the objective of a move is to improve land management and increase the effectiveness and efficiency of the agencies' diverse programs, other options might achieve better results. For example, numerous officials and experts suggested leaving the Forest Service in USDA and increasing collaboration among the land management agencies. If the Forest Service were moved into Interior, Interior and USDA would need to consider a number of cultural, organizational, and legal factors and related transition costs, some of which could be managed by certain practices successfully used in the past to merge and transform organizations. The agencies' long histories and traditions have created distinctive cultures, which officials and experts predicted could clash under Interior, leading to reduced morale and productivity. Changes needed to departmental and agency organization in the event of a move could also present challenges. For example, officials and experts said that integrating the Forest Service's reporting, budgeting, and personnel processes and systems into Interior's could be time-consuming, disruptive, and costly. Further, complex legal issues, such as differing statutory authorities, may need reconciliation. GAO's previous work on merging and transforming organizations, however, identified some key practices that Interior and USDA could use to facilitate a move and manage the costs; several of the practices were also mentioned by a number of officials and experts GAO interviewed. For example, identifying goals for a move, up front, would enable planning to achieve those goals, and creating an effective communication strategy would help agency employees understand the reason for a move. Organizational transformations are inevitably complex, involving many factors and often creating unintended consequences. In considering a move of the Forest Service into Interior, policymakers will need to carefully weigh mission and management gains against potential short-term disruption and operational costs.
GAO-09-223, Federal Land Management: Observations on a Possible Move of the Forest Service into the Department of the Interior
This is the accessible text file for GAO report number GAO-09-223
entitled 'Federal Land Management: Observations on a Possible Move of
the Forest Service into the Department of the Interior' which was
released on February 24, 2009.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as part
of a longer term project to improve GAO products' accessibility. Every
attempt has been made to maintain the structural and data integrity of
the original printed product. Accessibility features, such as text
descriptions of tables, consecutively numbered footnotes placed at the
end of the file, and the text of agency comment letters, are provided
but may not exactly duplicate the presentation or format of the printed
version. The portable document format (PDF) file is an exact electronic
replica of the printed version. We welcome your feedback. Please E-mail
your comments regarding the contents or accessibility features of this
document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
February 2009:
Federal Land Management:
Observations on a Possible Move of the Forest Service into the
Department of the Interior:
Forest Service-Interior Consolidation:
GAO-09-223:
GAO Highlights:
Highlights of GAO-09-223, a report to congressional requesters.
Why GAO Did This Study:
Growing ecological challenges ranging from wildland fires to climate
change have revived interest in moving the Department of Agriculture‘s
(USDA) Forest Service into the Department of the Interior (Interior).
The Forest Service manages almost a quarter of the nation‘s lands but
is the only major land management agency outside Interior.
GAO was asked to report on the potential effects of moving the Forest
Service into Interior and creating a new bureau equal to Interior‘s
other bureaus, such as the Bureau of Land Management (BLM). GAO was
also asked to identify factors that should be considered if such a move
were legislated and management practices that could facilitate a move.
GAO analyzed five historical proposals to reorganize federal land
management agencies; interviewed USDA, Interior, and other officials
and outside experts; and studied joint Forest Service–BLM programs to
assess efforts to integrate the agencies‘ work.
What GAO Found:
Moving the Forest Service into Interior could potentially improve
federal land management by consolidating into one department key
agencies with land management missions and increasing the effectiveness
of their programs. At the same time, a move would provide few
efficiencies in the short term and could diminish the role the Forest
Service plays in state and private land management, a mission the
agency has in common with USDA but not with Interior. According to many
agency officials and experts, where the Forest Service mission is
aligned with Interior‘s”in particular, the multiple-use mission
comparable to BLM‘s”a move could increase the overall effectiveness of
some of the agencies‘ programs and policies. For example, according to
some officials, a move could help harmonize the Forest Service‘s and
BLM‘s oil and gas, grazing, and other programs and potentially make the
agencies‘ appeals processes similar. Conversely, most agency officials
and experts GAO interviewed believed that few short-term efficiencies
would be realized from a move, although a number said opportunities
would be created for potential long-term efficiencies, such as
consolidating information technology systems. Many officials and
experts suggested that if the objective of a move is to improve land
management and increase the effectiveness and efficiency of the
agencies‘ diverse programs, other options might achieve better results.
For example, numerous officials and experts suggested leaving the
Forest Service in USDA and increasing collaboration among the land
management agencies.
If the Forest Service were moved into Interior, Interior and USDA would
need to consider a number of cultural, organizational, and legal
factors and related transition costs, some of which could be managed by
certain practices successfully used in the past to merge and transform
organizations. The agencies‘ long histories and traditions have created
distinctive cultures, which officials and experts predicted could clash
under Interior, leading to reduced morale and productivity. Changes
needed to departmental and agency organization in the event of a move
could also present challenges. For example, officials and experts said
that integrating the Forest Service‘s reporting, budgeting, and
personnel processes and systems into Interior‘s could be time-
consuming, disruptive, and costly. Further, complex legal issues, such
as differing statutory authorities, may need reconciliation. GAO‘s
previous work on merging and transforming organizations, however,
identified some key practices that Interior and USDA could use to
facilitate a move and manage the costs; several of the practices were
also mentioned by a number of officials and experts GAO interviewed.
For example, identifying goals for a move, up front, would enable
planning to achieve those goals, and creating an effective
communication strategy would help agency employees understand the
reason for a move. Organizational transformations are inevitably
complex, involving many factors and often creating unintended
consequences. In considering a move of the Forest Service into
Interior, policymakers will need to carefully weigh mission and
management gains against potential short-term disruption and
operational costs.
What GAO Recommends:
This report contains no recommendations, but provides decision makers
with details on the potential effects of moving the Forest Service into
Interior and factors that policymakers should consider in such a move.
Generally, the Forest Service and Interior agreed with the report, but
Interior observed that a move would not necessarily diminish the Forest
Service‘s state and private role.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-223]. For more
information, contact Robin M. Nazzaro at (202) 512-3841 or
nazzaror@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Moving the Forest Service into Interior Would Align Federal Land
Management Missions and Could Improve Effectiveness of Federal Programs
yet May Yield Few Efficiencies in the Short Term:
Move Would Entail Consideration of Numerous Factors and Could Lead to
Transition Costs, but Key Merger and Transformation Practices Could
Help Facilitate Move and Manage Disruptions:
Concluding Observations:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: List of Experts GAO Interviewed:
Appendix III: Five Selected Historical Proposals to Reorganize Federal
Natural Resource and Land Management Agencies:
Appendix IV: Service First:
Appendix V: Oil and Gas Federal Permit Streamlining Pilot Project:
Appendix VI: Comments from the Department of the Interior:
GAO Comments:
Appendix VII: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: Forest Service and Interior Agencies' Mission Statements:
Table 2: Key Practices and Implementation Steps for Mergers and
Organizational Transformations:
Table 3: Integration of Business Operations for the San Juan Public
Lands Center:
Table 4: Integration of Business Operations in Portland, Oregon,
Service First Site:
Table 5: Joint Forest Service-BLM Activities to Integrate Business
Operations:
Figures:
Figure 1: Federal Lands in the Contiguous United States Managed by
USDA's Forest Service and by the Department of the Interior:
Figure 2: Forested Lands in the Contiguous United States, 2000:
Figure 3: Organizational Chart for Interior:
Figure 4: Organizational Chart for USDA:
Abbreviations:
APHIS: Animal and Plant Health Inspection Service:
BLM: Bureau of Land Management:
DHS: Department of Homeland Security:
GIS: Geographic Information System:
GPRA: Government Performance and Results Act:
NEPA: National Environmental Policy Act:
NRCS: Natural Resources Conservation Service:
USDA: United States Department of Agriculture:
USGS: United States Geological Survey:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
February 11, 2009:
The Honorable Norm Dicks:
Chairman:
The Honorable Mike Simpson:
Ranking Member:
Subcommittee on Interior, Environment, and Related Agencies:
Committee on Appropriations:
House of Representatives:
The Honorable Todd Tiahrt:
House of Representatives:
The organizational arrangement and roles of the nation's land
management agencies have remained relatively static since the turn of
the twentieth century, although the agencies have confronted growing
challenges such as wildland fire, watershed protection, and
biodiversity loss and now face unprecedented impacts from climate
change and intense new development of energy resources. Four federal
land management agencies--the Forest Service within the Department of
Agriculture (USDA) and the Bureau of Land Management (BLM), Fish and
Wildlife Service, and National Park Service in the Department of the
Interior (Interior)--manage most of the 680 million acres of federal
land across the country. Established in 1849, Interior was given
authority for managing public lands, including those acquired by the
federal government during the nation's westward expansion. While the
government disposed of many of its lands to new states, the railroads,
homesteaders, and miners, in the late nineteenth century it also began
setting aside some lands under Interior's jurisdiction for parks and
forest reserves. Then in 1905 Congress transferred control of the
forest reserves from Interior to USDA, consolidating USDA's forestry
research program and the forest reserves into one agency, which became
known as the Forest Service. In creating the Forest Service in USDA,
where it remains today, Congress was responding in part to scientists
and policymakers who believed the nation's forests and timber supply
would be better managed under USDA's agriculture and conservation
mission. Between 1916 and 1956, Congress created the three other land
management agencies within Interior, in part to manage its parks,
wildlife refuges, and rangelands.
Since then, both the Forest Service and Interior's agencies--
particularly BLM--have experienced increased economic, ecological, and
legal transformations, such as shrinking supplies of natural resources,
passage of key environmental legislation in the 1960s and 1970s, and
shifting public expectations for land management. In particular,
changing public demands and legislative reform beginning in the 1960s
led to increasing conflicts among the uses of Forest Service and BLM
lands, especially between noncommodity uses, such as recreation,
wilderness preservation, and wildlife habitat, and commodity uses, such
as timber and grazing. In addition, Fish and Wildlife Service and
National Park Service lands have experienced increased demand for
recreation, wilderness, and other protected areas, including wild and
scenic rivers and wildlife habitat to safeguard species. Changes like
these have made managing federal lands more complex, with managers
needing to reconcile differences among growing demands for often
conflicting land uses. Most recently, all the land management agencies,
but particularly the Forest Service, have faced unprecedented
challenges in the form of large-scale, cross-boundary problems such as
wildland fire, invasive species, and development of private lands along
their borders.
Recognizing that federal land management agencies faced many similar
challenges but lacked unifying statutory authorities for management and
use of federal lands and resources, policymakers over the last 4
decades made several unsuccessful attempts to reorganize the nation's
land and resource agencies. These efforts were part of broader efforts
made during the Nixon, Carter, and Reagan administrations to reorganize
the federal agencies and departments to improve the efficiency and
effectiveness of the federal government. The specific proposals for
federal land management agencies included moving the Forest Service
into Interior, reorganizing all resource and environmental agencies
into a new department of natural resources that would replace Interior,
and exchanging certain lands managed by the Forest Service and BLM to
create contiguous blocks of land managed by one or the other of the two
agencies. These proposals, however, were unsuccessful for a number of
reasons, including political resistance to the specific changes and
shifting government priorities. For example, the energy crises of the
early and late 1970s diverted congressional and executive branch
attention from the administrations' proposals to consolidate the Forest
Service and Interior agencies--as well as other federal agencies--into
a single department of natural resources.
The emergence of new challenges for both the Forest Service and
Interior during a time of severe budgetary constraint, as well as the
growing need for agencies to collaborate on large-scale natural
resource problems, has revived interest in the potential for improving
federal land management and program efficiency and effectiveness. To
help inform congressional consideration of these issues, you asked us
to study the potential effects of moving the Forest Service into
Interior by transferring the authorities of the Forest Service Chief,
as well as those given to the Chief through the Secretary of
Agriculture, to the Secretary of the Interior and creating within
Interior a new bureau equivalent to the department's other bureaus.
Specifically, you asked us to describe (1) how federal land management
would potentially be affected by moving the Forest Service into
Interior and (2) what factors should be considered if Congress and the
administration were to decide to move the Forest Service into Interior
and what management practices could facilitate such a move.
To understand the potential effects of a move, the factors that should
be considered if a move were legislated, and practices that could
facilitate a move, we first analyzed the content of five historical
proposals on reorganizing the nation's federal land management
agencies, going back to the Public Land Law Review Commission report of
1970.[Footnote 1] We also interviewed USDA, Interior, Forest Service,
BLM, and other agency officials[Footnote 2] and natural resource and
public administration experts to discuss a possible move, its potential
effects on federal land management overall and resource programs in
particular, and any factors that would be involved in a move. The
agency officials we interviewed included the Forest Service Chief and
Deputy Chiefs, USDA Under Secretary for Natural Resources and
Environment, and several of Interior's Assistant Secretaries. We also
interviewed key managers for Forest Service and BLM programs, such as
timber, oil and gas, and wildland fire management, at headquarters,
state, regional, and field offices and at the agencies' financial,
legal, and audit offices. To identify experts for our interviews, we
reviewed literature on government organizational change and management
and obtained recommendations from agency officials; we selected and
interviewed 22 of the people identified. Seven of these experts were
former agency officials at USDA and Interior, including former
Secretaries and Forest Service Chiefs; seven were experts in public
administration who have studied organizational change; and the
remaining experts were academics who have studied natural resource laws
and agencies.
We also visited two sites in Colorado and Oregon where the Forest
Service and BLM are colocated and comanaged, called Service First
sites, to discuss the programs that the agencies manage in common, and
we interviewed officials involved in the oil and gas federal permit
streamlining pilot project to understand how the Forest Service and BLM
have integrated various aspects of their oil and gas programs. We also
interviewed 18 nonfederal groups that have an interest in the agencies
including environmental groups, forestry associations, the Intertribal
Timber Council, and groups representing state and local government. To
identify practices the departments could use to facilitate a move, we
referred to previous GAO work on key practices that have been found to
bring about successful mergers and organizational transformations,
[Footnote 3] as well as the results of our interviews with agency
officials and experts.
We conducted this work as a nonaudit service from March 2008 through
February 2009. This means the work was performed in accordance with
GAO's quality assurance framework, which requires that we plan and
perform the engagement to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings, conclusions, and
recommendations based on our objectives. Appendix I describes our scope
and methodology in greater detail, and appendix II contains a list of
experts we interviewed.
Results in Brief:
Moving the Forest Service into Interior could potentially improve
federal land management by consolidating into one department the key
federal agencies with land management missions; such a move could also
improve the effectiveness of federal land management programs, although
few management efficiencies may be gained in the short term. Moving the
Forest Service could also, however, diminish the role the agency plays
in state and private land management working with farmers, ranchers,
and state foresters to conserve resources on state and private lands--
a mission focus the Forest Service shares with USDA but does not have
in common with Interior. According to many agency officials and experts
with whom we spoke, where the Forest Service mission is aligned with
Interior's--in particular, the multiple-use mission comparable to
BLM's--a move could increase the overall effectiveness of some of the
agencies' programs and policies. For example, some officials stated
that a move would help harmonize the Forest Service's and BLM's oil and
gas, grazing, and other programs and potentially make the agencies'
internal administrative appeals processes similar. Conversely, most
agency officials and experts believed that few short-term efficiencies
would be realized from a move, although they said an opportunity would
be created for potential long-term efficiencies, such as consolidating
information technology systems. Officials reported that existing
efforts to integrate the agencies' programs, such as Service First,
demonstrated increased effectiveness, but agency reports showed few
efficiencies gained, in part because measuring and documenting
efficiencies across agencies are complex. Many officials and experts
suggested that if the objective of a move is to improve land management
and increase the efficiency and effectiveness of the agencies' diverse
programs, other options may achieve better results. For example,
numerous officials and experts believed that it would be more
effective, and perhaps more efficient, to leave the Forest Service in
USDA and work to increase collaboration among federal land management
agencies. In addition, other officials and experts said that creating a
new department of natural resources might allow decision makers to
better balance competing resource needs by providing a broad and
integrated view of land and resource issues.
If the Forest Service were to be moved into Interior, Interior and USDA
would need to consider a number of factors and related transition
costs, some of which could be managed by key practices that have been
successfully used in the past to merge and transform organizations.
Because of cultural, organizational, and legal factors, moving the
Forest Service into a new department could lead to organizational
disruptions and other transition costs. The Forest Service's 100-year
history and tradition have resulted in a distinctive culture, which
officials and experts predicted could clash with the cultures of the
land management agencies under Interior. All the land management
agencies have deeply rooted cultures, as well as employees who are
loyal to their respective agencies and departments; therefore, Forest
Service employees may feel a loss of identity in leaving USDA and would
fear and resist a move, while Interior employees may feel threatened by
the addition of the Forest Service into Interior. Similarly, changes
needed to departmental and agency organization--including information
and other business systems--to complete a move of the Forest Service
from USDA into Interior could also present significant challenges. For
example, officials and experts said, integrating the Forest Service's
reporting, budgeting, and personnel processes and systems into
Interior's would be time-consuming, disruptive, and costly. Also,
resolving legal differences, such as differing statutory authorities
and interpretations of authorities common to both agencies, could
further complicate a move. Given these factors, a move could lead to
organizational disruptions and operational costs: cultural factors
could lead to low morale and resistance to a move, while addressing
organizational and legal factors could consume significant time and
resources. Our previous work on merging and transforming organizations,
however, has identified some key practices that could help facilitate
the move and manage these disruptions and operational costs, and
several of these practices were echoed by a number of the officials and
experts we interviewed. For example, the practice of ensuring that top
leadership drives a move can ease cultural transitions and minimize
disruption, according to several officials. Further, identifying a
clear mission and goals for a move, up front, would enable planning to
achieve those goals, and creating an effective communication strategy
would help agency employees and stakeholders understand the reason for
a move.
In commenting on a draft of this report, the Forest Service and
Interior generally agreed with our findings. Interior observed,
however, that a move would not necessarily diminish the Forest
Service's role in state and private forestry or cause the Forest
Service to modify its current role. Interior also believes that a move
could strengthen its ability to work with state and private landowners
to conserve endangered species, wetlands, and other resources.
Background:
To a large extent, the establishment and organization of federal lands
and agencies was complete by the early twentieth century. The nation's
westward expansion and settlement during the nineteenth century created
a patchwork of federal lands interspersed among private and state
lands, especially in the West. During this expansion, the federal
government acquired and disposed of millions of acres of land for many
reasons, including private settlement. It also set aside certain lands
for specific public purposes, including military reservations, public
schools, town sites, forest reserves, and parks. To manage the
disposition of federal lands, Congress first created the General Land
Office in 1812 and then the Department of the Interior in 1849, which
incorporated the General Land Office and its duties. The first forest
reserves were set aside in 1891, the first national park (Yellowstone
National Park in Wyoming, Idaho, and Montana) in 1872, and the first
wildlife refuge (Pelican Island in Florida) in 1903. Ultimately, the
federal land base grew to more than 680 million acres, including a
significant portion of national forestland, parks, and wildlife refuges
in the eastern states.
