Forest Service
Vegetation Management Projects Approved during Calendar Years 2003 through 2005 Using Categorical Exclusions
Gao ID: GAO-07-1016T June 28, 2007
The Forest Service manages over 192 million acres of land, often conducting a variety of vegetation management projects such as thinning trees. Before approving projects that may significantly affect the environment, the National Environmental Policy Act (NEPA) generally requires the Forest Service to prepare an environmental assessment (EA) or an environmental impact statement (EIS). However, the Forest Service can decide not to prepare an EA or EIS if the project involves categories of activities that it previously found to have no significant environmental effect (categorical exclusions). As of 2003, the Forest Service had established one such exclusion affecting vegetation management projects and has since added four new ones. This testimony is based on GAO's report, Forest Service: Use of Categorical Exclusions for Vegetation Management Projects, Calendar Years 2003 through 2005 (GAO-07-99). For vegetation management during these years, GAO determined (1) how many projects the Forest Service approved, including those approved using categorical exclusions; (2) which categorical exclusions it used to approve projects; and (3) if categorical exclusions are not being used in any field offices, why. To answer these questions, GAO surveyed Forest Service officials at all 155 national forests.
The Forest Service approved 3,018 vegetation management projects to treat about 6.3 million acres during calendar years 2003 through 2005. Of these projects, the agency approved about 28 percent using an EA or EIS to treat about 3.4 million acres, while it approved the remainder using categorical exclusions. Although 72 percent of the projects were approved using categorical exclusions, these projects accounted for less than half--46 percent--of the total treatment acres. Forest Service officials said that the number and size of projects and types of environmental analyses used varied, depending upon forest size, ecology, and location. Of the vegetation management projects approved using categorical exclusions, half were approved using a categorical exclusion for improving timber stands or wildlife habitat, an exclusion in place before 2003. The agency used the newer four categorical exclusions for approving the remainder. Of these four, the agency primarily used the categorical exclusion for reducing hazardous fuels, followed by those for salvaging dead or dying trees, conducting limited harvests of live trees, and removing trees to control the spread of insects or disease. The projects approved using the categorical exclusion to improve timber stands or wildlife habitat accounted for about 2.4 million of the 2.9 million acres to be treated under projects approved using one of the five categorical exclusions. About 11 percent of the Forest Service's 509 field offices had not used any of the five vegetation management categorical exclusions during the 3-year period. The reasons why field offices had not used a specific categorical exclusion varied by office location and categorical exclusion. For example, a majority of the field offices--about 91 percent--had not used the categorical exclusion for the removal of trees to control the spread of insects or disease, primarily because these offices did not have a sufficient number of insect- or disease-infested trees. About 32 percent of the field offices had not used the categorical exclusion to improve timber stands or wildlife habitat, primarily because no projects of this type had been undertaken during the 3-year period.
GAO-07-1016T, Forest Service: Vegetation Management Projects Approved during Calendar Years 2003 through 2005 Using Categorical Exclusions
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Testimony:
Before the Subcommittee on National Parks, Forests and Public Lands,
Committee on Natural Resources, House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery Expected at 10:00 a.m. EDT:
Thursday, June 28, 2007:
Forest Service:
Vegetation Management Projects Approved during Calendar Years 2003
through 2005 Using Categorical Exclusions:
Statement of Robin M. Nazzaro, Director:
Natural Resources and Environment:
GAO-07-1016T:
GAO Highlights:
Highlights of GAO-07-1016T, testimony before the Subcommittee on
National Parks, Forests and Public Lands, Committee on Natural
Resources, House of Representatives
Why GAO Did This Study:
The Forest Service manages over 192 million acres of land, often
conducting a variety of vegetation management projects such as thinning
trees. Before approving projects that may significantly affect the
environment, the National Environmental Policy Act (NEPA) generally
requires the Forest Service to prepare an environmental assessment (EA)
or an environmental impact statement (EIS). However, the Forest Service
can decide not to prepare an EA or EIS if the project involves
categories of activities that it previously found to have no
significant environmental effect (categorical exclusions). As of 2003,
the Forest Service had established one such exclusion affecting
vegetation management projects and has since added four new ones.
