Forest Service: Use of Categorical Exclusions for Vegetation Management Projects, Calendar Years 2003 through 2005
Published: 2006-10-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Forest Service manages over 192 million acres of land, in part through vegetation management projects such as thinning trees. The National Environmental Policy Act (NEPA) requires the Forest Service to prepare either an environmental assessment (EA) or an environmental impact statement (EIS) before approving a project that may significantly affect the environment. The agency generally does not need to prepare such environmental analyses, however, if the project involves categories of activities that it previously found to have no significant environmental effects--activities known as a categorical exclusion. As of 2003, the Forest Service had one categorical exclusion--activities to improve timber stands or wildlife habitat. It has since added four new exclusions, but little is known about their use. GAO was asked to determine, for calendar years 2003 through 2005, (1) how many vegetation management projects the Forest Service approved, including those approved using categorical exclusions; (2) which categorical exclusions the agency used in approving projects; and (3) if field offices are not using categorical exclusions, why. To answer these objectives, GAO surveyed Forest Service officials from all of the 155 national forests. In commenting on a draft of this report, the Forest Service generally agreed with GAO's findings and observations.
section_title: What GAO Found
paragraphs: For calendar years 2003 through 2005, the Forest Service approved 3,018 vegetation management projects to treat about 6.3 million acres. Of these projects, the Forest Service approved about 28 percent using an EA or EIS to treat about 3.4 million acres, while it approved the remainder using categorical exclusions. Although a majority of the projects were approved using categorical exclusions, these projects accounted for less than half of the total treatment acres. The number and size of projects and types of environmental analysis used during the 3-year period varied, depending upon forest size, ecology, and location, according to Forest Service officials. Of nearly 2,200 vegetation management projects approved using categorical exclusions, the Forest Service approved half of them using the categorical exclusion for improving timber stands or wildlife habitat. In approving the remaining projects, the agency primarily used the categorical exclusion for reducing hazardous fuels, followed by those for salvaging dead or dying trees, conducting limited harvests of live trees, and removing trees to control the spread of insects or disease. The projects approved using the categorical exclusion to improve timber stands or wildlife habitat accounted for about 2.4 million of the 2.9 million acres to be treated under projects approved using categorical exclusions. About 11 percent of the Forest Service's 509 field offices had not used any of the five vegetation management categorical exclusions during the 3-year period. The reasons why they had not used specific categorical exclusions varied by office and categorical exclusion. For example, about 91 percent of the field offices had not used the categorical exclusion for the removal of trees to control the spread of insects or disease primarily because they did not have a sufficient number of insect- or disease-infested trees. Similarly, 32 percent of the field offices had not used the categorical exclusion to improve timber stands or wildlife habitat, primarily because no projects of this type had been proposed during the 3-year period.

section_title: Letter
paragraphs: The U.S. Department of Agriculture’s Forest Service is responsible for  managing about 192 million acres of public land—about 30 percent of all  federal lands in the United States. Under the National Environmental  Policy Act of 1969 (NEPA), agencies evaluate the likely environmental  effects of projects they are proposing using an environmental assessment  (EA) or, if the projects likely would significantly affect the environment, a  more detailed environmental impact statement (EIS). For example, certain  proposed vegetation management projects, which include activities such as  thinning trees and shrubs and harvesting and selling timber, may require  the Forest Service to prepare an EA or EIS for the treatment areas. If,  however, the Forest Service determines that activities of a proposed  project fall within a category of activities the agency has already  determined has no significant environmental impact—called a categorical  exclusion—then the agency generally need not prepare an EA or EIS. The  agency may instead approve projects that fit within a relevant category by  using one of the predetermined categorical exclusions. The extent to which  the Forest Service approves projects using these categorical exclusions has  been controversial. Some critics argue that, even though these types of  projects may be relatively small, the environmental effects of excluded  projects are not being fully analyzed. Others favor the expanded use of  categorical exclusions as a means to accomplish routine vegetation  management projects promptly.
As of 2003, the Forest Service had one categorical exclusion for vegetation  management activities—it covered certain activities intended to improve  timber stands or wildlife habitat. In 2003, it issued four more categorical  exclusions: (1) hazardous fuels reduction activities using prescribed fire,  not to exceed 4,500 acres, and mechanical methods such as thinning, not to  exceed 1,000 acres; (2) limited timber harvests of live trees, not to exceed  70 acres; (3) salvage of dead or dying trees, not to exceed 250 acres; and (4)  removal of trees to control the spread of insects or disease, not to exceed  250 acres. Little is known about the Forest Service’s use of these  categorical exclusions because, prior to 2005, the agency did not maintain  nationwide data on their use.