Gradually, Congress created federal land management agencies to oversee
lands set aside for forests, parks, and refuges, as well as the
remaining "public domain," lands that were not sold, disposed of, or
retained for particular purposes. In 1905, Congress transferred the
forest reserves, held by Interior, into USDA and created the Forest
Service. Congress then established the National Park Service in 1916 to
manage Yellowstone and several other parks, and the Fish and Wildlife
Service in 1956 to manage land reserved for wildlife.[Footnote 4]
Public domain lands remained in federal ownership and were used for
many years by local residents for livestock grazing and other purposes.
In 1934, partly because of overgrazing and range conflicts among
cattlemen and sheep herders, Congress passed the Taylor Grazing Act,
[Footnote 5] creating the Grazing Service to manage these public-
domain lands primarily for grazing. In 1946, the Grazing Service was
combined with the General Land Office to create BLM. It was not until
1976, however--with the passage of the Federal Land Policy and
Management Act--that the national policy for retaining public land in
federal ownership formally began.[Footnote 6]
As a result of this historical development, four distinct land
management agencies, each operating under unique authorities, today
oversee more than 630 million acres of federal land.[Footnote 7] Both
the Forest Service and BLM manage their lands for multiple uses and
provision of a sustained yield of renewable resources such as timber,
fish and wildlife, forage for livestock, and recreation. On the other
hand, the National Park Service manages its lands to conserve their
scenery, natural and historical objects, and wildlife so they will
remain unimpaired for the enjoyment of current and future generations.
Similarly, the Fish and Wildlife Service also manages national wildlife
refuges for the benefit of current and future generations, seeking to
conserve and, where appropriate, restore fish, wildlife, and plant
resources and their habitats. In addition to the requirements specific
to each agency, management activities undertaken by these four agencies
are all subject to numerous other laws affecting land and resource
management, such as the National Environmental Policy Act (NEPA) of
1969 and the Endangered Species Act of 1973.[Footnote 8] NEPA requires
federal agencies to evaluate the likely environmental effects of
proposed projects and plans using an environmental assessment or, if
the action is likely to affect the environment significantly, a more
detailed environmental impact statement. Under the Endangered Species
Act, federal agencies must use their authorities to further the
conservation of species listed as endangered or threatened and are
required to consult with the Fish and Wildlife Service to ensure that
any activities the agencies carry out do not jeopardize the continued
existence of a threatened or endangered species or destroy or harm any
habitat critical for the conservation of the species.[Footnote 9]
Federal Government Organization and Reorganization:
The organization of the federal government's departments and agencies
has evolved over time, depending on the nation's needs and
circumstances.[Footnote 10] Initial organization efforts resulted in
some of the original federal departments, including the establishment
in 1789 of the departments of State, War, and Treasury. As the country
grew, departments or agencies were created when a new federal mission
became important or needed emphasis, including the establishment of
Interior in 1849 and USDA in 1862. In addition, several departments or
agencies were created to focus on particular government missions:
Franklin D. Roosevelt's New Deal generated numerous federal agencies to
respond to the Great Depression; President Nixon created the
Environmental Protection Agency to establish a single federal agency
that could, in concert with the states, set and enforce standards for
air and water quality and for individual pollutants; and the Department
of Energy was created during the Carter administration in response to
an increasing shortage of nonrenewable energy sources in the 1970s. The
most recent organizational effort occurred in 2002, with the creation
of the Department of Homeland Security (DHS) and the merging of 22
agencies or portions of agencies into this new department to centralize
the federal government's focus on security matters in response to the
terrorist attacks of September 11, 2001.
Other reorganization efforts, such as those resulting in the
departments of Defense, Transportation, and Education, focused on
improving the efficiency and effectiveness of government programs.
Efforts to improve efficiency involve increasing productivity, that is,
gaining more output from the same quantity of resources (or obtaining
the same output from fewer resources), whereas increasing effectiveness
involves achieving improved results. While reorganization may result in
greater effectiveness of government policies, experts have found that
reorganization may not improve the efficiency of an organization in the
short term because the transition to a new organization takes many
years and does not yield immediate benefits. Various transition costs
are associated with reorganizing large entities, including short-term
costs of moving an agency and changing its space, information and other
business systems, and other operations. Transition costs also include
disruption of work and a loss of productivity. In the long term,
benefits could accrue if reorganization yields improved efficiencies
and effectiveness of affected agency programs; such benefits, however,
are often difficult to estimate.
Theories about organizing and reorganizing federal agencies have
evolved over time. Through the 1970s, public administration experts
advocated the creation of one large department around a specific
mission and development of independent agencies within that department
to implement individual components of that mission. This theory holds
that better coordination and cooperation occur among the agencies and
staff involved in a centralized department and that, ultimately,
responsibility for resolving differences falls to a single Secretary.
More recent theories, recognizing the interdependence of agencies and
the multiple missions they may hold, advocate networking and
collaboration among agencies, rather than reorganization. In such
instances, if the agencies clearly differ in their functions and
jurisdictional boundaries, then networking and collaboration could be
encouraged over moving the agencies into one department.
Since the 1990s, efforts to improve government have focused on
improving the management of existing departments and agencies, with an
emphasis on clarifying missions and aligning program goals and
objectives with an entity's mission.[Footnote 11] Under the Government
Performance and Results Act (GPRA) of 1993, federal agencies must (1)
complete strategic plans in which they define their missions, establish
results-oriented goals, and identify the strategies that will be needed
to achieve those goals; (2) measure performance toward the achievement
of the goals in an annual performance plan; and (3) report annually on
their progress in program performance reports.[Footnote 12] On the
basis of specific statutory requirements, departments and agencies are
to implement programs to support their missions and goals. In addition,
federal laws have focused on improving the efficiency and effectiveness
of agencies' business operations by increasing their financial
accountability and technical capabilities. In particular, the Chief
Financial Officers Act of 1990[Footnote 13] requires federal agencies
to develop and maintain integrated accounting and financial management
systems that provide for complete, reliable, and timely financial
information facilitating the systematic measurement of performance, the
development and reporting of cost information, and the integration of
accounting and budget information. Another act, the Clinger-Cohen Act
of 1996,[Footnote 14] requires the Office of Management and Budget to
establish processes to analyze, track, and evaluate the risks and
results of major capital investments in information technology systems
made by executive agencies. Generally, departments and agencies have a
number of business operations supporting their programs: budget,
information technology, financial management, human capital, and
acquisition.
Past Efforts to Reorganize Federal Land Management:
At least five major proposals have been put forth in the last 40 years
to reorganize federal land management agencies.[Footnote 15] These
proposals ranged from creating a department of natural resources, which
would have housed all federal land management agencies, to exchanging
lands among agencies to create more contiguous blocks of land for each
agency to manage. All the proposals projected benefits for efficiency
and effectiveness of land management, but none of them was carried out.
One of the proposals, however, was embedded in a larger report with
more than 130 recommendations for improving federal land management--
the Public Land Law Review Commission's report--which did contribute to
a major alteration of federal policy. The commission's recommendations
provided a basis for the Federal Land Policy and Management Act of
1976, which established as national policy that the public lands be
retained in federal ownership and managed through land use planning.
(See appendix III for a discussion of the five historical proposals for
restructuring federal land management, including that of the Public
Land Law Review Commission.)
Smaller-scale pilot efforts have also been made to "reorganize" land
management agencies by increasing the extent to which they conduct
joint or integrated programs or business operations. Two such efforts
are the Service First initiative, begun by the Forest Service and BLM
in 1996,[Footnote 16] and the oil and gas federal permit pilot project,
authorized by the Energy Policy Act of 2005.[Footnote 17] Both efforts
seek to improve the agencies' customer service, operational efficiency,
and land management. Under the Service First authority--which allows
the agencies to conduct projects, planning, permitting, leasing,
contracting, and other activities jointly or on behalf of one another-
-some local units of the Forest Service and BLM have begun integrating
their programs and operations to various degrees. For example, in
Durango, Colorado, the Forest Service and BLM are located in the same
building and have joined their staff under one leadership team formed
from staff of both agencies. In Portland, Oregon, on the other hand,
although the Forest Service regional office and the BLM state office
are located in the same building and have interagency teams, they
retain separate management; the agencies conduct joint programs and
operations when a business case can be made for joint effort, including
colocating field offices, developing integrated mapping programs, and
sharing radio equipment. Similarly, to improve coordination of permits
for oil and gas exploration, leasing, and production on federal lands,
the Energy Policy Act of 2005 designated seven BLM offices as pilot
offices with interagency staff, although it did not change Forest
Service or BLM responsibilities. For example, at the Glenwood Springs,
Colorado, office--which is still in the process of colocating--Forest
Service and BLM staff work jointly on NEPA analyses, permit approvals,
and inspection of oil and gas sites. (See apps. IV and V for more
detailed descriptions of Service First efforts and the oil and gas
permit pilot project.)
Moving the Forest Service into Interior Would Align Federal Land
Management Missions and Could Improve Effectiveness of Federal Programs
yet May Yield Few Efficiencies in the Short Term:
Moving the Forest Service into Interior could improve federal land
management by aligning the federal land management mission under one
department and creating an opportunity for greater effectiveness in
program management. According to many agency officials and experts with
whom we spoke, where the Forest Service mission is aligned with
Interior's--in particular, the multiple-use mission comparable to
BLM's--a move could increase the overall effectiveness of some of the
agencies' programs and policies. At the same time, however, a move may
yield few efficiencies in program management and could diminish the
role the Forest Service plays working with farmers, ranchers, and state
foresters to conserve resources on state and private lands--a mission
focus the Forest Service shares with USDA but would not have in common
with Interior. Officials said that existing efforts to integrate
programs, such as Service First, demonstrated improvements in the
effectiveness of program management and public service, but agency
reports showed little increased efficiency, in part because of the
complexity of measuring and documenting savings across agencies. Many
of the experts and officials we interviewed suggested that options
other than moving the Forest Service into Interior might have a greater
likelihood of improving land management or increasing the efficiency
and effectiveness of the agencies' diverse programs.
Although a Move Would Align Federal Land Management Missions, It Could
Diminish the Forest Service's State-and Private-Lands Mission and
Change Its Research Organization:
One result of moving the Forest Service into Interior would be an
alignment of the federal land management mission in one department by
bringing the Forest Service together with the other three federal
agencies having major land management missions. According to many of
the experts and officials we interviewed, however, a move of the Forest
Service into Interior could also diminish the role that the agency
plays in managing state and private forestlands and could change the
way the Forest Service does research.
Federal Land Management Missions Would Be Aligned by a Move:
One reason to create a new organization or reorganize an existing one
is to pull together agencies with similar programs to focus on a
priority mission area, according to several of the public
administration experts we interviewed. Moving the Forest Service into
Interior would align the agencies' land management missions and
programs in one department, potentially improving land management by
allowing different uses to be weighed and balanced against one another.
The Forest Service manages about one-quarter of all federal lands under
a land management mission that, many of the officials and experts we
interviewed noted, is similar to that of Interior's land management
agencies. While the Forest Service manages more than 190 million acres
of forestland, Interior's agencies manage almost 450 million acres of
land across the nation. As shown in figure 1, Forest Service and
Interior lands often abut each other and are sometimes intermingled. As
a result, particularly in the western states, land managers often cross
each other's lands to work on their own lands and work with members of
the same communities. Several experts and officials pointed to the
amount and proximity of Forest Service's and Interior's lands as a
reason for moving the Forest Service into Interior.
Figure 1: Federal Lands in the Contiguous United States Managed by
USDA's Forest Service and by the Department of the Interior:
[Refer to PDF for image]
This figure is a map of the continental United States with shading
indicating federal lands in five categories:
Forest Service;
Bureau of Land Management;
Bureau of Reclamation;
Fish and Wildlife Service;
National Park Service.
Source: GAO analysis of U.S. Geological Survey's National Atlas Web
site data.
[End of figure]
The agencies have similar mission statements, as shown in table 1. Both
the Forest Service and BLM state that they strive to sustain the
health, diversity, and productivity of the lands they manage, while the
Fish and Wildlife Service and National Park Service manage their lands
for conservation and the benefit of current and future generations.
Table 1: Forest Service and Interior Agencies' Mission Statements:
Agency: Forest Service;
Mission statement: To sustain the health, diversity, and productivity
of the nation's forests and grasslands to meet the needs of present and
future generations.
Agency: Interior;
Mission statement: To protect and manage the nation's natural resources
and cultural heritage; provide scientific and other information about
those resources; and honor its trust responsibilities or special
commitments to American Indians, Alaska Natives, and affiliated Island
Communities.
Agency: BLM;
Mission statement: To sustain the health, diversity, and productivity
of the public lands for the use and enjoyment of present and future
generations.
Agency: Fish and Wildlife Service;
Mission statement: To work with others to conserve, protect, and
enhance fish, wildlife, and plants and their habitats for the
continuing benefit of the American people.
Agency: National Park Service;
Mission statement: To promote and regulate the use of the ... national
parks ... to conserve the scenery, natural and historic objects, and
wildlife and to provide for the enjoyment of the same to leave them
unimpaired for the enjoyment of future generations.
Source: Forest Service and Interior.
[End of table]
Many officials and experts also noted, in particular, the similarities
between the Forest Service's and BLM's overall multiple-use missions
and programs. Both agencies manage their lands for multiple uses,
including timber, grazing, oil and gas, recreation, wilderness, and
wildlife habitat, although they emphasize different uses depending on
their specific authorities and public demands. For example, Forest
Service lands are largely forested and the agency has focused in the
past on timber harvest, while BLM's lands are primarily rangelands and
the agency has historically focused on providing forage for livestock.
Recent trends, however, reveal a decline in the amount of timber
harvested from national forests--from more than 12 billion board feet
to about 2 billion board feet[Footnote 18] in the last 20 years--which
many officials and experts said shows a shift in emphasis of Forest
Service responsibilities from timber harvesting to protecting and
providing multiple resources in a sustainable manner. More
specifically, trends in timber harvest over the last 2 decades have
reflected increasing production from private lands in the rest of the
country, as well as increased protection of endangered species on
forests in the western states; in addition, imports of timber have
grown in the last decade. The last several years have also seen an
increase in oil and gas exploration and drilling on BLM lands and some
Forest Service lands, according to a number of officials. Many
officials also noted similar increases in the demand for recreation on
both Forest Service and BLM lands.
Some of the officials and experts we interviewed view the four
agencies' missions and programs as similar, in that the agencies all
manage natural resources on their lands. These officials and experts
described the agencies' roles along a continuum, with BLM at one end
providing for extractive uses and the Fish and Wildlife Service and
National Park Service at the other providing preservation and habitat.
According to these officials and experts, Forest Service activities
overlap with each of these agencies. For example, BLM has jurisdiction
over underground oil and gas reserves on all federal lands, whereas the
Forest Service manages the oil and gas leasing and activities occurring
on national forests and grasslands. The Forest Service also oversees a
large share of the nation's wilderness areas--about 30 percent of the
total 107 million acres--similar to the National Park Service, which
manages about 41 percent of total wilderness acreage. And the number of
visitors and structures managed by the Forest Service is similar to the
number managed by the National Park Service. For example, in fiscal
year 2007, the Forest Service hosted almost 200 million visits, while
more than 275 million visits occurred on National Park Service lands in
the same year. While the Forest Service has more acres and the
possibility of dispersed recreation across these acres, it also has
many large developed recreation areas, such as campgrounds, much like
the National Park Service.
Finally, several of the officials and experts we interviewed identified
climate change, in addition to the agencies' existing missions, as a
new area that the land management agencies need to tackle. One expert
indicated that because climate change will greatly alter ecosystems
across the country, federal lands should be managed to provide
ecosystem services, which include biodiversity, clean air and water,
and other benefits derived from natural processes and systems. Several
officials identified opportunities for federal forests, as well as
private and state forests, to participate in markets for carbon
emissions trading because trees hold, or sequester, large amounts of
carbon as they grow.
Federal Focus on All Forested Lands, including State and Private, Could
Be Diminished:
The Forest Service's mission of working with state and private
landowners, a focus it shares with USDA, could be diminished by moving
the Forest Service away from USDA. USDA's mission--to use sound science
and policy to provide leadership on food, agriculture, and natural
resources--includes a goal to protect and enhance the nation's natural
resources on public and private lands. Some experts we interviewed
remarked on the importance of determining whether parts of an agency's
mission may be compromised by a move or reorganization. Some experts
said that in creating DHS, for example, Congress protected the Coast
Guard and its important life-saving mission by leaving it intact in the
new department. Such attention was not given to the Federal Emergency
Management Agency, however, and some experts believed that
reorganization compromised this agency's mission and capacity to
respond to large-scale natural disasters, particularly at the time of
Hurricane Katrina.[Footnote 19]
Some officials, experts, and state foresters said that a move could
disrupt the Forest Service's relationships with state and private
landowners, and with other USDA agencies, compromising the agency's
work with these entities in carrying out the mission of protecting and
enhancing state and private lands. Like USDA and its other agencies,
the Forest Service has adopted a watershed approach, which aims to
improve the condition of land and natural resources in a watershed
regardless of ownership. Toward this goal, the Forest Service's state
and private forestry arm provides technical and financial assistance to
state and private landowners to sustain and conserve forests and
protect them from wildland fires. Such outreach, or extension service,
is not a function of Interior agencies. In particular, under the
Cooperative Forestry Assistance Act of 1978,[Footnote 20] the Forest
Service has several programs to assist state foresters and private
owners in conserving soil, water, and wood resources on state and
private lands, including funding a portion of each state's forestry
program. Particularly in the eastern states, where state and private
forests are more abundant, state foresters use these funds to manage
state lands and provide services to private landowners who own and
manage small timber plots. According to many officials and others we
interviewed, moving the Forest Service into Interior could diminish
this role by directing the agency's attention to its federal lands and
away from the nation's nearly 750 million acres of forested lands
(shown in figure 2), including almost 430 million acres of private
forested lands across the nation, many of which are in the East near
national forests.
Figure 2: Forested Lands in the Contiguous United States, 2000:
[Refer to PDF for image]
This figure is a map of the continental United States with shading
indicating forested lands in the following categories:
White-red-jack pine;
Spruce-fir;
Longleaf-slash pine;
Loblolly-shortleaf pine;
Oak-pine;
Oak-hickory;
Oak-gum-cypress;
Lodgepole pine;
Larch;
Fir-spruce;
Redwood;
Chaparral;
Pinyon-juniper;
Western hardwoods;
Elm-ash-cottonwood;
Maple-beech-birch;
Aspen-birch;
Douglas-fir;
Hemlock-Sitka spruce;
Ponderosa pine;
Western white pine.
Source: U.S. Geological Survey's National Atlas Web site.
