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Report to Congressional Requesters:



United States General Accounting Office:



GAO:



July 2002:



National ForestS:



Information on the Process and Data Used to Revise the Chugach Forest 

Plan:



Chugach National Forest Plan Revision:



GAO-02-855:



Contents:



Letter:



Results in Brief:



Background:



Agency Regulations Prescribed the Process Used to Revise the Chugach 

Forest Plan:



The Chugach Used Innovative Techniques to Solicit and Respond to Public 

Concerns:



Some Decisions Contained in the Agency’s Draft Plan Were Based on 

Limited Data, but These Limitations Were Addressed in the Final Plan:



Agency Comments:



Appendix I: Forest Service Authority to Study or Recommend for 

Designation as Wilderness Chugach National Forest Lands:



Figure:



Figure 1: The Four Major Areas of the Chugach National Forest:



Letter:



July 26, 2002:



The Honorable Frank H. Murkowski

Ranking Minority Member

Committee on Energy and Natural Resources

United States Senate:



The Honorable Don Young

House of Representatives:



Located on the south-central Alaska coast, the Chugach National Forest 

(Chugach) is the second largest of the 155 forests in the National 

Forest System and stretches across an immensely varied and scenic area 

about the size of New Jersey. The Forest Service is required by law to 

develop a comprehensive, long-range management plan for each national 

forest. These plans, commonly called forest plans, must provide for 

multiple, and sometimes competing, public uses in each forest, such as 

fishing, mining, timbering, and preserving wildlife. The plans must be 

revised at least every 15 years. Forest plans reflect difficult and 

often controversial trade-offs among competing forest uses. In 

developing a forest plan, the Forest Service analyzes data on various 

potential uses of the forest’s lands and resources in order to 

determine the most appropriate combination of the potential uses. 

Forest Service officials began revising the Chugach forest plan in 

1997. The agency issued a draft revised plan for public comment in 

September 2000 and a final revised plan in May 2002.



In this report, we discuss the (1) process the Forest Service used to 

revise the Chugach forest plan, (2) actions it took to solicit and 

respond to key public concerns about the plan’s revision, and (3) data 

and analyses it used to develop the draft revised plan and whether any 

limitations in these data and analyses were appropriately disclosed in 

the final plan. In addition, in appendix I, we discuss differing views 

on whether the Forest Service has the legal authority to recommend 

lands within the Chugach for wilderness designation as part of its 

forest plan revision process. Some interested parties believe that the 

Alaska National Interest Lands Conservation Act (ANILCA) prohibits the 

Forest Service from making any such recommendations. On the other hand, 

the Forest Service maintains that it may do so without violating the 

act.



Results in Brief:



The Forest Service revised the Chugach National Forest Plan in 

accordance with the agency’s planning regulations. These regulations 

required that the Forest Service solicit and respond to public concerns 

in (1) identifying issues to be considered in revising the plan, (2) 

developing alternative plans for evaluation, (3) selecting a draft 

preferred alternative plan, and (4) adopting a final revised plan. 

Beginning in July 1997, the agency worked with the public to develop 30 

alternative plans, each of which proposed a different combination of 

recreation, wildlife, mining, timber, subsistence, wilderness, and 

other uses of the Chugach. The Forest Service then combined alternative 

plans having similar features to reduce the number down to six. The 

agency then performed a detailed comparative analysis of these six 

alternative plans and a preferred agency alternative that the Forest 

Service developed based on the combined features of the six alternative 

plans. In September 2000, the Forest Service issued for public comment 

the results of its comparative analysis together with its draft 

preferred alternative. In May 2002, the Forest Service issued a final 

revised plan based on its draft preferred alternative as modified by 

the public comments it received.



