United States Government Accountability Office

GAO Report to the Chairman, Subcommittee 

on Forests and Forest Health, 

Committee on Resources, House of 

Representatives 

WILDLAND FIRE 

REHABILITATION 

AND RESTORATION 

Forest Service and 

BLM Could Benefit 

from Improved 

Information on Status 

of Needed Work 

June 2006 

 

GAO-06-670 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

June 2006

WILDLAND FIRE REHABILITATION AND 

RESTORATION 

Forest Service and BLM Could Benefit 

from Improved Information on Status of 

Needed Work 

Highlights of GAO-06-670, a report to the 

Chairman, Subcommittee on Forests and 

Forest Health, Committee on Resources, 

House of Representatives

Since 2001, Congress and federal 

agencies, including the Forest

Service and Department of the 

Interior’s Bureau of Land 

Management (BLM), have

recognized the importance of 

rehabilitating and restoring lands 

unlikely to recover on their own

after wildland fires. However, 

while funding has increased for fire

prevention, suppression, and firstyear emergency stabilization, it has 

decreased for rehabilitation (work 

up to 3 years after fires) and 

restoration (work beyond the first 

3 years). GAO was asked (1) how

the Forest Service and BLM plan 

postfire rehabilitation and 

restoration projects, (2) how much

needed rehabilitation and 

restoration work they have 

completed for recent wildland 

fires, and (3) what challenges the 

agencies face in addressing their 

needs. 

What GAO Recommends

GAO is recommending that the 

Forest Service and BLM improve

their information on whether 

postfire rehabilitation and 

restoration needs are met, and that 

the Forest Service augment 

research to help guide decisions. 

In commenting on a draft of this 

report, the Forest Service and 

Interior generally agreed with 

GAO’s findings and 

recommendations. 

The Forest Service and BLM use similar procedures to identify rehabilitation 

and restoration needs, but differ in how they plan and fund related projects. 

Given the variety of ecosystems they manage, Forest Service field staff have

the discretion to locally prioritize projects, and the agency addresses them 

through various programs with appropriations from multiple accounts. In 

contrast, BLM has a standard process for planning needed rehabilitation 

projects and, through a single account, funds projects for up to 3 years after 

fires. For restoration projects—that is, work needed beyond 3 years after a 

fire—BLM requires them to be addressed through other programs such as 

rangeland management. 

With available information, it is not possible to reliably determine how much 

needed rehabilitation and restoration work has been completed for recent 

Forest Service and BLM fires. The Forest Service does not know how much 

work has been completed because it does not collect nationwide data. BLM

reported that, according to its data, it has completed most of its 

rehabilitation work, but the agency does not collect data on postfire 

restoration work, which is done through other programs. GAO surveyed 

Forest Service and BLM officials to determine how much needed work has 

been completed, but the information provided in the survey was not 

sufficiently reliable to report. 

Forest Service and BLM officials face different challenges to addressing their 

rehabilitation and restoration needs. Forest Service officials cited factors 

such as competing priorities within constrained budgets and controversy 

over certain activities. Agency officials said that controversy over harvesting 

burned timber can be exacerbated by the limited scientific research 

available to guide such decisions. BLM officials cited challenges to 

achieving long-term success when seeding burned areas. The agency is

taking several steps to improve success rates. 

Forest Service Building Partly Buried by Postfire Flood Debris (left) and Restored Later 

Source: Forest Service.

www.gao.gov/cgi-bin/getrpt?GAO-06-670.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robin M. 

Nazzaro at (202) 512-3841 or 

nazzaror@gao.gov. 
Contents 

Letter 1

Results in Brief 4

Background 6

Forest Service and BLM Differ in How They Plan Needed 

Rehabilitation and Restoration Work 10 

Forest Service Lacks Data on Rehabilitation and Restoration Work; 

BLM Lacks Data on Restoration Work 19 

Forest Service and BLM Officials Cite Different Challenges to

Rehabilitating and Restoring Their Lands 24 

Conclusions 34

Recommendations for Executive Action 35 

Agency Comments and Our Evaluation 35 

Appendix I Objectives, Scope, and Methodology 37 

Appendix II Comments from the Department of the Interior 41 

Appendix III GAO Contact and Staff Acknowledgments 43

Table 

Table 1: Verification Results for Survey Responses about Project 

Completion and Funding 40 

Figures 

Figure 1: Postfire Flood Damage at Sabino Canyon Recreation Site, 

Coronado National Forest, Arizona 7 

Figure 2: Completed Rehabilitation of Sabino Canyon Recreation 

Site, Coronado National Forest, Arizona 8 

Figure 3: A Helicopter Prepares to Aerially Seed a Burned Area 

after a 2005 BLM Fire 32 

Page i GAO-06-670 Wildland Fire Rehabilitation and Restoration
Abbreviations 

BLM Bureau of Land Management 

This is a work of the U.S. government and is not subject to copyright protection in the 

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other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page ii GAO-06-670 Wildland Fire Rehabilitation and Restoration
United States Government Accountability Office

Washington, DC 20548 

June 30, 2006 

The Honorable Greg Walden 

Chairman 

Subcommittee on Forests and Forest Health 

Committee on Resources 

House of Representatives 

Dear Mr. Chairman: 

In the past 5 years, wildland fires have burned millions of acres of federal

land, breaking records in size, costing billions of dollars to suppress, and 

drawing greater attention to the risks associated with wildland fires. Many 

fires occur naturally, and some ecosystems are adapted to fires, relying on 

them to maintain their health. However, wildland fires can sometimes 

leave behind a burned landscape that threatens human safety, property, 

and ecosystems. In areas of steep terrain, postfire rainstorms can cause 

mudslides that bury homes, destroy roads, and clog streams. Wildland 

fires also can create postfire environments that are ideal for the growth of 

noxious or invasive weeds. If these weeds replace native plant species, 

threatened or endangered wildlife species can lose their habitat. When 

fires result in such adverse effects, land managers may conduct emergency 

stabilization, rehabilitation, and restoration activities to mitigate the 

effects and to prevent further damage. The U.S. Department of 

Agriculture’s Forest Service and the Department of the Interior’s land 

management agencies are responsible for such activities on federal land.

1

Combined, the Forest Service and Interior manage about 630 million acres, 

or 94 percent, of the nation’s federal land, including forests, rangelands, 

and other lands. 

In 2001, in response to one of the worst fire seasons in over 50 years, the 

Departments of Agriculture and the Interior, in collaboration with state 

governors, adopted a 10-year strategy to address federal, state, local, and 

tribal management of wildland fires.2

 One of the four goals adopted in the 

strategy was to restore fire-adapted ecosystems through rehabilitation and 

 1

The Department of the Interior’s federal land management agencies include the Bureau of

Land Management, National Park Service, and Fish and Wildlife Service. 

2

Years cited in this report refer to calendar years except where otherwise specified. 

Page 1 GAO-06-670 Wildland Fire Rehabilitation and Restoration
restoration efforts, combined with scientific research and monitoring. In

support of this goal, Congress began providing funds in fiscal year 2001 to

the Forest Service and Interior specifically for postfire rehabilitation and 

restoration. 

In 2003, as a step toward coordinating their approaches to postfire 

management, the Forest Service and Interior adopted the following 

common definitions for emergency stabilization, rehabilitation, and 

restoration: 

• Emergency stabilization activities are conducted within 1 year of a fire 

to address threats to life, property, or resources. Such activities may 

include seeding and mulching to prevent soil erosion. 

• Rehabilitation activities, conducted within 3 years of a fire, address 

damage to minor facilities such as picnic facilities, or to lands unlikely to

recover to a desired condition on their own. Such activities may include 

repairing roads or trails, planting trees, and restoring wildlife habitat. 

• Restoration activities are a continuation of rehabilitation activities 

beyond the initial 3 years, or the repair or replacement of major facilities, 

such as a visitor center. 

Although the Forest Service and the Bureau of Land Management (BLM)—

the agency that manages the most land within Interior—are both 

responsible for managing postfire work on federal lands, the task is 

different for the two agencies. The Forest Service conducts emergency 

stabilization, rehabilitation, and restoration activities under multiple 

programs such as its watershed improvement and reforestation programs, 

while BLM conducts emergency stabilization and rehabilitation activities 

under distinct postfire programs that do not address restoration needs. 

Forest Service land encompasses a wide variety of ecosystems—

ecological communities such as old-growth forests, alpine meadows, and

marsh wetlands—and watersheds that provide drinking water and timber, 

while most of BLM’s land consists of rangeland (although BLM also 

manages about 55 million acres of forests and woodlands). These land 

characteristics influence the agencies’ work. For example, the Forest 

Service’s rehabilitation and restoration activities commonly include 

reforestation, road work, trail work, and weed control, but also can 

include activities ranging from surveying boundaries to securing 

archaeological sites. On the other hand, BLM’s rehabilitation activities 

include primarily weed control, grass and shrub seeding, and fence repair 

or replacement. 

Page 2 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Since 2001, Congress and the agencies have taken actions that recognize 

the importance of rehabilitation and restoration activities, including 

directing funds toward these activities and developing strategy documents. 

However, while resources for fire prevention, suppression, and emergency 

stabilization have increased, fewer resources have been focused on the 

long-term rehabilitation and restoration of lands burned by fires. Between 

fiscal year 2001 and 2005, annual appropriations to the Forest Service and 

Interior for fire prevention, suppression, and emergency stabilization 

increased by about 26 percent (15 percent adjusted for inflation), but 

rehabilitation and restoration appropriations (directed in law or 

committee reports) declined steeply, from $246 million in fiscal year 2001 

to $37 million in fiscal year 2005—a decrease of about 85 percent (86 

percent adjusted for inflation).3

 In this context, you asked us to determine 

(1) how the Forest Service and BLM identify and plan postfire 

rehabilitation and restoration activities; (2) how much needed 

rehabilitation and restoration work the agencies have completed for 

wildland fires that occurred between 2000 and 2004; and (3) what 

challenges the agencies face in addressing their postfire needs, and any

actions they are taking in response. 

In conducting our work, we met with Forest Service and BLM officials; 

reviewed agency documents about postfire rehabilitation and restoration 

programs, projects, and funding procedures; and discussed challenges the 

agencies face in addressing needed rehabilitation and restoration work. 

We visited seven forests and three BLM units in western states, where 

rehabilitation and restoration efforts are concentrated, to interview agency 

officials and observe postfire conditions and rehabilitation and restoration 

projects. We also administered a Web-based survey to agency officials for 

276 randomly sampled fires that occurred between 2000 and 2004 and 

burned over 500 acres each. For each of the fires in our sample, we 

surveyed agency officials in the field about any needed rehabilitation and 

restoration projects they identified, whether the projects were completed,

factors preventing their completion, and any effects of not completing 

needed projects. However, when we collected source documents to 

validate responses for 10 percent of the completed surveys, we found that 

the data provided were not sufficiently reliable to report. A more detailed 

description of our scope and methodology is presented in appendix I. We 

 3

Dollar amounts are presented in nominal terms—unadjusted for inflation—unless

otherwise noted. 

Page 3 GAO-06-670 Wildland Fire Rehabilitation and Restoration
performed our work from May 2005 through May 2006 in accordance with 

generally accepted government auditing standards. 