[End of figure]
A number of officials believed, however, that a move would not cause
the Forest Service to change its role, including its state and private
forestry programs, if it were moved into Interior with its authorities
intact. Although Interior largely focuses on federal lands and does not
have a state and private aspect to its mission, some officials said
that Interior could work more with state and local entities if the
authorities to do so were transferred with the Forest Service to
Interior and extended to Interior's other agencies. Officials
identified areas in which some of Interior's agencies have begun
playing a role in providing nonfederal entities with resources to
conserve or protect natural resources. For example, the Fish and
Wildlife Service's Partners for Fish and Wildlife Program provides
nonfederal groups with funding to protect habitat for threatened and
endangered species on private lands. In another example, BLM and
Interior's other land management agencies provide funding to local fire
departments to help them prepare to fight wildland fires. In commenting
on our report, Interior also said that the department's ability to
conserve endangered species, wetlands, and other resources could be
improved by a move. Other officials and state foresters, however, said
that USDA has developed a closer relationship with state and private
entities and has a better perspective on what private landowners need
to conserve their resources. For example, state foresters said their
relationship with USDA is longer, going back to the early twentieth
century, when state forestry assistance programs developed.
Research Organization Could Be Changed:
Moving the Forest Service into Interior could provide a research
benefit to Interior's land management agencies but could also affect
the Forest Service research organization and its focus. Several
officials saw in a move the opportunity for BLM, in particular, to gain
access to and benefit from rangeland and fire research conducted by the
Forest Service research stations. But, a number of officials and some
experts said that a move of the Forest Service into Interior could
result in reorganization of Forest Service research into Interior's
U.S. Geological Survey (USGS), which could change the focus of the
Forest Service's research branch. The Forest Service and Interior are
organized differently to achieve the research component of their
respective missions. The Forest Service's research arm is part of the
agency, which according to some officials and experts creates a more
direct link with forest management and land management decisions. On
the other hand, Interior's science agency--USGS--is a stand-alone
agency that provides scientific research and support to all the land
management agencies and other agencies within Interior. According to
one official, philosophies differ about how to organize most
effectively to manage science and to distribute it to land managers;
some officials said that the Forest Service's approach may be more
accountable to land managers, while others said having a separate
agency devoted to science provides greater credibility and potentially
less political interference.
A number of officials said that the Forest Service should stay in USDA
because its research program is closely related to USDA's. Some pointed
to similarities in the Forest Service's and Natural Resources
Conservation Service's (NRCS) responsibilities, including their
responsibilities to inventory agricultural and forest resources grown
in the nation. Other officials and experts noted that Forest Service
research is turning toward emerging issues, such as ecosystem services
and climate change, in particular because forests consume large amounts
of carbon dioxide when they are young and growing but also release
carbon dioxide when trees burn or are cut down and decompose. For this
reason, some of the officials found this role closely related to USDA's
new responsibility--given to it in the Food, Conservation, and Energy
Act of 2008--to establish guidelines related to farmer, rancher, and
forest landowner participation in carbon markets[Footnote 21].
A Move Could Improve Effectiveness of Federal Land Management Programs
but May Yield Few Efficiencies in the Short Term, as Demonstrated by
Existing Efforts to Integrate Programs:
A move of the Forest Service into Interior could improve the
effectiveness of federal land management programs overall, according to
many agency officials and experts with whom we spoke. In particular,
such a move could increase the effectiveness of several Forest Service
and BLM programs and policies because of the similarity of their
multiple-use missions. Most officials and experts we interviewed said,
however, that a move would not result in many efficiencies in program
management in the short term, although a number of them said that
efficiencies might be gained over many years if the department took
action to standardize its information technology and other business
systems. Existing efforts to integrate programs--such as wildland fire
coordination, the Service First initiative, and oil and gas permit
pilot project--illustrate the potential for increased effectiveness but
few efficiencies.
A Move Could Improve Program Effectiveness and Gain Efficiencies in the
Long Term While Yielding Few Short-Term Efficiencies:
Improvements in the effectiveness of federal land management programs
could result from a move of the Forest Service into Interior, according
to several officials, if the four agencies took the opportunity to
coordinate programs they have in common. A possible outcome of having
the land management agencies together in one department, according to a
number of officials and experts, could be the improvement of land
management across jurisdictional boundaries. For example, one official
said that landscape management could be improved, meaning that the
management of large areas of land could be better coordinated. Other
program areas that offer opportunities for improved coordination
include law enforcement, recreation, and wilderness management. The
four agencies each have law enforcement programs, although these
programs differ in terms of organization and authority. Similarly, the
four agencies developed a single recreation permit and Web site for
reservations at federal campgrounds but have other issues on which to
coordinate, such as prioritizing investments in recreation facilities
across federal lands. In terms of wilderness programs, the Forest
Service and National Park Service oversee the majority of wilderness
lands but have different policies and procedures for doing so.
The optimal approach for improving the effectiveness of federal land
management programs, according to many officials and experts, could be
to align the Forest Service's and BLM's statutes, regulations,
policies, and programs. Many of these officials and experts, however,
said an alignment would not automatically occur if the Forest Service
were moved into Interior and further action--legislative or executive-
-would need to be taken to improve effectiveness. Although the Forest
Service and BLM have multiple-use missions and similar programs for
managing their lands, the agencies' land management guidelines differ-
-a result of different statutes, regulations, or policies--and these
differences can confuse and frustrate the public seeking to use federal
lands. Often, the agencies' customers are the same, the services
provided are the same, and the resources used are similar, yet
differing laws, regulations, and policies can prevent the agencies from
integrating their activities. Officials identified a number of areas in
which the agencies' programs and policies differ and where aligning
them could improve the effectiveness of land management overall. They
cited the following examples:
* The Forest Service and BLM have different planning processes and time
frames, which means that adjoining units develop or amend these plans
at different times, and this difference can affect the units' ability
to conduct joint projects to improve resources. According to officials,
the Forest Service's and BLM's planning processes differ, in part,
because the agencies have different statutes and planning
regulations.[Footnote 22] In particular, according to officials, the
National Forest Management Act[Footnote 23] includes the concept of
biodiversity, which the Forest Service supports using studies of
population viability; under the Federal Land Policy and Management Act,
in contrast, BLM does not have this statutory or regulatory
requirement.
* The Forest Service and BLM do not take the same approach to oil and
gas management, and a move might help set consistent priorities for the
agencies' oil and gas programs. BLM manages federal oil and gas
resources underground or subsurface, while federal land management
agencies, including the Forest Service, manage the effects of oil and
gas drilling on their land or surface resources. According to some of
the officials we interviewed, the Forest Service and BLM have different
priorities for managing oil and gas resources, but if they were in one
department, these different priorities might be reconciled by
secretarial leadership. Specifically, the Forest Service is seen as
more cautious in allowing oil and gas development, while BLM is seen as
more responsive to opening lands to such development.
* The Forest Service and BLM have different internal administrative
appeals processes for resolving public challenges to proposed land
management projects. For example, BLM's leasing decisions can be
challenged to the appropriate BLM state office director, appealed to
the Interior Board of Land Appeals, and litigated in federal court. At
the Forest Service, planning and leasing decisions can sometimes be
appealed through the supervisory chain of command. In addition, the
Forest Service has specific time frames for deciding appeals, whereas
BLM and the Interior Board of Land Appeals do not. Differing processes
and time frames for resolving appeals can make it difficult for the
agencies to coordinate their joint projects.[Footnote 24]
* BLM's timber program differs in some respects from the Forest
Service's in Oregon, in part because of different statutory
requirements. In particular, according to some officials, BLM is
directed to manage its lands in Oregon primarily to produce timber, a
directive at variance with the multiple uses authorized on other BLM
and Forest Service lands. Also, the act governing these BLM
lands[Footnote 25] allows a greater share of receipts from timber
harvest on these lands to be shared with county governments. These
dissimilarities make it difficult for the agencies to coordinate their
timber programs in the western part of the state.
* The Forest Service's and BLM's grazing programs are not the same,
which means that ranchers with allotments on both agencies' lands can
face different requirements because of different agency regulations.
For example, the Forest Service may require cattle to be removed early,
before a BLM permit allows the same cattle to move onto its adjacent
lands.
* The Forest Service's and BLM's mapping and monitoring are hard to
coordinate, particularly with regard to geographic information system
(GIS) data, because the agencies use different databases, with
different rules for gathering certain data, and incompatible versions
of GIS software. Furthermore, when the agencies do try to share
databases, they cannot, because different security requirements prevent
staff of one agency from gaining access to the other agency's systems.
As a result, working on joint projects becomes more difficult and time-
consuming because maps are incompatible.
While many of the officials and experts we interviewed believed a move
would improve effectiveness, many did not believe a move would achieve
many efficiencies in the short term. A number of them, however,
believed that efficiencies might be gained in the long term if the
department took certain actions to convert the Forest Service to
Interior's information technology and other business systems. According
to several of the public administration officials we interviewed,
efficiencies are often the justification for major agency
reorganizations, even though reorganization does not often produce more
efficient organizations. Many agency officials and some experts
believed that few efficiencies would be achieved in the short term if
the Forest Service were moved into Interior as a separate bureau, with
its own authorities and programs. Some of these experts and officials
made the point that a move would not necessarily increase collaboration
or alter the Forest Service's statutes, regulations, or systems, which
would discourage changes leading to greater efficiencies, such as
moving to common management and information technology systems.
Furthermore, according to several officials, under a scenario in which
the Forest Service remains a separate bureau, there would be little
reduction in staff, and, therefore, few efficiencies gained. According
to other officials, depending on the structure of the Forest Service
within Interior, a new Assistant Secretary may even be needed to manage
the agency, necessitating the hiring of additional staff. Conversely, a
number of other officials and experts saw the move as an opportunity to
create some long-term operational efficiencies, particularly if
Interior converted Forest Service systems to Interior's systems,
including the department's information technology, financial, budget,
human capital, and other core business systems.
Existing Efforts to Integrate Programs Demonstrate Improved
Effectiveness but Few Efficiencies in the Short Term:
Some programs in which the Forest Service and BLM have coordinated
their efforts have demonstrated improvements in the effectiveness of
their program management and service to the public, a number of
officials and several experts said. These examples include management
of wildland fire suppression, Service First initiatives, and the oil
and gas permit pilot program. While these efforts may demonstrate
increased effectiveness, they do not always show increased efficiency
of program management, according to agency reports.
Wildland fire management. The Forest Service; BLM; Fish and Wildlife
Service; National Park Service; and the Bureau of Indian Affairs, which
works with Indian tribes to manage their more than 50 million acres of
tribal lands, have long coordinated their wildland fire suppression
efforts. The five agencies have been colocated and have worked together
at the National Interagency Fire Center in Boise, Idaho, since 1965
and, through the center, coordinate their mobilization of supplies,
equipment, and personnel to suppress wildland fires quickly and more
effectively. Coordination of firefighting assets and incident command
teams is guided by jointly developed Interagency Standards for Fire and
Aviation Operations (the Red Book). Coordination of other aspects of
wildland fire management, such as reduction of hazardous fuels,
outreach to communities at risk, and habitat restoration, has been
delegated to an intergovernmental Wildland Fire Leadership Council,
which was established by the Secretaries of the Interior and USDA in
2002. This council seeks to support implementation of federal fire
management policy by coordinating agency policies and providing
strategic direction.
Although the agencies have coordinated aspects of their suppression
programs, they still have key differences that hinder management
effectiveness and efficiency; such differences include incompatible
information technology, finance, procurement, human capital, and other
business operations and systems. For example, one difference mentioned
by several of the officials we interviewed is certification of
firefighters by the Forest Service and Interior. According to these
officials, firefighters certified by Interior have to take additional
training to be certified by the Forest Service because the Forest
Service and Interior have dissimilar qualification standards. Another
example is the lack of coordination of wildland fire budgets:
differences between the Forest Service and Interior agencies in how
they budget and pay for staff time produces estimates of firefighting
budgets that cannot be compared with each other.[Footnote 26]
Service First. The Service First offices (see appendix IV) have
integrated a number of programs that have helped improve the
effectiveness, and perhaps efficiency, of land management and public
service. For example, the San Juan Public Lands Center in Durango,
Colorado, is one of a few offices in the country that has cross-
delegated officials--that is, officials from the Forest Service who
have authority to manage BLM land and vice versa. The office has both
Forest Service and BLM staff working jointly to manage recreation
activities, grazing allotments, oil and gas exploration and production,
and other resources across federal lands. In addition, the agencies
share a front desk and information center for the public. The office
recently produced the nation's first joint land management plan,
although each agency is to approve the plan through its normal chain of
command. According to Forest Service and BLM officials, the office
provides better public service by making the agencies' processes
invisible to land users. For example, allowing recreation staff to
provide information and permits across Forest Service and BLM lands
means that members of the public need not apply for permits twice, once
to each agency. According to a community leader, Service First has been
successful because it allows the public "one-stop shopping" for
grazing, firewood, and recreation permits. It also increases the
effectiveness of land management by having resource specialists manage
the effects of different activities on both agencies' lands. Although
efficiencies could be gained through these efforts--to the extent that
staff duplication could be reduced-- no studies have been done
documenting these efficiencies.
The Service First efforts in Portland, Oregon, demonstrate improvements
in the effectiveness, and perhaps efficiency, of agency programs.
Forest Service Region 6 Office and the Oregon and Washington State
Office of BLM have colocated part of their management teams, allowing
them to coordinate more closely on land management issues such as the
Northwest Forest Plan. The agencies have integrated parts of their GIS
databases and mapping efforts, producing single recreation maps showing
both agencies' lands, as well as state lands. Another Service First
effort--a coordinated radio system throughout central Oregon--allows
the agencies to share and jointly maintain their radio equipment.
Furthermore, the agencies have written joint guidance on colocation to
assist their other field offices in making a business case for
colocation. A number of field units in the region and states have
colocated or are considering doing so. Efforts to produce unified maps
and use joint equipment could provide efficiencies if they reduce
duplication of staff effort or equipment purchased, and colocation
efforts can produce efficiencies if rents are saved; again, however,
studies have not been done to estimate the efficiencies.
The Service First efforts also demonstrate some of the difficulties
that the Forest Service and BLM have working together because of
different systems and the resulting inefficiencies. For example,
although the Colorado and Oregon Service First offices have integrated
aspects of their programs, the offices have to maintain two computer
systems, one for the Forest Service and the second for BLM. Dual
systems also exist for budget, human capital, and financial operations.
Consequently, staff must learn two sets of regulations and policies for
managing common projects and activities. A recent review by Forest
Service and BLM officials noted the increased workload and
inefficiencies stemming from two sets of rules and processes. Another
recent agency review identified the complexity of measuring data
consistently for the participating agencies, which in turn makes
efficiencies hard to document.
Oil and gas permit pilot project. A pilot project integrating federal
agencies' oil and gas permitting functions (see appendix V) has also
produced examples of increased program effectiveness. The Glenwood
Springs Energy Office--a joint Forest Service-BLM pilot project office
in Glenwood Springs, Colorado--has hired several specialists to help
manage increased workloads across both Forest Service and BLM lands.
The office also created an interagency team to manage most aspects of
oil and gas permitting such as conducting NEPA analysis on companies'
applications to drill on federal lands, analyzing rights-of-way for
pipelines and roads, analyzing drilling effects, approving permits, and
inspecting drilling operations once a permit is approved and oil and
gas are found. According to BLM reports, with additional staff, the
amount of time needed to approve permits has decreased, and the number
of inspections for both operational and environmental compliance has
increased. While Forest Service staff use BLM systems, which avoids the
inefficiency of using two systems, the agencies' budget, financial,
human capital, and other systems are not integrated, so staff must use
two systems to manage these areas.
Other Organizational Options May Better Define Land Management Mission,
Achieve Greater Efficiency and Effectiveness, or Both:
Many agency officials and experts we interviewed suggested that if the
objective of a move is to improve land management or increase the
efficiency and effectiveness of the agencies' diverse programs, other
organizational options may achieve better results than moving the
Forest Service into Interior. None of these officials and experts
identified one particular option as best overall; rather, they
recommended several:
* Increase collaboration and coordination through efforts such as
Service First. To increase the effectiveness, and perhaps efficiency,
of federal programs, a number of officials and some experts supported
intensifying efforts to collaborate and coordinate between agency
programs; some of them even supported creating a council or task force
to highlight programs for more effort. A move would not be necessary,
according to multiple officials and experts we interviewed, since
similar gains can be had by strengthening coordination and
collaboration between agency programs. Several experts said that in
deciding whether to move an agency, it is necessary to determine
whether agencies need to be together to carry out their work or whether
they can get that work done by other means, such as enhanced
collaboration and coordination.
* Review public land laws and then decide on agencies' organization. A
number of officials and experts said that public land laws should be
reviewed before a move, and some said that moving organizations would
simply be rearranging organizational boxes with little effect. Some
officials and experts stated that to gain efficiency and effectiveness,
a new legal framework would be needed, with consistent laws and
regulations. Others said that federal land laws--which establish agency
missions and goals--have created a patchwork of land management
agencies and may not reflect the best approach for managing lands to
provide the public what it wants. A few suggested that to gain
efficiencies, the laws could require the agencies to collaborate on
crosscutting issues. Some, considering challenges such as climate
change, stated that the focus of federal land management needs to
change to respond appropriately. For a review of federal land law with
any recommendations about legislative or structural changes, this
option would likely involve a task force or commission, similar to the
1964 Public Land Law Review Commission.
* Create a department of natural resources. A number of officials and
experts said a new department of natural resources should be created to
house all the federal resource agencies, including the Forest Service
and those in Interior. Some said that having one department focused on
natural resources would allow the Secretary to balance use of federal
natural resources with their protection. One official stated that such
an organization would bring together all the conservation-oriented
agencies, thereby improving management of lands located in the same
watersheds. A few officials and an expert stated that moving the Forest
Service into Interior could be the first step in creating such a
department. One rationale behind similar proposals made during the
Nixon and Carter administrations identified the possibility of
improving management of all federal resources and weighing resource use
and protection.
* Merge the Forest Service and BLM. Numerous officials and experts said
that moving the Forest Service into Interior without changing the
agencies' authorities would change little in the agencies' programs or
policies to increase their effectiveness or efficiency. Some officials
and experts identified inefficiencies in management as stemming from
inconsistent laws and regulations and thought a merger would begin to
remove these inconsistencies. The Public Land Law Review Commission
recognized the need for further reorganization of land management
agencies or functions within Interior if the Forest Service were moved
into the department. It recommended, first, that the Forest Service be
merged into Interior but also, second, that the Secretary reorganize
land management functions, including those within the Forest Service.
* Organize agencies geographically. Several officials and experts
stated that the best option for reorganizing the land management
agencies would be based on geographic distinctions. A geographic
organization could unify lands along ecosystem or other geographic
boundaries, according to several officials and some experts, helping to
resolve the intermingling of Forest Service and BLM lands and thereby
enabling better management of federal lands. This proposal is similar
to the interchange proposals recommended in the 1980s by the Grace
Commission[Footnote 27] and a task force of Forest Service and BLM
employees; these proposals recommended exchanging isolated areas of
federal land to create large, contiguous blocks of either Forest
Service or BLM land, facilitating more efficient and effective
management of those lands by one agency or the other.
* Move BLM to USDA. A few officials suggested moving the BLM into USDA
rather than moving the Forest Service into Interior. These officials
said that having the two multiple-use federal land management agencies
in USDA would retain and enhance the multiple-use missions of both
agencies and would bring them into the same organization as the NRCS,
which provides technical advice and funding to private landowners. Some
officials and interest groups said USDA's mission is more in line with
active land management, which involves using the lands to produce
resources such as timber and crops, while Interior's approach to land
management is generally more in line with preservation, including
preservation of habitat, species, and wilderness.
