This is the accessible text file for GAO report number GAO-09-277 
entitled 'Federal Land Management: Additional Documentation of Agency 
Experiences with Good Neighbor Authority Could Enhance Its Future Use' 
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Report to the Chairman, Committee on Energy and Natural Resources, U.S. 
Senate: 

United States Government Accountability Office: 
GAO: 

February 2009: 

Federal Land Management: 

Additional Documentation of Agency Experiences with Good Neighbor 
Authority Could Enhance Its Future Use: 

Good Neighbor Authority: 

GAO-09-277: 

GAO Highlights: 

Highlights of GAO-09-277, a report to the Chairman, Committee on Energy 
and Natural Resources, U.S. Senate. 

Why GAO Did This Study: 

In 2000, Congress authorized the U.S. Department of Agriculture’s 
Forest Service to allow the Colorado State Forest Service to conduct 
certain activities, such as reducing hazardous vegetation, on U.S. 
Forest Service land when performing similar activities on adjacent 
state or private land. The Department of the Interior’s Bureau of Land 
Management (BLM) received similar “Good Neighbor” authority in 2004, as 
did the U.S. Forest Service in Utah. Congress has also considered the 
authority’s expansion to other states. GAO was asked to determine (1) 
the activities conducted under the authority; 
(2) the federal and state guidance, procedures, and controls used to 
conduct Good Neighbor projects; and (3) successes, challenges, and 
lessons learned resulting from the authority’s use. To do so, GAO 
reviewed Good Neighbor project documentation and interviewed federal 
and state officials. 

What GAO Found: 

Fifty-three projects were conducted under Good Neighbor authority 
through fiscal year 2008, including 38 in Colorado and 15 in Utah, with 
most of the projects (44 of 53) conducted on U.S. Forest Service land. 
These projects included hazardous fuel reduction on about 2,700 acres 
of national forest and about 100 acres of BLM land, mostly in Colorado, 
and the repair of fire-damaged trails and watershed protection and 
restoration in Utah. Together, the two agencies spent about $1.4 
million on these projects, split almost evenly between the two states. 
Although most projects involved contracting for services such as fuel 
reduction, some projects involved timber sales in which contractors 
purchased timber resulting from their fuel reduction activities. These 
timber sales occurred only in Colorado and totaled about $26,000. 

State procedures are used in conducting Good Neighbor projects that 
involve service contracts, while projects that include timber sales 
incorporate both state and federal requirements. Both Colorado and Utah 
have contracting requirements that generally address three fundamental 
principles of government contracting—transparency, competition, and 
oversight. For example, both states solicit competition among bidders 
and generally require service contracts to be awarded to the lowest-
priced bidder meeting the contract criteria. State requirements were 
generally comparable to federal procurement requirements. When Good 
Neighbor projects involve timber sales, state procedures incorporate 
certain requirements that help the U.S. Forest Service account for 
state removal of federal timber. The U.S. Forest Service and Colorado 
are currently supplementing their joint Good Neighbor procedures to 
ensure that additional accountability provisions are included in future 
timber sale contracts. Neither BLM in Colorado nor the U.S. Forest 
Service in Utah has developed written procedures for conducting Good 
Neighbor timber sales, primarily because they have not sold timber 
under the authority. Such procedures could help ensure accountability 
for federal timber if future projects include such sales. 

Federal and state officials who have used Good Neighbor authority cited 
project efficiencies and enhanced federal-state cooperation as its key 
benefits. For example, the agencies cited their ability to improve the 
effectiveness of fuel reduction treatments in areas that include 
federal, state, and private ownership. Federal and state agencies have 
also encountered challenges such as a lack of understanding of the 
authority and complicated processes for approving Good Neighbor 
agreements. Agency officials and others also noted several factors to 
consider when conducting future Good Neighbor projects, whether in 
Colorado, Utah, or other states that may be granted the 
authority—including the type of projects to be conducted and the type 
of land to be treated. While the agencies are not required to document 
their experiences in using the authority, officials contemplating 
future use of the authority could benefit from such 
documentation—including information on successes, challenges, and 
lessons learned to date. 

What GAO Recommends: 

GAO recommends that the Secretaries of Agriculture and the Interior (1) 
require that the U.S. Forest Service in Utah, BLM in Colorado, and any 
agencies that receive the authority in other states, develop written 
procedures for Good Neighbor timber sales before conducting any future 
sales and (2) direct the agencies to better document their experiences 
using the authority. The U.S. Forest Service, Interior, and the 
Colorado and Utah forest agencies generally agreed with the report’s 
findings and recommendations. 

To view the full product, including the scope
and methodology, click on [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-09-277].
For more information, contact Robin Nazzaro at (202) 512-3841 or 
nazzaror@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Fifty-three Good Neighbor Projects Have Been Conducted in Colorado and 
Utah for Fuel Reduction and Other Purposes: 

Good Neighbor Projects Are Generally Governed by State Procedures, but 
Projects Involving Timber Sales Also Incorporate Certain Federal 
Requirements: 

Experiences with Good Neighbor Authority to Date Could, If Better 
Documented, Provide Insight for Potential Expansion of Its Use: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the U.S. Department of Agriculture's Forest 
Service: 

Appendix III: Comments from the Department of the Interior: 

Appendix IV: Comments from the Colorado State Forest Service: 

Appendix V: Comments from the Utah Division of Forestry, Fire and State 
Lands: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Figures: 

Figure 1: Good Neighbor Projects in Colorado, by National Forest and 
BLM Area: 

Figure 2: Completed Fuel Reduction Project in Pike National Forest with 
Slash Piled for Burning: 

Figure 3: Good Neighbor Projects in Utah, by National Forest: 

Figure 4: Barrier Rocks Placed along Dixie National Forest Roadway to 
Prevent Off-road Vehicle Use: 

Figure 5: Fuel Reduction Project Site in National Forest Area Bordering 
Private Subdivision: 

Abbreviations: 

BLM: Bureau of Land Management: 

CSFS: Colorado State Forest Service: 

CSU: Colorado State University: 

FAR: Federal Acquisition Regulation: 

NEPA: National Environmental Policy Act: 

UDFFSL: Utah Division of Forestry, Fire and State Lands: 

[End of section] 

United States Government Accountability Office: 

Washington, DC 20548: 

February 25, 2009: 

The Honorable Jeff Bingaman: 
Chairman: 
Committee on Energy and Natural Resources: 
United States Senate: 

Dear Mr. Chairman: 

The state of our nation's forests is of increasing concern, as many 
forests, whether in federal, state, or other ownership, have become 
densely stocked with trees and damaged by insects--two conditions that 
can increase the risk of severe wildland fires. In some cases, forests 
at high risk of fire span federal, state, and private land, making it 
difficult for a single entity to gain access to and address all areas 
needing protective or restorative treatment, such as reducing 
vegetation that can fuel wildland fires. Treating certain areas while 
leaving adjacent areas untreated may undermine the effectiveness of 
overall efforts--a problem that is particularly significant in Colorado 
and other western states undergoing increasing human development in or 
near wildlands, because these areas of wildland-urban interface often 
involve multiple landowners. In 1998, the U.S. Department of 
Agriculture's Forest Service and the Colorado State Forest Service 
(CSFS) began investigating ways to address this issue. As a result, in 
2000 Congress authorized the U.S. Forest Service to undertake a pilot 
program referred to as "Good Neighbor." This legislation authorizes the 
U.S. Forest Service to permit CSFS to conduct certain watershed 
restoration activities--such as reducing hazardous fuel to prevent 
wildland fires, addressing insect outbreaks, and improving drainage to 
prevent sediment from eroding into forest watersheds--on U.S. Forest 
Service land when conducting similar activities on adjacent state or 
private land.[Footnote 1] Under the act, the state may in some 
circumstances act as an agent of the federal government to conduct 
these projects. Although the projects are conducted by the state, 
projects on federal land remain subject to the provisions of the 
National Environmental Policy Act (NEPA),[Footnote 2] which requires 
federal agencies to consider any significant environmental impacts that 
may result from their actions. 

Initially, Good Neighbor authority was slated to expire at the end of 
fiscal year 2004, but Congress passed legislation that year extending 
the authority until the end of fiscal year 2009.[Footnote 3] The 2004 
legislation also expanded Good Neighbor authority to include lands in 
Colorado managed by the Department of the Interior's Bureau of Land 
Management (BLM); this authority also expires in 2009. The same 
legislation also established similar Good Neighbor authority concerning 
U.S. Forest Service land in Utah, but did not require the state to 
conduct similar work on adjacent state or private land; U.S. Forest 
Service authority in Utah expired at the end of fiscal year 2008. 

As Good Neighbor authority nears its expiration in Colorado and awaits 
reauthorization in Utah, Congress has considered potential expansion of 
the authority to other states. Legislation was introduced in the 110th 
Congress that would expand this authority to include U.S. Forest 
Service land in Wyoming,[Footnote 4] or to include all U.S. Forest 
Service and BLM land in the western United States.[Footnote 5] In this 
context, you asked us to determine (1) the activities conducted under 
Good Neighbor authority, including the number, type, and scope of 
projects undertaken; (2) the federal and state guidance, procedures, 
and controls being used to conduct Good Neighbor projects, including 
contracting requirements and timber sale procedures; and (3) the 
successes, challenges, or lessons learned, if any, that have resulted 
from the use of Good Neighbor authority. 

To determine the activities conducted under Good Neighbor authority in 
Colorado and Utah, we reviewed and analyzed documentation from the U.S. 
Forest Service; BLM; CSFS; and the Utah Division of Forestry, Fire and 
State Lands (UDFFSL). We also visited several completed or ongoing Good 
Neighbor project sites in both Colorado and Utah and interviewed 
federal and state officials to obtain an understanding of the type and 
scope of work being conducted under the authority. To determine the 
federal and state guidance, procedures, and controls used to conduct 
projects under Good Neighbor authority, we reviewed project operating 
procedures, federal and state procurement requirements, and federal and 
state timber sale requirements, comparing the requirements in several 
areas to identify similarities and differences. Finally, to determine 
the successes, challenges, and lessons learned resulting from the use 
of Good Neighbor authority, we interviewed federal and state officials 
involved with the authority's use in Colorado and Utah and discussed 
the potential uses of Good Neighbor authority with state officials in 
Idaho, Oregon, and Wyoming. We also spoke with other interested 
parties, including environmental groups and industry representatives 
based in Colorado, Utah, other western states, and Washington, D.C. 
Appendix I contains more detailed information on the objectives, scope, 
and methodology of our review. We conducted this performance audit from 
June 2008 through February 2009 in accordance with generally accepted 
government auditing standards. Those standards require that we plan and 
perform the audit to obtain sufficient, appropriate evidence to provide 
a reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 

Results in Brief: 

Fifty-three projects have been conducted under Good Neighbor authority 
as of the end of fiscal year 2008, including 38 in Colorado and 15 in 
Utah, with most of the projects (44 of 53) conducted on U.S. Forest 
Service land. These projects included fuel reduction on about 2,700 
acres of national forest and about 100 acres of BLM land, mostly in the 
Colorado wildland-urban interface, and the repair of fire-damaged 
trails and watershed protection and restoration in Utah. Together, the 
two agencies spent about $1.4 million on these projects, split almost 
evenly between the two states. Although most projects involved paying 
contractors for services such as fuel reduction (i.e., service 
contracts), some projects involved timber sales in which, for example, 
contractors purchased timber resulting from their fuel reduction 
activities. Such timber sales amounted to about $26,000. The specific 
purpose for using Good Neighbor authority to conduct projects varied. 
For example, under Good Neighbor authority, Colorado contracted with a 
single vendor to carry out fuel reduction activities across multiple 
tracts of land with fragmented federal, state, and private land 
ownership, to avoid leaving pockets of untreated forest in the project 
area. 

