Wildland Fires: Better Information Needed on Effectiveness of Emergency Stabilization and Rehabilitation Treatments
Published: 2003-04-04T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Wildfires burn millions of acres annually. Most burnt land can recover naturally, but a small percentage needs short-term emergency treatment to stabilize burnt land that threatens public safety, property, or ecosystems or longer-term treatments to rehabilitate land unlikely to recover naturally. The Department of the Interior (Interior) and the Department of Agriculture's (USDA's) Forest Service--the two departments that manage most federal land--spend millions of dollars annually on such treatments. GAO was asked to (1) describe the two departments' processes for implementing their programs, (2) identify the costs and types of treatments implemented, and (3) determine whether these treatments are effective.
section_title: What GAO Found
paragraphs: Both Interior and USDA's Forest Service use multidisciplinary teams of experts, such as ecologists and soil scientists, to assess damage and potential risks burnt land poses and to develop emergency stabilization and rehabilitation plans that identify needed treatments to reduce or eliminate those risks. The two departments differ in how they manage their programs, however. Interior uses a single process to assess damage and identify treatments for short-term emergency stabilization and longer-term rehabilitation, while USDA's Forest Service uses different processes for each of these two treatment types. The two departments recognize these differences and recently agreed to work toward standardizing certain aspects of their programs, such as definitions and time frames. Following the 2000 and 2001 fires, the Forest Service obligated $192 million and Interior $118 million for 421 emergency stabilization and rehabilitation treatment plans GAO reviewed. Treatments included seeding; fencing; installing soil erosion barriers such as straw bundles, or wattles; and road or trail work. Most of Interior's land--managed by the Bureau of Land Management--consists of rangeland. Thus, the bureau primarily seeded native grasses to retain soils and forage for cattle and wildlife and fenced to prevent grazing. Forest Service land is often steeply sloped and includes watersheds used for drinking water and timber. The Forest Service primarily seeded fast-growing grasses and built soil erosion barriers for emergency stabilization, and worked on roads, trails and reforested for rehabilitation. Neither the departments nor GAO could determine whether emergency stabilization and rehabilitation treatments were achieving their intended results. The departments require that treatments be monitored, but they do not specify how and the type of data to collect or analyze for determining effectiveness. The departments have stressed the need to systematically collect and share monitoring data for treatment decisions. Yet neither has developed a national interagency system to do so. Therefore, the nature and extent of data collection, analysis, and sharing vary widely. The departments recognize that they need better information on treatment effectiveness. However, they have not yet committed to this effort.

section_title: Letter
paragraphs: Wildfires burn millions of acres  annually. Most burnt land can  recover naturally, but a small  percentage needs short-term  emergency treatment to stabilize  burnt land that threatens public  safety, property, or ecosystems or  longer-term treatments to  rehabilitate land unlikely to recover  naturally. The Department of the  Interior (Interior) and the  Department of Agriculture’s  (USDA’s) Forest Service—the two  departments that manage most  federal land—spend millions of  dollars annually on such  treatments. GAO was asked to (1)  describe the two departments’  processes for implementing their  programs, (2) identify the costs and  types of treatments implemented,  and (3) determine whether these  treatments are effective.
Both Interior and USDA’s Forest Service use multidisciplinary teams of   experts, such as ecologists and soil scientists, to assess damage and  potential risks burnt land poses and to develop emergency stabilization and  rehabilitation plans that identify needed treatments to reduce or eliminate  those risks. The two departments differ in how they manage their programs,  however. Interior uses a single process to assess damage and identify   treatments for short-term emergency stabilization and longer-term  rehabilitation, while USDA’s Forest Service uses different processes for each  of these two treatment types. The two departments recognize these  differences and recently agreed to work toward standardizing certain  aspects of their programs, such as definitions and time frames.
Following the 2000 and 2001 fires, the Forest Service obligated $192 million  and Interior $118 million for 421 emergency stabilization and rehabilitation  treatment plans GAO reviewed. Treatments included seeding; fencing;   installing soil erosion barriers such as straw bundles, or wattles; and road   or trail work. Most of Interior’s land—managed by the Bureau of Land  Management—consists of rangeland. Thus, the bureau primarily seeded  native grasses to retain soils and forage for cattle and wildlife and fenced to  prevent grazing. Forest Service land is often steeply sloped and includes  watersheds used for drinking water and timber. The Forest Service primarily  seeded fast-growing grasses and built soil erosion barriers for emergency  stabilization, and worked on roads, trails and reforested for rehabilitation.
To ensure effective emergency  stabilization and rehabilitation  treatments, GAO recommends  Interior and USDA (1) specify  procedures to be used to monitor  treatment effectiveness, including  type and extent of monitoring data  collected and methods to collect  these data, and (2) develop an  interagency system to collect,  store, and disseminate information  on monitoring results.
Neither the departments nor GAO could determine whether emergency  stabilization and rehabilitation treatments were achieving their intended  results. The departments require that treatments be monitored, but they do  not specify how and the type of data to collect or analyze for determining  effectiveness. The departments have stressed the need to systematically  collect and share monitoring data for treatment decisions. Yet neither has  developed a national interagency system to do so. Therefore, the nature and  extent of data collection, analysis, and sharing vary widely. The departments  recognize that they need better information on treatment effectiveness.  However, they have not yet committed to this effort.
Commenting on the draft report,  Interior and USDA generally agreed  they can do more to ensure that  funds for emergency stabilization  and rehabilitation are used  effectively.
The Honorable Bob Goodlatte  Chairman, Committee on Agriculture  The Honorable Gil Gutknecht  Chairman, Subcommittee on Department Operations,     Oversight, Nutrition, and Forestry  Committee on Agriculture  In 2002—the second largest fire season in the past 50 years—wildland fires  burned almost 7 million acres and destroyed timber, natural vegetation,  habitat for wildlife, homes, and commercial businesses. Wildland fire is a  natural occurrence and millions of acres burn annually. Some ecosystems  rely on such fires to maintain their health, but unnatural fuel conditions  have increased the severity and extent of some wildfires and, in some  instances, the burnt landscape that remains after a catastrophic fire can  threaten human safety, property, and the ecosystem. Rainstorms that pelt  scorched and highly erosive soils can cause rock and mud slides in  watersheds and ultimately contaminate municipal water supplies. In areas  of steep terrain, sedimentary runoff can bury homes, destroy roads, and  clog streams. Wildland fires can also create postfire environments that are  ideal for the growth of noxious or invasive weeds. If these weeds replace  native plant species, threatened or endangered animals can lose their  habitat.
When burnt lands threaten human health and safety, property, and  ecosystems, treatment measures, such as seeding, may be undertaken to  stabilize soils and mitigate these risks. According to Department of the  Interior (Interior) and U.S. Department of Agriculture’s (USDA’s) Forest  Service data, only a small percentage of the many wildland fires that occur  each year require such treatment. Specifically, of the roughly 39,000  wildfires that occurred in 2000 and 2001 on lands managed by Interior and  the Forest Service, only about 600 required treatment.
The USDA’s Forest Service and Interior’s Bureau of Indian Affairs, its  Bureau of Land Management (BLM), its Fish and Wildlife Service, and its  National Park Service are responsible for implementing programs to  manage wildland fire, including determining whether the burnt lands  require treatment. Within Interior, BLM is the largest land manager and  oversees about half of the lands the department manages. In Interior  agencies as well as in the Forest Service, local land units, such as national  forests or national parks, are responsible for treating burnt lands that are  not likely to recover on their own.
Interior and the Forest Service categorize postwildland fire treatments as  either emergency stabilization or rehabilitation. Emergency stabilization  treatments are those judged necessary to apply following a wildland fire to  stabilize a burnt area and hence, any further damage; and protect valued  resources, such as public health and safety. These actions usually are taken  within a relatively short period of time following a wildfire, such as before  the first storm event. On the other hand, rehabilitation treatments occur  when the damages are deemed sufficiently severe that treatments for  reestablishing habitat—such as planting shrubs and trees—and repairing  fire damages—such as rebuilding burnt structures—when local land units  judge them as being necessary. Interior funds emergency stabilization and  rehabilitation treatments for up to 2 full growing seasons but no more than  3 years following a wildfire. The Forest Service specifies that emergency  stabilization treatments generally be undertaken within the first 2 years  following a wildfire, while rehabilitation treatments may be initiated for up  to 3 years following a fire.
In response to the catastrophic wildland fires of 2000, Interior and USDA  developed the National Fire Plan—a multibillion-dollar effort to address  the nation’s wildland fire threats. In supporting this plan, Congress targeted  funds for treating burnt lands that were unlikely to recover naturally from  the effects of wildland fire. In fiscal years 2001 and 2002, USDA received a  total of $205 million and Interior received a total of $125 million for treating  burnt lands.
