a

GAO

United States General Accounting Office

Report to Congressional Requesters

April 2003 WILDLAND FIRES

Better Information 

Needed on 

Effectiveness of 

Emergency 

Stabilization and 

Rehabilitation 

Treatments

GAO-03-430

Both Interior and USDA’s Forest Service use multidisciplinary teams of 

experts, such as ecologists and soil scientists, to assess damage and 

potential risks burnt land poses and to develop emergency stabilization and 

rehabilitation plans that identify needed treatments to reduce or eliminate 

those risks. The two departments differ in how they manage their programs, 

however. Interior uses a single process to assess damage and identify 

treatments for short-term emergency stabilization and longer-term 

rehabilitation, while USDA’s Forest Service uses different processes for each 

of these two treatment types. The two departments recognize these 

differences and recently agreed to work toward standardizing certain 

aspects of their programs, such as definitions and time frames. 

Following the 2000 and 2001 fires, the Forest Service obligated $192 million 

and Interior $118 million for 421 emergency stabilization and rehabilitation 

treatment plans GAO reviewed. Treatments included seeding; fencing; 

installing soil erosion barriers such as straw bundles, or wattles; and road 

or trail work. Most of Interior’s land—managed by the Bureau of Land 

Management—consists of rangeland. Thus, the bureau primarily seeded 

native grasses to retain soils and forage for cattle and wildlife and fenced to 

prevent grazing. Forest Service land is often steeply sloped and includes 

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. 

Neither the departments nor GAO could determine whether emergency 

stabilization and rehabilitation treatments were achieving their intended 

results. The departments require that treatments be monitored, but they do 

not specify how and the type of data to collect or analyze for determining 

effectiveness. The departments have stressed the need to systematically 

collect and share monitoring data for treatment decisions. Yet neither has 

developed a national interagency system to do so. Therefore, the nature and 

extent of data collection, analysis, and sharing vary widely. The departments 

recognize that they need better information on treatment effectiveness. 

However, they have not yet committed to this effort. 

WILDLAND FIRES 

Better Information Needed on 

Effectiveness of Emergency Stabilization 

and Rehabilitation Treatments 

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. 

Highlights of GAO-03-430, a report to the 

Chairman, House Committee on 

Agriculture, and the Chairman, House 

Subcommittee on Department Operations, 

Oversight, Nutrition, and Forestry, 

Committee on Agriculture 

April 2003 

Wildfires burn millions of acres 

annually. Most burnt land can 

recover naturally, but a small 

percentage needs short-term 

emergency treatment to stabilize 

burnt land that threatens public 

safety, property, or ecosystems or 

longer-term treatments to 

rehabilitate land unlikely to recover

naturally. The Department of the 

Interior (Interior) and the 

Department of Agriculture’s 

(USDA’s) Forest Service—the two 

departments that manage most 

federal land—spend millions of 

dollars annually on such 

treatments. GAO was asked to (1) 

describe the two departments’ 

processes for implementing their 

programs, (2) identify the costs and 

types of treatments implemented, 

and (3) determine whether these 

treatments are effective. 

To ensure effective emergency 

stabilization and rehabilitation 

treatments, GAO recommends 

Interior and USDA (1) specify 

procedures to be used to monitor 

treatment effectiveness, including 

type and extent of monitoring data 

collected and methods to collect 

these data, and (2) develop an 

interagency system to collect, 

store, and disseminate information 

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. 
Page i GAO-03-430 Wildland Fire Rehabilitation

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
Contents

Page ii GAO-03-430 Wildland Fire Rehabilitation

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 1 GAO-03-430 Wildland Fire Rehabilitation

United States General Accounting Office

Washington, D.C. 20548

A

April 4, 2003 Letr

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 2 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 3 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 4 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 longterm 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 5 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 6 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 7 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 8 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 9 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 10 GAO-03-430 Wildland Fire Rehabilitation

Processes Differ 

between the 

Departments for 

Assessing the Need to 

Treat Burnt Lands and 

Approving Treatment 

Plans

Interior and USDA have different policies and procedures to assess 

whether burnt lands need to receive any short-term or longer-term 

treatments following wildland fire. Interior has one overall policy and 

procedure for its four land management agencies to determine the need for 

both short- and longer-term treatments. USDA’s Forest Service has separate 

policies and procedures for assessing the need for short-term emergency 

stabilization treatments immediately following a wildland fire and for 

longer-term nonemergency treatments for rehabilitating burnt lands. 

