Forest Service Roadless Areas: Potential Impact of Proposed Regulations
on Ecological Sustainability (Letter Report, 11/08/2000, GAO/GAO-01-47).

The Forest Service manages about 192 million acres of land that makes up
the National Forest System. The agency has proposed to make ecological
sustainability its top priority in an attempt to sustain a flow of
products, services and values from the national forests and grasslands.
One of the most debated issues on how the Forest Service should do this
is the role of roads, especially in areas that are now roadless. This
report summarizes GAO's findings on how the potential roadless rule will
affect the Forest Service's ability to meet its goals of restoring and
maintaining ecological sustainability. GAO found that building roads in
national forests can have both positive and negative effects. Road
construction can alter a forest's ecosystem by facilitating timber
harvesting and disturbing wildlife. However, roads can be used to repair
environmental damage done by other activities. Forest Service officials
at the ten national forests that GAO reviewed provided general
observations on the proposed rule. GAO's review stated that the proposed
rule would have little effect on forest management efforts because there
was no plan to build roads in roadless areas if determined that doing so
would restore the forest's ecosystem.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GAO-01-47
     TITLE:  Forest Service Roadless Areas: Potential Impact of
	     Proposed Regulations on Ecological Sustainability
      DATE:  11/08/2000
   SUBJECT:  National forests
	     Forest management
	     Environmental policies
	     Agency missions
	     Forest conservation
	     Strategic planning
	     Road construction
	     Proposed legislation
IDENTIFIER:  USDA National Forest System
	     Boise National Forest (ID)
	     Payette National Forest (ID)
	     Routt National Forest (CO)
	     Malheur National Forest (OR)
	     Umatilla National Forest (OR)
	     Uinta National Forest (UT)
	     Tahoe National Forest (CA)
	     Shasta-Trinity National Forest (CA)
	     White Mountain National Forest (NH)
	     George Washington National Forest (VA/WV)

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GAO-01-47

Report to Congressional Requesters

November 2000 FOREST SERVICE ROADLESS AREAS

Potential Impact of Proposed Regulations on Ecological Sustainability

GAO- 01- 47

Letter 3 Appendixes Appendix I: Objectives, Scope, and Methodology 32

Appendix II: Comments From the Forest Service 35 Appendix III: GAO Contacts
and Staff Acknowledgments 41

Figures Figure 1: Location of the 10 National Forests Included in GAO's
Review 6

Figure 2: Effects of Wildfire on the Tahoe National Forest 11 Figure 3: The
Interior West 13 Figure 4: Trees Damaged by Spruce Bark Beetles in the

Boise National Forest 16 Figure 5: The Geographical Boundaries of the
Northwest

Forest Plan 18 Figure 6: The Geographic Boundaries of the Interior Columbia

Basin Ecosystem Management Project 20 Figure 7: The Geographical Boundaries
of the Sierra Nevada

Framework 22 Figure 8: Trees Killed in Routt National Forest by 1997
Windstorm 27

Lett er

November 8, 2000 The Honorable Larry Craig Chairman, Subcommittee on Forests
and Public Land Management Committee on Energy and Natural Resources United
States Senate

The Honorable Helen Chenoweth- Hage Chairman, Subcommittee on Forests and
Forest Health Committee on Resources House of Representatives

The U. S. Department of Agriculture's Forest Service manages about 192
million acres of land across the 155 national forests, 20 national
grasslands, and 17 national recreation areas that make up the National
Forest System. According to the agency, “the first priority for
management is the maintenance and restoration of ecological sustainability,
which is consistent with laws guiding use and enjoyment of National Forest
System lands.” The agency has proposed making ecological
sustainability its top priority in order to provide a sustainable flow of
products, services, and other values from the national forests and
grasslands. 1 Depending on the condition of the land, the Forest Service
recognizes that active management may be required to more quickly restore
and maintain ecological sustainability and enable ecological systems to
sustain desirable ecological conditions and human uses than would occur by
allowing nature to take its course. (Contributors to ecological
sustainability include fire and other ecological processes, and biological
diversity- diverse animal and plant communities.)

1 64 Fed. Reg. 54103 (Oct. 5, 1999).

Among the more contentious debates over how the Forest Service should meet
its mission priority of restoring and maintaining ecological sustainability
is the role of roads, particularly in areas that are now roadless. According
to the Forest Service, it intends to examine policies on road construction,
in both areas with and without roads, within the context of ecological
sustainability. On May 10, 2000, the Forest Service proposed a roadless area
conservation rule (the roadless rule). 2 The environmental documents
accompanying the proposed rule discuss the following four alternatives: (1)
no action; (2) a prohibition on road construction and reconstruction in the
areas largely devoid of roads, known as “the unroaded portion of
inventoried roadless areas,” and hereafter referred to as
“roadless areas;” (3) a prohibition on road construction,
reconstruction, and timber harvest, except for stewardship purposes, 3 in
roadless areas; and (4) a prohibition on road construction and
reconstruction and all timber harvest in roadless areas. The three action
alternatives would prohibit- under most circumstances- the construction and
reconstruction of roads on 43 million acres of the national forests. The
agency prefers the second action alternative, which would allow commercial
timber harvesting and forest health activities- such as removing brush to
reduce the risk of fire- but would not allow roads to be constructed to
carry them out. This is the alternative set out in the agency's proposed
rule. The agency also proposed procedures for making future decisions about
the management of inventoried and noninventoried roadless areas. The Forest
Service has received and is considering public comments on the proposal and
intends to issue a final rule by the end of 2000.

The Forest Service has developed or is developing other major national
regulations and regional strategies and plans within the context of its
focus on ecological sustainability. These include proposed changes to the
agency's internal procedures governing road management and transportation, a
current regional management plan for multiple national forests in the
Pacific Northwest, and proposed regional management plans for multiple
national forests in the interior Columbia River basin and the Sierra Nevada.