In addition to these options, a number of officials and experts thought
the Forest Service should remain separate from Interior and its
agencies because it provides an alternative model of land management. A
few officials said that consistency in land management may benefit land
users, but otherwise, the Forest Service and BLM serve to check and
balance each other, in that no one Secretary manages all public lands,
thereby diminishing the influence one person can have on these lands.
Other officials and experts pointed out that the two agencies manage
different lands and therefore have different management purposes: the
Forest Service manages higher, wetter, mountainous lands, while BLM
manages lower-elevation rangelands. One expert stated that the Forest
Service business models first need to be fixed to improve the agency's
efficiency and effectiveness and that moving would not achieve this
result.
Several officials described--and rejected--other options that have been
raised in policy discussions. One such option was the idea of splitting
the Forest Service into parts and moving the arm focused on national
forests into Interior while leaving the state and private forestry arm
in USDA. While some thought this idea was viable, a number of officials
and experts rejected the idea because it would split the federal
government's forestry expertise into two departments. Other officials
and experts told us that an option to create a separate fire agency
from all the agencies' wildland fire operations had been discussed by
managers and policymakers, but they did not believe this option should
be considered because it would separate firefighting from land
management--a separation that some argued would not provide for
effective or efficient management of either activity. Although one
official said it could be possible to set up a separate agency to deal
with large-fire suppression and still allow land management agencies to
handle initial attacks on fire, others said that wildland fire
suppression funding is problematic and would not be solved by
reorganization.
Move Would Entail Consideration of Numerous Factors and Could Lead to
Transition Costs, but Key Merger and Transformation Practices Could
Help Facilitate Move and Manage Disruptions:
Moving the Forest Service into Interior would raise a number of
cultural, organizational, and legal factors and related transition
costs for Interior and USDA to consider. Nevertheless, our previous
work has identified some key practices that Interior and USDA could
implement to help manage disruptions and other transition costs; the
experts and agency officials we interviewed mentioned several of these
practices.
Given Cultural, Organizational, and Legal Factors, a Move Could Lead to
Disruptions and Other Transition Costs:
Moving the Forest Service into Interior could lead to transition costs,
including lost productivity and operational costs.[Footnote 28] The
Forest Service and Interior's land management agencies have varied
cultures that could clash, decreasing morale and productivity if
employees resisted a move. Moreover, a number of organizational factors
could also complicate a move, such as integrating the Forest Service
into Interior's information technology and other business systems,
which would take time and resources to accomplish. Further, complex
legal issues, such as differing statutory authorities, may also need to
be reconciled.
Agencies' Cultural Differences Could Decrease Morale and Productivity:
As a result of the land management agencies' long, distinct histories,
differences between the Forest Service's culture and those of
Interior's land management agencies may produce clashes resulting in
decreased morale and productivity if the Forest Service were moved into
Interior. All the land management agencies have deeply rooted cultures
and employees who are loyal to their respective agencies and
departments. According to two experts, because these agencies were
established for different reasons and historically emphasized different
uses of federal lands (partly because each agency's land base contains
a different mix of resources), the agencies' employees take pride in
different things. For example, in part because BLM was created out of
the General Land Office and Grazing Service, it focuses more on
ranching and oil and gas than do the other land management agencies,
which influences the agency's culture, some officials said. In
contrast, the Forest Service historically emphasized timber production
and conservation, and over its 100-year history has developed a unique
culture: employees have a deep commitment to and pride in the agency
and its mission, strong esprit de corps, and a high degree of
independence, but they may also be seen as insular and resistant to
change, according to some officials. Within Interior, BLM is viewed as
a flexible, "can-do" agency; the Fish and Wildlife Service is focused
on its regulatory function and being the "savior of species;" and the
National Park Service has a culture similar to the Forest Service's,
with a strong esprit de corps and pride in the agency, officials said.
While the agencies' cultures stem in large part from their histories,
the cultures have also developed as a result of each agency's level of
autonomy within USDA or Interior. Several officials said that the
Forest Service has a fair degree of independence within the department.
For example, within USDA, the Forest Service budget does not receive as
much attention or scrutiny as other agency budgets, according to some
officials. Some officials indicated that after a move, the Secretary of
the Interior might exert more influence over the Forest Service--a
cultural change. The Forest Service's independence is also partly due
to the position of its Chief, who has typically been a career Forest
Service employee and not a political appointee--unlike the heads of BLM
and the other Interior agencies--and Forest Service employees take
great pride in their Chief's role as the "nation's forester." Some
experts and officials noted, however, that recently a new Chief of the
Forest Service has taken charge with each new administration, and the
Forest Service has become more politicized than it was in the past.
According to several experts and officials, having politically
appointed agency heads has caused BLM and the other Interior agencies
to experience greater shifts in their programs depending on the
administration, as opposed to the Forest Service, which tends to stay
the course.
Because of these cultural differences, many officials and experts
believed that moving the Forest Service into Interior could lead to
decreased morale and productivity. According to our past work, the
experience of major private sector mergers and acquisitions is that
productivity and effectiveness decline in the period immediately
following a merger and acquisition.[Footnote 29] Some experts and
officials indicated that Forest Service employees may feel a loss of
identity and independence in leaving USDA and would fear and resist a
move. At the same time, some officials and experts noted that a move
may leave employees of Interior and its bureaus feeling threatened,
worrying that because of its size, the Forest Service would dominate
Interior, so they too may resist a move; currently, the Forest Service
has about 29,000 permanent employees compared with a total of about
54,000 permanent employees in Interior, of which the largest agency is
the National Park Service, with about 16,000 permanent employees.
Consequently, many experts and officials indicated that employees may
be difficult to motivate, leading to decreased efficiency and
effectiveness immediately after a move. One expert added that the
longer employees have been at the Forest Service, the more they will
resist a change. Moreover, according to many officials and experts, the
agencies may see an increase in the number of retirements and
resignations after a move, which may facilitate cultural change but
also decrease productivity because of the loss of experienced staff.
For these reasons, many experts and officials predicted that it could
take at least several years--perhaps as long as a generation--for
Forest Service employees to fully assimilate into another department.
According to officials located in the Durango Service First office,
cultural issues would certainly be a factor in a move, but they would
not be insurmountable. They observed that the Service First initiative
has demonstrated that some cultural barriers between the Forest Service
and BLM can be broken down, although they also observed that it has
taken over a decade to do so.
The consolidation of Interior's National Biological Service into USGS
offers one illustration of possible cultural implications of moving the
Forest Service into Interior. The National Biological Service was
created in 1993[Footnote 30] to gather, analyze, and disseminate
biological information necessary for the sound stewardship of the
nation's natural resources and was originally staffed with scientists
from other agencies under Interior. In 1996, amid concerns about
federal agencies' searching for threatened and endangered species on
private land and concerns expressed by congressional appropriations
committees, the agency was merged into USGS as a new Biological
Resources Division. According to an Interior official, the cultural and
emotional aspects of the move caused a lot of hardship and mistrust
among employees within both the former National Biological Service and
USGS. For example, after the move, the agencies had to compare and
reconcile their scientific standards and processes, and scientists
argued about who was practicing pure or ethical science, according to
agency officials. Moreover, USGS had a long history of physical science
and geology, so it was something of a "forced marriage" to add the
biological sciences, one official said. As a result, the move led to
initial losses of productivity since the National Biological Service
employees had to learn about USGS and its processes. According to an
agency official, the transition into USGS took 4 to 5 years, and more
than a decade afterward, some employees still question the move. As our
past work shows, it can take at least 5 to 7 years to fully implement
initiatives to merge or transform organizations and sustainably
transform their organizational cultures.[Footnote 31]
Organizational Factors Could Complicate a Transition:
According to many experts and officials we interviewed, changes needed
to departmental and agency organization could complicate a transition
of the Forest Service from USDA into Interior and would need to be
considered. Factors needing attention include the organizational
structures of the agencies; effects on Interior functions, such as its
Office of Inspector General; the need to integrate the Forest Service
into Interior's information technology and other business systems;
effects on USDA functions, such as its relationship with other USDA
agencies; and human capital practices.
Organizational structure. Officials and experts raised differences
among the organizational structure of USDA, Interior, and their
respective agencies as a factor to be considered in a move. USDA is
home to 19 agencies, most of whose missions relate to agriculture, and
Interior has 9 agencies, which manage public lands and natural
resources, as well as Native American trust resources. Both are cabinet-
level departments organized under politically appointed Secretaries and
Deputy Secretaries, but the organizational structures of the
departments differ at the next levels, as shown in figures 3 and 4.
USDA has seven Under Secretaries, while Interior has five Assistant
Secretaries, all of whom are politically appointed.[Footnote 32] At the
agency level, the directors of Interior's land management agencies are
politically appointed, unlike the Chief of the Forest Service.
According to some agency officials and experts, if the Forest Service
were moved, Interior would need to consider how the Forest Service
would be placed in the department, unless this organization were
legislated. In particular, agency officials questioned which of
Interior's Assistant Secretaries the Forest Service would fall under or
if a new Assistant Secretary position would be created. Further, some
questioned whether the Forest Service would retain its career Chief or
if the Chief would be replaced with a politically appointed director,
consistent with Interior's other bureaus.[Footnote 33]
Figure 3: Organizational Chart for Interior:
[Refer to PDF for image]
Secretary:
Deputy Secretary:
* Chief Information Officer;
* Assistant Secretary Policy, Management and Budget;
- National Business Center;
* Inspector General;
* Special Trustee for American Indians;
* Solicitor;
* Assistant Secretary Fish and Wildlife and Parks;
- National Park Service;
- U.S. Fish and Wildlife Service;
* Assistant Secretary Indian Affairs;
- Bureau of Indian Affairs;
* Assistant Secretary Land and Minerals Management;
- Bureau of Land Management;
- Office of Surface Mining Reclamation and Enforcement;
- Minerals Management Service;
* Assistant Secretary Water and Science;
- U.S. Geological Survey;
- Bureau of Reclamation.
Source: Interior.
[End of figure]
Figure 4: Organizational Chart for USDA:
[Refer to PDF for image]
Secretary:
Deputy Secretary:
* Chief Information Officer;
* Chief Financial Officer;
* Inspector General;
* Executive Operations;
* Director of Communications;
* General Counsel;
* Under Secretary for Natural Resources and Environment;
- Forest Service;
- Natural Resources Conservation Service;
* Under Secretary for Farm and Foreign Agricultural Services;
- Farm Service Agency;
- Foreign Agricultural Service;
- Risk Management Agency;
* Under Secretary for Rural Development;
- Rural Utilities Service;
- Rural Housing Service;
- Rural Business Cooperative Service;
* Under Secretary for Food, Nutrition, and Consumer Services;
- Food and Nutrition Service;
- Center for Nutrition Policy and Promotion;
* Under Secretary for Food Safety;
- Food Safety and Inspection Service;
* Under Secretary for Research, Education, and Economics;
- Agricultural Research Service;
- Cooperative State Research, Education, and Extension Service;
- Economic Research Service;
- National Agricultural Library;
- National Agricultural Statistics Service;
* Under Secretary for Marketing and Regulatory Programs;
- Agricultural Marketing Service;
- Animal and Plant Health Inspection Service;
- Grain Inspection, Packers and Stockyards Administration;
* Assistant Secretary for Congressional Relations;
* Assistant Secretary for Administration;
* Assistant Secretary for Civil Rights.
Source: USDA.
[End of figure]
Interior functions. Moving the Forest Service into Interior would
likely increase the workload at the departmental level and strain
shared departmental resources. According to some officials and an
expert, adding about 29,000 Forest Service employees to Interior would
likely require more support personnel at the departmental level, such
as in human capital. Moreover, officials noted that employees may need
to be brought into Interior from USDA's Offices of Inspector General
and General Counsel to contribute agency expertise and address the
increased workload that would move with the Forest Service. To audit
the Forest Service, for example, employees in Interior's Office of
Inspector General would need to learn the agency's policies and
procedures, as well as communicate with USDA's Office of Inspector
General to ensure effective follow-up on past audit recommendations.
Similarly, since the Forest Service operates under a different set of
laws than Interior's agencies, attorneys in Interior's Office of the
Solicitor would face a learning curve. As a result, a move of the
Forest Service into Interior could lead to disruption and lost
productivity as Interior employees adjusted to their new workload and
familiarized themselves with the Forest Service, according to some
experts and officials, and the department could incur some additional
costs if extra employees needed to be hired. Furthermore, a move could
create additional expenses related to expanding office space;
purchasing new computers, uniforms, and other necessary equipment; and
changing signs and letterhead.
Information technology and other business systems. Integrating the
Forest Service's reporting, budgeting, finance, acquisition, and human
capital processes and systems into Interior's would be difficult, time-
consuming, and costly, according to many experts and officials. To do
so, the Forest Service would have to disengage from USDA's systems and
reconnect to Interior's systems, which could be risky; for example, the
transition could compromise information technology security, according
to officials. Moreover, some employees said that integrating systems
could be particularly complex because of the large number of Forest
Service employees. One official estimated that costs to integrate
systems could be on the order of tens of millions of dollars, while
others estimated costs on the order of hundreds of millions of dollars.
[Footnote 34] According to other officials, however, since the agencies
already update their systems as technology changes, the Forest Service
could be moved into Interior's systems during one of these updates. In
addition to integrating the Forest Service into Interior's systems,
some officials said, there would also be software-licensing issues
associated with adding such a large number of users, as well as the
need to train Forest Service employees on Interior's systems and
processes. A few officials said that at least in the short-term, the
Forest Service could retain its current systems if it were moved into
Interior, but other officials said that running parallel systems would
not work well and would be costly and inefficient.
At the time of our review, Interior and USDA were both moving to new
financial management systems, and some officials believed it would be
an opportune time to move the Forest Service into Interior since the
agency could be merged into Interior's new financial system without
further investment in USDA's system. Because both agencies are in the
planning stages for their new systems, a move of the Forest Service
into Interior's system now would avoid additional costs for the Forest
Service to conform to USDA's systems. In addition, according to
officials, if the Forest Service were moved while Interior was
developing its own new financial system, the Forest Service could be
part of the design process and help identify system requirements. Other
officials noted that Interior has already experienced some setbacks
with its new financial system--for example, it had to pare back the
number of subsystems that will be included in it--and indicated that
adding the Forest Service to Interior's systems could introduce more
challenges.
Other officials said, however, that now is not a good time to move the
Forest Service, because the agency has recently gone through many
difficult changes and may not be able to handle additional change
without detracting from its service to the public. One recent change is
the consolidation of some of the Forest Service's business practices
and systems, including its finance, human capital, and information
technology functions, into the Albuquerque Service Center, located in
Albuquerque, New Mexico. According to many officials, the consolidation
has been challenging and may illustrate some of the difficulties--
ranging from staffing and payroll errors to inadequate technical
support--that could be encountered in an integration of the Forest
Service into Interior's systems. Some officials noted that one lesson
learned from this consolidation was the importance of ensuring that
systems are in place before implementing a move. According to some
officials, any systems consolidation, even internal ones, brings
problems, but problems would likely increase as a result of moving the
Forest Service into a new department.
USDA functions. The Forest Service is the largest agency in USDA in
terms of employees, and many agency officials and experts noted that
moving it into Interior would affect USDA and its other agencies.
Because of its size, the Forest Service often takes the lead in
purchasing and developing new business systems for USDA, according to
agency officials. For example, USDA has been centralizing and
standardizing many systems at the department level; several officials
noted that the Forest Service has been leading, and contributing many
resources to, the department's implementation of the new financial
management system. As a result, moving the Forest Service into Interior
may disrupt development of this system, as well as other areas, such as
leadership development, where the Forest Service has taken the lead.
A move would also affect USDA's overhead expenses. The Forest Service
pays a large share of USDA's overhead charges, including for what USDA
calls its "green book" and working capital fund. Green book charges
cover various items, such as tribal liaisons and electronic-government
initiatives,[Footnote 35] and are apportioned to its agencies on the
basis of the number of full-time-equivalent employees at each agency.
USDA charged the Forest Service $21.4 million, or about 33 percent of
its total green book charges, in fiscal year 2007. The working capital
fund pays for basic services in USDA, such as infrastructure costs, and
charges to it are based on each agency's use of these services. USDA
charged the Forest Service about $72 million, or about 14 percent of
its total working capital fund charges, in fiscal year 2007.[Footnote
36] According to officials, removing the Forest Service from the
department might reduce economies of scale for USDA, thereby increasing
overhead costs for employees and the agencies.
Finally, according to many officials and experts, moving the Forest
Service out of USDA could affect its relationship with NRCS and other
agencies in the department. For example, the Forest Service and NRCS
coordinate providing technical assistance to private foresters and
other land conservation activities. In the view of some agency
officials, being in the same department facilitates the agencies'
relationship, and it would be difficult for these agencies to continue
their joint work across departmental boundaries. Other officials and
experts did not think that moving the Forest Service into Interior
would have a huge impact on NRCS, some noting that the agencies could
continue to coordinate across departments, although they believed that
special attention would be needed to facilitate the continued
relationship. The Forest Service also works with other agencies in
USDA, including the Agricultural Research Service; the Animal and Plant
Health Inspection Service (APHIS); and the Cooperative State Research,
Education, and Extension Service. For example, the Forest Service's
Forest Health Protection Program has responsibility for pest
suppression and technical transfer of expertise in disease and
infestations that no other federal agency has. The program staff
coordinates its work with APHIS, which is responsible for identifying
and regulating nonnative species, and consults with that agency on the
plants, insects, and diseases that can potentially be imported.
According to Forest Service officials, the invasive species program has
been very successful across USDA and might be harmed if the Forest
Service were moved into Interior.
Human capital. Human capital policies and practices also differ between
the Forest Service and the land management agencies under Interior.
Several officials noted that Interior and the Forest Service have
different position descriptions and related pay-grade structures.
According to these officials, at least the perception exists that the
Forest Service's positions are graded higher than BLM's, but a side-by-
side comparison of positions and grades would be needed to assess and
reconcile any differences. Some officials also noted that unions could
affect a move. The Forest Service is more unionized than Interior
agencies, and officials said that unions would need to be involved in a
transition to a new department.
Legal and Jurisdictional Factors Could Further Complicate a Move:
Legal issues--including differing statutory authorities among the
agencies, as well as legal precedent, tribal issues, congressional
committee jurisdictions, and interest groups--would need to be resolved
if a move were to take place.
Legislation and legal decisions. The Forest Service and Interior
operate under differing statutory authorities and legal precedents.
While moving the Forest Service into Interior as a separate bureau
would not necessarily entail changing the laws governing the agencies,
many officials and experts said that these laws should be examined and
may need to be reconciled if a move took place. According to some of
these experts and officials, changing the laws may require convening a
task force to review all the relevant laws, and such an undertaking
would be time and resource intensive--especially given the considerable
number of these laws. According to the Congressional Research Service,
consolidating federal land law could result in two possible outcomes.