In this context, you asked us to determine, for calendar years 2003 through  2005, (1) how many vegetation management projects the Forest Service  approved, including those approved using categorical exclusions, and the  number of associated treatment acres; (2) for those projects approved  using categorical exclusions, which categorical exclusions the agency used  and the associated treatment acreage under each; and (3) if the Forest  Service field offices are not approving vegetation management projects  using categorical exclusions, what are the primary reasons for not doing so.
Because the Forest Service has no centralized nationwide information on  vegetation management projects for calendar years 2003 through 2005, we  sent a questionnaire to all 155 national forests to obtain this information.  We asked Forest Service officials from these forests to provide information  on the number of vegetation management projects they approved during  the 3-year period and the number of treatment acres in each project, and  whether the Forest Service used an EA, EIS, or one of the five categorical  exclusions when approving the projects and, as appropriate, which  categorical exclusion was used. We also asked each forest whether each of  the ranger districts in that forest—administrative units primarily  responsible for deciding which types of environmental analysis should be  undertaken on projects within the forests—had used each of the five  categorical exclusions during the 3-year period and, if not, why the ranger  districts had not done so. All 155 national forests, representing 509 ranger  districts that manage National Forest System lands, responded to our  questionnaire. We tested the accuracy and reliability of the information by,  among other things, requesting supporting documentation from the Forest  Service for a randomly selected sample of projects and verifying  information submitted about these projects on the questionnaire. We found  that the information submitted was sufficiently reliable for our purposes.  Using a nonprobability sample, we also selected and interviewed 23 ranger  districts at 12 national forest units to obtain a better understanding of why  categorical exclusions may or may not have been used when approving  vegetation management projects. These ranger districts and national  forests were selected on the basis of their diverse ecosystems and  geographic location. Appendix I provides further details on our scope and  methodology. Appendix II provides a list of Forest Service categorical  exclusions. Appendixes III through VII provide the results of the  questionnaire in more detail. We performed our work from September 2005  through August 2006 in accordance with generally accepted government  auditing standards.
subsections: section_title: Background
paragraphs: The Forest Service is responsible for managing over 192 million acres of  public lands—about 30 percent of all federal lands in the United States. In  carrying out its responsibilities, the Forest Service traditionally has  administered its programs through 9 regional offices, 155 national forests,  20 national grasslands, and several hundred ranger districts. Figure 1  shows a map of the Forest Service regions and national forests.
To sustain the health, diversity, and productivity of the nation’s forests, the  Forest Service can propose land management projects that may change the  existing condition of vegetation—projects referred to as vegetation  management. Vegetation management projects may include, but are not  limited to, activities such as using prescribed burning, timber harvests, or  herbicides; or thinning trees, grass, weeds, or brush. Projects that include  these types of activities are intended to, among other things, maintain  healthy ecosystems, reduce the risk of catastrophic wildland fire, and  manage the nation’s forests for multiple uses, such as timber, recreation,  and watershed management.
Under NEPA, agencies such as the Forest Service generally evaluate the  likely environmental effects of projects they propose using an EA or, if the  projects likely would significantly affect the environment, a more detailed  EIS. However, an agency generally need not prepare an EA or EIS if it  determines that activities of a proposed project fall within a category of  activities the agency has already determined have no significant  environmental impact—called categorical exclusions. The agency may  then approve projects fitting within the relevant categories using these  predetermined categorical exclusions rather than carrying out a project- specific EA or EIS. For a project to be approved using a categorical  exclusion, the Forest Service must determine whether any extraordinary  circumstances exist in which a normally excluded action or project may  have a significant effect.4, 5 To establish categorical exclusions, the Forest  Service must determine that the categories of activities proposed for  exclusion do not individually or cumulatively have a significant impact on  the environment. In doing so, the public is to be provided an opportunity to  review and comment on proposed categorical exclusions.
Resource conditions that should be considered in determining whether extraordinary  circumstances exist include, among other things, the existence of federally listed threatened  or endangered species or designated critical habitat; congressionally designated wilderness  areas; inventoried roadless areas; and archaeological sites or historic properties. The mere  presence of one or more of these conditions does not preclude the use of a categorical  exclusion. Rather, it is the degree of the potential effect of the proposed action on these  conditions that determines whether extraordinary circumstances exist.
The Forest Service may decide to prepare an environmental assessment for a project that  could qualify for approval using a categorical exclusion.
Figure 2 shows the NEPA process the Forest Service generally follows for  assessing the likely environmental impacts of land management activities.
As of 2003, the Forest Service had one categorical exclusion for use in  approving projects involving certain vegetation management activities— timber stand or wildlife habitat improvement—that, still today, has no  acreage limitation. In 2003, after reviewing and evaluating data on the  environmental effects of vegetation management projects that had been  carried out by the national forests, the Forest Service added four new  vegetation management categorical exclusions, each of which has acreage  limitations: (1) hazardous fuels reduction, (2) limited timber harvests of  live trees, (3) salvage of dead or dying trees, and (4) removal of trees to  control insects and disease. Table 1 summarizes the Forest Service’s five  vegetation management categorical exclusions, including the four  approved in 2003, along with any corresponding acreage limitations. (App.  II provides a complete list of the Forest Service’s categorical exclusions.)