This testimony is based on GAO‘s report, Forest Service: Use of
Categorical Exclusions for Vegetation Management Projects, Calendar
Years 2003 through 2005 (GAO-07-99). For vegetation management during
these years, GAO determined (1) how many projects the Forest Service
approved, including those approved using categorical exclusions; (2)
which categorical exclusions it used to approve projects; and (3) if
categorical exclusions are not being used in any field offices, why. To
answer these questions, GAO surveyed Forest Service officials at all
155 national forests.
What GAO Found:
The Forest Service approved 3,018 vegetation management projects to
treat about 6.3 million acres during calendar years 2003 through 2005.
Of these projects, the agency approved about 28 percent using an EA or
EIS to treat about 3.4 million acres, while it approved the remainder
using categorical exclusions. Although 72 percent of the projects were
approved using categorical exclusions, these projects accounted for
less than half”46 percent”of the total treatment acres. Forest Service
officials said that the number and size of projects and types of
environmental analyses used varied, depending upon forest size,
ecology, and location.
Figure: Percentage of Vegetation Management Projects and Treatment
Acres Approved Using an EA, EIS, or Categorical Exclusion, Calendar
Years 2003 through 2005:
[See PDF for Image]
Source: GAO.
[End of figure]
Of the vegetation management projects approved using categorical
exclusions, half were approved using a categorical exclusion for
improving timber stands or wildlife habitat, an exclusion in place
before 2003. The agency used the newer four categorical exclusions for
approving the remainder. Of these four, the agency primarily used the
categorical exclusion for reducing hazardous fuels, followed by those
for salvaging dead or dying trees, conducting limited harvests of live
trees, and removing trees to control the spread of insects or disease.
The projects approved using the categorical exclusion to improve timber
stands or wildlife habitat accounted for about 2.4 million of the 2.9
million acres to be treated under projects approved using one of the
five categorical exclusions.
About 11 percent of the Forest Service‘s 509 field offices had not used
any of the five vegetation management categorical exclusions during the
3-year period. The reasons why field offices had not used a specific
categorical exclusion varied by office location and categorical
exclusion. For example, a majority of the field offices”about 91
percent”had not used the categorical exclusion for the removal of trees
to control the spread of insects or disease, primarily because these
offices did not have a sufficient number of insect- or disease-infested
trees. About 32 percent of the field offices had not used the
categorical exclusion to improve timber stands or wildlife habitat,
primarily because no projects of this type had been undertaken during
the 3-year period.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-1016T].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Robin M. Nazzaro (202)
512-3841 or nazzaror@gao.gov.
[End of section]
Mr. Chairman and Members of the Subcommittee:
I am pleased to be here today to discuss the Forest Service's use of
categorical exclusions to approve vegetation management
projects.[Footnote 1] As you know, under the National Environmental
Policy Act of 1969 (NEPA), agencies evaluate the likely environmental
effects of proposed projects using an environmental assessment (EA) or
a more detailed environmental impact statement (EIS) if the projects
are likely to significantly affect the environment. However, if an
agency determines that the activities of a proposed project fall within
a category of activities that it has already determined have no
significant environmental impact, it may approve the project without an
EA or EIS--instead granting the project a categorical exclusion. As of
2003, the Forest Service had established one categorical exclusion for
vegetation management activities that covered certain activities
intended to improve timber stands or wildlife habitat. In 2003, it
added four more categorical exclusions to (1) reduce hazardous fuels,
(2) allow the limited harvest of live trees, (3) salvage dead or dying
trees, and (4) remove trees to control the spread of insects or
disease.
The extent to which the Forest Service approves vegetation management
projects using categorical exclusions has been controversial. Critics
assert that the Forest Service's use of them is an attempt to
circumvent NEPA by precluding the need to perform an EA or EIS. In
contrast, supporters state that current analysis and documentation
requirements for an EA or EIS under NEPA are too burdensome and that
the categorical exclusions allow the agency to more efficiently
implement vegetation management projects. Little is known about the
Forest Service's use of the vegetation management categorical
exclusions because, prior to 2005, the agency did not maintain
nationwide data on their use.
My testimony today summarizes the findings of our October 2006 report
that discusses for calendar years 2003 through 2005, how many
vegetation management projects the Forest Service approved, including
how many were approved using categorical exclusions; which categorical
exclusions the agency used; and the primary reasons why Forest Service
ranger districts are not using the categorical exclusions for
vegetation management.[Footnote 2] This report is based on information
we collected from all 155 national forests representing 509 ranger
districts that manage National Forest System lands. It is also based on
interviews we conducted at 23 ranger districts at 12 national forest
units.