[Footnote 37] First, to provide consistent direction, existing laws
could be largely retained and revised only where they are duplicative
or contradictory. Second, to simplify the piecemeal guidance that has
evolved over the past 100 years, federal multiple-use land law could be
completely revised, which would likely be more difficult.
Even in areas in which the Forest Service and Interior agencies operate
under the same laws, such as NEPA and the Federal Lands Recreation
Enhancement Act,[Footnote 38] they have sometimes received different
legal opinions from USDA's Office of General Counsel and Interior's
Office of the Solicitor. For example, several officials and experts
noted, in some program areas, such as grazing and recreation, the
Forest Service and BLM tried to develop joint regulations in the past
but could not do so because of differing legal advice. According to
officials from Interior's Office of the Solicitor, Interior could adopt
the legal decisions that USDA's Office of General Counsel has already
made, and any differences could be worked out over time.
In addition, legislation authorizing a move would need careful
crafting. For example, such legislation could transfer the proper
authorities from the Secretary of Agriculture to the Secretary of the
Interior, as well as give the Secretary of the Interior broad
reorganization authority to bring the agencies' programs into alignment
and to manage and modify processes, some officials said. One expert
said that the process of aligning regulations would depend on the
authorities that the Secretary of the Interior was provided in the
legislation authorizing the move. Failing to give the Interior
Secretary full delegation over the Forest Service, as well as a scope
of authority broad enough to manage and modify processes, could limit
the Secretary's power to change the agencies. The authorizing
legislation would need to allow Interior flexibility and time to change
and deal with these details, one expert said.
Tribal issues. According to an agency official and an expert we
interviewed, tribal issues should also be considered in a move. In some
cases, treaties with Native American tribes have assured tribal
governments certain "reserved rights"--such as rights for grazing,
hunting, fishing, gathering, trapping, and water--on former tribal land
now part of present-day national forests and grasslands. In other
cases, according to tribal representatives, tribal aboriginal rights
still exist on national forests and grasslands, and sacred, ceremonial,
and repatriation sites important to tribal communities are often found
on national forests and grasslands. According to one official, tribes
would be concerned about how moving the Forest Service might affect
these rights and tribal access to national forests and grasslands and
would need to be consulted about a move. Representatives from the
Intertribal Timber Council[Footnote 39] said that while the effects of
a move were uncertain until the details were known, a move could
enhance tribes' ability to help manage national forests and grasslands
and increase the Forest Service's responsiveness to tribal concerns. In
many cases, Indian reservations are adjacent to national forests and
grasslands. Forest management problems--such as invasive species,
insect disease infestation, and wildland fire--sometimes threaten
tribal lands, according to the Intertribal Timber Council, so the
Tribal Forest Protection Act[Footnote 40] allows the tribes and the
Forest Service to develop projects to address these concerns.[Footnote
41] According to the Intertribal Timber Council, moving the Forest
Service into Interior could make the land management agencies' resource
management authorities and practices more consistent, as well as
consolidate and integrate research activities currently conducted by
the Forest Service and USGS. Further, the move could also improve
consistency in budgets and accounting practices between the federal
land management agencies and the Bureau of Indian Affairs.[Footnote 42]
Finally, the move could facilitate the return of former Indian
reservation lands acquired by the Forest Service.[Footnote 43]
Congressional committee jurisdictions. According to some experts,
aligning congressional committee structure to match a departmental
reorganization would be critical to the success of a move of the Forest
Service into Interior. By making such an alignment, the Secretary of
the Interior could report primarily to one congressional committee. The
Forest Service and Interior come under the jurisdiction of various
committees and subcommittees in the U.S. Senate and House of
Representatives,[Footnote 44] and if the current committee structure
were maintained after a move, the Secretary of the Interior would have
to report to multiple committees, which could create conflicts about
priorities, according to one expert. Historically, however, executive
reorganizations have not always been followed by congressional
committee reorganizations. According to some experts, overlapping
jurisdictions have hindered DHS--which combines 22 agencies overseen by
multiple congressional committees--by, for example, preventing the
department from taking a unified approach to homeland security and
fragmenting congressional oversight.[Footnote 45]
Interest groups. Our interviews revealed no consensus among outside
groups with an interest in the agencies about a move of the Forest
Service into Interior. Some groups, such as recreation or state
forestry organizations, worried about jeopardizing established
relationships with the Forest Service, while others were unsure of the
effects of a move on their organization. Some agency officials and one
group, however, said that stakeholder concerns could be alleviated and
interest-group resistance minimized if the Forest Service were to
remain a stand-alone agency in Interior.
Key Merger and Transformation Practices Can Help Manage Move and
Disruptions:
To help plan for and manage a move and possible disruptions, our
previous work on transforming organizations has identified some key
practices at the center of successful mergers and organizational
transformations (see table 2).[Footnote 46] The experts and agency
officials we interviewed mentioned several of them.
Table 2: Key Practices and Implementation Steps for Mergers and
Organizational Transformations:
Practice: Ensure that top leadership drives transformation;
Implementation step:
* Define and articulate a succinct and compelling reason for change;
* Balance continued delivery of services with merger and transformation
of activities.
Practice: Establish a coherent mission and integrated strategic goals
to guide transformation;
Implementation step:
* Adopt leading practices for results-oriented strategic planning and
reporting.
Practice: Focus on a key set of principles and priorities at the outset
of transformation;
Implementation step:
* Embed core values in every aspect of the organization to reinforce
new culture.
Practice: Set implementation goals and a timeline to build momentum and
show progress from day one;
Implementation step:
* Make implementation goals and timeline public;
* Seek and monitor employee attitudes and take appropriate follow-up
actions;
* Identify cultural features of merging organizations to increase
understanding of former work environments;
* Attract and retain key talent;
* Establish an organizationwide knowledge and skills inventory to
exchange knowledge among merging organizations.
Practice: Dedicate an implementation team to manage transformation
process;
Implementation step:
* Establish networks to support implementation team;
* Select high-performing teams.
Practice: Use performance management system to define responsibility
and ensure accountability for change;
Implementation step:
* Adopt leading practices to implement effective performance management
systems with adequate safeguards.
Practice: Establish a communication strategy to create shared
expectations and report related progress;
Implementation step:
* Communicate early and often to build trust;
* Ensure consistency of message;
* Encourage two-way communication;
* Provide information to meet specific needs of employees.
Practice: Involve employees to obtain their ideas and gain their
ownership for transformation;
Implementation step:
* Use employee teams;
* Involve employees in planning and sharing performance information;
* Incorporate employee feedback into new policies and procedures;
* Delegate authority to appropriate organizational levels.
Practice: Adopt leading practices to build a world-class organization;
Implementation step:
* Select leading processes, practices, and systems that are widely
recognized for contributing to performance improvements in areas such
as acquisition management, financial management, human capital, or
information technology.
Source: GAO.
[End of table]
The first key practice for mergers and organizational transformations
is to ensure that top leadership drives the transformation, and many
agency officials and experts we interviewed reiterated the importance
of leadership in any move of the Forest Service into Interior.
Remarking that strong leadership can ease cultural transitions and
minimize disruption, several officials told us that agency leaders
would need to clearly explain the reason for a move so that employees
understood the rationale and logic behind it and had incentives to
support it. Land managers are passionate about their jobs, some
officials said, and if it were clear that the reason to move the Forest
Service into Interior was to improve federal land management, that goal
would resonate with employees and they would be more likely to support
a move. Our past work has shown that articulating a succinct and
compelling reason for change helps employees, customers, and
stakeholders understand expected outcomes of a merger or transformation
and engenders not only their cooperation but also their ownership of
these outcomes. We also reported that the primary roles of leaders
during a merger or transformation are to help the organization remain
focused on the continued delivery of services, while simultaneously
carrying out the merger or transformation. Some officials we
interviewed said that it is important for leaders to dedicate one
person to be in charge of the transition who is not also responsible
for managing the agencies' daily work; one official noted that this
manager must have a separate budget and the authority to mandate
change.
Many officials and experts said that moving the Forest Service into
Interior would require a clear mission, strategy, and plan, which is
consistent with several of the key practices listed in table 2. Our
past work has shown that the mission and strategic goals of the new
organization must be clear to employees, customers, and stakeholders
because they may not otherwise understand what the organization intends
to accomplish; many officials we interviewed also emphasized the
importance of defining a clear mission and developing a strategic plan
for the move. We also reported in the past that a move must be closely
managed with implementation goals and a timeline. According to one
expert, moves require planning and performing key tasks in order of
priority; accordingly, after a move of the Forest Service into
Interior, leadership in the department would need to list problems to
be solved and then address them one by one. Further, an Interior
official emphasized the importance of a timeline for the move, noting
that the department would need clear goals with corresponding dates for
completion.
We found in the past that creating an effective strategy for continual
communication is also essential to mergers and organizational
transformations, and several experts and agency officials we
interviewed confirmed the importance of communication. According to our
past work, a new department must develop a comprehensive communication
strategy that reaches out and successfully engages employees,
customers, and stakeholders. One agency official who was involved in
the consolidation of the National Biological Service into USGS said
that the agencies have many stakeholders who have concerns about a
move; a great deal of communication and engagement must therefore take
place with the public and stakeholders if the Forest Service is to be
moved into Interior. Another official added that being clear about a
move--for example, reiterating that the Forest Service would be moved
into Interior as a separate agency with its current authorities intact-
-could alleviate some stakeholders' concerns. In addition to
communicating with stakeholders, some officials said that agency
leaders would also need to communicate extensively with agency
employees, which could put some employees at ease and mitigate
disruptions from decreased morale and productivity.
Concluding Observations:
Organizational transformations are inevitably complex, involving many
factors and often creating unintended consequences. In considering a
move of the Forest Service into Interior, policymakers will need to
carefully weigh long-term mission and management gains against
potential short-term disruption and operational costs. On one hand, a
move could improve federal land and program management by bringing the
key federal land management agencies together into one department,
thereby aligning their federal land management missions and creating
the opportunity for greater long-term program effectiveness. On the
other hand, given cultural, organizational, and legal factors, a move
could also lead to disruptions and other transition costs in the short
term, as well as diminish the Forest Service's focus on state and
private lands and affect relationships developed through USDA with
state and private landowners. Moreover, no move--including moving the
Forest Service into Interior--should be undertaken without sufficient
attention to defining the long-range goals and enduring capacity that
the move is to achieve. Once these are identified, the means that can
best achieve them can be considered. As many have suggested, a number
of options exist for organizing federal land management agencies,
including the idea of increasing collaboration among the agencies or
reviewing the nation's land and resource management laws. Significant
large-scale challenges to federal land management, such as climate
change, energy production, dwindling water supplies, wildland fire, and
constrained budgets, suggest the need to approach these problems
innovatively, perhaps even revisiting the legal framework of federal
land management agencies.
Certain well-demonstrated practices have been used in large private-and
public-sector organizations to assist mergers and organizational
transformations and avert such consequences. If a move were undertaken,
adequate time and attention would need to be devoted to planning for
and implementing these key practices to manage potential disruption and
other transition costs. In particular, any legislation authorizing a
move would need to provide the departments ample time to plan the move-
-in light of cultural, organizational, and legal factors--and
incorporate key merger and transformation practices.
Agency Comments and Our Evaluation:
We provided USDA and Interior with a draft of this report for review
and comment. The Forest Service provided oral comments on behalf of
USDA, saying the report provided an accurate, balanced, and
comprehensive assessment of the issues involved in a move. The agency
observed, however, that the report failed to adequately consider the
possibility of moving BLM into USDA. The agency said this move would be
substantially less costly than moving the Forest Service into Interior,
which it estimated could cost between $300 million and $500 million. We
did not include an in-depth discussion of moving BLM into USDA because
the scope of our review was restricted to examining a possible move of
the Forest Service into Interior. Furthermore, while we agree that
moving the Forest Service into Interior would be costly, we have no
basis to substantiate the Forest Service's estimate of this cost.
Interior provided written comments in which it generally agreed with
the report's findings (see appendix VI). The department observed,
however, that the diminishment of the Forest Service's role working
with farmers, ranchers, and state foresters would not necessarily be a
predictable outcome of a move. We did not mean to imply that
diminishment of the Forest Service's state and private forestry role is
a certain outcome. The report instead reflects the concerns of many
federal officials, several experts, and some state foresters that a
move could compromise the agency's work with state and private
landowners, and with other USDA agencies, in carrying out USDA's
mission to protect and enhance natural resources on private as well as
public lands. Such disruption could arise, according to some of these
officials, experts, and state foresters, because Interior does not have
USDA's long-standing relationships with nonfederal partners or mission
focus on nonfederal lands. We revised and added language in the report
to clarify these concerns. In further commenting about the effects of a
move, Interior also remarked that a move could possibly strengthen its
role in working with state and private landowners to conserve
endangered species, wetlands, and other resources. We agree that, over
time, a move could strengthen Interior's ability to work with state and
private landowners but believe that our report recognizes this
potential and provides sufficient examples illustrating Interior's
existing programs to work with state and private landowners.
USDA and Interior both provided a few technical comments, which we
incorporated as appropriate.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to interested congressional committees, the Secretaries of Agriculture
and the Interior, the Chief of the Forest Service, and other interested
parties. In addition, the report will be available at no charge on the
GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staff members have any questions about this report,
please contact me at (202) 512-3841 or nazzaror@gao.gov. Contact points
for our Offices of Public Affairs and Congressional Relations may be
found on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix VII.
Signed by:
Robin M. Nazzaro:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Scope and Methodology:
To understand the potential effects of, and factors involved in, a move
of the Department of Agriculture's (USDA) Forest Service into the
Department of the Interior (Interior) and practices that could
facilitate a move, we analyzed historical proposals on reorganizing the
land management agencies, interviewed agency officials and experts,
visited Forest Service and Bureau of Land Management (BLM) offices that
are colocated and comanaged, and interviewed representatives from
groups that have an interest in the agencies.
To understand the context and potential effects of a move and the
factors involved, we first conducted a content analysis of five
historical proposals on reorganizing the nation's federal land
management agencies: (1) Public Land Law Review Commission report of
1970; (2) report of the Advisory Council on Executive Organization
under the Nixon administration; (3) Reorganization Project from the
Office of Management and Budget under the Carter administration; (4)
President's Private Sector Survey on Cost Control in the Federal
Government under the Reagan administration; and (5) BLM and Forest
Service Interchange Proposal, also under the Reagan administration. In
analyzing these proposals, two GAO analysts independently grouped
statements describing potential effects into a number of categories,
such as efficiency, public service, and better land management, and
grouped factors involved into categories such as cultural factors,
personnel, and organizational structure. Once the statements were
grouped,the analysts discussed every statement for which they had
assigned different categories and reached agreement on which category
to assign each statement to. This analysis allowed us to understand the
broader context of proposed reorganizations of natural resource and
land management agencies, as well as a range of potential effects and
factors that might result from reorganization.
Besides this content analysis of historical reorganization proposals,
we used semistructured interviews of former and present USDA, Interior,
Forest Service, BLM, and other agency officials and of other experts to
gather data on their perspectives about a move, its potential effects
on federal land management overall and resource programs in particular,
and any factors that could be involved in a move. We then summarized
the responses to represent the officials' views. To understand the
effects and factors from the perspective of resource managers, at USDA
we interviewed the Under Secretary for Natural Resources and
Environment and the Forest Service Chief and Deputy Chiefs for the
National Forest System, Research, and State and Private Forestry. At
Interior we interviewed the Assistant Secretaries for Lands and
Minerals; Water and Science; and Fish, Wildlife, and Parks. We also
interviewed key managers for Forest Service and BLM programs such as
timber, oil and gas, grazing, recreation, and wildland fire management
at headquarters, state and regional, and field offices. To understand
the effects and factors related to business operations in the
departments and agencies, we interviewed USDA's Deputy Chief Financial
Officer and officials from the USDA Office of Budget and Program
Analysis; the Forest Service's Deputy Chief for Business Operations,
Chief Financial Officer, and Chief Information Officer; and Interior's
Deputy Assistant Secretary for Business Management and Wildland Fire,
Deputy Chief Financial Officer, Chief Information Officer, and Budget
Officer. We interviewed officials from USDA's Office of General Counsel
and Interior's Office of the Solicitor to understand the legal
implications of a move and legal factors that should be considered, and
we interviewed officials from the USDA and Interior Offices of
Inspector General to understand how the potential move would affect
these offices. We interviewed examiners from the Office of Management
and Budget to understand the effects of a potential move on their role
in overseeing the Forest Service and Interior.
To identify and select natural resource and public administration
experts to interview, we began with lists of experts in each of three
categories--(1) experts in organizational change and public
administration, (2) experts in natural resources or federal land
management, and (3) former senior-level agency officials--who were
recommended to us by knowledgeable agency officials, former officials,
and others or identified in literature on government organizational
change and management. Using a "snowball sampling" technique, we spoke
with everyone on these initial lists to solicit the names of more
experts to speak with and continued this iterative process until we no
longer found any new names to include. From these comprehensive lists
in all three categories, we chose a nonprobability sample, representing
varied perspectives, of 22 experts to interview. Our 22 experts
included former land management officials from different presidential
administrations and experts in various organizational theories and
federal land management. Seven of these experts were former agency
officials at USDA and Interior, including former Secretaries and Forest
Service Chiefs; seven were experts in public administration who have
studied organizational change; and the remaining experts were academics
who have studied natural resource law and land management agencies.
Appendix II lists the people we interviewed.
To discuss areas in which the agencies are integrated--including land
management planning, range management, recreation, and budget--we
visited two sites where the Forest Service and BLM are colocated and
comanaged under Service First authority: (1) San Juan Public Lands
Center in Durango, Colorado, and (2) Forest Service Region 6 Office and
the Oregon and Washington BLM State Office in Portland, Oregon. We also
interviewed officials involved in the oil and gas federal permit
streamlining pilot project in Glenwood Springs, Colorado, to understand
how the Forest Service and BLM have integrated various aspects of their
oil and gas programs.
To discuss a possible move and its potential effects on particular
interest groups, we again used a semistructured interview of 18
nonfederal parties. The parties we interviewed included, among others,
environmental groups such as The Wilderness Society; forestry
associations such as the National Association of State Foresters; the
American Recreation Coalition; a cattlemen's association; groups
representing Forest Service and BLM retirees; the Intertribal Timber
Council; and groups representing state and local governments, such as
the National Association of Counties.
To identify practices that the departments could use to facilitate a
move, we reviewed our own previous work on key practices found to bring
about successful mergers and organizational transformations, in
particular, our 2003 report on key practices and implementation steps
for such transformations.[Footnote 47] Our interviews with experts in
public administration, other experts, and agency officials supplemented
the information from our previous work.
We conducted this work as a nonaudit service from March 2008 through
February 2009. This means the work was performed in accordance with
GAO's quality assurance framework, which requires that we plan and
perform the engagement to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings, conclusions, and
recommendations based on our objectives.
[End of section]
Appendix II: List of Experts GAO Interviewed:
Former Senior-Level Agency Officials:
Dale N. Bosworth:
Chief:
Forest Service, 2001-2007:
Nancy S. Bryson, J.D.