Forest Service officials actively solicited key public concerns about 

revising the Chugach forest plan by distributing frequent newsletters; 

maintaining a Web site to allow the public access to key documents; and 

holding over 100 public meetings on the plan, including ones to solicit 

potential alternative revisions to the plan and, later, discuss 

concerns about its draft preferred alternative plan. As a result, over 

the entire planning period, the agency received more than 36,000 

comments from the public. These comments generally addressed concerns 

about the trade-offs among competing uses of the Chugach, such as 

conflicts between motorized and non-motorized recreation or habitat 

protection. Most suggested that the revised plan should place emphasis 

on preserving, rather than developing, the forest’s lands and 

resources. Most comments also suggested that the revised plan include a 

recommendation that the Congress designate additional portions of the 

forest as wilderness areas. Interested and affected parties told us 

that, while they would have preferred that the agency’s draft revised 

plan had emphasized more of the forest uses that they preferred, they 

believed that Forest Service officials included important elements of 

their views.



In developing its draft revised plan, issued in September 2000, the 

Forest Service obtained and analyzed a vast amount of data on various 

potential uses of the lands and resources within the Chugach. These 

data and analyses focused largely on timber harvesting, mineral mining, 

commercial fishing, recreation and tourism, forest vegetation, and fish 

and wildlife habitats, and were used to guide various decisions on 

difficult and sometimes controversial trade-offs among competing forest 

uses. Our review showed that the data and analyses that the Forest 

Service used to make some decisions had limitations that were not 

disclosed in the draft revised plan. These decisions involved (1) 

possible commercial harvesting of timber, (2) potential mining for 

minerals, and (3) protection of a potentially at-risk brown bear 

population on the Kenai Peninsula of the Chugach. For example, in 

making decisions on uses of the Kenai Peninsula, the Forest Service did 

not have sufficient data to determine whether a stable brown bear 

population existed in the peninsula and the measures necessary to 

ensure the population’s viability in the presence of human uses of the 

peninsula. The draft plan did not disclose these data limitations or 

any actions being considered by the Forest Service to fill data gaps 

and make appropriate adjustments to the plan. However, our review of 

the final revised forest plan, issued in May 2002, and discussions with 

agency officials, indicate that the agency has addressed our concerns 

about data limitations and how the Forest Service plans to fill data 

gaps and consider, where appropriate, amending the plan.



Background:



The Chugach National Forest was established in 1907 and is the second 

largest forest in the National Forest System. The forest extends for 

over 200 miles along the Alaska coastline southeast of Anchorage, 

encompasses over 5 million acres, and is bordered by two national 

parks, a state park, and a national wildlife refuge. A forest 

supervisor located in Anchorage manages the Chugach, and a regional 

forester located in Juneau has overall responsibility for the Chugach 

and the other national forest in Alaska.



The Chugach Comprises Four Major Geographic Areas:



As shown in figure 1, the Chugach covers four major areas, each of 

which presents agency planners and the public with significantly 

different issues.



Figure 1: The Four Major Areas of the Chugach National Forest:



[See PDF for image]



Source: Adapted from Forest Service data.



[End of figure]



As shown in figure 1, the westernmost major area of the Chugach is the 

Kenai Peninsula area. This area--the nearest to Alaska’s largest urban 

population center, Anchorage--is a growing recreation area, especially 

for motorized recreation such as snowmobiles and all-terrain vehicles. 

It also has a significant population of Alaska Brown Bears that the 

State of Alaska has designated as being of special concern because of 

vulnerability to human impacts.



The Nellie Juan-College Fiord Wilderness Study Area is a greatly 

glaciated, remote area lacking roads. The Forest Service had 

recommended that the Congress designate much of this area as wilderness 

where human activities would be significantly limited. Pending this 

designation, or its rejection, it is being managed as such.



The Prince William Sound area contains large offshore islands, such as 

Montague Island, where timber has been harvested in the past. The city 

of Valdez, located on the Sound, is the southern terminus of the Trans-

Alaska Pipeline. In 1989, the oil tanker Exxon Valdez spilled millions 

of gallons of oil into the sound, significantly damaging marine and 

shore animals and their habitat and requiring a multiyear, 

multibillion-dollar federal clean-up effort.



The Copper River Delta area, located at the forest’s eastern edge, is 

dominated by one of North America’s most significant rivers for salmon 

production. The city of Cordova contains major fish-processing 

facilities. At around 2 million acres, the Delta is the most extensive 

wetlands complex on the Pacific coast of North America and is a highly 

productive ecosystem for shorebirds, waterfowl, and fish. Portions of 

the Delta may contain commercial oil and gas.