You asked us to (1) describe Interior’s and USDA’s processes for  implementing their emergency stabilization and rehabilitation programs,  (2) identify the costs and types of treatments the departments have  implemented, and (3) determine whether these treatments are effective. To  answer these questions, we, among other things, reviewed 421 plans that  the departments developed for carrying out emergency stabilization and  rehabilitation treatments on lands burned by about 590 wildland fires in  calendar years 2000 and 2001. These plans represent about 90 percent of  the plans that the departments developed for treating the wildland fires  that occurred in 2000 and 2001. The plans identify the risks posed by these  fires, the need for and type of emergency stabilization or rehabilitation  treatments, estimated costs for those treatments, and the intended  treatment results. In addition, we gathered monitoring data on up to 3,  including some of the most expensive, treatments for 18 emergency  stabilization and rehabilitation plans for fires that occurred in 2000 to  determine if and how the departments are monitoring treatments, and  whether treatments are effective. In total, the treatments we reviewed  accounted for about 30 percent of the funding approved by the  departments for treating the fires that occurred in 2000 and 2001. In  addition, we reviewed departmental studies on monitoring and treatment  effectiveness. We conducted our review from August 2001 through  February 2003 in accordance with generally accepted government auditing  standards. (See app. I for details on our scope and methodology.)
subsections: section_title: Background
paragraphs: Recent fire seasons have shown that past fire suppression policies have not  worked as effectively as was once thought. In fact, they have had major  unintended consequences, particularly on federally owned lands. For  decades, the federal wildland fire community followed a policy of  suppressing all wildland fires as soon as possible. As a result, over the  years, brush, small trees, and other vegetation accumulated that can fuel  fires and cause them to spread more rapidly. This combination of  accumulated underbrush and rapidly spreading fires heighten the potential  for fires to become catastrophic. The buildup of excessive underbrush is  not the only cause of catastrophic wildfires, however. The weather  phenomenon known as La Nina, characterized by unusually cold Pacific  ocean temperatures, changed normal weather patterns when it formed in  1998. It caused severe, long-lasting drought across much of the country,  drying out forests and rangelands. This drought is cited by some as one of  the major causes for the 2002 catastrophic wildland fires, which nearly  surpassed those of 2000.
BLM, the Fish and Wildlife Service, the National Park Service, and the  Forest Service manage about 700 million acres, or 96 percent of all federal  lands. In addition, Interior’s Bureau of Indian Affairs manages another 55  million acres. Most federal lands in the 48 contiguous United States are  located in 11 western states, many of which have seen a dramatic surge in  population over the last two decades, complicating the management of  wildland fires. New development is occurring in fire-prone areas, often  adjacent to federal lands, and creating a wildland-urban interface—an area  where structures and other human development meet or intermingle with  undeveloped wildland. This relatively new phenomenon means that more  communities and structures are threatened by wildland fire and of  potential postfire effects, including increased erosion and flooding.
Interior agencies and the Forest Service have undertaken postwildfire  measures aimed at reducing potential postfire effects for several years.  Since the early 1960s, BLM has had a program to curb damages often  associated with wildfires—soil erosion and potential changes in vegetation.  Similarly, the Forest Service has implemented postfire measures, such as  seeding, since the 1930s. According to a Forest Service analysis of such  measures implemented between 1973 and 1998 in the western United  States, more than $110 million, in total, has been spent on treating burnt  lands. Furthermore, postfire expenditures have increased substantially,  especially during the 1990s, as the number of Forest Service acres that burn  annually increased and as the Forest Service used treatments more  extensively. This finding is consistent with Interior’s analysis of emergency  stabilization fire treatments on BLM lands. Similarly, according to Fish and  Wildlife Service officials, even though it has undertaken postwildfire  measures for several years, its policy on what measures are appropriate  has evolved from measures aimed primarily at “keeping the soil in place” to  those having additional functions such as combating invasive or noxious  weeds or plants.
Responding in the aftermath of the disastrous 1994 fire season, when  several lives were lost, Interior, the Forest Service, and other federal  agencies undertook an extensive interagency review and revision of federal  fire management policies. The resulting 1995 Federal Wildland Fire Policy  and Program Review proposed a set of uniform federal policies to enhance  effective and efficient operations across administrative boundaries and  improve the agencies’ capabilities to meet challenges posed by wildland  fire conditions.
Large-scale wildfires continued to burn throughout the United States, with  severe fire seasons in 1996, 1999, and 2000. Following the 2000 wildland  fires, the administration asked USDA and Interior to recommend how best  to respond to the 2000 fires and how to reduce the impacts of such fires in  the future. The resulting report—the National Fire Plan—recommended  increased funding for several key activities, such as suppressing wildland  fires and reducing the buildup of unwanted hazardous fuels. The report  also recommended expanded efforts to restore burnt lands because some  of the fires burned with such intensity that they drastically changed  ecosystems, and, without intervention, these ecosystems would recover  slowly. The report recognized two key aspects of treatment activities:   short-term treatments to remove hazards and stabilize soils and slopes,  such as constructing dams to hold soil on slopes, and longer-term  treatments to repair or improve lands unlikely to recover naturally from  severe fire damage by, for example, reforesting desired tree species. To set  priorities, restoration was to be undertaken on burnt lands that could affect  public health and safety, as in the case of lands used as sources for  domestic water supplies—that is, municipal watersheds;  unique natural and cultural resources, such as salmon and bull trout  habitat, and burnt land susceptible to the introduction of nonnative  invasive species; and  other environmentally sensitive areas where economic hardship may  result from a lack of reinvestment in restoring damaged land, such as  land used for recreation and tourism.
To fund the National Fire Plan, Congress appropriated $2.9 billion for the  two departments’ fiscal year 2001 wildland fire needs—an increase of $1.4  billion over the departments’ prior year funding of $1.5 billion. Of the $2.9  billion appropriated in 2001, $227 million was to be used for treating burnt  lands. For fiscal year 2002 wildland fire needs, Congress appropriated $2.3  billion for the two departments and specified that $103 million was to be  used for treating burnt lands. To carry out national fire plan goals and  objectives, including those for treating burnt lands, Interior and the Forest  Service have each designated national fire plan coordinators. To achieve  more consistent and coordinated efforts in implementing the Federal  Wildland Fire Policy and the National Fire Plan, and in response to a  recommendation made by the National Academy of Public Administration,  the Secretaries of Agriculture and of the Interior established a Wildland  Fire Leadership Council in April 2002. Comprised of members of both  departments, the council is charged with, among other things, coordinating  efforts to restore ecosystem health and monitoring performance.
Within the agencies of Interior and the Forest Service, wildland fire  activities are largely carried out by local land units. Within Interior, BLM’s  local land units include district or field offices; the Fish and Wildlife  Service’s and the National Park Service’s local land units consist of  facilities, refuges, or parks; and the Bureau of Indian Affairs’ local land  units consist of agencies. The Forest Service’s local land units consist of  national forests and grasslands. BLM’s state offices oversee the local land  units, while the Bureau of Indian Affairs, Fish and Wildlife Service, National  Park Service, and Forest Service regional offices oversee local land units.
section_title: Processes Differ between the Departments for Assessing the Need to Treat Burnt Lands and Approving Treatment Plans
paragraphs: Interior and USDA have different policies and procedures to assess  whether burnt lands need to receive any short-term or longer-term  treatments following wildland fire. Interior has one overall policy and  procedure for its four land management agencies to determine the need for  both short- and longer-term treatments. USDA’s Forest Service has separate  policies and procedures for assessing the need for short-term emergency  stabilization treatments immediately following a wildland fire and for  longer-term nonemergency treatments for rehabilitating burnt lands.  Interior and the Forest Service have attempted to adopt the same policies  and procedures for treating burnt lands, even though the National Fire Plan  does not require them to do so and recently agreed to work towards  standardizing certain aspects of their programs.
subsections: section_title: Interior Has a Single Process to Identify Both Emergency Stabilization and Rehabilitation Treatments
paragraphs: Under Interior’s policy and procedure for implementing its emergency  stabilization and rehabilitation program to treat burnt lands, its agencies  are to take four key steps. The agencies are to (1) assess burnt lands to  determine whether treatments should be taken to stabilize or rehabilitate  them, (2) identify treatments when actions are considered necessary,   (3) approve and fund necessary treatments, and (4) implement treatments  once funding is available.
Local land unit managers are responsible for having burnt lands assessed to  determine whether stabilization or rehabilitation is needed. Interior  recommends that these managers start the process before a fire is  contained in order to identify any emerging issues, conduct a preliminary  risk analysis, and ensure a smooth transition from fire suppression to  emergency stabilization and rehabilitation. Local land unit managers  decide whether an intensive assessment of the burnt lands is warranted. In  most cases, these managers decide that no such assessment is needed  because they believe that the burnt lands pose no risk and that the lands  will recover on their own within a relatively short period.
If local land unit managers decide that an intensive assessment is  warranted, they assemble an interdisciplinary teams from the local land  units to assess the burnt lands and where appropriate, propose treatment.  The team’s composition varies according to the complexity of the fire and  availability of personnel with different skills and backgrounds. In general,  Interior’s interagency guidance recommends that teams comprised of staff  specializing in, for example, wildlife, ecology, rangeland, soils, and  watersheds. The guidance also suggests that managers include expertise  from cooperating agencies’ offices, especially when needed skills are not  available within the local office. The agencies can also have available state  or regional staff assist local teams. While the teams are comprised of  agency officials, they can and do consult, as needed, with other  organizations and individuals, including those from local communities.
In some instances, wildland fires may encompass multiple agencies’ lands,  result in burnt conditions that are beyond the capability of the local staff to  assess, or place many valued resources at risk. In these situations, the local  land unit manager can ask Interior to deploy one of two interagency teams  to assess large, multijurisdictional wildland fires. Interior’s national  wildland fire management office must approve any request for assistance.  These teams include specialists from each of the affected agencies and  represent a wide variety of skills. In 2000 and 2001, these multiagency  teams were deployed eight times to assess fires we included in our review.