In the aftermath of wildland fires, the Forest Service and BLM use similar 

procedures to identify rehabilitation and restoration needs, but differ in 

how they plan, prioritize, and fund needed work. To determine what 

rehabilitation or restoration projects, if any, are necessary after a wildland

fire, both the Forest Service and BLM first assess the condition of the 

burned area and compare it with prefire and desired conditions. In many 

cases, the condition of the land is satisfactory—for example, because the 

fire did not burn severely—and no rehabilitation or restoration is needed. 

For fires that need rehabilitation or restoration, the Forest Service and 

BLM differ in how they plan, prioritize, and fund projects. The Forest 

Service has no national requirements for its rehabilitation and restoration 

activities; instead, it gives its regions and forests the discretion to develop

procedures independently, so they can tailor them to their particular 

ecosystems and priorities. For example, some regions place a higher 

priority on infrastructure projects, such as repairing roads, trails, and 

recreation facilities, while others prioritize projects to help ecosystems 

recover, such as replanting burned areas. The Forest Service pays for its 

rehabilitation and restoration projects using funds from several different 

appropriations, including appropriations specifically designated for such 

activities under the wildland fire management account; appropriations 

from the national forest system account, which are available for recreation 

and vegetation management, for example; and appropriations from the 

capital improvement and maintenance account, which are available for 

road and facility construction or repair, among other things. According to

Forest Service officials, relying on these other program funds allows 

regions and forests greater flexibility to determine their priorities across 

many program areas and to accommodate needs that arise after other 

unpredictable events, such as hurricanes. BLM, on the other hand, uses a 

standardized process to plan, prioritize, and fund its rehabilitation work. 

BLM field staff develop 3-year rehabilitation plans, its state and 

headquarters officials review and approve the plans, and headquarters 

officials allocate the available funding. Unlike the Forest Service, BLM 

pays for nearly all of its rehabilitation work with appropriations from a 

single source—its wildland fire management account—and requires the 

work to be complete within 3 years after a fire. BLM requires any 

subsequent restoration work to be addressed through other programs, 

such as range improvement and noxious weeds. 

Results in Brief 

Page 4 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Using available information, neither the agencies nor we could reliably 

determine how much needed rehabilitation and restoration work has been 

completed for Forest Service and BLM fires that occurred between 2000 

and 2004. The Forest Service does not maintain comprehensive data on 

rehabilitation and restoration work, and thus could not determine how 

much rehabilitation and restoration work has been completed nationwide. 

In our visits to several national forests, agency officials reported 

completing all needed rehabilitation and restoration work for some fires, 

and little or no needed work for other fires, but without nationwide data, it 

is unclear how widespread either of these situations is. Also, while BLM 

maintains data on its rehabilitation work, the agency does not maintain 

data on its postfire restoration work, which is completed through other 

programs. BLM officials told us that, according to their data, most 

rehabilitation work needed through fiscal year 2005 has been completed. 

However, we could not independently validate all of BLM’s rehabilitation 

data because these data are commingled with the agency’s emergency 

stabilization data for fires before 2004. We administered a survey to 

officials from both agencies to obtain this information, but determined 

that the data provided in the survey was not reliable. Specifically, we 

requested source documents from a sample of respondents to validate the 

survey data, but a significant portion of the documents we received did not 

substantiate the survey responses. Without comprehensive data on needed 

and completed rehabilitation and restoration work, Forest Service and 

BLM officials make management decisions, including requesting and 

allocating funding, without knowing to what extent they are addressing 

the needs on their lands.

Forest Service and BLM officials said they face different challenges in 

their efforts to address postfire rehabilitation and restoration needs, in 

part reflecting their different management approaches, ecosystems, and 

postfire activities. Forest Service field officials reported that a lack of 

dedicated funds, insufficient workforce, and other factors prevented many

needed projects from being completed. In addition, officials told us the 

method the agency used to allocate annual rehabilitation and restoration 

funding to regions meant that available funds fluctuated dramatically from

year to year, making it difficult to manage the program. Forest Service 

officials said they have tried to stabilize the erratic funding levels by 

changing how they allocate these funds to regions in fiscal year 2006, but 

have not asked for additional rehabilitation and restoration funding 

because of other competing program priorities and budget constraints. 

Forest Service field officials also noted that controversy about postfire 

activities, such as using chemical herbicides and harvesting burned timber, 

presented challenges. Disagreements about whether such actions would 

Page 5 GAO-06-670 Wildland Fire Rehabilitation and Restoration
result in beneficial or harmful effects compared with doing nothing 

sometimes delayed projects, they said. Several Forest Service officials 

expressed concern that in some cases there is insufficient scientific 

evidence to support one action over another, and further noted that little 

research has been done to address this shortage. Consequently, officials 

rely on a limited number of studies when making decisions in these cases, 

which may at times exacerbate the existing controversy. For BLM, 

headquarters and field officials told us that while they believe they have

completed most of their projects, they face challenges in achieving longterm success with some of their completed projects. According to agency

officials, many of BLM’s seeding and planting projects fail or are only 

partially successful because there is not enough rain for seeds to grow, or 

because officials, relying on limited information, use planting techniques 

that prevent seeds from germinating. To address this issue, BLM officials 

said they are now monitoring rehabilitation projects more consistently to 

learn why projects are effective or not, and have begun developing 

standard monitoring protocols and a Web-based information-sharing 

network that will allow staff to share lessons learned. 

To ensure that agency and congressional decision makers know if highpriority needs are being met, and to help them make informed funding and 

other decisions, we are recommending that (1) the Secretary of 

Agriculture direct the Forest Service to track and report to Congress the 

extent to which it is addressing its high-priority rehabilitation and 

restoration work, and (2) the Secretary of the Interior direct BLM to 

establish a procedure to address any postfire restoration work needed

after 3 years, and to track and report to Congress the status of such work. 

We also are recommending that the Secretary of Agriculture direct the 

Forest Service to conduct additional research on the effects of postfire 

projects to provide agency officials with more scientific evidence to better 

support their decisions, especially about controversial actions. In 

commenting on a draft of this report, the Forest Service and Interior 

generally agreed with our findings and recommendations. 

Although wildland fires are inevitable natural disturbances that have 

helped shape ecosystems over time, they can be unpredictable and 

destructive as well. Fires can kill trees and other vegetation, alter wildlife 

habitat and soils, and destroy roads, buildings, campgrounds and other 

infrastructure. Fires can also leave lands denuded of vegetation and 

vulnerable to severe erosion and mudslides, which can contaminate 

municipal water supplies and compromise water quality in streams and 

lakes. In addition, the open landscapes left by fires can create

Background 

Page 6 GAO-06-670 Wildland Fire Rehabilitation and Restoration
opportunities for invasive plants to become established or expand, 

crowding out native plants and the animals that depend on them. When 

wildland fires have adverse effects on natural resources, and federal land

managers believe the lands are unlikely to recover to a desired condition

on their own, they may conduct rehabilitation or restoration work to aid or 

accelerate recovery. Similarly, when wildland fires damage developed 

features such as roads, trails, buildings, fences, or campgrounds, land 

managers may identify needed work to repair or replace them, as shown in 

figures 1 and 2. Rehabilitation and restoration projects include, for 

example, repairing or maintaining roads and trails, controlling noxious and 

invasive weeds, replanting forests or grasslands, repairing or replacing 

fences, restoring fish or wildlife habitat, rebuilding burned facilities, 

replacing boundary markers, and stabilizing archaeological sites. 

Figure 1: Postfire Flood Damage at Sabino Canyon Recreation Site, Coronado

National Forest, Arizona

Source: Forest Service.

A restroom and turnaround (left) in a popular recreation area near Tucson, Arizona, were

inundated with 4 feet of debris that washed down the canyon in August 2003, 1 month after 

the Aspen fire was controlled. Mud blocked the restroom door (right) and completely covered

trash cans. The rock wall behind the restroom was damaged, and the road leading to the site

was impassable. Concerns about public safety and accessibility necessitated public-use 

closures for about a year as additional floods continued to damage the site. 

Page 7 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Figure 2: Completed Rehabilitation of Sabino Canyon Recreation Site, Coronado

National Forest, Arizona

In some cases, land managers may determine that no rehabilitation or 

restoration projects are needed because a fire did not have adverse effects 

on any resources or infrastructure, or because the burned lands are likely 

to recover on their own. Under historical conditions, many forest and 

rangeland ecosystems have adapted to wildland fire, and the vegetation, 

insects, fish, and wildlife in such systems benefit from the kind of fires 

that occur there, surviving and regenerating after fires occur. Fires can 

benefit resources by recycling soil nutrients, renewing vegetation growth, 

adding material to streams that improves spawning habitat for fish, and 

sustaining ecological functions. For example, when ponderosa pine forests 

are adapted to wildland fires, frequent less-intense fires remove brush and 

small trees, which allows the large trees to survive and grow.

Recognizing the need to restore historic vegetation conditions to help 

reduce the risks of wildland fires, as well as the need to address adverse 

effects that can result from fires, in 2001 and 2002, federal agencies, states, 

and others developed a 10-year strategy and implementation plan. The 

strategy established four broad goals for wildland fire management: (1) 

improving fire prevention and suppression for those areas that need it; (2) 

reducing hazardous fuels, by mechanically thinning forests and using 

controlled burns; (3) restoring fire-adapted ecosystems and rehabilitating 

burned areas; and (4) promoting community assistance to help conduct 

Source: Forest Service.

Forest Service officials repaired the damaged restroom in 2005 using rehabilitation and

restoration funding. They also replaced the small corrugated metal pipe that existed prior

to the fire with a large grated-box culvert (foreground, left photo), to prevent future clogging

like that which caused much of the damage during the August 2003 flood. 

Page 8 GAO-06-670 Wildland Fire Rehabilitation and Restoration
fire management activities. The implementation plan established measures 

for showing progress toward each of the goals. 

Around the same time, in fiscal year 2001, Congress began providing funds 

to the Forest Service and Interior specifically for postfire rehabilitation 

and restoration. The funding was greatest in 2001, and decreased after 

that, particularly for the Forest Service. To administer these funds and 

address its rehabilitation and restoration needs, the Forest Service relies 

on existing staff and programs, such as watershed improvement and 

recreation programs. On the other hand, BLM has a specific rehabilitation 

program and some dedicated staff to administer its funds. BLM’s program 

initially included both emergency stabilization and postfire rehabilitation 

work, but since 2004 has been separated into two programs. BLM’s 

rehabilitation program covers work up to 3 years after a fire and does not 

provide for subsequent postfire restoration work. The Forest Service 

manages its rehabilitation and restoration work through nine regional 

offices, and offices overseeing 155 national forests and 20 national 

grasslands across the nation. Each forest and grassland is divided into 

several ranger districts. BLM manages its rehabilitation program through 

state offices in 12 western states, including Alaska, that oversee field and 

district offices. 

Both the Forest Service and BLM manage their lands for multiple uses, 

including timber production, wildlife, recreation, and wilderness purposes. 

