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the Forest Service into the Department of the Interior' which was 
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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] 

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