Both local and multiagency teams evaluate whether and what kinds of  treatments are needed. They review any applicable land or resource  management plans for the affected land management units to ensure that  any recommended treatment action will be compatible with these plans.  The teams also review other available data that may help identify resources  at risk, including data on cultural resources; threatened and endangered  species; vegetation inventories, including information on invasive species;  and soil types.
Upon completing their field inspections, teams brief local land unit  managers on whether and what type of treatments may be appropriate. If  the local land unit managers decide to proceed with treatment, they direct  the team to prepare a treatment plan, which includes, among other things, a  summary of activities and costs. In developing these plans, the team must  consider the requirements of the National Environmental Policy Act and  any other relevant statutes. In general, a team requires about 2 to 3 weeks  to review the necessary land and resource management plan, data  associated with the wildland fire, and any other data that may identify  resources at risk; conduct the site inspection; and prepare the treatment  plan.
While Interior has a single process and uses the same funds and plans to  identify both emergency stabilization and rehabilitation treatments, it  recognizes that the treatments are intended for different purposes.  Emergency stabilization treatments include those to (1) stabilize and  prevent unacceptable degradation to natural or cultural resources, (2)  minimize threats to life or property, or (3) repair, replace, or construct  improvements to prevent land or resource degradation. Rehabilitation  treatments include those to repair or improve lands unlikely to recover  naturally. While Interior’s guidance indicates that plans are to identify  treatments undertaken for emergency stabilization purposes as opposed to  rehabilitation, our review of Interior’s emergency stabilization and  rehabilitation plans for calendar year 2000 and 2001 fires indicates that they  do not always make such a distinction. Interior’s guidance also states that  both emergency stabilization and rehabilitation treatments are to be  designed to be cost-effective and to meet treatment objectives.
The agencies differ in how quickly they require that treatment plans be  completed—from 5 days to 1 month. Once the treatment plan is completed,  the Interior agencies must approve it, usually within 1 to 2 weeks. The  agencies’ processes for approval vary, depending upon the cost of the  treatment. For example, BLM has delegated approval authority for plans of  less than $100,000 to its state offices, while its national office must approve  plans of $100,000 or more. In contrast, the National Park Service does not  delegate any approval authority to its local land management units; its  regional offices approve plans of less than $300,000, while its national  office approves plans of $300,000 or more. When a treatment plan and  funding is approved, the local land unit officials are generally responsible  for having the treatments specified in the plan implemented. Interior  requires that treatments be implemented within 3 years.
section_title: The Forest Service Has Different Processes to Identify Emergency Stabilization and Rehabilitation Treatments
paragraphs: The Forest Service distinguishes between short-term emergency  treatments to stabilize lands burnt by wildland fires and longer-term  rehabilitation treatments. Its process for short-term treatments is similar to  Interior’s. Under this process, local land units are responsible for  assembling interdisciplinary teams of agency officials to survey fires that  are 300 acres or larger to determine if emergency conditions exist and if so,  whether treatments are needed. Forest Service teams can also consult with  other agencies and individuals, as necessary. The Forest Service does not  have a national team to assess large, multijurisdictional fires. However,  Forest Service staff are members of Interior’s interagency teams and these  teams have assessed fires on National Forest System lands. The Forest  Service’s rehabilitation process, however, differs from Interior’s.
subsections: section_title: Emergency Stabilization
paragraphs: Under the Forest Service’s emergency stabilization process, local land units  are to undertake only those treatments necessary to alleviate emergency  conditions following wildfire. These treatments include those necessary to  protect life and property and to prevent additional damage to resources.  The Forest Service directs that treatments be undertaken only when an  analysis of risks shows that planned actions are likely to reduce risks  significantly and are cost-effective. Further, because the Forest Service  funds emergency stabilization with emergency wildland fire funding, to  qualify for funding the Forest Service requires that treatment measures  provide essential and proven protection at minimum cost. According to  Forest Service officials, because the treatments are considered as  emergency actions, the Forest Service does not complete environmental  impact statements. In keeping with the emergency status of these  treatments, the Forest Service requires that plans be developed and  approved within 10 to 13 days following total containment of the wildland  fire. Delegated approval authorities vary by Forest Service region. Certain  regions, with a history of more frequent and larger fires, have higher  approval authorities than other regions. For example, the Forest Service’s  Pacific Southwest and Pacific Northwest regions (regions 5 and 6,  respectively), which generally have most of the catastrophic wildfires,  could approve plans costing up to $200,000 in 2000, while the Southern and  Eastern regions (regions 8 and 9, respectively), where large, catastrophic  fires are rare, were delegated no approval authority. Forest Service  headquarters must approve plans exceeding regional delegated levels of  approval authority. As with the Interior agencies, once an emergency  stabilization plan is approved, the local land unit officials implement the  plan. The Forest Service generally requires that treatments be implemented  within the first year, but provides for funding to maintain or install  additional treatments the next year.
section_title: Longer-Term Rehabilitation
paragraphs: While the Forest Service’s short-term process for emergency stabilization is  similar to Interior’s, its longer-term rehabilitation process is not. According  to Forest Service officials, the agency developed a different process for  undertaking longer-term treatment on burnt lands when the National Fire  Plan was being developed and Congress was considering appropriating  additional funds to the Forest Service for restoring damaged lands. Before  the National Fire Plan, the Forest Service spent little money on  rehabilitation because it did not receive appropriations specifically for  such an effort. Once the agency realized that additional funding would be  available through the National Fire Plan, it began planning a separate  rehabilitation process. According to Forest Service officials, the agency  decided to have two separate processes because emergency treatments to  stabilize burnt lands are funded with emergency funding and must be  undertaken quickly. Further, such treatments generally do not have long- term consequences for land management, whereas rehabilitation  treatments can potentially have long-term consequences, which may  require an environmental assessment, and involve a number of different  Forest Service programs.
In October 2000, the Forest Service asked the regional foresters to identify  proposed rehabilitation projects that supported the National Fire Plan. In  accordance with that plan, the Forest Service’s national fire plan  coordinator gave primary responsibility to the regions for implementing the  rehabilitation program. The coordinator instructed the regions to focus  rehabilitation efforts on restoring watershed conditions, including  protecting basic soil, water resources, and habitat for various native  species such as plants and animals. Projects were envisioned to be those  long-term efforts to rehabilitate or improve lands unlikely to recover  naturally from wildland damage, or to repair or replace minor facilities  damaged by fire. The coordinator also stressed the need for projects to be  (1) consistent with long-term goals and approved land use plans; (2) based  on sound analyses of the projects’ potential consequences; (3) developed  cooperatively with other federal, state, or local jurisdictions when wildland  fires crossed their jurisdictional boundaries; (4) those that meet the basic  objective of protecting life, property, and unique or critical cultural and  natural resources; and (5) undertaken within the perimeter of the burned  area. Funding to the regions was allocated based on acres burned and acres  severely burned. The funding for such projects can be available for up to 3  years.
Building on these instructions, the Forest Service regions developed  different processes to identify proposed rehabilitation projects, as  illustrated by the experiences of the Northern and Intermountain regions,  respectively (regions 1 and 4) and the Southwestern Region (region 3).  Regions 1 and 4—which encompass Idaho, Montana, Nevada, North  Dakota, Utah, and portions of South Dakota and Wyoming—were most  affected by catastrophic wildland fires in 2000. The two regions jointly  developed additional criteria to use in identifying and reviewing  rehabilitation projects for fires that occurred in 2000. These criteria  included whether the proposed project would  improve or protect water quality, or restore long-term watershed   integrate several components in the project;  restore threatened or endangered species habitat;  protect public health and safety;  improve infrastructure as a necessary step in completing the project;  address noxious or invasive weeds as a component of the project;  be emphasized by the regional forester; or  have visible accomplishments within the first year.
According to region 1 and 4 officials, the regions developed these  additional criteria for reviewing their forests’ rehabilitation proposals  because Forest Service guidance was too general to assess and set  priorities for projects. These additional criteria allowed the two regions to  better compare proposals that the forests submitted.
Region 3, which encompasses Arizona and New Mexico, and which was the  next region most affected by wildland fires in 2000, used a different  approach to identify and set priorities for projects. According to the  region 3 emergency stabilization and rehabilitation program coordinator,  while Congress was considering appropriating additional funding for the  National Fire Plan, the region assembled a team to determine which fires  were catastrophic in 2000 based on the (1) value of the losses incurred as a  result of the fire, (2) capability to repair or restore the loss, and (3)  potential cost to repair or restore the loss. Given these criteria, region 3  considered as catastrophic 5 of the 18 largest fires that occurred in 2000  and eligible for rehabilitation projects.
Forest Service officials said that the agency and regions undertook similar  processes to identify rehabilitation projects in 2002. However, the Forest  Service did not distribute all of the $63 million appropriated in fiscal year  2002 because it needed some of these funds for wildfire suppression. The  agency used some of this appropriation for suppression because putting  out fires is the agency’s top priority. According to the Forest Service  national rehabilitation program coordinator, the severe wildland fires in  2002 required the Forest Service to use $84 million in rehabilitation  funding—a portion of the $63 million appropriated in fiscal year 2002 and a  portion of the $142 million appropriated in fiscal year 2001 but not yet  expended.
section_title: The Departments Are Working to Coordinate Their Processes for Administering Treatments Even Though Their Missions and Types of Land Differ
paragraphs: As noted previously, prior to receiving additional funding under the  National Fire Plan, USDA’s Forest Service largely limited its postwildland  fire treatments to emergency stabilization. However, in 1998, Interior and  USDA initiated an effort to apply a consistent approach for both emergency  stabilization and longer-term rehabilitation. This included an effort to  develop an interagency handbook that agencies in both departments could  use. This effort was undertaken, in part, in response to the 1995 Federal  Wildland Fire Policy, which recommended that agencies work toward  standardizing their policies and procedures. The Wildland Fire Leadership  Council recently addressed this effort, which was abandoned in 2002  because of differences the agencies perceived in their missions, lands, and  use of resources.