Under the National Forest Management Act, the primary law governing the 

land management planning activities of national forests in the Forest 

Service, all national forests must have land and resource management 

plans for the lands they manage. Generally, these plans describe desired 

future conditions for lands and resources in various geographic areas 

within the forest, and identify strategies to maintain or achieve those 

conditions. Similarly, BLM field offices develop resource management 

plans under the Federal Land Policy and Management Act for the lands 

they manage. Like the national forests’ plans, BLM plans identify specific 

desired outcomes and allowable uses and actions to achieve those 

outcomes. Generally, neither agency’s plans identify strategies or actions 

specifically related to postfire recovery. 

When agency officials identify needed projects—including postfire 

rehabilitation and restoration projects—they must ensure that the projects 

are consistent with these land management plans. In addition, if a project

could have environmental impacts, the agencies are required to conduct 

an analysis of the potential impacts. Under the National Environmental 

Policy Act of 1969, agencies generally evaluate the likely effects of projects 

Page 9 GAO-06-670 Wildland Fire Rehabilitation and Restoration
they propose using a relatively brief environmental assessment or, if the 

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

detailed environmental impact statement. One purpose of this analysis is 

to ensure that agencies have detailed information available to inform their 

decision making. The agencies give the public an opportunity to comment 

on draft environmental assessments and impact statements. Also, the 

Forest Service and BLM have established procedures for administrative 

appeal of their decisions. As a general rule, once the administrative 

appeals process is complete, the public can litigate the relevant project 

decision in federal court.

The Forest Service and BLM use similar procedures to determine whether 

any rehabilitation or restoration work is needed after a wildland fire, but 

they differ in how they plan, prioritize, and fund needed work. These 

differences reflect the distinct approaches the Forest Service and BLM 

have adopted for managing postfire rehabilitation and restoration. The 

Forest Service has no national guidance for postfire rehabilitation and 

restoration, in part because it does not have a discrete program for such 

activities. Instead, the agency addresses its rehabilitation and restoration 

needs through existing programs, including its watershed, forest 

management, recreation, rangeland management, wilderness, and 

construction programs, among others. Forest Service regions and forests 

have discretion to determine how to plan, prioritize, and fund needed

rehabilitation and restoration work in the context of these programs. To 

fund such work, the agency draws from several different appropriations.4

On the other hand, BLM has a distinct program for postfire rehabilitation, 

and has issued national guidance for the program. Following this 

guidance, agency officials use a standard process to plan, prioritize, and 

fund rehabilitation work, nearly all of which is paid for with funds 

specifically designated for rehabilitation under the wildland fire 

management appropriation. BLM’s rehabilitation program covers postfire 

work up to 3 years after a fire, and any subsequent restoration work must 

be addressed by other ongoing BLM programs, such as the wildlife and 

noxious weeds programs. 

Forest Service and 

BLM Differ in How 

They Plan Needed 

Rehabilitation and 

Restoration Work 

 4

The Forest Service uses appropriations from sources that include its national forest

system, capital improvement and maintenance, and wildland fire management accounts, as

well as the Knudsen-Vandenburg fund and the reforestation trust fund. GAO is exploring 

with the Department of Agriculture the availability of these appropriations for this purpose. 

Page 10 GAO-06-670 Wildland Fire Rehabilitation and Restoration
The Forest Service has no national guidance on how to identify, prioritize, 

and fund postfire rehabilitation and restoration work. According to a 

headquarters official, the agency has not developed guidance in part 

because appropriations specifically designated for these activities—about 

$12.8 million for fiscal year 2005 and $6.2 million for fiscal year 2006—did 

not warrant development of a manual. Instead, the agency provides its 

regions and forests with wide latitude to use varied procedures that 

accommodate their diverse ecosystems, priorities, and unique 

circumstances. 

The Forest Service allocates the appropriations designated for 

rehabilitation and restoration to its regions annually based on each 

region’s proportion of Forest Service acreage severely burned over the 

previous 5 years. The regions, in turn, allocate these funds to forests, 

usually applying a prioritization system to select among project proposals 

and funding requests submitted by forests. In addition, Forest Service 

regions and forests use appropriations available for activities such as 

reforestation and construction to help pay for related rehabilitation and 

restoration work. According to agency officials, relying on these other 

funds gives regions and forests the flexibility to determine their priorities 

while considering needs on burned lands as well as in other areas, and to 

accommodate needs that arise after unpredictable events in addition to 

fires, such as hurricanes. The Forest Service does not keep track of how 

much rehabilitation and restoration work is funded through these 

programs. 

According to agency officials, the first step in planning postfire 

rehabilitation and restoration projects is for forest and district-level staff 

to determine whether any such work is needed, by comparing postfire 

conditions with prefire and desired conditions. Typically, immediately 

after a wildland fire is contained, field officials assemble an 

interdisciplinary team made up of specialists such as foresters, wildlife 

biologists, hydrologists, botanists, and soil scientists, among others, to 

conduct an on-the-ground evaluation of the burned area. Officials use this 

evaluation along with satellite photographs of the burned area, for 

example, to assess a fire’s effects on the land and resources. Finally, 

agency officials compare these postfire conditions with historical photos

and data on prefire conditions, and with descriptions of desired conditions 

detailed in forest plans and other guidance documents. 

Agency officials told us that, in many cases, no rehabilitation or 

restoration work is needed. According to the officials, there are various 

reasons that natural recovery may be sufficient, and active rehabilitation 

Forest Service Regions and 

Forests Have Discretion to 

Plan Projects Using Varied 

Procedures 

Page 11 GAO-06-670 Wildland Fire Rehabilitation and Restoration
and restoration efforts may not be needed. For example, some fires burn 

in areas adapted to wildland fires and leave natural resources no worse off 

than before the fire, or benefit resources, for example, by stimulating 

vegetation growth or increasing denning and foraging habitat. When fires

also do no damage to infrastructure such as fences or campground 

facilities, there is usually no need for any active rehabilitation or 

restoration, according to agency officials. In other cases, agency officials 

said rehabilitation or restoration may not be needed if the burn is not 

severe; the burned area is inaccessible due to topography, legal access, or 

other issues; or the fire burned in a management area where such work is 

precluded, such as a wilderness or roadless area.

5

Often, forest officials determine that postfire rehabilitation or restoration 

is needed to repair damage to resources or infrastructure, or to prevent 

further damage from occurring after postfire rainstorms. The officials 

must then determine what projects are needed. Many Forest Service 

regions have no specific guidance for this step, and officials rely on the 

guidance available in program handbooks and legislation. For example, 

the trails management handbook includes guidance for planning projects, 

such as how to assess trail conditions against height, width, and other trail 

construction standards, depending on whether the trail is designated 

primarily for use by hikers or by pack animals as well. In addition, some 

laws include requirements or provisions that guide agency officials’ 

actions when planning projects. For example, for projects significantly 

affecting the environment, the National Environmental Policy Act requires 

agency officials to evaluate the environmental impacts of the proposed 

project and alternatives to the project in an environmental impact 

statement. Implementing regulations for the act require the agency to 

provide opportunities for the public to comment on the draft statement. In 

accordance with other laws, agency officials assess whether any cultural

resources, such as archaeological sites, will be affected by their proposed 

 5

The Wilderness Act of 1964 defines wilderness as areas of undeveloped federal land 

retaining their primeval character, without permanent improvements or human habitation. 

The act provided that wilderness areas would be designated by Congress and directed 

federal agencies to protect and manage such lands to preserve their natural condition. The

act generally prohibits road construction and the use of motorized equipment within 

wilderness areas. The Roadless Area Conservation Rule, issued by the Forest Service in 

2001 and in effect during most of the period we reviewed, generally prohibited road 

building, timber cutting, and certain other activities in inventoried roadless areas, which

are roadless areas identified in a series of analyses conducted prior to the 2001 rule. A new

roadless rule, issued in 2005, does not include the same prohibitions as the earlier rule, but 

forest plans may still restrict activities in roadless areas.

Page 12 GAO-06-670 Wildland Fire Rehabilitation and Restoration
actions, and whether any threatened or endangered species—or their 

habitat—will be affected. 

Once forest officials determine that rehabilitation or restoration work is 

needed, they have various approaches to documenting a need for the 

work, depending in part on legislative requirements, as well as the 

severity, complexity, and extent of the fire’s effects; available funding; 

anticipated level of controversy; and established regional or forest 

procedures. In some cases, forests prepare rehabilitation and restoration 

planning documents that describe and analyze all needed projects for a 

given fire, and cover time periods up to 9 years or longer. According to 

agency officials, such plans are useful when a wildland fire has 

widespread, severe, or complicated effects over a large territory and 

officials anticipate needing extensive analysis and planning efforts to 

determine project needs, costs, and time frames. Agency officials told us 

they also use comprehensive formal plans when they expect their actions

to be controversial, so that the rationale for their decision is clearly 

documented. On the other hand, sometimes agency officials do not 

prepare such planning documents because they do not have enough 

funding or they believe the funds are better spent elsewhere. They may 

instead prepare separate shorter plans in each of the program areas 

affected, or create a simple spreadsheet listing needed projects and 

estimated costs, for example. In other cases, officials do not prepare any

planning documents even if they believe rehabilitation or restoration work 

is needed, because they do not expect to receive funding to cover the 

costs of the work. 

The Pacific Northwest region, unlike other Forest Service regions, issued 

standardized guidance for its postfire rehabilitation and restoration 

activities in December 2005, to be used by forests in the region beginning

in 2006. The guidance established a uniform process to be followed by all 

forests in the region when assessing rehabilitation and restoration needs

after wildland fires or other disturbances. It is intended to be instructional 

as well as to ensure consistency among forests’ project proposals, so that 

regional officials can compare them equitably when deciding how to 

allocate funds. 

Page 13 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Generally all of the regions follow similar processes to prioritize and fund

projects, although the specifics vary widely.6

 Typically, forests submit 

project proposals and requests for postfire rehabilitation and restoration 

funding to regional officials annually.7

 In most regions, officials prioritize 

the proposed projects, often according to a predetermined set of criteria, 

and fund the highest-priority projects. Many regions include projects that 

will protect human safety among the top priorities, but beyond this 

similarity, priorities differ from region to region. For instance, the 

Southwestern region places a higher priority on repairing and replacing 

infrastructure needed for forest management, because such infrastructure 

will not recover naturally. Reforestation in the Southwestern region is 

lower priority, according to agency officials, because over time, the trees 

will grow back naturally. Also, agency officials at one forest in the region 

told us that efforts to plant seedlings in the forest’s dry climate tend to

have high failure rates especially during periods of drought. On the other 

hand, the Northern region emphasizes restoration of natural resources, 

including reforestation. Northern region officials said that in their region, 

without active reforestation efforts, less desirable species of trees would 

become dominant in some locations, perpetuating an undesirable cycle of

fires. In some regions, officials consider the forests’ priorities as well. For 

example, many forests consider boundary-marking projects among their 

lowest priorities, but for forests where logging operations are conducted 

adjacent to or on Forest Service land, such projects are important to 

protect against trespass. While most regions follow similar processes from 

year to year, some regional officials told us that in years when their 

funding allocations were relatively low—enough to fund only one or two 

projects, for example—they did not use a formal procedure to solicit and

fund project proposals because the amount of funding did not warrant 

such an effort. 

