oversight

Wildland Fires: Better Information Needed on Effectiveness of Emergency Stabilization and Rehabilitation Treatments

Published by the Government Accountability Office on 2003-04-04.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States General Accounting Office

GAO          Report to Congressional Requesters




April 2003
             WILDLAND FIRES
             Better Information
             Needed on
             Effectiveness of
             Emergency
             Stabilization and
             Rehabilitation
             Treatments




GAO-03-430
             a
                                               April 2003


                                               WILDLAND FIRES

                                               Better Information Needed on
Highlights of GAO-03-430, a report to the      Effectiveness of Emergency Stabilization
Chairman, House Committee on
Agriculture, and the Chairman, House           and Rehabilitation Treatments
Subcommittee on Department Operations,
Oversight, Nutrition, and Forestry,
Committee on Agriculture




Wildfires burn millions of acres               Both Interior and USDA’s Forest Service use multidisciplinary teams of
annually. Most burnt land can                  experts, such as ecologists and soil scientists, to assess damage and
recover naturally, but a small                 potential risks burnt land poses and to develop emergency stabilization and
percentage needs short-term                    rehabilitation plans that identify needed treatments to reduce or eliminate
emergency treatment to stabilize               those risks. The two departments differ in how they manage their programs,
burnt land that threatens public
safety, property, or ecosystems or
                                               however. Interior uses a single process to assess damage and identify
longer-term treatments to                      treatments for short-term emergency stabilization and longer-term
rehabilitate land unlikely to recover          rehabilitation, while USDA’s Forest Service uses different processes for each
naturally. The Department of the               of these two treatment types. The two departments recognize these
Interior (Interior) and the                    differences and recently agreed to work toward standardizing certain
Department of Agriculture’s                    aspects of their programs, such as definitions and time frames.
(USDA’s) Forest Service—the two
departments that manage most                   Following the 2000 and 2001 fires, the Forest Service obligated $192 million
federal land—spend millions of                 and Interior $118 million for 421 emergency stabilization and rehabilitation
dollars annually on such                       treatment plans GAO reviewed. Treatments included seeding; fencing;
treatments. GAO was asked to (1)               installing soil erosion barriers such as straw bundles, or wattles; and road
describe the two departments’
processes for implementing their
                                               or trail work. Most of Interior’s land—managed by the Bureau of Land
programs, (2) identify the costs and           Management—consists of rangeland. Thus, the bureau primarily seeded
types of treatments implemented,               native grasses to retain soils and forage for cattle and wildlife and fenced to
and (3) determine whether these                prevent grazing. Forest Service land is often steeply sloped and includes
treatments are effective.                      watersheds used for drinking water and timber. The Forest Service primarily
                                               seeded fast-growing grasses and built soil erosion barriers for emergency
                                               stabilization, and worked on roads, trails and reforested for rehabilitation.

To ensure effective emergency                  Neither the departments nor GAO could determine whether emergency
stabilization and rehabilitation               stabilization and rehabilitation treatments were achieving their intended
treatments, GAO recommends                     results. The departments require that treatments be monitored, but they do
Interior and USDA (1) specify
                                               not specify how and the type of data to collect or analyze for determining
procedures to be used to monitor
treatment effectiveness, including             effectiveness. The departments have stressed the need to systematically
type and extent of monitoring data             collect and share monitoring data for treatment decisions. Yet neither has
collected and methods to collect               developed a national interagency system to do so. Therefore, the nature and
these data, and (2) develop an                 extent of data collection, analysis, and sharing vary widely. The departments
interagency system to collect,                 recognize that they need better information on treatment effectiveness.
store, and disseminate information             However, they have not yet committed to this effort.
on monitoring results.

Commenting on the draft report,
Interior and USDA generally agreed
they can do more to ensure that
funds for emergency stabilization
and rehabilitation are used
effectively.
www.gao.gov/cgi-bin/getrpt?GAO-03-430.

To view the full report, including the scope
and methodology, click on the link above.
For more information, contact Barry Hill at
(202) 512-3841 or hillbt@gao.gov.
Contents



Letter                                                                                                     1
                             Results in Brief                                                              3
                             Background                                                                    6
                             Processes Differ between the Departments for Assessing the Need
                                to Treat Burnt Lands and Approving Treatment Plans                        10
                             Rehabilitation Plans Vary Widely in Cost and in the Number and
                                Types of Treatments                                                       20
                             Interior and the Forest Service Cannot Determine Overall Treatment
                                Effectiveness                                                             37
                             Conclusions                                                                  46
                             Recommendations for Executive Action                                         47
                             Agency Comments and Our Evaluation                                           47


Appendixes
              Appendix I:    Scope and Methodology                                                        49
             Appendix II:    Comments from the Departments of the Interior and
                             Agriculture                                                                  52
             Appendix III:   GAO Contact and Staff Acknowledgments                                        55


Tables                       Table 1: Amount of Funding and Number of Plans Approved, by
                                      State Where Wildland Fire Occurred, 2000 and 2001                   21
                             Table 2: Number and Percent of Plans in Different Cost Ranges and
                                      Total Costs and Percentage of Total Costs within Those
                                      Ranges, 2000 and 2001                                               22
                             Table 3: Number and Cost of Emergency Stabilization and
                                      Rehabilitation Plans Approved by Interior, 2000 and
                                      2001                                                                23
                             Table 4: Costs of Different Interior Emergency Stabilization and
                                      Rehabilitation Treatments, 2000 and 2001                            24
                             Table 5: Costs of Different Forest Service Emergency Stabilization
                                      and Rehabilitation Treatments, 2000 and 2001                        31


Figures                      Figure 1: Rangeland Drill Seeding in Idaho                                   26
                             Figure 2: Burnt BLM Lands Needing Fencing to Exclude
                                       Grazing                                                            27
                             Figure 3: Burnt and Unburnt Flammable Noxious or Invasive
                                       Weeds                                                              30




                             Page i                                   GAO-03-430 Wildland Fire Rehabilitation
Contents




Figure 4: Straw Wattles Used to Help Retain Soils and Reduce
          Erosion                                                                          33
Figure 5: Mulching Used to Stabilize Soils                                                 34
Figure 6: Upgraded Culvert to Withstand Increased Storm
          Runoff                                                                           35




Abbreviations

BLM          Bureau of Land Management
USDA         U.S. Department of Agriculture


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Page ii                                           GAO-03-430 Wildland Fire Rehabilitation
A
United States General Accounting Office
Washington, D.C. 20548



                                    April 4, 2003                                                                   Leter




                                    The Honorable Bob Goodlatte
                                    Chairman, Committee on Agriculture
                                    House of Representatives

                                    The Honorable Gil Gutknecht
                                    Chairman, Subcommittee on Department Operations,
                                     Oversight, Nutrition, and Forestry
                                    Committee on Agriculture
                                    House of Representatives

                                    In 2002—the second largest fire season in the past 50 years—wildland fires
                                    burned almost 7 million acres and destroyed timber, natural vegetation,
                                    habitat for wildlife, homes, and commercial businesses. Wildland fire is a
                                    natural occurrence and millions of acres burn annually. Some ecosystems
                                    rely on such fires to maintain their health, but unnatural fuel conditions
                                    have increased the severity and extent of some wildfires and, in some
                                    instances, the burnt landscape that remains after a catastrophic fire can
                                    threaten human safety, property, and the ecosystem. Rainstorms that pelt
                                    scorched and highly erosive soils can cause rock and mud slides in
                                    watersheds and ultimately contaminate municipal water supplies. In areas
                                    of steep terrain, sedimentary runoff can bury homes, destroy roads, and
                                    clog streams. Wildland fires can also create postfire environments that are
                                    ideal for the growth of noxious or invasive weeds. If these weeds replace
                                    native plant species, threatened or endangered animals can lose their
                                    habitat.

                                    When burnt lands threaten human health and safety, property, and
                                    ecosystems, treatment measures, such as seeding, may be undertaken to
                                    stabilize soils and mitigate these risks. According to Department of the
                                    Interior (Interior) and U.S. Department of Agriculture’s (USDA’s) Forest
                                    Service data, only a small percentage of the many wildland fires that occur
                                    each year require such treatment. Specifically, of the roughly 39,000
                                    wildfires that occurred in 2000 and 2001 on lands managed by Interior and
                                    the Forest Service, only about 600 required treatment.

                                    The USDA’s Forest Service and Interior’s Bureau of Indian Affairs, its
                                    Bureau of Land Management (BLM), its Fish and Wildlife Service, and its
                                    National Park Service are responsible for implementing programs to
                                    manage wildland fire, including determining whether the burnt lands
                                    require treatment. Within Interior, BLM is the largest land manager and



                                    Page 1                                    GAO-03-430 Wildland Fire Rehabilitation
oversees about half of the lands the department manages. In Interior
agencies as well as in the Forest Service, local land units, such as national
forests or national parks, are responsible for treating burnt lands that are
not likely to recover on their own.

Interior and the Forest Service categorize postwildland fire treatments as
either emergency stabilization or rehabilitation. Emergency stabilization
treatments are those judged necessary to apply following a wildland fire to
stabilize a burnt area and hence, any further damage; and protect valued
resources, such as public health and safety. These actions usually are taken
within a relatively short period of time following a wildfire, such as before
the first storm event. On the other hand, rehabilitation treatments occur
when the damages are deemed sufficiently severe that treatments for
reestablishing habitat—such as planting shrubs and trees—and repairing
fire damages—such as rebuilding burnt structures—when local land units
judge them as being necessary. Interior funds emergency stabilization and
rehabilitation treatments for up to 2 full growing seasons but no more than
3 years following a wildfire. The Forest Service specifies that emergency
stabilization treatments generally be undertaken within the first 2 years
following a wildfire, while rehabilitation treatments may be initiated for up
to 3 years following a fire.

In response to the catastrophic wildland fires of 2000, Interior and USDA
developed the National Fire Plan—a multibillion-dollar effort to address
the nation’s wildland fire threats. In supporting this plan, Congress targeted
funds for treating burnt lands that were unlikely to recover naturally from
the effects of wildland fire. In fiscal years 2001 and 2002, USDA received a
total of $205 million and Interior received a total of $125 million for treating
burnt lands.




Page 2                                      GAO-03-430 Wildland Fire Rehabilitation
                   You asked us to (1) describe Interior’s and USDA’s processes for
                   implementing their emergency stabilization and rehabilitation programs,
                   (2) identify the costs and types of treatments the departments have
                   implemented, and (3) determine whether these treatments are effective. To
                   answer these questions, we, among other things, reviewed 421 plans that
                   the departments developed for carrying out emergency stabilization and
                   rehabilitation treatments on lands burned by about 590 wildland fires in
                   calendar years 2000 and 2001.1 These plans represent about 90 percent of
                   the plans that the departments developed for treating the wildland fires
                   that occurred in 2000 and 2001. The plans identify the risks posed by these
                   fires, the need for and type of emergency stabilization or rehabilitation
                   treatments, estimated costs for those treatments, and the intended
                   treatment results. In addition, we gathered monitoring data on up to 3,
                   including some of the most expensive, treatments for 18 emergency
                   stabilization and rehabilitation plans for fires that occurred in 2000 to
                   determine if and how the departments are monitoring treatments, and
                   whether treatments are effective. In total, the treatments we reviewed
                   accounted for about 30 percent of the funding approved by the
                   departments for treating the fires that occurred in 2000 and 2001. In
                   addition, we reviewed departmental studies on monitoring and treatment
                   effectiveness. We conducted our review from August 2001 through
                   February 2003 in accordance with generally accepted government auditing
                   standards. (See app. I for details on our scope and methodology.)



Results in Brief   Interior’s and USDA’s processes for stabilizing and rehabilitating severely
                   burnt lands often start while a wildfire is still burning or immediately after
                   it has been contained. To determine the need for emergency stabilization
                   treatments, both Interior agencies and USDA’s Forest Service use
                   multidisciplinary teams of experts, such as wildlife biologists, ecologists,
                   and soil scientists, who assess the extent of damage and the potential risks
                   the burnt lands pose to public health and safety. However, Interior agencies
                   and the Forest Service differ in their approaches to assessing the need for,
                   and approval of, the longer-term rehabilitation of burnt lands. Interior uses
                   the same process for emergency stabilization and rehabilitation by
                   concurrently assessing both the need for and type of treatment after a
                   wildland fire; and funding for such treatments. In contrast, the Forest


                   1
                    Some Interior and Forest Service plans covered more than one fire. In those instances,
                   several fires on an agency’s local land unit occurred at about the same time, and local land
                   unit officials decided to include treatments for those fires under one plan.