Interior and the Forest Service have attempted to adopt the same policies 

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 

Process to Identify Both 

Emergency Stabilization 

and Rehabilitation 

Treatments 

Under Interior’s policy and procedure for implementing its emergency 

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 

determine whether treatments should be taken to stabilize or rehabilitate 

them, (2) identify treatments when actions are considered necessary, 

(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 11 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 12 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 13 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 

Different Processes to 

Identify Emergency 

Stabilization and 

Rehabilitation Treatments 

The Forest Service distinguishes between short-term emergency 

treatments to stabilize lands burnt by wildland fires and longer-term 

rehabilitation treatments. Its process for short-term treatments is similar to 

Interior’s. Under this process, local land units are responsible for 

assembling interdisciplinary teams of agency officials to survey fires that 

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 14 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 15 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 longterm 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 

10The 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 16 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.

11Of 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 17 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 

12In 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). 

13Of the 275,036 Forest Service acres that were severely burned in 2000, about 41,800 acres, 

or 15 percent, were located in region 3. 

14When 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 18 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 

Working to Coordinate 

Their Processes for 

Administering Treatments 

Even Though Their Missions 

and Types of Land Differ

As noted previously, prior to receiving additional funding under the 

National Fire Plan, USDA’s Forest Service largely limited its postwildland 

fire treatments to emergency stabilization. However, in 1998, Interior and 

USDA initiated an effort to apply a consistent approach for both emergency 

stabilization and longer-term rehabilitation. This included an effort to 

develop an interagency handbook that agencies in both departments could 

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 19 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 

15Interior 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 20 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 

Vary Widely in Cost 

and in the Number and 

Types of Treatments 

Following the calendar years 2000 and 2001 fires, Interior and USDA’s 

Forest Service approved 421 plans for stabilization and rehabilitation 

treatments for an estimated total of more than $310 million. Nearly all of 

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 

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 

and Rehabilitation Plans 

Were Concentrated in 

Western States and the Cost 

of Treatment Varied 

As shown in table 1 for both Interior and the Forest Service, most 

emergency stabilization and rehabilitation treatments occurred in western 

states. Treatments occurred there primarily because much of the lands 

Interior and the Forest Service manage are in these states. Furthermore, 

during the summers of 2000 and 2001, states in the intermountain west 

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 21 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

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. 

Dollars in millions

State Funding 

Percent of 

totala

Number of 

plans

Percent of 

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
Page 22 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

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 

Dollars in millions

Range of costs per 

plan

Number of 

plans

Percent of 

plans Cost 

Percent of 

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

16Similarly, all five fires were covered by one emergency stabilization plan.
Page 23 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 

Management Used the Most 

Treatments, Primarily for 

Restoring Forage Used for 

Grazing and Wildlife Habitat

Interior’s 4 agencies approved 266 plans, costing about $118.5 million. Of 

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 

and cost of plans approved by Interior’s agencies in 2000 and 2001. 

Table 3: Number and Cost of Emergency Stabilization and Rehabilitation Plans 

Approved by Interior, 2000 and 2001

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. 

Dollars in millions

Agency

Number of 

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
Page 24 GAO-03-430 Wildland Fire Rehabilitation

Table 4: Costs of Different Interior Emergency Stabilization and Rehabilitation 

Treatments, 2000 and 2001

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:

Dollars in millions

Treatment

Cost of treatment in 

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

Checkdams,b 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
Page 25 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 26 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 27 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 28 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 29 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.

