Forest Service: Vegetation Management Projects Approved during
Calendar Years 2003 through 2005 Using Categorical Exclusions
(28-JUN-07, GAO-07-1016T).
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.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-1016T
ACCNO: A71614
TITLE: Forest Service: Vegetation Management Projects Approved
during Calendar Years 2003 through 2005 Using Categorical
Exclusions
DATE: 06/28/2007
SUBJECT: Environmental assessment
Environmental impact statements
Environmental law
Forest management
National forests
Policy evaluation
Program evaluation
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GAO-07-1016T
* [1]Summary
* [2]Background
* [3]Categorical Exclusions Were Used to Approve the Majority of
* [4]The Categorical Exclusion for Improving Timber Stands or Wil
* [5]Primary Reasons for Not Using Vegetation Management Categori
* [6]Concluding Comments
* [7]GAO Contacts and Staff Acknowledgements
* [8]Appendix I: Forest Service's Vegetation Management Categoric
* [9]Appendix II: Number of Projects and Acres by Type of Environ
* [10]Appendix III: Number of Ranger Districts Not Using One of th
* [11]Order by Mail or Phone
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
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.^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.^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.
^1Vegetation 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.
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.
^2GAO, Forest Service: Use of Categorical Exclusions for Vegetation
Management Projects, Calendar Years 2003 through 2005, GAO-07-99
(Washington, D.C.: Oct. 10, 2006).
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.^3,4
^3Resource 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.
^4The Forest Service may decide to prepare an EA for a project that could
qualify for approval using a categorical exclusion.
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.^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.^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.
^5In 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).
^668 Fed. Reg. 33814 (June 5, 2003) and 68 Fed. Reg. 44598 (July 29,
2003).
Table 1: Number of Vegetation Management Projects Approved and Treatment
Acres for Different Types of Environmental Analyses (Calendar Years 2003
through 2005)
Type of environmental analysis
Environmentalimpact Environmental Categorical
statement assessment exclusion Total
Number of
projects
(percent of 3,018
total) 141 (4.7) 690 (22.9) 2,187 (72.5) (100.0)^a
Number of
treatment acres
(percent of 2,506,984 2,856,472 6,262,681
total) 899,225 (14.4) (40.0) (45.6) (100.0)^a
Median number
of treatment 1,366 (1 to 215 (1 to 375 (1 to
acres (range)^b 2,768 (51 to 60,000) 124,971) 97,326) 124,971)
Source: GAO.
aNumbers may not total to 100 percent due to rounding.
bOf 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.
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)
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)
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:
o 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.
o 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)
Improve Removal of
timber Limited insect- or
stands or Hazardous Salvage of timber disease-
wildlife fuels dead or harvest of infested
habitat (no reduction dying trees live trees trees
acre (5,500-acre (250-acre (70-acre (250-acre
limitation) limitation) limitation) limitation) limitation) Total
Number of
projects
(percent 1,094 2,187
of total) (50.0) 485 (22.2) 264 (12.1) 220 (10.1) 124 (5.7) (100.0)^a
Number of
treatment
acres 2,402,188
(percent 405,546 28,939 10,541 2,856,472
of total) (84.1) (14.2) (1.0) (0.4) 9,258 (0.3) (100.0)^a
Median
number of
treatment
acres 433 (1 to 450 (1 to 96 (1 to 59 (1 to 8 (1 to 215 (1 to
(range)^b 97,326) 4,637) 250) 70) 250) 97,326)
Source: GAO.
aNumbers may not add to 100 percent due to rounding.
bOf 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.
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^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,
o 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.
^7Of 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.
o 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 [12][email protected] . 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.
Appendix I: Forest Service's Vegetation Management Categorical Exclusions
Type of categorical exclusion for
vegetation management and conditions Examples of activities
Timber stand or wildlife habitat
improvement
No acreage restrictions. May not use o Girdling trees to create
herbicides. No more than 1 mile of low snags.^b
standard road construction.^a o Thinning or brush control
to improve growth or reduce
fire hazard, including the
opening of an existing road
to a dense timber stand.
o Prescribed burning to
control understory hardwoods
in stands of southern pine.
o 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
Prescribed fire not to exceed 4,500 acres o Prescribed burning.
and mechanical methods not to exceed 1,000 o Mechanically crushing,
acres. Activities are limited to (1) areas piling, thinning, pruning,
in the wildland-urban interface or (2) cutting, chipping, mulching,
designated areas outside the and mowing.
wildland-urban interface.^c Activities
must
o 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;
o be conducted consistent with agency
and departmental procedures and
applicable land and resource management
plans;
o 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
o not be conducted in wilderness areas
or impair the suitability of wilderness
study areas for preservation as
wilderness.
