United States Government Accountability Office

GAO Testimony 

Before the Subcommittee on National 

Parks, Forests and Public Lands, 

Committee on Natural Resources, House 

of Representatives

FOREST SERVICE 

Vegetation Management 

Projects Approved during 

Calendar Years 2003 

through 2005 Using 

Categorical Exclusions 

Statement of Robin M. Nazzaro, Director 

Natural Resources and Environment 

For Release on Delivery

Expected at 10:00 a.m. EDT 

Thursday, June 28, 2007

 

GAO-07-1016T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 28, 2007

FOREST SERVICE

Vegetation Management Projects 

Approved during Calendar Years 2003 

through 2005 Using Categorical 

Exclusions 

Highlights of GAO-07-1016T, testimony 

before the Subcommittee on National 

Parks, Forests and Public Lands, 

Committee on Natural Resources, House

of Representatives 

The Forest Service manages over 192

million acres of land, often 

conducting a variety of vegetation 

management projects such as

thinning trees. Before approving 

projects that may significantly affect 

the environment, the National 

Environmental Policy Act (NEPA) 

generally requires the Forest Service 

to prepare an environmental

assessment (EA) or an

environmental impact statement 

(EIS). However, the Forest Service

can decide not to prepare an EA or 

EIS if the project involves categories

of activities that it previously found 

to have no significant environmental 

effect (categorical exclusions). As of 

2003, the Forest Service had 

established one such exclusion 

affecting vegetation management 

projects and has since added four 

new ones. 

This testimony is based on GAO’s 

report, Forest Service: Use of

Categorical Exclusions for 

Vegetation Management Projects, 

Calendar Years 2003 through 2005 

(GAO-07-99). For vegetation 

management during these years,

GAO determined (1) how many 

projects the Forest Service approved, 

including those approved using 

categorical exclusions; (2) which 

categorical exclusions it used to 

approve projects; and (3) if 

categorical exclusions are not being 

used in any field offices, why. To

answer these questions, GAO 

surveyed Forest Service officials at

all 155 national forests.

The Forest Service approved 3,018 vegetation management projects to treat 

about 6.3 million acres during calendar years 2003 through 2005. Of these 

projects, the agency approved about 28 percent using an EA or EIS to treat 

about 3.4 million acres, while it approved the remainder using categorical 

exclusions. Although 72 percent of the projects were approved using 

categorical exclusions, these projects accounted for less than half—46 

percent—of the total treatment acres. Forest Service officials said that the 

number and size of projects and types of environmental analyses used 

varied, depending upon forest size, ecology, and location. 

Percentage of Vegetation Management Projects and Treatment Acres Approved

Using an EA, EIS, or Categorical Exclusion, Calendar Years 2003 through 2005 

Of the vegetation management projects approved using categorical

exclusions, half were approved using a categorical exclusion for improving 

timber stands or wildlife habitat, an exclusion in place before 2003. The 

agency used the newer four categorical exclusions for approving the 

remainder. Of these four, the agency primarily used the categorical 

exclusion for reducing hazardous fuels, followed by those for salvaging dead 

or dying trees, conducting limited harvests of live trees, and removing trees 

to control the spread of insects or disease. The projects approved using the

categorical exclusion to improve timber stands or wildlife habitat accounted 

for about 2.4 million of the 2.9 million acres to be treated under projects 

approved using one of the five categorical exclusions. 

About 11 percent of the Forest Service’s 509 field offices had not used any of 

the five vegetation management categorical exclusions during the 3-year 

period. The reasons why field offices had not used a specific categorical 

exclusion varied by office location and categorical exclusion. For example, a 

majority of the field offices—about 91 percent—had not used the categorical 

exclusion for the removal of trees to control the spread of insects or disease, 

primarily because these offices did not have a sufficient number of insect- or 

disease-infested trees. About 32 percent of the field offices had not used the 

categorical exclusion to improve timber stands or wildlife habitat, primarily 

because no projects of this type had been undertaken during the 3-year

period. 

www.gao.gov/cgi-bin/getrpt?GAO-07-1016T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robin M. 