In addition to rehabilitation and restoration funds, some regions allocate 

portions of other funds to help forests pay for projects that are not funded 

with rehabilitation and restoration funds. For example, the Southwestern 

region uses 50 percent of its share of the reforestation trust fund to pay for 

 6

Because the Forest Service’s Alaska, Southern, and Eastern regions do very little, if any, 

postfire rehabilitation and restoration, they do not have formal processes for prioritizing 

and funding projects.

7

In the Northern region, rather than submitting project proposals, forests are directed to

input project needs and funding requests into the National Fire Plan Operations and

Reporting System, a national fire management database. Regional officials then query the 

database to assess total regional needs and select projects for funding. 

Page 14 GAO-06-670 Wildland Fire Rehabilitation and Restoration
needs after wildland fires in the region, and directs moneys from the roads 

and trails fund to eligible rehabilitation and restoration projects.8

 Some 

agency officials said that these funds, distributed at the discretion of 

regional officials, can be particularly important for forests with smaller 

budgets that provide little flexibility to accommodate unpredictable 

expenses. 

When funding is not available from the region, forests use funds for 

programs such as watershed management, wildlife, and road construction 

to pay for related rehabilitation and restoration projects. The budget 

process for these funds begins up to 2 years in advance of when the funds 

are actually needed, so agency officials must plan ahead, and any 

rehabilitation and restoration projects funded through this process must 

compete with normal program needs for funding. Once the budget process 

is complete, there are ways to fund rehabilitation and restoration projects 

even if they were not in the original budget request. Sometimes funded 

projects are less costly than anticipated, and the resulting savings can be

directed toward needed rehabilitation or restoration projects that were not

in the budget. Alternatively, forest officials may determine that some 

unexpected postfire rehabilitation or restoration needs are higher priority 

than certain projects already in the budget, and direct the budgeted 

projects’ funds to the rehabilitation or restoration work, deferring the 

work originally planned.

Some Forest Service officials said they rely on sources of funding other 

than appropriations specifically designated for rehabilitation and 

restoration to pay for a significant portion of needed work. For example, 

in 2003, the first year after the Biscuit fire in Oregon, Forest Service 

officials told us they spent a total of about $7 million on rehabilitation and 

restoration work; about $2 million, or 29 percent, of the total was 

rehabilitation and restoration funding, while the remaining 71 percent of 

funds came from other sources. To complete needed work, Forest Service 

officials said that in addition to appropriations specifically designated for 

rehabilitation and restoration, they use appropriations designated for 

activities such as watershed improvement, road maintenance and repair, 

 8

In 1980, Congress created the reforestation trust fund by directing a portion of tariffs on 

imported wood products to provide dedicated funding for reforestation and related 

treatments. The roads and trails fund, established in 1913, authorizes use of a portion of 

Forest Service receipts (for example from the sale of timber and grazing permits, and the 

collection of recreation fees) for the construction and maintenance of roads and trails. 

Page 15 GAO-06-670 Wildland Fire Rehabilitation and Restoration
and recreation management, as well as receipts from salvage timber sales 

and funding from other sources such as states and private parties. 

BLM has a standard process to identify, plan and fund any needed postfire 

rehabilitation projects, guided by Department of the Interior policy and a 

draft BLM handbook. The handbook prescribes specific procedures, time 

frames, and rules for identifying, planning, and funding rehabilitation 

work. BLM’s postfire recovery program, unlike the Forest Service’s 

program, is limited to rehabilitation and does not include restoration. BLM 

pays for nearly all of its postfire rehabilitation work with rehabilitation 

funds within its wildland fire management appropriation, and funding for 

such work is available for only 3 years after a fire. According to Interior 

policy, any restoration needs remaining after this time are to be 

incorporated into ongoing programs of work in resource programs such as 

the wildlife, noxious weeds, and rangeland management programs. 

The first step in planning postfire rehabilitation work is for agency 

officials in the field to assess whether any rehabilitation work is needed. 

BLM headquarters officials encourage field officials to do this immediately 

after a fire, at the same time they are assessing the need for emergency 

stabilization projects. As with the Forest Service, BLM field officials 

typically assemble an interdisciplinary team of specialists to conduct an 

on-the-ground evaluation of the burned area and compare the condition of 

the burned land to prefire and desired conditions. Generally, agency 

officials told us they rely on historical knowledge to determine prefire 

conditions, and on resource management plans and other planning 

documents, as well as professional judgment, to determine desired 

conditions. 

In addition to its resource management plans, many BLM field offices have

preapproved plans that outline the postfire work they would do if a 

wildland fire occurred on their lands. These plans, called Normal Fire 

Rehabilitation Plans, are prepared for a specified management area in 

advance of any fires, and describe typical projects that would be 

implemented under normal conditions after a fire. The plans detail the 

criteria for selecting each type of project and for determining when such 

projects are not needed, and provide guidance for developing a sitespecific rehabilitation plan following a wildland fire. The handbook 

recommends that field offices develop Normal Fire Rehabilitation Plans to

facilitate more efficient and timely approval of emergency stabilization 

and rehabilitation plans. 

BLM Follows a Standard 

Process to Plan 

Rehabilitation Projects 

Page 16 GAO-06-670 Wildland Fire Rehabilitation and Restoration
In many cases, agency officials said they decide that no active

rehabilitation activities are needed. For example, BLM officials told us that 

almost 10 million acres of land burned in Alaska between 2000 and 2004, 

but that little or no rehabilitation was needed because, for example, the 

lands were adapted to wildland fire. In other cases, agency officials said 

no rehabilitation was needed because the fire had no negative impacts and 

the site could recover naturally. When lands are adapted to wildland fire or

a fire has no negative impacts, there may be enough plants remaining that

the site can recover naturally as long as it is protected from further 

disturbances, according to the officials. 

In cases where rehabilitation work is needed, the BLM handbook requires 

agency officials to identify and estimate costs for all rehabilitation projects 

needed during the 3 years following the fire, and document these elements

in a plan. The plan is required, among other things, to describe each 

project, how it is compatible with approved land-use plans, and how it is 

related to damage or changes caused by the wildland fire. In addition, the 

plans must include a provision for monitoring the projects to determine 

whether they meet their objectives.9

 Besides requirements about the plan, 

the handbook provides guidance about which activities meet the definition

of postfire rehabilitation and qualify for rehabilitation funds. This guidance 

is particularly important, according to agency officials, because BLM only 

recently separated its emergency stabilization program and funding from 

its rehabilitation program. In addition, field staff work with BLM state 

rehabilitation coordinators to clarify any questions they have while 

preparing rehabilitation plans. The plans must be completed before the 

end of the fiscal year during which the fire occurred, which, in some 

locations, means that agency officials typically have 1 to 3 months to 

complete their plans. Also, like the Forest Service, BLM must ensure that it 

meets the requirements of relevant laws, such as the National 

Environmental Policy Act and the Endangered Species Act, among others. 

Once rehabilitation plans are complete, field officials submit them to 

agency officials in state offices and headquarters for approval. These 

officials review the plans to ensure that all proposed projects meet 

eligibility requirements for rehabilitation funding, and to assess the costeffectiveness of the proposed projects. For projects that do not meet the 

 9

In fiscal years 2004 and 2005, monitoring of both emergency stabilization and 

rehabilitation projects was paid for through the emergency stabilization program, using fire

suppression funds. In fiscal year 2006, BLM began to use rehabilitation funds to pay for 

monitoring rehabilitation projects. 

Page 17 GAO-06-670 Wildland Fire Rehabilitation and Restoration
eligibility requirements or are judged to be too costly, state and 

headquarters officials return the plan to field officials for revisions and 

resubmission. In addition, reviewing officials may return a plan if projects 

seem inappropriate or imprudent for other reasons—for example if 

officials believe a proposed seeding technique will be ineffective for the 

context in which it is proposed. 

Approval of rehabilitation plans is only the first step; the proposed 

projects must still be selected for funding. Funding for rehabilitation 

projects is allocated 1 year at a time, in a departmentwide process in 

which BLM’s projects must compete with projects from the other Interior 

agencies. At the start of each fiscal year, a team representing all of 

Interior’s land management agencies meets to allocate the department’s 

rehabilitation funding. So far, Interior has been able to fund all needed 

projects that meet eligibility requirements, according to BLM officials. As a 

result, agency officials told us they pay for nearly all rehabilitation 

projects with rehabilitation funds. In the future, if there are more funding 

requests than available funding, the interagency team plans to assess the 

projects against a set of prioritization criteria and fund only the highestpriority categories of projects. The criteria, not yet finalized by the 

interagency team, may include factors such as whether the proposed 

project incorporates partners and addresses resource objectives. 

Once projects are funded for a given year, BLM officials in the field begin

implementing them. At the end of each of the first 2 years covered by the 

plan, officials must complete an accomplishment report recording the 

projects completed during the year and their costs, as well as a monitoring 

summary for the completed projects reporting whether they were 

successful and whether additional projects are needed. For any remaining 

work, officials must submit a funding request. After the final year, BLM 

requires officials to submit a closeout report to headquarters detailing the 

projects completed, their cost, whether they were successful, and any 

lessons learned. 

Page 18 GAO-06-670 Wildland Fire Rehabilitation and Restoration
With available information, neither the agencies nor we could reliably 

determine how much needed rehabilitation and restoration work has been 

completed for Forest Service and BLM fires that occurred between 2000 

and 2004. The Forest Service does not know how much rehabilitation and 

restoration work has been completed because it does not maintain 

comprehensive data on such work. The agency only tracks rehabilitation 

and restoration work accomplished using appropriations specifically

designated for such activities under the wildland fire management 

account, and does not collect data on such work paid for with other funds. 

BLM officials reported completing most needed rehabilitation work for 

fires between 2000 and 2004, but said they do not know how much 

restoration work is needed or completed because they do not track data

on postfire restoration. We could not independently verify all of BLM’s 

rehabilitation data because these data are commingled with the agency’s 

emergency stabilization data for fires before 2004. Because the Forest 

Service had no national data and we could not verify BLM’s data, we 

administered a survey to officials from both agencies to obtain information 

about how much rehabilitation and restoration work has been completed. 

However, we determined that the information provided in the survey was 

not sufficiently reliable to report because when we assessed a sample of 

responses, we found that in a significant number of cases, supporting 

documents were either unavailable or they did not substantiate the 

answers provided in the survey. 

Forest Service officials acknowledged that they could not tell us what 

portion of the agency’s nationwide rehabilitation and restoration needs 

have been addressed because they do not track such information on a 

national level. Field staff are only required to report accomplishment 

information for rehabilitation and restoration projects funded specifically

with rehabilitation and restoration moneys, even though much of this 

work is funded through other agency programs. They are not required to 

report information about how much rehabilitation and restoration work is 

needed, although staff in some regions do so; they also are not required to

report information about rehabilitation and restoration work completed 

using other funds. Consequently, there is no centralized source of 

information about all rehabilitation and restoration needs and 

accomplishments nationwide. According to a headquarters official, the

Forest Service does not require forest officials to collect data on 

rehabilitation and restoration work because the agency does not manage 

such work under a single program; instead, the work cuts across multiple 

programs. Furthermore, the official said the Forest Service does not 

Forest Service Lacks 

Data on 

Rehabilitation and 

Restoration Work; 

BLM Lacks Data on 

Restoration Work 

Forest Service Lacks Data 

to Know Whether HighPriority Needs Are Being 

Addressed 

Page 19 GAO-06-670 Wildland Fire Rehabilitation and Restoration
maintain data on needed work because agency officials do not expect 

there to be sufficient funding to pay for all of it. 