2 65 Fed. Reg. 30276 (May 10, 2000). 3 Stewardship purposes include
improving the vigor of remaining trees to withstand insects, disease, and
wind; reducing forest fuels through thinning; and creating desired wildlife
habitat conditions.

You asked us to determine if the Forest Service's proposed roadless rule
will affect the agency's ability to meet its mission priority of restoring
and maintaining ecological sustainability. More specifically, as agreed,
this report discusses (1) the role that roads play in both causing and
mitigating ecological problems; (2) differences between the approach to
achieve ecological sustainability under the proposed roadless rule and the
approaches of other current and proposed national and regional Forest
Service strategies and plans; and (3) the views of national forest managers
on the proposed roadless rule's likely impact on their ability to manage
their lands and resources for ecological sustainability. We did not examine
the potential impact of the proposed rule on recreational use in the
national forests or on the production of commodities, such as timber and
forage.

In performing our work, we visited 10 national forests located in various
parts of the nation that, according to Forest Service data, are experiencing
ecological problems, such as buildups of hazardous fuels, outbreaks of
insects or diseases, invasions of noxious weeds, degradation of water
quality, and/ or the loss of important ecosystems and species. These forests
would likely be among those affected- both positively and negatively- by the
proposed rule. We discussed the proposed rule with forest supervisors and/
or natural resource specialists from the following 10 national forests: the
Boise and Payette in Idaho, the Routt in Colorado, the Malheur and Umatilla
in Oregon, the Uinta in Utah, the Tahoe and Shasta- Trinity in California,
the White Mountain in New Hampshire and Maine, and the George Washington in
Virginia and West Virginia. (See fig. 1.) The process by which we selected
these forests and our overall scope and methodology are explained in more
detail in appendix I.

Figure 1: Location of the 10 National Forests Included in GAO's Review

Malheur NF Umatilla NF

Payette NF White Mountain NF Boise NF

Uinta NF Shasta- Trinity NF

Routt NF Tahoe NF

George Washington NF National forests visited by GAO Other national forests
and grasslands

Source: The Forest Service.

Results in Brief Roads can have lasting impacts on the national forests.
When improperly constructed or maintained or when constructed along streams
or on

hillsides, roads can create excessive sediment that damages watersheds and
degrades aquatic habitat. Moreover, in providing access into remote areas,
roads can alter forest ecosystems by facilitating timber harvesting,
increasing fires caused by individuals, spreading noxious weeds, and
disturbing wildlife habitat. However, roads can also be used to repair
environmental damage caused by other activities. For example, decades of

fire suppression in the national forests have increased the risk of
uncontrollable and often catastrophic wildfires by creating unnaturally
dense forests with large amounts of accumulated hazardous fuels, such as
underbrush and dead vegetation. Roads can provide a means of restoring these
forests to what is considered a more natural state by providing access for
thinning stands of trees and mechanically removing accumulated fuels that
otherwise would have been removed by frequent but low- intensity natural
fires. When fuel levels are low enough, the Forest Service can more safely
reintroduce fire into an ecosystem, either by allowing natural fires to burn
or by setting prescribed fires. Thinning dense forests can also improve
their resistance to insects and diseases that otherwise could kill trees,
thereby adding to fuel loads.

Compared with another proposed national rule on transportation management
and with regional strategies and plans approved or proposed by the Forest
Service that also strive to restore and maintain ecological sustainability,
the proposed roadless rule takes a more restrictive approach to decision-
making concerning road construction in roadless areas. The proposed roadless
rule- which the agency asserts would supercede relevant portions of the
proposed national transportation management rule and approved regional
plans- would apply a national prohibition on road construction in roadless
areas. In contrast, the transportation rule and regional plans would
generally allow roads to be constructed, on a limited basis, to actively
manage lands and resources to restore and maintain desired ecological
conditions.

Forest Service officials on the 10 national forests included in our review
provided three general observations on the proposed rule's likely impact on
their ability to manage their lands and resources for ecological
sustainability. First, the impact of the preferred alternative- which
prohibits only road construction and reconstruction- is likely to be
minimal. Although the reasons varied by forest, in sum, the forests
generally did not plan to construct roads in roadless areas with or without
the roadless rule. Second, although they say the need may be rare, forest
officials would like to retain some discretion to construct roads in
roadless areas on an exception basis to restore and maintain ecological
sustainability, primarily on forests in the dry interior West with large
amounts of accumulated hazardous fuels and/ or large numbers of dead or
dying trees. Third, officials on all 10 forests had a far greater concern
with the proposed alternative that would prohibit not only road construction
and reconstruction but also all timber harvesting in roadless areas. This
alternative, they said, would have a far greater impact on their ability to

manage their lands and resources for ecological sustainability and could
place at risk not only ecosystems, watersheds, and species but also human
property and safety.

We provided a draft of this report to the Forest Service and the Department
of Agriculture for review and comment. The Forest Service provided comments
that we incorporated as appropriate. The Forest Service's comments and our
response are provided in appendix II.

Background The Forest Service, created in 1905, is an organization whose
management is highly decentralized and whose regional foresters and forest
supervisors

have considerable autonomy in interpreting and applying the agency's
policies and directions, guided by a system of manuals and handbooks keyed
to statutes and regulations. The Forest Service has three levels of field
management- 9 regional offices, 115 forest offices, and about 600 district
offices. Regional offices, each managed by a regional forester, interpret
policy and provide additional direction to the 115 forest offices that
manage the 155 national forests, 20 national grasslands, and 17 national
recreation areas. In turn, the forest offices, each managed by a forest
supervisor, oversee some 600 district offices, most of which are managed by
a district ranger. The forest supervisors are primarily responsible for
developing and implementing forest plans for their respective forest( s) and
grassland( s). The district rangers are primarily responsible for
implementing project- level decisions-“ on- the- ground
activities,” such as harvesting timber, restoring species' habitats,
and constructing campsites- within their respective districts.

