See comment 1.

Now on p. 16.

See comment 2.

Now on pp. 6 and 30.

Thank you for the opportunity to comment on the subject report.
Copies of the report were distributed to the Area Forestry programs
as well as to the Forestry Program Directors for official review
and comment in order that a good representation of all offices
effected could be provided. Overall we found the report to be well
constructed and, with a few exceptions noted in
our response,

accurate. Following is an accumulation of the Area and Central
Office comments along with our response to the one recommendation
made in the draft report which appears on pages 6 and 28 regarding
the Forest Development Program.

GENERAL COMMENTS

Although GAO correctly states that it is the policy of the
Bureau of Indian Affairs to secure approval or authorization
for the sale of forest products from the tribe, or the
allottee, it must be understood that the actual "approval" of
the sale rests with the Secretary of the Interior. In fact, 25
CFR 163.7(b) provides the Secretary the authority to sell
timber without the consent of the owners under certain
circumstances. The statements made referring to the "approval"
of timber sales by the tribe should be changed to read
"authorization" and in light of 25 CFR 163.7(b), the statement
made on page 15, paragraph 2, that the tribe "must
individual timber sales" should be deleted.

approve all

The figure of 5.7 million acres given on page 2, paragraph 1

for commercial forest land is incorrect. The Bureau of Indian Affairs forestry program currently manages 15.99 million acres of forest land of which 10.60 million acres are considered to be "commercial forest".

RECOMMENDATIONS

On pages 6 and 28 of the draft report, GAO recommends that the
Secretary of the Interior direct the Assistant Secretary for
Indian Affairs to determine the most important and most cost
effective forest development needs consistent with current

Comments From the Department of
the Interior

reservations'

-2

forest management plans and annual harvesting activity and annually prioritize these needs to support the Bureau's budget requests for forest development funding.

GAO recommends further that Congress discontinue funding specifically to eliminate the 1977 forest development backlog and base funding instead, on annual determinations by the Bureau of the most important and highest priority forest development needs.

BUREAU RESPONSE TO RECOMMENDATIONS

Congress has advised, through the House of Representatives Report on the Department of the Interior and Related Agencies Appropriations Bill, 1991, that the Bureau should update its inventory of the backlog of forest development work, including an update of the status reports and accomplishments. Congress further advised because so much new acreage has been added since the time the original backlog was developed, the Bureau should include in the update all the newly acquired lands since 1977 requiring forest development work and should begin to make the forest development funds available to these lands.

Comments From the Department of
the Interior

-3

See comment 3.

In addition to this response, we are including copies of those comments received from the Albuquerque, Sacramento, Phoenix, and Navajo Area Offices for your information. Any questions on this report or the enclosed comments should be directed to the Chief, Division of Forestry at FTS 268-6067 or commercial (202) 208-6067.

Comments From the Department of
the Interior

GAO Comments

The following are GAO's comments on the Department of the Interior's letter dated January 18, 1991.

1. Bureau policy is to secure tribal approval or authorization for timber sales even though actual approval of the sales rests with the Secretary of the Interior. The authority provided the Secretary in 25 CFR 163.7 (b) to sell timber without the consent of the owner is directed at very specific situations and does not represent the normal timber sales process. We revised our report, where appropriate, to address this comment.

2. The 10.6 million acres of commercial forests consists of 5.7 million acres of commercial timberland and 4.8 million acres of commercial woodlands. The focus of our work was the management of the 5.7 million acres of commercial timberland. The report was revised to clearly distinguish between commercial timberland and commercial woodlands.

3. The comments referred to contained more detailed comments of an editorial nature which we considered in finalizing our report.

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