General Counsel:
USDA, 2002-2005:
Michael P. Dombeck, Ph.D.
Chief Forest Service, 1997-2001:
Acting Director:
BLM, 1994-1997:
John Leshy, J.D.
Solicitor:
Department of the Interior, 1993-2001:
James R. Lyons:
Under Secretary for Natural Resources and Environment:
USDA, 1993-2001:
Gale A. Norton, J.D.
Secretary:
Department of the Interior, 2001-2006:
Ann M. Veneman, J.D.
Secretary:
USDA, 2001-2005:
Natural Resource Experts:
Sally K. Fairfax, Ph.D.
Henry J. Vaux Distinguished Professor Emerita:
Department of Environmental Science, Policy and Management:
University of California, Berkeley:
Ross W. Gorte, Ph.D.
Specialist in Natural Resources Policy:
Congressional Research Service, Library of Congress:
Perry R. Hagenstein, Ph.D.
Assistant Chief:
Public Land Law Review Commission:
Daniel Kemmis, J.D.
Senior Fellow:
Center for the Rocky Mountain West:
Randal O'Toole:
Senior Fellow:
Cato Institute:
V. Alaric Sample, Ph.D.
President:
Pinchot Institute for Conservation:
Carol Hardy Vincent:
Specialist in Natural Resources Policy:
Congressional Research Service, Library of Congress:
Charles Wilkinson, J.D.
Professor:
School of Law:
University of Colorado, Boulder:
Public Administration Experts:
Robert Agranoff, Ph.D.
Professor Emeritus:
School of Public and Environmental Affairs:
Indiana University at Bloomington:
Instituto Universitario Ortega y Gasset, Madrid, Spain:
Alan L. Dean:
Consultant:
National Academy of Public Administration:
William Dinsmore:
Study Director:
Reorganization Study of Natural Resource Functions:
Office of Management and Budget:
Donald F. Kettl, Ph.D.
Professor:
Political Science Department:
University of Pennsylvania:
Beryl A. Radin, Ph.D.
Scholar in Residence:
School of Public Affairs:
American University:
Harold C. Relyea, Ph.D.
Specialist in American National Government:
Congressional Research Service, Library of Congress:
Charles R. Wise, Ph.D.
Director and Professor:
John Glenn School of Public Affairs:
Ohio State University:
[End of section]
Appendix III: Five Selected Historical Proposals to Reorganize Federal
Natural Resource and Land Management Agencies:
A variety of proposals have been made over the past 80 years to
reorganize federal land management and natural resource agencies.
[Footnote 48] These proposals vary widely, including to move the USDA
Forest Service into Interior, to merge the Forest Service and
Interior's BLM, to move BLM and other agencies to USDA, and to exchange
lands between the agencies. This appendix describes the five recent
proposals, the effects arising from the proposed reorganizations, and
the factors that could influence their implementation.[Footnote 49]
Three of the five were developed for the Nixon, Carter, and Reagan
administrations by special commissions or offices designated to review
the organization of land and resource management agencies. One of the
remaining two was made by a special commission established by Congress
to study public land laws, and the other was developed by staff at the
Forest Service and BLM. The five proposals generally approach
reorganization in two ways, which are not mutually exclusive:
reorganizing the agencies themselves or reorganizing the agencies'
lands.
Public Land Law Review Commission:
In 1964, Congress created the Public Land Law Review Commission to
explore how to simplify public land laws and make administering them
more effective. The commission submitted its report to the President
and Congress in June 1970.[Footnote 50] The report made more than 130
recommendations about a wide range of land laws and issues, including a
recommendation to transfer the Forest Service into Interior and to name
the resulting agency the Department of Natural Resources. This
recommendation further stated that the Secretary of the renamed
department should consider further consolidation of agencies and
programs.
In making this recommendation, the report noted that the Forest Service
and BLM have similar land uses and management objectives and that a
Department of Natural Resources could contribute to better management
of federal lands, as well as to greater alignment of agencies,
potential cost savings and other efficiencies, and improvements in
public service. The report noted that by not being part of Interior,
the Forest Service is under different policy direction than the other
federal land agencies, leading to expensive duplication of staff,
offices, programs, and facilities; confusion on the part of the public
using the lands; and conflicts between the Forest Service and
Interior's agencies over how national forestlands should be used. The
commission noted that reorganizing the agencies could be challenging,
given cultural, organizational, and legal factors, including program
differences between the two agencies, caused in large part because of
their historical development. For example, the commission's report said
that the Forest Service and BLM differ significantly in their
management of programs affecting the same resources (e.g., timber,
forage, and recreation), requiring continuing efforts to achieve
uniformity and promote the coordination of such programs. In addition,
the commission identified political challenges for reorganization
because many of the recommended changes would have required
congressional action.
In the end, no bills were introduced containing the proposal from the
commission. One of the other recommendations regarding federal lands,
however, was influential in changing federal land law. The commission
made a recommendation to end the nation's policy of disposing of public
lands and to retain them in federal ownership for multiple-use
purposes. In 1976, the Federal Land Policy and Management Act was
enacted, which, among other things, established the federal policy to
retain the remaining federal land in federal ownership.
Advisory Council on Executive Organization (Ash Council):
In 1968, President Nixon created the Advisory Council on Executive
Organization to consider revamping the structure of the executive
branch, which had evolved over time. The council considered two
options, one to establish a Department of Environment and Natural
Resources and another to create a Department of Natural Resources. In
March 1971, the President presented the Department of Natural Resources
proposal to Congress and the public.[Footnote 51] This proposal would
have created a Cabinet-level department combining the Forest Service,
the Soil Conservation Service (now the Natural Resources Conservation
Service), and certain other USDA functions; all Interior agencies;
certain functions of the Army Corps of Engineers; the National Oceanic
and Atmospheric Administration from the Department of Commerce; and
other agencies. The Department of Natural Resources proposal included
fewer agencies than that proposed for a Department of Environment and
Natural Resources, which also included the Environmental Protection
Agency, to make it more politically feasible to congressional
committees.
The council believed that the proposed creation of a Department of
Natural Resources was supported by the similarities in tasks carried
out by the Forest Service and Interior agencies on their respective
lands. The council's report noted the potential for better land
management and program effectiveness; increased cost efficiency; better
alignment of congressional, executive, or departmental entities; and
improved public service. For example, according to the report, the
related land management agencies and functions could be grouped into
one branch of the Department of Natural Resources to enable better
planning and management of public lands and allow for administrative
efficiencies and savings over the long term. The report also identified
organizational factors as a primary challenge in the reorganization.
For example, a new Department of Natural Resources would have required
a new appropriations structure; merging and consolidating agencies'
accounts; and more uniformity at the regional, and possibly field,
level.
While several bills were introduced in Congress to establish a
Department of Natural Resources or Department of Environment and
Natural Resources, and hearings were held on the proposals, no other
action was taken. During the hearings, concerns arose about disrupting
agency operations and the established relationships between interest
groups and agencies. Discussions raised the idea that a Department of
Natural Resources could facilitate implementation of national policies
but limit national policy debates. Finally, a new Department of Natural
Resources could have affected congressional oversight because more
committees would have had jurisdiction over aspects of the department's
functions. In June 1973, President Nixon presented a revised
reorganization proposal for a Department of Energy and Natural
Resources. Legislation was introduced, but no bills for such a
department were signed into law. Helping the proposals' demise was
opposition from stakeholders, some members of Congress, and midlevel
managers of the organizations involved.[Footnote 52]
Reorganization Project, Office of Management and Budget:
In 1977, President Carter established the Reorganization Project in the
Office of Management and Budget to conduct a comprehensive study of
government organization, including natural resource organizations.
[Footnote 53] One report in the study centered on restructuring federal
management of natural resources and was to recommend any changes deemed
necessary to improve natural resource management and environmental
protection. In 1979, President Carter announced a reorganization plan
to create a Department of Natural Resources from the existing Interior,
Forest Service, and the National Oceanic and Atmospheric
Administration.
In discussing the reasons for reorganization, the report noted that the
Forest Service and BLM have similar multiple-use missions. The report
described the potential for better land management and program
effectiveness, as well as improved public service, given its finding
that the agencies had multiple interagency task forces and cooperative
agreements to coordinate their work, which would be simplified with
both agencies merged into one department. The report estimated savings
to taxpayers of $160 million over several years as reorganization took
place. The report also cited multiple factors challenging
reorganization, including cultural issues, such as a potential loss of
Forest Service expertise and professionalism through a merger with BLM
and stretching staff to cover more acreage.
The administration and members of Congress disagreed about the need for
Congress to introduce and pass legislation enacting this proposal; some
members of Congress argued that the proposal exceeded presidential
authority. Concerns about the proposal itself were raised by
congressional members, including members of the House and Senate
Agriculture Committees. Because of these concerns and other
administration priorities, such as the Strategic Arms Limitation Treaty
talks with the then Soviet Union, the President withdrew the proposal.
President's Private Sector Survey on Cost Control in the Federal
Government (Grace Commission):
In 1982, President Reagan signed an executive order directing the
President's Private Sector Survey on Cost Control to, among other
things, identify opportunities to increase efficiency and reduce costs
within federal departments. An August 1983 report completed as part of
the survey recommended that the Forest Service and BLM each transfer
jurisdiction of some of its lands to that of the other agency and
combine administrative functions.[Footnote 54] Citing inconsistent
policies and intermingled land ownership patterns between the Forest
Service and BLM, the report recommended that the President direct the
Secretaries of the Interior and Agriculture, through the Forest Service
and BLM, to plan and schedule a program for increased land transfers
between jurisdictions and elimination of administrative overlap between
the two agencies. The report also recommended, for the western states,
combining the agencies' shared functions, such as permit processing,
public affairs, and training to make the agencies more effective and
facilitate their interactions with the public.
The report said that better public service, structural improvements,
and efficiencies could be gained, estimating potential savings of $32
million to $40 million over 3 years. It also noted organizational
factors--including the agencies' structures, personnel, physical
boundaries, and administrative jurisdictions--that could challenge
implementation of the proposal. In contrast, the report's authors
believed that their proposal was relatively uncontroversial because it
did not involve reorganizing agencies. The report helped support a
subsequent Interior and USDA effort, called the "Interchange Proposal,"
to consider transfers of land from the jurisdiction of one agency to
that of the other. In the end, local communities, counties, and states,
as well as members of Congress, opposed the transfer of lands between
agencies.
BLM and Forest Service Interchange Proposal:
In 1985, the Reagan administration announced a proposal to transfer
almost 20 million acres of BLM lands to the Forest Service and almost
14 million acres of Forest Service lands to BLM.[Footnote 55] The goals
of this jurisdictional transfer were to enhance public service, improve
efficiency, and reduce costs. This proposed interchange would have
required legislation because each agency's lands were subject to
specific authorities that could not be transferred or modified
administratively.
Like earlier proposals, the interchange proposal cited overlapping and
intermixed Forest Service and BLM land ownership patterns, saying they
presented management inefficiencies. For example, the report noted 71
communities with offices for both agencies, which result in duplication
of effort and staffing requirements, waste, inefficiency, and public
confusion. The proposal mentioned improved land management, public
service, and efficiency as the effects of a land exchange between the
two agencies. The proposal also cited organizational and legal factors,
as well as political resistance, as challenges. For example,
legislation would have been needed to implement the proposal because no
existing law allowed transfers of land or minerals between agencies.
In 1986, the administration proposed legislation to adjust the land
jurisdictions and in the same year completed a legislative
environmental impact statement to support the proposal, but legislation
was never put forth. Although the agencies held public hearings in 1985
with stakeholders in areas affected by the interchange, in the end,
members of Congress, local communities, counties, and states, opposed
the proposal.
[End of section]
Appendix IV: Service First:
Service First is an example of federal land management agencies working
together to improve federal land management. Under the Service First
program, initiated in 1996, the Forest Service and BLM, Fish and
Wildlife Service, and National Park Service in Interior can use each
other's authorities, duties, and responsibilities.[Footnote 56] Service
First efforts have resulted in improvements in land management and
public service; still, differences in administration, information
technology, budget, and other business operations have been barriers to
operating more efficiently at Service First locations. This appendix
describes ways in which the Forest Service and BLM have implemented
Service First at two locations--Durango, Colorado, and Portland,
Oregon.
Background:
Regardless of land ownership, the Forest Service's and BLM's missions
are to provide responsible land management that protects and enhances
resources and provides efficient and effective service to the public.
Yet while federal lands managed by the Forest Service and BLM often
share boundaries and in many cases the same users, and both agencies
manage their lands for multiple uses--including timber, grazing,
minerals, and recreation--each agency carries out its responsibilities
under different rules, follows different administrative processes, and
takes a different approach to customer service.
In March 1996, the Forest Service and BLM announced what they call the
Service First initiative--an effort to reduce some of the
dissimilarities that can confuse the public and result in ineffective
and inefficient use of resources.[Footnote 57] The initiative was
piloted in two locations--one in Colorado and another in Oregon--to
provide the public with "one-stop shopping" for the services offered by
the agencies. The initiative's three primary objectives were to (1)
provide better customer service, (2) improve natural resource
stewardship, and (3) conduct business more effectively and efficiently.
By 2000, the initiative included 272 projects in 59 Forest Service and
BLM locations in 11 states.
The extent to which the agencies coordinate use of the Service First
authority varies from location to location and comprises offices and
programs that are fully integrated and managed by a single manager, as
well as offices that simply share space, or are colocated, within the
same building.[Footnote 58] At the Service First location in Durango,
Colorado, also known as the San Juan Public Lands Center, the Forest
Service and BLM are colocated and closely integrated, with most work
done by interagency teams. The Forest Service and BLM are also
colocated at the Portland Service First location, but management is not
integrated as in Durango; where a business case can be made, the
agencies have integrated numerous programs. The Service First
initiatives in these two locations arose for different reasons, in part
because of the unique needs of the communities they serve. For example,
in Durango, ranchers who held allotments on both Forest Service and BLM
land supported federal land management that would provide more uniform
treatment by the agencies, and others in the community supported a
single planning and public involvement process. In Portland, an impetus
for Service First came from users who supported the idea of one-stop
shopping when obtaining permits, such as for firewood, and from field
offices seeking to improve customer service and cooperation and
collaboration across Oregon and Washington, according to officials.
Another difference is that the Portland office oversees many national
forests and BLM field offices and provides policy to staff at these
units to carry out Service First activities as appropriate.
In 2000, we reported that several barriers, such as different land use
planning legislation and regulations, impeded full integration of the
agencies' resource programs at Service First sites.[Footnote 59] Other
barriers included incompatible communication systems, such as e-mail,
and differing human capital practices. More fundamentally, however,
some arenas may not lend themselves to collaboration. For example,
integrating offices and programs may not make sense where the agencies'
roles and responsibilities differ dramatically or where managed lands
are not contiguous.
Since our last report, recognizing that Service First can be
implemented in many ways, the Forest Service and BLM produced an
implementation guide to assist interested locations. This joint guide
provides templates for a memorandum of understanding to help the
agencies work together; options for sharing front-desk duties,
including map and other product sales; and interagency billing
procedures. It also provides procedures for hiring, employee relations,
awards, and performance management, among others.
Durango, Colorado:
The Service First initiative in Durango, Colorado, is managed through
the San Juan Public Lands Center, which is responsible for overseeing
both the San Juan National Forest and BLM's San Juan Resource Area and
Canyons of the Ancients National Monument. The center has a single
manager and is the first in the country to develop a joint land
management plan for Forest Service and BLM lands. The San Juan Public
Lands Center is integrated in additional areas, including as follows:
* The center has several cross-trained specialists to provide
permitting and general assistance to members of the public who want to
use public lands for multiple purposes, such as oil and gas
development, recreation, or grazing. For example, firewood permits for
both Forest Service and BLM land are issued jointly, and recreation
specialists issue one permit to recreationists according to which
agency's land will be used most. In addition, a single range
conservationist works with ranchers holding permits on both Forest
Service and BLM lands to provide greater continuity and more-effective
service.
* Forest Service and BLM staff at the center developed one joint land
management plan and National Environmental Policy Act (NEPA) analysis;
staff struggle, however, to align regulations, policies, and
guidelines. Agency officials stated that each agency still issues
separate decisions because each has different regulations and laws.
* The agencies hired a geographic information system (GIS) specialist
to consolidate Forest Service and BLM maps into one set of compatible
maps, which were used to develop their joint land management plan. To
gather common data, the GIS staff collected BLM data according to
Forest Service standards. When conducting joint projects, center staff
often use whichever agency's rules work best for the project.
The Forest Service and BLM at the San Juan Public Lands Center are also
integrated in some of their business operations (see table 3).
Table 3: Integration of Business Operations for the San Juan Public
Lands Center:
Business operation: Human capital;
Activities: The center has one administrative officer for both agencies
and cross-delegation of authority for all line officers. Resource
management staff are commingled, and their operations are integrated.
Agencies retain separate human capital systems.
Business operation: Information technology and other business systems;
Activities: The center once used connected computers for both the
Forest Service and BLM. As the result of litigation affecting
Interior's computer security procedures, however, each staff member
with both Forest Service and BLM duties must use two separate
computers--one running Forest Service systems and another running BLM
systems.
Business operation: Shared facilities and equipment;
Activities: The Forest Service and BLM are colocated in one building
and have a fully integrated fleet management system. They also use a
helicopter that is shared by the Forest Service, BLM, Fish and Wildlife
Service, National Park Service, and two Indian reservations.
Business operation: Budget;
Activities: Agencies have different budget nomenclature and use
different work-planning systems to allocate their budgets for projects.
Staff design joint projects and then develop separate Forest Service
and BLM work plans to fund part of the work. Agencies use interagency
agreements to fund BLM staff to work on Forest Service land and
projects and vice versa.
Business operation: Performance measures;
Activities: Although the center tries to focus on where work is most
needed, regardless of land ownership, agencies have different work
performance targets and accomplishment-tracking systems.
Source: GAO analysis of Forest Service and BLM information.
[End of table]
Portland, Oregon:
The Service First initiative in Portland, Oregon, combines management
of Forest Service and BLM lands at a higher organizational level than
in Durango. This site colocates part of the management team from Forest
Service region 6 and the BLM combined state office of Oregon and
Washington. Together, the office manages 17 national forests and 10 BLM
districts. While this location is not as integrated as the Durango
location, it has hired several Service First employees who oversee
management of similar programs, such as fire programs, GIS efforts, and
interpretive services, across both agencies. Although several hurdles
related to information technology systems continue to challenge greater
integration, this location developed one map, for the general public to
use for recreation, that combines Forest Service and BLM datasets. The
agencies are integrated at the Portland location in additional areas,
including as follows:
* The Portland office has a joint fire program with cross-delegation of
authority; the agencies still retain their distinct authorities,
budgets, funding, and other processes.
* The Portland location has one Service First position for an
Interpretive Services and Tourism Specialist for both the Forest
Service and BLM. This office has also integrated sales of interagency
passes and consolidated maps.