The Forest Service began assembling an inventory of roadless areas for
further study as potential wilderness areas in the 1970s as part of a
continuing effort to establish and administer the National Wilderness
Preservation System. The agency's criteria allowed some areas with few roads
to be inventoried as “roadless.” Subsequent reviews, conducted
as part of the agency's forest planning process or broader- scale
assessments, have identified additional roadless areas. In all, the agency's
reviews identified over 2,800 inventoried roadless areas- 20 percent of
which are less than 5,000 acres- totaling approximately 54.3 million acres.
Over the intervening two decades, the agency has constructed roads on about
2. 8 million acres in these areas, bringing the total of forest system roads
to about 386,000 miles and leaving about 51. 5 million acres in the unroaded
portion of the inventoried roadless areas.

On October 13, 1999, President Clinton directed the Forest Service to
develop, and propose for public comment, regulations to provide appropriate
long- term protection for most or all of the roadless areas and to determine
whether such protection is warranted for any smaller roadless areas not yet
inventoried. On May 10, 2000, the Forest Service issued its proposed
alternatives, including its preferred alternative. The agency's preferred
alternative, presented in the proposed rule, is to restrict road
construction and reconstruction but not timber harvesting. The preferred
alternative would also require land managers to consider the protection of
“roadless characteristics” when revising their forest plans.

Each of the three action alternatives would include exceptions to the
prohibition on road construction and reconstruction. The circumstances under
which the proposed rule would allow road construction or reconstruction are:
(1) to protect public health and safety in cases of an imminent threat of
flood, fire, or other catastrophic event that, without intervention, would
cause the loss of life or property; (2) to prevent irreparable resource
damage by an existing road that is deemed essential for access, management,
or public health and safety where such damage cannot be corrected by
maintenance; (3) to act in accordance with reserved or outstanding rights or
in accordance with statutes or treaties; and (4) to take response actions
under the Comprehensive Environmental Response, Compensation, and Liability
Act or to conduct a natural resource restoration action under that act;,
section 311 of the Clean Water Act; or the Oil Pollution Act.

As defined in the proposed roadless rule, the characteristics of roadless
areas to be protected are (1) soil, water, and air; (2) sources of public
drinking water; (3) diversity of plant and animal communities; (4) habitat
for threatened, endangered, proposed, candidate, and sensitive species and
for those species that depend on large, undisturbed areas of land; (5)
primitive, semiprimitive nonmotorized, and semiprimitive motorized classes
of dispersed recreation; (6) reference landscapes for research, study, or
interpretation; (7) landscape character and scenic integrity; (8)
traditional cultural properties and sacred sites; and (9) other locally
identified unique characteristics. The preferred alternative would also
delay for 5 years a determination of whether the prohibition on road
construction and reconstruction should apply to the 8. 5 million acres of
roadless areas on the Tongass National Forest in Alaska.

As the Forest Service develops the proposed roadless area rule, it also
faces major ecological issues. One of particular importance- as evidenced by
the burning of over 6.5 million acres of public and private land this year-
is the safe reintroduction of fire into the forests and grasslands. 4 During
most of the twentieth century, the Forest Service's policy was to suppress
all fires. As a result of this and other policies, the health and structure
of certain ecosystems that depend upon fire have been adversely affected.
Fire suppression has also created unnaturally dense forests that are more
susceptible to insects and disease and to catastrophic wildfire. Given the
ecological damage that has resulted from fire suppression, as well as the
increased risks to human development from uncontrollable wildfires, the
agency's fire and management policies are coming under scrutiny. Methods of
reducing fuel levels include (1) allowing natural fires to burn under
certain circumstances; (2) mechanically thinning trees or removing brush;
and (3) using prescribed fire- sometimes in combination with mechanical
removal- cases in which forest managers deliberately set fires in an attempt
to remove brush and small- diameter material.

4 Reducing Wildfire Threats: Funds Should Be Targeted to the Highest Risk
Areas( GAO/ TRCED- 00- 296, Sept. 13, 2000).

Figure 2: Effects of Wildfire on the Tahoe National Forest

Source: GAO.

Roads Can Have Both Few human disturbances have had a more lasting legacy on
the national

Positive and Negative forests than roads. For example, forest roads
constructed prior to the early

1970s along streams and on hillsides used designs that were subject to
Effects

erosion and failure. These roads have been found to cause significant damage
to watersheds and aquatic habitat by collecting, concentrating, and
directing storm runoff and the sediment that it carries into streams and
rivers. Excessive sediment suffocates developing fish eggs and buries
aquatic insects upon which fish depend for food. Changes in streamflows and
increases in water temperatures caused by roads further impair the ability
of native fish to survive and reproduce. Roads also dissect terrestrial
habitat into isolated patches, thereby interfering with the ability of
certain wildlife species to travel and reproduce.

By providing access into remote areas, roads have also facilitated certain
human activities that have resulted in significant changes to forest
ecosystems. For instance, most roads on national forests were initially
constructed to harvest timber. Past timber- harvesting practices, including
removing all of the trees from a timber- harvesting site at one time
(clearcutting) and using heavy equipment such as tractors to haul logs

along roads, were often not designed to protect water quality. These
practices resulted in cleared and compacted areas that exposed soil to the
erosive impact of rain and contributed sediment to streams, especially
during large storms. Large clearcut areas and the selective removal of
larger trees have also resulted in forests that differ widely from their
historic conditions. In some forests, certain species of trees have declined
by as much as 95 percent and have been replaced by other species that have
markedly changed the forests' composition and structure. As a result, fish
and wildlife species that depend on historic conditions, including oldgrowth
forests and undisturbed watersheds, have declined in distribution and
abundance. In addition, roads further push forest ecosystems away from
historic conditions by increasing fires caused by individuals, poaching, and
the spread of nonnative weeds that can out- compete and replace native
plants.

Current road construction and timber- harvesting practices on Forest Service
lands are designed to mitigate their adverse effects on ecosystems. 5
Specifically, new forest roads are designed to be more stable and to reduce
the potential for failure, and road drainage systems have been improved to
reduce the amount of water and sediment delivered to streams. Additionally,
newer timber- harvesting practices are less damaging to the soil than older
practices and leave trees and large, woody debris in riparian buffers to
trap and filter sediment before it reaches streams.