                   Page 3                                              GAO-03-430 Wildland Fire Rehabilitation
Service uses a separate planning process and funding to identify and set
priorities for rehabilitation treatments, after much of the fire season has
ended. According to Interior officials, it is easier to administer the program
through one process. Forest Service officials said that the agency has two
separate processes. This is because emergency treatments to stabilize
burnt lands must be undertaken quickly and generally do not have long-
term consequences for land management, whereas rehabilitation
treatments can potentially have long-term consequences and potentially
involve a number of different Forest Service programs. The departments
are not required to develop a single process to administer their emergency
stabilization and rehabilitation programs, although federal policy
encourages the departments to standardize their processes and
procedures. To this end, in January 2003, the two departments agreed to
work towards standardizing certain aspects of their programs, such as
definitions and timeframes.

Following the calendar year 2000 and 2001 fires, Interior obligated about
$118 million, and USDA’s Forest Service about $192 million, on emergency
stabilization and rehabilitation for the 421 wildland fire plans we reviewed.
The bulk of these funds—82 percent—were to treat burnt lands in Idaho,
Montana, Nevada, and New Mexico. These four states experienced a
relatively high percentage of the catastrophic fires in 2000 and 2001 that
required treatment. Most of the departments’ individual emergency
stabilization and rehabilitation plans called for spending less than $1
million for one or more projects, but the plans varied widely in terms of the
cost and scope of work, ranging from about $2,000 to over $40 million.
Most of the funds were used to seed, reforest, and repair roads and trails.
Although the Forest Service and Interior agencies used similar treatments,
they varied in which treatments they used most frequently, primarily
because the lands they manage have different characteristics. For example,
most of Interior’s land is managed by BLM. Because much of BLM’s lands
consist of rangeland, including land that is arid and semi-arid, it relies
primarily on treatments such as seeding with native grasses to retain soils
and forage for cattle and wildlife, and fencing to prevent grazing on burnt
lands. In contrast, Forest Service land is often steeply sloped and includes
watersheds that are used as drinking water sources and timber growth. As
a result, the Forest Service relies primarily on emergency treatments, such
as stabilizing soils and slopes by, for example, installing soil erosion
barriers such as straw bundles, or wattles, and seeding with fast-growing
grasses; the Forest Service’s rehabilitation treatments include longer-term
treatments such as road and trail work and reforestation.




Page 4                                     GAO-03-430 Wildland Fire Rehabilitation
The departments do not, and we could not, determine the overall
effectiveness of emergency stabilization and rehabilitation treatments
because most land units do not routinely document monitoring results, use
comparable monitoring procedures, collect comparable data, or report
monitoring results to the agencies' regional or national offices. Both
departments either require or strongly encourage land units to monitor for
treatment effectiveness, but neither department provides specific
standardized guidance on how these units should monitor. As a result, we
found that local land units used different monitoring methods, making it
difficult to assess the effectiveness of treatments. Three national forests
treating similarly burnt slopes with the same treatment—soil erosion
barriers—illustrate this point. In one forest, staff only visually observed the
treated slopes; in another the staff both visually observed and collected soil
erosion data, which they analyzed to assess treatment effectiveness; and in
the third the staff both visually observed and collected soil erosion data,
which, because of data limitations, they were unable to analyze to assess
treatment effectiveness. To judge whether soil erosion barriers were
effective, each forest developed its own standard for treatment
effectiveness. Because these national forests used different methods and
standards to assess and judge treatment effectiveness, we could not draw
overall conclusions about the effectiveness of erosion barriers in
protecting resources at risk at these three forests. In addition, even when
local land units collected data and made assessments of treatment
effectiveness, they had not generally shared results with other land units or
reported these results to the agencies’ regional or national offices. The
departments’ internal reviews noted similar concerns about differences in
monitoring procedures, the quality of monitoring data, the inability to
assess the effectiveness of treatments, and the lack of data analysis and
dissemination. The departments recognize the need for improved
monitoring and data dissemination, but a lack of priority and concern
about the extent of work that could be required to accomplish this has
resulted in little effort being spent to address these issues. Consequently,
the departments can neither compile nor verify the accuracy of monitoring
results to determine overall treatment effectiveness or lessons learned.

To better judge the effectiveness of emergency stabilization and
rehabilitation treatments in accomplishing their intended purposes and to
benefit from lessons learned, we are recommending that the Secretaries of
Agriculture and of the Interior specify the monitoring data that local land
units should gather and require their agencies to collect, analyze, and
disseminate the results of these data.




Page 5                                      GAO-03-430 Wildland Fire Rehabilitation
             In responding to a draft of this report, the departments generally agreed
             with our recommendations and acknowledged that more needs to be done
             to ensure that funds for emergency stabilization and rehabilitation
             treatments on burnt lands are used as effectively as possible. The
             departments provided us with some examples on how they have tried or
             are trying to obtain and share better data on treatment effectiveness. For
             the most part, these examples are either (1) individual agency actions, as
             opposed to interagency or interdepartmental collaborative efforts, or (2)
             not extensive enough to ensure that sufficient data are routinely collected,
             analyzed, and disseminated.



Background   Recent fire seasons have shown that past fire suppression policies have not
             worked as effectively as was once thought. In fact, they have had major
             unintended consequences, particularly on federally owned lands. For
             decades, the federal wildland fire community followed a policy of
             suppressing all wildland fires as soon as possible. As a result, over the
             years, brush, small trees, and other vegetation accumulated that can fuel
             fires and cause them to spread more rapidly. This combination of
             accumulated underbrush and rapidly spreading fires heighten the potential
             for fires to become catastrophic. The buildup of excessive underbrush is
             not the only cause of catastrophic wildfires, however. The weather
             phenomenon known as La Nina, characterized by unusually cold Pacific
             ocean temperatures, changed normal weather patterns when it formed in
             1998. It caused severe, long-lasting drought across much of the country,
             drying out forests and rangelands. This drought is cited by some as one of
             the major causes for the 2002 catastrophic wildland fires, which nearly
             surpassed those of 2000.

             BLM, the Fish and Wildlife Service, the National Park Service, and the
             Forest Service manage about 700 million acres, or 96 percent of all federal
             lands. In addition, Interior’s Bureau of Indian Affairs manages another 55
             million acres. Most federal lands in the 48 contiguous United States are
             located in 11 western states, many of which have seen a dramatic surge in
             population over the last two decades, complicating the management of
             wildland fires. New development is occurring in fire-prone areas, often
             adjacent to federal lands, and creating a wildland-urban interface—an area
             where structures and other human development meet or intermingle with
             undeveloped wildland. This relatively new phenomenon means that more
             communities and structures are threatened by wildland fire and of
             potential postfire effects, including increased erosion and flooding.




             Page 6                                    GAO-03-430 Wildland Fire Rehabilitation
Interior agencies and the Forest Service have undertaken postwildfire
measures aimed at reducing potential postfire effects for several years.
Since the early 1960s, BLM has had a program to curb damages often
associated with wildfires—soil erosion and potential changes in vegetation.
Similarly, the Forest Service has implemented postfire measures, such as
seeding, since the 1930s. According to a Forest Service analysis of such
measures implemented between 1973 and 1998 in the western United
States, more than $110 million, in total, has been spent on treating burnt
lands.2 Furthermore, postfire expenditures have increased substantially,
especially during the 1990s, as the number of Forest Service acres that burn
annually increased and as the Forest Service used treatments more
extensively. This finding is consistent with Interior’s analysis of emergency
stabilization fire treatments on BLM lands.3 Similarly, according to Fish and
Wildlife Service officials, even though it has undertaken postwildfire
measures for several years, its policy on what measures are appropriate
has evolved from measures aimed primarily at “keeping the soil in place” to
those having additional functions such as combating invasive or noxious
weeds or plants.




2
 USDA, Forest Service, Rocky Mountain Research Station, Evaluating the Effectiveness of
Postfire Rehabilitation Treatments, General Technical Report RMRS-GTR-63 (Fort Collins,
Colo.: Sept. 2000).
3
 U.S. Geological Survey, Forest & Rangeland Ecosystem Science Center and Oregon State
University, Department of Rangeland Resources, Emergency Fire Rehabilitation of BLM
Lands in the Intermountain West: Revegetation & Monitoring, Interim Report to the BLM
(Corvallis, Oreg.: Jan. 26, 2002).




Page 7                                          GAO-03-430 Wildland Fire Rehabilitation
Responding in the aftermath of the disastrous 1994 fire season, when
several lives were lost, Interior, the Forest Service, and other federal
agencies undertook an extensive interagency review and revision of federal
fire management policies.4 The resulting 1995 Federal Wildland Fire Policy
and Program Review proposed a set of uniform federal policies to enhance
effective and efficient operations across administrative boundaries and
improve the agencies’ capabilities to meet challenges posed by wildland
fire conditions.5

Large-scale wildfires continued to burn throughout the United States, with
severe fire seasons in 1996, 1999, and 2000. Following the 2000 wildland
fires, the administration asked USDA and Interior to recommend how best
to respond to the 2000 fires and how to reduce the impacts of such fires in
the future. The resulting report—the National Fire Plan—recommended
increased funding for several key activities, such as suppressing wildland
fires and reducing the buildup of unwanted hazardous fuels. The report
also recommended expanded efforts to restore burnt lands because some
of the fires burned with such intensity that they drastically changed
ecosystems, and, without intervention, these ecosystems would recover
slowly. The report recognized two key aspects of treatment activities:
short-term treatments to remove hazards and stabilize soils and slopes,
such as constructing dams to hold soil on slopes, and longer-term
treatments to repair or improve lands unlikely to recover naturally from
severe fire damage by, for example, reforesting desired tree species. To set
priorities, restoration was to be undertaken on burnt lands that could affect

• public health and safety, as in the case of lands used as sources for
  domestic water supplies—that is, municipal watersheds;

• unique natural and cultural resources, such as salmon and bull trout
  habitat, and burnt land susceptible to the introduction of nonnative
  invasive species; and




4
 In addition to Interior and USDA, the Federal Emergency Management Agency, the
Environmental Protection Agency, and the National Oceanic and Atmospheric
Administration participated in the review.
5
 In 2001, the federal agencies responsible for the Federal Wildland Fire Policy updated the
1995 policy to clarify its purpose and intent and to address issues not fully covered in 1995.
The 2001 review and update replaced the 1995 policy.




Page 8                                              GAO-03-430 Wildland Fire Rehabilitation
• other environmentally sensitive areas where economic hardship may
  result from a lack of reinvestment in restoring damaged land, such as
  land used for recreation and tourism.

To fund the National Fire Plan, Congress appropriated $2.9 billion for the
two departments’ fiscal year 2001 wildland fire needs—an increase of $1.4
billion over the departments’ prior year funding of $1.5 billion. Of the $2.9
billion appropriated in 2001, $227 million was to be used for treating burnt
lands. For fiscal year 2002 wildland fire needs, Congress appropriated $2.3
billion for the two departments and specified that $103 million was to be
used for treating burnt lands. To carry out national fire plan goals and
objectives, including those for treating burnt lands, Interior and the Forest
Service have each designated national fire plan coordinators. To achieve
more consistent and coordinated efforts in implementing the Federal
Wildland Fire Policy and the National Fire Plan, and in response to a
recommendation made by the National Academy of Public Administration,6
the Secretaries of Agriculture and of the Interior established a Wildland
Fire Leadership Council in April 2002. Comprised of members of both
departments, the council is charged with, among other things, coordinating
efforts to restore ecosystem health and monitoring performance.

Within the agencies of Interior and the Forest Service, wildland fire
activities are largely carried out by local land units. Within Interior, BLM’s
local land units include district or field offices; the Fish and Wildlife
Service’s and the National Park Service’s local land units consist of
facilities, refuges, or parks; and the Bureau of Indian Affairs’ local land
units consist of agencies. The Forest Service’s local land units consist of
national forests and grasslands. BLM’s state offices oversee the local land
units, while the Bureau of Indian Affairs, Fish and Wildlife Service, National
Park Service, and Forest Service regional offices oversee local land units.




6
National Academy of Public Administration, Managing Wildland Fire: Enhancing
Capacity to Implement the Federal Interagency Policy (Washington, D.C.: Dec. 2001).




Page 9                                           GAO-03-430 Wildland Fire Rehabilitation
Processes Differ           Interior and USDA have different policies and procedures to assess
                           whether burnt lands need to receive any short-term or longer-term
between the                treatments following wildland fire. Interior has one overall policy and
Departments for            procedure for its four land management agencies to determine the need for
                           both short- and longer-term treatments. USDA’s Forest Service has separate
Assessing the Need to      policies and procedures for assessing the need for short-term emergency
Treat Burnt Lands and      stabilization treatments immediately following a wildland fire and for
Approving Treatment        longer-term nonemergency treatments for rehabilitating burnt lands.
                           Interior and the Forest Service have attempted to adopt the same policies
Plans                      and procedures for treating burnt lands, even though the National Fire Plan
                           does not require them to do so and recently agreed to work towards
                           standardizing certain aspects of their programs.