The Original Chugach Forest Plan:



The original Chugach forest plan was adopted in July 1984, but several 

environmental groups appealed the plan through the Forest Service’s 

appeal procedures, arguing that the plan was based on an analysis that 

had been done at too large a geographical scale to identify many actual 

effects in specific areas on the ground. As a result, they contended, 

the plan allowed too much development and was likely to damage fish and 

wildlife resources. The Forest Service and the appellants negotiated a 

settlement agreement in 1985. In January 1986, Forest Service officials 

amended the 1984 plan to incorporate the requirements of the agreement.



Among other things, the 1986 amendment limited timber sales on the 

Chugach to an average of about 8 million board feet per year over the 

next decade, or about half the originally approved plan’s level of over 

16 million board feet.[Footnote 1] The amendment also committed the 

Chugach to conduct further studies at smaller geographic scales, which 

might result in additional amendments to the plan.



Agency Regulations Prescribed the Process Used to Revise the Chugach 

Forest Plan:



The National Forest Management Act (NFMA) of 1976 requires the Forest 

Service to, among other things, (1) develop a plan to manage the lands 

and resources of each national forest in coordination with the land 

management planning processes of other federal agencies, states, and 

localities and (2) revise each plan at least every 15 years. The Forest 

Service’s planning regulations in effect during the Chugach revision 

process established detailed procedures for developing a forest plan. 

These procedures required the agency to develop several alternatives 

for managing a forest and to make these alternatives available for 

public comment.[Footnote 2] Furthermore, the regulations required the 

agency to develop an environmental impact statement in accordance with 

the National Environmental Policy Act of 1969 (NEPA) to accompany each 

forest plan. An environmental impact statement assesses the effects of 

a major federal action that may significantly affect the quality of the 

human environment.



In accordance with the process specified in the agency’s then-existing 

planning regulations, the Chugach Forest Supervisor appointed an 

interdisciplinary team that began revising the forest plan in April 

1997. Agency regulations encouraged the public to participate 

throughout the planning process in order to (1) broaden the agency’s 

information base; (2) ensure that the agency understands the needs, 

concerns, and values of the public; (3) inform the public of the 

agency’s planning activities; and 

(4) provide the public with an understanding of the agency’s programs 

and proposed actions.



The interdisciplinary team, working with the public, developed 30 

alternative plans. Each alternative proposed a different combination of 

recreation, wildlife, mining, timber, subsistence, wilderness, and 

other uses in the Chugach. The team then combined similar alternatives 

to reduce the number of alternatives down to six. It then conducted a 

detailed comparative analysis of these six alternatives together with a 

required “no action” (i.e., no change) alternative, and a preferred 

agency alternative developed by the Forest Supervisor that combined 

features from all six alternative plans. In September 2000, the 

Supervisor of the Chugach National Forest issued for public comment the 

agency’s draft preferred alternative together with the detailed 

comparative analysis of all these alternatives.



Forest Service officials reviewed public comments received on the 

preferred alternative and, in response to these comments as well as 

further study, made changes to its preferred alternative for the Forest 

Supervisor’s approval. Upon approval, the Forest Supervisor forwarded 

the proposed final plan and an accompanying environmental impact 

statement to the Regional Forester for approval. In May 2002, the 

Regional Forester approved the final revised plan.



According to Forest Service officials, the vast majority of forest 

plans, since the first one adopted in 1982, have been administratively 

appealed, and many have subsequently have been litigated in federal 

courts.



The Forest Service Took Extensive Actions to Solicit and Respond to 

Public Concerns:



The Forest Service undertook sustained actions to solicit and respond 

to key public concerns about the revision to the Chugach forest plan. 

These actions included (1) distributing frequent newsletters on the 

planning process and its progress, (2) maintaining a Web site on the 

Internet with links to key planning documents and making available 

compact discs containing these documents, and (3) holding over 100 

meetings in which the public was invited to define key issues and 

formulate alternatives. These extensive actions went beyond those 

required under the agency’s planning process and those used in previous 

forest planning exercises. Also unique to this plan was the intensive 

work of the Chugach’s interdisciplinary team in what the agency termed 

a “collaborative learning process” to help members of the public 

fashion their own varied alternatives.