Both federal and state guidance, procedures, and controls are used in 
conducting Good Neighbor projects; state procedures are used in 
conducting projects that involve service contracts, while projects that 
include timber sales incorporate both federal and state requirements. 
For all Good Neighbor projects, the U.S. Forest Service and BLM are 
responsible for ensuring compliance with NEPA. For those projects 
involving service contracts, a master agreement with each state allows 
Colorado and Utah to use state procedures to enter into contracts with 
vendors that provide services such as fuel reduction. We examined both 
states' contracting requirements concerning three fundamental 
principles of government contracting----transparency, competition, and 
oversight--and found that state requirements generally address each of 
these areas. For example, we found that both states solicit competition 
among bidders, give potential contractors reasonable amounts of time to 
prepare bids, and generally require service contracts to be awarded to 
the lowest-priced bidder meeting the contract criteria. We also found 
state requirements to be generally comparable to federal procurement 
requirements in specific areas that we examined. When Good Neighbor 
projects involve timber sales, state procedures incorporate certain 
requirements that help the U.S. Forest Service account for state 
removal of federal timber. For example, Good Neighbor project 
procedures developed jointly by the U.S. Forest Service and CSFS direct 
state foresters to work with U.S. Forest Service officials to appraise 
the value of timber on the project site and determine the minimum bid 
price. However, we found that the provisions in standard U.S. Forest 
Service timber sale contracts are typically more extensive than those 
in timber sales administered by CSFS under Good Neighbor authority. For 
example, initial Good Neighbor timber sale contracts administered by 
CSFS did not include certain elements--such as provisions requiring the 
contractor to address aspects of road maintenance, or information about 
whether there were threatened and endangered species in the project 
area--that are part of U.S. Forest Service contracts. The U.S. Forest 
Service and CSFS developed more detailed Good Neighbor procedures to 
ensure that these types of provisions are included in future Good 
Neighbor timber sale contracts administered by Colorado, and are 
supplementing these procedures to strengthen timber accountability. We 
did not compare Colorado's timber sale requirements with those of BLM, 
or Utah's requirements with those of the U.S. Forest Service, because 
neither BLM in Colorado nor the U.S. Forest Service in Utah has 
conducted timber sales under Good Neighbor authority to date. Neither 
BLM in Colorado nor the U.S. Forest Service in Utah has developed 
written procedures for conducting Good Neighbor projects involving 
timber sales; such procedures could help ensure accountability for 
federal timber if future Good Neighbor projects on the part of these 
agencies involve the sale of such timber. 

Experiences with Good Neighbor authority in Colorado and Utah may 
provide insights for the authority's potential expansion in those 
states and others, although the agencies can enhance the usefulness of 
these insights by systematically documenting their experiences in using 
the authority. Federal and state officials who have used Good Neighbor 
authority cited project efficiencies and enhanced federal-state 
cooperation as its key benefits. For example, the agencies cited their 
ability to begin projects more quickly; work on federal lands that are 
otherwise difficult to access because they are surrounded by private 
property; and improve the effectiveness of fuel reduction treatments in 
areas that include federal, state, and private ownership. On the other 
hand, federal and state agencies have encountered some challenges in 
using the authority, such as a lack of understanding of the authority, 
which has complicated partnerships between federal and state officials. 
In addition, some U.S. Forest Service officials in Colorado considered 
state timber sale procedures to be insufficient to protect federal 
interests and have imposed additional requirements on the state before 
agreeing to Good Neighbor projects. Conversely, some state officials 
have found the overlay of federal requirements burdensome, making them 
less likely to participate in Good Neighbor projects. Federal, state, 
and other stakeholders identified several factors to consider when 
conducting future Good Neighbor projects. For example, to ensure the 
support of the public and environmental groups, some suggested that 
projects be undertaken only in the wildland-urban interface, where the 
potential public benefit is the greatest. Moreover, several 
stakeholders noted that, while it is important to understand the 
experiences using Good Neighbor authority in Colorado and Utah when 
considering its expansion to other states, it is likewise important to 
account for differences among states as well. Stakeholders told us that 
differences in the structure, staffing levels, and workload of other 
state forest services, and the characteristics of federal lands in 
various states--particularly the value of timber on these lands--would 
all affect the authority's chances for success in other states and, 
thus, are important factors to consider when evaluating its potential 
expansion. Consequently, agency officials contemplating future use of 
the authority--whether in Colorado, Utah, or other states--would 
benefit from documentation of agency experiences in using the authority 
to date. Such documentation could include, for example, an analysis of 
cost savings or other efficiencies that have been achieved through its 
use, and a discussion of the types of projects in which Good Neighbor 
authority has been most successful. Without such information, agency 
officials will need to independently assess which projects would best 
be conducted using the authority, including the extent to which 
individual projects might reduce costs or lead to other efficiencies--
an inefficient approach that could reduce the potential value of Good 
Neighbor authority. 

To enhance the U.S. Forest Service and BLM's use of Good Neighbor 
authority, we are recommending that they (1) develop written procedures 
for Good Neighbor timber sales before conducting these sales in areas 
where such procedures do not already exist and (2) document how prior 
experiences with Good Neighbor projects offer lessons for the future, 
and make this information available to current and prospective users of 
the authority. In commenting on a draft of this report, the U.S. Forest 
Service, the Department of the Interior, CSFS, and UDFFSL generally 
agreed with its findings and recommendations. However, we are concerned 
that the actions the U.S. Forest Service intends to take in addressing 
our recommendation to better document agency experiences with Good 
Neighbor authority will not meet the intent of that recommendation, and 
we have noted this concern in our response to the agency's letter. 
Comments from the U.S. Forest Service (along with our response to those 
comments), the Department of the Interior, CSFS, and UDFFSL are 
reprinted in appendixes II, III, IV, and V, respectively. 

Background: 

Although its effect on communities can be devastating, wildland fire is 
a natural and necessary process that provides many benefits to 
ecosystems, such as maintaining habitat diversity, recycling soil 
nutrients, limiting the spread of insects and disease, and promoting 
new growth by causing the seeds of fire-dependent species to germinate. 
Wildland fire also periodically removes brush, small trees, and other 
vegetation that can otherwise accumulate and increase the size, 
intensity, and duration of subsequent fires. Wildland fire occurs in 
various combinations of frequency and severity, from low-severity 
events that return every few decades to high-severity fires that occur 
once every 200 years or more. Over the past century, however, various 
management practices--including fire suppression, grazing, and timber 
harvest--have reduced the normal frequency of fires in many forest and 
rangeland ecosystems and contributed to abnormally dense, continuous 
accumulations of vegetation, which can fuel uncharacteristically large 
or severe wildland fires. The impacts of these fires have intensified 
as more and more communities develop in areas that are adjacent to 
fire-prone lands--the wildland-urban interface. Federal researchers 
have estimated that unnaturally dense fuel accumulations on 90 million 
to 200 million acres of federal lands in the contiguous United States 
place these lands at an elevated risk of severe wildland fire. 

The rapid urbanization of forested land in Colorado and Utah has raised 
concerns about the unhealthy condition of forests in those states and 
the potential for resulting wildland fires. These forests also have 
undergone insect and disease attacks of epidemic proportions, further 
weakening them and contributing to the abundance of fuels for wildland 
fires. For example, the mountain pine beetle epidemic now affecting the 
southern Rocky Mountains and other western areas has produced vast 
areas of dead and dying lodgepole pine forests in Colorado and Wyoming. 
In recent years, wildland fires in Colorado and Utah have increasingly 
threatened communities in the interface as well as watersheds (i.e., 
areas that are drained by rivers or other waterways) that provide water 
to populated areas in or near forests. 

The U.S. Forest Service and BLM are the primary federal agencies 
responsible for wildland fire management--together, they oversee about 
450 million acres of forest and rangeland.[Footnote 6] These agencies 
take various steps to reduce hazardous fuels (fuel reduction) on 
wildlands, including mechanical treatments that use equipment to cut 
vegetation back to desired levels (thinning), planned low-level fires 
that burn small trees and underbrush (prescribed fire), herbicides that 
kill unwanted vegetation, animal grazing, or combined treatments that 
comprise one or more of these methods. Through these efforts, the 
agencies attempt to restore forest and rangeland ecosystems to their 
historical conditions and reduce the risk of severe wildland fires. 
Like their federal counterparts, some state forest services also have 
an important role in community fire prevention. Such agencies maintain 
crews that suppress wildland fires, conduct forest thinning and 
prescribed burns, advise local landowners on ways to build fire-
resistant structures, and direct homeowners to local contractors who 
provide fuel reduction services. They also assist in the development of 
community wildland fire protection plans that set priorities for fuel 
reduction treatments and recommend specific strategies to reduce fire 
risk on public and private land.[Footnote 7] 

In addition to efforts to reduce the risk that wildland fires will 
occur, federal and state agencies take other steps to mitigate the 
impact of wildland fires. These steps include projects to stabilize 
damaged areas and rehabilitate them more quickly than would occur under 
natural conditions. Such projects involve activities such as planting 
native grasses, shrubs, and trees; protecting waterways from erosion 
that could introduce sediment into municipal water supplies; and 
restoring habitat for local fish and wildlife populations. 

Attempts at widespread fuel reduction and postfire rehabilitation in 
the wildland-urban interface can be frustrated by the diverse mixture 
of property ownership typically found in this region. A single forest 
area may contain tracts of land that are publicly owned, such as 
national forests and state parklands, as well as tracts that are 
controlled by a multitude of private owners. This mixed-ownership 
setting creates the potential for individual pockets of untreated land 
to exist within a project area if some property owners do not want to 
join the effort. For example, U.S. Forest Service efforts to treat 
national forest land may be impeded if access to these areas is 
dependent upon consent from private property owners. Access to national 
forest land may also be limited if the project site falls within an 
area where road construction is restricted. In such instances, areas 
left untreated can diminish the effectiveness of the overall project. 
Even if the U.S. Forest Service wanted to join the project, a separate 
contract with the vendor--containing separate requirements for contract 
performance--would typically be necessary. 

Beginning in 1998, the U.S. Forest Service and CSFS began exploring 
ways to manage land across ownership boundaries, particularly in 
wildland-urban interface areas. The two forest services agreed that 
management activities such as fuel reduction should be undertaken only 
where community interest and support exists, and, thus, these 
activities would be driven largely by state, local, and private 
projects. To facilitate this work, they determined that it would be 
useful for Colorado state foresters to serve as agents of the U.S. 
Forest Service for the purpose of conducting projects on federal lands 
immediately adjacent to state, local, or private lands where similar 
work was under way. Colorado's foresters would be authorized to mark 
boundaries, designate trees for removal, and administer other project 
activities--including sales of designated trees in the project area--to 
reduce fuel risk on federal lands as a complement to similar activities 
on adjacent lands. Because of the collaborative nature of these 
projects, the proposed program became known as "Good Neighbor." 

In the Department of the Interior and Related Agencies Appropriations 
Act, 2001, Congress established the program, authorizing the U.S. 
Forest Service to allow its state counterpart in Colorado to perform 
forest, rangeland, and watershed restoration services, such as fuel 
reduction or treatment of insect-infected trees, on national forest 
lands. The services provided by the state, either directly or through 
contracts with private vendors utilizing state contracting procedures, 
were permitted when similar and complementary activities were being 
performed on adjacent state or private lands. According to the 
subsequent agreement signed by representatives of the two forest 
services, the following benefits were anticipated from Good Neighbor 
authority: 

* national forest, state, and private lands would be at less risk from 
catastrophic wildland fire; 

* fuel treatments would provide defensible space for firefighters to 
occupy while combating fires moving from forests to developed areas, or 
vice versa; 

* an impediment to cross-boundary watershed restoration activities 
would be removed, resulting in greater protective and restorative 
accomplishments; and: 

* CSFS and the U.S. Forest Service would demonstrate cooperation as 
encouraged in the National Fire Plan, the federal government's wildland 
fire management strategy.[Footnote 8] 

Congressional reauthorization of Good Neighbor authority in 2004 added 
BLM areas in Colorado to the authority's scope. In addition, the 2004 
legislation authorized the U.S. Forest Service to work with Utah's 
forest service to perform similar watershed restoration and protection 
projects in Utah. Unlike the authorizing legislation for Colorado, 
however, there was no provision in the authorizing legislation for Utah 
requiring Good Neighbor projects to correspond to similar and 
complementary activities under way on adjacent state or private lands. 