Summary:
In summary, from calendar years 2003 through 2005, the Forest Service
approved 3,018 vegetation management projects to treat about 6.3
million acres. Most of these projects--about 72 percent--were approved
using categorical exclusions to treat slightly less than half of the
acres--2.9 million--while about 28 percent were approved using an EA or
EIS to treat the remaining 3.4 million acres. Even though more projects
were approved using categorical exclusions than using an EA or EIS, the
total treatment acreage was about the same because the relative size of
projects approved using categorical exclusions was much smaller than
those approved using an EA or EIS. According to Forest Service
officials, the number and size of vegetation management projects and
type of environmental analysis used varied depending upon the forest's
size, ecology, and location.
Of the nearly 2,200 vegetation management projects approved using
categorical exclusions during calendar years 2003 through 2005, the
Forest Service most frequently used the categorical exclusion for
improving timber stands or wildlife habitat. This categorical exclusion
accounted for half of the projects approved using the five vegetation
management categorical exclusions. For the remaining projects, the
Forest Service primarily used the categorical exclusion for reducing
hazardous fuels, followed by salvaging dead or dying trees, conducting
limited timber harvests of live trees, and removing trees to control
the spread of insects or disease. While the categorical exclusion for
timber stand or wildlife habitat improvement was the most frequently
used and included the most treatment acres--about 2.4 million of the
2.9 million acres included in all projects approved using categorical
exclusions--92 percent of the projects approved using this categorical
exclusion were smaller than 5,000 acres.
Of the 509 ranger districts, about 11 percent had not used any of the
five vegetation management categorical exclusions during the 3-year
period. The percentage of ranger districts not using a specific
categorical exclusion varied by type of categorical exclusion, however.
Just over 90 percent of the 509 ranger districts had not used the
categorical exclusion for the removal of trees to control the spread of
insects or disease and about 32 percent had not used the categorical
exclusion to improve timber stands or wildlife habitat. Reasons cited
for not using a categorical exclusion varied by type of categorical
exclusion and ranger district. For example, not all ranger districts
had used the categorical exclusion for removing insect-or disease-
infested trees because they did not have these types of trees or
because projects for removing such trees had already been or were to be
included in an EA or EIS.
Background:
The Forest Service is responsible for managing over 192 million acres
of public lands--about 30 percent of all federal lands in the United
States. In carrying out its responsibilities, the Forest Service
traditionally has administered its programs through 9 regional offices,
155 national forests, 20 national grasslands, and several hundred
ranger districts.
Under NEPA, agencies such as the Forest Service generally evaluate the
likely effects of projects they propose using a relatively brief EA or,
if the action would be likely to significantly affect the environment,
a more detailed EIS. However, an agency may generally exclude
categories of actions from the requirement to prepare an EA or EIS if
it has determined that the actions do not individually or cumulatively
have a significant impact on the environment--these categories are
known as categorical exclusions. The agency may then approve projects
fitting within the relevant categories using these predetermined
categorical exclusions rather than carrying out project-specific
environmental analyses. For a project to be approved using a
categorical exclusion, the agency must determine whether any
extraordinary circumstances exist in which a normally excluded action
may have a significant effect.[Footnote 3],[Footnote 4]
As of 2003, the Forest Service had one categorical exclusion available
for use in approving certain vegetation management activities--timber
stand or wildlife habitat improvement--that has no acreage
limitation.[Footnote 5] In 2003, after reviewing and evaluating data on
the environmental effects of vegetation management projects that had
been carried out by the national forests, the Forest Service added four
new vegetation management categorical exclusions, each of which has
acreage limitations: (1) hazardous fuels reduction activities using
prescribed fire, not to exceed 4,500 acres, and mechanical methods such
as thinning, not to exceed 1,000 acres; (2) limited timber harvests of
live trees, not to exceed 70 acres; (3) salvage of dead or dying trees,
not to exceed 250 acres; and (4) removal of trees to control insects
and disease, not to exceed 250 acres.[Footnote 6] Appendix I provides
more detailed information on the Forest Service's five vegetation
management categorical exclusions.
Categorical Exclusions Were Used to Approve the Majority of Vegetation
Management Projects and about Half of the Total Treatment Acres:
For calendar years 2003 through 2005, the Forest Service approved about
3,000 vegetation management projects to treat about 6.3 million acres.