Interior Has a Single      Under Interior’s policy and procedure for implementing its emergency
Process to Identify Both   stabilization and rehabilitation program to treat burnt lands, its agencies
                           are to take four key steps. The agencies are to (1) assess burnt lands to
Emergency Stabilization    determine whether treatments should be taken to stabilize or rehabilitate
and Rehabilitation         them, (2) identify treatments when actions are considered necessary,
Treatments                 (3) approve and fund necessary treatments, and (4) implement treatments
                           once funding is available.

                           Local land unit managers are responsible for having burnt lands assessed to
                           determine whether stabilization or rehabilitation is needed. Interior
                           recommends that these managers start the process before a fire is
                           contained in order to identify any emerging issues, conduct a preliminary
                           risk analysis, and ensure a smooth transition from fire suppression to
                           emergency stabilization and rehabilitation. Local land unit managers
                           decide whether an intensive assessment of the burnt lands is warranted. In
                           most cases, these managers decide that no such assessment is needed
                           because they believe that the burnt lands pose no risk and that the lands
                           will recover on their own within a relatively short period.

                           If local land unit managers decide that an intensive assessment is
                           warranted, they assemble an interdisciplinary teams from the local land
                           units to assess the burnt lands and where appropriate, propose treatment.
                           The team’s composition varies according to the complexity of the fire and
                           availability of personnel with different skills and backgrounds. In general,
                           Interior’s interagency guidance recommends that teams comprised of staff
                           specializing in, for example, wildlife, ecology, rangeland, soils, and
                           watersheds. The guidance also suggests that managers include expertise



                           Page 10                                   GAO-03-430 Wildland Fire Rehabilitation
from cooperating agencies’ offices, especially when needed skills are not
available within the local office. The agencies can also have available state
or regional staff assist local teams. While the teams are comprised of
agency officials, they can and do consult, as needed, with other
organizations and individuals, including those from local communities.

In some instances, wildland fires may encompass multiple agencies’ lands,
result in burnt conditions that are beyond the capability of the local staff to
assess, or place many valued resources at risk. In these situations, the local
land unit manager can ask Interior to deploy one of two interagency teams
to assess large, multijurisdictional wildland fires. Interior’s national
wildland fire management office must approve any request for assistance.
These teams include specialists from each of the affected agencies and
represent a wide variety of skills. In 2000 and 2001, these multiagency
teams were deployed eight times to assess fires we included in our review.

Both local and multiagency teams evaluate whether and what kinds of
treatments are needed. They review any applicable land or resource
management plans for the affected land management units to ensure that
any recommended treatment action will be compatible with these plans.7
The teams also review other available data that may help identify resources
at risk, including data on cultural resources; threatened and endangered
species; vegetation inventories, including information on invasive species;
and soil types.




7
 Land or resource management plans serve as a basis for activities that occur on lands
managed by Interior agencies. The Forest Service is required to develop similar plans for
lands that it manages.




Page 11                                            GAO-03-430 Wildland Fire Rehabilitation
Upon completing their field inspections, teams brief local land unit
managers on whether and what type of treatments may be appropriate. If
the local land unit managers decide to proceed with treatment, they direct
the team to prepare a treatment plan, which includes, among other things, a
summary of activities and costs. In developing these plans, the team must
consider the requirements of the National Environmental Policy Act and
any other relevant statutes.8 In general, a team requires about 2 to 3 weeks
to review the necessary land and resource management plan, data
associated with the wildland fire, and any other data that may identify
resources at risk; conduct the site inspection; and prepare the treatment
plan.

While Interior has a single process and uses the same funds and plans to
identify both emergency stabilization and rehabilitation treatments, it
recognizes that the treatments are intended for different purposes.
Emergency stabilization treatments include those to (1) stabilize and
prevent unacceptable degradation to natural or cultural resources, (2)
minimize threats to life or property, or (3) repair, replace, or construct
improvements to prevent land or resource degradation. Rehabilitation
treatments include those to repair or improve lands unlikely to recover
naturally. While Interior’s guidance indicates that plans are to identify
treatments undertaken for emergency stabilization purposes as opposed to
rehabilitation, our review of Interior’s emergency stabilization and
rehabilitation plans for calendar year 2000 and 2001 fires indicates that they
do not always make such a distinction. Interior’s guidance also states that
both emergency stabilization and rehabilitation treatments are to be
designed to be cost-effective and to meet treatment objectives.

The agencies differ in how quickly they require that treatment plans be
completed—from 5 days to 1 month. Once the treatment plan is completed,

8
 The National Environmental Policy Act requires all federal agencies to prepare detailed
environmental impact statements for major federal actions that may significantly affect the
quality of the human environment. Agencies may exclude categories of actions that do not
significantly affect the environment from the act’s environmental impact requirements.
Some Interior agencies, such as the National Park Service and the Bureau of Indian Affairs,
have developed categorical exclusions. Interior and USDA are currently proposing to
categorically exclude stabilization and rehabilitation of all lands and infrastructure
impacted by wildland fires or fire suppression. Other relevant statutes include the
Endangered Species Act, which requires agencies to ensure that their actions are not likely
to jeopardize the continued existence of species listed as threatened or endangered or to
adversely modify habitat critical to their survival. In addition, the National Historic
Preservation Act requires federal agencies to take into account the effects of their actions
on sites or buildings on or eligible for inclusion on the National Register of Historic Places.




Page 12                                              GAO-03-430 Wildland Fire Rehabilitation
                            the Interior agencies must approve it, usually within 1 to 2 weeks. The
                            agencies’ processes for approval vary, depending upon the cost of the
                            treatment. For example, BLM has delegated approval authority for plans of
                            less than $100,000 to its state offices, while its national office must approve
                            plans of $100,000 or more. In contrast, the National Park Service does not
                            delegate any approval authority to its local land management units; its
                            regional offices approve plans of less than $300,000, while its national
                            office approves plans of $300,000 or more. When a treatment plan and
                            funding is approved, the local land unit officials are generally responsible
                            for having the treatments specified in the plan implemented. Interior
                            requires that treatments be implemented within 3 years.



The Forest Service Has      The Forest Service distinguishes between short-term emergency
Different Processes to      treatments to stabilize lands burnt by wildland fires and longer-term
                            rehabilitation treatments. Its process for short-term treatments is similar to
Identify Emergency
                            Interior’s. Under this process, local land units are responsible for
Stabilization and           assembling interdisciplinary teams of agency officials to survey fires that
Rehabilitation Treatments   are 300 acres or larger to determine if emergency conditions exist and if so,
                            whether treatments are needed. Forest Service teams can also consult with
                            other agencies and individuals, as necessary. The Forest Service does not
                            have a national team to assess large, multijurisdictional fires. However,
                            Forest Service staff are members of Interior’s interagency teams and these
                            teams have assessed fires on National Forest System lands. The Forest
                            Service’s rehabilitation process, however, differs from Interior’s.




                            Page 13                                     GAO-03-430 Wildland Fire Rehabilitation
Emergency Stabilization   Under the Forest Service’s emergency stabilization process, local land units
                          are to undertake only those treatments necessary to alleviate emergency
                          conditions following wildfire. These treatments include those necessary to
                          protect life and property and to prevent additional damage to resources.
                          The Forest Service directs that treatments be undertaken only when an
                          analysis of risks shows that planned actions are likely to reduce risks
                          significantly and are cost-effective. Further, because the Forest Service
                          funds emergency stabilization with emergency wildland fire funding, to
                          qualify for funding the Forest Service requires that treatment measures
                          provide essential and proven protection at minimum cost. According to
                          Forest Service officials, because the treatments are considered as
                          emergency actions, the Forest Service does not complete environmental
                          impact statements.9 In keeping with the emergency status of these
                          treatments, the Forest Service requires that plans be developed and
                          approved within 10 to 13 days following total containment of the wildland
                          fire. Delegated approval authorities vary by Forest Service region. Certain
                          regions, with a history of more frequent and larger fires, have higher
                          approval authorities than other regions. For example, the Forest Service’s
                          Pacific Southwest and Pacific Northwest regions (regions 5 and 6,
                          respectively), which generally have most of the catastrophic wildfires,
                          could approve plans costing up to $200,000 in 2000, while the Southern and
                          Eastern regions (regions 8 and 9, respectively), where large, catastrophic
                          fires are rare, were delegated no approval authority. Forest Service
                          headquarters must approve plans exceeding regional delegated levels of
                          approval authority. As with the Interior agencies, once an emergency
                          stabilization plan is approved, the local land unit officials implement the
                          plan. The Forest Service generally requires that treatments be implemented
                          within the first year, but provides for funding to maintain or install
                          additional treatments the next year.




                          9
                           The Council on Environmental Quality, in its regulations implementing the National
                          Environmental Policy Act, states that there are “emergency circumstances [that] make it
                          necessary to take an action with significant environmental impact without observing the
                          provisions of these regulations.” In such circumstances, however, agencies “should consult
                          with the Council about alternative arrangements.”




                          Page 14                                           GAO-03-430 Wildland Fire Rehabilitation
Longer-Term Rehabilitation   While the Forest Service’s short-term process for emergency stabilization is
                             similar to Interior’s, its longer-term rehabilitation process is not. According
                             to Forest Service officials, the agency developed a different process for
                             undertaking longer-term treatment on burnt lands when the National Fire
                             Plan was being developed and Congress was considering appropriating
                             additional funds to the Forest Service for restoring damaged lands. Before
                             the National Fire Plan, the Forest Service spent little money on
                             rehabilitation because it did not receive appropriations specifically for
                             such an effort. Once the agency realized that additional funding would be
                             available through the National Fire Plan, it began planning a separate
                             rehabilitation process. According to Forest Service officials, the agency
                             decided to have two separate processes because emergency treatments to
                             stabilize burnt lands are funded with emergency funding and must be
                             undertaken quickly. Further, such treatments generally do not have long-
                             term consequences for land management, whereas rehabilitation
                             treatments can potentially have long-term consequences, which may
                             require an environmental assessment,10 and involve a number of different
                             Forest Service programs.

                             In October 2000, the Forest Service asked the regional foresters to identify
                             proposed rehabilitation projects that supported the National Fire Plan. In
                             accordance with that plan, the Forest Service’s national fire plan
                             coordinator gave primary responsibility to the regions for implementing the
                             rehabilitation program. The coordinator instructed the regions to focus
                             rehabilitation efforts on restoring watershed conditions, including
                             protecting basic soil, water resources, and habitat for various native
                             species such as plants and animals. Projects were envisioned to be those
                             long-term efforts to rehabilitate or improve lands unlikely to recover
                             naturally from wildland damage, or to repair or replace minor facilities
                             damaged by fire. The coordinator also stressed the need for projects to be
                             (1) consistent with long-term goals and approved land use plans; (2) based
                             on sound analyses of the projects’ potential consequences; (3) developed
                             cooperatively with other federal, state, or local jurisdictions when wildland
                             fires crossed their jurisdictional boundaries; (4) those that meet the basic
                             objective of protecting life, property, and unique or critical cultural and
                             natural resources; and (5) undertaken within the perimeter of the burned
                             area. Funding to the regions was allocated based on acres burned and acres


                             10
                              The Forest Service is currently proposing to categorically exclude stabilization and
                             rehabilitation of lands and infrastructure damaged by wildland fires or fire suppression from
                             further analysis under an environmental assessment or an impact statement.




                             Page 15                                             GAO-03-430 Wildland Fire Rehabilitation
severely burned. The funding for such projects can be available for up to 3
years.

Building on these instructions, the Forest Service regions developed
different processes to identify proposed rehabilitation projects, as
illustrated by the experiences of the Northern and Intermountain regions,
respectively (regions 1 and 4) and the Southwestern Region (region 3).
Regions 1 and 4—which encompass Idaho, Montana, Nevada, North
Dakota, Utah, and portions of South Dakota and Wyoming—were most
affected by catastrophic wildland fires in 2000.11 The two regions jointly
developed additional criteria to use in identifying and reviewing
rehabilitation projects for fires that occurred in 2000. These criteria
included whether the proposed project would

• improve or protect water quality, or restore long-term watershed
  functions;

• restore municipal watersheds;

• involve community partnerships;

• involve nonfederal partners;

• integrate several components in the project;

• restore threatened or endangered species habitat;

• protect public health and safety;

• improve infrastructure as a necessary step in completing the project;

• address noxious or invasive weeds as a component of the project;

• be emphasized by the regional forester; or

• have visible accomplishments within the first year.