The U.S. Forest Service manages 11 national forests in Colorado, within 
the agency's Rocky Mountain Region, and manages 7 national forests in 
Utah, within the Intermountain Region.[Footnote 9] Each national forest 
is divided into ranger districts that conduct or oversee "on-the-
ground" activities. BLM lands in Colorado are managed by the Colorado 
State Office, which in turn oversees BLM field offices across the 
state. CSFS administers 17 districts throughout the state, each led by 
a district forester. UDFFSL, a unit of the state's Department of 
Natural Resources, is divided into six areas, each administered by an 
area manager.[Footnote 10] 

Fifty-three Good Neighbor Projects Have Been Conducted in Colorado and 
Utah for Fuel Reduction and Other Purposes: 

Under Good Neighbor authority, 53 projects have been conducted in 
Colorado and Utah as of the end of fiscal year 2008 at a cost to the 
federal government of about $1.4 million. Colorado Good Neighbor 
projects focused on fuel reduction activities, such as tree thinning, 
mostly in the Colorado wildland-urban interface. In Utah, Good Neighbor 
projects focused on the repair of fire-damaged trails and watershed 
protection and restoration. 

Colorado Good Neighbor Projects Focused on Fuel Reduction: 

In Colorado, 38 projects were conducted under Good Neighbor authority 
from fiscal year 2002, after the authority was granted, through fiscal 
year 2008. These projects primarily focused on fuel reduction. CSFS 
planned these projects in conjunction with the U.S. Forest Service or 
BLM, as well as private owners, and then contracted with private 
vendors or state crews to perform the work on U.S. Forest Service or 
BLM land. Of these 38 projects, 29 were on U.S. Forest Service land. 
These 29 projects included fuel reduction treatment on about 2,400 
acres in 5 of the 11 national forests in the state--the Arapaho, Pike, 
Roosevelt, San Isabel, and San Juan National Forests--with 25 of the 
projects conducted in the Pike and San Isabel National Forests. The 
remaining 9 Good Neighbor projects occurred on forested BLM land 
covering about 100 acres in Boulder County.[Footnote 11] The number of 
acres being treated under individual Good Neighbor projects on U.S. 
Forest Service land in Colorado ranged from 1 acre to about 300 acres 
and on BLM land ranged from 2 acres to 21 acres. Figure 1 depicts the 
number of Good Neighbor projects in each of the Colorado national 
forests and BLM areas. 

Figure 1: Good Neighbor Projects in Colorado, by National Forest and 
BLM Area: 

[Refer to PDF for image] 

This figure is a map showing the Good Neighbor projects in Colorado, by 
National Forest and BLM area. 

Colorado: 

National forests without Good Neighbor projects: 
Rio Grande; 
Grand Mesa; 
Uncompahgre; 
Gunnison; 
White River; 
Ruott. 

National forests with Good Neighbor projects: 
San Isabel (16); 
Pike (9); 
San Juan (2); 
Roosevelt (1). 

BLM areas with Good Neighbor projects: 
Boulder, Boulder County (9). 
 
Source: Map resources (map); U.S. Forest Service. 

[End of figure] 

Costs to the U.S. Forest Service for the 29 projects conducted on its 
land in Colorado have totaled about $679,000 through fiscal year 2008, 
while costs to BLM for its 9 projects in Boulder County have totaled 
$74,000 through the same time period. Individual project costs in 
Colorado varied, ranging from a low of $7,000 to a high of $233,000, 
depending on the number of acres treated and the type of work and 
equipment required. For example, one U.S. Forest Service district 
ranger stated that in a typical tree-thinning project, the contractor 
would pile and burn the cut branches and other thinned material (known 
as slash) resulting from the work, which is relatively inexpensive, but 
when the work is done in close proximity to homes, it usually requires 
more expensive treatments and means of disposal, such as mechanical 
grinding or chipping. 

In Colorado, Good Neighbor projects have been initiated as part of 
larger fuel reduction efforts being planned or conducted by the state 
on state, local, and private land in the state's wildland-urban 
interface. The Good Neighbor project portion is usually smaller--in 
acres and cost--than the overall fuel reduction effort in a given area. 
For example, in the upper South Platte region, which includes portions 
of the Pike National Forest, CSFS has reduced fuels on thousands of 
acres in highly fire-prone areas on Denver Water[Footnote 12] land and 
other privately owned land after a severe fire in 1996 caused extensive 
sediment runoff into a primary Denver water source. However, a portion 
of these lands was adjacent or intermingled with Pike National Forest 
land, making it difficult to effectively treat the entire area without 
conducting work on federal land. According to CSFS officials, the 
state, as a result of the Good Neighbor authority, was able to contract 
with individual vendors to perform the work required on several hundred 
acres of the Pike National Forest as well as on private lands, thereby 
ensuring a seamless fuel reduction effort across Denver Water, private, 
and U.S. Forest Service lands. Figure 2 shows a slash pile on a fuel 
reduction project site in the Pike National Forest. 

Figure 2: Completed Fuel Reduction Project in Pike National Forest with 
Slash Piled for Burning: 

[Refer to PDF for image] 

This figure is a photograph of completed fuel reduction project in Pike 
National Forest with slash piled for burning. 

Source: GAO. 

[End of figure] 

In most Good Neighbor projects, the state either performs the services 
or contracts with vendors under a service contract; however, several 
projects in Colorado on U.S. Forest Service land were conducted under 
timber sale contracts in which fuel reduction projects aimed at 
thinning forests are structured as timber sales. Acting through Good 
Neighbor authority, state foresters sold the timber to professional 
loggers or, in some cases, to residents of adjacent subdivisions who 
used it for firewood. Instead of having to pay fuel reduction 
contractors to remove the timber, the U.S. Forest Service received a 
small amount of sale revenue from the state and paid only for the state 
forester's administration of the sale.[Footnote 13] Of the 29 Good 
Neighbor projects the CSFS has conducted in Colorado on U.S. Forest 
Service land, 15 were conducted in the San Isabel National Forest and 1 
was conducted in the Pike National Forest using timber sale 
contracts.[Footnote 14] Through these timber contracts, about 345,000 
cubic feet of timber has been harvested and sold as of September 30, 
2008, for a total of about $19,000.[Footnote 15] According to CSFS 
officials, the amount received for the timber is relatively small 
because the ponderosa pine, lodgepole pine, and mixed conifer timber 
primarily found in the Pike and San Isabel National Forests is small 
and of low value, as is timber in much of the rest of Colorado, in 
part, because of limited markets for timber. 

In addition, in 3 of the 13 Good Neighbor projects that involved 
service contracts on U.S. Forest Service land, timber sales were 
included as part of the service contract, rather than in a separate 
timber sale contract. As an incentive to attract bidders for these 
projects, timber harvested during fuel reduction was permitted to be 
removed from the forest and sold to local mills, rather than cut and 
piled on-site. Because prospective bidders contemplated the value of 
this timber in their bids, the cost of the resulting service contract 
was likely lower than it would have been without the incentive. For 2 
of these projects, 1 located in the San Juan National Forest and the 
other located in the Arapaho National Forest, the total volume and 
value of included timber was 278 CCF for $1,378 and 1,312 CCF for 
$5,472, respectively.[Footnote 16] 

Utah Good Neighbor Projects Focused on Rehabilitation of Burned Areas 
and Watershed Health: 

In Utah, 15 projects have been conducted under Good Neighbor authority 
from fiscal year 2005, when the authority was enacted, through fiscal 
year 2008. All of the projects in Utah have been conducted in one 
national forest--the Dixie National Forest--which is in the southern 
part of the state. According to a U.S. Forest Service Intermountain 
Region official, U.S. Forest Service ranger district officials in the 
Dixie National Forest and UDFFSL Southwestern Area officials have 
historically had a good relationship with each other and thought Good 
Neighbor projects could be beneficial to both. As a result, U.S. Forest 
Service officials in this district decided to use Good Neighbor 
authority to conduct several projects that they had originally planned 
to undertake themselves. Figure 3 depicts the national forests located 
in Utah and the number of projects undertaken in the one forest that 
has used the authority. 

Figure 3: Good Neighbor Projects in Utah, by National Forest: 

[Refer to PDF for image] 

This figure is a map showing the Good Neighbor projects in Utah, by 
National Forest. 

National forests without Good Neighbor projects: 
Fishlake; 
Wasatch; 
Manti-LaSal; 
Cache; 
Wasatch; 
Uinta; 
Ashley. 

National forests with Good Neighbor projects: 
Dixie (15). 

Source: Map Resources (map); U.S. Forest Service. 

[End of figure] 

The types of Good Neighbor projects in Utah are more diverse than those 
in Colorado. Unlike Colorado, where the projects are generally driven 
by overall state fuel reduction initiatives, in Utah, the U.S. Forest 
Service initiates projects and then obtains the assistance of UDFFSL to 
perform work on national forest land. According to Utah state 
officials, of the 15 Good Neighbor projects conducted in Utah, only 2 
projects were fuel reduction-related, where state crews burned piles of 
brush and slash on over 300 acres near adjacent private lands to assist 
the U.S. Forest Service in a larger fuel reduction project in the 
forest. Of the remaining 13 projects, 8 involved using state crews or 
contractors to rehabilitate burned areas following wildland fires, 
including activities such as repairing and constructing fences, 
cleaning impoundments used by cattle and wildlife, and reconstructing 
forest trails. In the 5 remaining Good Neighbor projects, the state 
used crews or contractors to protect the watershed from erosion and 
sediment runoff by, for example, rehabilitating trails used by all-
terrain vehicles and transportation and placement of large barrier 
rocks on either side of a roadway near public campsites to prevent 
vehicles from traveling off-road and damaging forest resources (see 
fig. 4). 

Figure 4: Barrier Rocks Placed along Dixie National Forest Roadway to 
Prevent Off-road Vehicle Use: 

[See PDF for image] 

This figure is a photograph of barrier rocks placed along Dixie 
National Forest roadway to prevent off-road vehicle use. 

Source: GAO. 

[End of figure] 

Costs to the U.S. Forest Service for these 15 projects have totaled 
about $674,000 through fiscal year 2008. As in Colorado, costs varied 
depending on the type of work and equipment provided. For example, 
project costs ranged from $1,500 for a pile burning on a few acres to 
$174,000 for replacement of existing culverts--large pipes that allow 
natural waterways to flow under road crossings--with new structures 
that will improve the forest watershed by facilitating the passage of 
trout and other fish species. 

Good Neighbor Projects Are Generally Governed by State Procedures, but 
Projects Involving Timber Sales Also Incorporate Certain Federal 
Requirements: 

State procedures are used for projects that involve service contracts, 
which include most Good Neighbor projects to date, while projects that 
include timber sales incorporate both state and federal requirements. 
We examined both states' contracting requirements concerning three 
fundamental principles of government contracting--transparency, 
competition, and oversight--and found that state requirements generally 
address each of these areas. The U.S. Forest Service and CSFS are 
currently updating their Good Neighbor timber sale procedures, however, 
to make certain that timber sales conducted under the authority include 
all protections that federal officials believe are necessary when 
dealing with federal timber. Neither BLM in Colorado nor the U.S. 
Forest Service in Utah has developed written procedures for conducting 
Good Neighbor timber sales, primarily because neither agency has sold 
timber under the authority. However, such procedures could help ensure 
accountability for federal timber if these agencies conduct such sales 
in the future. 