Roads can also provide access for restoring ecological disturbance processes
to degraded ecosystems. Ecological disturbance processes, such as fire and
insects or disease infestation, are necessary for keeping ecosystems
healthy, but the size and intensity of these disturbances has exceeded
historical levels in places. For example, decades of fire suppression on the
national forests have increased the risk of uncontrollable and often
catastrophic wildfires by creating unnaturally dense forests with large
amounts of accumulated hazardous fuels, such as underbrush, small trees,
dead branches, and carpets of dry needles. 6 Unnaturally dense forests- such
as many ponderosa pine forests in the dry, inland portion of the western
United States (the interior West) (see fig. 3)- also cause individual trees
to compete for limited quantities of water and,

5 Oregon Watersheds: Many Activities Contribute to Increased Turbidity
During Large Storms (GAO/ RCED- 98- 220, July 29, 1998). 6 Western National
Forests: A Cohesive Strategy Is Needed to Address Catastrophic Wildfire
Threats( GAO/ RCED- 99- 65, Apr. 2, 1999).

during drought conditions, weakened trees become susceptible to insect
infestations and diseases and die in unnaturally high numbers. Large stands
of dead trees further contribute to accumulated hazardous fuels, increasing
the risk of uncontrollable and catastrophic wildfires.

Figure 3: The Interior West

Source: The Forest Service.

According to the Forest Service, 67 million acres on national forests across
the country are at moderate to high risk from catastrophic wildfire and need
to be treated over a 15- year period. 7 Ten million of these acres are in
inventoried roadless areas. 8 Damage to forested and rangeland ecosystems
caused by these fires is potentially equal to or greater than that of timber
harvesting with respect to (1) exposing soil to the erosive impact of rain
and contributing sediment to streams, especially during large storms, and
(2) resulting in forests that differ widely from their historic conditions.
Roads increase the efficiency of restoring these forests to a more natural
state- by providing access to forests to thin stands of trees and
mechanically removing accumulated fuels that otherwise would have been
removed by frequent but low- intensity natural fires- so that fire can be
safely reintroduced into an ecosystem. Roads can also (1) serve as fire
breaks when applying prescribed fire and when attempting to suppress
wildfires and (2) provide access to rehabilitate and restore burned areas.
In addition, the Forest Service estimates that approximately 24 million
acres on the national forests are at risk of excessive tree mortality from
insects or diseases- 7 million of which it estimates to be in roadless
areas. 9 Thinning dense forests can improve their resistance to insects and
diseases that otherwise could kill trees and add to fuel loads.

7 Protecting People and Sustaining Resources in Fire- Adapter Ecosystems: A
Cohesive Strategy, Forest Service( Apr. 13, 2000). 8 Forest Service Roadless
Area Conservation Draft Environmental Impact Statement( May 2000). 9 Forest
Service Roadless Area Conservation Draft Environmental Impact Statement( May
2000).

The Approach to Road The proposed roadless rule is more restrictive than
another proposed

Construction in the national rule and regional strategies and plans recently
approved or

proposed by the Forest Service. These other rules, strategies, and plans
Proposed Roadless

would allow roads to be constructed, on a limited basis, to actively manage
Rule Is More

lands and resources to restore and maintain desired ecological conditions.
Restrictive Than The

Under these other situations, decisions to construct roads would have to be
supported by detailed scientific analysis.

Approach in Another Proposed National Rule and Regional Strategies and Plans

The Proposed Roadless The proposed roadless rule takes an approach to
decision- making on road

Rule construction in roadless areas that is different from the approaches of

other recent Forest Service proposed rules, strategies, and plans. The
proposed rule- which the agency asserts would supercede relevant portions of
existing plans and transportation management regulations- would apply a
national prohibition on road construction in roadless areas, even if local
conditions suggest that a road would help the agency to restore and maintain
desired ecological conditions. Although the proposed rule includes several
exceptions that would authorize road construction or reconstruction in
inventoried roadless areas, the exceptions would not authorize road
construction or reconstruction in inventoried roadless areas to restore and
maintain ecological sustainability. Therefore, national forests could
generally not construct a road to thin stands of trees and mechanically
remove underbrush and dead vegetation to reduce the risk of uncontrollable
and potentially catastrophic fire or to improve the forests' resistance to
insects and diseases that otherwise could kill trees and add to fuel loads.
(Fig. 4 shows a stand of trees damaged by spruce bark beetles in the Boise
National Forest.)

Figure 4: Trees Damaged by Spruce Bark Beetles in the Boise National Forest

Source: GAO.

The Proposed Unlike the proposed roadless rule, another proposed rule would
allow

Transportation Rule more road construction and reconstruction in roadless
areas if sciencebased

analyses show benefits. In March 2000, the Forest Service proposed changes
to the agency's internal procedures governing road management and
transportation (the transportation rule). 10 The proposed transportation
rule would establish policies and procedures regarding the construction,
reconstruction, maintenance, and decommissioning of roads throughout the
National Forest System, including those in roadless areas. The proposed
transportation rule would require national forest and grassland managers to
use science- based analyses to identify the minimum road system needed to
administer, use, and protect their lands and resources. The analyses would
examine issues at various scales, be flexible, and be driven by road issues
important to both the managers and other stakeholders. On the basis of the
analyses, managers would decide which roads to keep, maintain, and close,
and where to construct new roads.

10 65 Fed. Reg. 11684 (Mar. 3, 2000).

Under internal procedures that would implement the proposed transportation
rule, the agency would not expect that roads would be constructed in
roadless areas. However, until the relevant science- based analysis is
performed, road construction could occur in roadless areas only if managers
could show a “compelling need” for the road. Under the
procedures, “compelling need” includes restoring and protecting
critical resources. The proposed roadless rule would, if made final,
supercede these procedures.