11
 Of the 275,036 Forest Service acres that were severely burned in 2000, about 176,062 acres,
or 64 percent, were located in regions 1 and 4.




Page 16                                            GAO-03-430 Wildland Fire Rehabilitation
According to region 1 and 4 officials, the regions developed these
additional criteria for reviewing their forests’ rehabilitation proposals
because Forest Service guidance was too general to assess and set
priorities for projects. These additional criteria allowed the two regions to
better compare proposals that the forests submitted.12

Region 3, which encompasses Arizona and New Mexico, and which was the
next region most affected by wildland fires in 2000, used a different
approach to identify and set priorities for projects.13 According to the
region 3 emergency stabilization and rehabilitation program coordinator,
while Congress was considering appropriating additional funding for the
National Fire Plan, the region assembled a team to determine which fires
were catastrophic in 2000 based on the (1) value of the losses incurred as a
result of the fire, (2) capability to repair or restore the loss, and (3)
potential cost to repair or restore the loss. Given these criteria, region 3
considered as catastrophic 5 of the 18 largest fires that occurred in 2000
and eligible for rehabilitation projects.

Forest Service officials said that the agency and regions undertook similar
processes to identify rehabilitation projects in 2002. However, the Forest
Service did not distribute all of the $63 million appropriated in fiscal year
2002 because it needed some of these funds for wildfire suppression. The
agency used some of this appropriation for suppression because putting
out fires is the agency’s top priority.14 According to the Forest Service


12
  In 2001, USDA’s Office of Inspector General reviewed controls over the National Fire Plan
funds in Forest Service region 1 and concluded that the Washington office had not
sufficiently overseen the selection process to ensure that projects met National Fire Plan
goals and objectives. The Forest Service agreed to review selected projects as part of its
fiscal year 2002 management review of regional operations. USDA, Office of Inspector
General, Forest Service National Fire Plan Implementation, Western Region Audit Report
No. 08601-26-SF (Washington, D.C.: Nov. 2001).
13
 Of the 275,036 Forest Service acres that were severely burned in 2000, about 41,800 acres,
or 15 percent, were located in region 3.
14
   When fire suppression costs exceed annual fire suppression appropriations, including
emergency funds, the Forest Service can transfer funds from any appropriation available to
the agency to the fire management appropriation. While Congress provided emergency
funding to the Forest Service in August 2002, the amounts provided were not sufficient to
cover that year’s suppression costs. As a result, the Forest Service was required to borrow
funds from other programs, including rehabilitation. According to Forest Service officials,
the agency’s fiscal year 2003 appropriation was not sufficient to fully reimburse all the
programs from which it borrowed in fiscal year 2002, and, as of March 2003, it was unclear
how the rehabilitation program would be affected.




Page 17                                            GAO-03-430 Wildland Fire Rehabilitation
                             national rehabilitation program coordinator, the severe wildland fires in
                             2002 required the Forest Service to use $84 million in rehabilitation
                             funding—a portion of the $63 million appropriated in fiscal year 2002 and a
                             portion of the $142 million appropriated in fiscal year 2001 but not yet
                             expended.



The Departments Are          As noted previously, prior to receiving additional funding under the
Working to Coordinate        National Fire Plan, USDA’s Forest Service largely limited its postwildland
                             fire treatments to emergency stabilization. However, in 1998, Interior and
Their Processes for          USDA initiated an effort to apply a consistent approach for both emergency
Administering Treatments     stabilization and longer-term rehabilitation. This included an effort to
Even Though Their Missions   develop an interagency handbook that agencies in both departments could
and Types of Land Differ     use. This effort was undertaken, in part, in response to the 1995 Federal
                             Wildland Fire Policy, which recommended that agencies work toward
                             standardizing their policies and procedures. The Wildland Fire Leadership
                             Council recently addressed this effort, which was abandoned in 2002
                             because of differences the agencies perceived in their missions, lands, and
                             use of resources.




                             Page 18                                   GAO-03-430 Wildland Fire Rehabilitation
According to Interior and Forest Service officials, they had worked to
integrate their different approaches, but discontinued this effort in 2002
because they decided that integration would be too difficult. The difficulty
arose because, according to these officials, their agencies and the lands
they manage are too dissimilar to have a consistent approach for treating
burnt lands. For example, BLM’s emergency stabilization and rehabilitation
efforts focus on stabilizing soils and ensuring a diversity of animal and
plant species because its mission emphasizes sustaining its lands for
multiple uses. The National Park Service’s emergency stabilization and
rehabilitation efforts focus on naturally preserving the lands and resources
for use by people. In contrast, the Forest Service stated that, historically, its
efforts have focused on short-term stabilization treatments that are
intended to protect life and property and prevent additional resource
damage because its mission emphasizes protecting and improving forests
and preserving watersheds. With the advent of the National Fire Plan,
however, the Forest Service enlarged this focus to consider not only
watersheds but also longer-term treatments to improve lands unlikely to
recover naturally by, for example, planting trees or monitoring for and
treating noxious plants or weeds. Because of this emphasis and the funding
specifically authorized for rehabilitation, the Forest Service established a
separate process for these longer-term efforts. The following illustrates the
extent of the difference between Interior and the Forest Service: Interior
uses the same process, staff, and funds to implement its emergency
stabilization and rehabilitation program because, according to Interior
officials, it is easier to do so. The Forest Service uses different processes,
staff, and funds to implement its emergency stabilization program and its
rehabilitation program because emergency stabilization has existed for
about 25 years while it considers rehabilitation as an expanded mission
based on the National Fire Plan appropriations language.15 The difference
in how the two departments fund emergency stabilization and
rehabilitation treatments resulted in the Office of Management and Budget
directing the Department of the Interior to identify nonemergency funding
options for its nonemergency treatments by March 2003.

Interior and Forest Service officials acknowledged that the Federal
Wildland Fire Policy encourages federal agencies to standardize processes
and procedures and said that their respective departments are working
together to better coordinate their programs. Even though the Fire Policy


15
 Interior uses both emergency and nonemergency funds for its program, while the Forest
Service limits its use of emergency funds to its emergency stabilization program.




Page 19                                          GAO-03-430 Wildland Fire Rehabilitation
                              and the National Fire Plan do not require that the departments have the
                              same processes for their respective programs or that they be fully
                              integrated, the Wildland Fire Leadership Council addressed differences in
                              the departments’ emergency stabilization and rehabilitation programs. In
                              January 2003, the council decided that both departments should have
                              standard and uniform definitions, time frames, and funding mechanisms for
                              efforts they take under their respective programs. According to the Forest
                              Service’s national emergency stabilization program coordinator, the
                              council’s decision will result in the two departments resuming their efforts
                              to develop and adopt the same interagency handbook for carrying out their
                              emergency stabilization and rehabilitation programs.



Rehabilitation Plans          Following the calendar years 2000 and 2001 fires, Interior and USDA’s
                              Forest Service approved 421 plans for stabilization and rehabilitation
Vary Widely in Cost           treatments for an estimated total of more than $310 million. Nearly all of
and in the Number and         the plans and costs were to treat fires that occurred in western states.
                              Within Interior, BLM accounted for the most plans—210 out of 266—and
Types of Treatments           approved the bulk of Interior’s funds—$88 million out of $118 million. The
                              Forest Service accounted for the next largest number of plans—155—and
                              approved $192 million—$53 million for short-term emergency stabilization
                              and $139 million for longer-term rehabilitation. While the two departments
                              implemented the same types of treatments on their lands following
                              wildland fire, such as seeding, the frequency with which they relied on
                              these treatments varied, primarily because of the types of lands they
                              manage.



Emergency Stabilization       As shown in table 1 for both Interior and the Forest Service, most
and Rehabilitation Plans      emergency stabilization and rehabilitation treatments occurred in western
                              states. Treatments occurred there primarily because much of the lands
Were Concentrated in
                              Interior and the Forest Service manage are in these states. Furthermore,
Western States and the Cost   during the summers of 2000 and 2001, states in the intermountain west
of Treatment Varied           were especially hard hit by drought and persistently dry conditions, which
                              gave rise to two of the worst wildfire seasons in the past 50 years.




                              Page 20                                   GAO-03-430 Wildland Fire Rehabilitation
Table 1: Amount of Funding and Number of Plans Approved, by State Where
Wildland Fire Occurred, 2000 and 2001

Dollars in millions
                                                   Percent of         Number of       Percent of
State                                  Funding          totala           plans             total
Montana                                  $96.0              30.9              33             7.8
Idaho                                     59.7              19.2              99            23.5
Nevada                                    56.1              18.1              98            23.3
New Mexico                                42.9              13.8              26             6.2
Oregon                                    15.7               5.1              40             9.5
Utah                                      10.8               3.5              49            11.6
Other                                     29.0               9.3              76            18.1
Total                                   $310.2             100.0             421           100.0
Source: Forest Service and Interior.

Note: GAO analysis of Forest Service and Interior data.
a
 The sum of the numbers does not add to the total because of rounding.


As table 1 shows, Montana and Idaho received more than 50 percent of the
stabilization and rehabilitation funding for the 2000 and 2001 fires.
Montana, which received the largest allocation, proposed to use almost half
of its funds for longer-term rehabilitation treatments in the Bitterroot
National Forest.

According to the estimates provided in the stabilization and rehabilitation
plans, the costs to treat wildfires varied widely. About 56 percent ($174.3
million) of the estimated $310 million was associated with only 18 of the
421 plans. Most of the plans (87 percent) estimated that treatment costs
would be under $1 million and the majority of those were less than
$100,000. Table 2 shows the number and percentage of plans that fall within
various cost estimate ranges and the total estimated costs and percentage
within these ranges.




Page 21                                                   GAO-03-430 Wildland Fire Rehabilitation
Table 2: Number and Percent of Plans in Different Cost Ranges and Total Costs and
Percentage of Total Costs within Those Ranges, 2000 and 2001

Dollars in millions
Range of costs per                     Number of    Percent of                        Percent of
plan                                      plans         plans               Cost       total cost
$10 million and over                          5              1.2           $96.2            31.0
$4 million to $9.999
million                                      13              3.1            78.1            25.2
$2 million to $3.999
million                                      14              3.3            37.0            11.9
$1 million to $1.999
million                                      22              5.2            30.7             9.9
Under $1 million                            367             87.2            68.1            22.0
Total                                       421            100.0          $310.1           100.0
Source: Forest Service and Interior.

Note: GAO analysis of Forest Service and Interior data.


The cost of individual emergency stabilization and rehabilitation
treatments ranged from about $2,000 to about $42 million. Cost differences
occurred primarily because of the number and type of treatments included
in the plan and the number of acres to be treated. This is illustrated in the
following examples:

• The most costly plan involved longer-term rehabilitation for the
  Bitterroot National Forest in Montana. In this plan, the Forest Service
  regional office included 5 different but almost simultaneous fires that
  engulfed about 185,000 acres in 2000.16 This plan includes planting trees,
  roadwork—including cleaning drainage structures, restoring road
  surfacing, and taking roads out of service—and removing dead and
  dying timber. The entire proposed cost of the plan is about $42 million,
  which, according to Forest Service officials, would be spent over a
  period of several years.

• One of the least costly plans—for the Lower Rio Grande Valley National
  Wildlife Refuge in southern Texas—proposed spending only about
  $2,500. While the fire was relatively small and only grew to about 10
  acres, the tract was in an urban area, surrounded by many homes and


16
     Similarly, all five fires were covered by one emergency stabilization plan.




Page 22                                                   GAO-03-430 Wildland Fire Rehabilitation
                                    farms. Given the fire’s location and the unique climate, geology,
                                    vegetation, and wildlife of the site, the Fish and Wildlife Service
                                    proposed to revegetate 5 of the burnt acres with native brush.



Interior’s Bureau of Land      Interior’s 4 agencies approved 266 plans, costing about $118.5 million. Of
Management Used the Most       the four agencies, BLM approved the largest number of plans and had the
                               largest share of total costs. Table 3 provides information on the number
Treatments, Primarily for
                               and cost of plans approved by Interior’s agencies in 2000 and 2001.
Restoring Forage Used for
Grazing and Wildlife Habitat

                               Table 3: Number and Cost of Emergency Stabilization and Rehabilitation Plans
                               Approved by Interior, 2000 and 2001

                               Dollars in millions
                                                              Number of
                               Agency                            plans Percent of plans                    Cost       Percent of cost
                               BLM                                     210                  78.9           $87.9                74.2
                               Bureau of Indian
                               Affairs                                  26                    9.8           17.6                14.9
                               Fish and Wildlife
                               Service                                  17                    6.4             8.7                 7.3
                               National Park
                               Service                                  13                    4.9             4.3                 3.6
                               Total                                   266                 100.0         $118.5                100.0
                               Source: Interior.