As a result of this outreach, the agency received thousands of comments 

on its draft preferred alternative. These comments generally reflected 

differing viewpoints about desirable trade-offs among competing uses of 

the Chugach. For example, many interested parties expressed concern 

that too much land was being allocated for motorized versus 

nonmotorized recreation, while others believed that too much land was 

being proposed for wilderness designations versus more intensive uses. 

Forest Service officials told us that, in general, nearly all parties 

agreed that they did not want the Chugach to change from its generally 

undisturbed character and existing usages, but that they disagreed over 

what posed the biggest threat to existing conditions and uses. Some 

thought the greatest threat came from increased development while 

others felt it came from increased restrictions on existing uses. Most 

suggested that the revised plan should place emphasis on preserving, 

rather than developing, the forest’s lands and resources.



To respond to these concerns, the agency (1) obtained additional 

information, (2) held additional meetings with the public, and 

(3) considered specific changes to its preferred alternative. 

Throughout the planning process all parties were provided numerous 

opportunities to place on the record their concerns about forest 

issues. Some members of the public told us that they felt there were 

times during the planning process that some Forest Service staff 

inappropriately expressed personal views on issues but that, during the 

long planning process, those staff transferred to other agency 

assignments and their replacements did not seem to share those views. 

Although some interested and affected parties still had concerns about 

the results of the revision process and the agency’s draft preferred 

alternative, virtually all parties told us they believed the Forest 

Service had included important elements of their views in the draft 

revised plan.



Some Decisions Contained in the Agency’s Draft Plan Were Based on 

Limited Data, but These Limitations Were Addressed in the Final Plan:



In developing the draft revised plan, the Forest Service obtained and 

analyzed a vast amount of data on timber harvesting, mineral mining, 

commercial fishing, recreation and tourism, forest vegetation, and fish 

and wildlife habitats. These data and analyses were used to make 

various decisions on difficult and sometimes controversial trade-offs 

among competing forest uses. In three areas, we found that the data and 

analyses used for making some decisions had limitations that were not 

disclosed in the draft revised plan. These decisions involved (1) 

possible commercial harvesting of timber, (2) potential mining for 

minerals, and (3) protection of a potentially at-risk brown bear 

population.



* Possible commercial harvesting of timber. The Forest Service did not 

calculate the maximum quantity of timber that might be sold over a 

decade from the area of suitable land covered by the forest plan. The 

agency did not perform such an analysis because officials believed (1) 

they were not legally required to do so, (2) commercial timber 

harvesting was not economically feasible in the Chugach because of the 

generally low quality of timber in the forest, low market prices, and 

the lack of nearby large markets, and (3) gathering and analyzing the 

data needed to calculate the maximum quantity was not worth the time, 

expense, and difficulty of doing so. However, the agency’s draft 

revision did not discuss the limitations of the analysis on which this 

decision was based.



* Potential mining for minerals. In order to make decisions about areas 

in the Chugach where mining would be permitted, the Forest Service 

analyzed a substantial body of data that it had gathered on past mining 

activities in the forest. However, such past activities were conducted 

in only a small portion of the forest, typically in areas accessible 

from existing forest roads. Forest Service officials told us that the 

Department of the Interior had estimated that it would cost 

approximately $8 million to survey the entire forest to determine the 

full potential for mineral mining activities. They believed that such 

costs were not warranted in view of other priorities of the forest 

competing for limited funds and that they were justified in basing 

decisions on the information that they had gathered on the past mining 

activities. However, the agency’s draft revised plan did not discuss 

the limitations of the analysis on which it based its decisions on 

mining activities within the forest.