* The agencies developed joint standards for GIS mapping to make each
agency's GIS data available and usable to the other agency's GIS
system.
* The agencies developed Service First best practices, including a
framework for agency management and local unions to cooperate in
communicating potential local policy changes, and also completed a side-
by-side comparison of safety manuals to determine a "best-of-both-
worlds" mode of operation.
* The Forest Service and BLM have developed a coordinated radio system
to serve both agencies in central Oregon. The system is intended to
provide communications in remote field locations not served by other
radio systems. It is used in both agencies' fire and resource
management programs and to meet safety needs for employees in the
field.
Table 4 illustrates examples of other coordination efforts at the
Portland office and at several of the forests in region 6 and BLM
districts in Oregon and Washington.
Table 4: Integration of Business Operations in Portland, Oregon,
Service First Site:
Business operation: Human capital;
Activities: Agencies retain separate human capital systems and
practices.
Business operation: Shared facilities and equipment;
Activities: Portland office is colocated, as are several local offices.
Service First Colocation and BLM Oregon/Washington Space Policy was
completed in June 2006 for colocated facilities.
Business operation: Information technology and other business systems;
Activities: Although several offices are colocated, Forest Service and
BLM staff must use two separate computers on their desks to provide
interoperability and access to the other agency's network and
infrastructure.
Business operation: Performance measures;
Activities: Agencies have different performance measures, but in some
cases the Portland office provides balanced budgets and targets to
Service First field offices to ensure that work on both agencies' land
is accomplished.
Source: GAO analysis of Forest Service and BLM information.
[End of table]
Effects of Service First:
While to some degree Service First efforts generally increase program
effectiveness and perhaps efficiency, the extent to which the efforts
result in cost savings is not clear. In a 2004 Forest Service and BLM
review of nine Service First sites,[Footnote 60] evaluators reported
that Service First is most effective when employees are colocated,
commingled, and integrated and equipment and resources are shared. The
Forest Service and BLM estimated potential cost savings of $5.4 million
from fiscal year 1996 through the first half of fiscal year 2000
through Service First, but neither our past work nor an agency
evaluation found enough documentation to verify these savings.
Nevertheless, the 2004 review concluded that maximum operational
efficiency is achieved where a single manager has the authority to
manage the land, office, and employees. Additionally, offices that are
colocated without work project collaboration or other sharing operate
least efficiently. Areas where reviewers anticipated potential savings
included integrated fleets, shared telecommunications equipment, and
joint radio systems, among others. The evaluation team also found that
the most efficient organization arises when agencies jointly conduct a
single study, or plan across agency boundaries, and produce a single
report used by each agency.
In a 2006 roundtable discussion of the benefits of Service First,
agency managers highlighted improvements in public service and land
management. For example, one manager said that working together
improved the agencies' ability to manage their lands at the watershed
level, and another highlighted the ability of an individual or entity
to get permits for two agencies at one location. Another manager
brought up the challenges agencies face working together, in
particular, the incompatibility of computer systems and numerous
agreements needed to track funding agreements between the agencies. A
recent evaluation of one Service First location concluded that the
implementation of Service First has been positive for customer service,
one-stop shopping, and resource management. The evaluation also
concluded, however, that barriers to meeting Service First objectives
still exist, including differences in administration, information
technology, and budget. Employees interviewed as part of the evaluation
said they believed that the increased workload associated with the
initiative was inadequately recognized. Specifically, employees
explained that following two sets of rules takes more time and funding,
and Service First efforts require more communication on everyone's
part.
[End of section]
Appendix V: Oil and Gas Federal Permit Streamlining Pilot Project:
Mandated by the Energy Policy Act of 2005,[Footnote 61] the oil and gas
federal permit streamlining pilot project is an example of how two
federal land management agencies, the Forest Service within USDA and
BLM within Interior, have integrated various aspects of their
respective oil and gas programs. This appendix describes how the two
agencies are working together in the Glenwood Springs Energy Office to
improve efficiency and effectiveness of oil and gas management while
maintaining the agencies' separate legal authorities, regulations, and
other systems.
Background:
The federal government owns the rights to minerals, including oil and
gas, found on or beneath the surface of federal lands and under certain
private lands for which the federal government retained mineral rights-
-amounting to roughly 700 million acres. Under federal law, BLM manages
the federal oil and gas beneath these federal and private lands.
Extracting federally owned oil and gas generally involves (1)
identifying lands that will be available for leasing; (2) leasing the
lands, subject to stipulations or restrictions needed to mitigate
potential damage from drilling activity; (3) issuing permits for
drilling on leased parcels, including any further site-specific
conditions that must be met; (4) inspecting sites for compliance with
permitted stipulations and other conditions; and (5) monitoring idle
wells and ensuring proper plugging and reclamation of well sites when
drilling is complete.
BLM identifies land it will offer for leasing through its land
management planning process. Often, another federal agency, such as the
Forest Service, has jurisdiction over the lands lying atop federal oil
and gas reserves. When the land involved is the Forest Service's, under
federal law, the Forest Service follows its land use planning process
to determine whether its land is available for leasing. If so, BLM
issues the lease, while the Forest Service retains the authority to
regulate access from the surface to the underlying minerals. Under
NEPA, the Forest Service and BLM must evaluate the likely environmental
effects of proposed oil and gas development projects on their own lands
before drilling can be permitted. In general, both agencies issue a
relatively brief environmental assessment, or, if an action would be
likely to affect the environment significantly, a more detailed
environmental impact statement.
Oil and Gas Federal Permit Streamlining Pilot Project:
The Energy Policy Act established a pilot project to improve the
efficiency of processing oil and gas permits. The act requires Interior
to enter into a memorandum of understanding with the Secretary of
Agriculture, the Environmental Protection Agency, and the Corps of
Engineers and authorizes Interior to request that the Governors of
Wyoming, Montana, Colorado, Utah, and New Mexico be signatories. To
coordinate their efforts, the participating departments and agencies
created common goals for participating pilot project offices, including
to (1) react to increasing demand for natural gas drilling, (2) provide
improved customer service, (3) meet goals for environmental monitoring
and compliance, and (4) ensure environmentally sound development.
[Footnote 62] Finally, the act authorizes Interior to transfer funds to
relevant federal and state agencies for the coordination and processing
of oil and gas use authorizations under the oil and gas permit pilot
project.
The 2005 act designated seven BLM field offices to be included in the
pilot, which, combined, represent about 75 percent of the national oil
and gas permit approvals in recent years.[Footnote 63] One of these
pilot offices, the Glenwood Springs Energy Office, brings 5 Forest
Service and 21 BLM staff together to manage oil and gas operations in
western Colorado, including 567,000 acres of BLM-administered land, 1.5
million acres of minerals underlying the Forest Service lands, and
another 181,000 acres of minerals under privately owned lands. While
the Forest Service and BLM develop separate land use plans, as called
for by the National Forest Management Act and the Federal Land Policy
and Management Act, the pilot office's interagency team has integrated
several steps of oil and gas development. After leases are issued and
before drilling can begin, the Glenwood Springs interagency team is
involved in several integrated activities, including approving rights-
of-way (access corridors for roads and pipelines) and applications for
permits to drill. Both agencies have adopted BLM's process for
approving rights-of-way across federal land and BLM's standard guidance
on oil and gas permitting. The agencies have created joint guidelines
for standard stipulations--such as restrictions during certain months
to protect wildlife--in all lease agreements; they have also
standardized processes for oil and gas leases and operators.
The Glenwood Springs Energy Office has integrated some, but not all, of
the steps required by NEPA. The interagency team or an environmental
contractor conducts an environmental analysis and prepares an
environmental assessment or environmental impact statement for Forest
Service and BLM approval; each agency, however, issues an independent
decision on the lease. Also, the Glenwood Springs interagency team has
used categorical exclusions from NEPA analysis, established under
section 390 of the Energy Policy Act, for certain activities. These
categorical exclusions allow the agencies to move ahead with projects
without conducting environmental analyses if the projects meet certain
conditions.[Footnote 64]
Once drilling for oil and gas production begins on a leased parcel,
Glenwood Springs pilot project staff inspect the site to ensure that
operations comply with the lease's environmental provisions and any
conditions in the drilling permit. For example, a BLM petroleum
engineering technician may help inspect sites on Forest Service lands,
while a Forest Service biologist may inspect wells on BLM lands. Joint
Forest Service-BLM activities also include reclamation of drilling
sites. For example, a Forest Service ecologist with the Glenwood
Springs pilot project developed comprehensive plans for reclamation and
monitoring and control of weeds on both agencies' lands.
In addition, the Glenwood Springs pilot project has also integrated
some of the agencies' business operations, as shown in table 5.
Table 5: Joint Forest Service-BLM Activities to Integrate Business
Operations:
Business operation: Agreements;
Activities: Local Forest Service and BLM managers signed a memorandum
of understanding to establish guidelines for both agencies. Under this
agreement, the managers meet regularly to review and change staffing
levels and requests, supervision, budget, and overall management of
Glenwood Springs Energy Office.
Business operation: Human capital;
Activities: Human capital, which includes staffing and training, is
integrated, but the agencies maintain their own personnel management
systems. BLM coordinated with its National Training Center to provide
necessary training specifically for pilot office staff. Pilot offices
also conducted internal workshops and provided on-the-job training for
new hires.
Business operation: Information technology and other business systems;
Activities: The Glenwood Springs pilot project staff rely on BLM
systems to track pilot performance measures. In addition, the Glenwood
Springs Energy Office created several tracking systems to augment BLM
systems, including a spreadsheet to track permits requiring interagency
coordination, the permit type, the NEPA document type, and the elapsed
time to complete the review. The two agencies have also developed an
integrated GIS to facilitate environmental reviews and the preparation
of environmental documents.
Business operation: Shared facilities;
Activities: BLM is pursuing larger office space to house all the
Glenwood Springs Energy Office staff in one location. Staff have had to
use two separate office locations a few miles apart.
Business operation: Performance measures;
Activities: The pilot established performance measures to report on its
progress. The Glenwood Springs office uses these performance measures.
Examples of the measures include permit-processing times, cost to
process permits, and inspection and enforcement actions completed.
Business operation: Budget;
Activities: The 2005 act created a special fund in the Treasury for the
coordination and processing of oil and gas use permits under the
jurisdiction of the pilot project. This funding has resulted in about
$23 million annually for all pilot offices.
Source: GAO analysis of Forest Service and BLM information.
[End of table]
After the pilot project's second year, the Forest Service and BLM
issued a joint report on the progress made in approving permits more
quickly. The agencies reported significant progress for two of the
pilot's key objectives--improving the reliability of permits needed to
develop energy resources and increasing environmental stewardship and
mitigation of environmental impacts resulting from energy development.
The report also documented challenges with human capital and
information technology systems, however, and recommended several
improvements for the program. Many of the human capital recommendations
are designed to address the difficulty of recruiting and retaining
qualified staff and include increasing the use of experienced retirees
and establishing recruitment and retention bonuses for hard-to-fill
positions. In addition, the report recommends that BLM assess the
constraints of current information technology systems because the
primary system used to track drilling activities on federal land is
more than 10 years old and beyond its normal lifecycle.
[End of section]
Appendix VI: Comments from the Department of the Interior:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
The Associate Deputy Secretary Of The Interior:
Washington:
January 16, 2009:
Ms. Robin M. Nazzaro:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G. Street, NW:
Washington, D.C. 20548:
Dear Ms. Nazzaro:
Thank you for providing the Department of the Interior the opportunity
to review and comment on the draft Government Accountability Office
report entitled, "Federal Land Management: Observations on a Possible
Move of the Forest Service into the Department of the Interior," (GAO-
09-223). We appreciate the diligent work of the team that prepared the
report to accurately and fairly present the information collected from
a diverse array of sources and the divergent views of the many involved
stakeholders. We are providing some general comments that apply to the
entire report and some specific comments that are described in the
enclosure.
The Department of the Interior generally agrees with the depiction of
the challenges associated with a potential consolidation of land
management agencies and the need to adequately assess the cultural,
organizational, and legal factors and related transition costs for such
a move. All the costs of such a transition should be carefully
considered, as they likely would be substantial, and it is certain that
there would be significant hidden costs caused by lost productivity and
reduced customer service while the people and the organization are
adjusting to the changes. We appreciate the perspective that there may
be limited short-term efficiencies and significant costs related to the
necessary changes to processes and systems. It would be important to
ensure funding is available to address such costs in order to avoid
additional impacts to ongoing programs and mission goals.
A considerable portion of the report is dedicated to depicting the
views of stakeholders and individuals who would be impacted by the
possible move. We suggest that the report include the source of the
specific views depicted in the report. If possible, cite whether the
experts and officials are representing the Federal bureaucracy, States,
local governments, or other stakeholder groups. Documentation of the
source of the specific observations that are represented would put this
information in perspective and add value to the presentation. [See
comment 1]
We appreciate the time and attention given to the Service First
Program. We are convinced that the Service First Program demonstrates
the improved effectiveness that is possible when barriers that separate
agency programs are addressed head-on. However, it is currently very
difficult to measure and report on the benefits resulting from
increased customer satisfaction, improved efficiency for the clients of
the agencies, and best practices in overcoming bureaucratic hurdles.
The comment on page 8 that "reports showed few efficiencies gained"
clearly points to the need for Interior and Forest Service to continue
to eliminate barriers that make interagency collaboration complex and
costly.
We do not agree that a predictable outcome of the move of the Forest
Service to Interior would be diminution of the role that the Forest
Service plays working with farmers, ranchers, and State foresters to
conserve resources on State and private lands. There is no basis to
assume that the Forest Service would modify its current role in these
areas simply as a result of moving to Interior. We believe it may be
possible that the move could strengthen Interior's ability to venture
into these areas in order to improve the conservation of endangered
species, wetlands, and other resources on State and private lands.
These programs already exist in Interior bureaus and have been an area
of increasing focus in recent years. A fuller examination of the
potential outcomes relative to this issue could add balance to the
report. [See comment 2]
Although it is not addressed in this draft report, we believe that an
assessment of opportunities for improved land and resource management
practices would assist in arriving at the appropriate course of action.
A move to collocate Forest Service and the Bureau of Land Management
would create numerous challenges. Most would be overcome in 10-15
years. These challenges, however, should not stand in the way of
positioning these agencies to confront the complex land management
issues that will be facing the Nation in the years to come. Would the
move advance the ability of the agencies to manage lands and protect
resources, adapt to climate change, or utilize science? Would it
improve capabilities in the management of natural resources in forests,
on rangelands, wetlands? Answers to these questions are a very
important part of the decisionmaking process. [See comment 3]
We hope these comments will assist you in preparing the final report.
If you have any additional questions or concerns, please contact Ms.
Nancy Thomas, GAO Audit Liaison, at (202) 208-7954.
Sincerely,
Signed by:
James E. Cason:
Enclosure:
The following are GAO's comments on the Department of the Interior's
letter dated January 16, 2009.
GAO Comments:
1. Throughout our report, the word officials refers to federal agency
officials, and experts refers to the individuals listed in appendix II.
When we speak of state or local government officials or other
stakeholders, we identify them as such. We added a footnote on page 3
of this report to explain our use of the word officials.
2. We did not mean to imply that diminishment of the Forest Service's
state and private forestry role is a certain outcome. Rather, the
report reflects the concerns of many federal officials, some experts,
and some state foresters who cautioned against disrupting the Forest
Service's relationships with state and private landowners, and with
other USDA agencies. Specifically, these officials, experts, and state
foresters were concerned that a move could disrupt the agency's work
with these entities in carrying out USDA's mission to protect and
enhance natural resources on private as well as public lands. The
officials and state foresters also raised concerns that Interior does
not have USDA's long-standing relationships with nonfederal partners or
mission focus on nonfederal lands, which may cause the Forest Service's
focus to shift to public lands. Further, some officials and state
foresters were uncertain whether the authorities provided to the Forest
Service through USDA (e.g., through the Farm Bill) would be transferred
if the agency were moved and how smoothly such transfers of authority
could be implemented. To clarify these concerns, we revised and added
language to the report on pages 17, 18, and 19. We agree that, over
time, a move could strengthen Interior's ability to work with state and
private landowners but believe that our report recognizes this
potential and provides sufficient examples illustrating Interior's
existing programs to work with state and private landowners. We added a
sentence on page 19 to convey Interior's belief that the department
could better conserve endangered species, wetlands, and other species
on state and private lands if the Forest Service were housed within the
department.
3. We agree that an assessment of this nature would be of value in
deciding on a further course of action. We added a statement on page 20
of the report to highlight a number of officials' and experts'
statements that land management--including management across landscapes
and administrative jurisdictions--could be improved by a move.
[End of section]
Appendix VII: GAO Contact and Staff Acknowledgments:
GAO Contact:
Robin M. Nazzaro (202) 512-3841 or nazzaror@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, David P. Bixler, Assistant
Director; Ulana Bihun; Ellen W. Chu; Susan Iott; Richard P. Johnson;
Mehrzad Nadji; Susan Offutt; Angela Pleasants; Anne Rhodes-Kline;
Lesley Rinner; Dawn Shorey; and Sarah Veale made key contributions to
this report. In addition, Muriel Brown, Douglas Cole, Melinda Cordero,
and Mike Jenkins also contributed to this report.
[End of section]
Related GAO Products:
Resource and Environment Agencies:
Natural Resource Management: Opportunities Exist to Enhance Federal
Participation in Collaborative Efforts to Reduce Conflicts and Improve
Natural Resource Conditions. [hyperlink,
http://www.gao.gov/products/GAO-08-262]. Washington, D.C.: February 12,
2008.
Federal Oversight of Food Safety: High-Risk Designation Can Bring
Attention to Limitations in the Government's Food Recall Programs.
[hyperlink, http://www.gao.gov/products/GAO-07-785T]. Washington, D.C.:
April 24, 2007.
Federal Food Safety and Security System: Fundamental Restructuring Is
Needed to Address Fragmentation and Overlap. [hyperlink,
http://www.gao.gov/products/GAO-04-588T]. Washington, D.C.: March 30,
2004.
Environmental Protection: Observations on Elevating the Environmental
Protection Agency to Cabinet Status. [hyperlink,
http://www.gao.gov/products/GAO-02-552T]. Washington, D.C.: March 21,
2002.
Land Management Agencies: Ongoing Initiative to Share Activities and
Facilities Needs Management Attention. [hyperlink,
http://www.gao.gov/products/GAO-01-50]. Washington, D.C.: November 21,
2000.
Land Management: The Forest Service's and BLM's Organizational
Structures and Responsibilities. [hyperlink,
http://www.gao.gov/products/GAO/RCED-99-227]. Washington, D.C.: July
29, 1999.
Land Management Agencies: Major Activities at Selected Units Are Not
Common across Agencies. [hyperlink,
http://www.gao.gov/products/GAO/RCED-97-141]. Washington, D.C.: June
26, 1997.
Federal Land Management: Streamlining and Reorganization Issues.
[hyperlink, http://www.gao.gov/products/GAO/T-RCED-96-209]. Washington,
D.C.: June 27, 1996.