Because the Forest Service does not have comprehensive data on 

rehabilitation and restoration needs and accomplishments nationwide, we 

administered a survey to agency officials in the field to collect this 

information, but determined that the information provided in the survey 

was not sufficiently reliable to report. The survey asked for qualitative

information about rehabilitation and restoration needs and 

accomplishments for a random sample of fires that occurred between 2000 

and 2004 and burned over 500 acres. After administering the survey, we 

requested supporting documents to validate a sample of responses. 

However, we found that a significant portion of the responses were not 

adequately supported. For example, in some cases, respondents 

mistakenly reported information about emergency stabilization projects 

rather than rehabilitation and restoration projects. In other cases, no 

documentation was provided to support survey responses, or the 

information in the documents contradicted the survey responses. 

Consequently, we determined that the data provided in the survey could 

not be reliably reported.

An interregional group of Forest Service officials reached a similar 

conclusion about the agency’s rehabilitation and restoration data when it 

attempted to collect and report related information.10 The group—tasked 

with developing an agencywide strategy for postfire recovery in 2004—

found that they could not identify the agency’s total rehabilitation and 

restoration needs and accomplishments because the agency did not 

maintain consistent, reliable data about such needs. The group noted that 

the Forest Service has a fire management database with the capacity to 

track rehabilitation and restoration needs and accomplishments, and that 

headquarters officials originally used the system to determine priorities 

and funding allocations.11 However, they said that field staff rarely enter 

data into the system because headquarters officials no longer use it this 

way, now that they delegated the task of prioritizing and funding projects 

 10U.S. Forest Service Interregional Ecosystem Management Coordination Group, “A 

Strategy for Post-Fire Recovery” (Dec. 3, 2004). 

11The National Fire Plan Operations and Reporting System is an interagency system 

designed to assist field personnel in managing and reporting accomplishments for work

conducted under the National Fire Plan, including hazardous fuels, rehabilitation, and 

restoration activities. Planned and completed activities may be entered into the system 

with funding sources. 

Page 20 GAO-06-670 Wildland Fire Rehabilitation and Restoration
to the regions. Some regions have developed their own systems to track 

regionwide data, but because the systems are not consistent, the data 

cannot accurately be combined or compared across regions. The 

interregional group recommended that if agencywide consistency is 

needed for data on rehabilitation and restoration, the Forest Service 

should consider identifying the minimum data necessary and modifying 

existing or emerging systems to incorporate such information. 

In our visits to seven national forests and telephone interviews with 

officials from all of the Forest Service regions, agency officials reported 

that varied amounts of rehabilitation and restoration work have been 

completed. For some fires, agency officials said they had completed all or 

almost all needed rehabilitation and restoration work, while for others, 

they told us that a significant amount of work remains to be done. For 

example, agency officials reported that almost all of the needed 

rehabilitation and restoration work is complete for the Diamond Point fire, 

which burned nearly 150,000 acres in the Payette National Forest in Idaho 

during the summer of 2000. According to one official, the only work that 

has not been completed for that fire is work that will not be needed until

15 or 20 years after the fire, such as clearing hiking trails when dead trees 

fall in the future. Similarly, agency officials reported completing all or 

almost all needed rehabilitation and restoration work for the 3,000-acre 

Thorn fire in the Wallowa-Whitman National Forest in 2000, and the 

18,000-acre Fridley fire in the Gallatin National Forest in 2001, among 

others. In contrast, agency officials reported that a significant portion of 

needed rehabilitation and restoration work remains for the Bitterroot fires 

of 2000, which burned about 300,000 acres, as well as for the Bullock and 

Aspen fires of 2002 and 2003, which burned a total of about 115,000 acres 

in the Coronado National Forest. For the 2002 Red Waffle fire, which 

burned about 5,000 acres in the Custer National Forest, agency officials 

told us that almost none of the needed work had been completed. These 

examples suggest that, for at least some fires, a significant portion of 

needed rehabilitation and restoration work has not been completed. 

However, without comprehensive data, neither we nor agency decision 

makers know how common this situation is across the nation. 

Furthermore, while we found that a substantial portion of needed work 

remains undone for some fires, it is unclear whether more should be done 

at this point because the Forest Service has no clear time frames for 

completing such work. Some Forest Service officials told us that, although

they had not yet completed all of the rehabilitation and restoration work 

they believed was needed, they were not concerned because they planned 

to complete the work over the course of 5 or 10 years after the fire. Few of 

Page 21 GAO-06-670 Wildland Fire Rehabilitation and Restoration
the agency officials we interviewed reported adverse effects that had 

already resulted from not completing projects. However, some officials 

expressed concern about future effects, such as compromised water 

quality and loss of forest habitat, that could result if needs were left unmet 

over the long term. 

Given constrained budgets and competing priorities, a headquarters 

official explained that the Forest Service does not expect forests to 

complete every needed rehabilitation and restoration project; instead, 

forests are expected to complete the high-priority projects. However, 

agency officials do not know whether they have addressed the highest 

priority projects nationwide, because they do not track this information, 

either. In our interviews with officials in the field, we found that regions 

have addressed their priorities to varying degrees from year to year and 

region to region. For example, in 2004, the Intermountain region was able 

to fund the top 14 of its 20 priority categories, while the Southwestern 

region was only able to fund the top 2 of its 9 priority categories using 

rehabilitation and restoration funds.12 As a result, the Southwestern region 

identified about $5.2 million in unfunded needs that year, including about 

$2.3 million in high-priority needs, according to an agency official. 

However, in fiscal year 2005, because the Southwestern region received 

about $7 million in rehabilitation and restoration funds—an increase of 

more than $6 million over the previous year—the region was able to 

address its backlog, agency officials told us. For fiscal year 2006, the

region was allocated under $1 million and expects once again to only 

address projects in its top 1 or 2 priority categories, leaving what agency

officials estimate to be millions of dollars in needs unfunded. While some 

regional officials tracked such information, others did not, and none of the 

regions routinely reported such information to headquarters.

Consequently, Forest Service officials make management and funding 

decisions without knowing, on a national scale, whether the agency is 

keeping pace with its high-priority rehabilitation and restoration needs. 

 12Because Forest Service regions independently developed prioritization criteria, the

regions have different categories, as well as a different ordering of the categories, and they 

are not directly comparable. 

Page 22 GAO-06-670 Wildland Fire Rehabilitation and Restoration
BLM officials told us that, according to agency data, most rehabilitation 

work needed for fires that occurred between 2000 and 2004 has been 

completed. The agency requires field staff to report all rehabilitation needs 

to headquarters in rehabilitation plans and budget requests. BLM officials 

in each state office assemble and review the data on budget requests and

allocations for all of the district and field offices within the state. Once

rehabilitation work is funded, agency officials said there are only a few 

factors—such as unusual weather or other unanticipated events—that 

prevent the work from being completed. Consequently, agency officials 

infer that nearly all needed work that has been funded through fiscal year 

2005 has been completed. In addition, BLM tracks nationwide data on the 

total number of acres that have been rehabilitated, and reviews the data 

for any anomalies, correcting errors when found. The agency reports this 

information to Congress each year in its budget request as well as in its 

annual report on public lands.13 Further, one agency official reported that 

BLM is currently revising its performance measures, and is planning to 

report the percentage and number of acres identified in rehabilitation 

plans as needing rehabilitation treatments that actually received the 

treatments. The agency has begun to informally collect these data in fiscal

year 2006 to prepare for reporting the information in the future. 

While BLM collects data on nationwide rehabilitation needs and 

accomplishments, we could not independently verify the data because, for 

fires before 2004, the agency’s rehabilitation and emergency stabilization 

data are commingled. In an effort to collect this information, we 

administered a survey to agency officials in the field. The survey we 

administered to BLM officials asked for qualitative information about 

rehabilitation needs and accomplishments for a random sample of BLM 

fires that occurred between 2000 and 2004 and burned over 500 acres. 

However, like the Forest Service survey, when we compared a sample of 

responses to supporting documents, we found that a significant portion of 

responses were not adequately supported. Specifically, we found that 

respondents sometimes reported information about emergency 

stabilization work rather than rehabilitation work. While we recognize that 

this could be a result of the relatively recent separation between the two 

programs in 2004, we determined that the data provided in the survey were 

not reliable.

BLM Officials Report 

Completing Most 

Rehabilitation Work, but 

Do Not Know Whether 

Restoration Needs Are 

Being Addressed 

 13Each year, BLM publishes a Public Lands Statistics report. In this report, BLM reports 

rehabilitation accomplishments combined with emergency stabilization accomplishments. 

Page 23 GAO-06-670 Wildland Fire Rehabilitation and Restoration
In our visits to three BLM field locations and interviews with BLM officials 

from four state offices, agency officials consistently reported completing 

all or almost all rehabilitation work that was needed for fires that occurred 

between 2000 and 2004. For example, in Idaho, BLM officials told us that 

all of the agency’s rehabilitation work identified as needed in the state 

during this time period has been funded, and that nearly all of the funded 

work has been completed. Several officials told us that the only 

incomplete work is that needed beyond the first 3 years after a fire, which

is defined as restoration work. Agency officials in Oregon, Utah, and 

Nevada also reported completing nearly all needed rehabilitation work, 

with few exceptions—such as work that was hindered by uncontrollable 

events like weather, or work needed beyond 3 years after a fire. 

Although BLM keeps close track of its postfire rehabilitation needs and 

accomplishments nationwide, and reports completing most of this work, 

the agency’s rehabilitation program does not fund or track any restoration 

work—that is, work needed more than 3 years after a fire. Instead, Interior

policy calls for any restoration needs to be addressed by other agency

programs, such as the wildlife, noxious weed, or rangeland management 

programs. However, BLM officials we talked with did not know whether 

these other programs were addressing postfire restoration needs. Several 

BLM officials indicated that continued monitoring beyond the 3-year 

period is important in some cases to determine the effectiveness of 

projects that have been completed. One BLM analysis of postfire projects 

from 1999 to 2003 concluded that time and funding limits on monitoring 

prevented field officials from determining the success or failure of some 

projects. In some cases for which projects were known to be only partially 

successful, agency officials said that if they could identify and address the 

issue right away—for example, by seeding native plants so that invasive 

species could not expand—they could avoid losing their original 

investment. 