State Procedures Are Generally Used for Projects That Involve Service 
Contracts: 

State procedures generally govern Good Neighbor projects that involve 
service contracts, which include 37 of the 53 Good Neighbor projects to 
date. Good Neighbor projects are initiated under the authority of Good 
Neighbor agreements between each state and federal agency, which 
describe at a high level the authority and responsibilities of each 
agency in conducting projects, including the project's planning, 
design, preparation, contracting, and administration.[Footnote 17] For 
those projects involving service contracts, Good Neighbor agreements 
allow the states to use their own procedures to enter into contracts 
with vendors that provide services, such as fuel reduction, in 
conducting forest restoration projects, or the states may use their own 
crews to carry out the work. Under the agreements, however, the U.S. 
Forest Service and BLM retain certain authorities when Good Neighbor 
projects are conducted. For example, for projects carried out on their 
respective lands, the U.S. Forest Service and BLM remain responsible 
for ensuring that the requirements of NEPA are satisfied. Once NEPA 
requirements are satisfied and project planning is completed, the state 
and federal agencies develop a task order for each project, detailing 
its objectives and cost.[Footnote 18] The state can then proceed with 
procuring the needed services using its own procurement and contracting 
process. In Colorado, the Colorado State University (CSU) administers 
procurement and contracting for all CSFS service contracts, including 
those for Good Neighbor projects. In Utah, procurement and contracting 
for service contracts are administered and approved by either UDFFSL or 
the Utah Division of Purchasing, depending on the size of the 
procurement. 

We examined CSU's and the Utah agencies' contracting requirements 
concerning three fundamental principles of government contracting----
transparency, competition, and oversight. Specifically, we examined 
each state agency's procurement rules concerning the following 
practices: 

* soliciting contracts through public notice, with reasonable time 
allowed for potential vendors to develop and offer their bids; 

* ensuring competition, except in cases where there are legitimate 
extenuating circumstances, such as projects for which there is only one 
responsive bidder; 

* using simplified acquisition procedures for contracts whose dollar 
value is below a specified amount; 

* awarding contracts to the lowest-priced vendor when evaluating 
competing offers, and requiring justification when any additional 
criteria, such as past performance, are used; 

* giving preference to small businesses when awarding contracts; 

* using fixed-price contracts;[Footnote 19] 

* avoiding the awarding of contracts to private vendors for the 
performance of inherently governmental functions, such as budgeting and 
hiring; 

* including worker protection provisions in state contracts; 

* conducting orientation conferences with vendors at project sites; 
and: 

* providing for ongoing quality control, and requiring the government 
to conduct quality assurance inspections to determine whether the 
vendor is fulfilling the contract. 

In our analysis, we found that the state agencies' contracting and 
procurement requirements generally address each of these areas. We 
discuss five of these areas in the following text: 

* We found that agencies in both states provide a reasonable amount of 
time to advertise and receive bid proposals as well as provide 
competition among vendors. In CSU procurements, for example, contracts 
for services that will cost between $25,000 and $150,000 are generally 
advertised on Colorado's Internet bidding system for not less than 3 
days--to allow vendors time to develop and offer their bids. CSU 
provides additional requirements for procurements relating to CSFS 
forest-related work, allowing a minimum of 14 days for vendors to 
submit a bid regardless of the type of procurement because vendors that 
may be interested are often in the field conducting forest-related work 
and may not see the advertisement for several days. Services that will 
cost less than $25,000 are left to the discretion of the purchasing 
agent, who may advertise the bid or solicit vendors via telephone to 
determine whether they are interested. According to CSU procurement 
officials in Colorado, competition is generally promoted, except in two 
circumstances: (1) when only one vendor is available, and the contract 
has to be awarded to that vendor, or (2) the service being obtained 
will cost less than $25,000, which allows the purchasing agent to 
obtain services through other state agencies, such as the Colorado 
Corrections Industry, without written justification, if a fair market 
price is obtained. Competition is similarly promoted in Utah, according 
to state contracting officials, but contracting officers in the state 
may use informal procedures to acquire services, if the services will 
cost less than $50,000. For example, to award a $30,000 service 
contract, the state's centralized Division of Purchasing may solicit 
telephone bids from three known vendors, then select one of the three 
vendors. This would not be an acceptable amount of competition for 
acquisitions exceeding $50,000, which would require the invitation to 
bid to be disseminated via the state's Internet bidding system for a 
minimum of 10 days' bidding time. 

* Agencies in both states are generally required to award a contract to 
the lowest-priced bidder who meets the requirements set forth in the 
solicitation for bids for contracts, except in certain circumstances, 
such as when contracts are sizable enough to require a request for 
proposal--in which the state requires bidders to address additional 
criteria in their bids, such as technical requirements--or when strong 
justifications for not choosing the lowest bidder can be documented by 
the contracting officer. Additional requirements are imposed by the 
state agency to ensure that contracts are awarded to reputable 
contractors. For example, contract terms and conditions in both states 
require contractors to certify that they have not been debarred, 
suspended, or proposed for debarment by any governmental department or 
agency. In addition, for all proposed contracts that are federally 
funded, including Good Neighbor contracts, CSU purchasing agents search 
for prospective vendors' names on the General Services Administration's 
Excluded Parties List System, which is a database for obtaining 
information on parties that are excluded from receiving federal 
contracts, certain subcontracts, and certain federal financial and 
nonfinancial assistance and benefits. If a prospective vendor is on the 
list, the CSU purchasing agent will not consider this vendor's bid, 
even if it is the lowest priced. 

* According to state agency officials, the procurement policies of 
agencies in both states encourage contracting for services with small 
or disadvantaged businesses, although there are no specific set asides 
for small or disadvantaged businesses in either state. A CSU official 
stated that CSU promotes such businesses through a small business 
program, and that about 90 percent of CSFS contracts, including 
contracts for Good Neighbor projects, go to small businesses. However, 
attaining this percentage is not a requirement, according to this 
official, but simply results from the fact that types of work required 
in forest restoration projects, such as fuel reduction, are typically 
performed by small businesses. A Utah Division of Purchasing official 
stated that, although set asides are not required in Utah, the state 
will incorporate them into any procurement if the federal government 
requires set asides as the condition of a particular grant or contract 
under which the procurement is conducted. The official added that the 
federal government, rather than the state, is ultimately responsible 
for determining whether contracts are awarded pursuant to federal 
requirements for small businesses. 

* According to state agency officials in both states, contractors are 
generally required to have liability insurance. In addition, the state 
agencies incorporate federal worker protection provisions into state 
contracts as requested by federal agencies. For example, the Migrant 
and Seasonal Agricultural Workers Protection Act[Footnote 20] is a 
federal law that applies to migrant and seasonal agricultural workers, 
including at least some forestry workers.[Footnote 21] While none of 
the agencies we reviewed specifically requires that the act's 
provisions be explicitly included in state contracts, procurement 
officials in both states said that they include such federal provisions 
if they are conditions of grants or are otherwise stipulated in 
federal-state agreements. 

* The responsibility for monitoring contract performance--through 
activities such as project site visits to ensure satisfactory work and 
a quality assurance inspection at the job's completion--is largely left 
to the state forest services' project managers in the field. However, 
both states use contract mechanisms to ensure that a vendor's 
performance meets government standards, including performance bonding 
and requirements that contractors operate within an agency-approved 
scope of work. 

In reviewing state requirements concerning transparency, competition, 
and oversight, we compared selected state procurement and contracting 
requirements with those in the Federal Acquisition Regulation (FAR), 
which governs federal procurement activities, as well as specific U.S. 
Forest Service and BLM procurement guidance, and found them to be 
generally comparable. For example, we reviewed FAR provisions on (1) 
publicizing contract actions, which can include the establishment of a 
minimum bidding period that gives potential vendors a reasonable 
opportunity to respond; (2) competition requirements, which includes a 
requirement to provide for full and open competition through the use of 
competitive procedures, but allows for an exception to these procedures 
in limited circumstances, for example, if there is only one suitable 
vendor; and (3) quality assurance, which details several mechanisms--
including inspection requirements and contract clauses--for 
maintaining project oversight and ensuring that the government receives 
quality work. Although we did not analyze all portions of the FAR, our 
broad comparison suggests that state and federal procurement 
requirements are generally similar in the areas we examined. 

Projects That Include Timber Sales Incorporate Both State and Federal 
Requirements: 

While most Good Neighbor projects are carried out through service 
contracts, certain CSFS districts in Colorado, such as the Salida 
District, also use timber sale contracts to conduct fuel reduction 
projects when the project is expected to involve the harvest of 
merchantable timber. In such cases, CSFS Good Neighbor timber operating 
procedures incorporate certain federal requirements beyond those used 
for ordinary state timber sales, to ensure proper oversight of, and 
accountability for, state removal of federal timber. For example, the 
following additional project requirements are included in Good Neighbor 
timber sale operating procedures: 

* state foresters should determine the timber sale volume, using 
standard federal tree sampling methods; 

* state foresters should work with the local U.S. Forest Service ranger 
district to develop a sale appraisal and determine a minimum bid price; 
and: 

* project sites with total timber sale volume greater than 25 CCF or 
values greater than $5,000 should be marked with U.S. Forest Service 
tracer paint to identify trees to be cut and boundaries around the area 
in which cutting is to take place. 

CSFS officials, in conjunction with U.S. Forest Service regional 
officials, developed these CSFS timber operating procedures in 2007, in 
response to confusion over the requirements governing timber sales. 
When Good Neighbor authority was first being used, general operating 
procedures were contained in the master agreements, but no specific 
operating procedures existed, and some CSFS district officials were 
unsure about, or unaware of, certain requirements that needed to be 
followed as part of conducting a timber sale on federal land. We 
reviewed the provisions in the initial timber sale contracts that CSFS 
administered under Good Neighbor authority and found that they were not 
as extensive as standard U.S. Forest Service timber sale contracts. For 
example, the state Good Neighbor timber sale contracts did not 
specifically require the contractor to consider additional activities 
associated with the project, such as road maintenance, and did not 
include information about whether threatened and endangered species 
were in the project area. In addition, these contracts did not include 
detailed descriptions of the type and amount of timber sold. This type 
of information was included in standard U.S. Forest Service timber sale 
contracts. CSFS's recent operating procedures address these issues, and 
a U.S. Forest Service Rocky Mountain Region official told us that CSFS 
has begun to include some of this information in more recent timber 
sale contracts--for example, CSFS included a clause addressing 
threatened and endangered species in a recent timber sale contract. 

Some U.S. Forest Service officials told us, however, that they remain 
concerned about certain aspects of timber sales conducted under Good 
Neighbor authority. Accordingly, the U.S. Forest Service and CSFS are 
drafting additional timber procedures that were not addressed in the 
initial procedures in 2007. These revised operating procedures add or 
revise procedures that identify federal and state roles in Good 
Neighbor timber sales from the initial NEPA documentation through the 
sale and subsequent harvesting of national forest timber. For example, 
the agencies are considering adding procedures for better 
accountability of timber sales by outlining the necessary information 
that needs to be included in the U.S. Forest Service's Timber 
Information Management System, a system which tracks all information 
connected with each federal timber sale from its inception to 
completion. These provisions are currently in draft form, but when 
finalized will be considered joint operating procedures for both 
agencies. 

In addition, the U.S. Forest Service has already begun initiating some 
changes to the timber sale contract requirements in its latest Good 
Neighbor projects. According to a U.S. Forest Service official, one 
important change to the procedure is that national forest timber will 
be considered as "sold" first to the state, which in turn will sell it 
to the private contractor. According to a CSFS official, project task 
orders for timber sale contracts will clearly specify any special U.S. 
Forest Service contract requirements that are the responsibility of the 
state, which in turn will hold the contractor accountable for meeting 
those requirements. With this change, the state will more clearly know 
what special additions they must make to their Good Neighbor timber 
sale contract for a particular project. State officials believe this 
change will improve the project administration by the state and the 
accountability for enforcing certain U.S. Forest Service requirements. 
For example, an October 2008 Good Neighbor timber sale contract between 
the state and the buyer includes a U.S. Forest Service stipulation 
resulting from the project's federal NEPA analysis, specifically 
prohibiting logging work from December 1 through April 15, to avoid 
interfering with the winter range of big game animals, such as deer and 
elk. Under the new contracting provisions, the state is now responsible 
for enforcing this provision. 