According to Interior and Forest Service officials, they had worked to  integrate their different approaches, but discontinued this effort in 2002  because they decided that integration would be too difficult. The difficulty  arose because, according to these officials, their agencies and the lands  they manage are too dissimilar to have a consistent approach for treating  burnt lands. For example, BLM’s emergency stabilization and rehabilitation  efforts focus on stabilizing soils and ensuring a diversity of animal and  plant species because its mission emphasizes sustaining its lands for  multiple uses. The National Park Service’s emergency stabilization and  rehabilitation efforts focus on naturally preserving the lands and  resources  for use by people. In contrast, the Forest Service stated that, historically, its  efforts have focused on short-term stabilization treatments that are  intended to protect life and property and prevent additional resource  damage because its mission emphasizes protecting and improving forests  and preserving watersheds. With the advent of the National Fire Plan,  however, the Forest Service enlarged this focus to consider not only  watersheds but also longer-term treatments to improve lands unlikely to  recover naturally by, for example, planting trees or monitoring for and  treating noxious plants or weeds. Because of this emphasis and the funding  specifically authorized for rehabilitation, the Forest Service established a  separate process for these longer-term efforts. The following illustrates the  extent of the difference between Interior and the Forest Service: Interior  uses the same process, staff, and funds to implement its emergency  stabilization and rehabilitation program because, according to Interior  officials, it is easier to do so. The Forest Service uses different processes,  staff, and funds to implement its emergency stabilization program and its  rehabilitation program because emergency stabilization has existed for  about 25 years while it considers rehabilitation as an expanded mission  based on the National Fire Plan appropriations language. The difference  in how the two departments fund emergency stabilization and  rehabilitation treatments resulted in the Office of Management and Budget  directing the Department of the Interior to identify nonemergency funding  options for its nonemergency treatments by March 2003.
Interior and Forest Service officials acknowledged that the Federal  Wildland Fire Policy encourages federal agencies to standardize processes  and procedures and said that their respective departments are working  together to better coordinate their programs. Even though the Fire Policy  and the National Fire Plan do not require that the departments have the  same processes for their respective programs or that they be fully  integrated, the Wildland Fire Leadership Council addressed differences in  the departments’ emergency stabilization and rehabilitation programs. In  January 2003, the council decided that both departments should have  standard and uniform definitions, time frames, and funding mechanisms for  efforts they take under their respective programs. According to the Forest  Service’s national emergency stabilization program coordinator, the  council’s decision will result in the two departments resuming their efforts  to develop and adopt the same interagency handbook for carrying out their  emergency stabilization and rehabilitation programs.
section_title: Rehabilitation Plans Vary Widely in Cost and in the Number and Types of Treatments
paragraphs: Following the calendar years 2000 and 2001 fires, Interior and USDA’s  Forest Service approved 421 plans for stabilization and rehabilitation  treatments for an estimated total of more than $310 million. Nearly all of  the plans and costs were to treat fires that occurred in western states.  Within Interior, BLM accounted for the most plans—210 out of 266—and  approved the bulk of Interior’s funds—$88 million out of $118 million. The  Forest Service accounted for the next largest number of plans—155—and  approved $192 million—$53 million for short-term emergency stabilization  and $139 million for longer-term rehabilitation. While the two departments  implemented the same types of treatments on their lands following  wildland fire, such as seeding, the frequency with which they relied on  these treatments varied, primarily because of the types of lands they  manage.
subsections: section_title: Emergency Stabilization and Rehabilitation Plans Were Concentrated in Western States and the Cost of Treatment Varied
paragraphs: As shown in table 1 for both Interior and the Forest Service, most  emergency stabilization and rehabilitation treatments occurred in western  states. Treatments occurred there primarily because much of the lands  Interior and the Forest Service manage are in these states. Furthermore,  during the summers of 2000 and 2001, states in the intermountain west  were especially hard hit by drought and persistently dry conditions, which  gave rise to two of the worst wildfire seasons in the past 50 years.
As table 1 shows, Montana and Idaho received more than 50 percent of the  stabilization and rehabilitation funding for the 2000 and 2001 fires.  Montana, which received the largest allocation, proposed to use almost half  of its funds for longer-term rehabilitation treatments in the Bitterroot  National Forest.
According to the estimates provided in the stabilization and rehabilitation  plans, the costs to treat wildfires varied widely. About 56 percent ($174.3  million) of the estimated $310 million was associated with only 18 of the  421 plans. Most of the plans (87 percent) estimated that treatment costs  would be under $1 million and the majority of those were less than  $100,000. Table 2 shows the number and percentage of plans that fall within  various cost estimate ranges and the total estimated costs and percentage  within these ranges.
The cost of individual emergency stabilization and rehabilitation  treatments ranged from about $2,000 to about $42 million. Cost differences  occurred primarily because of the number and type of treatments included  in the plan and the number of acres to be treated. This is illustrated in the  following examples:   The most costly plan involved longer-term rehabilitation for the  Bitterroot National Forest in Montana. In this plan, the Forest Service  regional office included 5 different but almost simultaneous fires that  engulfed about 185,000 acres in 2000. This plan includes planting trees,  roadwork—including cleaning drainage structures, restoring road  surfacing, and taking roads out of service—and removing dead and  dying timber. The entire proposed cost of the plan is about $42 million,  which, according to Forest Service officials, would be spent over a  period of several years.
One of the least costly plans—for the Lower Rio Grande Valley National  Wildlife Refuge in southern Texas—proposed spending only about  $2,500. While the fire was relatively small and only grew to about 10  acres, the tract was in an urban area, surrounded by many homes and  farms. Given the fire’s location and the unique climate, geology,  vegetation, and wildlife of the site, the Fish and Wildlife Service  proposed to revegetate 5 of the burnt acres with native brush.
section_title: Interior’s Bureau of Land Management Used the Most Treatments, Primarily for Restoring Forage Used for Grazing and Wildlife Habitat
paragraphs: Interior’s 4 agencies approved 266 plans, costing about $118.5 million. Of  the four agencies, BLM approved the largest number of plans and had the  largest share of total costs. Table 3 provides information on the number  and cost of plans approved by Interior’s agencies in 2000 and 2001.
Most of the funds Interior approved were used for seeding and fencing,  primarily because most of the fires occurred on rangelands BLM manages  in Idaho, Nevada, and Utah. About $67.2 million, or 70 percent, of the $96.1  million were for these two treatments. Table 4 provides data on the  treatments Interior used most frequently and the cost of these treatments.
Of the four Interior agencies, BLM accounted for the largest share of  treatment costs and included some type of seeding as a treatment in about  190, or 90 percent, of its 210 plans. Similarly, BLM accounted for about $50  million of the $57.5 million that Interior approved for seeding. Much of the  lands managed by BLM consist of rangelands that produce forage for wild  and domestic animals, such as cattle and deer, as well as many other forms  of wildlife; its lands include grasslands and deserts—both arid and  semiarid land. Seeding was done to prevent soil erosion and to restore  forage used by cattle, mule deer, or elk; habitat used by other species such  as sage grouse; or reduce the potential for the invasion of undesirable or  noxious plants or weeds. According to BLM officials, the method used to  seed—whether by air or by drilling—depends primarily on the terrain, soil,  and seed or seed mixture used. This is illustrated by the following  examples:  Aerial seeding. One of the largest seeding treatments occurred to  aerially seed about 40,000 acres in Nevada burned by the Twin Peaks  Fire in 2000, at a cost of $5.4 million. For seeding the entire burnt area  with a native seed mixture of wheat grasses, sagebrush, and wildrye, the  local office decided that aerially seeding would be the most appropriate  method. The seeded area was hilly to mountainous and because of this,  the use of a helicopter or fixed-wing aircraft was proposed to spread  seed across the burnt area. The seeding was intended to reduce the  invasion and establishment of undesirable or invasive species of  vegetation, particularly noxious weeds. In addition, the seeding—if  successful—would provide mule deer and livestock with critical forage.
Drilling. According to BLM officials, BLM frequently uses rangeland  drills to seed. For example, following the Flat Top, Coffee Point, and Tin  Cup wildfires, which burned about 117,000 acres of the Big Desert in  Idaho, BLM approved $1.5 million to drill and aerially seed the burnt  acreage. For seeding a mixture of wheatgrass, ricegrass, needlegrass,  wildrye, and rice hulls, the local office decided to use a rangeland drill  because the terrain was relatively flat and could be easily drilled.  According to BLM, if BLM had not seeded, the lack of remaining seed  could have impaired the land’s recovery and, in the long term, reduced  species diversity and degraded habitat conditions for all wildlife species  that used the Big Desert. Figure 1 depicts BLM seeding with a rangeland  drill.
Interior agencies also frequently repaired or installed fencing following  wildland fire, primarily to protect burnt rangelands from cattle grazing to  allow for regeneration. Under Interior policy, BLM can exclude burnt lands  from grazing that are recovering from wildfire for a minimum of 2 years. Of  Interior’s 266 plans, 171 included fencing at a cost of $9.7 million. Most of  this cost—about $8.1 million—was for fencing on BLM lands. This is  illustrated by the following examples:  After the West Mona Fire burned more than 22,500 acres in Utah, BLM  approved a $1.7 million plan, which included about $241,000 to remove  about 28 miles of fencing that was destroyed by the fire, construct 34  miles of new protective fence, repair 11 miles of existing fence, and  install 6 cattleguards. The new fencing was to be installed after the area  was seeded. The fencing was to protect the burnt and seeded areas from  livestock grazing for 2 years.
After the Abert Fire burned 10,000 acres in Oregon, BLM approved a  $61,000 plan that included about $10,500 for fencing. Much of the burnt  acreage, before the fire, consisted mainly of sagebrush and native bunch  grasses. BLM concluded that the majority of the burnt area retained  sufficient native seeds and plant material in the soil for it to recover  naturally. However, to help ensure natural vegetative recovery, BLM  concluded that the burnt area needed to be protected from livestock  grazing for at least 2 years.
Figure 2 shows BLM grazing lands that were burnt and will require new  fencing to exclude cattle.
Reforestation, while not frequently used, was fairly costly. Reforestation  was used in 24 of the 266 plans, for a cost of $6.6 million, or an average of  about $275,000 per treatment. The only other treatment that was  comparable in cost was seeding, which averaged about $248,000 per  treatment. Reforestation was generally approved for funding to control the  spread of invasive species or to reduce wind and water erosion. For  example, the Fish and Wildlife Service developed a $181,500 plan to treat  the Ash Meadows National Wildlife Refuge in Nevada following a fire that  burned about 658 acres. The assessment team recommended that staff  from the local land unit collect seeds from mesquite and ash trees, contract  with nurseries to grow seedlings, and plant seedlings and cuttings primarily  to control the spread of invasive species and reduce erosion.
In addition, the Bureau of Indian Affairs used reforestation to replace  commercial timber trees that were lost as a result of wildfires. Beginning in  1998, the Bureau of Indian Affairs began to allow a limited amount of this  treatment to help ensure that Indian forest land continued to be perpetually  productive—a management objective established by the National Indian  Forest Resources Management Act. According to bureau officials,  catastrophic wildland fires can destroy viable seed necessary for regrowth  and the additional funding provided by the National Fire Plan allowed the  bureau to better meet reforestation needs after such wildfires. For  example, following the Clear Creek Divide Fire in 2000 on the Salish and  Kootenai Indian Reservation, the bureau approved $2 million to collect  ponderosa and lodgepole pine and western larch tree seeds on the  reservation, grow 2.5 million seedlings, and plant them on about 8,000  acres.
In conjunction with seeding and fencing, Interior agencies frequently  included monitoring burnt areas to see if noxious or invasive plants or  weeds had regenerated or moved into the area and treating them as  necessary. Of Interior’s 266 plans, 166, or more than 60 percent, included  monitoring and/or treating noxious or invasive plants or weeds as a  treatment, for a total cost of $6.9 million. BLM accounted for most of these  treatments. According to BLM officials, noxious or invasive weeds,  particularly cheatgrass, are one of the factors that has caused an increase  in the number and size of wildland fires. Such noxious or invasive weeds,  which grow vigorously in the early spring, can crowd out native grasses  and, during the arid summer months, can dry and provide excessive fine  fuels for wildland fires to spread over large expanses of land. Because fire  does not destroy some noxious or invasive plant seeds, the plants can  resprout and grow with even greater vigor following a wildland fire.  According to BLM officials, many local land units had completed the  necessary environmental assessments to use selected herbicides on  specified noxious or invasive weeds on its lands. As a result, the local land  units could include noxious or invasive weed treatments in their  emergency stabilization and rehabilitation plans. Figure 3 shows dried,  flammable noxious or invasive weeds prone to wildfire.
Interior agencies also included cultural resource surveys in many plans and  treatments for known artifacts damaged or threatened by wildfire. Over  half of the plans included cultural resource surveys, for a total of $5.2  million. Although cultural surveys are not treatments, but activities, they  were included as treatment costs. According to BLM, which conducted  many of these surveys, it routinely conducts cultural surveys before  conducting ground-disturbing activities that have the potential to affect  sites or objects that could be or are eligible for the National Register of  Historic Places. When BLM anticipated any ground-disturbing treatment,  such as rangeland drill seeding or installing new fencing, it included  cultural resource surveys.
section_title: Most Forest Service Funds Were Used for Rehabilitation
paragraphs: Most of the funds the Forest Service approved for emergency stabilization  or rehabilitation were for longer-term rehabilitation. Of the $192 million  that the Forest Service approved, $139 million was for longer-term  rehabilitation while $53 million was for short-term emergency stabilization.  As noted previously, the Forest Service did not use all of its fiscal year 2002  appropriation of $63 million on longer-term rehabilitation because it  needed to spend some of these funds on suppressing wildfires.
Table 5 provides information on treatments and their costs in the Forest  Service’s 113 emergency stabilization plans and its 42 rehabilitation plans.
According to Forest Service officials, for short-term emergency  stabilization, the agency relies on treatments that are intended to reduce  soil erosion in watersheds that have the greatest potential to create further  damage to people, property, or other valued resources if the agency does  not act before the first major storm event after a wildfire. For example,  some watersheds are used as sources of drinking water supplies for  municipalities. Because much of its lands are steeply sloped, the agency  relies on check dams, straw wattles (tubes of straw wrapped in netting),  and other similar structures, such as logs, to retain soil, as well as seeding  with fast-growing grasses. In contrast, for longer-term rehabilitation, the  agency repairs resource damage caused by the fire through treatments,  such as road or trail work to reduce erosion in other watersheds,  reforestation to replace timber growth, and monitoring for or treating  noxious or invasive weeds.
As shown in table 5, for stabilization treatments, the agency approved  about 31.5 percent of its 2001 and 2002 funds for erosion treatments such  as building check dams with rocks, logs, or straw, which are then placed in  stream beds or in steeply sloped channels on hillsides in order to slow  runoff from storm events and help prevent soil erosion. This runoff can  consist of water, soil, rocks, branches, and trees. To trap sediment, the  Forest Service uses felled logs or log terraces placed perpendicular to  sloped hillsides. It may specify the use of straw wattles placed  perpendicular to slopes to trap sedimentation when the number of logs is  insufficient to trap erosion effectively. Straw mulch or branches cut from  trees may also be placed on slopes to retard soil erosion. For example,  following the Trail Creek Fire, which burned about 32,000 acres on the  Boise National Forest in Idaho, the Forest Service approved an emergency  stabilization plan that included about $3 million for straw wattles, $344,000  for cutting down burnt trees and positioning them along slopes, $203,000  for mulch, and $203,000 for straw bales and other soil erosion control  structures. The Forest Service plan included multiple soil erosion  treatments because the property at risk from soil erosion included homes,  community centers, and businesses. Figures 4 and 5 show slope  stabilization treatments on Forest Service lands, including straw wattles  and mulch.
As table 5 also shows, the Forest Service used more than 25 percent of both  its stabilization and rehabilitation funds for road and trail treatments  because, according to Forest Service officials, it has an extensive network  of roads and trails on its forests that required treatment after the 2000 and  2001 fires. Road work includes installing and enlarging culverts so that  additional runoff anticipated from burnt lands can pass under roadways,  and regrading roads so that storm runoff will be less likely to erode road  surfaces. Similarly, trail work includes regrading or repairing trails to  reduce erosion and protect public safety. If the roads or trails pose a public  health or safety risk, and if the treatments need to be implemented before a  major storm event occurs, then short-term stabilization funds are used. In  contrast, if the roads or trails do not pose a health or safety concern, then  the Forest Service uses longer-term rehabilitation funds. For example,  following the Bitterroot Complex of five fires or fire complexes that burned  about 185,000 Forest Service acres, the Forest Service recommended about  $4 million in emergency road and trail treatments, to prevent damage by  debris torrents and runoff. Treatments included installing larger culverts,  cleaning ditches and culverts, recontouring roads, and repairing trails. If  these treatments were not taken, the Forest Service anticipated that (1)  fish habitat could be degraded and (2) private residences, a recreational  development, and an irrigation system that were downstream from the  burnt area could be harmed. In contrast, the rehabilitation plan included  about $11 million for road and trail treatments. This funding is for  roadwork along 400 miles of roads within the areas that burned with  moderate to high intensity. Because vegetation no longer existed to  stabilize road surfaces and slopes, the Forest Service stated it needed to  perform work to reduce erosion from them. Similarly, 150 miles of trail  were located in intensely burnt areas, which rendered some trails unsafe.  Figure 6 shows a culvert installed to handle anticipated increased storm  runoff.
Seeding was another widely used stabilization treatment. This treatment  accounted for more than 25 percent of the stabilization costs for 2000 and  2001 fires. Seeding was generally used to reduce erosion and thereby better  protect watersheds. Forest Service plans included treatments such as  seeding with fast-growing grasses—such as barley and winter wheat—that  would be more likely to grow quickly or would be less likely to compete  with the longer-term recovery of natural vegetation. For example, the  Forest Service approved about $7 million for the Cerro Grande Fire for  seeding to help stabilize soils. The assessment team concluded that natural  regrowth of vegetation would be too slow to prevent significant runoff and  soil erosion. It recommended grass seeding with annual ryegrass, barley,  mountain brome, and slender wheatgrass, to quickly restore vegetation and  reduce soil erosion, protect soil productivity, and reduce runoff.