Regional Strategies and Several approved or proposed large- scale regional
strategies and plans that

Plans promote the management of ecosystems would also allow for the

possibility of road construction in roadless areas to restore desired
ecological conditions in limited situations, after appropriate analysis and
public participation. First, in 1994, the Secretaries of Agriculture and of
the Interior approved the Northwest Forest Plan. The plan provides direction
for the 22. 3 million acres of land managed by the Forest Service or the
Department of the Interior's Bureau of Land Management in the range of the
northern spotted owl (northern California, western Oregon, and western
Washington). (See fig. 5.)

Figure 5: The Geographical Boundaries of the Northwest Forest Plan

Washington Oregon California

Source: The Forest Service and the Bureau of Land Management.

Critical ecological issues addressed in the plan include conserving
oldgrowth forests and protecting aquatic ecosystems. Threats to those values
include human activities, such as timber harvesting and road construction,
as well as wildfire. The plan prohibits new roads in “key
watersheds” managed for at- risk anadromous fish, bull trout, and
resident fish or where

high water quality is important. However, the plan allows management
activities, including road construction, in “non- key
watersheds,” including those with inventoried roadless areas,
following a watershed analysis that focuses on collecting and compiling
information within the watershed, which is essential for making sound
management decisions.

Second, the Forest Service and the Bureau of Land Management are developing
a broad- scale, ecosystem- based strategy for the approximately 63 million
acres of land they administer in the interior Columbia River basin (eastern
Oregon and Washington, much of Idaho, and western Montana). (See fig. 6.)

Figure 6: The Geographic Boundaries of the Interior Columbia Basin Ecosystem
Management Project

Washington Montana

Oregon Idaho

Wyoming Nevada California

Utah

Source: The Forest Service and the Bureau of Land Management.

The agencies proposed a set of alternatives in 1997 and issued three
supplemental alternatives in March 2000. Under their preferred alternative,
science- based analyses would be used to plan and conduct restoration
activities across the basin to address long- term risks associated with
disturbance events, such as wildfire and disease. The preferred alternative
would discourage new road construction, particularly in riparian areas.

However, the agencies stated that, although roads significantly modify
landscapes and ecological processes, they also facilitate the accomplishment
of many management objectives. The preferred alternative calls for science-
based analyses of roads at multiple geographic scales, as appropriate, to
systematically evaluate existing road system needs and to establish
priorities for road restoration activities. The agencies expect that new
roads into watersheds that currently have no or very few roads would be
rare. However, new roads into such areas could occur following analyses that
demonstrate that access is needed to prevent or address imminent
environmental damage.

Finally, in April 2000, the Forest Service proposed eight alternatives for
the Sierra Nevada Framework- including two preferred alternatives- for
managing nine national forests in the Sierra Nevada and on the Modoc Plateau
in California, the Lake Tahoe Basin Management Unit, and a portion of the
Humboldt- Toiyabe National Forest in Nevada. (See fig. 7.) The planning
process identified numerous issues to be addressed by the alternatives,
including old- growth forest ecosystems, fire and fuels, wildlife habitat,
and roads.

Figure 7: The Geographical Boundaries of the Sierra Nevada Framework

Oregon Nevada California

National parks and monuments National forest lands

Source: The Forest Service.

In assessing the eight alternatives' potential environmental impacts, the
Forest Service stated that forest roads provide access for many uses and
management activities, including research, fish and wildlife habitat
management, fire protection, and insect and disease control. Under each of
the proposed alternatives, an analysis of roads would be an integral part of
each landscape/ watershed analysis. A full range of road system management
options, including new road construction, would be considered on the basis
of social and environmental effects as well as administrative needs, such as
access to wildfires. Neither of the two preferred alternatives for the
Sierra Nevada Framework would specifically prohibit road construction in
roadless areas.

National Forest Forest Service officials on the 10 national forests included
in our review

Managers Believe the provided three general observations on the proposed
roadless rule's likely

impact on their ability to manage their lands and resources for ecological
Preferred Alternative

sustainability. First, the impact of the preferred alternative in the
proposed in the Proposed

roadless rule is likely to have limited impact on these management Roadless
Rule Will

responsibilities. Although the reasons varied by forest, in sum, the forests
generally did not plan to construct roads in roadless areas with or without

Likely Have Minimal the roadless rule. Second, the officials would like to
retain some discretion

Impact on Their Ability to construct roads in roadless areas on an exception
basis. This was

particularly true on forests in the dry interior West with large amounts of
to Restore or Maintain

accumulated hazardous fuels and/ or large numbers of dead or dying trees.
Ecological

And, third, officials on all 10 forests cautioned that one of the
alternatives Sustainability

other than the preferred alternative- prohibiting not only road construction
and reconstruction but also all timber harvesting in inventoried roadless
areas- would have a far greater impact on their ability to manage their
lands and resources for ecological sustainability and could place at risk
ecosystems, watersheds, and species, as well as human property and safety.

Most Roadless Areas Would Few roads have been built in roadless areas in
recent years, and few were

Remain Roadless With or likely to be built in the future, even before the
roadless rule was proposed.

Without the Roadless Rule Since 1979, the Forest Service has constructed
roads on about 5 percent of

the acres in roadless areas on the national forests. Current forest plans
have already placed about 20.5 million of the 51. 5 million acres of
roadless area off- limits to road construction. Officials from several
forests indicated that they expected future forest plans to prohibit road
construction on additional acres even without the proposed rule or that they
did not have

plans to build roads in the roadless areas where construction is now
allowed.

Officials on national forests included in our review identified several
specific reasons why roadless areas would likely remain roadless with or
without the rule. First, if areas inventoried in 1979 as roadless areas were
accessible and had suitable commercial timber, they would have likely been
entered previously, when the Forest Service emphasized timber production
over other uses on the national forests. However, many roadless areas are
inaccessible and/ or do not have suitable commercial timber.