Forest Service and BLM officials reported different challenges to their 

efforts to rehabilitate or restore their lands after fires. Forest Service 

officials cited a lack of funding, transfers of funding for fire suppression, 

and erratic funding levels from year to year as hindering their 

rehabilitation and restoration efforts. In addition, some Forest Service 

officials told us that controversy around certain types of postfire activities, 

market forces, and insufficient workforce made it difficult to address 

needed rehabilitation and restoration work. For BLM, headquarters and 

field officials told us that while they have completed most of their 

projects, they face challenges in achieving long-term success with some 

Forest Service and 

BLM Officials Cite 

Different Challenges 

to Rehabilitating and 

Restoring Their Lands

Page 24 GAO-06-670 Wildland Fire Rehabilitation and Restoration
projects. Many of BLM’s seeding and planting projects fail or are only 

partially successful when new plants do not become established because 

of drought, soil conditions, or planting techniques, for example. To 

address this issue, BLM officials said they are now monitoring 

rehabilitation treatments more comprehensively to learn why treatments 

are effective or not, and have begun developing standard monitoring 

protocols, a database to track project information and success rates, and a 

Web-based information-sharing network that will allow staff to share 

lessons learned. 

According to Forest Service officials, various factors related to funding 

hindered their postfire rehabilitation and restoration efforts. Specifically, 

agency officials reported that a lack of dedicated funds, the transfer of 

funds to pay for fire suppression, and the low priority of one project 

compared with others competing for the same funds prevented completion 

of some projects. Regarding the lack of dedicated funds, several officials 

we interviewed cited the downward trend in funding for postfire 

rehabilitation and restoration, and commented that funding for other 

programs had not increased to compensate. According to a regional 

official, in 2004, forests in the Northern region identified about $46 million

in rehabilitation and restoration needs attributable to the previous year’s 

fires, but the region had only about $3 million in rehabilitation and 

restoration funds to allocate to the forests. Officials in several regions told 

us that, although their projects had been approved for rehabilitation and 

restoration funding, much of the funding was transferred to pay for fire 

suppression.14 For example, after 307,000 acres burned in the Bitterroot 

National Forest in Montana, forest officials identified and received funding

for about $30 million in rehabilitation and restoration work in 2002. 

However, according to these officials, later that year most of the funding—

about $26 million—was transferred to pay for fire suppression elsewhere.

Consequently, the forest did not have enough funding to pay for all of the 

Forest Service Reports 

Funding and Other Issues 

Hinder Its Rehabilitation 

and Restoration Efforts 

 14Although the Forest Service transferred funds from various programs to help pay for fire 

suppression in fiscal years 2002 and 2003, agency officials said they did not need to do so in

fiscal year 2004 or 2005. Furthermore, in the Consolidated Appropriations Act for Fiscal 

Year 2005, Congress appropriated an additional $400 million to the Forest Service as a 

supplemental appropriation for urgent fire suppression needs—which can be carried over

from one year to the next if unspent—to help address suppression needs in unusually 

costly years and avoid the need to transfer funds from other land management accounts. 

For more information, see GAO, Wildfire Suppression: Funding Transfers Cause Project 

Cancellations and Delays, Strained Relationships, and Management Disruptions, 

GAO-04-612 (Washington, D.C.: June 2, 2004).

Page 25 GAO-06-670 Wildland Fire Rehabilitation and Restoration
work, and as of March 2006, much of it still had not been done. According 

to agency officials, the situation was made worse because they had made 

assurances to the public, which expected the Forest Service to complete 

the work they planned. 

In other cases, agency officials told us they were not able to complete 

some rehabilitation and restoration projects because they were lower 

priority than other needed work on the forest. For example, after a 

wildland fire at the Custer National Forest in Montana, officials told us 

that they needed to thin the forest to reduce the risk of a future fire 

causing severe damage. However, this fuels reduction project, located far

from any communities, was not selected for funding at the regional level, 

and it was not funded by the forest because the forest’s budget could only 

accommodate the highest-priority fuels reduction projects—where 

communities would be threatened if a wildland fire started. 

In addition, during our field visits, officials told us that erratic funding 

levels hindered their ability to address postfire rehabilitation and 

restoration needs. Specifically, agency officials said that the amount of 

rehabilitation and restoration funding headquarters allocated to the 

regions has fluctuated dramatically from year to year, making it difficult to

plan budgets. For example, the Southwestern region received about 

$600,000 in fiscal year 2004, about $6.8 million in 2005, and about $900,000 

in 2006. Based on 2004 funding levels, forests in the region did not expect

to receive substantial funding in 2005. When about $6.8 million became 

available, however, some Southwestern forests could not spend all of the 

money before the end of the year because they had not hired additional 

seasonal staff, prepared contracting or planning documents, or otherwise

established the necessary infrastructure to spend the funds and implement 

needed work. 

Agency officials reported that factors unrelated to funding also hindered 

their ability to address needed postfire rehabilitation and restoration 

work. Even if there were unlimited funding, some officials told us they 

would be limited by the size of their staff or other operational constraints, 

such as the length of their field season. For example, in 2005, the ApacheSitgreaves National Forest received about $2.4 million for needed 

rehabilitation and restoration after the Rodeo-Chediski fire. However, 

because of their limited staff and the time required to complete the 

contracting process, which they only initiated in February when they 

learned that they would receive the funding, forest officials said they were 

not able to spend all of the funds. Exacerbating the challenge, the Forest 

Service was implementing a new procurement system at the time, which 

Page 26 GAO-06-670 Wildland Fire Rehabilitation and Restoration
officials said took additional time to learn. In other cases, agency officials 

anticipated workforce and operational limitations, and accounted for them 

by developing long-range plans with annual workloads that could be 

accommodated within such limitations. However, because these plans 

covered longer time periods, planned work was still incomplete several 

years after a fire. For example, at the Coronado National Forest in 

Arizona, officials planned to spread the needed work out over a period of 

10 years or more, scheduling a feasible workload each year, given 

projected staff and infrastructure constraints. 

Forest Service officials also noted that controversy about postfire 

activities presented challenges. General dissonance about the role of 

natural recovery versus managed recovery, as well as disagreement about 

specific decisions, such as whether to use chemical herbicides and 

whether to harvest burned timber as part of restoration efforts, created 

challenges for agency officials and sometimes prevented projects from 

being completed. Forest managers use herbicides to, for example, control 

the spread of invasive weeds or eradicate vegetation that competes with 

young seedlings planted to reforest burned lands. Its use is controversial, 

however, because herbicides can be harmful to native vegetation, wildlife,

water, and soils. Harvesting burned timber is also controversial. 

Supporters say that the timber should be harvested to capture its 

economic value and remove its potential to fuel future fires, while critics 

say the burned trees should be left for wildlife habitat and to avoid any 

impacts that could be caused by harvesting operations. 

Because of the controversy surrounding these issues, agency officials said

they often invested more time and resources in developing defensible 

documents to support their decisions, which sometimes delayed project 

implementation. Also, appeals and litigation of such decisions sometimes 

caused projects to be delayed. For example, after a 2001 wildland fire at 

the Tahoe National Forest in California, the Forest Service spent a year 

preparing a plan, finalized in 2002, that proposed harvesting and selling 

burned timber both outside and within a roadless area to help finance 

needed rehabilitation work. The agency began harvesting timber outside 

the roadless area and had virtually completed doing so by July 2004. 

However, in response to a lawsuit, a federal district court issued a 

preliminary injunction in August 2004, prohibiting the Forest Service from 

harvesting timber inside the roadless area. In February 2006, the agency

settled the case, agreeing not to harvest timber in the roadless area. By 

that point—4-1/2 years after the fire—agency officials said that the value 

of the timber had declined to the point that it was no longer feasible to sell 

it. 

Page 27 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Faced with repeated decisions about harvesting burned timber, some 

Forest Service officials expressed concern that there is insufficient 

scientific evidence to support one action or another, and further noted 

that little research is being done to address the question. In a 2004 report 

entitled “Strategy for Post-Fire Recovery,” an interregional group of Forest 

Service officials noted that there is “very limited scientific information on 

long-term effects of uncharacteristically severe fires, the effectiveness of 

post-fire rehabilitation and restoration treatments, or the impacts of postfire timber harvesting.” Without such information, they concluded, “Policy 

choices are often based on ideology and emotion rather than objective 

scientific information.”15 According to one Forest Service scientist, there is 

an urgent need for more information on salvage logging—especially

information about the effects of logging operations under various 

conditions and in different geographic locations because such effects vary 

widely depending on the type and extent of logging, site conditions, and 

climatic conditions. Moreover, such research is needed to improve the 

models used by agency decision makers to predict the potential impacts of 

proposed actions such as locations and rates of erosion because, 

currently, none of them account for the effects of salvage logging on the 

postfire environment. 

The 2002 Biscuit fire in Oregon, which has been a focal point for recent 

debates about harvesting burned timber, has also drawn attention to the 

role of scientific research. After the fire, a study was published stating that 

removing dead and dying trees from the Biscuit fire area would reduce the 

risk of recurring large-scale fires in the area.16 Forest Service officials 

decided to offer 12 sales of burned timber as part of a larger recovery 

plan, one purpose of which was to reduce the risk of such fires. The sales

were controversial and were the target of legal challenges, but the timber 

was ultimately harvested in 2004 and 2005. In 2006, a study was published 

concluding that salvage logging after the Biscuit fire may have been 

counterproductive to forest recovery goals in part because, during the 

logging operations, some seedlings were destroyed.17 Release of the study 

 15U.S. Forest Service Interregional Ecosystem Management Coordination Group, “A 

Strategy for Post-Fire Recovery” (2004). 

16J. Sessions, R. Buckman, M. Newton, and J. Hamann, “The Biscuit Fire: Management 

Options for Forest Regeneration, Fire and Insect Risk Reduction and Timber Salvage” 

(unpublished report, College of Forestry, Oregon State University, Corvallis, Oregon, 2003). 

17D.C. Donato, J.B. Fontaine, J.L. Campbell, W.D. Robinson, J.B. Kauffman, and B.E. Law,

“Post-Wildfire Logging Hinders Regeneration and Increases Fire Risk,” Science, vol. 311 

(2006). 

Page 28 GAO-06-670 Wildland Fire Rehabilitation and Restoration
spurred additional controversy and media attention. In response, the 

study’s authors issued a statement saying that “the controversy over the

topic of postfire logging is indicative of how little is known about its 

effects.” In a congressional hearing on the topic, other scientists and 

researchers told members of Congress that there is not a lot of peerreviewed science on this issue, and a sustained commitment to such 

research is needed. Several bills pending before Congress contain 

provisions for research, pilot projects, and monitoring, related to the 

effects of postfire harvest.18

In addition to controversy, Forest Service officials told us that factors 

related to market forces also hinder their efforts to harvest burned timber 

after fires. For example, sometimes the trees burned in wildland fires are 

too small to be of any commercial value. Other times, a long distance to 

the nearest timber mill or difficult access to the burned timber reduces the 

cost-effectiveness of a project for the timber purchaser, especially because

burned timber loses value over time as it deteriorates. In some locations, 

the small number of nearby timber mills can limit competitive bidding. For 

example, at the Eldorado National Forest in California, the Forest Service 

offered burned timber for sale in 2005 but received no bids on most of the 

sales because the only timber company close enough to harvest the trees 

was already busy with timber from previous sales. Agency officials said 

they were concerned that if too much time passed, the timber would lose 

value and the sale would no longer be economically viable. In the fall of 

2005, they lowered the price of the timber and completed the sales. While 

agency officials acknowledged that market forces had sometimes hindered 

their ability to sell burned timber, they said this had not always been the 

case, and it was difficult to predict whether or how such forces might 

affect a sale.

To address challenges related to the controversy over salvage logging and 

in recognition of the shortage of related scientific research available, the 

Forest Service has begun to conduct such research in the past several 

years—for example, through its wildland fire research and development 

program. In addition, the Joint Fire Science Program—a partnership of six 

federal agencies, including the Forest Service—has called for and funded

some research proposals in this area. In its October 2005 announcement, 

 18For example, the Forest Emergency Recovery and Research Act, H.R. 4200, 109th Cong. 

(2005), and the National Forest Rehabilitation and Recovery Act, H.R. 3973, 109th Cong. 

(2005). 

Page 29 GAO-06-670 Wildland Fire Rehabilitation and Restoration
the program specifically sought proposals from agency and university 

scientists “that evaluate the effects and effectiveness of postfire 

management activities, including but not limited to burned area 

emergency stabilization, rehabilitation, restoration treatments, and 

postfire removal of woody material (e.g., salvage logging, biomass 

utilization).” In May 2006, the program funded several studies in this area.

For example, one Forest Service researcher received funding to study the 

effects of different salvage-logging techniques at a few sites and develop

some guidelines for use by land managers. While we commend the Forest 

Service for taking these initial steps, it will require a long-term 

commitment to the issue to accumulate research that provides sufficient 

information about the effects of salvage logging under various conditions, 

including diverse geographic locations and ecosystem types, and different

burn severities, logging techniques, soil conditions, species types, and 

other features. 

To address challenges related to funding, Forest Service officials said they 

changed the formula for allocating rehabilitation and restoration funds to 

regions in fiscal year 2006, so that funding levels would be more stable 

from year to year, but did not request additional rehabilitation and 

restoration funds from Congress because of competing program priorities. 

The new formula for allocating funds considers the amount of lands 

burned in each region over the previous 5 years, in contrast to the old 

formula, which considered only the lands burned during the prior year. 

This way, if acres burned in a region fluctuate dramatically from year to 

year, funding levels do not follow the erratic pattern. Also, the new system 

considers only severely burned acres rather than also considering the total 

number of acres burned in each region, as did the old formula. According

to agency officials, severely burned lands are more likely to need 

rehabilitation or restoration than are lands burned at moderate or low 

severity. Finally, agency officials plan to exclude wilderness acres 

beginning in fiscal year 2007 because, in many cases, wilderness lands 

need little or no active rehabilitation or restoration projects because they 

are managed to recover naturally. Agency officials said they have not 

requested more rehabilitation and restoration funding from Congress 

because, given the current environment of constrained budgets, they did 

not expect an overall increase in the agency’s budget and did not want to 

sacrifice other critical programs’ budgets. Also, the officials explained that

by receiving relatively more funding for other programs, they maintained 

more flexibility to determine how to spend the funds. This way, if postfire

rehabilitation or restoration work was the highest-priority work for a 

forest, it could direct its regular program funds to pay for it. On the other 

hand, if the forest had other higher-priority work needs, such as 

Page 30 GAO-06-670 Wildland Fire Rehabilitation and Restoration
rehabilitating lands after a hurricane or repairing roads to meet basic 

safety standards, it could fund these needs. 

Although BLM officials reported completing most of the agency’s needed 

rehabilitation projects, some officials expressed concern that these 

completed projects were not always successful. BLM officials in several 

states told us that many of their seeding and planting projects did not 

successfully establish new vegetation because the seeds did not germinate, 

or germinated but later died. For example, after a 2002 wildland fire in 

Idaho, BLM officials seeded about 4,400 acres of land, but 3 years later, 

most of the plants had not survived. Field office officials speculated that 

this was due to several factors, including drought, competition from 

invasive weeds such as cheatgrass, poor seed viability, and an insufficient 

number of seeds. In an initial attempt to understand the extent of its 

planting challenge, a BLM official reviewed rehabilitation monitoring 

reports submitted after fires occurring from 1999 through 2003, and found 

that a significant portion of the projects were described as failures or as 

only partially successful. BLM officials qualified these results, emphasizing 

that success is a subjective standard, and cited a need for improved 

standards and guidance for determining and reporting success of 

rehabilitation projects. Nevertheless, the officials acknowledged that the 

low success rate should be a cause for concern.

According to BLM officials, a variety of factors can cause planting and 

seeding projects to fail or to be only partially successful. For example, 

BLM officials we interviewed frequently singled out lack of precipitation 

as a key factor causing projects to fail. In some BLM locations, agency

officials told us that months can go by with little or no precipitation, and 

many species will not germinate without moisture. Also, there are 

technical factors that can influence a project’s degree of success. 

Sometimes seeds do not grow when initially planted because they are not 

viable or the variety selected is not appropriate for the environment in 

which they are planted. Other times, it is because the seeds are damaged 

during application, or planted too late in the season or too deep in the soil. 

Alternatively, seeds may successfully germinate, but the seedlings later die 

because, for example, there are not enough available nutrients or moisture

in the soil. The BLM official who reviewed recent rehabilitationmonitoring reports highlighted the poor success rates of sagebrushplanting projects that relied on aerial seeding, a technique to distribute 

seeds by aircraft (see fig. 3). For the aerial-seeding projects, agency

officials estimated that more than half either failed or were only partially

successful. Another study concluded that aerially seeding sagebrush 

BLM Cites Challenges to 

Ensuring Success of 

Completed Seeding and 

Planting Projects 

Page 31 GAO-06-670 Wildland Fire Rehabilitation and Restoration
following select Idaho fires was “not a reliable, effective seeding method,” 

at least in the sites studied. Sagebrush shrubs were not established on 23 

of the 35 projects in the study.19

Figure 3: A Helicopter Prepares to Aerially Seed a Burned Area after a 2005 BLM 

Fire 

When postfire seeding or planting projects are not successful, invasive

weeds can spread, crowding out native species, increasing fire frequency,

and displacing wildlife habitat. This is because after a wildland fire burns 

in a forest or rangeland, an opening is left for plants to grow, and if land 

managers do not successfully establish plants in such an opening 

immediately, invasive species—which multiply rapidly and compete 

aggressively with other plants for nutrients, water, and sunlight—often fill 

the void. Once they have arrived, invasive plants are hard to eradicate. 

Some invasive plants, such as cheatgrass, have increased the frequency of

wildland fires in western grasslands because they add to fuel loads, 

become dry early in the summer when wildland fires are most common, 

and can grow back after fires. In some locations where cheatgrass has 

Source: BLM.

 19BLM Idaho State Office, ID Technical Bulletin No. 2004-01: Establishment of Aerially 

Seeded Big Sagebrush Following Southern Idaho Wildfires (August 2004). 

Page 32 GAO-06-670 Wildland Fire Rehabilitation and Restoration
invaded ecosystems that cannot handle frequent, intense fires, native 

plants and animals have been nearly eliminated. In other cases, failure of 

seeding or planting projects can directly result in a loss of wildlife habitat.

For example, wildlife such as the sage grouse, pronghorn antelope, and 

mule deer are dependent on sagebrush for their survival, so when 

sagebrush projects fail, these animals lose their habitats. 

BLM officials are aware of and concerned about the success rate of 

postfire planting and seeding projects. In an effort to learn more about and 

improve the effectiveness of these projects, BLM has taken several 

actions. Specifically, in fiscal year 2005, BLM began requiring field staff to 

monitor all rehabilitation projects for effectiveness, and document the 

assessment in a closeout report completed at the end of the third year of 

rehabilitation activities. In fiscal years 2004 and 2005, monitoring work 

was funded through the emergency stabilization program under the 

wildland fire operations account. According to a BLM official, this was to 

ensure that funding would be available for monitoring. In fiscal year 2006, 

however, BLM began to use rehabilitation funds to pay for monitoring 

rehabilitation projects, in accordance with agency policy. In addition, in 

response to a previous GAO recommendation, BLM is working with the 

Forest Service and the United States Geological Survey to develop 

standard monitoring protocols, so that agencywide monitoring data will be

comparable and can facilitate learning. With consistent monitoring 

protocols, agency officials expect to be able to isolate some of the 

common factors that cause seeding projects to fail under various 

conditions. For example, they hope to identify seed types and planting 

techniques that work best in arid climates, with certain types of soils, or in 

competition with particular invasive weeds. In response to another GAO 

recommendation, BLM, the Forest Service, and the United States 

Geological Survey are also working together to develop a data system that 

can serve as a repository of information and lessons learned through 

implementing and monitoring rehabilitation projects.20 The agencies have 

implemented a pilot to test the data system in Nevada, and they expect to

begin development of the nationwide system in fiscal year 2008. 

 20GAO, Wildland Fires: Better Information Needed on Effectiveness of Emergency

Stabilization and Rehabilitation Treatments, GAO-03-430 (Washington, D.C.: Apr. 4,

2003).

Page 33 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Faced with millions of acres of burned federal lands, the Forest Service 

and BLM have a daunting task in identifying and addressing postfire 

rehabilitation and restoration needs. Given the enormity of the task and 

the scarcity of funding to address needed rehabilitation and restoration 

work, the Forest Service has chosen to give its regions and forests the 

discretion to decide what, if any, rehabilitation or restoration work is 

warranted, given competing priorities. While we agree that a degree of 

freedom is appropriate, so that the agency can accommodate diverse 

ecosystems and unique circumstances, the Forest Service must balance 

this freedom with its obligation to be accountable to the public and 

Congress. Without complete information on the magnitude of its 

rehabilitation and restoration needs relative to its capacity to address 

them, the Forest Service can neither make informed funding decisions nor 

show Congress and the public whether it is keeping pace with the most 

critical postfire work. Because the Forest Service already has a system to 

capture and report some data on rehabilitation and restoration 

accomplishments, expanding its use might be a straightforward way to 

provide a more complete picture of the agency’s high-priority 

rehabilitation and restoration needs relative to its accomplishments. 

For its part, BLM has acknowledged that one limitation of its rehabilitation 

program is its 3-year time constraint, which precludes any subsequent 

restoration work from being implemented under the program. In some 

cases, the time constraint also limits the agency’s ability to monitor 

rehabilitation projects long enough to ascertain whether they are 

successful, a critical shortfall given BLM’s challenge with success rates. In 

recognition of this limitation, agency officials have said—and we agree—

that the program could be improved by extending management and datatracking efforts beyond the initial 3 years to better understand whether 

long-term restoration needs are being addressed.

With millions of acres of burned lands, the Forest Service and BLM face 

significant challenges in addressing rehabilitation and restoration needs. 

While there are no quick fixes for these challenges, there are some actions 

the agencies could take to smooth the way. BLM has already taken the first 

steps toward improving its understanding about how frequently its 

rehabilitation projects fail and why. The Forest Service could improve the 

foundation from which it makes decisions about postfire work that may be

controversial, including postfire timber harvests, by conducting additional 

research in this area, so that such decisions can be informed by ample 

scientific evidence rather than the limited number of studies currently 

available. 

Conclusions 

Page 34 GAO-06-670 Wildland Fire Rehabilitation and Restoration
To help Congress and the Forest Service make more informed funding 

decisions, and to help the Forest Service better address its high-priority 

postfire rehabilitation and restoration needs, we recommend that the 

Secretary of Agriculture direct the Forest Service to take the following two 

actions: 

• Track and report to Congress all high-priority rehabilitation and 

restoration work needed and accomplished, regardless of funding source.