Limited harvest of live trees
Not to exceed 70 acres. No more than o Removing individual trees
one-half mile of temporary road for saw logs, specialty
construction. This categorical exclusion products, or fuel wood.
is not to be used for harvesting or o Commercial thinning of
generating same-aged trees or converting overstocked stands to
to a different type of vegetation. May achieve the desired stocking
include incidentally removing trees for level to increase health and
landings, skid trails, and road clearing. vigor.
Salvage of dead and/or dying trees
Not to exceed 250 acres. No more than o Harvesting a portion of a
one-half mile of temporary road stand damaged by a wind or
construction. May include incidentally ice event and construction
removing trees for landings, skid trails, of a short temporary road to
and road clearing. access the damaged trees.
o Harvesting fire-damaged
trees.
Removal of insect- or disease-infested
trees
Not to exceed 250 acres. No more than o Felling and harvesting
one-half mile of temporary road trees infested with southern
construction. Includes removing infested pine beetles and immediately
or infected trees and adjacent live adjacent un-infested trees
un-infested or uninfected trees as to control expanding spot
determined necessary to control the spread infestations.
of insects or disease. May include o Removing and destroying
incidentally removing trees for landings, infested trees affected by a
skid trails, and road clearing. new exotic insect or
disease, such as emerald ash
borer, Asian long horned
beetle, and sudden oak death
pathogen.
Source: Forest Service Handbook.
aA 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.
bGirdling 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.
cThese include certain areas with fire regimes that have been
moderately or significantly altered from historical ranges.
Appendix II: Number of Projects and Acres by Type of Environmental
Analysis and Forest Service Region (2003 - 2005)
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.
^aNumbers do not add due to rounding.
Appendix III: Number of Ranger Districts Not Using One of the Five
Categorical Exclusions and Reasons Why (2003 - 2005)
Categorical exclusion
Improve
Limited timber
Removal of timber Salvage of Hazardous stands or
insect- or harvest of dead or fuels wildlife
disease-infested live trees dying trees reduction habitat (no
trees (250-acre (70-acre (250-acre (5,500-acre acreage
limitation) limitation) limitation) limitation) limitation)
Number of the
509 (percent of
total) ranger
districts that
had not used the
categorical
exclusion 462 (90.8) 395 (77.6) 353 (69.4) 256 (50.3) 165 (32.4)
Primary reason
for not using an Number of ranger districts not using the categorical exclusion
exclusion that cited the primary reason
Lack of insect-
or
disease-infested
trees 114 (24.7) a a a a
Size (acreage)
of potential
projects is
larger than that
allowed 27 (5.8) 110 (27.9) 36 (10.2) 22 (8.6) a
Lack of dead or
dying trees to
salvage a a 95 (26.9) a a
Projects that
could fit the
category have
already been or
will be included
in an
environmental
assessment or
impact statement 108 (23.4) 100 (25.3) 66 (18.7) 62 (24.2) 59 (35.8)
No projects
undertaken to
improve timber
stands or
wildlife habitat a a a a 61 (37.0)
Have insect- or
disease-infested
trees, but other
priorities
precluded its
use 88 (19.1) a a a a
Lack of internal
Forest Service
resources to
propose and plan
a vegetation
management
project 27 (5.8) 55 (13.9) 28 (7.9) 33 (12.9) 26 (15.8)
Lack of required
wildland fire
risk reduction
plan for using
the category a a a 46 (18.0) a
Have dead or
dying trees, but
other priorities
precluded its
use a a 47 (13.3) a a
Other
categorical
exclusion used 14 (3.0) 16 (4.1) 13 (3.7) 21 (8.2) 2 (1.2)
Lack of
commercial
infrastructure
to harvest or
salvage trees 14 (3.0) 21 (5.3) 16 (4.5) 2 (0.8) 2 (1.2)
No hazardous
fuels a a a 13 (5.1) a
Ranger district
or national
forest
preference to
use an
environmental
assessment as
opposed to the
categorical
exclusion 5 (1.1) 13 (3.3) 8 (2.3) 6 (2.3) 5 (3.0)
Other reasons 64 (13.9) 80 (20.3) 45 (12.7) 51 (20.0) 10 (6.1)
Source: GAO.
aThe primary reason listed was not applicable to the categorical
exclusion and, thus, was not an option for the Forest Service to
choose.
(360854)
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Highlights of [20]GAO-07-1016T , testimony before the Subcommittee on
National Parks, Forests and Public Lands, Committee on Natural Resources,
House of Representatives
June 28, 2007
FOREST SERVICE
Vegetation Management Projects Approved during Calendar Years 2003 through
2005 Using Categorical Exclusions
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.
Percentage of Vegetation Management Projects and Treatment Acres Approved
Using an EA, EIS, or Categorical Exclusion, Calendar Years 2003 through
2005
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.
References
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19. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1016T
20. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1016T
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