We did not compare Colorado's timber sale requirements with those of 
BLM, or Utah's with those of the U.S. Forest Service, because neither 
BLM in Colorado nor the U.S. Forest Service in Utah has conducted 
timber sales under Good Neighbor authority to date, and neither BLM in 
Colorado nor the U.S. Forest Service in Utah has developed written 
procedures for doing so. According to a CSFS official, detailed 
operating procedures for BLM Good Neighbor projects have not been 
developed because CSFS's experience with the agency--consisting of nine 
projects in Boulder County at a total cost of $74,000--has been too 
limited to justify spending time and resources in developing such 
procedures. In addition, a BLM official stated that if the agency 
decided to have CSFS conduct timber sales as part of its Good Neighbor 
projects, it would likely require CSFS to utilize a BLM timber sales 
contract on the basis of agency timber sale requirements, or work with 
CSFS to ensure that the necessary federal requirements were accounted 
for in a state timber sales contract. As for Utah, a senior UDFFSL 
official told us that there is no official UDFFSL timber sale contract 
or process, because neither UDFFSL nor its parent Department of Natural 
Resources is involved in the sale of state timber. Instead, this is the 
role of a separate state agency that administers real estate trusts 
granted to Utah at statehood and is not involved in Good Neighbor 
projects. UDFFSL has developed a sale contract template for private 
landowners to use when selling timber from their land to commercial 
loggers. If timber were sold as part of a Good Neighbor project in 
Utah, a senior UDFFSL official speculated that agency managers in the 
field might use this contract template in the absence of other 
guidance. 

Although the value of timber removed through Good Neighbor projects has 
been minimal, the agencies' experiences in using the authority to sell 
timber have demonstrated the importance of having detailed Good 
Neighbor timber sale operating procedures. Such procedures can help 
ensure that officials in both the federal and state agencies understand 
each agency's roles and responsibilities and can help provide the 
guidance necessary to ensure proper accountability for federal timber. 
Should BLM in Colorado or the U.S. Forest Service in Utah decide to 
undertake timber sales through Good Neighbor authority in the future, 
or should the authority be expanded to include other states where such 
timber sales might occur, both federal and state agencies would benefit 
from written procedures detailing each party's responsibilities in 
conducting Good Neighbor project timber sales. 

Experiences with Good Neighbor Authority to Date Could, If Better 
Documented, Provide Insight for Potential Expansion of Its Use: 

Federal and state officials who have participated in Good Neighbor 
projects cited project efficiencies as the authority's primary benefit, 
including the ability to begin work more quickly and to reduce 
hazardous fuels across multiple ownerships with a single contract. The 
authority also provides a forum for federal-state cooperation that can 
aid other collaborative efforts, such as emergency wildland fire 
suppression. Challenges encountered by the agencies include federal and 
state officials' incomplete understanding of how projects should be 
administered under the authority and concern about the adequacy of 
state contract procedures. Future use of Good Neighbor authority may 
benefit from documentation of agency experiences in using the authority 
to date, particularly since stakeholders told us that the authority's 
chances for success in other states hinge on several factors, including 
the structure, staffing levels, and workloads of other state forest 
services, as well as the characteristics of those states' federal 
lands. 

Benefits of Good Neighbor Authority Include Project Efficiencies and 
Increased Federal-State Cooperation: 

Federal and state officials who have used Good Neighbor authority cited 
project efficiencies as its primary benefit. The efficiencies cited 
include an ability to begin work more quickly, in part because the 
Colorado and Utah state forest services have established relationships 
with local communities and in part because state contracting procedures 
are considered to be simpler than federal procedures. In Colorado, for 
example, CSFS's mission includes a mandate to assist local property 
owners with forest management on their lands. The state agencies' 
resulting familiarity with local communities extends to knowledge of 
local vendors that offer services such as fuel reduction, which--
combined with the states' simplified contracting procedures--can 
shorten the time required to identify a suitable contractor, secure a 
contract, and begin work. According to one U.S. Forest Service district 
ranger in Colorado, this type of local-level coordination with private 
landowners and local contractors is not a specialty of most ranger 
districts' staff. The state foresters' familiarity with local 
landowners also speeds implementation when access is required across 
private land to reach a project site on federal land--for example, when 
a project site is far from existing forest roadways but is near a 
network of private roads within a subdivision. In one such instance, 
the U.S. Forest Service needed to gain access through a private 
subdivision to treat a densely forested area in an adjoining national 
forest. As part of a Good Neighbor agreement, CSFS negotiated with the 
subdivision's owners to gain access to the site so that a private 
contractor could begin work. Figure 5 shows a map of the project area. 

Figure 5: Fuel Reduction Project Site in National Forest Area Bordering 
Private Subdivision: 

[Refer to PDF for image] 

This figure is an image of a fuel reduction project site in National 
Forest Area bordering private subdivision. 

Source: GAO adaptation of Colorado State Forest Service map. 

Note: The project area was divided into four units and numbered in 
order of priority. 

[End of figure] 

According to state officials, securing this access is often less time-
consuming for state foresters because, as a result of their state 
agencies' emphasis on local outreach, they are often better known in 
the community than their federal counterparts. Moreover, several state 
officials noted that the U.S. Forest Service sometimes attempts to 
secure a permanent easement across private land in this scenario, which 
is less likely to result in a landowner's cooperation, instead of 
temporary access for the duration of a specific project. 

The ability to begin work more quickly can be important when Good 
Neighbor projects use funding that is only available for the remainder 
of the current fiscal year. (Good Neighbor projects do not receive 
dedicated funding; instead, projects are funded from a variety of 
accounts, including grant funds.) In certain cases, the U.S. Forest 
Service decides to fund a project for one field unit near the end of 
the fiscal year--for example, by shifting funds from another field unit 
that has no further fuel reduction activities to fund that year. 
Partnering with the state forest service through a Good Neighbor 
agreement that expedites contracting can allow the project to be 
started prior to the end of the current fiscal year. 

In some cases, according to federal and state officials, using state 
foresters to administer Good Neighbor projects increased the efficiency 
of federal activities because the state was willing to assume 
responsibility for project administration. For example, state foresters 
in Utah performed project management duties, such as locating 
responsible vendors, negotiating contracts, and processing payments to 
vendors as work progressed. According to Utah officials, the state 
forest service was willing to undertake these Good Neighbor project 
duties because the projects benefited shared watersheds, accomplished 
important work for communities, and had a positive impact on local 
economies. Similarly, Colorado's state forest service administered Good 
Neighbor fuel reduction projects in the state's South Platte district 
under an arrangement funded by Denver Water, which benefited from the 
resulting watershed protection. In other cases, because the state 
structured fuel reduction projects as timber sales, fees related to the 
state forester's administration of these sales were the only costs to 
the federal government--there were no service costs. 

The use of Good Neighbor authority also increased the effectiveness of 
fuel reduction treatments in areas that include federal, state, and 
private ownership and helped to maximize the degree of wildland fire 
risk reduction per dollar spent on the project, according to agency 
officials. Arranging for a single vendor to perform the work across 
ownership boundaries increased the likelihood that forest treatment was 
conducted in a uniform way and avoided leaving untreated land parcels 
in the project area. According to one U.S. Forest Service official, the 
ability to treat land parcels under multiple ownerships is critical 
because fire "doesn't know the boundary" between federal, state, and 
private forest land. 

Given the advantages of partnering with the state--including the 
ability to negotiate access agreements, find suitable vendors, utilize 
more nimble contracting procedures, and share some project management 
duties--the use of Good Neighbor authority allowed the agencies to 
accomplish more than they would have accomplished in the absence of the 
authority, according to officials with whom we spoke. As U.S. Forest 
Service officials in Utah noted, the ability to leverage state 
employees to work on national forest lands increases the number of 
initiatives that a manager can undertake. For example, the Cedar City 
ranger district in the Dixie National Forest enlisted the state to 
reconstruct an all-terrain vehicle trail running through the forest, 
adding a layer of gravel to prevent trail erosion from continuing to 
spread sediment into nearby wetlands. According to the project's 
federal manager, U.S. Forest Service crews' already heavy workload was 
one reason for giving the project to the state. A second reason was 
UDFFSL's ability to employ a county road crew on the project that would 
do similar work on private portions of the trail that access nearby 
communities.[Footnote 22] In other cases, projects benefiting local 
communities may "fly under the [U.S.] Forest Service's radar," as one 
state official said. That is, due to their inaccessible location or 
relatively small size, the national forest portions of some fuel 
reduction projects may not have been part of the U.S. Forest Service's 
annual work plan until the state proposed including the parcels in 
landscapewide projects being planned for state and private property. 
Using state crews and private companies to do this work has additional 
advantages. For example, state and federal officials in Utah said that 
employing seasonal state fire response personnel on Good Neighbor 
projects brings revenue to the state that allows it to maintain these 
personnel for a longer period, keeping them available for emergency 
fire response outside of the state's peak summer fire season. On the 
other hand, having the state contract with private companies allows the 
skills needed for necessary work such as fuel reduction to develop 
within a community, increasing the number of potential vendors that are 
qualified to work with federal agencies in the future. 

In addition to creating project and agency efficiencies, the use of 
Good Neighbor authority provided a forum for collaboration between 
federal and state agencies that officials told us can increase the 
effectiveness of other cooperative efforts. For example, emergency 
suppression of wildland fires demands that agency officials be able to 
coordinate under tight time and resource constraints with 
representatives of many different governmental entities. According to 
federal and state officials, this coordination is made easier by past 
working relationships on collaborative projects, such as those 
conducted under Good Neighbor authority that develop familiarity and 
instill mutual trust. This collaboration is useful outside of emergency 
scenarios as well. Officials identified stewardship contracting--where 
agencies use other special contracting authorities, such as the 
exchange of timber for fuel reduction services, to meet community land 
management needs--as another initiative that can benefit from a shared 
history of cooperation on Good Neighbor projects.[Footnote 23] 

Challenges in Conducting Projects Include Lack of Understanding of the 
Authority and Concern about Adequacy of State Contract Procedures: 

Federal and state agencies have also encountered challenges in using 
Good Neighbor authority, including a lack of understanding of the 
authority that has complicated partnerships between federal and state 
officials. In Colorado, several state foresters said that their initial 
attempts to interest their U.S. Forest Service counterparts in 
potential projects were hampered by the federal officials' lack of 
familiarity with the authority. In some of these areas, projects were 
eventually undertaken, but confusion about roles and responsibilities 
made project implementation more difficult--especially for projects 
involving timber sales. In Utah, projects have been conducted by only 
one national forest, in partnership with one of the state's six 
districts. State officials in two of Utah's remaining districts 
reported that they have encountered a lack of awareness of the 
authority from their prospective federal counterparts, similar to the 
early years of Colorado's Good Neighbor experience. 

Likewise, concern over the adequacy of state contracting procedures 
hampered the use of the authority. Some U.S. Forest Service officials 
in Colorado considered state timber sale procedures to be insufficient 
to protect federal interests and imposed additional contracting 
requirements on the state before agreeing to Good Neighbor projects. 
For example, in one Colorado district, a state forester's agreement 
with the local U.S. Forest Service ranger district staff about how to 
proceed on an early Good Neighbor project was overruled by the ranger 
district's regional management, which placed additional requirements on 
the project. The regional office did not approve of some of the state's 
processes--such as the state's appraisal of timber value, and the way 
the state's timber contract was written--and asked that additional 
requirements be included to ensure that the state could account for any 
federal timber removed. This request resulted in two separate contracts 
with the project's single vendor--one for work being done on U.S. 
Forest Service land, and a second for work being done on private land. 
In another state district, a state forester who coordinated Good 
Neighbor projects for two ranger districts on the same national forest 
found that project requirements in one ranger district were more 
rigorous than for those in the other. In the latter district, the 
ranger allowed the state forester to administer projects involving 
timber sales using state contracting processes; however, the ranger in 
charge of the first district required that the U.S. Forest Service have 
more involvement in administering that district's sale, believing that 
the U.S. Forest Service's timber sale procedures did a better job of 
holding contractors accountable for their project performance than did 
state contracting procedures. 