Reforestation treatments were almost entirely done as a longer-term  rehabilitation treatment and accounted for about 25 percent of the  rehabilitation costs for the 2000 and 2001 wildfires. The Forest Service uses  reforestation treatments sparingly and restricts their use as a stabilization  treatment because (1) replanting commercial species burned by wildfire is  viewed as the responsibility of the forest management program, as opposed  to an emergency measure to be funded by the wildland fire program, and  (2) planting trees does not meet the emergency stabilization objective of  preventing additional damage to resources. Rather, replanting trees is  generally considered as repairing resource damage caused by wildfire and  therefore not a large part of the rehabilitation program. In keeping with its  interpretation of the need to restrict emergency stabilization treatments as  those necessary to prevent additional resource damage, the Forest Service  generally restricts the use of reforestation to no more than $25,000 per  treatment. However, once it received funding under the National Fire Plan  for longer-term rehabilitation, the Forest Service used this funding to  develop reforestation proposals for 21 national forests burned by wildland  fire.
Similarly, the percentage of funding the Forest Service used for noxious or  invasive weed monitoring or treatment varied depending on whether the  treatment was for emergency stabilization or rehabilitation. According to  Forest Service officials, noxious or invasive weed monitoring or treatment  is not generally viewed as an emergency treatment. For example, the  Forest Service proposed spending $1.3 million for noxious or invasive  weed monitoring or treatment as an emergency stabilization measure;  however, it proposed spending $25.1 million for such monitoring and  treatment as a rehabilitation measure. Similarly, in its rehabilitation plan  for the Salmon Challis National Forest in Idaho, the Forest Service  proposed spending $9.5 million on noxious or invasive weed treatments  because of known infestations of noxious weeds where several fires  occurred in 2000. The weeds were expected to spread rapidly through the  burnt areas, especially where fire suppression activities, such as  bulldozing, exposed bare soils. The Forest Service also proposed to  conduct a National Environmental Policy Act analysis for treating noxious  or invasive weeds in another portion of the forest that had also been burnt  in 2000 and which had not yet had an environmental analysis completed for  such a treatment.
section_title: Interior and the Forest Service Cannot Determine Overall Treatment Effectiveness
paragraphs: Neither we nor the Forest Service or Interior know the overall  effectiveness of emergency stabilization and rehabilitation treatments  because local land units do not routinely document monitoring results,  collect comparable monitoring information, and disseminate the results of  their monitoring to other land units or to the agencies’ regional or national  offices. As a result, it is difficult to compile information from land units to  make overall assessments about the extent to which treatments are  effective or about the conditions in which treatments are most effective.  Furthermore, the departments have not developed an interagency system  to collect, store, and disseminate monitoring results. Consequently, it is  difficult for agency officials to learn from the results of treatments applied  on other sites in order to most efficiently and effectively protect resources  at risk.
subsections: section_title: Lack of Comparable Monitoring Data at the Local Land Unit Makes It Difficult to Comprehensively Assess Treatment Effectiveness
paragraphs: As noted previously, both Interior and the USDA’s Forest Service require  local land units to install treatments that are effective. In addition, Interior  requires, and the Forest Service strongly encourages, local land units to  monitor for treatment effectiveness. However, neither department specifies  how land units should conduct such monitoring or how they should  document monitoring results. Both our and the departments’ own internal  reviews found that inconsistencies in monitoring methods prevent a  comprehensive assessment of treatment effectiveness.
subsections: section_title: Local Land Units We Reviewed Do Not Use Comparable Methods to Monitor and Document the Effectiveness of Identical Treatments
paragraphs: To determine the methods local land units use to monitor and document  the effectiveness of their treatments, we reviewed 18 emergency  stabilization and rehabilitation plans that were implemented on 12 local  land units—6 of Interior’s and 6 of the Forest Service’s. We selected these  12 local land units because they obligated the most funds for emergency  stabilization and rehabilitation treatments within their regions in 2000, the  most recent year since the establishment of the National Fire Plan in which  local land units could have accomplished significant monitoring at the time  of our review.  For each of the 18 plans, we reviewed up to 3 of the most  costly treatments, for a total of 48 treatments. These 48 treatments are not  a representative sample of all emergency stabilization and rehabilitation  treatments implemented by the departments, and therefore our findings  cannot be projected. However, the data do represent monitoring practices  for a significant proportion of departmental outlays for treatments, since  the total cost of the treatments we reviewed was $84 million, or 30 percent  of the total funds obligated by Interior and the Forest Service for  emergency stabilization and rehabilitation treatments undertaken for  wildfires that occurred in 2000 and 2001.
Local land units monitored all of the 48 treatments we reviewed, but  documented conclusions about treatment effectiveness for only half of the  48 treatments. Land units monitored some treatments through visual  inspection alone and other treatments through both visual inspection and  data collection. For treatments that entail building or repairing  infrastructure—such as roadwork, trail repair, and fencing—local land  units typically monitored treatment effectiveness solely through visual  observation. Of the 19 such treatments, local land units visually observed  all and collected monitoring data for only 1. For example, national forests  often resurface roads and install drainage systems, such as culverts, to  prevent storm runoff from concentrating into torrents, eroding road  surfaces and depositing sediment into streams. To monitor the  effectiveness of such treatments, according to local national forest  officials, staff typically drive along repaired road segments and visually  observe road surfaces for gullies or other signs of erosion. In contrast, for  treatments designed to restore natural conditions—such as seeding,  reforestation, weed treatment, and erosion barriers—staff often collect  monitoring data, in addition to visually observing treatment sites. Of the 30  such treatments, local land units collected monitoring data on treatment  effectiveness for 22 and visually observed all 30. For example, one BLM  district office used two methods to monitor their seeding treatment:  (1)  they visually observed the seeded acreage and estimated the proportion of  the burnt area covered by native plants, weeds, and bare soil; and (2) they  collected data on the most abundant plant species, precipitation levels, soil  types, and terrain within a selected number of small, delineated sections  within the seeded acreage. Local land units documented conclusions about  treatment effectiveness for 24 of the 48 treatments we reviewed. In  documenting these results, land units used a wide variety of different  formats, including summaries of visual observations, tables of data  analyses, and presentations for academic conferences.
Even though the 12 local land units we reviewed generally monitored the  effectiveness of treatments, each used a different method to do so.  According to local land unit officials, departmental guidance does not  identify the methods they should use to visually inspect different types of  treatments, when they should collect and analyze monitoring data, the  types of data they should collect, or the techniques they should use to  collect and analyze monitoring data. In some instances, local land unit  officials said they used monitoring methods prescribed for programs other  than emergency stabilization and rehabilitation. For example, on three  national forests, Forest Service officials said that they used monitoring  methods specified by the agency’s forestry, or silviculture, program to  monitor reforestation treatments. In another instance, an interagency  technical reference describes 12 procedures for monitoring vegetation, but  the departments do not indicate which of these methods should be used to  monitor the seeding applied to burnt lands.
As a result of the lack of clarity, the 12 local land units differed significantly  in the methods they used to monitor the 30 treatments designed to restore  natural conditions. Of these 30 treatments, local land units collected data to  monitor the effectiveness of 22 of the treatments, in addition to making  visual observations, and relied solely on visual observations to monitor the  remaining 8 treatments. Likewise, local land units monitored untreated  sites for comparison with treated sites in 17 instances, while they  monitored just the treated sites in the remaining 13 instances. Furthermore,  in judging whether a treatment was effective, local land units established  measurable standards of effectiveness for 9 of the 30 treatments and relied  purely on the knowledge of local land officials to make this judgment for  the other 21. As one local land unit official said, each staff member has his  or her “own definition of success.” Overall, local land unit officials judged  most of the treatments as effective. However, because local land units (1)  collected different monitoring data, (2) used different methods to collect  monitoring data, and (3) developed their own definitions of treatment  effectiveness, the results of monitoring treatments we reviewed for these  18 emergency stabilization and rehabilitation plans cannot be compared to  determine if the treatments were effective.
For example, three national forests we reviewed spent more than $5  million to install erosion barriers on severely burnt slopes to protect homes  and streams from flooding and sedimentation after catastrophic wildfires  in 2000. Although all three forests installed the same treatment to  accomplish the same objective, the forests’ monitoring methods differed in  the extent to which they collected monitoring data, type of monitoring data  they collected, methods used to collect and analyze monitoring data, and  standards for judging treatment success. This situation is illustrated by the  following examples:  In one forest, local land unit officials observed treated slopes for  evidence of erosion but did not collect monitoring data or document  their findings. Because the officials observed that only small amounts of  sediment washed to the bottom of slopes after a rainstorm, they  concluded that the treatments had been effective. Without collecting  monitoring data, however, these officials could not accurately estimate  the amount of erosion prevented by the barriers placed on the slope or  the level of precipitation that would render the barriers ineffective.
In another forest, local land unit officials worked with Forest Service  researchers to collect data on precipitation levels and soil erosion from  both treated and untreated slopes, in addition to conducting visual  observations. The researchers used a computerized hydrological model  to analyze the monitoring data and concluded that the erosion barriers  decreased the risk of erosion by 19 percent—from an 86 percent risk on  untreated slopes to a 67 percent risk on treated slopes—and  documented these results in a presentation to a professional  conference. However, during visual observations, local land unit  officials disagreed on whether the presence of sediment trapped behind  the erosion barriers constituted treatment success:  some believed that  the barriers were effective because they had trapped erosion from  washing further down the slope, while others concluded that the  barriers were ineffective because they had not prevented soil from  eroding at the top of the slope.
In a third forest, local land unit officials collected monitoring data and  visually observed the erosion barriers. However, they said it was  difficult to accurately measure soil erosion and water quality in order to  determine treatment effectiveness. They therefore did not report on  their data collection and analysis and relied on visual observations to  judge treatment effectiveness: after observing significant amounts of  erosion, they concluded that the treatments were not effective.
Because these national forests used different methods to judge treatment  effectiveness, we could not draw overall conclusions about the  effectiveness of erosion barriers in protecting resources at risk at these  three forests. We found similar inconsistencies in monitoring data,  monitoring methods, documentation, and standards for treatment  effectiveness among other Forest Service land units as well as Interior’s.  For example, at two BLM district offices, we reviewed how local land unit  officials monitored seeding of burnt areas that was intended to establish  native species and prevent the spread of noxious weeds. One district  collected data from both seeded and unseeded plots, while the other only  collected data from seeded plots. In addition, one district used a  measurable standard to judge treatment success, while the other relied on  the professional judgment of land managers.
section_title: Departments’ Studies Could Not Determine Overall Treatment Effectiveness
paragraphs: Similarly, a 2000 USDA Forest Service study and a 2002 Interior study  found that it is difficult to determine overall treatment effectiveness  because land units use different methods to monitor identical treatments  and rarely document monitoring results. For example, as part of its study,  Forest Service officials reviewed more than 150 monitoring reports for  emergency stabilization and rehabilitation treatments undertaken at  national forests. As part of its study, Interior reviewed techniques that BLM  field offices in Idaho, Nevada, Oregon, and Utah used to monitor seeding  treatments. Both of these studies concluded that local land units often did  not collect or record data important to interpreting treatment  effectiveness, including data on site conditions and treatment outcomes. In  addition, both studies found that only approximately one third of local land  units collected monitoring data, and among these local land units, few  collected the same type of data or used the same data collection methods.  Because of the lack of documentation and the differences in monitoring  methods, neither study was able to determine the validity of monitoring  results, to calculate the extent to which treatments were effective, or to  compare the effectiveness of treatments in different regions or land units.  According to Interior and Forest Service officials, including the authors of  these studies, the departments know little about the extent to which  emergency stabilization and rehabilitation treatments prevent erosion,  protect water quality, restore native vegetation, reduce invasive weeds, or  protect wildlife. In a separate 2001 study of its emergency stabilization  program in the Northern and Intermountain regions, the Forest Service  concluded that the agency is “often . . . uncertain that  actually  work. There is a concern that treatments may look good, but their  functional effectiveness is unknown.”
Improved monitoring would provide critical information to departmental  officials making decisions about emergency stabilization and rehabilitation  treatments, according to the Interior and Forest Service studies. According  to the Forest Service study, knowing the effectiveness of particular  treatments would help local land units select the most appropriate  treatments for installation and could assist them in defending and  explaining their decisions. For example, knowing the likelihood that  erosion barriers will effectively prevent erosion on a certain soil type could  help land unit officials determine whether installing such barriers is  worthwhile, according to the lead author of the study. Likewise, the  Interior study noted that a synthesis of monitoring data could assist BLM in  restoring native plants and reducing invasive weeds in the Intermountain  West.
In order to gather such information, these studies recommended that the  agencies improve monitoring. The Forest Service study of treatment  effectiveness recommended that national forests “increase monitoring  efforts” to determine the effectiveness of treatments under various  conditions, while the agency’s review of the emergency stabilization  program recommended “a quick format for minimal quantitative  monitoring.” Similarly, the Interior study recommended that BLM districts  adopt a common monitoring technique and report whether treatments  meet their objectives.
The departments have not implemented these recommendations, however.  According to departmental officials responsible for overseeing their  emergency stabilization and rehabilitation efforts, implementation has not  occurred because of the difficulty associated with the development of  standardized monitoring and data collection methods and the collection of  such data. At the local level, even though land units typically conduct some  type of monitoring and view monitoring as valuable, agency officials  consider extensive monitoring to be a less important use of their time than  other immediate wildland fire duties, such as serving on emergency  stabilization and rehabilitation assessment teams and overseeing the  installation of treatments. These wildland fire duties are in addition to their  normal duties they must carry out on a routine basis. Furthermore,  departmental officials said that because land characteristics and treatment  objectives vary significantly from land unit to land unit and from agency to  agency, it is difficult to establish standard monitoring or data collection  methods that would apply in all circumstances. At the same time, however,  they acknowledged that there are enough commonalities among land units,  agencies, and treatments, that some aspects of monitoring and data  collection could be standardized, such as consistently collecting and  documenting data on precipitation, soil type, and terrain. BLM officials  added that they have recently begun to discuss the development of  standardized monitoring methods and possible criteria for treatment  success. Departmental officials commented, however, that if monitoring  methods were standardized and data were routinely collected and  analyzed, it might be more appropriate for an independent organization  such as the department’s science agency—the U.S. Geological Survey—to  conduct this work and assess the relative success and failure of treatments.
section_title: The Departments Do Not Routinely Collect, Archive, and Disseminate Monitoring Results Collected by Local Land Units
paragraphs: Interagency and departmental policies direct the departments to collect,  archive, and disseminate monitoring results collected by local land units so  that the departments can make more informed decisions on the  effectiveness of the treatments being used. According to Interior, for  example, “Priority should be given to developing a simple interagency  electronic mechanism for archiving and broadly disseminating the  treatment and technique results.” Similarly, the Forest Service cited the  need for the agency to develop a clearinghouse of monitoring plans and a  system for sharing monitoring results. Nevertheless, neither Interior nor  the Forest Service developed an interagency system to collect, store, and  disseminate monitoring results of emergency stabilization and  rehabilitation treatments.
Based on our review of treatments for 18 emergency stabilization and  rehabilitation plans at 12 local land units, we found that local land units did  not routinely share monitoring results with other land units or with  program management, even in instances when they learned valuable  lessons about treatment effectiveness. For example, according to local land  unit officials, they shared information with their peers through informal  means such as phone calls to neighboring land units and conversations at  regional meetings for only 24 of the 48 treatments we reviewed. Similarly,  these officials said that they submitted their monitoring results to their  agency’s state or regional offices for only 19 of the 48 treatments. At the  same time, local land unit officials said they learned lessons while  monitoring that would be worth sharing with other land units in 37 of the  48 cases.
Currently, the departments do not have an interagency database that local  land units can submit monitoring data and then use to determine the  relative success of different treatments, according to Forest Service and  Interior emergency stabilization and rehabilitation officials. Several local  land unit officials said that if such information were accessible, they would  be better able to select the most appropriate treatment to meet certain  objectives in specific conditions. Officials in one BLM Nevada land unit  said that the BLM state office was developing a database to collect, store,  and disseminate monitoring results. BLM Nevada officials said that the  database would be used to collect and store the specifications and results  of seeding treatments that have been applied on BLM lands in the entire  state. When BLM officials in Nevada then consider using a seeding  treatment following a wildfire, they would be able to search the BLM  Nevada database to identify the results of prior seeding treatments that  were applied in similar terrain, on similar soil types, at similar elevations,  and with similar precipitation levels, according to these officials. Local land  unit officials could use this information to make treatment decisions, such  as whether to seed a burnt area or whether to allow it to recover naturally.  BLM Nevada officials said that such a database would be “worth its weight  in gold” because of the difficulty in identifying the most appropriate plant  species and seed application techniques that will be effective in Nevada’s  arid rangelands.
According to Interior and Forest Service officials responsible for their  emergency stabilization and rehabilitation programs, the departments had  not developed an interagency monitoring database for the same reasons  that they have not standardized monitoring and data collection methods:   coordinating such a task with multiple agencies would require a substantial  amount of work and monitoring has historically been considered a lower  priority than other more pressing tasks. Departmental officials said that it  would be time-consuming to develop a database to meet the needs of  multiple agencies, each of which manages different types of land. Other  departmental officials said that the departments typically respond well to  emergencies, such as fire suppression, but have placed less emphasis on  monitoring. These officials acknowledged, however, that a monitoring  database would be valuable and said that they had scheduled interagency  meetings in early 2003 to discuss developing such a database.
While the Forest Service has already begun work on a database of  monitoring results, the database is limited in scope and application. The  database includes information that the Forest Service collected as part of  its 2000 study of the effectiveness of emergency stabilization treatments,  according to the agency official who led that study. Beginning in 2003, this  official said that local Forest Service land unit officials will be able to  access information collected during the course of that study, including any  monitoring information, to help inform their treatment decisions. This  official noted, however, that because of differences and shortcomings in  the ways that national forests collected and retained monitoring  information for the emergency stabilization plans that were reviewed for  that study, the database has several limitations:  it will (1) not provide  quantitative data on the extent of treatment effectiveness; (2) not provide  information necessary to determine the conditions—such as soil  characteristics or vegetation types—under which treatments are most  effective; (3) not provide a means by which local Forest Service land unit  officials could report their current monitoring results to other local land  units or to Forest Service regional or national offices.
section_title: Conclusions
paragraphs: Most lands burned by catastrophic wildfires will recover naturally, without  posing a threat to public safety or ecosystems. However, in those relatively  few instances where burnt lands threaten safety, ecosystems, or cultural  resources, emergency stabilization and rehabilitation treatments can play a  critical role—a role that is emphasized by the appropriations Congress has  dedicated to postwildfire treatments.
The treatments Interior and the Forest Service use to protect and restore  burnt lands—slope stabilization measures such as mulching to prevent soil  from eroding into rivers and streams, seeding to regenerate important  grasses and shrubs, and noxious or invasive weed monitoring and  control—appear, on the face of it, to be reasonable. For the most part,  however, Interior and the Forest Service are approving treatment plans  without comprehensive information on the extent to which a treatment is  likely to be effective given the severity of the wildfire, the weather, soil, and  terrain. Such information could help ensure that the agencies, including the  local land units, are using resources effectively to protect public safety,  ecosystems, and cultural resources.
Interior and USDA’s Forest Service have also done studies that recognize  the need for information on treatment effectiveness, but they have not  emphasized the importance of collecting, storing, analyzing, and  disseminating such data. Nor can they reasonably take action to collect,  store, analyze, or disseminate such data until the departments have  comparable monitoring data from their local land units. Interior and the  Forest Service have yet to set standards for data collection, develop  reporting procedures, or establish criteria for judging treatment  effectiveness, which makes it possible to assess treatment effectiveness. As  their and our own analyses have shown, this situation has resulted in local  land units using different monitoring methods, even when similar  treatments are being used under similar conditions, and a lack of  consistency in judging whether treatments have been effective.
section_title: Recommendations for Executive Action
paragraphs: In order to better ensure that funds for emergency stabilization and  rehabilitation treatments on burnt lands are used as effectively as possible,  we recommend that the Secretaries of Agriculture and of the Interior  require the heads of their respective land management agencies to   specify the type and extent of monitoring data that local land units are  to collect and methods for collecting these data, and  develop an interagency system for collecting, storing, analyzing, and  disseminating information on monitoring results for use in management  decisions.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Secretaries of Agriculture and of  the Interior for review and comment. The departments provided a  consolidated response to our draft report, which is included in appendix II  of this report. They generally agreed that more can be done to ensure that  funds for emergency stabilization and rehabilitation on burnt lands are  used as effectively as possible and with our recommendations that they  obtain and disseminate better data for determining treatment effectiveness.  In commenting on our recommendation that the departments obtain better  data on treatment effectiveness, the departments said that they were aware  that some of their own studies had previously identified the need to obtain  and disseminate better data for determining treatment effectiveness. They  cited several examples where they have or are trying to accomplish this,  including an effort to determine the effectiveness of log erosion barriers,  which is cited in this report. The departments, in their comments, said they  recognize that many of the efforts are individual agency initiated actions, as  opposed to a systematic approach, to collect data on treatment  effectiveness. They said that they are currently planning actions that would  address data collection concerns in a more collaborative manner by  establishing an interdepartmental committee of scientists and managers to  identify the dominant postfire stabilization and rehabilitation treatments  for which monitoring methods will be established. An interdepartmental  approach is essential, not only for identifying the amount and type of data  that local land units should collect, but also for developing an interagency  and interdepartmental system for routinely collecting, storing, analyzing,  and disseminating these data. The departments also provided several  technical changes that we incorporated into the report, as appropriate.
As arranged with your offices, unless you publicly announce the contents  earlier, we plan no further distribution of this report until 30 days after the  date of this letter. At that time, we will send copies of this report to the  Chairman and Ranking Minority Member, Subcommittee on Public Lands  and Forests, Senate Committee on Energy and Natural Resources; the  Chairman and Ranking Minority Member, House Committee on Resources;  the Chairman and Ranking Minority Member, Subcommittee on Forests  and Forest Health, House Committee on Resources; the Chairman and  Ranking Minority Member, Subcommittee on Interior and Related  Agencies, House Committee on Appropriations; the Ranking Minority  Member, House Committee on Agriculture; the Ranking Minority Member,  Subcommittee on Department Operations, Oversight, Nutrition and  Forestry, House Committee on Agriculture; and other interested  congressional committees. We will also send copies of this report to the  Secretary of Agriculture; the Secretary of the Interior; the Chief of the  Forest Service; the Directors of BLM, the National Park Service, and the  Fish and Wildlife Service; the Deputy Commissioner, Bureau of Indian  Affairs; the Director, Office of Management and Budget; and other  interested parties. We will make copies available at no charge to others  upon request. This report will also be available at no charge on GAO’s home  page at http://www.gao.gov/.
If you or your staff have any questions about this report, please contact me  at (202) 512-3841. Key contributors to this report are listed in appendix III.
section_title: Scope and Methodology
paragraphs: To describe the Department of the Interior’s and the U.S. Department of  Agriculture’s Forest Service processes for implementing their emergency  stabilization and rehabilitation programs, we obtained departmental  manuals, handbooks, and other guidance that describe Interior’s process  for implementing emergency stabilization and rehabilitation and the Forest  Service’s emergency stabilization program. We also interviewed Interior  and Forest Service officials responsible for overseeing the department’s  respective programs to obtain an overview of Interior’s and the Forest  Service’s processes for their programs. Because the Forest Service’s  rehabilitation program is relatively new and has not yet been incorporated  into the Forest Service manual or handbook, we obtained guidance  developed by the Forest Service and provided to Forest Service regional  offices on the process used to implement that program. We also obtained  additional guidance and documentation from the Forest Service’s  Northern, Southwestern, and Intermountain regions (regions 1, 3, and 4,  respectively)—the three regions that received the largest share of Forest  Service rehabilitation program funding in fiscal year 2001—to determine  what additional processes these regions developed and used to implement  the program. Further, we interviewed Bureau of Land Management (BLM),  Bureau of Indian Affairs, Fish and Wildlife Service, National Park Service,  and Forest Service officials at regional, state, and local land management  units that had experienced wildland fires in 2000 or 2001 to discuss  procedures used in assessing burnt lands and identifying appropriate  treatments.
To identify the costs and types of treatments the departments have  implemented, we obtained 266 emergency stabilization and rehabilitation  plans that Interior agencies prepared for wildfires that occurred in calendar  years 2000 and 2001 on  BLM managed lands in Idaho, Nevada, Oregon, and Utah;  Bureau of Indian Affairs managed lands in its Northwest, Rocky  Mountain, Southwest, and Western regions;  Fish and Wildlife Service managed lands in its Mountain Prairie, Pacific,  Southeast, and Southwest regions; and  National Park Service managed lands in its Intermountain and Pacific  West regions.
For the Forest Service, we requested and obtained 155 emergency  stabilization plans and rehabilitation plans for wildfires that occurred in  calendar years 2000 and 2001 on Forest Service lands managed in its  Intermountain, Northern, Pacific Northwest, Pacific Southwest, and  Southwestern regions (regions 4, 1, 6, 5, and 3, respectively). We selected  these Interior and Forest Service regions because they accounted for about  90 percent of the plans that the departments developed for treating  wildfires that occurred in 2000 and 2001.
To identify the types of treatments implemented, we reviewed these 421  plans and identified treatments proposed and approved in the plans. To  identify the costs of the plans and the treatments, we obtained estimated  costs that the departments approved to carry out the plans and implement  the individual treatments. Because these costs are estimates, they do not  necessarily reflect actual costs that could be incurred in carrying out the  plans during the 3 years that may be required to implement them. We did  not obtain actual costs incurred, to date, in carrying out these plans  because this data are not readily available.
To determine whether emergency stabilization and rehabilitation  treatments are achieving their intended results, we reviewed 18 emergency  stabilization and rehabilitation plans that were implemented on 12 land  units—6 of Interior’s and 6 of the Forest Service’s. We selected these 12  land units because they obligated the most funds for emergency  stabilization and rehabilitation treatments within their regions in 2000, the  most recent year since the establishment of the National Fire Plan in which  local land units could have accomplished significant monitoring at the time  of our review. We did not select emergency stabilization and rehabilitation  plans for wildland fires that occurred in 2001 because, at the time of our  review, local land units would have had little time to monitor treatments  that had been implemented. For each of the 18 plans, we reviewed up to 3  of the most costly treatments. One of the 18 plans we selected had only 2  treatments, both of which we reviewed. In addition, we did not review five  treatments we initially selected either because the treatments had not yet  been fully implemented, or because we were unable to obtain timely  information on the treatment’s status. Therefore, the total number of  treatments we reviewed was 48. For each of these treatments, we  interviewed the land manager responsible for monitoring and reviewed  associated documentation of monitoring results, when available. These 48  treatments are not a representative sample of all emergency stabilization  and rehabilitation treatments implemented by the departments, and  therefore our findings cannot be projected. However, the data do represent  monitoring practices for a significant proportion of departmental outlays  for treatments, since the total cost of the treatments we reviewed was $84  million, or 30 percent of the total funds obligated by Interior and the Forest  Service for emergency stabilization and rehabilitation treatments  undertaken for wildfires that occurred in 2000 and 2001.
In addition, we obtained program reviews or other studies conducted by  the Forest Service or Interior on their emergency stabilization and  rehabilitation reports to determine if the departments monitor treatments  and, if so, the type and quality of departmental monitoring data. We also  interviewed emergency stabilization and rehabilitation officials at the  departments’ national, regional, or state levels, and local land unit offices  to determine what monitoring is being conducted by local land unit offices,  whether data are collected, and what use is made of these data for  assessing treatment effectiveness or sharing lessons learned.
We conducted our review from August 2001 through February 2003 in  accordance with generally accepted government auditing standards.
section_title: Comments from the Departments of the Interior and Agriculture
section_title: GAO Contact and Staff Acknowledgments
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section_title: Staff Acknowledgments
paragraphs: In addition, Mark Braza, Marcia Brouns McWreath, Carol Herrnstadt  Shulman, and Katheryn Summers made key contributions to this report.
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