Nazzaro (202) 512-3841 or

nazzaror@gao.gov. 
Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss the Forest Service’s use of 

categorical exclusions to approve vegetation management projects.1

 As 

you know, under the National Environmental Policy Act of 1969 (NEPA), 

agencies evaluate the likely environmental effects of proposed projects 

using an environmental assessment (EA) or a more detailed environmental 

impact statement (EIS) if the projects are likely to significantly affect the 

environment. However, if an agency determines that the activities of a 

proposed project fall within a category of activities that it has already 

determined have no significant environmental impact, it may approve the

project without an EA or EIS—instead granting the project a categorical

exclusion. As of 2003, the Forest Service had established one categorical 

exclusion for vegetation management activities that covered certain 

activities intended to improve timber stands or wildlife habitat. In 2003, it

added four more categorical exclusions to (1) reduce hazardous fuels, (2) 

allow the limited harvest of live trees, (3) salvage dead or dying trees, and 

(4) remove trees to control the spread of insects or disease. 

The extent to which the Forest Service approves vegetation management 

projects using categorical exclusions has been controversial. Critics assert 

that the Forest Service’s use of them is an attempt to circumvent NEPA by 

precluding the need to perform an EA or EIS. In contrast, supporters state 

that current analysis and documentation requirements for an EA or EIS 

under NEPA are too burdensome and that the categorical exclusions allow 

the agency to more efficiently implement vegetation management projects. 

Little is known about the Forest Service’s use of the vegetation 

management categorical exclusions because, prior to 2005, the agency did 

not maintain nationwide data on their use. 

My testimony today summarizes the findings of our October 2006 report 

that discusses for calendar years 2003 through 2005, how many vegetation 

management projects the Forest Service approved, including how many 

were approved using categorical exclusions; which categorical exclusions

the agency used; and the primary reasons why Forest Service ranger 

districts are not using the categorical exclusions for vegetation 

 1

Vegetation management projects may include, but are not limited to, activities such as 

using prescribed burning, timber harvests, or herbicides; or thinning trees, grass, weeds, or 

brush. Projects that include these types of activities are intended to, among other things, 

maintain healthy ecosystems, reduce the risk of catastrophic wildland fire, and manage the

nation’s forests for multiple uses, such as timber, recreation, and watershed management. 

Page 1 GAO-07-1016T 
management.2

 This report is based on information we collected from all 

155 national forests representing 509 ranger districts that manage National 

Forest System lands. It is also based on interviews we conducted at 23 

ranger districts at 12 national forest units. 

In summary, from calendar years 2003 through 2005, the Forest Service 

approved 3,018 vegetation management projects to treat about 6.3 million 

acres. Most of these projects—about 72 percent—were approved using 

categorical exclusions to treat slightly less than half of the acres—2.9 

million—while about 28 percent were approved using an EA or EIS to 

treat the remaining 3.4 million acres. Even though more projects were 

approved using categorical exclusions than using an EA or EIS, the total 

treatment acreage was about the same because the relative size of projects 

approved using categorical exclusions was much smaller than those 

approved using an EA or EIS. According to Forest Service officials, the 

number and size of vegetation management projects and type of 

environmental analysis used varied depending upon the forest’s size, 

ecology, and location. 

Summary 

Of the nearly 2,200 vegetation management projects approved using 

categorical exclusions during calendar years 2003 through 2005, the Forest 

Service most frequently used the categorical exclusion for improving 

timber stands or wildlife habitat. This categorical exclusion accounted for 

half of the projects approved using the five vegetation management 

categorical exclusions. For the remaining projects, the Forest Service 

primarily used the categorical exclusion for reducing hazardous fuels, 

followed by salvaging dead or dying trees, conducting limited timber 

harvests of live trees, and removing trees to control the spread of insects 

or disease. While the categorical exclusion for timber stand or wildlife 

habitat improvement was the most frequently used and included the most 

treatment acres—about 2.4 million of the 2.9 million acres included in all

projects approved using categorical exclusions—92 percent of the projects 

approved using this categorical exclusion were smaller than 5,000 acres.