Some state and federal officials found the overlay of federal 
requirements burdensome, making them less likely to participate in Good 
Neighbor projects. In one state district where U.S. Forest Service 
regional management imposed additional federal requirements on early 
projects because of doubts about the sufficiency of state procedures, 
state officials expressed a reluctance to pursue future projects until 
differences between the federal and state approaches are resolved. A 
former U.S. Forest Service official involved in this district's 
projects said that the region's additional requirements were counter to 
Good Neighbor's core philosophy of landscape-level management requiring 
one appraisal, one vendor, and one contract. A second federal official 
added that the timber involved in these projects was of such little 
value that the attempt to add additional time-consuming accountability 
procedures was not cost-effective. State officials in the district and 
their federal counterparts have not pursued additional Good Neighbor 
projects to date, but state officials noted that timber sale procedures 
have been streamlined in the years since they experienced their early 
difficulties. 

In addition, the CSFS official in charge of coordinating Good Neighbor 
projects for the state said that the cumbersome administrative process 
imposed by both CSU and the U.S. Forest Service has effectively 
eliminated the use of Good Neighbor authority for small-scale projects 
in Colorado, frustrating an important original intent of the program. 
This process often makes such activities--for example, allowing an 
individual landowner to expand fuel reduction treatments onto U.S. 
Forest Service land to remove insect-infested trees or to establish an 
adequate defensible space for improved wildland fire protection--too 
burdensome and time-consuming to pursue. According to the CSFS 
official, both CSFS and U.S. Forest Service timber staff have 
recognized the need to streamline the task order approval process to 
address this problem if Good Neighbor authority is extended. 

According to several federal and state officials, a lack of detailed 
guidance in the early years of using Good Neighbor authority created 
confusion over the respective duties of federal and state project 
participants. In Colorado, federal and state officials issued general 
project guidelines as part of their Good Neighbor master agreement that 
addressed general operating procedures, but did not provide specific 
project-level direction--particularly concerning the use of timber 
sales in fuel reduction projects. As we have previously mentioned, more 
detailed guidance specifically addressing timber sales was issued in 
2007, as a result of lessons learned from projects involving such sales 
and in recognition of the fact that sale procedures being used in some 
ranger districts differed from those used in others. These procedures 
are now being revised by the U.S. Forest Service and CSFS to address 
unresolved issues, such as how Good Neighbor timber sales should be 
reported in the U.S. Forest Service's performance and financial 
tracking systems. The revised guidance--now in draft form--also 
includes additional timber accountability procedures. In Utah, U.S. 
Forest Service and state officials agreed on general project 
guidelines, but they have not issued more detailed guidance for project 
implementation, including instructions regarding timber sales. 
Although such instructions have not been needed to date because no 
timber sales have occurred under Good Neighbor authority in Utah, the 
area manager for the one state district where Good Neighbor projects 
have been conducted said that future projects may include timber sales. 
In addition, an area manager in another Utah district said that he had 
approached his U.S. Forest Service counterpart with a fuel reduction 
project proposal involving a timber sale. There is no official guidance 
that encompasses BLM's Good Neighbor project responsibilities on BLM 
land in Colorado, in part because there have been few projects on BLM 
land. 

The nature of Good Neighbor authorization and funding posed a challenge 
in some districts. Federal and state officials in Utah said that 
because Good Neighbor projects do not receive dedicated funding, money 
to conduct the projects instead comes from supplemental accounts, such 
as funding associated with the National Fire Plan. In the past, such 
funding has arrived several months or more after the beginning of the 
federal fiscal year. This shortens the project window for fuel 
reduction work, which can be especially problematic for projects 
involving pile burnings or prescribed fire because such projects must 
be completed outside of fire season, which can stretch from mid-May to 
mid-October in the Dixie National Forest. Other state officials agreed 
that the annual federal appropriations cycle--which included, for 
example, reauthorization of Good Neighbor authority in Utah for a 
period of just over 9 months in fiscal year 2008--makes long-term 
project planning more difficult, resulting in less Good Neighbor 
activity. 

Officials in federal and state districts where Good Neighbor projects 
have not been undertaken had various reasons for not using the 
authority. Some foresters said they had not seen opportunities for 
projects that fit Good Neighbor's criteria, while others lacked staff 
or other resources. One national forest supervisor in Utah saw several 
advantages to using the authority, but he wanted to ensure that his own 
staff was fully utilized before giving work to the state. Conversely, a 
senior official in Utah said that some state foresters see little 
benefit in adding projects that benefit the U.S. Forest Service to 
their workload, unless they are compensated by the U.S. Forest Service 
for their associated project administration duties. 

Future Use of Good Neighbor Authority May Be Enhanced by Documentation 
of Experiences with the Authority to Date: 

Experiences with Good Neighbor authority in Colorado and Utah may 
provide insights for its potential expansion in those and other states. 
Specifically, federal, state, and other stakeholders identified several 
factors that affect Good Neighbor authority's chances for success, 
including the structure, staffing levels, and workloads of state forest 
services and state purchasing staff, as well as the characteristics of 
those states' federal lands. These stakeholders noted that while it is 
important to understand the successes and challenges of Good Neighbor 
authority's use in Colorado and Utah when considering its expansion to 
other states, it is equally important to account for differences among 
states as well. One key difference is the structure and mission of 
state forest services: whereas these agencies in Colorado and Utah 
emphasize community forestry assistance, other states may have 
different priorities reflecting differences in their history, 
geography, or institutional framework. For example, the Idaho 
Department of Public Lands manages its state's forest resources to 
maximize the revenue from these resources and other state lands through 
activities such as timber harvesting, livestock grazing, and commercial 
building, according to a senior department official; the revenue 
generated from most of these trust lands supports the state's public 
schools. Though this official could see advantages to having Good 
Neighbor authority in Idaho, such as the ability to conduct uniform 
land management practices across broader areas, she said she would be 
wary of any activities that would divert her agency from its primary 
mission of managing the state's trust lands. A representative of an 
environmental group in Idaho told us that state forest management 
practices--such as the focus on timber harvesting--could lead to 
competing priorities if the state manages Good Neighbor projects on 
behalf of the federal government. To avoid this, he suggested that 
roles and responsibilities should be clearly defined at the outset for 
both federal and state participants if Good Neighbor authority is 
extended to Idaho. Moreover, a U.S. Forest Service official in Colorado 
who had previously worked for the relatively small forest service in a 
nearby state said that Good Neighbor's effectiveness in other states 
would depend on their capacity to implement the agreements and monitor 
the projects within their staffing resources and workload, and that he 
did not think state forest services with limited resources would be 
able to handle a Good Neighbor project workload comparable to 
Colorado's. There may also be differences in the federal and state 
forest services' relationship, the strength of which is a major 
determinant of Good Neighbor project success, according to numerous 
federal and state officials with whom we spoke in Colorado and Utah. 

Another major difference among states is the value of timber on their 
lands. While fuel reduction projects undertaken thus far under Good 
Neighbor authority have generally harvested low-value trees in a 
depressed timber market, project sites in other areas of Colorado and 
Utah, or in other states, may contain more valuable timber. Fuel 
reduction projects carried out under Good Neighbor authority in those 
areas, especially those involving timber sales, would likely attract 
more federal timber sale oversight, and might likewise attract 
additional scrutiny from environmental stakeholders concerned that 
projects were being undertaken for their timber value, rather than for 
ecological necessity. For example, representatives of one environmental 
group in Colorado told us they did not have concerns about Good 
Neighbor projects conducted to date, but stated that this is in part 
due to the low timber value in the state--saying "there's little worry 
here because there's so little [timber value] at stake." These 
representatives noted that their level of scrutiny would likely be much 
higher if Good Neighbor projects were conducted in timber-rich areas. 

Differences in the authorizing legislation for Colorado and Utah have 
led to differences in the types of projects conducted under Good 
Neighbor authority, which could lead to divergent outcomes if the 
authority is extended to other states. According to their Good Neighbor 
authorizing legislation, the U.S. Forest Service and BLM in Colorado 
may permit CSFS to perform watershed restoration activities on federal 
lands when the agency is carrying out similar and complementary 
activities on adjacent state or private lands. This has generally 
resulted in fuel reduction projects that take place near state or 
private boundaries, where nonfederal fuel reduction efforts had already 
occurred or were under way. In Utah, however, the authorization 
requires neither that the projects be part of a broader effort nor that 
they be adjacent to nonfederal lands. In practice, this less 
restrictive standard has led to a wider array of projects in Utah, such 
as the culvert replacement, barrier rock installation, and trail 
reconstruction undertaken in the Dixie National Forest. 

Moreover, to ensure the support of the public and environmental groups 
in Colorado, Utah, or other states, several stakeholders suggested that 
projects be undertaken only in the wildland-urban interface, where the 
potential public benefit is the greatest, rather than in more remote 
reaches of U.S. Forest Service and BLM lands. Also, according to 
federal and state officials as well as representatives of environmental 
groups, environmental stakeholders should be kept informed during Good 
Neighbor project design, and should be encouraged to participate during 
the NEPA process. Officials in Colorado and Utah told us they have done 
so on Good Neighbor projects to date, and they believe that this 
practice has been responsible for the general lack of opposition to 
Good Neighbor projects from members of the environmental community. 

Differences among states in the structure of their forest services, the 
value of their timber, and the potential content of their authorities, 
as well as the successes and challenges encountered in using Good 
Neighbor authority in Colorado and Utah, would be worth considering for 
agency officials contemplating future use of the authority--whether in 
Colorado, Utah, or other states. Although CSFS has prepared periodic 
summaries of Good Neighbor operations in Colorado, future users of the 
authority would benefit from a more systematic and comprehensive 
documentation of agencies' experiences in conducting projects under 
Good Neighbor authority. While the agencies are not required to develop 
such documentation as part of their use of Good Neighbor authority, 
doing so could benefit future users--by, for example, providing them 
with an analysis of cost savings or other efficiencies and benefits 
that have been achieved through Good Neighbor's use, and discussing the 
types of projects in which the authority has been most successful. In 
addition, as they have done for stewardship contracting,[Footnote 24] 
the agencies could disseminate this information through agency Web 
sites and handbooks and incorporate it into existing training to ensure 
that future users have access to the information. Without such 
information, agency officials will need to independently assess which 
projects would best be conducted using the authority, and the extent to 
which individual projects might reduce costs or lead to other 
efficiencies and benefits. With the aid of this information, federal 
and state officials in Colorado and Utah, and potentially in other 
states, could consider adopting those procedures that have worked well 
and avoid the early pitfalls experienced in applications of Good 
Neighbor authority. 

Conclusions: 

Given the state of our nation's forests, and in light of our nation's 
long-term fiscal constraints, land management agencies are seeking to 
enhance their effectiveness in improving forest conditions and helping 
prevent severe wildland fires. Good Neighbor authority can help this 
effort by allowing federal and state agencies to work more closely 
together to treat lands across ownership boundaries. The agencies have 
differed on how best to apply the authority, however, as evidenced by 
the variation in its use to date. In Colorado, Good Neighbor authority 
has been used by federal and state partners to work across multiple 
ownerships to increase the effectiveness of fuel reduction efforts, 
while projects in Utah have focused on watershed health and 
rehabilitation of burned areas on U.S. Forest Service land. These 
variations arise in part because of differences in the laws authorizing 
these states' activities, and in part because of differences in how 
state and federal agencies collaborate on Good Neighbor projects--
highlighting an important issue as projects proceed in Colorado and 
Utah, and as Congress and the agencies consider expanding the use of 
Good Neighbor authority. That is, the type of projects conducted under 
the authority, and the extent to which those projects enhance the 
effectiveness of agency land management efforts, depend on many state-
specific factors, including the scope of the Good Neighbor authority 
under which the state operates, the laws governing the state's 
contracting activities, and the characteristics of federal land 
targeted for treatment, particularly the value of any timber. Without 
procedures that ensure timber accountability in all states, however, 
and without understanding and benefiting from the lessons learned from 
past use of the authority, including the state-specific factors that 
influence the success of Good Neighbor projects, the agencies may fail 
to capitalize fully on the potential of Good Neighbor authority. 

