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Testimony: 

Before the Subcommittee on Interior, Environment, and Related Agencies, 
Committee on Appropriations, House of Representatives: 

United States Government Accountability Office: 
GAO: 

For Release on Delivery: 
Expected at 9:30 a.m. EST: 
Tuesday, February 24, 2009: 

Federal Land Management: 

Potential Effects and Factors to Consider in a Move of the Forest 
Service into the Department of the Interior: 

Statement of Robin M. Nazzaro, Director: 
Natural Resources and Environment: 

GAO-09-412T: 

GAO Highlights: 

Highlights of GAO-09-412T, a testimony to the Subcommittee on Interior, 
Environment, and Related Agencies, Committee on Appropriations, House 
of Representatives. 

Why GAO Did This Study: 

The Department of Agriculture’s (USDA) Forest Service, which manages 
almost a quarter of the nation’s lands, is the only major land 
management agency outside the Department of the Interior (Interior). 
Four federal land management agencies—the Forest Service and the Bureau 
of Land Management (BLM), Fish and Wildlife Service, and National Park 
Service in Interior—manage most of the 680 million acres of federal 
land across the country. Growing ecological challenges, ranging from 
wildland fires to climate change, have revived interest in moving the 
Forest Service into 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 BLM. GAO was also asked to identify factors that 
should be considered if such a move were legislated, as well as 
management practices that could facilitate a move. This testimony is 
based on GAO’s report, Federal Land Management: Observations on a 
Possible Move of the Forest Service into the Department of the Interior 
(GAO-09-223), released today. 

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. 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. 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. 
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. 

If the Forest Service were moved into Interior, USDA and Interior 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. For example, integrating the Forest Service’s reporting, 
budgeting, and human capital processes and systems into Interior’s 
could be time-consuming, costly, and disruptive. Nevertheless, Interior 
and USDA could implement some key merger and transformation practices 
to help manage any resulting disruptions and other transition costs. 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. 

Figure: Federal Lands in the Contiguous United States: 

[Refer to PDF for image] 

This figure is a map of the continental United States with shading 
indicating federal lands in two categories: 
Forest Service; 
Department of the Interior. 

Source: GAO analysis of U.S. Geological Survey's National Atlas Web 
site data. 

[End of figure] 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-412T]. For more 
information, contact Robin M. Nazzaro at (202) 512-3841 or 
nazzaror@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss a possible move of the Forest 
Service from the Department of Agriculture (USDA) into the Department 
of the Interior (Interior). The Forest Service, which manages almost a 
quarter of the nation's lands, is the only major land management agency 
outside Interior. Four federal land management agencies--USDA's Forest 
Service and Interior's Bureau of Land Management (BLM), Fish and 
Wildlife Service, and National Park Service--manage most of the 680 
million acres of federal land across the country. Recognizing that 
federal land management agencies have faced many similar challenges but 
lacked unifying statutory authorities for the management and use of 
federal lands and resources, policymakers over the last 4 decades have 
made several unsuccessful attempts to reorganize the nation's land and 
resource agencies. The emergence of new challenges for both the Forest 
Service and Interior during a time of severe economic crisis, as well 
as the growing need for agencies to collaborate on urgent large-scale 
natural resource problems, has revived interest in the potential for 
improving federal land management. 

My testimony today summarizes the findings of our recent report 
discussing a potential move of the Forest Service into Interior. This 
move would entail 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 a new bureau 
equivalent to Interior's other bureaus. Specifically, I will discuss 
how federal land management would potentially be affected by moving the 
Forest Service into Interior and what factors should be considered if 
Congress and the administration were to decide to move the Forest 
Service and what management practices could facilitate such a move. 
[Footnote 1] This report is based on our analysis of historical 
proposals on reorganizing federal land management agencies, interviews 
with agency officials and experts, visits to Forest Service and BLM 
offices that are colocated and comanaged, and interviews with 
representatives from groups that have an interest in the agencies. 

Background: 

As a result of their historical development, four distinct land 
management agencies, each operating under unique authorities, today 
oversee more than 630 million acres of federal land.[Footnote 2] 
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. 

Over the past several decades, both the Forest Service and Interior's 
bureaus--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. 
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 problems that cross agency and 
ownership boundaries such as wildland fire, invasive species, and 
development of private lands along their borders. 

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: 

A move of the Forest Service into Interior could improve federal land 
management by aligning the federal land management mission under one 
department and increasing program effectiveness. It may also yield long-
term, but few short-term, efficiencies. 