                               Notes: GAO analysis of Interior data.

                               Interior’s plans include both emergency stabilization and rehabilitation treatments.


                               Most of the funds Interior approved were used for seeding and fencing,
                               primarily because most of the fires occurred on rangelands BLM manages
                               in Idaho, Nevada, and Utah. About $67.2 million, or 70 percent, of the $96.1
                               million were for these two treatments. Table 4 provides data on the
                               treatments Interior used most frequently and the cost of these treatments.




                               Page 23                                                   GAO-03-430 Wildland Fire Rehabilitation
Table 4: Costs of Different Interior Emergency Stabilization and Rehabilitation
Treatments, 2000 and 2001

Dollars in millions
                                                             Cost of treatment in
Treatment                                                         agency plansa               Percent
Seeding                                                                        $57.5              59.8
Fencing                                                                           9.7             10.1
Reforestation                                                                     6.6               6.9
Cultural resource survey and/or cultural
resource protection                                                               5.2               5.4
Noxious or invasive plant monitoring and/or
weed treatment                                                                    6.9               7.2
                    b
Checkdams, straw wattles, contour felled
trees or log terraces, mulch                                                      2.9               3.0
Road or trail work                                                                1.6               1.7
Otherc                                                                            5.7               5.9
Total                                                                          $96.1             100.0
Source: Interior.

Note: GAO analysis of Interior data.
a
 Treatment cost excludes other costs associated with plans, such as plan development and monitoring
costs.
b
 Check dams are small structures made of rocks, logs, plant materials, or geotextile fabric. They are
designed to stabilize slopes and store small amounts of sediment.
c
  Other includes a number of infrequently used and less costly treatments, such as building or cleaning
out cachement basins, repairing or replacing minor structures, signs, felling trees that pose a hazard,
constructing racks to trap large debris, removing horses, and installing flood warning systems.


Of the four Interior agencies, BLM accounted for the largest share of
treatment costs and included some type of seeding as a treatment in about
190, or 90 percent, of its 210 plans. Similarly, BLM accounted for about $50
million of the $57.5 million that Interior approved for seeding. Much of the
lands managed by BLM consist of rangelands that produce forage for wild
and domestic animals, such as cattle and deer, as well as many other forms
of wildlife; its lands include grasslands and deserts—both arid and
semiarid land. Seeding was done to prevent soil erosion and to restore
forage used by cattle, mule deer, or elk; habitat used by other species such
as sage grouse; or reduce the potential for the invasion of undesirable or
noxious plants or weeds. According to BLM officials, the method used to
seed—whether by air or by drilling—depends primarily on the terrain, soil,
and seed or seed mixture used. This is illustrated by the following
examples:



Page 24                                                  GAO-03-430 Wildland Fire Rehabilitation
• Aerial seeding. One of the largest seeding treatments occurred to
  aerially seed about 40,000 acres in Nevada burned by the Twin Peaks
  Fire in 2000, at a cost of $5.4 million. For seeding the entire burnt area
  with a native seed mixture of wheat grasses, sagebrush, and wildrye, the
  local office decided that aerially seeding would be the most appropriate
  method. The seeded area was hilly to mountainous and because of this,
  the use of a helicopter or fixed-wing aircraft was proposed to spread
  seed across the burnt area. The seeding was intended to reduce the
  invasion and establishment of undesirable or invasive species of
  vegetation, particularly noxious weeds. In addition, the seeding—if
  successful—would provide mule deer and livestock with critical forage.

• Drilling. According to BLM officials, BLM frequently uses rangeland
  drills to seed. For example, following the Flat Top, Coffee Point, and Tin
  Cup wildfires, which burned about 117,000 acres of the Big Desert in
  Idaho, BLM approved $1.5 million to drill and aerially seed the burnt
  acreage. For seeding a mixture of wheatgrass, ricegrass, needlegrass,
  wildrye, and rice hulls, the local office decided to use a rangeland drill
  because the terrain was relatively flat and could be easily drilled.
  According to BLM, if BLM had not seeded, the lack of remaining seed
  could have impaired the land’s recovery and, in the long term, reduced
  species diversity and degraded habitat conditions for all wildlife species
  that used the Big Desert. Figure 1 depicts BLM seeding with a rangeland
  drill.




Page 25                                   GAO-03-430 Wildland Fire Rehabilitation
Figure 1: Rangeland Drill Seeding in Idaho




Interior agencies also frequently repaired or installed fencing following
wildland fire, primarily to protect burnt rangelands from cattle grazing to
allow for regeneration. Under Interior policy, BLM can exclude burnt lands
from grazing that are recovering from wildfire for a minimum of 2 years. Of
Interior’s 266 plans, 171 included fencing at a cost of $9.7 million. Most of
this cost—about $8.1 million—was for fencing on BLM lands. This is
illustrated by the following examples:

• After the West Mona Fire burned more than 22,500 acres in Utah, BLM
  approved a $1.7 million plan, which included about $241,000 to remove
  about 28 miles of fencing that was destroyed by the fire, construct 34
  miles of new protective fence, repair 11 miles of existing fence, and
  install 6 cattleguards. The new fencing was to be installed after the area
  was seeded. The fencing was to protect the burnt and seeded areas from
  livestock grazing for 2 years.

• After the Abert Fire burned 10,000 acres in Oregon, BLM approved a
  $61,000 plan that included about $10,500 for fencing. Much of the burnt



Page 26                                      GAO-03-430 Wildland Fire Rehabilitation
   acreage, before the fire, consisted mainly of sagebrush and native bunch
   grasses. BLM concluded that the majority of the burnt area retained
   sufficient native seeds and plant material in the soil for it to recover
   naturally. However, to help ensure natural vegetative recovery, BLM
   concluded that the burnt area needed to be protected from livestock
   grazing for at least 2 years.

Figure 2 shows BLM grazing lands that were burnt and will require new
fencing to exclude cattle.



Figure 2: Burnt BLM Lands Needing Fencing to Exclude Grazing




Reforestation, while not frequently used, was fairly costly. Reforestation
was used in 24 of the 266 plans, for a cost of $6.6 million, or an average of
about $275,000 per treatment. The only other treatment that was
comparable in cost was seeding, which averaged about $248,000 per
treatment. Reforestation was generally approved for funding to control the
spread of invasive species or to reduce wind and water erosion. For
example, the Fish and Wildlife Service developed a $181,500 plan to treat
the Ash Meadows National Wildlife Refuge in Nevada following a fire that



Page 27                                    GAO-03-430 Wildland Fire Rehabilitation
burned about 658 acres. The assessment team recommended that staff
from the local land unit collect seeds from mesquite and ash trees, contract
with nurseries to grow seedlings, and plant seedlings and cuttings primarily
to control the spread of invasive species and reduce erosion.

In addition, the Bureau of Indian Affairs used reforestation to replace
commercial timber trees that were lost as a result of wildfires. Beginning in
1998, the Bureau of Indian Affairs began to allow a limited amount of this
treatment to help ensure that Indian forest land continued to be perpetually
productive—a management objective established by the National Indian
Forest Resources Management Act. According to bureau officials,
catastrophic wildland fires can destroy viable seed necessary for regrowth
and the additional funding provided by the National Fire Plan allowed the
bureau to better meet reforestation needs after such wildfires. For
example, following the Clear Creek Divide Fire in 2000 on the Salish and
Kootenai Indian Reservation, the bureau approved $2 million to collect
ponderosa and lodgepole pine and western larch tree seeds on the
reservation, grow 2.5 million seedlings, and plant them on about 8,000
acres.




Page 28                                    GAO-03-430 Wildland Fire Rehabilitation
In conjunction with seeding and fencing, Interior agencies frequently
included monitoring burnt areas to see if noxious or invasive plants or
weeds had regenerated or moved into the area and treating them as
necessary. Of Interior’s 266 plans, 166, or more than 60 percent, included
monitoring and/or treating noxious or invasive plants or weeds as a
treatment, for a total cost of $6.9 million. BLM accounted for most of these
treatments. According to BLM officials, noxious or invasive weeds,
particularly cheatgrass, are one of the factors that has caused an increase
in the number and size of wildland fires.17 Such noxious or invasive weeds,
which grow vigorously in the early spring, can crowd out native grasses
and, during the arid summer months, can dry and provide excessive fine
fuels for wildland fires to spread over large expanses of land. Because fire
does not destroy some noxious or invasive plant seeds, the plants can
resprout and grow with even greater vigor following a wildland fire.
According to BLM officials, many local land units had completed the
necessary environmental assessments to use selected herbicides on
specified noxious or invasive weeds on its lands. As a result, the local land
units could include noxious or invasive weed treatments in their
emergency stabilization and rehabilitation plans. Figure 3 shows dried,
flammable noxious or invasive weeds prone to wildfire.




17
  Cheatgrass is a winter annual plant introduced from Europe and Asia. It grows during the
fall and winter and sets its seed in the early summer. Cheatgrass can take valuable mineral
and water resources from the soil, leaving native grasses, which are summer annuals, with
little nutrition. Because winter annuals set their seeds prior to the wildfire season in the
summer, they can quickly resprout in the fall. However, because native grasses set their
seeds in the fall, if they are consumed by wildfire in the summer, they are unable to leave
any seed.




Page 29                                            GAO-03-430 Wildland Fire Rehabilitation
                            Figure 3: Burnt and Unburnt Flammable Noxious or Invasive Weeds




                            Interior agencies also included cultural resource surveys in many plans and
                            treatments for known artifacts damaged or threatened by wildfire. Over
                            half of the plans included cultural resource surveys, for a total of $5.2
                            million. Although cultural surveys are not treatments, but activities, they
                            were included as treatment costs. According to BLM, which conducted
                            many of these surveys, it routinely conducts cultural surveys before
                            conducting ground-disturbing activities that have the potential to affect
                            sites or objects that could be or are eligible for the National Register of
                            Historic Places. When BLM anticipated any ground-disturbing treatment,
                            such as rangeland drill seeding or installing new fencing, it included
                            cultural resource surveys.



Most Forest Service Funds   Most of the funds the Forest Service approved for emergency stabilization
Were Used for               or rehabilitation were for longer-term rehabilitation. Of the $192 million
                            that the Forest Service approved, $139 million was for longer-term
Rehabilitation
                            rehabilitation while $53 million was for short-term emergency stabilization.
                            As noted previously, the Forest Service did not use all of its fiscal year 2002



                            Page 30                                     GAO-03-430 Wildland Fire Rehabilitation
appropriation of $63 million on longer-term rehabilitation because it
needed to spend some of these funds on suppressing wildfires.

Table 5 provides information on treatments and their costs in the Forest
Service’s 113 emergency stabilization plans and its 42 rehabilitation plans.



Table 5: Costs of Different Forest Service Emergency Stabilization and
Rehabilitation Treatments, 2000 and 2001

Dollars in millions
                             Cost of emergency                                   Cost of
                                   stabilization                          rehabilitation
Treatment                           treatmentsa        Percent              treatmentsb      Percent
Checkdams, straw
wattles, contour
felled trees or log
terraces, mulch                               $14.4         31.5                     $0.0          0.0
Seeding                                        12.5         27.4                      0.1          0.1
Road or trail work                             12.3         26.9                     39.7         28.8
Noxious or invasive
weed monitoring
and/or treatment                                 1.3         2.8                     25.1         18.2
Fencing                                          0.8         1.8                      4.2          3.0
Reforestation                                    0.5         1.1                     35.3         25.6
Build or clean out
cachement basins                                 0.5         1.1                      0.8          0.6
Repairing or
replacing minor
structures                                       0.2         0.4                      2.1          1.5
Cultural resource
survey or protection                             0.1         0.2                      3.6          2.6
        c
Other                                            3.1         6.8                     27.0         19.6
Total                                         $45.7       100.0                   $137.9        100.0
Source: Forest Service.

Note: GAO analysis of Forest Service data.
a
 Treatment cost excludes other costs associated with plans, such as plan development and monitoring
costs.
b
 The Forest Service distinguishes between emergency stabilization treatments and rehabilitation
treatments and includes them in separate plans.
c
  Other primarily includes wildlife, fish, threatened or endangered species habitat or watershed
restoration, which the Forest Service did not allocate to categories such as check dams, seeding, road
or trail work, weed treatment, or fencing.