Recommendations for Executive Action: 

We are making two recommendations to enhance the agencies' use of Good 
Neighbor authority in Colorado and Utah as well as in states in which 
Good Neighbor projects may be authorized in the future. 

First, if U.S. Forest Service officials in Utah or BLM officials in 
Colorado decide to conduct timber sales under Good Neighbor authority, 
or if timber sales are pursued under expanded Good Neighbor authority 
in additional states, we recommend that the Secretaries of Agriculture 
and the Interior direct the agencies to first develop written 
procedures for Good Neighbor timber sales in collaboration with each 
state to better ensure accountability for federal timber. In doing so, 
the agencies may want to consult the U.S. Forest Service's Good 
Neighbor timber sale procedures for Colorado. 

Second, we recommend that the Secretaries of Agriculture and the 
Interior direct the U.S. Forest Service and BLM, in collaboration with 
their state Good Neighbor partners, to document how prior experiences 
with Good Neighbor projects offer ways to enhance the use of the 
authority in the future and make such information available to current 
and prospective users of the authority. Specifically, the U.S. Forest 
Service should collaborate with Colorado and Utah, and BLM should 
collaborate with Colorado, to document information such as (1) the 
types of projects that have proven to be successful uses of the 
authority; (2) how differences in the authority's scope within each 
state have affected project selection; (3) how project planning and 
implementation responsibilities have been divided among federal and 
state project partners; and (4) the costs and benefits associated with 
using Good Neighbor authority to conduct projects, including any 
project efficiencies and cost savings that have resulted from the 
authority's use. In addition, to ensure that this information is 
available to current and future users of the authority, the agencies 
should develop a strategic approach for disseminating it--for example, 
through agency Web sites, handbooks, training, or other means. 

Agency Comments and Our Evaluation: 

We provided the U.S. Department of Agriculture's Forest Service, the 
Department of the Interior, CSFS, and UDFFSL with a draft of this 
report for review and comment. All four agencies generally agreed with 
the findings and recommendations in the report. The U.S. Forest Service 
noted, however, that it will address our recommendation about 
documenting experiences with Good Neighbor projects by providing our 
report to current and prospective users of the authority. While we are 
pleased that the U.S. Forest Service believes our report accurately 
documents lessons learned to date, we believe the agency will need to 
provide additional details if future users are to fully benefit from 
this information. For example, while our report includes a general 
description of the primary reasons for choosing Good Neighbor authority 
to conduct certain projects, it does not include a detailed discussion 
of the potential costs and benefits associated with this decision, 
which may prove beneficial to managers as they assess the applicability 
of the authority to future projects. The U.S. Forest Service's written 
comments, along with our response, are presented in appendix II, 
Interior's written comments are presented in appendix III, CSFS's 
written comments are presented in appendix IV, and UDFFSL's written 
comments are presented in appendix V. 

As agreed with your office, 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 to interested 
congressional committees, the Secretary of Agriculture, the Secretary 
of the Interior, the Chief of the Forest Service, the Director of the 
Bureau of Land Management, and other interested parties. The report 
also will be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or nazzaror@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made major contributions 
to this report are listed in appendix VI. 

Signed by: 

Sincerely yours, 

Robin M. Nazzaro: 

Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to determine (1) the activities conducted under 
Good Neighbor authority, including the number, type, and scope of 
projects undertaken; (2) the federal and state guidance, procedures, 
and controls being used to conduct Good Neighbor projects, including 
contracting requirements and timber sale procedures; and (3) the 
successes, challenges, or lessons learned, if any, that have resulted 
from the use of Good Neighbor authority. Our review of Good Neighbor 
authority included obtaining documentation and holding meetings and 
discussions with the U.S. Department of Agriculture's Forest Service 
and the Bureau of Land Management (BLM), the two agencies that have 
implemented Good Neighbor authority; the Colorado State Forest Service 
(CSFS) and the Utah Division of Forestry, Fire and State Lands 
(UDFFSL), the two state agencies that have conducted Good Neighbor 
projects; and Colorado State University (CSU) and the Utah Division of 
Purchasing, the agencies in each of these states generally responsible 
for administering service contracts for each state's forest service. 

To determine the activities conducted under Good Neighbor authority in 
Colorado and Utah, we interviewed U.S. Forest Service, BLM, CSFS, and 
UDFFSL officials on their overall management of Good Neighbor projects, 
including how projects are chosen, the coordination involved between 
federal and state agencies, and the type and scope of projects that are 
undertaken. We also reviewed and analyzed specific data on Good 
Neighbor projects conducted through fiscal year 2008 that were provided 
by these officials, including the specific project objectives, 
location, start and completion dates, acreage involved, the federal 
cost share of the project, and the type of contract used in conducting 
the project--service or timber sale--as well as the amount and value of 
any timber removed from federal land. We also visited several completed 
or ongoing Good Neighbor project sites located on both U.S. Forest 
Service land and BLM land, including six sites in Colorado and four in 
Utah, to obtain an understanding of the type of work performed and type 
of equipment required to conduct projects. During our site visits, we 
also reviewed selected Good Neighbor projects' contracting and 
financial files to obtain information on the planning, contracting, and 
monitoring processes each agency uses on Good Neighbor projects. We 
also obtained, through telephone interviews and e-mail, additional 
project information from U.S. Forest Service and state districts that 
we did not visit. We assessed the reliability of the project data we 
obtained by comparing a random sample of data provided to us by agency 
and state officials with similar information we had obtained directly 
from project files. We further assessed the reliability of timber sales 
data we obtained from the U.S. Forest Service's timber sale accounting 
system by conducting telephone interviews with a U.S. Forest Service 
official responsible for entering data into the system, maintaining 
these data, and preparing reports using system data. In addition, GAO 
has previously assessed the reliability of data maintained in this 
system.[Footnote 25] To ensure that GAO's previous assessment was still 
accurate, we confirmed with the U.S. Forest Service that the 
information previously obtained on the reliability of the system 
remained relevant. As a result, we believe that the data we obtained 
from this system were sufficiently reliable for our purposes in 
conducting this review. 

To determine the federal and state guidance, procedures, and controls 
used to conduct projects under Good Neighbor authority, including state 
contracting requirements and timber sale procedures, we obtained 
documentation on Colorado's and Utah's procurement and contracting 
processes for acquiring services from vendors, including the 
requirements of each state concerning three fundamental principles of 
government contracting--transparency, competition, and oversight. 
Specifically, we chose several of the states' procurement rules related 
to these three areas to examine, and we interviewed procurement and 
contracting officials with CSU and the Utah Division of Purchasing to 
obtain additional information on how the states put these rules into 
practice when conducting Good Neighbor projects. We also compared these 
selected state procurement and contracting requirements with those in 
the Federal Acquisition Regulation, and with U.S. Forest Service and 
BLM procurement guidance, to identify similarities and differences. To 
identify the timber sale procedures being used in Good Neighbor 
projects, we interviewed U.S. Forest Service, BLM, CSFS, and UDFFSL 
officials to determine whether Good Neighbor timber sale operating 
procedures had been established and their composition. We reviewed 
joint guidance prepared by the U.S. Forest Service and CSFS on 
conducting Good Neighbor projects to determine the type and extent of 
requirements incorporated. We also compared federal and state timber 
sale contracts and interviewed timber sale officials with the U.S. 
Forest Service in Colorado to obtain their opinions on differences 
between the two types of contracts, as well as any resulting effects on 
federal timber sale accountability. 

Finally, to identify successes, challenges, and lessons learned that 
the federal and state agencies experienced using Good Neighbor 
authority, we interviewed U.S. Forest Service, BLM, CSFS, and UDFFSL 
officials who had participated in Good Neighbor projects to obtain 
their views on the successes and challenges associated with the 
authority, including the factors they believe contributed to these 
successes and challenges and the measures they believe could be taken 
in the future to overcome these challenges. For example, we interviewed 
officials from five U.S. Forest Service ranger districts as well as 
officials from five CSFS district offices who had participated in Good 
Neighbor projects. We also obtained opinions about Good Neighbor 
authority from several state officials who had not participated in Good 
Neighbor projects, as well as their reasons for not participating. To 
obtain information on the potential uses of Good Neighbor authority in 
other states, we asked federal and state officials familiar with Good 
Neighbor authority, as well as representatives from the National 
Association of State Foresters, to identify states they believed would 
be the best candidates for us to interview regarding potential use of 
the authority. From the states that they recommended, we selected 
Idaho, Oregon, and Wyoming. We then interviewed officials in those 
states to discuss their opinions on whether Good Neighbor authority 
would be successful in their states, the factors for success, and any 
concerns that they believed would need to be addressed. We also spoke 
with other interested parties, including representatives of six 
environmental groups--based in Colorado, Utah, and other western 
states--and two industry groups--one based in Washington, D.C., and the 
other based in South Dakota--to get their opinions on how well Good 
Neighbor authority was being implemented in Colorado and Utah, and the 
factors that would be important for success if Congress were to expand 
the authority to other states. 

We conducted this performance audit from June 2008 through February 
2009 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the U.S. Department of Agriculture's Forest 
Service: 

USDA: 
United States: 
Forest	Service: 

Washington Office: 

1400 Independence Avenue, SW: 
Washington, DC 20250: 

Agriculture	
File Code: 2520/6320/2400
Date: 

February 13, 2009: 

Ms. Robin M. Nazzaro: 
Director, Natural Resources and Environment:  
Government Accountability Office: 
441 G.Street, NW: 
Washington, DC 20548: 

Dear Ms. Nazzaro: 

Thank you for the opportunity to review and comment on the draft 
Government Accountability Office report GAO-09-277, "Federal Land 
Management: Additional Documentation of Agency Experiences with Good 
Neighbor Authority Could Enhance Its Future Use". The Forest Service 
generally agrees with the GAO findings. 

Under the first recommendation, written policy for federal timber 
accountability will be developed in collaboration with each state. 
Regarding the second recommendation, the draft GAO audit report does a 
good job of documenting the information gathered in the audit of the 
two states currently having Good Neighbor Authority. We will provide 
the report to these current users and also to prospective user states 
prior to their receiving and implementing the authority. 

See comment 1. 

If you have any questions, please contact Sandy T. Coleman, Assistant 
Director for GAO/OIG Audit Liaison Staff, at 703-605-4699. 

Sincerely,

Signed by: 

Abigail R. Kimbell: 
Chief: 
cc: Tom Peterson, Ronald Hooper, Anne Zimmermann, Sandy T Coleman

GAO Comment: 

1. The U.S. Forest Service noted in its comments that it will address 
our recommendation about documenting experiences with Good Neighbor 
projects by providing our report to current and prospective users of 
the authority. While we are pleased that the U.S. Forest Service 
believes our report accurately documents lessons learned to date, we 
believe the agency will need to provide additional details if future 
users are to fully benefit from this information. For example, while 
our report includes a general description of the primary reasons for 
choosing Good Neighbor authority to conduct certain projects, it does 
not include a detailed discussion of the potential costs and benefits 
associated with this decision, which may prove beneficial to managers 
as they assess the applicability of the authority to future projects. 
As a result, we continue to believe it will be important for the U.S. 
Forest Service to systematically collect and document information on 
its experiences using Good Neighbor authority, and that this 
information should go beyond that contained in our report. 