17Cheatgrass 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 30 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 

Were Used for 

Rehabilitation

Most of the funds the Forest Service approved for emergency stabilization 

or rehabilitation were for longer-term rehabilitation. Of the $192 million 

that the Forest Service approved, $139 million was for longer-term 

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 31 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

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. 

Dollars in millions

Treatment

Cost of emergency 

stabilization 

treatmentsa Percent

Cost of 

rehabilitation 

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

Otherc 3.1 6.8 27.0 19.6

Total $45.7 100.0 $137.9 100.0
Page 32 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 33 GAO-03-430 Wildland Fire Rehabilitation

Figure 4: Straw Wattles Used to Help Retain Soils and Reduce Erosion
Page 34 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 35 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 36 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 37 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 

Service Cannot 

Determine Overall 

Treatment 

Effectiveness

Neither we nor the Forest Service or Interior know the overall 

effectiveness of emergency stabilization and rehabilitation treatments 

because local land units do not routinely document monitoring results, 

collect comparable monitoring information, and disseminate the results of 

their monitoring to other land units or to the agencies’ regional or national 

offices. As a result, it is difficult to compile information from land units to 

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 

Monitoring Data at the Local 

Land Unit Makes It Difficult 

to Comprehensively Assess 

Treatment Effectiveness

As noted previously, both Interior and the USDA’s Forest Service require 

local land units to install treatments that are effective. In addition, Interior 

requires, and the Forest Service strongly encourages, local land units to 

monitor for treatment effectiveness. However, neither department specifies 

how land units should conduct such monitoring or how they should 

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 38 GAO-03-430 Wildland Fire Rehabilitation

Local Land Units We Reviewed 

Do Not Use Comparable 

Methods to Monitor and 

Document the Effectiveness of 

Identical Treatments 

To determine the methods local land units use to monitor and document 

the effectiveness of their treatments, we reviewed 18 emergency 

stabilization and rehabilitation plans that were implemented on 12 local 

land units—6 of Interior’s and 6 of the Forest Service’s. We selected these 

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 

18We 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. 

19Of 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 39 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 40 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 41 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 42 GAO-03-430 Wildland Fire Rehabilitation

Departments’ Studies Could Not 

Determine Overall Treatment 

Effectiveness 

Similarly, a 2000 USDA Forest Service study and a 2002 Interior study 

found that it is difficult to determine overall treatment 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 

20USDA, 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 43 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 44 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 

Routinely Collect, Archive, 

and Disseminate Monitoring 

Results Collected by Local 

Land Units

Interagency and departmental policies direct the departments to collect, 

archive, and disseminate monitoring results collected by local land units so 

that the departments can make more informed decisions on the 

effectiveness of the treatments being used. According to Interior, for 

example, “Priority should be given to developing a simple interagency 

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 45 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 46 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 47 GAO-03-430 Wildland Fire Rehabilitation

Recommendations for 

Executive Action

In order to better ensure that funds for emergency stabilization and 

rehabilitation treatments on burnt lands are used as effectively as possible, 

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 

Our Evaluation

We provided a draft of this report to the Secretaries of Agriculture and of 

the Interior for review and comment. The departments provided a 

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 48 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 49 GAO-03-430 Wildland Fire Rehabilitation

Appendix I

Scope and Methodology AAppenednxidexiIs

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. 
Appendix I

Scope and Methodology

Page 50 GAO-03-430 Wildland Fire Rehabilitation

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 
Appendix I

Scope and Methodology

Page 51 GAO-03-430 Wildland Fire Rehabilitation

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 52 GAO-03-430 Wildland Fire Rehabilitation

Appendix II

Comments from the Departments of the 

Interior and Agriculture ApendxiI
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
Page 55 GAO-03-430 Wildland Fire Rehabilitation

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

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

Staff 

Acknowledgments

In addition, Mark Braza, Marcia Brouns McWreath, Carol Herrnstadt 

Shulman, and Katheryn Summers made key contributions to this report.

(360124)
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