Of these projects, the Forest Service approved about 70 percent using
categorical exclusions and the remaining projects using an EA or EIS.
Although a majority of projects were approved using categorical
exclusions, these projects accounted for slightly less than half of the
total treatment acres because the size of these projects was much
smaller than those approved using an EA or EIS. Table 1 provides this
information in greater detail.
Table 1: Number of Vegetation Management Projects Approved and
Treatment Acres for Different Types of Environmental Analyses (Calendar
Years 2003 through 2005):
Number of projects (percent of total);
Type of environmental analysis: Environmental impact statement: 141
(4.7);
Type of environmental analysis: Environmental assessment: 690 (22.9);
Type of environmental analysis: Categorical exclusion: 2,187 (72.5);
Total: 3,018 (100.0)[A].
Number of treatment acres (percent of total);
Type of environmental analysis: Environmental impact statement: 899,225
(14.4);
Type of environmental analysis: Environmental assessment: 2,506,984
(40.0);
Type of environmental analysis: Categorical exclusion: 2,856,472
(45.6);
Total: 6,262,681 (100.0)[A].
Median number of treatment acres (range)[B];
Type of environmental analysis: Environmental impact statement: 2,768
(51 to 60,000);
Type of environmental analysis: Environmental assessment: 1,366 (1 to
124,971);
Type of environmental analysis: Categorical exclusion: 215 (1 to
97,326);
Total: 375 (1 to 124,971).
Source: GAO.
[A] Numbers may not total to 100 percent due to rounding.
[B] Of the 3,018 vegetation management projects, 113 had no acreage or
an unknown acreage, according to the Forest Service. The acreage
associated with a vegetation management project may be zero or unknown
because, among other reasons, the unit of measure for the project is in
miles of roadside to be treated or number of trees to be removed. These
projects were not used in calculating the median or range of treatment
acres.
[End of table]
Our analysis of the project data also revealed that the total number of
vegetation management projects approved, including those approved using
categorical exclusions, varied over the 3-year period, while the number
of treatment acres did not. As can be seen in figure 1, the number of
projects approved using an EA or EIS varied little over the 3-year
period; however, the number of projects approved using categorical
exclusions increased from January 2003 through December 2004--primarily
because of an increased use of the four new categorical exclusions--and
then decreased from January through December 2005. Forest Service
officials said that any number of factors could have influenced the
increase and subsequent decrease in the use of categorical exclusions
over the 3-year period. However, given the relatively short period of
time during which the four new categorical exclusions were in use,
these officials said that it was not possible to speculate why the
decrease had occurred.
Figure 1: Number of Vegetation Management Projects Approved Using an
EA, EIS, or Categorical Exclusion (Calendar Years 2003 through 2005):
[See PDF for image]
Source: GAO.
[End of figure]
In contrast, as can be seen in figure 2, an analysis of the total
treatment acres included in projects approved using an EA, EIS, or a
categorical exclusion did not reveal any notable change over the 3-year
period.
Figure 2: Number of Treatment Acres Included in those Projects Approved
Using an EA, EIS, or Categorical Exclusion (Calendar Years 2003 through
2005):
[See PDF for Image]
Source: GAO.
[End of figure]
We also found that the number of vegetation management projects
approved, including those approved using categorical exclusions, varied
by Forest Service region and forest. For example, of all vegetation
management projects approved nationwide, Region 8--the Southern Region-
-accounted for about 29 percent, of which just over two-thirds were
approved using categorical exclusions. In contrast, Region 10--Alaska-
-accounted for about 2 percent of all vegetation management projects,
about 60 percent of which were approved using categorical exclusions.
According to several Forest Service officials, the number of vegetation
management projects approved and the type of environmental analysis
used in approving them depended on the forest's size, ecology, and
location, as the following illustrates:
* At the 1.8 million-acre Ouachita National Forest, a pine and hickory
forest in western Arkansas and southeastern Oklahoma, 163 projects were
approved--119 using categorical exclusions. Forest officials said the
forest has a very active vegetation management program because, among
other things, the types of trees located on the forest tend to
regenerate quickly and are an excellent product for milling. In
addition, a large timber harvest infrastructure is located nearby,
which helps ensure that timber sale contracts can be readily competed
and awarded.