Second, public values about public lands changed during the 1990s, and
concerns were raised about the management of the national forests, making
roadless areas even more controversial and, therefore, more costly to
actively manage compared with other areas on the forests. Because of these
lands' status as roadless areas, any plan or project that required active
management in them was almost always delayed, altered, or withdrawn. For
instance, officials on the Boise National Forest in Idaho had planned, but
have not implemented for nearly a decade, the Deadwood project- a project
aimed at restoring historic ecological conditions on 10 percent of the
forest's remaining ponderosa pine ecosystem through a combination of salvage
logging, prescribed burns, and commercial thinning. Because of potential
controversy, officials on the 10 forests believed that it was not usually
worth the additional time, staff, and money required to construct a road in
a roadless area.

Third, looking to the future, even without the rule, these officials will
construct far fewer roads in roadless areas than in the past. They noted
that the Forest Service- consistent with its existing legislative framework-
has shifted its priorities away from producing timber and other commodities
toward restoring and maintaining land health and forest resources. 11 In
this context, approved and proposed national rules and regional plans,
including those discussed above, make clear that constructing a new road
anywhere and for any reason on a national forest will be rare and must be
scientifically credible, legally defensible, and developed with public
participation. Moreover, although roads may facilitate management activities
to address certain ecological problems, such as hazardous fuels

11 See Forest Service Priorities: Evolving Mission Favors Resource
Protection Over Production( GAO/ RCED- 99- 166, June 17, 1999).

and insects and diseases, officials pointed out that these activities can
often be accomplished in roadless areas without having to construct new
roads, although sometimes at increased cost.

Forest Officials Would Like Even though officials on the 10 national forests
included in our review

to Retain Some Discretion believe that they will need to construct few roads
in roadless areas in the

to Construct Roads in future, some wanted to retain the discretion to
construct or reconstruct

Roadless Areas on an roads in roadless areas on an exception basis to help
restore and maintain

ecological sustainability. Officials on three national forests in the
interior Exception Basis

West also identified several projects that they believe may require road
construction to restore ecosystems to the ecological conditions that existed
prior to the advent of fire suppression. This restoration would involve
mechanically removing and thinning accumulated fuels; setting prescribed
fires; and allowing less severe, naturally occurring fires to return to the
ecosystem; and reducing the threat of unnaturally occurring attacks from
insects and disease. Other projects would protect human property and safety
on private lands immediately adjacent to roadless areas that are at risk of
insect infestation and subsequent wildfire.

For example, officials on the Payette National Forest in Idaho said that,
under the preferred alternative in the proposed rule, they would not
undertake projects in certain roadless areas that are designed to help
restore a healthy ponderosa pine forest. This is the ecosystem most at risk
in Idaho and on the forest as a result of decades of fire suppression,
livestock grazing, and timber harvesting. Most of the ponderosa pine forest
at risk is in roaded areas. However, significant portions in roadless areas
are also at risk. The forest has developed a forestwide plan that includes
projects in roadless areas to help restore the ponderosa pine forest to a
more natural condition. However, according to forest officials, they would
not treat at least half of the acreage of six projects because treatment
would require new road construction; helicopter logging is not economically
feasible as an alternative. These projects would combine prescribed burns
and mechanical thinning in an attempt to restore the ponderosa forest to
historic conditions.

According to officials on the Shasta- Trinity National Forest in California,
the preferred alternative would limit their ability to use mechanical
thinning and prescribed fire to reduce hazardous fuels and thus reduce the
risk of uncontrollable and potentially catastrophic wildfires in a key
watershed- the Lower McCloud River watershed. This watershed also contains
old- growth forest habitat critical to the survival of the threatened

northern spotted owl and other species that depend on old- growth forest.
Officials had planned to reconstruct and maintain old jeep trails to provide
short- term access for mechanical thinning. They had also planned to
maintain the trails as firebreaks for controlling prescribed fires and as
access points for suppressing potential wildfires. However, sections of the
trails are in a roadless area, and forest officials believe that the
preferred alternative in the proposed roadless rule could prevent them from
reconstructing and maintaining these trails.

In Colorado, on the Routt National Forest, forest officials had planned to
construct temporary roads into several roadless areas immediately adjacent
to private property and homes to thin dense lodgepole pine forests that are
currently at risk of insect infestation and subsequent standreplacing
wildfire. Although this is a natural ecological process in lodgepole pine
forests, it is not desirable in such close proximity to residential
development on private lands. According to forest officials, the preferred
alternative in the proposed roadless rule would prevent them from treating
these areas because they could not construct even temporary roads, and other
harvesting methods are not economically feasible. These officials also
expressed concern that residential development adjacent to or intermingled
with roadless areas is increasing, making it likely that this problem will
be greater in the future.

Officials on several national forests included in our review voiced concerns
about the long- term impacts of the roadless rule. For instance, officials
on the Boise and Payette national forests said that the encroachment of fir
trees into ponderosa pine stands- a phenomenon caused by fire suppression-
will increase over time and makes the use of prescribed fire more dangerous
unless these fir trees are mechanically removed, which is most efficiently
and economically accomplished with the aid of roads. Officials on the Routt
National Forest anticipate an outbreak of spruce beetles resulting from a
catastrophic windstorm in 1997 that felled 13, 000 acres of mostly spruce
and fir trees in or adjacent to roadless areas on the forest. (Fig. 8 shows
an area affected by the storm, with dead trees appearing in light gray.)
They believe that the preferred alternative would not allow them to
construct the roads necessary to remove trees in roadless areas that in the
future may become infected by beetles currently living within this deadfall.
Therefore, they would be unable to protect highly valued resources, such as
scenic areas and adjacent campgrounds and ski slopes.

Figure 8: Trees Killed in Routt National Forest by 1997 Windstorm

Source: GAO.