Page 31                                                  GAO-03-430 Wildland Fire Rehabilitation
According to Forest Service officials, for short-term emergency
stabilization, the agency relies on treatments that are intended to reduce
soil erosion in watersheds that have the greatest potential to create further
damage to people, property, or other valued resources if the agency does
not act before the first major storm event after a wildfire. For example,
some watersheds are used as sources of drinking water supplies for
municipalities. Because much of its lands are steeply sloped, the agency
relies on check dams, straw wattles (tubes of straw wrapped in netting),
and other similar structures, such as logs, to retain soil, as well as seeding
with fast-growing grasses. In contrast, for longer-term rehabilitation, the
agency repairs resource damage caused by the fire through treatments,
such as road or trail work to reduce erosion in other watersheds,
reforestation to replace timber growth, and monitoring for or treating
noxious or invasive weeds.

As shown in table 5, for stabilization treatments, the agency approved
about 31.5 percent of its 2001 and 2002 funds for erosion treatments such
as building check dams with rocks, logs, or straw, which are then placed in
stream beds or in steeply sloped channels on hillsides in order to slow
runoff from storm events and help prevent soil erosion. This runoff can
consist of water, soil, rocks, branches, and trees. To trap sediment, the
Forest Service uses felled logs or log terraces placed perpendicular to
sloped hillsides. It may specify the use of straw wattles placed
perpendicular to slopes to trap sedimentation when the number of logs is
insufficient to trap erosion effectively. Straw mulch or branches cut from
trees may also be placed on slopes to retard soil erosion. For example,
following the Trail Creek Fire, which burned about 32,000 acres on the
Boise National Forest in Idaho, the Forest Service approved an emergency
stabilization plan that included about $3 million for straw wattles, $344,000
for cutting down burnt trees and positioning them along slopes, $203,000
for mulch, and $203,000 for straw bales and other soil erosion control
structures. The Forest Service plan included multiple soil erosion
treatments because the property at risk from soil erosion included homes,
community centers, and businesses. Figures 4 and 5 show slope
stabilization treatments on Forest Service lands, including straw wattles
and mulch.




Page 32                                    GAO-03-430 Wildland Fire Rehabilitation
Figure 4: Straw Wattles Used to Help Retain Soils and Reduce Erosion




Page 33                                     GAO-03-430 Wildland Fire Rehabilitation
Figure 5: Mulching Used to Stabilize Soils




As table 5 also shows, the Forest Service used more than 25 percent of both
its stabilization and rehabilitation funds for road and trail treatments
because, according to Forest Service officials, it has an extensive network
of roads and trails on its forests that required treatment after the 2000 and
2001 fires. Road work includes installing and enlarging culverts so that
additional runoff anticipated from burnt lands can pass under roadways,
and regrading roads so that storm runoff will be less likely to erode road
surfaces. Similarly, trail work includes regrading or repairing trails to
reduce erosion and protect public safety. If the roads or trails pose a public
health or safety risk, and if the treatments need to be implemented before a
major storm event occurs, then short-term stabilization funds are used. In
contrast, if the roads or trails do not pose a health or safety concern, then
the Forest Service uses longer-term rehabilitation funds. For example,
following the Bitterroot Complex of five fires or fire complexes that burned
about 185,000 Forest Service acres, the Forest Service recommended about
$4 million in emergency road and trail treatments, to prevent damage by



Page 34                                      GAO-03-430 Wildland Fire Rehabilitation
debris torrents and runoff. Treatments included installing larger culverts,
cleaning ditches and culverts, recontouring roads, and repairing trails. If
these treatments were not taken, the Forest Service anticipated that (1)
fish habitat could be degraded and (2) private residences, a recreational
development, and an irrigation system that were downstream from the
burnt area could be harmed. In contrast, the rehabilitation plan included
about $11 million for road and trail treatments. This funding is for
roadwork along 400 miles of roads within the areas that burned with
moderate to high intensity. Because vegetation no longer existed to
stabilize road surfaces and slopes, the Forest Service stated it needed to
perform work to reduce erosion from them. Similarly, 150 miles of trail
were located in intensely burnt areas, which rendered some trails unsafe.
Figure 6 shows a culvert installed to handle anticipated increased storm
runoff.



Figure 6: Upgraded Culvert to Withstand Increased Storm Runoff




Page 35                                     GAO-03-430 Wildland Fire Rehabilitation
Seeding was another widely used stabilization treatment. This treatment
accounted for more than 25 percent of the stabilization costs for 2000 and
2001 fires. Seeding was generally used to reduce erosion and thereby better
protect watersheds. Forest Service plans included treatments such as
seeding with fast-growing grasses—such as barley and winter wheat—that
would be more likely to grow quickly or would be less likely to compete
with the longer-term recovery of natural vegetation. For example, the
Forest Service approved about $7 million for the Cerro Grande Fire for
seeding to help stabilize soils. The assessment team concluded that natural
regrowth of vegetation would be too slow to prevent significant runoff and
soil erosion. It recommended grass seeding with annual ryegrass, barley,
mountain brome, and slender wheatgrass, to quickly restore vegetation and
reduce soil erosion, protect soil productivity, and reduce runoff.

Reforestation treatments were almost entirely done as a longer-term
rehabilitation treatment and accounted for about 25 percent of the
rehabilitation costs for the 2000 and 2001 wildfires. The Forest Service uses
reforestation treatments sparingly and restricts their use as a stabilization
treatment because (1) replanting commercial species burned by wildfire is
viewed as the responsibility of the forest management program, as opposed
to an emergency measure to be funded by the wildland fire program, and
(2) planting trees does not meet the emergency stabilization objective of
preventing additional damage to resources. Rather, replanting trees is
generally considered as repairing resource damage caused by wildfire and
therefore not a large part of the rehabilitation program. In keeping with its
interpretation of the need to restrict emergency stabilization treatments as
those necessary to prevent additional resource damage, the Forest Service
generally restricts the use of reforestation to no more than $25,000 per
treatment. However, once it received funding under the National Fire Plan
for longer-term rehabilitation, the Forest Service used this funding to
develop reforestation proposals for 21 national forests burned by wildland
fire.

Similarly, the percentage of funding the Forest Service used for noxious or
invasive weed monitoring or treatment varied depending on whether the
treatment was for emergency stabilization or rehabilitation. According to
Forest Service officials, noxious or invasive weed monitoring or treatment
is not generally viewed as an emergency treatment. For example, the
Forest Service proposed spending $1.3 million for noxious or invasive
weed monitoring or treatment as an emergency stabilization measure;
however, it proposed spending $25.1 million for such monitoring and
treatment as a rehabilitation measure. Similarly, in its rehabilitation plan



Page 36                                    GAO-03-430 Wildland Fire Rehabilitation
                               for the Salmon Challis National Forest in Idaho, the Forest Service
                               proposed spending $9.5 million on noxious or invasive weed treatments
                               because of known infestations of noxious weeds where several fires
                               occurred in 2000. The weeds were expected to spread rapidly through the
                               burnt areas, especially where fire suppression activities, such as
                               bulldozing, exposed bare soils. The Forest Service also proposed to
                               conduct a National Environmental Policy Act analysis for treating noxious
                               or invasive weeds in another portion of the forest that had also been burnt
                               in 2000 and which had not yet had an environmental analysis completed for
                               such a treatment.



Interior and the Forest        Neither we nor the Forest Service or Interior know the overall
                               effectiveness of emergency stabilization and rehabilitation treatments
Service Cannot                 because local land units do not routinely document monitoring results,
Determine Overall              collect comparable monitoring information, and disseminate the results of
                               their monitoring to other land units or to the agencies’ regional or national
Treatment                      offices. As a result, it is difficult to compile information from land units to
Effectiveness                  make overall assessments about the extent to which treatments are
                               effective or about the conditions in which treatments are most effective.
                               Furthermore, the departments have not developed an interagency system
                               to collect, store, and disseminate monitoring results. Consequently, it is
                               difficult for agency officials to learn from the results of treatments applied
                               on other sites in order to most efficiently and effectively protect resources
                               at risk.



Lack of Comparable             As noted previously, both Interior and the USDA’s Forest Service require
Monitoring Data at the Local   local land units to install treatments that are effective. In addition, Interior
                               requires, and the Forest Service strongly encourages, local land units to
Land Unit Makes It Difficult   monitor for treatment effectiveness. However, neither department specifies
to Comprehensively Assess      how land units should conduct such monitoring or how they should
Treatment Effectiveness        document monitoring results. Both our and the departments’ own internal
                               reviews found that inconsistencies in monitoring methods prevent a
                               comprehensive assessment of treatment effectiveness.




                               Page 37                                     GAO-03-430 Wildland Fire Rehabilitation
Local Land Units We Reviewed    To determine the methods local land units use to monitor and document
Do Not Use Comparable           the effectiveness of their treatments, we reviewed 18 emergency
Methods to Monitor and          stabilization and rehabilitation plans that were implemented on 12 local
Document the Effectiveness of   land units—6 of Interior’s and 6 of the Forest Service’s. We selected these
Identical Treatments            12 local land units because they obligated the most funds for emergency
                                stabilization and rehabilitation treatments within their regions in 2000, the
                                most recent year since the establishment of the National Fire Plan in which
                                local land units could have accomplished significant monitoring at the time
                                of our review.18 For each of the 18 plans, we reviewed up to 3 of the most
                                costly treatments, for a total of 48 treatments.19 These 48 treatments are not
                                a representative sample of all emergency stabilization and rehabilitation
                                treatments implemented by the departments, and therefore our findings
                                cannot be projected. However, the data do represent monitoring practices
                                for a significant proportion of departmental outlays for treatments, since
                                the total cost of the treatments we reviewed was $84 million, or 30 percent
                                of the total funds obligated by Interior and the Forest Service for
                                emergency stabilization and rehabilitation treatments undertaken for
                                wildfires that occurred in 2000 and 2001.

                                Local land units monitored all of the 48 treatments we reviewed, but
                                documented conclusions about treatment effectiveness for only half of the
                                48 treatments. Land units monitored some treatments through visual
                                inspection alone and other treatments through both visual inspection and
                                data collection. For treatments that entail building or repairing
                                infrastructure—such as roadwork, trail repair, and fencing—local land
                                units typically monitored treatment effectiveness solely through visual
                                observation. Of the 19 such treatments, local land units visually observed
                                all and collected monitoring data for only 1. For example, national forests
                                often resurface roads and install drainage systems, such as culverts, to
                                prevent storm runoff from concentrating into torrents, eroding road
                                surfaces and depositing sediment into streams. To monitor the
                                effectiveness of such treatments, according to local national forest
                                officials, staff typically drive along repaired road segments and visually


                                18
                                  We did not select emergency stabilization and rehabilitation plans for wildland fires that
                                occurred in 2001 because, at the time of our review, local land units would have had little
                                time to monitor treatments that had been implemented.
                                19
                                 Of the 18 plans we selected for review, one included only two treatments—both of which
                                we reviewed. In addition, the most costly treatments in some of the 18 plans had either not
                                yet been fully implemented, or we could not get timely information on the treatment’s
                                status. We did not include these treatments in our analysis.




                                Page 38                                             GAO-03-430 Wildland Fire Rehabilitation
observe road surfaces for gullies or other signs of erosion. In contrast, for
treatments designed to restore natural conditions—such as seeding,
reforestation, weed treatment, and erosion barriers—staff often collect
monitoring data, in addition to visually observing treatment sites. Of the 30
such treatments, local land units collected monitoring data on treatment
effectiveness for 22 and visually observed all 30. For example, one BLM
district office used two methods to monitor their seeding treatment: (1)
they visually observed the seeded acreage and estimated the proportion of
the burnt area covered by native plants, weeds, and bare soil; and (2) they
collected data on the most abundant plant species, precipitation levels, soil
types, and terrain within a selected number of small, delineated sections
within the seeded acreage. Local land units documented conclusions about
treatment effectiveness for 24 of the 48 treatments we reviewed. In
documenting these results, land units used a wide variety of different
formats, including summaries of visual observations, tables of data
analyses, and presentations for academic conferences.

Even though the 12 local land units we reviewed generally monitored the
effectiveness of treatments, each used a different method to do so.
According to local land unit officials, departmental guidance does not
identify the methods they should use to visually inspect different types of
treatments, when they should collect and analyze monitoring data, the
types of data they should collect, or the techniques they should use to
collect and analyze monitoring data. In some instances, local land unit
officials said they used monitoring methods prescribed for programs other
than emergency stabilization and rehabilitation. For example, on three
national forests, Forest Service officials said that they used monitoring
methods specified by the agency’s forestry, or silviculture, program to
monitor reforestation treatments. In another instance, an interagency
technical reference describes 12 procedures for monitoring vegetation, but
the departments do not indicate which of these methods should be used to
monitor the seeding applied to burnt lands.