* At the 28,000-acre Caribbean National Forest, a humid tropical forest
in Puerto Rico, no vegetation management projects were approved.
According to forest officials, the forest does not have an active
vegetation management program because the forest focuses more on
developing recreational sites and wildlife habitat and because the
island has no commercial infrastructure to support harvesting or
milling timber.
Appendix II provides detailed information on the number of vegetation
management projects and acres Forest Service regions approved using
different types of environmental analysis, for calendar years 2003
through 2005.
The Categorical Exclusion for Improving Timber Stands or Wildlife
Habitat Was the Most Frequently Used:
Of the almost 2,200 projects approved using categorical exclusions over
the 3-year period, the Forest Service most frequently used the
vegetation management categorical exclusion for improving timber stands
or wildlife habitat; this categorical exclusion was used on half of the
projects to treat about 2.4 million acres. As shown in table 2, for the
remaining projects, the Forest Service primarily used the categorical
exclusion for reducing hazardous fuels, followed by salvaging dead or
dying trees, conducting limited timber harvests of live trees, and
removal of trees to control the spread of insects or disease; in all,
these categorical exclusions were used to approve treatments on about a
half-million acres. In addition, the size of approved projects varied
depending on the categorical exclusion and any associated acreage
limitation.
Table 2: Number of Vegetation Management Projects Approved and
Treatment Acres for Different Types of Categorical Exclusions (Calendar
Years 2003 through 2005):
Number of projects (percent of total);
Improve timber stands or wildlife habitat (no acre limitation): 1,094
(50.0);
Hazardous fuels reduction (5,500-acre limitation): 485 (22.2);
Salvage of dead or dying trees (250-acre limitation): 264 (12.1);
Limited timber harvest of live trees (70-acre limitation): 220 (10.1);
Removal of insect-or disease- infested trees (250-acre limitation): 124
(5.7);
Total: 2,187 (100.0)[A].
Number of treatment acres (percent of total);
Improve timber stands or wildlife habitat (no acre limitation):
2,402,188; (84.1);
Hazardous fuels reduction (5,500-acre limitation): 405,546 (14.2);
Salvage of dead or dying trees (250-acre limitation): 28,939 (1.0);
Limited timber harvest of live trees (70-acre limitation): 10,541
(0.4);
Removal of insect-or disease-infested trees (250-acre limitation):
9,258 (0.3);
Total: 2,856,472 (100.0)[A].
Median number of treatment acres (range)[B];
Improve timber stands or wildlife habitat (no acre limitation): 433 (1
to 97,326);
Hazardous fuels reduction (5,500-acre limitation): 450 (1 to 4,637);
Salvage of dead or dying trees (250-acre limitation): 96 (1 to 250);
Limited timber harvest of live trees (70-acre limitation): 59 (1 to
70);
Removal of insect-or disease-infested trees (250-acre limitation): 8 (1
to 250);
Total: 215 (1 to 97,326).
Source: GAO.
[A] Numbers may not add to 100 percent due to rounding.
[B] Of the 2,187 vegetation management projects approved using
categorical exclusions, 71 had no acreage or an unknown acreage,
according to the Forest Service. The acreage associated with a
vegetation management project may be zero or unknown because, among
other reasons, the unit of measure for the project is listed as miles
of roadside to be treated or number of trees to be removed. These
projects were not used in the calculation of the median or range. In
addition, the Forest Service indicated that for 38 projects, in
addition to the categorical exclusion cited as being used, one or more
of the remaining four categorical exclusions was also used. We counted
only the first categorical exclusion cited.
[End of table]
According to Forest Service officials, a number of factors influenced
the reasons that the categorical exclusion for timber stand or wildlife
habitat improvement was used most frequently for the most treatment
acreage. For example, officials at the George Washington and Jefferson
National Forests and the Monongahela National Forest said they relied
on this categorical exclusion more than others because the use of this
category was consistent with their forest management plans, which
dictate the types of activities that may take place on their forests.
Santa Fe National Forest officials said that the forest has relied
heavily on this categorical exclusion because it does not have an
acreage limitation.
We also analyzed the categorical exclusion for timber stand or wildlife
habitat improvement to determine whether its lack of size limitation
resulted in projects that are larger than those undertaken using the
other four exclusions that have acreage limitations. We found that
almost 92 percent of the 1,054 projects[Footnote 7] approved using the
categorical exclusion for timber stand or wildlife habitat improvement
were smaller than 5,000 acres--which is the approximate size limitation
of the categorical exclusion for hazardous fuels reduction, the largest
size limitation of the four more recent categorical exclusions.
