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dysfunctional agency policy. This policy results "in unnecessary delays, and costly expenditures of 

 taxpayer dollars that could be more wisely spent by the Forest Service to achieve its multiple-use 

 objectives. Plainly speaking, time and money the Forest Service spends on appeals and litigation 

 is time and money not spent on trail maintenance, improving wildlife habitat, or protecting forest 

 and rangeland health. 



In 1985, the Forest Service received 118 appeals against timber sales. This doubled in 1986, 

 and by 1990, the Forest Service received 11 54 appeals against 585 timber sales. Since 1990, this 

 rate has dropped somewhat, but then the number of timber sales has dropped as well. 



It seems unlikely that the problem of excessive administrative appeals results from a lack of 

 diligence on the part of the Forest Service. According to General Accounting Office testimony given 

 before the Senate Subcommittee on Forest and Public Land Management, the "Forest Service 

 estimates that it spends more than $250 million each year conducting environmental analyses and 

 preparing about 20,000 environmental documents to support project-level decisions—consuming 

 about 18 percent of the funds available to manage the National Forest System, and an estimated 30 

 percent of its field units' staff resources. According to the Forest Service, it has conducted extensive, 

 complies analyses in order to comply with NEPA and other environmental laws and to avoid or 

 prevail against challenges to its compliance with these laws at the project level." (GAO testimony 

 ofBarryT. Hill, 1/25/96) 



This would seem to be bom out by the relatively few times these appeals are successfiil. In 

 most cases, the original Forest Service decision is confirmed. 



Unfortunately, some special interest groups regard administrative appeals as just the first 

 rung on the ladder when it comes to stopping timber sales. According to the Region 8 Forest Service 

 office in Atlanta, there has been a shift in tactics from appeals to litigation in Fiscal Year 1995. The 

 Forest Service estimates that appeals have dropped by 1/3 while litigation has tripled. 



There no longer seems reason to doubt the misuse of the appeals process by some groups. 

 The actions of these groups shows a clear pattern that I believe attempts to thwart the multiple-use 

 objectives of the Forest Service. I doubt the adminisfrative appeals process was ever intended to 

 grant so much power to a minority of the public opposed to timber sales. And I do believe it is a 

 minority. At the recent Seventh American Forest Congress, 91 percent of the delegates rejected the 