Although a Move Would Align Federal Land Management Missions, It Could 
Diminish the Forest Service's State-and Private-Lands Mission: 

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. The Forest Service and 
BLM both manage their lands for multiple uses, including timber, 
grazing, oil and gas, recreation, wilderness, and fish and wildlife, 
although they emphasize different uses depending on their specific 
authorities and public demands. 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] 

According to many of the experts and officials we interviewed, however, 
a move of the Forest Service into Interior could diminish the role that 
the agency plays in managing state and private forestlands--a mission 
focus the Forest Service shares with USDA but does not have in common 
with Interior. 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. 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. According to some officials and state 
foresters, 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. Other officials said, 
however, 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. 

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. 

Source: U.S. Geological Survey's National Atlas Web site. 

[End of figure] 

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: 

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. For example, a possible 
outcome of having the land management agencies together in one 
department could be the improvement of land management across 
jurisdictional boundaries. Program areas that offer opportunities for 
improved coordination include law enforcement, recreation, and 
wilderness management. 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 in such areas as timber, 
grazing, oil and gas, appeals, and mapping. 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. While many of the officials and experts we interviewed 
believed a move would improve effectiveness, many did not believe that 
many 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. Still, a number of them 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 officials and experts, existing efforts to 
integrate programs demonstrate improved program effectiveness and 
public service but few efficiencies in the short term. For example, 
parts of the Forest Service, BLM, Fish and Wildlife Service, National 
Park Service, and Interior's Bureau of Indian Affairs have been 
colocated 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. Despite this coordination, the agencies still 
have key differences that hinder management effectiveness and 
efficiency; such differences include incompatible information 
technology and other business operations and systems. Service First 
offices have also integrated a number of programs that have helped 
improve the effectiveness, and perhaps efficiency, of land management 
and public service. Under the Service First program begun in 1996, the 
Forest Service, BLM, Fish and Wildlife Service, and National Park 
Service can use one another's authorities, duties, and responsibilities 
to conduct joint or integrated programs or business operations to 
improve the agencies' customer service, operational efficiency, and 
land management.[Footnote 3] For example, a Service First office in 
Durango, Colorado, has both Forest Service and BLM staff working 
jointly to manage recreation activities, grazing allotments, oil and 
gas exploration and production, and other resources to increase the 
effectiveness of land management. 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 Service First 
offices have integrated aspects of their programs, the offices have to 
maintain two separate computer systems, one for the Forest Service and 
the second for BLM. 

Many agency officials and experts we interviewed suggested that if the 
objective of a move is to improve federal 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. These officials and experts raised a 
range of other options, such as increasing collaboration and 
coordination, moving BLM to USDA, and creating a new department of 
natural resources. In addition to these options, a number of officials 
and experts believed 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 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. 

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, Interior and 
USDA could implement some key merger and transformation practices to 
help manage any resulting disruptions and other transition costs. 

Given Cultural, Organizational, and Legal Factors, a Move Could Lead to 
Disruptions and Other Transition Costs: 

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 is moved into 
Interior. The agencies' cultures stem in large part from their 
histories and have also developed as a result of each agency's level of 
autonomy within USDA or Interior. A number of officials said that the 
Forest Service has a fair degree of independence within USDA. For 
example, some agency officials said that the Forest Service budget does 
not receive as much attention or scrutiny as other USDA agency budgets. 
Because of cultural differences, many officials and experts believed 
that moving the Forest Service into Interior could lead to decreased 
morale and productivity. 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, while a move may 
leave Interior employees feeling threatened, worrying that because of 
its size, the Forest Service would dominate Interior; they too may 
resist a move.[Footnote 4] According to many officials and experts, the 
agencies may also 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. 

The consolidation of Interior's National Biological Service into the 
United States Geological Survey (USGS) offers one illustration of 
possible cultural implications of moving the Forest Service into 
Interior. The National Biological Service was created in 1993[Footnote 
5] to gather, analyze, and disseminate biological information necessary 
for the sound stewardship of the nation's natural resources. In 1996, 
the agency was merged into USGS. 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. According to this official, the transition into USGS 
took 4 to 5 years, and more than a decade afterward, some employees 
still question the move. We previously reported that 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 6] 

Organizational factors could also complicate a transition, including 
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. 
USDA and Interior are both cabinet-level departments organized under 
politically appointed Secretaries and Deputy Secretaries, but the 
organizational structures of the departments differ at the next levels. 
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. 