As a result of the lack of clarity, the 12 local land units differed significantly
in the methods they used to monitor the 30 treatments designed to restore
natural conditions. Of these 30 treatments, local land units collected data to
monitor the effectiveness of 22 of the treatments, in addition to making
visual observations, and relied solely on visual observations to monitor the
remaining 8 treatments. Likewise, local land units monitored untreated
sites for comparison with treated sites in 17 instances, while they
monitored just the treated sites in the remaining 13 instances. Furthermore,
in judging whether a treatment was effective, local land units established



Page 39                                       GAO-03-430 Wildland Fire Rehabilitation
measurable standards of effectiveness for 9 of the 30 treatments and relied
purely on the knowledge of local land officials to make this judgment for
the other 21. As one local land unit official said, each staff member has his
or her “own definition of success.” Overall, local land unit officials judged
most of the treatments as effective. However, because local land units (1)
collected different monitoring data, (2) used different methods to collect
monitoring data, and (3) developed their own definitions of treatment
effectiveness, the results of monitoring treatments we reviewed for these
18 emergency stabilization and rehabilitation plans cannot be compared to
determine if the treatments were effective.

For example, three national forests we reviewed spent more than $5
million to install erosion barriers on severely burnt slopes to protect homes
and streams from flooding and sedimentation after catastrophic wildfires
in 2000. Although all three forests installed the same treatment to
accomplish the same objective, the forests’ monitoring methods differed in
the extent to which they collected monitoring data, type of monitoring data
they collected, methods used to collect and analyze monitoring data, and
standards for judging treatment success. This situation is illustrated by the
following examples:

• In one forest, local land unit officials observed treated slopes for
  evidence of erosion but did not collect monitoring data or document
  their findings. Because the officials observed that only small amounts of
  sediment washed to the bottom of slopes after a rainstorm, they
  concluded that the treatments had been effective. Without collecting
  monitoring data, however, these officials could not accurately estimate
  the amount of erosion prevented by the barriers placed on the slope or
  the level of precipitation that would render the barriers ineffective.

• In another forest, local land unit officials worked with Forest Service
  researchers to collect data on precipitation levels and soil erosion from
  both treated and untreated slopes, in addition to conducting visual
  observations. The researchers used a computerized hydrological model
  to analyze the monitoring data and concluded that the erosion barriers
  decreased the risk of erosion by 19 percent—from an 86 percent risk on
  untreated slopes to a 67 percent risk on treated slopes—and
  documented these results in a presentation to a professional
  conference. However, during visual observations, local land unit
  officials disagreed on whether the presence of sediment trapped behind
  the erosion barriers constituted treatment success: some believed that
  the barriers were effective because they had trapped erosion from



Page 40                                    GAO-03-430 Wildland Fire Rehabilitation
   washing further down the slope, while others concluded that the
   barriers were ineffective because they had not prevented soil from
   eroding at the top of the slope.

• In a third forest, local land unit officials collected monitoring data and
  visually observed the erosion barriers. However, they said it was
  difficult to accurately measure soil erosion and water quality in order to
  determine treatment effectiveness. They therefore did not report on
  their data collection and analysis and relied on visual observations to
  judge treatment effectiveness: after observing significant amounts of
  erosion, they concluded that the treatments were not effective.

Because these national forests used different methods to judge treatment
effectiveness, we could not draw overall conclusions about the
effectiveness of erosion barriers in protecting resources at risk at these
three forests. We found similar inconsistencies in monitoring data,
monitoring methods, documentation, and standards for treatment
effectiveness among other Forest Service land units as well as Interior’s.
For example, at two BLM district offices, we reviewed how local land unit
officials monitored seeding of burnt areas that was intended to establish
native species and prevent the spread of noxious weeds. One district
collected data from both seeded and unseeded plots, while the other only
collected data from seeded plots. In addition, one district used a
measurable standard to judge treatment success, while the other relied on
the professional judgment of land managers.




Page 41                                   GAO-03-430 Wildland Fire Rehabilitation
Departments’ Studies Could Not   Similarly, a 2000 USDA Forest Service study and a 2002 Interior study
Determine Overall Treatment      found that it is difficult to determine overall treatment effectiveness
Effectiveness                    because land units use different methods to monitor identical treatments
                                 and rarely document monitoring results.20 For example, as part of its study,
                                 Forest Service officials reviewed more than 150 monitoring reports for
                                 emergency stabilization and rehabilitation treatments undertaken at
                                 national forests. As part of its study, Interior reviewed techniques that BLM
                                 field offices in Idaho, Nevada, Oregon, and Utah used to monitor seeding
                                 treatments. Both of these studies concluded that local land units often did
                                 not collect or record data important to interpreting treatment
                                 effectiveness, including data on site conditions and treatment outcomes. In
                                 addition, both studies found that only approximately one third of local land
                                 units collected monitoring data, and among these local land units, few
                                 collected the same type of data or used the same data collection methods.
                                 Because of the lack of documentation and the differences in monitoring
                                 methods, neither study was able to determine the validity of monitoring
                                 results, to calculate the extent to which treatments were effective, or to
                                 compare the effectiveness of treatments in different regions or land units.
                                 According to Interior and Forest Service officials, including the authors of
                                 these studies, the departments know little about the extent to which
                                 emergency stabilization and rehabilitation treatments prevent erosion,
                                 protect water quality, restore native vegetation, reduce invasive weeds, or
                                 protect wildlife. In a separate 2001 study of its emergency stabilization
                                 program in the Northern and Intermountain regions, the Forest Service
                                 concluded that the agency is “often . . . uncertain that [treatments] actually
                                 work. There is a concern that treatments may look good, but their
                                 functional effectiveness is unknown.”21

                                 Improved monitoring would provide critical information to departmental
                                 officials making decisions about emergency stabilization and rehabilitation
                                 treatments, according to the Interior and Forest Service studies. According
                                 to the Forest Service study, knowing the effectiveness of particular


                                 20
                                  USDA, Forest Service, Rocky Mountain Research Station, Evaluating the Effectiveness of
                                 Postfire Rehabilitation Treatments, General Technical Report RMRS-GTR-63 (Fort Collins,
                                 Colo.: Sept. 2000); and U.S. Geological Survey, Forest & Rangeland Ecosystem Science
                                 Center and Oregon State University, Department of Rangeland Resources, Emergency Fire
                                 Rehabilitation of BLM Lands in the Intermountain West: Revegetation & Monitoring,
                                 Interim Report to the BLM (Corvallis, Oreg.: Jan. 26, 2002).
                                 21
                                  USDA, Forest Service, Watershed, Fish, Wildlife, Air and Rare Plants Staff, Burned Area
                                 Emergency Rehabilitation (BAER) Program Review Report: Northern and Intermountain
                                 Regions. (Washington, D.C.: June 2001).




                                 Page 42                                          GAO-03-430 Wildland Fire Rehabilitation
treatments would help local land units select the most appropriate
treatments for installation and could assist them in defending and
explaining their decisions. For example, knowing the likelihood that
erosion barriers will effectively prevent erosion on a certain soil type could
help land unit officials determine whether installing such barriers is
worthwhile, according to the lead author of the study. Likewise, the
Interior study noted that a synthesis of monitoring data could assist BLM in
restoring native plants and reducing invasive weeds in the Intermountain
West.

In order to gather such information, these studies recommended that the
agencies improve monitoring. The Forest Service study of treatment
effectiveness recommended that national forests “increase monitoring
efforts” to determine the effectiveness of treatments under various
conditions, while the agency’s review of the emergency stabilization
program recommended “a quick format for minimal quantitative
monitoring.” Similarly, the Interior study recommended that BLM districts
adopt a common monitoring technique and report whether treatments
meet their objectives.

The departments have not implemented these recommendations, however.
According to departmental officials responsible for overseeing their
emergency stabilization and rehabilitation efforts, implementation has not
occurred because of the difficulty associated with the development of
standardized monitoring and data collection methods and the collection of
such data. At the local level, even though land units typically conduct some
type of monitoring and view monitoring as valuable, agency officials
consider extensive monitoring to be a less important use of their time than
other immediate wildland fire duties, such as serving on emergency
stabilization and rehabilitation assessment teams and overseeing the
installation of treatments. These wildland fire duties are in addition to their
normal duties they must carry out on a routine basis. Furthermore,
departmental officials said that because land characteristics and treatment
objectives vary significantly from land unit to land unit and from agency to
agency, it is difficult to establish standard monitoring or data collection
methods that would apply in all circumstances. At the same time, however,
they acknowledged that there are enough commonalities among land units,
agencies, and treatments, that some aspects of monitoring and data
collection could be standardized, such as consistently collecting and
documenting data on precipitation, soil type, and terrain. BLM officials
added that they have recently begun to discuss the development of
standardized monitoring methods and possible criteria for treatment



Page 43                                     GAO-03-430 Wildland Fire Rehabilitation
                              success. Departmental officials commented, however, that if monitoring
                              methods were standardized and data were routinely collected and
                              analyzed, it might be more appropriate for an independent organization
                              such as the department’s science agency—the U.S. Geological Survey—to
                              conduct this work and assess the relative success and failure of treatments.



The Departments Do Not        Interagency and departmental policies direct the departments to collect,
Routinely Collect, Archive,   archive, and disseminate monitoring results collected by local land units so
                              that the departments can make more informed decisions on the
and Disseminate Monitoring    effectiveness of the treatments being used. According to Interior, for
Results Collected by Local    example, “Priority should be given to developing a simple interagency
Land Units                    electronic mechanism for archiving and broadly disseminating the
                              treatment and technique results.” Similarly, the Forest Service cited the
                              need for the agency to develop a clearinghouse of monitoring plans and a
                              system for sharing monitoring results. Nevertheless, neither Interior nor
                              the Forest Service developed an interagency system to collect, store, and
                              disseminate monitoring results of emergency stabilization and
                              rehabilitation treatments.

                              Based on our review of treatments for 18 emergency stabilization and
                              rehabilitation plans at 12 local land units, we found that local land units did
                              not routinely share monitoring results with other land units or with
                              program management, even in instances when they learned valuable
                              lessons about treatment effectiveness. For example, according to local land
                              unit officials, they shared information with their peers through informal
                              means such as phone calls to neighboring land units and conversations at
                              regional meetings for only 24 of the 48 treatments we reviewed. Similarly,
                              these officials said that they submitted their monitoring results to their
                              agency’s state or regional offices for only 19 of the 48 treatments. At the
                              same time, local land unit officials said they learned lessons while
                              monitoring that would be worth sharing with other land units in 37 of the
                              48 cases.

                              Currently, the departments do not have an interagency database that local
                              land units can submit monitoring data and then use to determine the
                              relative success of different treatments, according to Forest Service and
                              Interior emergency stabilization and rehabilitation officials. Several local
                              land unit officials said that if such information were accessible, they would
                              be better able to select the most appropriate treatment to meet certain
                              objectives in specific conditions. Officials in one BLM Nevada land unit
                              said that the BLM state office was developing a database to collect, store,



                              Page 44                                     GAO-03-430 Wildland Fire Rehabilitation
and disseminate monitoring results. BLM Nevada officials said that the
database would be used to collect and store the specifications and results
of seeding treatments that have been applied on BLM lands in the entire
state. When BLM officials in Nevada then consider using a seeding
treatment following a wildfire, they would be able to search the BLM
Nevada database to identify the results of prior seeding treatments that
were applied in similar terrain, on similar soil types, at similar elevations,
and with similar precipitation levels, according to these officials. Local land
unit officials could use this information to make treatment decisions, such
as whether to seed a burnt area or whether to allow it to recover naturally.
BLM Nevada officials said that such a database would be “worth its weight
in gold” because of the difficulty in identifying the most appropriate plant
species and seed application techniques that will be effective in Nevada’s
arid rangelands.

According to Interior and Forest Service officials responsible for their
emergency stabilization and rehabilitation programs, the departments had
not developed an interagency monitoring database for the same reasons
that they have not standardized monitoring and data collection methods:
coordinating such a task with multiple agencies would require a substantial
amount of work and monitoring has historically been considered a lower
priority than other more pressing tasks. Departmental officials said that it
would be time-consuming to develop a database to meet the needs of
multiple agencies, each of which manages different types of land. Other
departmental officials said that the departments typically respond well to
emergencies, such as fire suppression, but have placed less emphasis on
monitoring. These officials acknowledged, however, that a monitoring
database would be valuable and said that they had scheduled interagency
meetings in early 2003 to discuss developing such a database.