Primary Reasons for Not Using Vegetation Management Categorical
Exclusions Varied Depending on the Ranger District and Type of
Categorical Exclusion:
Eleven percent of the 509 ranger districts had not used any of the five
vegetation management categorical exclusions during the 3-year period.
The percentage of ranger districts that did not use specific
categorical exclusions ranged widely, from 91 percent not using the
category for the removal of trees to control the spread of insects or
disease, to 32 percent not using the category for timber stand or
wildlife habitat improvement. Ranger districts' reasons for not using a
specific categorical exclusion also varied. The primary reason cited
for not using the categorical exclusion for the removal of trees to
control the spread of insects or disease was that their forests did not
have insect-or disease-infested trees and that projects that could have
fit the category had already been or were to be included in an EA or
EIS. Similarly, the primary reasons cited for not using the categorical
exclusion for timber stand or wildlife habitat improvement were that
projects that could have fit the category had already been or were to
be included in an EA or EIS and no projects were undertaken to improve
stands or wildlife habitat. Appendix III provides the number of ranger
districts not using one of the five vegetation management categorical
exclusions and primary reasons cited for not doing so.
Ranger district officials we interviewed offered some reasons for why
specific vegetation management categorical exclusions may not be used.
For example,
* The Tonasket Ranger District, located in north-central Washington
State in the Okanogan-Wenatchee National Forests, had not used the
categorical exclusion for the removal of trees to control the spread of
insects or disease because, according to district officials, the 250-
acre size limitation of the categorical exclusion constrains its use.
The district has huge areas infested with beetles and mistletoe and, to
be effective, any salvage would have to cover a much larger area.
* The Canyon Lakes Ranger District, located in north-central Colorado
in the Arapaho-Roosevelt National Forests, had not used the categorical
exclusion for timber stand or wildland habitat improvement. According
to ranger district officials, they have not used this categorical
exclusion because project planning typically consists of an EA or EIS.
These types of environmental analysis allow the district to better
evaluate multiple activities over large geographic areas using a single
analysis--which is more efficient than approving different projects
using several vegetation management categorical exclusions.
Concluding Comments:
Because four of the five categorical exclusions have only been
available since 2003, it is premature to draw any conclusions about
trends in the Forest Service's use of them to approve vegetation
management projects. More information over a longer period of time will
be useful in addressing some of the controversial issues, such as
whether categorical exclusions, individually or cumulatively, have any
significant effect on the environment or whether their use is enabling
more timely Forest Service vegetation management.
Mr. Chairman, this concludes my prepared statement. I would be pleased
to answer any questions that you or other Members of the Subcommittee
may have at this time.
GAO Contacts and Staff Acknowledgements:
For further information about this testimony, 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 statement. David P. Bixler, Assistant Director; Rich
Johnson; Marcia Brouns McWreath; Matthew Reinhart; and Carol Herrnstadt
Shulman made key contributions to this statement.
[End of section]
Appendix I: Forest Service's Vegetation Management Categorical
Exclusions:
Timber stand or wildlife habitat improvement.
Type of categorical exclusion for vegetation management and conditions:
No acreage restrictions. May not use herbicides. No more than 1 mile of
low standard road construction.[A];
Examples of activities:
* Girdling trees to create snags.[B];
* Thinning or brush control to improve growth or reduce fire hazard,
including the opening of an existing road to a dense timber stand;
* Prescribed burning to control understory hardwoods in stands of
southern pine;
* Prescribed burning to reduce natural fuel build-up and improve plant
vigor.
Hazardous fuels reduction activities using prescribed fire; and
mechanical methods for crushing, piling, thinning, pruning, cutting,
chipping, mulching, and mowing.