Of the 509 ranger districts, about 11 percent had not used any of the five 

vegetation management categorical exclusions during the 3-year period. 

The percentage of ranger districts not using a specific categorical 

 2

GAO, Forest Service: Use of Categorical Exclusions for Vegetation Management Projects,

Calendar Years 2003 through 2005, GAO-07-99 (Washington, D.C.: Oct. 10, 2006).

Page 2 GAO-07-1016T 
exclusion varied by type of categorical exclusion, however. Just over 90 

percent of the 509 ranger districts had not used the categorical exclusion 

for the removal of trees to control the spread of insects or disease and 

about 32 percent had not used the categorical exclusion to improve timber 

stands or wildlife habitat. Reasons cited for not using a categorical 

exclusion varied by type of categorical exclusion and ranger district. For 

example, not all ranger districts had used the categorical exclusion for 

removing insect- or disease-infested trees because they did not have these 

types of trees or because projects for removing such trees had already

been or were to be included in an EA or EIS. 

The Forest Service is responsible for managing over 192 million acres of 

public lands—about 30 percent of all federal lands in the United States. In

carrying out its responsibilities, the Forest Service traditionally has 

administered its programs through 9 regional offices, 155 national forests, 

20 national grasslands, and several hundred ranger districts. 

Background 

Under NEPA, agencies such as the Forest Service generally evaluate the 

likely effects of projects they propose using a relatively brief EA or, if the 

action would be likely to significantly affect the environment, a more 

detailed EIS. However, an agency may generally exclude categories of 

actions from the requirement to prepare an EA or EIS if it has determined 

that the actions do not individually or cumulatively have a significant 

impact on the environment—these categories are known as categorical 

exclusions. The agency may then approve projects fitting within the 

relevant categories using these predetermined categorical exclusions 

rather than carrying out project-specific environmental analyses. For a 

project to be approved using a categorical exclusion, the agency must 

determine whether any extraordinary circumstances exist in which a 

normally excluded action may have a significant effect.3,4

 3

Resource conditions that should be considered in determining whether extraordinary 

circumstances exist include, among other things, the existence of federally listed 

threatened or endangered species or designated critical habitat; congressionally designated 

wilderness areas; inventoried roadless areas; and archaeological sites or historic 

properties. The mere presence of one or more of these conditions does not preclude the 

use of a categorical exclusion. Rather, it is the degree of the potential effect of the 

proposed action on these conditions that determines whether extraordinary circumstances 

exist. 

4

The Forest Service may decide to prepare an EA for a project that could qualify for 

approval using a categorical exclusion. 

Page 3 GAO-07-1016T 
As of 2003, the Forest Service had one categorical exclusion available for 

use in approving certain vegetation management activities—timber stand 

or wildlife habitat improvement—that has no acreage limitation.5

 In 2003, 

after reviewing and evaluating data on the environmental effects of 

vegetation management projects that had been carried out by the national 

forests, the Forest Service added four new vegetation management 

categorical exclusions, each of which has acreage limitations: (1) 

hazardous fuels reduction activities using prescribed fire, not to exceed 

4,500 acres, and mechanical methods such as thinning, not to exceed 1,000 

acres; (2) limited timber harvests of live trees, not to exceed 70 acres; (3) 

salvage of dead or dying trees, not to exceed 250 acres; and (4) removal of

trees to control insects and disease, not to exceed 250 acres.6

 Appendix I 

provides more detailed information on the Forest Service’s five vegetation 

management categorical exclusions.

For calendar years 2003 through 2005, the Forest Service approved about 

3,000 vegetation management projects to treat about 6.3 million acres. Of 

these projects, the Forest Service approved about 70 percent using 

categorical exclusions and the remaining projects using an EA or EIS. 

Although a majority of projects were approved using categorical 

exclusions, these projects accounted for slightly less than half of the total 

treatment acres because the size of these projects was much smaller than 

those approved using an EA or EIS. Table 1 provides this information in 

greater detail. 