[End of section] 

Appendix III: Comments from the Department of the Interior: 

United States Department of the Interior: 

Office Of The Secretary: 
Washington, D.C. 20240: 

February 17, 2009: 

Ms. Robin M. Nazzaro: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office 
441 G Street, N.W.: 
Washington, D.C. 20548-0001: 

Dear Ms. Nazzaro: 

Thank you for the opportunity to review and comment on the Government 
Accountability Office's draft report entitled "Federal Land Management: 
Additional Documentation of Agency Experiences with Good Neighbor 
Authority Could Enhance Its Future Use," (GAO-09-277). 

The Department of the Interior concurs with the recommendations for 
executive action and generally agrees with the interpretation of the 
Bureau of Land Management's use of the Good Neighbor authority and its 
efforts to mitigate the impact of wildland fires and restore forest 
ecosystem health. Although the BLM does not have specific Good Neighbor 
guidance in place, written procedures exist with interagency and 
assistance agreements; service contracts; and permitting and sale of 
forests products, which all provide guidance on partnerships with 
private and state entities and Good Neighbor projects. We are also 
aware that Good Neighbor projects currently are focused in the Wildland 
Urban Interface (WUI) areas, however, we believe that projects outside 
of the WUI should continue to be implemented. Imposing area-specific 
limitations conflicts with the intent of the Good Neighbor Authority 
and will further impede the efficiency of operations in conducting 
landscape-level projects between federal, state, and private 
landowners. 

We hope these general comments will provide clarity and further support 
the statements received from various BLM officials, and will be 
considered when preparing the final report. If you have any questions, 
please contact Scott Lieurance, Chief, Division of Forests and 
Woodlands, at (202) 452-0316 or LaVanna Stevenson-Harris, BLM Audit 
Liaison Officer, at (202) 785-6580. 

Sincerely, 

Signed by: 

Richard T. Cardinale: 
Chief of Staff: 
Land and Minerals Management: 

[End of section] 

Appendix IV: Comments from the Colorado State Forest Service: 

Colorado State Forest Service: 

Colorado State University
Fort Collins, Colorado 80523-5060: 
(970) 491-6303: 
FAX: (970) 491-7736: 

February 4, 2009: 

Ms. Robin Nazzaro: 
Director, Natural Resources and Environment: 
United States Government Accountability Office: 
441 G Street, NW: 
Washington, D.C. 20548: 

Dear Ms. Nazarro, 

On behalf of the Colorado State Forest Service and Colorado State 
University, I want to sincerely thank you for the opportunity to 
participate in and review the findings of the audit of the use of Good 
Neighbor Authorities in Colorado. We concur with both the findings of 
the audit and the recommendations. We will take immediate steps to 
incorporate these recommendations into our operating procedures for 
application in future Good Neighbor projects. 

Good Neighbor Authorities are a valuable tool for achieving cross-
boundary implementation of wildfire hazard mitigation, forest health 
and other necessary treatments and projects. As you are aware, these 
authorities expire September 30, 2009. We encourage the US Forest 
Service, Bureau of Land Management, and Congress to make 
these authorities permanent. As they do this, we sincerely hope that as 
much freedom and flexibility as possible can be retained in the use of 
these authorities. 

While we in Colorado will continue to use these authorities primarily 
where similar treatments are occurring or planned on adjacent non-
federal lands, it would be valuable to have the opportunity to utilize 
the authorities on areas distant from non-federal lands, as is now 
possible in Utah. 

Sincerely, 

Signed by: 
Jeff Jahnke: 

State Forester/Director: 
Colorado State Forest Service: 

cc: Sen. Michael Bennet, Colorado: 
Sen. Jeff Bingaman, New Mexico: 
Sen. Mark Udall, Colorado: 
Rep. Mike Coffman, Colorado: 
Rep. Diana DeGette, Colorado: 
Rep. Doug Lamborn, Colorado: 
Rep. Betsy Markey, Colorado: 
Rep. Ed Perlmutter, Colorado: 
Rep. Jared Polis, Colorado: 
Rep. John Salazar, Colorado:

[End of section] 

Appendix V: Comments from the Utah Division of Forestry, Fire and State 
Lands: 

State of Utah: 

Department Of Natural Resources: 

Michael R. Styler: 
Executive Director: 

Division of Forestry, Fire and State Lands

Richard J. Buehler: 
State Forester/Division Director: 

Jon M. Huntsman, Jr.: 
Governor: 

Gary R. Herbert	
Lieutenant Governor: 

February 10, 2009: 

Ms. Robin Nazzaro: 
Director, Natural Resources and Environment: 
U.S. Government Accountability Office: 
441 G St., N.W.: 
Washington, D.C. 20548: 

Dear Ms. Nazzaro:

Thank you for the opportunity to comment on Federal Land Management
Additional Documentation of Agency Experiences with Good Neighbor 
Authority Could Enhance Its Future Use (GAO-09-277). 

Overall, we feel that both the document and (especially) the 
professionalism shown by your staff were outstanding. We agree with the 
GAO's findings. The document is also very informative, organizing 
various background, historical, and other information into one concise 
and well written reference. 

The Good Neighbor Authority is very important to us, and we hope that 
it not only continues, but expands in scope and allows us to 
participate in more challenging and interesting projects. We would 
also support expanding the participation to other federal agencies such 
as the Bureau of Land Management (BLM). Some of the problems the 
document reveals (such as timber sale contracts in Colorado) serve as 
important cautions as we work to expand the scope of projects here in 
Utah. 

Our only significant concern is the recommendation for additional 
documentation of procedures, successes, and other administrative tasks. 
Whether these tasks fall to federal or state agencies (or both), 
this represents additional administrative burden at a time when other 
cooperative programs are also increasing these requirements. We 
understand the need to ensure that public funds are being spent 
legally and efficiently, but please recognize that additional 
administrative tasks reduce the amount of actual project work that gets 
done on the ground. 

Thank you once again for allowing us to participate in a very important 
and informative process. 

Sincerely, 

Signed by: 

Geoffrey McNaughton, Ph.D.: 
Forest Programs Administrator: 

1594 West North Temple, Suite 3520, PO Box 145703, Salt Lake City, UT 
84114,5703: 

telephone (801) 538-5555: 
facsimile (801) 533-4111: 
TTY (801) 538-7458: 
[hyperlink, http://www.ffsl.utah.gov]: 

[End of section] 

Appendix VI: 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, Steve Gaty, Assistant 
Director; David Brown; and Greg Carroll made key contributions to this 
report. Cindy Gilbert, Rich Johnson, Alison O'Neill, Jena Sinkfield, 
and Bill Woods also made important contributions to this report. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 106-291, § 331 (2000). 

[2] For major actions that may significantly affect the quality of the 
human environment, the act requires all federal agencies, including the 
U.S. Forest Service and BLM, to analyze the potential environmental 
effects of the proposed action. See 42 U.S.C. § 4332(2)(C). 

[3] Pub. L. No. 108-447, § 336 (2004). 

[4] S. 2468 (2007). 

[5] S. 3302 (2008). The bill would have covered any state "that 
contains National Forest System land or Bureau of Land Management land 
located west of the 100th meridian." 

[6] Other federal agencies with wildland fire management 
responsibilities include the Bureau of Indian Affairs, Fish and 
Wildlife Service, and National Park Service, all of which are within 
the Department of the Interior. 

[7] Under the Healthy Forests Restoration Act of 2003, a community 
wildfire protection plan is a plan--developed primarily by state and 
local agencies in consultation with interested parties and federal land 
management agencies--that identifies and prioritizes areas in and near 
a community for fuel reduction treatments and recommends the types of 
treatments to be used. 

[8] The National Fire Plan comprises multiple documents, including (1) 
a September 2000 report from the Secretaries of Agriculture and the 
Interior to the President in response to the wildland fires of 2000, 
(2) congressional direction accompanying substantial new 
appropriations in fiscal year 2001, and (3) several strategies to 
implement all or parts of the plan. For a description of these 
documents and their contents, goals, and relationships to one another, 
see GAO, Severe Wildland Fires: Leadership and Accountability Needed to 
Reduce Risks to Communities and Resources, GAO-02-259 (Washington, 
D.C.: Jan. 31, 2002). 

[9] Several of these forests have been combined into larger 
administrative units composed of two or more forests. In this report, 
we discuss national forests individually, except where noted. 

[10] For the purposes of this report, we refer to UDFFSL's six 
administrative areas as "districts." 

[11] Our count of "projects" includes those Good Neighbor projects that 
have been initiated under an agreement or task order between the 
federal agency and the state; projects can be subsequently modified to 
change the cost, scope, or schedule of work. In addition, "conducted" 
projects include all that have received approval by CSFS and the U.S. 
Forest Service or BLM as of fiscal year 2008, whether planned, 
initiated, or completed. 

[12] Established in 1918, Denver Water is Colorado's oldest and largest 
water utility. Its board is responsible for ensuring a continuous 
supply of water to the city and county of Denver and to the nearly 50 
percent of Denver Water customers who live in the surrounding suburbs. 

[13] This administrative role includes duties such as advertising the 
sale, determining the volume of timber on site, and monitoring the 
buyer's work after the contract is awarded. 

[14] As of September 30, 2008, 11 of these timber sales had been 
completed or closed, 1 was under way, and 4 were in the planning stage. 

[15] The U.S. Forest Service's standard unit of measure for wood 
products is 100 cubic feet, or 1 CCF. Thus, 345,000 cubic feet of 
timber would be measured as 3,450 CCF. The total amount of timber and 
associated value from these sales is based on data obtained from the 
U.S. Forest Service's Timber Sale Accounting System. For more 
information on this system's process for tracking and accounting for 
timber, see GAO, Federal Timber Sales: Forest Service Could Improve 
Efficiency of Field Level Timber Sales Management by Maintaining More 
Detailed Data, GAO-07-764 (Washington, D.C.: June 27, 2007). 

[16] Information on the value of the timber removed on a third project 
located in the San Juan National Forest was not included in the timber 
contract. 

[17] The U.S. Forest Service has Good Neighbor "master" agreements in 
place with Colorado and Utah, and also initiates separate agreements, 
referred to as "task orders," for each Good Neighbor project. BLM has 
initiated one agreement for its Boulder County fuel reduction projects 
and amends this agreement as projects are modified or added, but has no 
master agreement in place. 

[18] BLM calls these task orders "agreement modifications." 

[19] A fixed-price contract provides for a price that is not subject to 
adjustment on the basis of the contractor's cost experience in 
performing the contract. 

[20] The act, 29 U.S.C. §§ 1801-1872, was enacted to eliminate 
activities that are detrimental to migrant and seasonal agricultural 
workers, to require registration of farm labor contracts, and to ensure 
necessary protections for workers. 

[21] See Morante-Navarro v. T&Y Pine Straw, 350 F.3d 1163, 1170-72 & 
n.4 (11th Cir. 2003) (and cases cited). 

[22] According to a contracting officer in Utah's Division of 
Purchasing, state agencies are permitted to enter into agreements with 
other agencies and with political subdivisions of the state, such as 
counties, outside of the standard state contracting process. The state 
presumes that two of its government entities collaborating on a project 
will be less costly and more efficient than hiring a private 
contractor, because there is no profit motive. 

[23] For more information about stewardship contracting, see GAO, 
Federal Land Management: Additional Guidance on Community Involvement 
Could Enhance Effectiveness of Stewardship Contracting, [hyperlink, 
http://www.gao.gov/products/GAO-04-652] (Washington, D.C.: June 14, 
2004); and Federal Land Management: Use of Stewardship Contracting Is 
Increasing, but Agencies Could Benefit from Better Data and Contracting 
Strategies, [hyperlink, http://www.gao.gov/products/GAO-09-23] 
(Washington, D.C.: Nov. 13, 2008). 

[24] [hyperlink, http://www.gao.gov/products/GAO-09-23]. 

[25] GAO, Federal Timber Sales: Forest Service Could Improve Efficiency 
of Field-Level Timber Sales Management by Maintaining More Detailed 
Data, [hyperlink, http://www.gao.gov/products/GAO-07-764] (Washington, 
D.C.: June 27, 2007). 

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