Type of categorical exclusion for vegetation management and conditions:
Prescribed fire not to exceed 4,500 acres and mechanical methods not to
exceed 1,000 acres. Activities are limited to (1) areas in the wildland-
urban interface or (2) designated areas outside the wildland- urban
interface.[C] Activities must;
* be identified through a collaborative framework as described in A
Collaborative Approach for Reducing Wildland Fire Risks to Communities
and Environment 10-Year Comprehensive Strategy Improvement Plan, May
2002;
* be conducted consistent with agency and departmental procedures and
applicable land and resource management plans;
* not include the use of herbicides or pesticides or the construction
of new permanent roads or other new permanent infrastructure, and may
include the sale of vegetative material if the primary purpose of the
activity is hazardous fuels reduction; and;
* not be conducted in wilderness areas or impair the suitability of
wilderness study areas for preservation as wilderness;
Examples of activities:
* Prescribed burning;
* Mechanically crushing, piling, thinning, pruning, cutting, chipping,
mulching, and mowing.
Limited harvest of live trees.
Type of categorical exclusion for vegetation management and conditions:
Not to exceed 70 acres. No more than one-half mile of temporary road
construction. This categorical exclusion is not to be used for
harvesting or generating same-aged trees or converting to a different
type of vegetation. May include incidentally removing trees for
landings, skid trails, and road clearing;
Examples of activities:
* Removing individual trees for saw logs, specialty products, or fuel
wood;
* Commercial thinning of overstocked stands to achieve the desired
stocking level to increase health and vigor.
Salvage of dead and/or dying trees.
Type of categorical exclusion for vegetation management and conditions:
Not to exceed 250 acres. No more than one-half mile of temporary road
construction. May include incidentally removing trees for landings,
skid trails, and road clearing;
Examples of activities:
* Harvesting a portion of a stand damaged by a wind or ice event and
construction of a short temporary road to access the damaged trees;
* Harvesting fire- damaged trees.
Removal of insect-or disease-infested trees.
Type of categorical exclusion for vegetation management and conditions:
Not to exceed 250 acres. No more than one-half mile of temporary road
construction. Includes removing infested or infected trees and adjacent
live un-infested or uninfected trees as determined necessary to control
the spread of insects or disease. May include incidentally removing
trees for landings, skid trails, and road clearing;
Examples of activities:
* Felling and harvesting trees infested with southern pine beetles and
immediately adjacent un-infested trees to control expanding spot
infestations;
* Removing and destroying infested trees affected by a new exotic
insect or disease, such as emerald ash borer, Asian long horned beetle,
and sudden oak death pathogen.
Source: Forest Service Handbook.
[A] A low standard road is one which has a rough and irregular surface
where traffic flow is slow and two-way traffic is difficult. While the
road can accommodate high clearance vehicles, it may not provide safe
service to all traffic.
[B] Girdling is a process whereby tree trunks are severed to remove the
outer layers of bark and other woody material. This constricts the
level of nutrients available to support tree life and can result in a
snag--a standing, dead tree.
[C] These include certain areas with fire regimes that have been
moderately or significantly altered from historical ranges.
[End of table]
[End of section]
Appendix II: Number of Projects and Acres by Type of Environmental
Analysis and Forest Service Region (2003 - 2005):
[See PDF for Image]
Source: GAO.
Note: Of the 3,018 vegetation management projects, 113 had no acreage
or an unknown acreage, according to the Forest Service. The acreage
associated with a vegetation management project may be zero or unknown
because, among other reasons, the unit of measure for the project is
listed as miles of roadside to be treated or number of trees to be
removed.
[A] Numbers do not add due to rounding.
[End of figure]
[End of section]
Appendix III: Number of Ranger Districts Not Using One of the Five
Categorical Exclusions and Reasons Why (2003 - 2005):
Number of the 509 (percent of total) ranger districts that had not used
the categorical exclusion;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 462 (90.8);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): 395 (77.6);
Categorical exclusion: Salvage of dead or dying trees (250- acre
limitation): 353 (69.4);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 256 (50.3);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): 165 (32.4).
Primary reason for not using an exclusion.
Number of ranger districts not using the categorical exclusion that
cited the primary reason:
Lack of insect-or disease-infested trees;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 114 (24.7);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): [A];
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): [A];
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): [A];
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): [A].
Size (acreage) of potential projects is larger than that allowed;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 27 (5.8);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): 110 (27.9);
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 36 (10.2);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 22 (8.6);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): [A].
Lack of dead or dying trees to salvage;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): [A];
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): [A];
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 95 (26.9);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): [A];
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): [A].
Projects that could fit the category have already been or will be
included in an environmental assessment or impact statement;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 108 (23.4);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): 100 (25.3);
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 66 (18.7);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 62 (24.2);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): 59 (35.8).