Categorical 

Exclusions Were Used 

to Approve the 

Majority of Vegetation 

Management Projects 

and about Half of the 

Total Treatment Acres 

 5

In addition to the timber stand and wildlife habitat improvement categorical exclusion, the 

Forest Service previously had a categorical exclusion for timber sales of 250,000 board-feet 

or less of merchantable wood products or 1 million board-feet of salvage. In 1999, a federal 

district court issued a nationwide injunction barring use of this categorical exclusion, 

holding that the agency did not provide any rationale for why the specified magnitude of 

timber sales would not have a significant effect on the environment. Heartwood v. U.S.

Forest Service, 73 F. Supp. 2d 962,975 (S.D. Ill. 1999), aff’d on other grounds, 230 F. 3d 947 

(7th Cir. 2000). 

6

68 Fed. Reg. 33814 (June 5, 2003) and 68 Fed. Reg. 44598 (July 29, 2003). 

Page 4 GAO-07-1016T 
Table 1: Number of Vegetation Management Projects Approved and Treatment Acres for Different Types of Environmental 

Analyses (Calendar Years 2003 through 2005) 

Type of environmental analysis 

Environmental

impact statement

Environmental

 assessment

Categorical

exclusion Total

Number of projects (percent of total) 141 (4.7) 690 (22.9) 2,187 (72.5) 3,018 (100.0)a

Number of treatment acres (percent 

of total) 899,225 (14.4) 2,506,984 (40.0) 2,856,472 (45.6) 6,262,681 (100.0)a

Median number of treatment acres 

(range)b

2,768 (51 to 60,000) 1,366 (1 to 124,971) 215 (1 to 97,326) 375 (1 to 124,971)

Source: GAO.

a

Numbers may not total to 100 percent due to rounding. 

b

Of the 3,018 vegetation management projects, 113 had no acreage or an unknown acreage, 

according to the Forest Service. The acreage associated with a vegetation management project may 

be zero or unknown because, among other reasons, the unit of measure for the project is in miles of 

roadside to be treated or number of trees to be removed. These projects were not used in calculating

the median or range of treatment acres. 

Our analysis of the project data also revealed that the total number of 

vegetation management projects approved, including those approved 

using categorical exclusions, varied over the 3-year period, while the 

number of treatment acres did not. As can be seen in figure 1, the number 

of projects approved using an EA or EIS varied little over the 3-year 

period; however, the number of projects approved using categorical 

exclusions increased from January 2003 through December 2004—

primarily because of an increased use of the four new categorical 

exclusions—and then decreased from January through December 2005.

Forest Service officials said that any number of factors could have 

influenced the increase and subsequent decrease in the use of categorical

exclusions over the 3-year period. However, given the relatively short 

period of time during which the four new categorical exclusions were in 

use, these officials said that it was not possible to speculate why the 

decrease had occurred.

Page 5 GAO-07-1016T 
Figure 1: Number of Vegetation Management Projects Approved Using an EA, EIS,

or Categorical Exclusion (Calendar Years 2003 through 2005) 

In contrast, as can be seen in figure 2, an analysis of the total treatment 

acres included in projects approved using an EA, EIS, or a categorical 

exclusion did not reveal any notable change over the 3-year period. 

Page 6 GAO-07-1016T 
Figure 2: Number of Treatment Acres Included in those Projects Approved Using an

EA, EIS, or Categorical Exclusion (Calendar Years 2003 through 2005)

We also found that the number of vegetation management projects 

approved, including those approved using categorical exclusions, varied 

by Forest Service region and forest. For example, of all vegetation 

management projects approved nationwide, Region 8—the Southern 

Region—accounted for about 29 percent, of which just over two-thirds 

were approved using categorical exclusions. In contrast, Region 10—

Alaska—accounted for about 2 percent of all vegetation management 

projects, about 60 percent of which were approved using categorical 

exclusions. According to several Forest Service officials, the number of 

vegetation management projects approved and the type of environmental 

analysis used in approving them depended on the forest’s size, ecology,

and location, as the following illustrates: 

• At the 1.8 million-acre Ouachita National Forest, a pine and hickory forest 

in western Arkansas and southeastern Oklahoma, 163 projects were 

Page 7 GAO-07-1016T 
approved—119 using categorical exclusions. Forest officials said the 

forest has a very active vegetation management program because, among

other things, the types of trees located on the forest tend to regenerate 

quickly and are an excellent product for milling. In addition, a large timber 

harvest infrastructure is located nearby, which helps ensure that timber 

sale contracts can be readily competed and awarded. 