* Protection of a potentially at-risk brown bear population. An 

interagency study on the size and trends of the brown bear population 

on the Kenai Peninsula of the Chugach, which may be at risk from human 

activities, was produced while the Forest Service was reviewing public 

comments on its draft-revised plan. This study, which the Forest 

Service participated in, reported that data are not available to 

determine whether a stable brown bear population currently exists in 

the peninsula and whether additional measures are needed to maintain 

the population’s viability in the presence of all types of human uses 

of the peninsula. The study calls for additional research to help 

answer these questions. The Forest Service’s draft revised plan did not 

disclose the findings of this interagency study nor did it identify 

steps that the agency would take to obtain additional data. Neither had 

the agency included reference to it in changes to the draft made during 

the comment period on it while our review was being conducted. Should 

evidence suggesting serious problems with the population trends of the 

Kenai brown bear become available during the time frame covered by the 

Chugach’s revised forest plan, it may be necessary to make changes to 

the plan that could unexpectedly alter planned human uses in some areas 

of the forest.



In March 2002, we met with the Forest Supervisor and other Forest 

Service officials and told them that our review indicated that 

limitations existed in some of the agency’s data and analyses and that 

the draft plan neither disclosed such limitations nor identified 

planned actions to address them. In May 2002, the agency issued a final 

revised Chugach forest plan. Our review of the final plan and 

discussions with agency officials indicate that the agency has 

addressed our concerns by

(1) agreeing to augment their analysis of data regarding timber 

harvesting in the forest, (2) explaining the limitations of data on 

potential mineral deposits in the forest and the agency’s decision to 

not incur costs associated with performing a comprehensive survey to 

determine the potential for mining minerals throughout the forest, and 

(3) referring to the findings of the interagency brown bear study and 

the agency’s planned monitoring of the brown bear population. In 

addressing these concerns, the agency also completed an internal 

science consistency evaluation considering data and limitations.



Agency Comments:



We provided a draft of this report to the Supervisor of the Chugach 

National Forest for review and comment. He generally concurred with our 

findings and made certain technical suggestions that we incorporated as 

appropriate.



We conducted our work from August 2001 through July 2002 in accordance 

with generally accepted government auditing standards. We visited the 

Chugach National Forest and obtained the views of and related 

documentation from Forest Service, state, industry, and environmental 

group officials located in Alaska and Forest Service headquarters 

officials located in Washington, D.C. We are sending copies of this 

report to the Secretary of Agriculture and the Chief of the Forest 

Service. In addition, the report will be available at no charge on the 

GAO Web site at http://www.gao.gov.



If you have any questions about this report, please call me at 202-512-

3841. Key contributors to this report were Charles S. Cotton, Richard 

P. Johnson, Chester M. Joy, and Edward A. Kratzer.



Barry T. Hill

Director, Natural Resources

 and Environment:



Signed by Barry T. Hill:



[End of section]



Appendix I: Forest Service Authority to Study or Recommend for 

Designation as Wilderness Chugach National Forest Lands:



In 1980, after several years of consideration, the Congress passed the 

Alaska National Interest Lands Conservation Act (ANILCA), which, among 

other things, addressed ongoing land disputes between the federal 

government and the state. Specifically, the act set aside millions of 

acres in “conservation system units,” a statutory term including 

national parks, wildlife refuges, wilderness areas, and wild and scenic 

rivers. The law also rescinded numerous public land withdrawals within 

Alaska by the President and Interior that had occurred in the 1970s. 

Section 1326(a) of ANILCA limited future executive branch land 

withdrawals of more than 5,000 acres in Alaska.



In addition, section 1326(b) of ANILCA prohibited “further studies of 

federal lands for the single purpose of considering the establishment 

of a conservation system unit” or other similar units unless authorized 

by ANILCA or future legislation. The Forest Service and other 

interested parties hold differing views on how this section should be 

interpreted with regard to the Forest Service’s legal authority to 

recommend to the Congress that portions of the Chugach be managed as 

wilderness areas. Some supporters of greater development maintain that 

section 1326 (b) prohibits the Forest Service from making any such 

recommendations outside the existing Wilderness Study Area in the 

forest. On the other hand, the Forest Service maintains that it may do 

so without violating ANILCA, as long as the recommendation is not based 

upon a study performed for the single purpose of designating an area as 

wilderness. Stakeholders also disagree over the proper interpretation 

of Section 501(b) of ANILCA. Some supporters of greater development 

believe that this section requires that the Copper River Delta within 

the Chugach be managed for fish and wildlife conservation and prohibits 

the Forest Service from recommending to the Congress that any portion 

of delta be designated as a wilderness area. The Forest Service 

believes that the delta can contain wilderness designations so long as 

the applicable management direction for the delta provides for the 

primacy of fish and wildlife conservation.