Effects on Interior functions and the need to integrate systems would 
also complicate a move. Adding about 29,000 Forest Service employees to 
Interior would likely increase the workload at the departmental level 
and strain shared departmental resources. Furthermore, integrating the 
Forest Service's reporting, budgeting, acquisition, and other processes 
and systems into Interior's would be difficult, time-consuming, and 
costly, according to many experts and officials. 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 7] Some officials believed, 
however, that the timing is opportune to move the Forest Service 
because Interior and USDA are both moving to new financial management 
systems and the agency could be merged into Interior's new financial 
system without further investment in USDA's system. In contrast, other 
officials said 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. 

The Forest Service is the largest agency in USDA in terms of employees, 
and many agency officials and experts noted that moving would affect 
not only Interior but USDA and its other agencies. For example, the 
Forest Service pays a large share of USDA's overhead charges; 
therefore, a move would affect these expenses and economies of scale 
within the department. Further, moving the Forest Service out of USDA 
could affect its relationship with the Natural Resources Conservation 
Service (NRCS) and other agencies in the department. The Forest Service 
and NRCS coordinate providing technical assistance to private foresters 
and other land conservation activities. The Forest Service also works 
with other agencies in USDA, including the Animal and Plant Health 
Inspection Service. 

Legal issues would also need to be resolved if a move were to take 
place. 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 these laws should be examined and may need to be reconciled if a 
move took place. Even in areas in which the Forest Service and Interior 
agencies operate under the same laws, they have sometimes received 
different legal opinions from USDA's Office of General Counsel and 
Interior's Office of the Solicitor. 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. The authorizing legislation would need to allow 
Interior flexibility and time to change and deal with these details, 
one expert said. 

Additional legal factors needing consideration include tribal issues, 
congressional committee jurisdiction, and interest groups. In some 
cases, treaties with Native American tribes have assured tribal 
governments certain "reserved rights"--such as rights for grazing, 
hunting, fishing, trapping, and water--on former tribal land now part 
of present-day 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. 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. While 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. 

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,[Footnote 8] and the experts and officials we 
interviewed mentioned several of them. For example, one key practice is 
to ensure that top leadership drives the transformation. 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. We also 
reported in the past that a move must be closely managed with 
implementation goals and a timeline and that creating an effective 
strategy for continual communication is essential. Some officials said 
that agency leaders would need to communicate extensively with 
stakeholders and agency employees if the Forest Service is to be moved, 
which could put some employees at ease and mitigate disruptions from 
decreased morale and productivity. 

Concluding Observations: 

A move of the Forest Service into Interior would be no small 
undertaking. Organizational transformations are inevitably complex, 
involving many factors and often creating unintended consequences. 
Further, these transformations can take many years to achieve. 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. 
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. If a move were undertaken, adequate time and 
attention would need to be devoted to planning for and implementing key 
merger and transformation 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 these key practices. 

Mr. Chairman, this concludes my prepared statement. I would be pleased 
to answer any questions that you or other Members of the Subcommittee 
may have at this time. 

GAO Contact and Staff Acknowledgments: 

For further information about this testimony, please contact me at 
(202) 512-3841 or at nazzaror@gao.gov. Contact points for our Offices 
of Public Affairs and Congressional Relations may be found on the last 
page of this report. Ulana Bihun, David P. Bixler, 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 statement. 

[End of section] 

Footnotes: 

[1] GAO, Federal Land Management: Observations on a Possible Move of 
the Forest Service into the Department of the Interior, [hyperlink, 
http://www.gao.gov/products/GAO-09-223] (Washington, D.C.: Feb. 11, 
2009). 

[2] The remaining federal lands are managed by other federal agencies, 
including the Department of Defense, Department of Energy, and Bureau 
of Reclamation. 

[3] 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). 

[4] Currently, the Forest Service has about 29,000 permanent employees 
compared with a total of about 54,000 permanent employees in Interior, 
whose largest agency is the National Park Service, with about 16,000 
permanent employees. 

[5] The agency was originally named the National Biological Survey but 
was renamed the National Biological Service in 1995. 

[6] 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). 

[7] According to officials, costs to plan and acquire shared USDA 
systems totaled almost $180 million through fiscal year 2008. 

[8] [hyperlink, http://www.gao.gov/products/GAO-03-669]. 

[End of section] 

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