Department of Energy: A Framework for Restructuring DOE and Its
Missions. GAO/RCED-95-197. Washington, D.C.: August 21, 1995.
Program to Transfer Land between the Bureau of Land Management and the
Forest Service Has Stalled. [hyperlink,
http://www.gao.gov/products/GAO/RCED-85-21]. Washington, D.C.: December
27, 1984.
Department of Homeland Security:
Homeland Security: Departmentwide Integrated Financial Management
Systems Remain a Challenge. [hyperlink,
\http://www.gao.gov/products/GAO-07-536]. Washington, D.C.: June 21,
2007.
Federal Emergency Management Agency: Factors for Future Success and
Issues to Consider for Organizational Placement. [hyperlink,
http://www.gao.gov/products/GAO-06-746T]. Washington, D.C.: May 9,
2006.
Department of Homeland Security: A Comprehensive and Sustained Approach
Needed to Achieve Management Integration. [hyperlink,
http://www.gao.gov/products/GAO-05-139]. Washington, D.C.: March 16,
2005.
Homeland Security: Management Challenges Remain in Transforming
Immigration Programs. [hyperlink,
http://www.gao.gov/products/GAO-05-81]. Washington, D.C.: October 14,
2004.
Homeland Security: Challenges Facing the Coast Guard as It Transitions
to the New Department. [hyperlink,
http://www.gao.gov/products/GAO-03-467T]. Washington, D.C.: February
12, 2003.
Homeland Security: Effective Intergovernmental Coordination Is Key to
Success. [hyperlink, http://www.gao.gov/products/GAO-02-1013T].
Washington, D.C.: August 23, 2002.
Homeland Security: Critical Design and Implementation Issues.
[hyperlink, http://www.gao.gov/products/GAO-02-957T]. Washington, D.C.:
July 17, 2002.
Government Reorganization:
Review of Potential Merger of the Library of Congress Police and/or the
Government Printing Office Police with the U.S. Capitol Police.
[hyperlink, http://www.gao.gov/products/GAO-02-272R]. Washington, D.C.:
July 5, 2002.
Government Reorganization: Observations on the Department of Commerce.
[hyperlink, http://www.gao.gov/products/GAO/T-GGD/RCED/AIMD-95-248].
Washington, D.C.: July 25, 1995.
Federal Reorganization: Congressional Proposal to Merge Education,
Labor, and EEOC. [hyperlink,
http://www.gao.gov/products/GAO/HEHS-95-140]. Washington, D.C.: June 7,
1995.
Government Restructuring: Identifying Potential Duplication in Federal
Missions and Approaches. [hyperlink,
http://www.gao.gov/products/GAO/T-AIMD-95-161]. Washington, D.C.: June
7, 1995.
Government Reorganization: Issues and Principles. [hyperlink,
http://www.gao.gov/products/GAO/T-GGD/AIMD-95-166]. Washington, D.C.:
May 17, 1995.
Managing for Results:
Results-Oriented Government: Practices That Can Enhance and Sustain
Collaboration among Federal Agencies. [hyperlink,
http://www.gao.gov/products/GAO-06-15]. Washington, D.C.: October 21,
2005.
Twenty-first Century Challenges: Reexamining the Base of the Federal
Government. [hyperlink, http://www.gao.gov/products/GAO-05-325SP].
Washington, D.C.: February, 2005.
Results-Oriented Cultures: Implementation Steps to Assist Mergers and
Organizational Transformations. [hyperlink,
http://www.gao.gov/products/GAO-03-669]. Washington, D.C.: July 2,
2003.
Highlights of a GAO Forum: Mergers and Transformation: Lessons Learned
for a Department of Homeland Security and Other Federal Agencies.
[hyperlink, http://www.gao.gov/products/GAO-03-293SP]. Washington,
D.C.: November 14, 2002.
Managing for Results: Barriers to Interagency Coordination. [hyperlink,
http://www.gao.gov/products/GAO/GGD-00-106]. Washington, D.C.: March
29, 2000.
Managing for Results: The Statutory Framework for Performance-Based
Management and Accountability. [hyperlink,
http://www.gao.gov/products/GAO/GGD/AIMD-98-52]. Washington, D.C.:
January 28, 1998.
[End of section]
Footnotes:
[1] Public Land Law Review Commission, One-Third of the Nation's Land
(Washington, D.C.: Government Printing Office, 1970).
[2] Throughout this report, the word officials refers to federal agency
officials.
[3] GAO, Results-Oriented Cultures: Implementation Steps to Assist
Mergers and Organizational Transformations, [hyperlink,
http://www.gao.gov/products/GAO-03-669] (Washington, D.C.: July 2,
2003).
[4] After the turn of the twentieth century and before 1956, a number
of programs dealing with fish and wildlife were created. The Fish and
Wildlife Service was administratively created from two of these
programs in 1940. And although a number of refuges were set aside and
legislation was passed to fund and manage the refuges, the first
comprehensive legislation addressing refuge management was not enacted
until 1966, with passage of the National Wildlife Refuge System
Administration Act. Pub. L. No. 89-669, 80 Stat. 927.
[5] Act of June 28, 1934, 48 Stat. 1269.
[6] Pub. L. No. 94-579, § 102(a), 90 Stat. 2743 (1976). For a more
detailed discussion of the history of federal land ownership, see
Kristina Alexander and Ross W. Gorte, Federal Land Ownership:
Constitutional Authority and the History of Acquisition, Disposal, and
Retention (Washington, D.C.: Congressional Research Service, 2007).
[7] The remaining federal lands are managed by other federal agencies,
including the Department of Defense, Department of Energy, and Bureau
of Reclamation.
[8] Pub. L. No. 91-190, 83 Stat. 853 (1970); Pub. L. No. 93-205, 87
Stat. 886 (1973).
[9] The agencies are also required to consult with the National Oceanic
and Atmospheric Administration's National Marine Fisheries Service, in
the Department of Commerce, for actions that may affect threatened and
endangered species under this agency's jurisdiction. Such species
include marine mammals, marine turtles, marine and anadromous (fresh-
saltwater migrant) fish, and marine invertebrates and plants.
[10] Brian Balogh et al., Making Democracy Work: A Brief History of
Twentieth-Century Federal Executive Reorganization (Charlottesville,
Va.: Miller Center of Public Affairs, 2002).
[11] Under a series of laws authorizing the reorganization of the
executive branch, the President developed reorganization plans and
submitted them to Congress for approval subject to the veto of either
house. The Supreme Court held such "legislative veto" mechanisms
unconstitutional in Immigration and Naturalization Service v. Chadha,
462 U.S. 919 (1983). In 1984, Congress specifically ratified all
reorganization plans that had taken place under the reorganization
laws. Pub. L. No. 98-532, 98 Stat. 2705 (1984). No reorganization plan
has taken effect since.
[12] GPRA, Pub. L. No. 103-62 (1993), was enacted to help resolve long-
standing management problems that undermined the federal government's
efficiency and effectiveness and to provide greater accountability for
results.
[13] Pub. L. No. 101-576, 104 Stat. 2838 (1990), as amended.
[14] Pub. L. No. 104-106, Div. E, 110 Stat. 186 (1996), as amended.
[15] Other proposals were made during this time, such as a pilot
project to manage ecosystems across agency boundaries and a
congressional bill to create a department of natural resources. The
first proposal did not suggest a full reorganization, and the second
was not subject to further hearings or debate, and for these reasons,
we did not count them here as full-fledged proposals.
[16] The Service First authority was recently extended to March 2009 in
Pub. L. No. 110-329, Div. A, § 106, 122 Stat. 3575; § 147, 122 Stat.
3581 (2008).
[17] Pub. L. No. 109-58, § 365, 119 Stat. 723 (2005).
[18] A measurement of lumber in a tree or elsewhere, a board foot
equals a board that is 1 inch thick, 12 inches long, and 12 inches
wide, or 144 cubic inches.
[19] The Post-Katrina Emergency Management Reform Act addressed many of
these issues and enhanced the agency's position within DHS (Pub. L. No.
109-295, 120 Stat. 1355).
[20] Pub. L. No. 95-313, 92 Stat. 365 (1978), as amended.
[21] Pub. L. No. 110-246, § 2709, 122 Stat. 1809 (2008).
[22] On April 21, 2008, USDA issued the most recent version of the
forest planning rule. Environmental groups have challenged the rule in
court, asserting that USDA issued it in violation of NEPA and the
Endangered Species Act. The case is pending.
[23] Pub. L. No. 94-588, 90 Stat. 2949.
[24] For a comparison of BLM and Forest Service appeals processes, see
GAO, Oil and Gas Development: Challenges to Agency Decisions and
Opportunities for BLM to Standardize Data Collection, [hyperlink,
http://www.gao.gov/products/GAO-05-124] (Washington, D.C.: Nov. 30,
2004).
[25] Act of Aug. 28, 1937, 50 Stat. 874.
[26] The Forest Service has firefighters charge all their hours to fire
suppression, including the regular 8 hours an employee would work,
while the Interior agencies charge only overtime pay, over and above
the 8 hours an employee would work. The first 8 hours of an employee's
time are called the "base-8," and the agencies and Office of Management
and Budget cannot agree on how to budget for or charge this time--
whether it should be part of emergency fire suppression funds or part
of the agency's budget for fire preparedness.
[27] The Grace Commission was created by President Ronald Reagan to
study potential efficiencies in government agencies (see appendix III).
[28] Although attempts have been made to estimate the costs of lost
productivity, it is difficult to generalize because the scale of such
losses varies from case to case.
[29] [hyperlink, http://www.gao.gov/products/GAO-03-669].
[30] The agency was originally named the National Biological Survey but
was renamed the National Biological Service in 1995.
[31] GAO, Highlights of a GAO Forum: Mergers and Transformation:
Lessons Learned for a Department of Homeland Security and Other Federal
Agencies, [hyperlink, http://www.gao.gov/products/GAO-03-293SP]
(Washington, D.C.: Nov. 14, 2002).
[32] At the time of this review, some of these positions were vacant.
[33] While the Forest Service has a regional structure different from
that of Interior's agencies, some officials did not think this
difference would be a factor to consider in a move because none of
Interior's land management agencies have identical regional boundaries.
The Forest Service has 9 regions, BLM has 12 state offices, the
National Park Service has 7 regions, and the Fish and Wildlife Service
has 8 regions.
[34] According to officials, costs to plan and acquire shared USDA
systems totaled almost $180 million through fiscal year 2008.
[35] Electronic-government initiatives use Internet-based technology to
make it easier for citizens and businesses to interact with the
government, save taxpayer dollars, and streamline citizen-to-
government communications.
[36] Interior's working capital fund totaled about $174 million in
fiscal year 2007. Of this amount, Interior charged BLM about $21
million (12 percent) and National Park Service about $30 million (17
percent).
[37] Ross W. Gorte, Proposals to Merge the Forest Service and the
Bureau of Land Management: Issues and Approaches (Washington, D.C.:
Congressional Research Service, 2008).
[38] Pub. L. No. 108-447, Div. J., title VIII, 118 Stat. 3377 (2004).
[39] The Intertribal Timber Council is a nonprofit nationwide
consortium of Indian tribes, Alaska Native corporations, and
individuals dedicated to improving the management of natural resources
important to Native American communities.
[40] Pub. L. No. 108-278, 118 Stat. 868 (2004).
[41] Title I of the Indian Self-Determination and Education Assistance
Act, Pub. L. No. 93-638, 88 Stat. 2206 (1975), as amended, authorizes
tribes to take over, through contractual agreements with the agencies
that previously administered them, administration of certain programs
administered on their behalf by Interior. Title IV of the act, as
amended, authorizes Interior to enter into annual funding agreements
for self-governance with tribes.
[42] In particular, the Intertribal Timber Council said, moving the
Forest Service could standardize wildland fire budgets and accounting
practices across the federal land management agencies and the Bureau of
Indian Affairs; provide greater visibility of funding equity for forest
management across the federal land management agencies and the Bureau
of Indian Affairs; and facilitate the transfer of funds to tribes to
address insect and disease infestations affecting tribal forests and
woodlands.
[43] For example, a tribal representative noted that more than 50
percent of the Winema National Forest consists of former Klamath Indian
Reservation land purchased during the 1960s and 1970s, and the Olympic
National Forest includes a small, isolated parcel of land within the
boundaries of the Quinault Indian Reservation, which was acquired
during the 1990s.
[44] In the Senate and House of Representatives, the resources
committees have jurisdiction over Interior's land management agencies
and the forest reserves (national forests) created from the public
domain, and the agriculture committees have jurisdiction over acquired
forest lands and forest management generally. Within the appropriations
committees in the Senate and House of Representatives, the Interior
subcommittees have jurisdiction over Interior's land management
agencies, as well as the Forest Service.
[45] In 2002, the Congressional Research Service reported that at least
11 full Senate committees and 14 full House committees, as well as
their subcommittees, have some responsibility for oversight of U.S.
programs to combat terrorism, see Harold C. Relyea, Homeland Security:
Department Organization and Management (Washington, D.C.: Congressional
Research Service, 2002).
[46] [hyperlink, http://www.gao.gov/products/GAO-03-669].
[47] GAO, Results-Oriented Cultures: Implementation Steps to Assist
Mergers and Organizational Transformations, [hyperlink,
http://www.gao.gov/products/GAO-03-669] (Washington, D.C.: July 2,
2003).
[48] Ross W. Gorte, Proposals to Merge the Forest Service and the
Bureau of Land Management: Issues and Approaches (Washington, D.C.:
Congressional Research Service, May 2008).
[49] In 1991, the House Budget Committee proposed eliminating eight
cabinet departments by consolidating existing agencies and departments,
including combining Interior, USDA, and Energy into a Department of
Natural Resources. Committee Chair Leon Panetta introduced a bill in
1992 to establish a Commission on Executive Organization to consider
such consolidations, but no hearings on the bill were held. In
addition, under President Clinton, the National Performance Review
recommended a pilot program based on ecosystem management principles
that did not contemplate a full reorganization of the Forest Service or
Interior's agencies. We did not include either of these proposals in
our historical review.
[50] Public Land Law Review Commission, One-Third of the Nation's Land
(Washington, D.C.: Government Printing Office, 1970).
[51] President's Advisory Council on Executive Organization, Memorandum
for the President: Subject: The Establishment of a Department of
Natural Resources (Washington, D.C., May 12, 1970).
[52] The Nixon administration was successful in creating the
Environmental Protection Agency in Reorganization Plan No. 3 of 1970.
[53] Executive Office of the President, Office of Management and
Budget, President's Reorganization Project: Report on Reorganization
Study of Natural Resource Functions (Washington, D.C.: June 1979).
[54] President's Private Sector Survey on Cost Control, Department of
the Interior Task Force, President's Private Sector Survey on Cost
Control: Report on the Department of the Interior (Washington, D.C.:
August 1983).
[55] Department of the Interior, BLM, and USDA, Forest Service,
BLM/Forest Service Interchange: National Summary and Legislative
Concepts (Washington, D.C.: 1985).
[56] The Service First authority was recently extended to March 2009 in
Pub. L. No. 110-329.
[57] The Service First initiative was called the Trading Post program
until fiscal year 1998, when the name was changed to Service First.
[58] Two or more agencies integrate operations when similar units work
as one. For example, integration occurs when fleet, road maintenance,
or telecommunications units work together in the same space and the
public is unable to discern who works for which agency.
[59] GAO, Land Management Agencies: Ongoing Initiative to Share
Activities and Facilities Needs Management Attention, [hyperlink,
http://www.gao.gov/products/GAO-01-50] (Washington, D.C.: Nov. 21,
2000).
[60] The Service First efforts reviewed included sites in Durango,
Colorado; Lakeview, Oregon; Salmon, Idaho; Idaho Falls, Idaho; Las
Vegas, Nevada; Milwaukee, Wisconsin; Portland, Oregon; Buffalo,
Wyoming; and Pocatello, Idaho.
[61] Pub. L. No. 109-58.
[62] See GAO, Oil and Gas Development: Increased Permitting Activity
Has Lessened BLM's Ability to Meet Its Environmental Protection
Responsibilities, [hyperlink, http://www.gao.gov/products/GAO-05-418]
(Washington, D.C.: June 17, 2005), for additional background on oil and
gas permitting.
[63] The seven offices include Buffalo, Wyoming; Carlsbad, New Mexico;
Farmington, New Mexico; Grand Junction-Glenwood Springs, Colorado;
Miles City, Montana; Rawlins, Wyoming; and Vernal, Utah.
[64] Section 390 provides that "action by the Secretary of the Interior
in managing the public lands, or the Secretary of Agriculture in
managing National Forest System Lands, with respect to any of the
activities described in subsection (b) of this section shall be subject
to a rebuttable presumption that the use of a categorical exclusion
under the National Environmental Policy Act of 1969 (NEPA) would apply
if the activity is conducted pursuant to the Mineral Leasing Act for
the purpose of exploration or development of oil or gas." 42 U.S.C. §
15942(a). The five categories include (1) individual surface
disturbances of less than 5 acres, as long as the total surface
disturbance on the lease is not greater than 150 acres, and site-
specific analysis in a document prepared pursuant to NEPA has been
previously completed; (2) drilling an oil or gas well at a location or
well pad site at which drilling has already occurred no more than 5
years before the date of spudding (breaking ground for) the well; (3)
drilling an oil or gas well within a developed field for which an
approved land use plan, or any environmental document prepared pursuant
to NEPA, analyzed such drilling as a reasonably foreseeable activity,
as long as such plan or document was approved no more than 5 years
before the date of spudding the well; (4) placement of a pipeline in an
approved right-of-way corridor, as long as the corridor was approved no
more than 5 years before the date of placement of the pipeline; and (5)
maintenance of a minor activity, other than any construction or major
renovation or a building or facility. 42 U.S.C. 15942(b).
[End of section]
GAO's Mission:
The Government Accountability Office, the audit, evaluation and
investigative arm of Congress, exists to support Congress in meeting
its constitutional responsibilities and to help improve the performance
and accountability of the federal government for the American people.
GAO examines the use of public funds; evaluates federal programs and
policies; and provides analyses, recommendations, and other assistance
to help Congress make informed oversight, policy, and funding
decisions. GAO's commitment to good government is reflected in its core
values of accountability, integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each
weekday, GAO posts newly released reports, testimony, and
correspondence on its Web site. To have GAO e-mail you a list of newly
posted products every afternoon, go to [hyperlink, http://www.gao.gov]
and select "E-mail Updates."
Order by Phone:
The price of each GAO publication reflects GAO‘s actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO‘s Web site,
[hyperlink, http://www.gao.gov/ordering.htm].
Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.
Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional
information.
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]:
E-mail: fraudnet@gao.gov:
Automated answering system: (800) 424-5454 or (202) 512-7470:
Congressional Relations:
Ralph Dawn, Managing Director, dawnr@gao.gov:
(202) 512-4400:
U.S. Government Accountability Office:
441 G Street NW, Room 7125:
Washington, D.C. 20548:
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov:
(202) 512-4800:
U.S. Government Accountability Office:
441 G Street NW, Room 7149:
Washington, D.C. 20548:
