GAO

United States General Accounting Office

Report to Congressional Requesters

November 2000 FOREST SERVICE

ROADLESS AREAS

Potential Impact of

Proposed Regulations

on Ecological

Sustainability

GAO-01-47

Page 1 GAO-01-47 Forest Service Roadless Areas

Contents

Letter 3

Appendixes Appendix I: Objectives, Scope, and Methodology 32

Appendix II: Comments From the Forest Service 35

Appendix III: GAO Contacts and Staff Acknowledgments 41

Figures Figure 1: Location of the 10 National Forests Included in

GAO’s Review 6

Figure 2: Effects of Wildfire on the Tahoe National Forest 11

Figure 3: The Interior West 13

Figure 4: Trees Damaged by Spruce Bark Beetles in the

Boise National Forest 16

Figure 5: The Geographical Boundaries of the Northwest

Forest Plan 18

Figure 6: The Geographic Boundaries of the Interior Columbia

Basin Ecosystem Management Project 20

Figure 7: The Geographical Boundaries of the Sierra Nevada

Framework 22

Figure 8: Trees Killed in Routt National Forest by 1997 Windstorm 27
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Page 3 GAO-01-47 Forest Service Roadless Areas

United States General Accounting Office

Washington, D.C. 20548 Letr

November 8, 2000

The Honorable Larry Craig

Chairman, Subcommittee on Forests

and Public Land Management

Committee on Energy and Natural Resources

United States Senate

The Honorable Helen Chenoweth-Hage

Chairman, Subcommittee on Forests

and Forest Health

Committee on Resources

House of Representatives

The U.S. Department of Agriculture’s Forest Service manages about 192

million acres of land across the 155 national forests, 20 national grasslands,

and 17 national recreation areas that make up the National Forest System.

According to the agency, “the first priority for management is the

maintenance and restoration of ecological sustainability, which is

consistent with laws guiding use and enjoyment of National Forest System

lands.” The agency has proposed making ecological sustainability its top

priority in order to provide a sustainable flow of products, services, and

other values from the national forests and grasslands.1 Depending on the

condition of the land, the Forest Service recognizes that active

management may be required to more quickly restore and maintain

ecological sustainability and enable ecological systems to sustain desirable

ecological conditions and human uses than would occur by allowing nature

to take its course. (Contributors to ecological sustainability include fire

and other ecological processes, and biological diversity—diverse animal

and plant communities.)

1

64 Fed. Reg. 54103 (Oct. 5, 1999).
Page 4 GAO-01-47 Forest Service Roadless Areas

Among the more contentious debates over how the Forest Service should

meet its mission priority of restoring and maintaining ecological

sustainability is the role of roads, particularly in areas that are now

roadless. According to the Forest Service, it intends to examine policies on

road construction, in both areas with and without roads, within the context

of ecological sustainability. On May 10, 2000, the Forest Service proposed a

roadless area conservation rule (the roadless rule).2 The environmental

documents accompanying the proposed rule discuss the following four

alternatives: (1) no action; (2) a prohibition on road construction and

reconstruction in the areas largely devoid of roads, known as “the

unroaded portion of inventoried roadless areas,” and hereafter referred to

as “roadless areas;” (3) a prohibition on road construction, reconstruction,

and timber harvest, except for stewardship purposes,3 in roadless areas;

and (4) a prohibition on road construction and reconstruction and all

timber harvest in roadless areas. The three action alternatives would

prohibit—under most circumstances—the construction and reconstruction

of roads on 43 million acres of the national forests. The agency prefers the

second action alternative, which would allow commercial timber

harvesting and forest health activities—such as removing brush to reduce

the risk of fire—but would not allow roads to be constructed to carry them

out. This is the alternative set out in the agency’s proposed rule. The agency

also proposed procedures for making future decisions about the

management of inventoried and noninventoried roadless areas. The Forest

Service has received and is considering public comments on the proposal

and intends to issue a final rule by the end of 2000.

The Forest Service has developed or is developing other major national

regulations and regional strategies and plans within the context of its focus

on ecological sustainability. These include proposed changes to the

agency’s internal procedures governing road management and

transportation, a current regional management plan for multiple national

forests in the Pacific Northwest, and proposed regional management plans

for multiple national forests in the interior Columbia River basin and the

Sierra Nevada.

2

65 Fed. Reg. 30276 (May 10, 2000).

3

Stewardship purposes include improving the vigor of remaining trees to withstand insects,

disease, and wind; reducing forest fuels through thinning; and creating desired wildlife

habitat conditions.
Page 5 GAO-01-47 Forest Service Roadless Areas

You asked us to determine if the Forest Service’s proposed roadless rule

will affect the agency’s ability to meet its mission priority of restoring and

maintaining ecological sustainability. More specifically, as agreed, this

report discusses (1) the role that roads play in both causing and mitigating

ecological problems; (2) differences between the approach to achieve

ecological sustainability under the proposed roadless rule and the

approaches of other current and proposed national and regional Forest

Service strategies and plans; and (3) the views of national forest managers

on the proposed roadless rule’s likely impact on their ability to manage

their lands and resources for ecological sustainability. We did not examine

the potential impact of the proposed rule on recreational use in the national

forests or on the production of commodities, such as timber and forage.

In performing our work, we visited 10 national forests located in various

parts of the nation that, according to Forest Service data, are experiencing

ecological problems, such as buildups of hazardous fuels, outbreaks of

insects or diseases, invasions of noxious weeds, degradation of water

quality, and/or the loss of important ecosystems and species. These forests

would likely be among those affected—both positively and negatively—by

the proposed rule. We discussed the proposed rule with forest supervisors

and/or natural resource specialists from the following 10 national forests:

the Boise and Payette in Idaho, the Routt in Colorado, the Malheur and

Umatilla in Oregon, the Uinta in Utah, the Tahoe and Shasta-Trinity in

California, the White Mountain in New Hampshire and Maine, and the

George Washington in Virginia and West Virginia. (See fig. 1.) The process

by which we selected these forests and our overall scope and methodology

are explained in more detail in appendix I.
Page 6 GAO-01-47 Forest Service Roadless Areas

Figure 1: Location of the 10 National Forests Included in GAO’s Review

Source: The Forest Service.

Results in Brief Roads can have lasting impacts on the national forests. When improperly

constructed or maintained or when constructed along streams or on

hillsides, roads can create excessive sediment that damages watersheds

and degrades aquatic habitat. Moreover, in providing access into remote

areas, roads can alter forest ecosystems by facilitating timber harvesting,

increasing fires caused by individuals, spreading noxious weeds, and

disturbing wildlife habitat. However, roads can also be used to repair

environmental damage caused by other activities. For example, decades of

Malheur NF

Umatilla NF

Payette NF

Boise NF

Uinta NF

Routt NF

White Mountain NF

George Washington NF

National forests visited by GAO

Other national forests and grasslands

Shasta-Trinity NF

Tahoe NF
Page 7 GAO-01-47 Forest Service Roadless Areas

fire suppression in the national forests have increased the risk of

uncontrollable and often catastrophic wildfires by creating unnaturally

dense forests with large amounts of accumulated hazardous fuels, such as

underbrush and dead vegetation. Roads can provide a means of restoring

these forests to what is considered a more natural state by providing access

for thinning stands of trees and mechanically removing accumulated fuels

that otherwise would have been removed by frequent but low-intensity

natural fires. When fuel levels are low enough, the Forest Service can more

safely reintroduce fire into an ecosystem, either by allowing natural fires to

burn or by setting prescribed fires. Thinning dense forests can also improve

their resistance to insects and diseases that otherwise could kill trees,

thereby adding to fuel loads.

Compared with another proposed national rule on transportation

management and with regional strategies and plans approved or proposed

by the Forest Service that also strive to restore and maintain ecological

sustainability, the proposed roadless rule takes a more restrictive approach

to decision-making concerning road construction in roadless areas. The

proposed roadless rule—which the agency asserts would supercede

relevant portions of the proposed national transportation management rule

and approved regional plans—would apply a national prohibition on road

construction in roadless areas. In contrast, the transportation rule and

regional plans would generally allow roads to be constructed, on a limited

basis, to actively manage lands and resources to restore and maintain

desired ecological conditions.

Forest Service officials on the 10 national forests included in our review

provided three general observations on the proposed rule’s likely impact on

their ability to manage their lands and resources for ecological

sustainability. First, the impact of the preferred alternative—which

prohibits only road construction and reconstruction—is likely to be

minimal. Although the reasons varied by forest, in sum, the forests

generally did not plan to construct roads in roadless areas with or without

the roadless rule. Second, although they say the need may be rare, forest

officials would like to retain some discretion to construct roads in roadless

areas on an exception basis to restore and maintain ecological

sustainability, primarily on forests in the dry interior West with large

amounts of accumulated hazardous fuels and/or large numbers of dead or

dying trees. Third, officials on all 10 forests had a far greater concern with

the proposed alternative that would prohibit not only road construction

and reconstruction but also all timber harvesting in roadless areas. This

alternative, they said, would have a far greater impact on their ability to
Page 8 GAO-01-47 Forest Service Roadless Areas

manage their lands and resources for ecological sustainability and could

place at risk not only ecosystems, watersheds, and species but also human

property and safety.

We provided a draft of this report to the Forest Service and the Department

of Agriculture for review and comment. The Forest Service provided

comments that we incorporated as appropriate. The Forest Service’s

comments and our response are provided in appendix II.

Background The Forest Service, created in 1905, is an organization whose management

is highly decentralized and whose regional foresters and forest supervisors

have considerable autonomy in interpreting and applying the agency’s

policies and directions, guided by a system of manuals and handbooks

keyed to statutes and regulations. The Forest Service has three levels of

field management—9 regional offices, 115 forest offices, and about 600

district offices. Regional offices, each managed by a regional forester,

interpret policy and provide additional direction to the 115 forest offices

that manage the 155 national forests, 20 national grasslands, and 17

national recreation areas. In turn, the forest offices, each managed by a

forest supervisor, oversee some 600 district offices, most of which are

managed by a district ranger. The forest supervisors are primarily

responsible for developing and implementing forest plans for their

respective forest(s) and grassland(s). The district rangers are primarily

responsible for implementing project-level decisions—“on-the-ground

activities,” such as harvesting timber, restoring species’ habitats, and

constructing campsites—within their respective districts.

The Forest Service began assembling an inventory of roadless areas for

further study as potential wilderness areas in the 1970s as part of a

continuing effort to establish and administer the National Wilderness

Preservation System. The agency’s criteria allowed some areas with few

roads to be inventoried as “roadless.” Subsequent reviews, conducted as

part of the agency’s forest planning process or broader-scale assessments,

have identified additional roadless areas. In all, the agency’s reviews

identified over 2,800 inventoried roadless areas—20 percent of which are

less than 5,000 acres—totaling approximately 54.3 million acres. Over the

intervening two decades, the agency has constructed roads on about 2.8

million acres in these areas, bringing the total of forest system roads to

about 386,000 miles and leaving about 51.5 million acres in the unroaded

portion of the inventoried roadless areas.
Page 9 GAO-01-47 Forest Service Roadless Areas

On October 13, 1999, President Clinton directed the Forest Service to

develop, and propose for public comment, regulations to provide

appropriate long-term protection for most or all of the roadless areas and

to determine whether such protection is warranted for any smaller roadless

areas not yet inventoried. On May 10, 2000, the Forest Service issued its

proposed alternatives, including its preferred alternative. The agency’s

preferred alternative, presented in the proposed rule, is to restrict road

construction and reconstruction but not timber harvesting. The preferred

alternative would also require land managers to consider the protection of

“roadless characteristics” when revising their forest plans.

Each of the three action alternatives would include exceptions to the

prohibition on road construction and reconstruction. The circumstances

under which the proposed rule would allow road construction or

reconstruction are: (1) to protect public health and safety in cases of an

imminent threat of flood, fire, or other catastrophic event that, without

intervention, would cause the loss of life or property; (2) to prevent

irreparable resource damage by an existing road that is deemed essential

for access, management, or public health and safety where such damage

cannot be corrected by maintenance; (3) to act in accordance with

reserved or outstanding rights or in accordance with statutes or treaties;

and (4) to take response actions under the Comprehensive Environmental

Response, Compensation, and Liability Act or to conduct a natural

resource restoration action under that act;, section 311 of the Clean Water

Act; or the Oil Pollution Act.

As defined in the proposed roadless rule, the characteristics of roadless

areas to be protected are (1) soil, water, and air; (2) sources of public

drinking water; (3) diversity of plant and animal communities; (4) habitat

for threatened, endangered, proposed, candidate, and sensitive species and

for those species that depend on large, undisturbed areas of land; (5)

primitive, semiprimitive nonmotorized, and semiprimitive motorized

classes of dispersed recreation; (6) reference landscapes for research,

study, or interpretation; (7) landscape character and scenic integrity; (8)

traditional cultural properties and sacred sites; and (9) other locally

identified unique characteristics. The preferred alternative would also

delay for 5 years a determination of whether the prohibition on road

construction and reconstruction should apply to the 8.5 million acres of

roadless areas on the Tongass National Forest in Alaska.
Page 10 GAO-01-47 Forest Service Roadless Areas

As the Forest Service develops the proposed roadless area rule, it also

faces major ecological issues. One of particular importance—as evidenced

by the burning of over 6.5 million acres of public and private land this

year—is the safe reintroduction of fire into the forests and grasslands.4

During most of the twentieth century, the Forest Service’s policy was to

suppress all fires. As a result of this and other policies, the health and

structure of certain ecosystems that depend upon fire have been adversely

affected. Fire suppression has also created unnaturally dense forests that

are more susceptible to insects and disease and to catastrophic wildfire.

Given the ecological damage that has resulted from fire suppression, as

well as the increased risks to human development from uncontrollable

wildfires, the agency’s fire and management policies are coming under

scrutiny. Methods of reducing fuel levels include (1) allowing natural fires

to burn under certain circumstances; (2) mechanically thinning trees or

removing brush; and (3) using prescribed fire—sometimes in combination

with mechanical removal—cases in which forest managers deliberately set

fires in an attempt to remove brush and small-diameter material.

4

Reducing Wildfire Threats: Funds Should Be Targeted to the Highest Risk Areas (GAO/TRCED-00-296, Sept. 13, 2000).
Page 11 GAO-01-47 Forest Service Roadless Areas

Figure 2: Effects of Wildfire on the Tahoe National Forest

Source: GAO.

Roads Can Have Both

Positive and Negative

Effects

Few human disturbances have had a more lasting legacy on the national

forests than roads. For example, forest roads constructed prior to the early

1970s along streams and on hillsides used designs that were subject to

erosion and failure. These roads have been found to cause significant

damage to watersheds and aquatic habitat by collecting, concentrating, and

directing storm runoff and the sediment that it carries into streams and

rivers. Excessive sediment suffocates developing fish eggs and buries

aquatic insects upon which fish depend for food. Changes in streamflows

and increases in water temperatures caused by roads further impair the

ability of native fish to survive and reproduce. Roads also dissect terrestrial

habitat into isolated patches, thereby interfering with the ability of certain

wildlife species to travel and reproduce.

By providing access into remote areas, roads have also facilitated certain

human activities that have resulted in significant changes to forest

ecosystems. For instance, most roads on national forests were initially

constructed to harvest timber. Past timber-harvesting practices, including

removing all of the trees from a timber-harvesting site at one time

(clearcutting) and using heavy equipment such as tractors to haul logs
Page 12 GAO-01-47 Forest Service Roadless Areas

along roads, were often not designed to protect water quality. These

practices resulted in cleared and compacted areas that exposed soil to the

erosive impact of rain and contributed sediment to streams, especially

during large storms. Large clearcut areas and the selective removal of

larger trees have also resulted in forests that differ widely from their

historic conditions. In some forests, certain species of trees have declined

by as much as 95 percent and have been replaced by other species that

have markedly changed the forests’ composition and structure. As a result,

fish and wildlife species that depend on historic conditions, including oldgrowth forests and undisturbed watersheds, have declined in distribution

and abundance. In addition, roads further push forest ecosystems away

from historic conditions by increasing fires caused by individuals,

poaching, and the spread of nonnative weeds that can out-compete and

replace native plants.

Current road construction and timber-harvesting practices on Forest

Service lands are designed to mitigate their adverse effects on ecosystems.5

Specifically, new forest roads are designed to be more stable and to reduce

the potential for failure, and road drainage systems have been improved to

reduce the amount of water and sediment delivered to streams.

Additionally, newer timber-harvesting practices are less damaging to the

soil than older practices and leave trees and large, woody debris in riparian

buffers to trap and filter sediment before it reaches streams.

Roads can also provide access for restoring ecological disturbance

processes to degraded ecosystems. Ecological disturbance processes, such

as fire and insects or disease infestation, are necessary for keeping

ecosystems healthy, but the size and intensity of these disturbances has

exceeded historical levels in places. For example, decades of fire

suppression on the national forests have increased the risk of

uncontrollable and often catastrophic wildfires by creating unnaturally

dense forests with large amounts of accumulated hazardous fuels, such as

underbrush, small trees, dead branches, and carpets of dry needles.6

Unnaturally dense forests—such as many ponderosa pine forests in the dry,

inland portion of the western United States (the interior West) (see fig. 3)—

also cause individual trees to compete for limited quantities of water and,

5

Oregon Watersheds: Many Activities Contribute to Increased Turbidity During Large Storms

(GAO/RCED-98-220, July 29, 1998).

6

Western National Forests: A Cohesive Strategy Is Needed to Address Catastrophic Wildfire

Threats (GAO/RCED-99-65, Apr. 2, 1999).
Page 13 GAO-01-47 Forest Service Roadless Areas

during drought conditions, weakened trees become susceptible to insect

infestations and diseases and die in unnaturally high numbers. Large stands

of dead trees further contribute to accumulated hazardous fuels, increasing

the risk of uncontrollable and catastrophic wildfires.

Figure 3: The Interior West

Source: The Forest Service.
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According to the Forest Service, 67 million acres on national forests across

the country are at moderate to high risk from catastrophic wildfire and

need to be treated over a 15-year period.7 Ten million of these acres are in

inventoried roadless areas.8 Damage to forested and rangeland ecosystems

caused by these fires is potentially equal to or greater than that of timber

harvesting with respect to (1) exposing soil to the erosive impact of rain

and contributing sediment to streams, especially during large storms, and

(2) resulting in forests that differ widely from their historic conditions.

Roads increase the efficiency of restoring these forests to a more natural

state—by providing access to forests to thin stands of trees and

mechanically removing accumulated fuels that otherwise would have been

removed by frequent but low-intensity natural fires—so that fire can be

safely reintroduced into an ecosystem. Roads can also (1) serve as fire

breaks when applying prescribed fire and when attempting to suppress

wildfires and (2) provide access to rehabilitate and restore burned areas. In

addition, the Forest Service estimates that approximately 24 million acres

on the national forests are at risk of excessive tree mortality from insects

or diseases—7 million of which it estimates to be in roadless areas.9

Thinning dense forests can improve their resistance to insects and diseases

that otherwise could kill trees and add to fuel loads.

7

Protecting People and Sustaining Resources in Fire-Adapter Ecosystems: A Cohesive

Strategy, Forest Service (Apr. 13, 2000).

8

Forest Service Roadless Area Conservation Draft Environmental Impact Statement (May

2000).

9

Forest Service Roadless Area Conservation Draft Environmental Impact Statement (May

2000).
Page 15 GAO-01-47 Forest Service Roadless Areas

The Approach to Road

Construction in the

Proposed Roadless

Rule Is More

Restrictive Than The

Approach in Another

Proposed National

Rule and Regional

Strategies and Plans

The proposed roadless rule is more restrictive than another proposed

national rule and regional strategies and plans recently approved or

proposed by the Forest Service. These other rules, strategies, and plans

would allow roads to be constructed, on a limited basis, to actively manage

lands and resources to restore and maintain desired ecological conditions.

Under these other situations, decisions to construct roads would have to be

supported by detailed scientific analysis.

The Proposed Roadless

Rule

The proposed roadless rule takes an approach to decision-making on road

construction in roadless areas that is different from the approaches of

other recent Forest Service proposed rules, strategies, and plans. The

proposed rule—which the agency asserts would supercede relevant

portions of existing plans and transportation management regulations—

would apply a national prohibition on road construction in roadless areas,

even if local conditions suggest that a road would help the agency to

restore and maintain desired ecological conditions. Although the proposed

rule includes several exceptions that would authorize road construction or

reconstruction in inventoried roadless areas, the exceptions would not

authorize road construction or reconstruction in inventoried roadless areas

to restore and maintain ecological sustainability. Therefore, national

forests could generally not construct a road to thin stands of trees and

mechanically remove underbrush and dead vegetation to reduce the risk of

uncontrollable and potentially catastrophic fire or to improve the forests’

resistance to insects and diseases that otherwise could kill trees and add to

fuel loads. (Fig. 4 shows a stand of trees damaged by spruce bark beetles in

the Boise National Forest.)
Page 16 GAO-01-47 Forest Service Roadless Areas

Figure 4: Trees Damaged by Spruce Bark Beetles in the Boise National Forest

Source: GAO.

The Proposed

Transportation Rule

Unlike the proposed roadless rule, another proposed rule would allow

more road construction and reconstruction in roadless areas if sciencebased analyses show benefits. In March 2000, the Forest Service proposed

changes to the agency’s internal procedures governing road management

and transportation (the transportation rule).10 The proposed transportation

rule would establish policies and procedures regarding the construction,

reconstruction, maintenance, and decommissioning of roads throughout

the National Forest System, including those in roadless areas. The

proposed transportation rule would require national forest and grassland

managers to use science-based analyses to identify the minimum road

system needed to administer, use, and protect their lands and resources.

The analyses would examine issues at various scales, be flexible, and be

driven by road issues important to both the managers and other

stakeholders. On the basis of the analyses, managers would decide which

roads to keep, maintain, and close, and where to construct new roads.

1065 Fed. Reg. 11684 (Mar. 3, 2000).
Page 17 GAO-01-47 Forest Service Roadless Areas

Under internal procedures that would implement the proposed

transportation rule, the agency would not expect that roads would be

constructed in roadless areas. However, until the relevant science-based

analysis is performed, road construction could occur in roadless areas only

if managers could show a “compelling need” for the road. Under the

procedures, “compelling need” includes restoring and protecting critical

resources. The proposed roadless rule would, if made final, supercede

these procedures.

Regional Strategies and

Plans

Several approved or proposed large-scale regional strategies and plans that

promote the management of ecosystems would also allow for the

possibility of road construction in roadless areas to restore desired

ecological conditions in limited situations, after appropriate analysis and

public participation. First, in 1994, the Secretaries of Agriculture and of the

Interior approved the Northwest Forest Plan. The plan provides direction

for the 22.3 million acres of land managed by the Forest Service or the

Department of the Interior’s Bureau of Land Management in the range of

the northern spotted owl (northern California, western Oregon, and

western Washington). (See fig. 5.)
Page 18 GAO-01-47 Forest Service Roadless Areas

Figure 5: The Geographical Boundaries of the Northwest Forest Plan

Source: The Forest Service and the Bureau of Land Management.

Critical ecological issues addressed in the plan include conserving oldgrowth forests and protecting aquatic ecosystems. Threats to those values

include human activities, such as timber harvesting and road construction,

as well as wildfire. The plan prohibits new roads in “key watersheds”

managed for at-risk anadromous fish, bull trout, and resident fish or where

Washington

Oregon

California
Page 19 GAO-01-47 Forest Service Roadless Areas

high water quality is important. However, the plan allows management

activities, including road construction, in “non-key watersheds,” including

those with inventoried roadless areas, following a watershed analysis that

focuses on collecting and compiling information within the watershed,

which is essential for making sound management decisions.

Second, the Forest Service and the Bureau of Land Management are

developing a broad-scale, ecosystem-based strategy for the approximately

63 million acres of land they administer in the interior Columbia River

basin (eastern Oregon and Washington, much of Idaho, and western

Montana). (See fig. 6.)
Page 20 GAO-01-47 Forest Service Roadless Areas

Figure 6: The Geographic Boundaries of the Interior Columbia Basin Ecosystem

Management Project

Source: The Forest Service and the Bureau of Land Management.

The agencies proposed a set of alternatives in 1997 and issued three

supplemental alternatives in March 2000. Under their preferred alternative,

science-based analyses would be used to plan and conduct restoration

activities across the basin to address long-term risks associated with

disturbance events, such as wildfire and disease. The preferred alternative

would discourage new road construction, particularly in riparian areas.

California

Nevada

Utah

Wyoming

Idaho

Washington

Oregon

Montana
Page 21 GAO-01-47 Forest Service Roadless Areas

However, the agencies stated that, although roads significantly modify

landscapes and ecological processes, they also facilitate the

accomplishment of many management objectives. The preferred

alternative calls for science-based analyses of roads at multiple geographic

scales, as appropriate, to systematically evaluate existing road system

needs and to establish priorities for road restoration activities. The

agencies expect that new roads into watersheds that currently have no or

very few roads would be rare. However, new roads into such areas could

occur following analyses that demonstrate that access is needed to prevent

or address imminent environmental damage.

Finally, in April 2000, the Forest Service proposed eight alternatives for the

Sierra Nevada Framework—including two preferred alternatives—for

managing nine national forests in the Sierra Nevada and on the Modoc

Plateau in California, the Lake Tahoe Basin Management Unit, and a

portion of the Humboldt-Toiyabe National Forest in Nevada. (See fig. 7.)

The planning process identified numerous issues to be addressed by the

alternatives, including old-growth forest ecosystems, fire and fuels, wildlife

habitat, and roads.
Page 22 GAO-01-47 Forest Service Roadless Areas

Figure 7: The Geographical Boundaries of the Sierra Nevada Framework

Source: The Forest Service.

Oregon

California

Nevada

National parks and monuments

National forest lands
Page 23 GAO-01-47 Forest Service Roadless Areas

In assessing the eight alternatives’ potential environmental impacts, the

Forest Service stated that forest roads provide access for many uses and

management activities, including research, fish and wildlife habitat

management, fire protection, and insect and disease control. Under each of

the proposed alternatives, an analysis of roads would be an integral part of

each landscape/watershed analysis. A full range of road system

management options, including new road construction, would be

considered on the basis of social and environmental effects as well as

administrative needs, such as access to wildfires. Neither of the two

preferred alternatives for the Sierra Nevada Framework would specifically

prohibit road construction in roadless areas.

National Forest

Managers Believe the

Preferred Alternative

in the Proposed

Roadless Rule Will

Likely Have Minimal

Impact on Their Ability

to Restore or Maintain

Ecological

Sustainability

Forest Service officials on the 10 national forests included in our review

provided three general observations on the proposed roadless rule’s likely

impact on their ability to manage their lands and resources for ecological

sustainability. First, the impact of the preferred alternative in the proposed

roadless rule is likely to have limited impact on these management

responsibilities. Although the reasons varied by forest, in sum, the forests

generally did not plan to construct roads in roadless areas with or without

the roadless rule. Second, the officials would like to retain some discretion

to construct roads in roadless areas on an exception basis. This was

particularly true on forests in the dry interior West with large amounts of

accumulated hazardous fuels and/or large numbers of dead or dying trees.

And, third, officials on all 10 forests cautioned that one of the alternatives

other than the preferred alternative—prohibiting not only road

construction and reconstruction but also all timber harvesting in

inventoried roadless areas—would have a far greater impact on their ability

to manage their lands and resources for ecological sustainability and could

place at risk ecosystems, watersheds, and species, as well as human

property and safety.

Most Roadless Areas Would

Remain Roadless With or

Without the Roadless Rule

Few roads have been built in roadless areas in recent years, and few were

likely to be built in the future, even before the roadless rule was proposed.

Since 1979, the Forest Service has constructed roads on about 5 percent of

the acres in roadless areas on the national forests. Current forest plans

have already placed about 20.5 million of the 51.5 million acres of roadless

area off-limits to road construction. Officials from several forests indicated

that they expected future forest plans to prohibit road construction on

additional acres even without the proposed rule or that they did not have
Page 24 GAO-01-47 Forest Service Roadless Areas

plans to build roads in the roadless areas where construction is now

allowed.

Officials on national forests included in our review identified several

specific reasons why roadless areas would likely remain roadless with or

without the rule. First, if areas inventoried in 1979 as roadless areas were

accessible and had suitable commercial timber, they would have likely

been entered previously, when the Forest Service emphasized timber

production over other uses on the national forests. However, many

roadless areas are inaccessible and/or do not have suitable commercial

timber.

Second, public values about public lands changed during the 1990s, and

concerns were raised about the management of the national forests,

making roadless areas even more controversial and, therefore, more costly

to actively manage compared with other areas on the forests. Because of

these lands’ status as roadless areas, any plan or project that required

active management in them was almost always delayed, altered, or

withdrawn. For instance, officials on the Boise National Forest in Idaho

had planned, but have not implemented for nearly a decade, the Deadwood

project—a project aimed at restoring historic ecological conditions on 10

percent of the forest’s remaining ponderosa pine ecosystem through a

combination of salvage logging, prescribed burns, and commercial

thinning. Because of potential controversy, officials on the 10 forests

believed that it was not usually worth the additional time, staff, and money

required to construct a road in a roadless area.

Third, looking to the future, even without the rule, these officials will

construct far fewer roads in roadless areas than in the past. They noted that

the Forest Service—consistent with its existing legislative framework—has

shifted its priorities away from producing timber and other commodities

toward restoring and maintaining land health and forest resources.11 In this

context, approved and proposed national rules and regional plans,

including those discussed above, make clear that constructing a new road

anywhere and for any reason on a national forest will be rare and must be

scientifically credible, legally defensible, and developed with public

participation. Moreover, although roads may facilitate management

activities to address certain ecological problems, such as hazardous fuels

11See Forest Service Priorities: Evolving Mission Favors Resource Protection Over

Production (GAO/RCED-99-166, June 17, 1999).
Page 25 GAO-01-47 Forest Service Roadless Areas

and insects and diseases, officials pointed out that these activities can

often be accomplished in roadless areas without having to construct new

roads, although sometimes at increased cost.

Forest Officials Would Like

to Retain Some Discretion

to Construct Roads in

Roadless Areas on an

Exception Basis

Even though officials on the 10 national forests included in our review

believe that they will need to construct few roads in roadless areas in the

future, some wanted to retain the discretion to construct or reconstruct

roads in roadless areas on an exception basis to help restore and maintain

ecological sustainability. Officials on three national forests in the interior

West also identified several projects that they believe may require road

construction to restore ecosystems to the ecological conditions that

existed prior to the advent of fire suppression. This restoration would

involve mechanically removing and thinning accumulated fuels; setting

prescribed fires; and allowing less severe, naturally occurring fires to

return to the ecosystem; and reducing the threat of unnaturally occurring

attacks from insects and disease. Other projects would protect human

property and safety on private lands immediately adjacent to roadless areas

that are at risk of insect infestation and subsequent wildfire.

For example, officials on the Payette National Forest in Idaho said that,

under the preferred alternative in the proposed rule, they would not

undertake projects in certain roadless areas that are designed to help

restore a healthy ponderosa pine forest. This is the ecosystem most at risk

in Idaho and on the forest as a result of decades of fire suppression,

livestock grazing, and timber harvesting. Most of the ponderosa pine forest

at risk is in roaded areas. However, significant portions in roadless areas

are also at risk. The forest has developed a forestwide plan that includes

projects in roadless areas to help restore the ponderosa pine forest to a

more natural condition. However, according to forest officials, they would

not treat at least half of the acreage of six projects because treatment

would require new road construction; helicopter logging is not

economically feasible as an alternative. These projects would combine

prescribed burns and mechanical thinning in an attempt to restore the

ponderosa forest to historic conditions.

According to officials on the Shasta-Trinity National Forest in California,

the preferred alternative would limit their ability to use mechanical

thinning and prescribed fire to reduce hazardous fuels and thus reduce the

risk of uncontrollable and potentially catastrophic wildfires in a key

watershed—the Lower McCloud River watershed. This watershed also

contains old-growth forest habitat critical to the survival of the threatened
Page 26 GAO-01-47 Forest Service Roadless Areas

northern spotted owl and other species that depend on old-growth forest.

Officials had planned to reconstruct and maintain old jeep trails to provide

short-term access for mechanical thinning. They had also planned to

maintain the trails as firebreaks for controlling prescribed fires and as

access points for suppressing potential wildfires. However, sections of the

trails are in a roadless area, and forest officials believe that the preferred

alternative in the proposed roadless rule could prevent them from

reconstructing and maintaining these trails.

In Colorado, on the Routt National Forest, forest officials had planned to

construct temporary roads into several roadless areas immediately

adjacent to private property and homes to thin dense lodgepole pine forests

that are currently at risk of insect infestation and subsequent standreplacing wildfire. Although this is a natural ecological process in

lodgepole pine forests, it is not desirable in such close proximity to

residential development on private lands. According to forest officials, the

preferred alternative in the proposed roadless rule would prevent them

from treating these areas because they could not construct even temporary

roads, and other harvesting methods are not economically feasible. These

officials also expressed concern that residential development adjacent to

or intermingled with roadless areas is increasing, making it likely that this

problem will be greater in the future.

Officials on several national forests included in our review voiced concerns

about the long-term impacts of the roadless rule. For instance, officials on

the Boise and Payette national forests said that the encroachment of fir

trees into ponderosa pine stands—a phenomenon caused by fire

suppression—will increase over time and makes the use of prescribed fire

more dangerous unless these fir trees are mechanically removed, which is

most efficiently and economically accomplished with the aid of roads.

Officials on the Routt National Forest anticipate an outbreak of spruce

beetles resulting from a catastrophic windstorm in 1997 that felled 13,000

acres of mostly spruce and fir trees in or adjacent to roadless areas on the

forest. (Fig. 8 shows an area affected by the storm, with dead trees

appearing in light gray.) They believe that the preferred alternative would

not allow them to construct the roads necessary to remove trees in

roadless areas that in the future may become infected by beetles currently

living within this deadfall. Therefore, they would be unable to protect

highly valued resources, such as scenic areas and adjacent campgrounds

and ski slopes.
Page 27 GAO-01-47 Forest Service Roadless Areas

Figure 8: Trees Killed in Routt National Forest by 1997 Windstorm

Source: GAO.

In the impact analysis that accompanied the proposed roadless rule, the

Forest Service stated that it considered exemptions to permit road

construction for fire suppression, insect and disease treatment, and forest

health management but did not consider such an alternative in detail

because “road construction is not necessary for the maintenance and

protection of roadless area characteristics.” However, the impact analysis

also acknowledges that there are situations where road construction in

roadless areas may be warranted, but the agency considered the cost

associated with not being able to do so—such as a decrease in the acreage

treated for fuel management—to be an “unavoidable adverse effect.”12

12Forest Service Roadless Area Conservation Draft Environmental Impact Statement (May

2000).
Page 28 GAO-01-47 Forest Service Roadless Areas

In elaborating on the impact analysis, Forest Service officials charged with

developing the roadless rule stated that they are aware of the concerns

raised by forest officials. They also believe that national ecological and

social values associated with keeping roadless areas roadless outweigh

local adverse impacts associated with not constructing a road in a roadless

area. Therefore, these Forest Service officials believe that national

direction on roadless areas is appropriate and that the rule should

supercede all other approved national rules and regional strategies and

plans and apply uniformly across the agency. Accordingly, the proposed

rule concludes that, with respect to roadless areas, local discretion to build

or reconstruct a road should be replaced by a national policy that would

apply to all the national forests.

One Other Alternative in the

Proposed Rule Could

Further Limit the Ability of

the National Forests to

Manage Their Lands and

Resources

Officials on all 10 forests included in our review expressed concern that

one of the other alternatives in the proposed roadless rule would have a far

greater impact on their ability to manage their lands and resources for

ecological sustainability. This alternative would prohibit not only road

construction and reconstruction but also all timber harvesting in roadless

areas. This alternative could place not only ecosystems, watersheds, and

species at risk but also human property and safety. The officials viewed this

alternative as inconsistent with both the Forest Service’s stated priority of

restoring and maintaining ecological sustainability and its goal of

protecting roadless characteristics.

In the impact analysis accompanying the proposed rule, the Forest Service

stated that it assumed that most forests in roadless areas at a moderate to

high risk from insects, disease, or catastrophic wildfire would be given a

low priority for treatment unless there was an imminent threat to public

safety, private property, water quality, or threatened and endangered

species. However, the Forest Service officials charged with developing the

impact analysis and the proposed rule told us that they recognize the

importance of providing the national forests with flexibility to manage their

lands and resources—including the use of timber harvesting—to restore

and maintain desired ecological conditions. The preferred alternative

would allow more flexibility by not placing direct restrictions on timber

harvesting.

Agency Comments and

Our Evaluation

We provided copies of a draft of this report to the Forest Service and the

U.S. Department of Agriculture for review and comment. The Forest

Service provided a number of technical comments that we incorporated as
Page 29 GAO-01-47 Forest Service Roadless Areas

appropriate. As part of its comments, the Forest Service stressed that

reducing fuel and risks from fire will not be a top priority in roadless areas.

The agency also stated that, if needed, fuel reduction work could be done in

roadless areas without constructing new roads. We agree that the agency’s

priorities are likely to be in areas with roads that are near communities. On

the other hand, in our report we cite the agency’s report—Protecting

People and Sustaining Resources in Fire-Adapted Ecosystem: A Cohesive

Strategy—as support for the statement that there is a need for treatment in

roadless areas over the next 15 years. We also cite the views of national

forest managers that such work is needed and that some of it cannot

feasibly be done without new road construction. The agency’s written

comments and our detailed response to them are found in appendix II.

We conducted our work from April 2000 through October 2000 in

accordance with generally accepted government auditing standards.

Appendix I provides information on our scope and methodology.

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

earlier, we plan no further distribution of this report until 7 days after the

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

Honorable Frank Murkowski, Chairman, and the Honorable Jeff Bingaman,

Ranking Minority Member, Senate Committee on Energy and Natural

Resources; the Honorable Don Young, Chairman, and the Honorable

George Miller, Ranking Minority Member, House Committee on Resources;

the Honorable Ron Wyden, Ranking Minority Member, Subcommittee on

Forests and Public Lands Management, Senate Committee on Energy and

Natural Resources; the Honorable Adam Smith, Ranking Minority Member,

Subcommittee on Forests and Forest Health, House Committee on

Resources; the Honorable Dan Glickman, Secretary of Agriculture; the

Honorable Mike Dombeck, Chief of the Forest Service; and other interested

parties. We will also make copies available to others on request.
Page 30 GAO-01-47 Forest Service Roadless Areas

If you or your staff have any questions about this report, please call me at

(202) 512-3841. Key contributors to this report are listed in appendix III.

Barry T. Hill

Director, Natural Resources

and Environment
Page 31 GAO-01-47 Forest Service Roadless Areas
Page 32 GAO-01-47 Forest Service Roadless Areas

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

To determine the role that roads play in both causing and mitigating

ecological problems—including catastrophic wildfire, insect infestations

and diseases, noxious weeds, degraded watersheds, loss of critical fish and

wildlife habitat, and loss of important ecosystems—we examined

documents prepared by the Forest Service, the World Wildlife Fund, the

Wilderness Society, the National Audubon Society, and the Boise Cascade

Corporation. We also interviewed resource managers with these agencies

and organizations to clarify these studies when necessary, and we

interviewed state governmental agencies in Colorado, Idaho, and Virginia.

To determine the differences between the approach to achieving ecological

sustainability taken by the proposed roadless area conservation rule and

other national and regional Forest Service strategies and plans, we

examined and analyzed the following documents: the proposed regulations

for the National Forest System road management and transportation

system; the proposed regulations for National Forest System land and

resource management planning; the Standards and Guidelines for

Management of Habitat for Late-Successional and Old-Growth Forest

Related Species Within the Range of the Northern Spotted Owl; the Interior

Columbia Basin Supplemental Draft Environmental Impact Statement; and

the Sierra Nevada Forest Plan Amendment Draft Environmental Impact

Statement. Our particular interest was in how these strategies and plans

would, or do, make decisions about building new roads in roadless areas.

We also relied on our previous reports on the Forest Service's planning

process and use of regional ecosystem management plans.

To determine the proposed roadless area conservation rule's likely impact

on the agency's ability to manage its land and resources for ecological

sustainability, we took both a local and a national approach. To assess the

potential impact of the proposed rule on local national forests, we selected

and visited 10 national forests. We did not select the forests randomly, and

they are not intended to be representative of all national forests in any way.

Indeed, we used a subjective process that was intended to select national

forests that may have significant ecological management issues within their

roadless areas. The forests we chose met the following criteria:

• had a substantial amount of their land in roadless areas (the range was

from 12 percent to 66 percent, and the average for the 10 forests was

about 30 percent);

• appeared, on the basis of national Forest Service data, to have varying

amounts of roadless areas at significant risk from either catastrophic

wildfire or insects and disease;
Appendix I

Objectives, Scope, and Methodology

Page 33 GAO-01-47 Forest Service Roadless Areas

• had other ecological management issues, such as species of concern,

watershed restoration, or invasive species; and

• were in the midst of revising their forest plans or had revised their plans

in recent years.

Our rationale for the criteria regarding the status of forest plan revisions

was that the managers of those forests would be more likely to have

accurate information on the condition of the forests and on planned

management activities. Furthermore, although the overall selection of

forests was not intended to be representative of all national forests, we did

strive for some geographic dispersion among the 10 that we selected. The

10 forests represent six of the nine Forest Service regions.

Once we selected the 10 forests, we visited each and interviewed numerous

natural resource staff, district rangers, fire management officials, and 9 of

the 10 forest supervisors. In each case, our primary line of questioning

regarded the potential impact of the proposed rule on managing the forests

to maintain and restore ecological sustainability. At each forest, we were

shown roadless areas, with an emphasis on those areas that need active

management to address a particular ecological problem. In addition to

meeting with Forest Service staff, we spoke with representatives from

nonfederal entities, including state and local governments, environmental

groups, and private timber industry. Our emphasis with these groups was,

again, to determine the potential impact of the proposed rule on the

management of ecological problems at particular national forests in

roadless areas. We did not attempt to determine the potential impact of the

proposed rule on the production of goods and services, such as timber,

forage, or recreational opportunities. Nor did we focus on the public

participation process that has been implemented by the national forests as

part of the rulemaking.

On the basis of our review of conditions and potential impacts at the 10

national forests, we determined that the most likely impact of the proposed

rule on ecological management would relate to fuel reduction and insect

and disease control. Therefore, we focused our effort to gauge the potential

national impact of the rule on those two issues. We reviewed and analyzed

information on these two issues presented in the draft environmental

impact statement that accompanied the proposed rule and in “specialist

reports” prepared by the Forest Service's roadless area project team. With

respect to the issue of fuel reduction, we also analyzed the Forest Service's

April 13, 2000, document entitled Protecting People and Sustaining

Resources in Fire-Adapted Ecosystems: A Cohesive Strategy, and the
Appendix I

Objectives, Scope, and Methodology

Page 34 GAO-01-47 Forest Service Roadless Areas

departments of Agriculture and Interior's September 8, 2000, report to the

President entitled Managing the Impact of Wildfires on Communities and

the Environment. We also relied on our previous reports and testimonies

on the issue of fuel reduction and fire management.

Our review was conducted from March 2000 through October 2000 in

accordance with generally accepted government accounting standards.
Page 35 GAO-01-47 Forest Service Roadless Areas

Appendix II

Comments From the Forest Service ApendxiI

Note: GAO’s comments

supplementing those in

the report text appear at

the end of this appendix.
Appendix II

Comments From the Forest Service

Page 36 GAO-01-47 Forest Service Roadless Areas

See comment 1.

Now on p. 9.

See comment 2.

Now on p. 14.

See comment 3.
Appendix II

Comments From the Forest Service

Page 37 GAO-01-47 Forest Service Roadless Areas

Now on p. 8.

See comment 4.

Now on pp. 14 and 28.

See comment 5.
Appendix II

Comments From the Forest Service

Page 38 GAO-01-47 Forest Service Roadless Areas

Now on p. 15.

See comment 6.

Now on p. 15.

See comment 7.

Now on p. 17.

See comment 8.
Appendix II

Comments From the Forest Service

Page 39 GAO-01-47 Forest Service Roadless Areas

The following are GAO’s comments on the Forest Service’s letter dated

October 23, 2000.

GAO’s Comments 1. We agree with this characterization but note that the cohesive fire

strategy, while not released to the public, was signed by the Chief of the

Forest Service.

2. We added the other two exemptions to the report.

3. We changed “of” to “from.” In our view, the key to the sentence is the

number of acres of national forest and inventoried roadless area that,

according to the cohesive strategy, “need to be treated.”

4. We made this change.

5. We recognize that the Forest Service has different priorities for treating

areas at risk from fire, insects, and disease and that roadless areas may

be a lower priority than areas with roads. The Forest Service cites two

documents—a report to the President from the Secretaries of

Agriculture and of the Interior and the Forest Service’s cohesive fire

strategy—that emphasize that reducing fire risk outside of roadless

areas and near communities will be a top priority. The report to the

President states, “given current funding levels and the scope of the

fuels issue, the Forest Service would do fuels reduction work for 15

years in roaded areas.” However, in the cohesive strategy, the Chief of

the Forest Service recommended that funding be substantially

increased to treat 67 million acres, including an estimated 10 million

acres of inventoried roadless area, over a 15-year period. The agency

also commented that fire hazard reduction work could be done in

roadless areas without constructing or reconstructing roads if there

were a threat to specific resources and values. We agree that such work

could be done under the proposed regulation, and that in many

situations new roads are not needed. However, national forest

managers with whom we spoke did not believe that all such work could

feasibly be done without new road construction.

6. We recognize that constructing roads would add to the cost of

mechanical treatment and prescribed fire. Nevertheless, in the view of

some forest managers, there are situations where this work is needed

but cannot feasibly be done without roads. The Forest Service will have

to weigh the potential effect of not treating these areas against the cost
Appendix II

Comments From the Forest Service

Page 40 GAO-01-47 Forest Service Roadless Areas

of treating them with a method that does not rely on roads, such as

helicopters.

7. We deleted the phrase “even on a temporary basis.”

8. We changed this section to reflect that the proposed transportation rule

procedures would apply to inventoried roadless areas until the

proposed roadless rule is made final.
Page 41 GAO-01-47 Forest Service Roadless Areas

Appendix III

GAO Contacts and Staff Acknowledgments ApendxiI

GAO Contacts Barry T. Hill (202) 512-3841

Charles S. Cotton (202) 512-3841

Acknowledgments In addition to those named above, Ronald Belak, Ross Campbell, Richard

Johnson, and Angela Sanders made key contributions to this report.

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