• At the 28,000-acre Caribbean National Forest, a humid tropical forest in 

Puerto Rico, no vegetation management projects were approved. 

According to forest officials, the forest does not have an active vegetation 

management program because the forest focuses more on developing

recreational sites and wildlife habitat and because the island has no 

commercial infrastructure to support harvesting or milling timber. 

Appendix II provides detailed information on the number of vegetation

management projects and acres Forest Service regions approved using 

different types of environmental analysis, for calendar years 2003 through 

2005. 

Of the almost 2,200 projects approved using categorical exclusions over 

the 3-year period, the Forest Service most frequently used the vegetation 

management categorical exclusion for improving timber stands or wildlife 

habitat; this categorical exclusion was used on half of the projects to treat 

about 2.4 million acres. As shown in table 2, for the remaining projects, the 

Forest Service primarily used the categorical exclusion for reducing 

hazardous fuels, followed by salvaging dead or dying trees, conducting 

limited timber harvests of live trees, and removal of trees to control the 

spread of insects or disease; in all, these categorical exclusions were used 

to approve treatments on about a half-million acres. In addition, the size of 

approved projects varied depending on the categorical exclusion and any 

associated acreage limitation. 

The Categorical 

Exclusion for 

Improving Timber 

Stands or Wildlife 

Habitat Was the Most 

Frequently Used 

Page 8 GAO-07-1016T 
Table 2: Number of Vegetation Management Projects Approved and Treatment Acres for Different Types of Categorical 

Exclusions (Calendar Years 2003 through 2005) 

Improve 

timber stands

 or wildlife 

habitat (no acre 

limitation) 

Hazardous

 fuels reduction

(5,500-acre 

limitation)

Salvage of

 dead or

 dying trees 

(250-acre

limitation)

Limited timber

harvest of live 

trees (70-acre 

limitation)

Removal of 

insect- or

 diseaseinfested trees 

(250-acre

limitation) Total

Number of 

projects (percent 

of total) 1,094 (50.0) 485 (22.2) 264 (12.1) 220 (10.1) 124 (5.7) 2,187 (100.0)a

Number of 

treatment acres 

(percent of total) 

2,402,188 

(84.1) 405,546 (14.2) 28,939 (1.0) 10,541 (0.4) 9,258 (0.3) 2,856,472 (100.0)a

Median number 

of treatment 

acres (range)b

433 (1 to 97,326) 450 (1 to 4,637) 96 (1 to 250) 59 (1 to 70) 8 (1 to 250) 215 (1 to 97,326)

Source: GAO.

a

Numbers may not add to 100 percent due to rounding. 

b

Of the 2,187 vegetation management projects approved using categorical exclusions, 71 had no 

acreage or an unknown acreage, according to the Forest Service. The acreage associated with a 

vegetation management project may be zero or unknown because, among other reasons, the unit of

measure for the project is listed as miles of roadside to be treated or number of trees to be removed.

These projects were not used in the calculation of the median or range. In addition, the Forest 

Service indicated that for 38 projects, in addition to the categorical exclusion cited as being used, one 

or more of the remaining four categorical exclusions was also used. We counted only the first 

categorical exclusion cited. 

According to Forest Service officials, a number of factors influenced the 

reasons that the categorical exclusion for timber stand or wildlife habitat

improvement was used most frequently for the most treatment acreage.