• Conduct additional research on the beneficial and harmful effects of 

postfire projects, including but not limited to, postfire timber harvests. 

To help ensure that long-term postfire restoration needs are addressed on 

BLM lands, we also recommend that the Secretary of the Interior direct 

BLM to address postfire restoration needs that persist more than 3 years 

after a fire by establishing a procedure to transfer any incomplete work—

including monitoring—from the rehabilitation program to other ongoing 

programs, and by tracking and reporting to Congress the status of all 

needed and completed postfire restoration work in those programs. 

We received comments on a draft of this report from the Forest Service 

and Interior. The Forest Service, in comments provided via email, 

generally agreed with our findings and recommendations. With respect to 

our recommendation to conduct additional research on the effects of postfire projects, the Forest Service noted that it will need to set priorities for 

this work. While we recognize that the Forest Service must balance 

competing priorities when allocating its resources, we continue to believe 

that such research warrants particular emphasis because of the 

heightened controversy surrounding some postfire projects, including 

postfire timber harvests, and the relative shortage of available scientific 

information in this area. The Forest Service also provided additional 

comments, which we have incorporated in this report where appropriate. 

Interior, in a written letter reproduced in appendix II, concurred with the 

report’s findings and recommendations. 

As arranged with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days from the 

report date. At that time, we will send copies to the Secretary of 

Agriculture, Secretary of the Interior, Chief of the Forest Service, and

Director of BLM. We also will make copies available to others upon 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 35 GAO-06-670 Wildland Fire Rehabilitation and Restoration
request. In addition, this report will be available at no charge on the GAO 

Web site at http://www.gao.gov. 

If you or your staff have questions about this report, 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 report. GAO staff who made major contributions to this report are 

listed in appendix III. 

Sincerely yours, 

Robin M. Nazzaro 

Director, Natural Resources and Environment 

Page 36 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Appendix I: 

Methodology 

Objectives, Scope, and 

Page 37 GAO-06-670 

Appendix I: Objectives, Scope, and 

Methodology 

The objectives of our study were to determine (1) how the Forest Service 

and the Bureau of Land Management (BLM) identify and plan postfire 

rehabilitation and restoration activities; (2) how much needed 

rehabilitation and restoration work the agencies have completed for 

wildland fires that occurred between 2000 and 2004; and (3) the challenges

the agencies face in addressing their needs, and any actions they are 

taking in response. 

To learn how the Forest Service and BLM identify and plan postfire 

rehabilitation and restoration activities, we reviewed agency documents 

and interviewed officials in headquarters, regional and state offices, and 

local units. We collected and reviewed documents on policies, procedures, 

and practices relevant to rehabilitation and restoration activities in both 

agencies. These included interagency agreements, such as one establishing

common definitions for rehabilitation and restoration, as well as 

departmental, agency headquarters, and regional or state guidance for 

nonemergency rehabilitation and restoration activities. We reviewed 

relevant portions of agency manuals and handbooks, documents detailing 

procedures for identifying needed postfire activities, as well as any 

documents describing prioritization and funding approval processes. For 

select fires, we reviewed environmental impact statements, needs 

assessments, rehabilitation plans, and other relevant planning documents. 

When we adjusted dollars for inflation, we used the gross domestic 

product (chained) price index, with 2001 as the base year. 

We also visited regions and states with large numbers of acres burned by 

wildland fire—excluding Alaska, where the agencies conducted little or no

rehabilitation or restoration work after wildland fires. For the Forest 

Service, we visited the Northern, Pacific Northwest, Pacific Southwest, 

and Southwestern regions to interview officials that manage lands in 

Arizona, California, Montana, New Mexico, North Dakota, Oregon, 

Washington, and parts of Idaho. In each of the four regions, we visited one 

or two forests and interviewed forest- and district-level staff. In addition, 

we contacted officials in Forest Service headquarters and all of the 

agency’s regions by telephone to discuss how the Forest Service identifies, 

plans, and funds postfire rehabilitation and restoration activities. For BLM, 

we visited Idaho and Oregon to interview officials in BLM’s state and field 

offices there. We also contacted, by telephone, officials in BLM’s 

headquarters and Utah and Nevada state offices to discuss how they 

identify and plan rehabilitation activities. 

Planning Rehabilitation 

and Restoration Activities 

Wildland Fire Rehabilitation and Restoration
Appendix I: Objectives, Scope, and 

Methodology 

To determine how much needed rehabilitation and restoration work the 

Forest Service and BLM have completed, we collected available national,

regional, state, and local data on project needs and accomplishments, 

interviewed Forest Service and BLM officials at all levels to ascertain their 

subjective assessments of the extent to which they had addressed postfire 

rehabilitation and restoration needs, and reviewed relevant agency 

reports. We also met with field staff to discuss proposed and completed 

projects for select fires and conducted detailed reviews of these needs and 

accomplishments using a structured data collection instrument. In 

addition, we conducted a Web-based survey of agency officials in the field,

but after checking a sample of survey responses against supporting 

documents, we determined that the information provided in the survey 

was not sufficiently reliable to report.

We selected a stratified random sample of 276 fires from the population of

BLM and Forest Service fires that burned more than 500 acres and 

occurred between 2000 and 2004. The sample was stratified by agency and 

by year (2000-2002 and 2003-2004), so that results could be generalized for 

each stratum as well as in the aggregate. To identify the universe of these 

fires, we combined two separate lists of fires obtained from the Forest 

Service and BLM. We excluded fires that occurred in Alaska because 

Forest Service officials reported little, and BLM officials reported no, 

postfire rehabilitation activity in Alaska during this period. 

Our survey asked agency officials to provide qualitative information about 

needed projects, the portion of those projects completed, factors that 

hindered their ability to complete needed projects, and any effects 

associated with not completing projects. We surveyed Forest Service 

officials about both rehabilitation and restoration projects, but we 

surveyed BLM officials only about rehabilitation projects because BLM’s 

postfire programs do not include restoration. Also, to account for BLM 

projects implemented before BLM separated its emergency stabilization 

projects from its rehabilitation projects in 2004, we requested that agency 

officials use the current interagency definitions of emergency stabilization 

and rehabilitation when providing information about all rehabilitation 

projects. 

To identify potential survey questions, we interviewed Forest Service and 

BLM officials at headquarters and in the field, and reviewed agency

documents and other reports. We took several quality assurance steps to 

minimize nonsampling errors, which can be introduced, for example, 

when respondents do not understand questions or do not have the 

information required to answer questions. Social science survey specialists 

Amount of Needed 

Rehabilitation and 

Restoration Work That Has 

Been Completed 

Survey Design 

Page 38 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Appendix I: Objectives, Scope, and 

Methodology 

designed draft questionnaires, and we conducted six pretests with agency 

officials in the field. After each pretest, we conducted an interview to 

determine (1) the extent to which respondents interpreted questions and 

response categories consistently, (2) whether respondents had the 

necessary information to answer the questions, and (3) how long it took 

individuals to complete the survey. In addition, we asked headquarters 

officials with national responsibility for postfire work in each agency to 

review our draft questionnaires and provide comments. Based on the 

results of these pretests and comments, we made multiple revisions to the 

survey. 

To determine to whom to send our survey, we contacted forest 

supervisors or natural resources directors in the Forest Service, and state

office rehabilitation coordinators in the BLM, and asked them to identify 

the field staff most knowledgeable about rehabilitation and restoration for 

each fire in our sample. In a few cases—where we lacked timely contact 

information or the person we initially contacted referred us to someone 

else—we asked agency field officials to forward the survey to the 

appropriate person. 

We administered the survey via the internet for 8 weeks between 

November 21, 2005, and January 13, 2006, and at the close of our 

administration period, we had received a total of 256 responses for an 

overall response rate of 93 percent. After the survey, we checked the

survey data and verified the data analysis programming. We also verified

select responses for 10 percent of surveys that we randomly selected from 

those that had been completed. Specifically, we verified responses to 

questions about the proportion of projects completed for a particular fire 

and the funding sources used to pay for such projects by contacting 

respondents and requesting supporting documents—such as project plans, 

accomplishment reports, and contracts—to compare their survey 

responses with information in the documents. Our verification revealed 

that a significant portion of responses were not supported by the 

documentation we received. As shown in table 1, we found that in 6 of the 

26 cases, none of the responses we checked were fully supported; in 

another 6 cases, only some of the responses were supported; and in 14 

cases, all were supported. 

Survey Administration and 

Data Verification 

Page 39 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Appendix I: Objectives, Scope, and 

Methodology 

Table 1: Verification Results for Survey Responses about Project Completion and 

Funding 

All responses

supported

Mix of supported, 

unsupported, and 

uncertain level of

support for responses

No responses

supported

Forest Service fires 5 5 3

BLM fires 9 1 3

Total fires 14 6 6

Source: GAO.

For example, sometimes responses were not supported because 

respondents had mistakenly reported information about emergency 

stabilization activities or funding, rather than rehabilitation and 

restoration activities or funding. Other times, respondents had either 

erroneously transferred the information from supporting documents to 

our survey, or had no documentation to support their answers. Overall, 

this outcome indicates that there is a degree of nonsampling error in our 

survey results that is not quantifiable, but which we determined is too 

great to ensure sufficient reliability. 

To determine what challenges the Forest Service and BLM face in 

addressing postfire rehabilitation and restoration needs, and what actions, 

if any, they are taking in response, we relied on interviews with agency 

officials and agency documents. In our interviews with agency officials at

all levels, we asked about challenges at the program level as well as the 

project level, and about actions the agencies are taking to address such 

challenges. During our visits to the field, we also observed rehabilitation 

or restoration project sites and discussed challenges officials faced in 

successfully completing those and other projects. We reviewed Forest 

Service and BLM reports describing agencywide challenges as well as 

select reports detailing challenges to addressing rehabilitation or 

restoration needs for a specific fire. To better understand some challenges 

agency officials reported, and some actions they are taking in response to 

challenges, we conducted additional interviews with agency research 

scientists, biologists, and ecologists, and reviewed relevant agency studies. 

We conducted our work from May 2005 through May 2006 in accordance 

with generally accepted government auditing standards. 

Challenges to Addressing 

Needs 

Page 40 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Appendix II: Comments from the Department Appendix II: Comments from the Department of the Interior 

of the Interior 

Page 41 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Appendix II: Comments from the Department 

of the Interior 

Page 42 GAO-06-670 Wildland Fire Rehabilitation and Restoration
Appendix III: GAO

A

 Contact and Staff 

cknowledgments 

Page 43 GAO-06-670 

Appendix III: GAO Contact and Staff 

Acknowledgments 

Robin Nazzaro, (202) 512-3841 or nazzaror@gao.gov

In addition to the contact named above, David P. Bixler, Assistant 

Director; Carl Barden; Mark Braza; Sandy Davis; Christine Feehan; Rich 

Johnson; Alison O’Neill; Anthony Padilla; and Judy Pagano made key 

contributions to this report. 

Wildland Fire Rehabilitation and Restoration

GAO Contact 

Staff 

Acknowledgments 

(360589) 
GAO’s Mission The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

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