In the impact analysis that accompanied the proposed roadless rule, the
Forest Service stated that it considered exemptions to permit road
construction for fire suppression, insect and disease treatment, and forest
health management but did not consider such an alternative in detail because
“road construction is not necessary for the maintenance and protection
of roadless area characteristics.” However, the impact analysis also
acknowledges that there are situations where road construction in roadless
areas may be warranted, but the agency considered the cost associated with
not being able to do so- such as a decrease in the acreage treated for fuel
management- to be an “unavoidable adverse effect.” 12

12 Forest Service Roadless Area Conservation Draft Environmental Impact
Statement( May 2000).

In elaborating on the impact analysis, Forest Service officials charged with
developing the roadless rule stated that they are aware of the concerns
raised by forest officials. They also believe that national ecological and
social values associated with keeping roadless areas roadless outweigh local
adverse impacts associated with not constructing a road in a roadless area.
Therefore, these Forest Service officials believe that national direction on
roadless areas is appropriate and that the rule should supercede all other
approved national rules and regional strategies and plans and apply
uniformly across the agency. Accordingly, the proposed rule concludes that,
with respect to roadless areas, local discretion to build or reconstruct a
road should be replaced by a national policy that would apply to all the
national forests.

One Other Alternative in the Officials on all 10 forests included in our
review expressed concern that

Proposed Rule Could one of the other alternatives in the proposed roadless
rule would have a far

Further Limit the Ability of greater impact on their ability to manage their
lands and resources for

the National Forests to ecological sustainability. This alternative would
prohibit not only road

construction and reconstruction but also all timber harvesting in roadless
Manage Their Lands and

areas. This alternative could place not only ecosystems, watersheds, and
Resources

species at risk but also human property and safety. The officials viewed
this alternative as inconsistent with both the Forest Service's stated
priority of restoring and maintaining ecological sustainability and its goal
of protecting roadless characteristics.

In the impact analysis accompanying the proposed rule, the Forest Service
stated that it assumed that most forests in roadless areas at a moderate to
high risk from insects, disease, or catastrophic wildfire would be given a
low priority for treatment unless there was an imminent threat to public
safety, private property, water quality, or threatened and endangered
species. However, the Forest Service officials charged with developing the
impact analysis and the proposed rule told us that they recognize the
importance of providing the national forests with flexibility to manage
their lands and resources- including the use of timber harvesting- to
restore and maintain desired ecological conditions. The preferred
alternative would allow more flexibility by not placing direct restrictions
on timber harvesting.

Agency Comments and We provided copies of a draft of this report to the
Forest Service and the

Our Evaluation U. S. Department of Agriculture for review and comment. The
Forest

Service provided a number of technical comments that we incorporated as

appropriate. As part of its comments, the Forest Service stressed that
reducing fuel and risks from fire will not be a top priority in roadless
areas. The agency also stated that, if needed, fuel reduction work could be
done in roadless areas without constructing new roads. We agree that the
agency's priorities are likely to be in areas with roads that are near
communities. On the other hand, in our report we cite the agency's report-
Protecting People and Sustaining Resources in Fire- Adapted Ecosystem: A
Cohesive Strategy- as support for the statement that there is a need for
treatment in roadless areas over the next 15 years. We also cite the views
of national forest managers that such work is needed and that some of it
cannot feasibly be done without new road construction. The agency's written
comments and our detailed response to them are found in appendix II.

We conducted our work from April 2000 through October 2000 in accordance
with generally accepted government auditing standards. Appendix I provides
information on our scope and methodology.

As arranged with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 7 days after
the date of this letter. At that time, we will send copies of this report to
the Honorable Frank Murkowski, Chairman, and the Honorable Jeff Bingaman,
Ranking Minority Member, Senate Committee on Energy and Natural Resources;
the Honorable Don Young, Chairman, and the Honorable George Miller, Ranking
Minority Member, House Committee on Resources; the Honorable Ron Wyden,
Ranking Minority Member, Subcommittee on Forests and Public Lands
Management, Senate Committee on Energy and Natural Resources; the Honorable
Adam Smith, Ranking Minority Member, Subcommittee on Forests and Forest
Health, House Committee on Resources; the Honorable Dan Glickman, Secretary
of Agriculture; the Honorable Mike Dombeck, Chief of the Forest Service; and
other interested parties. We will also make copies available to others on
request.

If you or your staff have any questions about this report, please call me at
(202) 512- 3841. Key contributors to this report are listed in appendix III.

Barry T. Hill Director, Natural Resources and Environment

Appendi Appendi xes xI

Objectives, Scope, and Methodology To determine the role that roads play in
both causing and mitigating ecological problems- including catastrophic
wildfire, insect infestations and diseases, noxious weeds, degraded
watersheds, loss of critical fish and wildlife habitat, and loss of
important ecosystems- we examined documents prepared by the Forest Service,
the World Wildlife Fund, the Wilderness Society, the National Audubon
Society, and the Boise Cascade Corporation. We also interviewed resource
managers with these agencies and organizations to clarify these studies when
necessary, and we interviewed state governmental agencies in Colorado,
Idaho, and Virginia.

To determine the differences between the approach to achieving ecological
sustainability taken by the proposed roadless area conservation rule and
other national and regional Forest Service strategies and plans, we examined
and analyzed the following documents: the proposed regulations for the
National Forest System road management and transportation system; the
proposed regulations for National Forest System land and resource management
planning; the Standards and Guidelines for Management of Habitat for Late-
Successional and Old- Growth Forest Related Species Within the Range of the
Northern Spotted Owl; the Interior Columbia Basin Supplemental Draft
Environmental Impact Statement; and the Sierra Nevada Forest Plan Amendment
Draft Environmental Impact Statement. Our particular interest was in how
these strategies and plans would, or do, make decisions about building new
roads in roadless areas. We also relied on our previous reports on the
Forest Service's planning process and use of regional ecosystem management
plans.