For example, officials at the George Washington and Jefferson National 

Forests and the Monongahela National Forest said they relied on this 

categorical exclusion more than others because the use of this category 

was consistent with their forest management plans, which dictate the 

types of activities that may take place on their forests. Santa Fe National 

Forest officials said that the forest has relied heavily on this categorical 

exclusion because it does not have an acreage limitation. 

We also analyzed the categorical exclusion for timber stand or wildlife 

habitat improvement to determine whether its lack of size limitation 

resulted in projects that are larger than those undertaken using the other 

four exclusions that have acreage limitations. We found that almost 92 

Page 9 GAO-07-1016T 
percent of the 1,054 projects7

 approved using the categorical exclusion for 

timber stand or wildlife habitat improvement were smaller than 5,000 

acres—which is the approximate size limitation of the categorical 

exclusion for hazardous fuels reduction, the largest size limitation of the 

four more recent categorical exclusions. 

Eleven percent of the 509 ranger districts had not used any of the five 

vegetation management categorical exclusions during the 3-year period. 

The percentage of ranger districts that did not use specific categorical 

exclusions ranged widely, from 91 percent not using the category for the 

removal of trees to control the spread of insects or disease, to 32 percent

not using the category for timber stand or wildlife habitat improvement. 

Ranger districts’ reasons for not using a specific categorical exclusion also 

varied. The primary reason cited for not using the categorical exclusion 

for the removal of trees to control the spread of insects or disease was that

their forests did not have insect- or disease-infested trees and that projects 

that could have fit the category had already been or were to be included in

an EA or EIS. Similarly, the primary reasons cited for not using the 

categorical exclusion for timber stand or wildlife habitat improvement 

were that projects that could have fit the category had already been or 

were to be included in an EA or EIS and no projects were undertaken to 

improve stands or wildlife habitat. Appendix III provides the number of 

ranger districts not using one of the five vegetation management 

categorical exclusions and primary reasons cited for not doing so. 

Primary Reasons for 

Not Using Vegetation 

Management 

Categorical 

Exclusions Varied 

Depending on the 

Ranger District and 

Type of Categorical 

Exclusion 

Ranger district officials we interviewed offered some reasons for why 

specific vegetation management categorical exclusions may not be used. 

For example, 

• The Tonasket Ranger District, located in north-central Washington State in

the Okanogan-Wenatchee National Forests, had not used the categorical 

exclusion for the removal of trees to control the spread of insects or 

disease because, according to district officials, the 250-acre size limitation 

of the categorical exclusion constrains its use. The district has huge areas

infested with beetles and mistletoe and, to be effective, any salvage would 

have to cover a much larger area. 

 7

Of the 1,094 projects approved using the categorical exclusion to improve timber stands or

wildlife habitat, 40 had no acreage or an unknown acreage, according to the Forest Service. 

Page 10 GAO-07-1016T 
• The Canyon Lakes Ranger District, located in north-central Colorado in 

the Arapaho-Roosevelt National Forests, had not used the categorical 

exclusion for timber stand or wildland habitat improvement. According to 

ranger district officials, they have not used this categorical exclusion 

because project planning typically consists of an EA or EIS. These types of 

environmental analysis allow the district to better evaluate multiple 

activities over large geographic areas using a single analysis—which is 

more efficient than approving different projects using several vegetation 

management categorical exclusions.

Because four of the five categorical exclusions have only been available 

since 2003, it is premature to draw any conclusions about trends in the 

Forest Service’s use of them to approve vegetation management projects. 

More information over a longer period of time will be useful in addressing 

some of the controversial issues, such as whether categorical exclusions, 

individually or cumulatively, have any significant effect on the

environment or whether their use is enabling more timely Forest Service 

vegetation management. 

Mr. Chairman, this concludes my prepared statement. I would be pleased

to answer any questions that you or other Members of the Subcommittee 

may have at this time. 

For further information about this testimony, please contact me at (202) 

512-3841 or nazzaror@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this statement. David P. Bixler, Assistant Director; Rich Johnson; 

Marcia Brouns McWreath; Matthew Reinhart; and Carol Herrnstadt 

Shulman made key contributions to this statement. 