No projects undertaken to improve timber stands or wildlife habitat;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): [A];
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): [A];
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): [A];
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): [A];
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): 61 (37.0).
Have insect-or disease-infested trees, but other priorities precluded
its use;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 88 (19.1);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): [A];
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): [A];
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): [A];
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): [A].
Lack of internal Forest Service resources to propose and plan a
vegetation management project;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 27 (5.8);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): 55 (13.9);
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 28 (7.9);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 33 (12.9);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): 26 (15.8).
Lack of required wildland fire risk reduction plan for using the
category;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): [A];
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): [A];
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): [A];
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 46 (18.0);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): [A].
Have dead or dying trees, but other priorities precluded its use;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): [A];
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): [A];
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 47 (13.3);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): [A];
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): [A].
Other categorical exclusion used;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 14 (3.0);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): 16 (4.1);
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 13 (3.7);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 21 (8.2);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): 2 (1.2).
Lack of commercial infrastructure to harvest or salvage trees;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 14 (3.0);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): 21 (5.3);
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 16 (4.5);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 2 (0.8);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): 2 (1.2).
No hazardous fuels;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): [A];
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): [A];
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): [A];
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 13 (5.1);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): [A].
Ranger district or national forest preference to use an environmental
assessment as opposed to the categorical exclusion;
Categorical exclusion: Removal of insect-or disease-infested trees (250-
acre limitation): 5 (1.1);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): 13 (3.3);
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 8 (2.3);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 6 (2.3);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): 5 (3.0).
Other reasons;
Categorical exclusion: Removal of insect-or disease- infested trees
(250-acre limitation): 64 (13.9);
Categorical exclusion: Limited timber harvest of live trees (70-acre
limitation): 80 (20.3);
Categorical exclusion: Salvage of dead or dying trees (250-acre
limitation): 45 (12.7);
Categorical exclusion: Hazardous fuels reduction (5,500-acre
limitation): 51 (20.0);
Categorical exclusion: Improve timber stands or wildlife habitat (no
acreage limitation): 10 (6.1).
Source: GAO.
[A] The primary reason listed was not applicable to the categorical
exclusion and, thus, was not an option for the Forest Service to
choose.
[End of table]
[End of section]
FOOTNOTES
[1] Vegetation management projects may include, but are not limited to,
activities such as using prescribed burning, timber harvests, or
herbicides; or thinning trees, grass, weeds, or brush. Projects that
include these types of activities are intended to, among other things,
maintain healthy ecosystems, reduce the risk of catastrophic wildland
fire, and manage the nation's forests for multiple uses, such as
timber, recreation, and watershed management.
[2] GAO, Forest Service: Use of Categorical Exclusions for Vegetation
Management Projects, Calendar Years 2003 through 2005, GAO-07-99
(Washington, D.C.: Oct. 10, 2006).
[3] Resource conditions that should be considered in determining
whether extraordinary circumstances exist include, among other things,
the existence of federally listed threatened or endangered species or
designated critical habitat; congressionally designated wilderness
areas; inventoried roadless areas; and archaeological sites or historic
properties. The mere presence of one or more of these conditions does
not preclude the use of a categorical exclusion. Rather, it is the
degree of the potential effect of the proposed action on these
conditions that determines whether extraordinary circumstances exist.
[4] The Forest Service may decide to prepare an EA for a project that
could qualify for approval using a categorical exclusion.
[5] In addition to the timber stand and wildlife habitat improvement
categorical exclusion, the Forest Service previously had a categorical
exclusion for timber sales of 250,000 board-feet or less of
merchantable wood products or 1 million board-feet of salvage. In 1999,
a federal district court issued a nationwide injunction barring use of
this categorical exclusion, holding that the agency did not provide any
rationale for why the specified magnitude of timber sales would not
have a significant effect on the environment. Heartwood v. U.S. Forest
Service, 73 F. Supp. 2d 962,975 (S.D. Ill. 1999), aff'd on other
grounds, 230 F. 3d 947 (7th Cir. 2000).
[6] 68 Fed. Reg. 33814 (June 5, 2003) and 68 Fed. Reg. 44598 (July 29,
2003).
[7] Of the 1,094 projects approved using the categorical exclusion to
improve timber stands or wildlife habitat, 40 had no acreage or an
unknown acreage, according to the Forest Service.
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