Only one court has examined section 1326(b) of ANILCA in any detail. In 

a recently completed forest plan for Tongass National Forest in 

southeast Alaska, the Forest Service recommended certain rivers for 

designation under the Wild and Scenic Rivers Act. Opponents of these 

recommendations challenged the Forest Service’s decision in Sierra Club 

v. Lyons, contending that ANILCA § 1326(b) prohibited the Forest 

Service’s action. In an unpublished opinion, the court in a brief 

discussion rejected the argument. The court stated that:



A review of the record before the Court reveals that the Forest Service 

did not study rivers in Alaska for the single purpose of considering 

the establishment of a conservation system unit. Rather the Forest 

Service conducted a study of the rivers for their eligibility as wild 

and scenic for the purposes of a general land management plan. Thus, no 

ANILCA violation occurred. Sierra Club v. Lyons, J00-0009 CV (JKS), 

Slip. Op. at 31 (March 30, 2001) (citations omitted).



The court in Lyons also held that the Forest Service had violated its 

planning regulations by failing to evaluate roadless areas within the 

Tongass to determine whether any of these should be recommended for 

inclusion in the National Wilderness Preservation System. The court 

ordered the Forest Service to carry out such an evaluation, which is 

currently being performed.



Supporters of greater development have asserted that section 1326(b) of 

ANILCA prohibits the Forest Service from studying national forest lands 

in Alaska for the purpose of considering additions to the Wild and 

Scenic River and Wilderness systems. Although the court in Lyons 

rejected this argument with respect to Wild and Scenic Rivers, these 

stakeholders contend that the government did not adequately explain the 

provisions of ANILCA to the court, thus leading the court to an 

erroneous conclusion. The Record of Decision states that the revised 

forest plan does not violate section 1326(b) because the plan is a 

general land management plan rather than a single purpose study.



Stakeholders also disagree over the proper management of the Copper 

River Delta. The Copper River Delta is a highly productive ecosystem 

that may contain commercial oil and gas deposits. A House version of 

ANILCA would have designated the area as a National Wildlife Refuge. As 

ultimately enacted, section 501(b) retained the Copper River Delta 

under the Forest Service’s jurisdiction, but provided that the primary 

purpose of the area was to further fish and wildlife conservation.



Some stakeholders have asserted that section 501(b) of ANILCA prohibits 

the Forest Service from recommending any areas within the Copper River 

Delta for designation as wilderness because such a designation would 

prohibit the Forest Service from undertaking certain actions to 

conserve fish and wildlife. These stakeholders have also asserted that 

proposed wilderness designation would hinder future oil and gas 

development near the town of Katalla. However, others who support 

preserving the forest’s lands and resources argued that some of the 

land management prescriptions in the draft plan would violate section 

501(b) by failing to prohibit activities that conflict with the area’s 

purpose of conserving fish and wildlife, such as mining, road 

construction, and off-road vehicle use, among others.



The revised plan does not recommend any areas for wilderness 

designation within the Copper River Delta. The Record of Decision 

states that each of the three management prescriptions applied to the 

Delta have fish and wildlife conservation as their primary goal. 

According to the ROD, each prescription provides for a different mix of 

multiple use activities consistent with the conservation of fish and 

wildlife and their habitat.



[End of section]



FOOTNOTES



[1] A “board foot” is a unit of measurement of timber equaling the 

amount of wood contained in a finished board 1 inch thick, 12 inches 

long, and 12 inches wide.



[2] See app. I of U.S. General Accounting Office, Forest Service 

Decision-Making: A Framework for Improving Performance, GAO/

RCED-97-71, Washington, D.C.: April 29, 1997, for a more detailed 

discussion of the agency’s planning process.



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