Concluding 

Comments 

GAO Contacts and 

Staff 

Acknowledgements 

Page 11 GAO-07-1016T 
Page 12 GAO-07-1016T 

Type of categorical exclusion for vegetation management and

conditions Examples of activities 

Timber stand or wildlife habitat improvement 

No acreage restrictions. May not use herbicides. No more than 

1 mile of low standard road construction.a

 

• Girdling trees to create snags.

b

• Thinning or brush control to improve growth or reduce fire 

hazard, including the opening of an existing road to a dense

timber stand. 

• Prescribed burning to control understory hardwoods in 

stands of southern pine. 

• Prescribed burning to reduce natural fuel build-up and 

improve plant vigor. 

Hazardous fuels reduction activities using prescribed fire; 

and mechanical methods for crushing, piling, thinning, pruning, 

cutting, chipping, mulching, and mowing 

Prescribed fire not to exceed 4,500 acres and mechanical methods 

not to exceed 1,000 acres. Activities are limited to (1) areas in the 

wildland-urban interface or (2) designated areas outside the wildlandurban interface.

c

 Activities must 

• be identified through a collaborative framework as described in A 

Collaborative Approach for Reducing Wildland Fire Risks to 

Communities and Environment 10-Year Comprehensive Strategy 

Improvement Plan, May 2002;

• be conducted consistent with agency and departmental

procedures and applicable land and resource management plans; 

• not include the use of herbicides or pesticides or the construction 

of new permanent roads or other new permanent infrastructure, 

and may include the sale of vegetative material if the primary 

purpose of the activity is hazardous fuels reduction; and 

• not be conducted in wilderness areas or impair the suitability of 

wilderness study areas for preservation as wilderness. 

• Prescribed burning. 

• Mechanically crushing, piling, thinning, pruning, cutting, 

chipping, mulching, and mowing. 

Limited harvest of live trees

Not to exceed 70 acres. No more than one-half mile of temporary 

road construction. This categorical exclusion is not to be used for 

harvesting or generating same-aged trees or converting to a different 

type of vegetation. May include incidentally removing trees for 

landings, skid trails, and road clearing. 

• Removing individual trees for saw logs, specialty products, 

or fuel wood. 

• Commercial thinning of overstocked stands to achieve the 

desired stocking level to increase health and vigor. 

Salvage of dead and/or dying trees 

Not to exceed 250 acres. No more than one-half mile of temporary 

road construction. May include incidentally removing trees for 

landings, skid trails, and road clearing. 

• Harvesting a portion of a stand damaged by a wind or ice 

event and construction of a short temporary road to access 

the damaged trees. 

• Harvesting fire-damaged trees. 

Appendix I: Forest Service’s Vegetation 

Management Categorical Exclusions 
Type of categorical exclusion for vegetation management and

conditions Examples of activities 

Removal of insect- or disease-infested trees 

Not to exceed 250 acres. No more than one-half mile of temporary 

road construction. Includes removing infested or infected trees and 

adjacent live un-infested or uninfected trees as determined necessary 

to control the spread of insects or disease. May include incidentally 

removing trees for landings, skid trails, and road clearing. 

• Felling and harvesting trees infested with southern pine 

beetles and immediately adjacent un-infested trees to 

control expanding spot infestations. 

• Removing and destroying infested trees affected by a new 

exotic insect or disease, such as emerald ash borer, Asian 

long horned beetle, and sudden oak death pathogen. 

Source: Forest Service Handbook. 

a

A low standard road is one which has a rough and irregular surface where traffic flow is slow and 

two-way traffic is difficult. While the road can accommodate high clearance vehicles, it may not 

provide safe service to all traffic. 

b

Girdling is a process whereby tree trunks are severed to remove the outer layers of bark and other 

woody material. This constricts the level of nutrients available to support tree life and can result in a 

snag—a standing, dead tree. 

c

These include certain areas with fire regimes that have been moderately or significantly altered from 

historical ranges.