While the Forest Service has already begun work on a database of
monitoring results, the database is limited in scope and application. The
database includes information that the Forest Service collected as part of
its 2000 study of the effectiveness of emergency stabilization treatments,
according to the agency official who led that study. Beginning in 2003, this
official said that local Forest Service land unit officials will be able to
access information collected during the course of that study, including any
monitoring information, to help inform their treatment decisions. This
official noted, however, that because of differences and shortcomings in
the ways that national forests collected and retained monitoring
information for the emergency stabilization plans that were reviewed for
that study, the database has several limitations: it will (1) not provide



Page 45                                     GAO-03-430 Wildland Fire Rehabilitation
              quantitative data on the extent of treatment effectiveness; (2) not provide
              information necessary to determine the conditions—such as soil
              characteristics or vegetation types—under which treatments are most
              effective; (3) not provide a means by which local Forest Service land unit
              officials could report their current monitoring results to other local land
              units or to Forest Service regional or national offices.



Conclusions   Most lands burned by catastrophic wildfires will recover naturally, without
              posing a threat to public safety or ecosystems. However, in those relatively
              few instances where burnt lands threaten safety, ecosystems, or cultural
              resources, emergency stabilization and rehabilitation treatments can play a
              critical role—a role that is emphasized by the appropriations Congress has
              dedicated to postwildfire treatments.

              The treatments Interior and the Forest Service use to protect and restore
              burnt lands—slope stabilization measures such as mulching to prevent soil
              from eroding into rivers and streams, seeding to regenerate important
              grasses and shrubs, and noxious or invasive weed monitoring and
              control—appear, on the face of it, to be reasonable. For the most part,
              however, Interior and the Forest Service are approving treatment plans
              without comprehensive information on the extent to which a treatment is
              likely to be effective given the severity of the wildfire, the weather, soil, and
              terrain. Such information could help ensure that the agencies, including the
              local land units, are using resources effectively to protect public safety,
              ecosystems, and cultural resources.

              Interior and USDA’s Forest Service have also done studies that recognize
              the need for information on treatment effectiveness, but they have not
              emphasized the importance of collecting, storing, analyzing, and
              disseminating such data. Nor can they reasonably take action to collect,
              store, analyze, or disseminate such data until the departments have
              comparable monitoring data from their local land units. Interior and the
              Forest Service have yet to set standards for data collection, develop
              reporting procedures, or establish criteria for judging treatment
              effectiveness, which makes it possible to assess treatment effectiveness. As
              their and our own analyses have shown, this situation has resulted in local
              land units using different monitoring methods, even when similar
              treatments are being used under similar conditions, and a lack of
              consistency in judging whether treatments have been effective.




              Page 46                                      GAO-03-430 Wildland Fire Rehabilitation
Recommendations for   In order to better ensure that funds for emergency stabilization and
                      rehabilitation treatments on burnt lands are used as effectively as possible,
Executive Action      we recommend that the Secretaries of Agriculture and of the Interior
                      require the heads of their respective land management agencies to

                      • specify the type and extent of monitoring data that local land units are
                        to collect and methods for collecting these data, and

                      • develop an interagency system for collecting, storing, analyzing, and
                        disseminating information on monitoring results for use in management
                        decisions.



Agency Comments and   We provided a draft of this report to the Secretaries of Agriculture and of
                      the Interior for review and comment. The departments provided a
Our Evaluation        consolidated response to our draft report, which is included in appendix II
                      of this report. They generally agreed that more can be done to ensure that
                      funds for emergency stabilization and rehabilitation on burnt lands are
                      used as effectively as possible and with our recommendations that they
                      obtain and disseminate better data for determining treatment effectiveness.
                      In commenting on our recommendation that the departments obtain better
                      data on treatment effectiveness, the departments said that they were aware
                      that some of their own studies had previously identified the need to obtain
                      and disseminate better data for determining treatment effectiveness. They
                      cited several examples where they have or are trying to accomplish this,
                      including an effort to determine the effectiveness of log erosion barriers,
                      which is cited in this report. The departments, in their comments, said they
                      recognize that many of the efforts are individual agency initiated actions, as
                      opposed to a systematic approach, to collect data on treatment
                      effectiveness. They said that they are currently planning actions that would
                      address data collection concerns in a more collaborative manner by
                      establishing an interdepartmental committee of scientists and managers to
                      identify the dominant postfire stabilization and rehabilitation treatments
                      for which monitoring methods will be established. An interdepartmental
                      approach is essential, not only for identifying the amount and type of data
                      that local land units should collect, but also for developing an interagency
                      and interdepartmental system for routinely collecting, storing, analyzing,
                      and disseminating these data. The departments also provided several
                      technical changes that we incorporated into the report, as appropriate.




                      Page 47                                    GAO-03-430 Wildland Fire Rehabilitation
As arranged with your offices, unless you publicly announce the contents
earlier, we plan no further distribution of this report until 30 days after the
date of this letter. At that time, we will send copies of this report to the
Chairman and Ranking Minority Member, Subcommittee on Public Lands
and Forests, Senate Committee on Energy and Natural Resources; the
Chairman and Ranking Minority Member, House Committee on Resources;
the Chairman and Ranking Minority Member, Subcommittee on Forests
and Forest Health, House Committee on Resources; the Chairman and
Ranking Minority Member, Subcommittee on Interior and Related
Agencies, House Committee on Appropriations; the Ranking Minority
Member, House Committee on Agriculture; the Ranking Minority Member,
Subcommittee on Department Operations, Oversight, Nutrition and
Forestry, House Committee on Agriculture; and other interested
congressional committees. We will also send copies of this report to the
Secretary of Agriculture; the Secretary of the Interior; the Chief of the
Forest Service; the Directors of BLM, the National Park Service, and the
Fish and Wildlife Service; the Deputy Commissioner, Bureau of Indian
Affairs; the Director, Office of Management and Budget; and other
interested parties. We will make copies available at no charge to others
upon request. This report will also be available at no charge on GAO’s home
page at http://www.gao.gov/.

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

Sincerely yours,




Barry T. Hill
Director, Natural Resources
and Environment




Page 48                                     GAO-03-430 Wildland Fire Rehabilitation
Appendix I

Scope and Methodology                                                                         AA
                                                                                               ppp
                                                                                                 ep
                                                                                                  ned
                                                                                                    n
                                                                                                    x
                                                                                                    id
                                                                                                     e
                                                                                                     x
                                                                                                     Iis




             To describe the Department of the Interior’s and the U.S. Department of
             Agriculture’s Forest Service processes for implementing their emergency
             stabilization and rehabilitation programs, we obtained departmental
             manuals, handbooks, and other guidance that describe Interior’s process
             for implementing emergency stabilization and rehabilitation and the Forest
             Service’s emergency stabilization program. We also interviewed Interior
             and Forest Service officials responsible for overseeing the department’s
             respective programs to obtain an overview of Interior’s and the Forest
             Service’s processes for their programs. Because the Forest Service’s
             rehabilitation program is relatively new and has not yet been incorporated
             into the Forest Service manual or handbook, we obtained guidance
             developed by the Forest Service and provided to Forest Service regional
             offices on the process used to implement that program. We also obtained
             additional guidance and documentation from the Forest Service’s
             Northern, Southwestern, and Intermountain regions (regions 1, 3, and 4,
             respectively)—the three regions that received the largest share of Forest
             Service rehabilitation program funding in fiscal year 2001—to determine
             what additional processes these regions developed and used to implement
             the program. Further, we interviewed Bureau of Land Management (BLM),
             Bureau of Indian Affairs, Fish and Wildlife Service, National Park Service,
             and Forest Service officials at regional, state, and local land management
             units that had experienced wildland fires in 2000 or 2001 to discuss
             procedures used in assessing burnt lands and identifying appropriate
             treatments.

             To identify the costs and types of treatments the departments have
             implemented, we obtained 266 emergency stabilization and rehabilitation
             plans that Interior agencies prepared for wildfires that occurred in calendar
             years 2000 and 2001 on

             • BLM managed lands in Idaho, Nevada, Oregon, and Utah;

             • Bureau of Indian Affairs managed lands in its Northwest, Rocky
               Mountain, Southwest, and Western regions;

             • Fish and Wildlife Service managed lands in its Mountain Prairie, Pacific,
               Southeast, and Southwest regions; and

             • National Park Service managed lands in its Intermountain and Pacific
               West regions.




             Page 49                                    GAO-03-430 Wildland Fire Rehabilitation
Appendix I
Scope and Methodology




For the Forest Service, we requested and obtained 155 emergency
stabilization plans and rehabilitation plans for wildfires that occurred in
calendar years 2000 and 2001 on Forest Service lands managed in its
Intermountain, Northern, Pacific Northwest, Pacific Southwest, and
Southwestern regions (regions 4, 1, 6, 5, and 3, respectively). We selected
these Interior and Forest Service regions because they accounted for about
90 percent of the plans that the departments developed for treating
wildfires that occurred in 2000 and 2001.

To identify the types of treatments implemented, we reviewed these 421
plans and identified treatments proposed and approved in the plans. To
identify the costs of the plans and the treatments, we obtained estimated
costs that the departments approved to carry out the plans and implement
the individual treatments. Because these costs are estimates, they do not
necessarily reflect actual costs that could be incurred in carrying out the
plans during the 3 years that may be required to implement them. We did
not obtain actual costs incurred, to date, in carrying out these plans
because this data are not readily available.

To determine whether emergency stabilization and rehabilitation
treatments are achieving their intended results, we reviewed 18 emergency
stabilization and rehabilitation plans that were implemented on 12 land
units—6 of Interior’s and 6 of the Forest Service’s. We selected these 12
land units because they obligated the most funds for emergency
stabilization and rehabilitation treatments within their regions in 2000, the
most recent year since the establishment of the National Fire Plan in which
local land units could have accomplished significant monitoring at the time
of our review. We did not select emergency stabilization and rehabilitation
plans for wildland fires that occurred in 2001 because, at the time of our
review, local land units would have had little time to monitor treatments
that had been implemented. For each of the 18 plans, we reviewed up to 3
of the most costly treatments. One of the 18 plans we selected had only 2
treatments, both of which we reviewed. In addition, we did not review five
treatments we initially selected either because the treatments had not yet
been fully implemented, or because we were unable to obtain timely
information on the treatment’s status. Therefore, the total number of
treatments we reviewed was 48. For each of these treatments, we
interviewed the land manager responsible for monitoring and reviewed
associated documentation of monitoring results, when available. These 48
treatments are not a representative sample of all emergency stabilization
and rehabilitation treatments implemented by the departments, and
therefore our findings cannot be projected. However, the data do represent



Page 50                                    GAO-03-430 Wildland Fire Rehabilitation
Appendix I
Scope and Methodology




monitoring practices for a significant proportion of departmental outlays
for treatments, since the total cost of the treatments we reviewed was $84
million, or 30 percent of the total funds obligated by Interior and the Forest
Service for emergency stabilization and rehabilitation treatments
undertaken for wildfires that occurred in 2000 and 2001.

In addition, we obtained program reviews or other studies conducted by
the Forest Service or Interior on their emergency stabilization and
rehabilitation reports to determine if the departments monitor treatments
and, if so, the type and quality of departmental monitoring data. We also
interviewed emergency stabilization and rehabilitation officials at the
departments’ national, regional, or state levels, and local land unit offices
to determine what monitoring is being conducted by local land unit offices,
whether data are collected, and what use is made of these data for
assessing treatment effectiveness or sharing lessons learned.

We conducted our review from August 2001 through February 2003 in
accordance with generally accepted government auditing standards.




Page 51                                    GAO-03-430 Wildland Fire Rehabilitation
Appendix II

Comments from the Departments of the
Interior and Agriculture                                           Appendx
                                                                         Ii




              Page 52        GAO-03-430 Wildland Fire Rehabilitation
Appendix II
Comments from the Departments of the
Interior and Agriculture




Page 53                                GAO-03-430 Wildland Fire Rehabilitation
Appendix II
Comments from the Departments of the
Interior and Agriculture




Page 54                                GAO-03-430 Wildland Fire Rehabilitation
Appendix III

GAO Contact and Staff Acknowledgments                                                          Appendx
                                                                                                     iI




GAO Contact       Chester F. Janik (202) 512-6508



Staff             In addition, Mark Braza, Marcia Brouns McWreath, Carol Herrnstadt
                  Shulman, and Katheryn Summers made key contributions to this report.
Acknowledgments




(360124)          Page 55                                GAO-03-430 Wildland Fire Rehabilitation
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