To determine the proposed roadless area conservation rule's likely impact on
the agency's ability to manage its land and resources for ecological
sustainability, we took both a local and a national approach. To assess the
potential impact of the proposed rule on local national forests, we selected
and visited 10 national forests. We did not select the forests randomly, and
they are not intended to be representative of all national forests in any
way. Indeed, we used a subjective process that was intended to select
national forests that may have significant ecological management issues
within their roadless areas. The forests we chose met the following
criteria:

had a substantial amount of their land in roadless areas (the range was from
12 percent to 66 percent, and the average for the 10 forests was about 30
percent); appeared, on the basis of national Forest Service data, to have
varying

amounts of roadless areas at significant risk from either catastrophic
wildfire or insects and disease;

had other ecological management issues, such as species of concern,
watershed restoration, or invasive species; and were in the midst of
revising their forest plans or had revised their plans

in recent years. Our rationale for the criteria regarding the status of
forest plan revisions was that the managers of those forests would be more
likely to have accurate information on the condition of the forests and on
planned management activities. Furthermore, although the overall selection
of forests was not intended to be representative of all national forests, we
did strive for some geographic dispersion among the 10 that we selected. The
10 forests represent six of the nine Forest Service regions.

Once we selected the 10 forests, we visited each and interviewed numerous
natural resource staff, district rangers, fire management officials, and 9
of the 10 forest supervisors. In each case, our primary line of questioning
regarded the potential impact of the proposed rule on managing the forests
to maintain and restore ecological sustainability. At each forest, we were
shown roadless areas, with an emphasis on those areas that need active
management to address a particular ecological problem. In addition to
meeting with Forest Service staff, we spoke with representatives from
nonfederal entities, including state and local governments, environmental
groups, and private timber industry. Our emphasis with these groups was,
again, to determine the potential impact of the proposed rule on the
management of ecological problems at particular national forests in roadless
areas. We did not attempt to determine the potential impact of the proposed
rule on the production of goods and services, such as timber, forage, or
recreational opportunities. Nor did we focus on the public participation
process that has been implemented by the national forests as part of the
rulemaking.

On the basis of our review of conditions and potential impacts at the 10
national forests, we determined that the most likely impact of the proposed
rule on ecological management would relate to fuel reduction and insect and
disease control. Therefore, we focused our effort to gauge the potential
national impact of the rule on those two issues. We reviewed and analyzed
information on these two issues presented in the draft environmental impact
statement that accompanied the proposed rule and in “specialist
reports” prepared by the Forest Service's roadless area project team.
With respect to the issue of fuel reduction, we also analyzed the Forest
Service's April 13, 2000, document entitled Protecting People and Sustaining
Resources in Fire- Adapted Ecosystems: A Cohesive Strategy, and the

departments of Agriculture and Interior's September 8, 2000, report to the
President entitled Managing the Impact of Wildfires on Communities and the
Environment. We also relied on our previous reports and testimonies on the
issue of fuel reduction and fire management.

Our review was conducted from March 2000 through October 2000 in accordance
with generally accepted government accounting standards.

Appendi xII

Comments From the Forest Service Note: GAO's comments supplementing those in
the report text appear at the end of this appendix.

See comment 1. Now on p. 9. See comment 2.

Now on p. 14. See comment 3.

Now on p. 8. See comment 4.

Now on pp. 14 and 28. See comment 5.

Now on p. 15. See comment 6.

Now on p. 15. See comment 7.

Now on p. 17. See comment 8.

The following are GAO's comments on the Forest Service's letter dated
October 23, 2000.

GAO's Comments 1. We agree with this characterization but note that the
cohesive fire strategy, while not released to the public, was signed by the
Chief of the

Forest Service. 2. We added the other two exemptions to the report. 3. We
changed “of” to “from.” In our view, the key to the
sentence is the

number of acres of national forest and inventoried roadless area that,
according to the cohesive strategy, “need to be treated.”

4. We made this change. 5. We recognize that the Forest Service has
different priorities for treating

areas at risk from fire, insects, and disease and that roadless areas may be
a lower priority than areas with roads. The Forest Service cites two
documents- a report to the President from the Secretaries of Agriculture and
of the Interior and the Forest Service's cohesive fire strategy- that
emphasize that reducing fire risk outside of roadless areas and near
communities will be a top priority. The report to the President states,
“given current funding levels and the scope of the fuels issue, the
Forest Service would do fuels reduction work for 15 years in roaded
areas.” However, in the cohesive strategy, the Chief of the Forest
Service recommended that funding be substantially increased to treat 67
million acres, including an estimated 10 million acres of inventoried
roadless area, over a 15- year period. The agency also commented that fire
hazard reduction work could be done in roadless areas without constructing
or reconstructing roads if there were a threat to specific resources and
values. We agree that such work could be done under the proposed regulation,
and that in many situations new roads are not needed. However, national
forest managers with whom we spoke did not believe that all such work could
feasibly be done without new road construction.

6. We recognize that constructing roads would add to the cost of mechanical
treatment and prescribed fire. Nevertheless, in the view of some forest
managers, there are situations where this work is needed but cannot feasibly
be done without roads. The Forest Service will have to weigh the potential
effect of not treating these areas against the cost

of treating them with a method that does not rely on roads, such as
helicopters.

7. We deleted the phrase “even on a temporary basis.” 8. We
changed this section to reflect that the proposed transportation rule

procedures would apply to inventoried roadless areas until the proposed
roadless rule is made final.

Appendi xI II

GAO Contacts and Staff Acknowledgments GAO Contacts Barry T. Hill (202) 512-
3841 Charles S. Cotton (202) 512- 3841 Acknowledgments In addition to those
named above, Ronald Belak, Ross Campbell, Richard

Johnson, and Angela Sanders made key contributions to this report.

(141412) Lett er

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GAO United States General Accounting Office

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Appendix I

Appendix I Objectives, Scope, and Methodology

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Appendix I Objectives, Scope, and Methodology

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Appendix II

Appendix II Comments From the Forest Service

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Appendix II Comments From the Forest Service

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Appendix II Comments From the Forest Service

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Appendix II Comments From the Forest Service

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Appendix II Comments From the Forest Service

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Appendix III

United States General Accounting Office Washington, D. C. 20548- 0001

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