Page 13 GAO-07-1016T 
Page 14 GAO-07-1016T 

Appendix II: Number of Projects and Acres 

by Type of Environmental Analysis and 

Forest Service Region (2003 - 2005) 

Regions

Region 1

Region 2

Region 3

Projects Acres (in thousands)

28

33

228

289

206

73

139

419a

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

14

63

153

230

83

171

117

371

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

5

40

192

237

47

695

262

1,004

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

Region 5

Region 4 22

42

175

239

74

94

141

309

14

62

282

358

87

108

198

393
Note: Of the 3,018 vegetation management projects, 113 had no acreage or an unknown acreage, 

according to the Forest Service. The acreage associated with a vegetation management project may 

be zero or unknown because, among other reasons, the unit of measure for the project is listed as

miles of roadside to be treated or number of trees to be removed. 

a

Numbers do not add due to rounding. 

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

0 100 200 300 400 500 600 700 800 900 0 500 1,000 1,500 2,000 2,500 3,000

Region 6

Region 8

Region 9

Region 10

Regions Projects Acres (in thousands)

Source: GAO.

Total

Environmental impact statement 

Environmental assessment

Categorical exclusion

28

88

321

437

275

223

302

800

4

249

633

886

21

915

1,609

2,545

16

104

176

296

95

222

73

390

10

9

27

46

10

4

16

30

Page 15 GAO-07-1016T 
Page 16 GAO-07-1016T 

Appendix III: Number of Ranger Districts Not 

Using One of the Five Categorical Exclusions 

and Reasons Why (2003 – 2005) 

Categorical exclusion 

Removal of insector disease-infested

trees (250-acre 

limitation)

Limited timber

harvest of live 

trees (70-acre 

limitation)

Salvage of

dead or

dying trees 

(250-acre

limitation) 

Hazardous

fuels 

reduction 

(5,500-acre 

limitation)

Improve

timber 

stands or

wildlife 

habitat (no 

acreage 

limitation)

Number of the 509 (percent of total) ranger 

districts that had not used the categorical 

exclusion 462 (90.8) 395 (77.6) 353 (69.4) 256 (50.3) 165 (32.4)

Primary reason for not using an exclusion Number of ranger districts not using the categorical exclusion that cited the 

primary reason

Lack of insect- or disease-infested trees 114 (24.7) a a a a

Size (acreage) of potential projects is larger 

than that allowed 27 (5.8) 110 (27.9) 36 (10.2) 22 (8.6) a

Lack of dead or dying trees to salvage a a95 (26.9) a a

Projects that could fit the category have already 

been or will be included in an environmental 

assessment or impact statement 108 (23.4) 100 (25.3) 66 (18.7) 62 (24.2) 59 (35.8)

No projects undertaken to improve timber 

stands or wildlife habitat a a a a

61 (37.0)

Have insect- or disease-infested trees, but other 

priorities precluded its use 88 (19.1) a a a a

Lack of internal Forest Service resources to 

propose and plan a vegetation management 

project 27 (5.8) 55 (13.9) 28 (7.9) 33 (12.9) 26 (15.8)

Lack of required wildland fire risk reduction plan 

for using the category a a a

46 (18.0) a

Have dead or dying trees, but other priorities

precluded its use a a

47 (13.3) a a

Other categorical exclusion used 14 (3.0) 16 (4.1) 13 (3.7) 21 (8.2) 2 (1.2)

Lack of commercial infrastructure to harvest or 

salvage trees 14 (3.0) 21 (5.3) 16 (4.5) 2 (0.8) 2 (1.2)

No hazardous fuels a a a13 (5.1) a

Ranger district or national forest preference to

use an environmental assessment as opposed 

to the categorical exclusion 5 (1.1) 13 (3.3) 8 (2.3) 6 (2.3) 5 (3.0)

Other reasons 64 (13.9) 80 (20.3) 45 (12.7) 51 (20.0) 10 (6.1)

Source: GAO.

a

The primary reason listed was not applicable to the categorical exclusion and, thus, was not an 

option for the Forest Service to choose. 

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