The Forest Service requires agency officials responsible for making  vegetation management project decisions to prepare and retain a file and  decision memo for each vegetation management project approved using a  categorical exclusion. Decision memos are to include, among other  information, the title of each proposed action, an outline of the decision  being made, a description of the public’s involvement in the decision- making process, and the date for implementing the project.
Controversy has surrounded the Forest Service’s use of vegetation  management categorical exclusions because, on the one hand, critics  assert that the use of categorical exclusions is an attempt to circumvent  NEPA by precluding the need to perform an EA or EIS. Supporters, on the  other hand, have responded that current analysis and documentation  requirements for an EA or EIS under NEPA are too burdensome and that  the new categorical exclusions allow the Forest Service to more efficiently  undertake routine vegetation management activities. Adding to this  controversy, the Forest Service initially did not subject projects being  approved using the five vegetation management categorical exclusions to a  formal notice, comment, and appeal process as it did to projects being  approved using an EA or EIS. As a result of litigation, the Forest Service  now requires that vegetation management projects being approved using  these categorical exclusions be subject to formal notice, comment, and  appeal. Critics argue that such public involvement is essential for  responsive decision making, while others argue the formal appeal process  is unnecessarily burdensome and prevents the Forest Service from  undertaking routine vegetation management activities in a timely manner.  The debate surrounding the use of categorical exclusions centers on the  types of vegetation management projects approved using categorical  exclusions, how often the categorical exclusions are used, and how many  acres are treated when using them.
section_title: Categorical Exclusions Were Used to Approve Most Vegetation Management Projects and about Half of the Total Treatment Acres
paragraphs: For calendar years 2003 through 2005, as shown in table 2, the Forest  Service approved about 3,000 vegetation management projects to treat  about 6.3 million acres. Of these projects, the Forest Service approved  about 70 percent using categorical exclusions and the remaining projects  using an EA or EIS. Although a majority of projects were approved using  categorical exclusions, these projects accounted for slightly less than half  of the total treatment acres because the size of these projects was much  smaller than those approved using an EA or EIS.
Our analysis of the project data also revealed that the total number of  vegetation management projects approved, including those approved using  categorical exclusions, varied over the 3-year period, while the number of  treatment acres was relatively constant. As can be seen in figure 3, the  number of projects approved using an EA or EIS varied little over the 3- year period; however, the number of projects approved using categorical  exclusions increased from January 2003 through December 2004— primarily because of increased use of the four new categorical  exclusions—and then decreased from January through December 2005.  Forest Service officials said that any number of factors could have  influenced the increase and subsequent decrease in the use of categorical  exclusions over the 3-year period. However, given the relatively short  period of time during which the four new categorical exclusions were in  use, these officials said that it was not possible to speculate why the  decrease had occurred.
In contrast, as can be seen in figure 4, an analysis of the total treatment  acres included in projects approved using an EA, EIS, or categorical  exclusion did not reveal any notable change over the 3-year period.
Additional analyses of the project data also revealed that the number of  vegetation management projects approved, including those approved using  categorical exclusions, varied by Forest Service region and forest. For  example, of all vegetation management projects nationwide, Region 8—the  Southern Region—accounted for about 29 percent, of which just over two- thirds were approved using categorical exclusions. In contrast, Region 10— Alaska—accounted for about 2 percent of all vegetation management  projects, about 60 percent of which were approved using categorical  exclusions. According to several Forest Service officials, the number of  vegetation management projects approved and the type of environmental  analysis used in approving them depended on the forest’s size, ecology, and  location, as can be seen in the following examples:   At the 2 million-acre Superior National Forest, a pine, fir, and spruce  forest, in rural northeastern Minnesota, forest officials relied more on  environmental assessments and environmental impact statements in  approving projects because most of the projects were larger in terms of  geographic coverage and more inherently complex; they used  categorical exclusions only for a few smaller scale projects or projects  undertaken in response to unanticipated events such as a wind storm  that blew down trees on several hundred thousands of acres and that  subsequently needed to be removed to reduce the risk of wildland fire.  Of the 13 projects approved, forest officials used either environmental  impact statements or environmental assessments in approving 8 and  categorical exclusions in approving 5.
At the 1.8 million-acre Ouachita National Forest, a pine and hickory  forest in western Arkansas and southeastern Oklahoma, 163 projects  were approved—of which 119 were approved using categorical  exclusions. Forest officials said the forest has a very active vegetation  management program because, among other things, the types of trees  located on the forest tend to regenerate quickly and are an excellent  product for milling. In addition, a large timber harvest infrastructure is  located nearby, which helps ensure that timber-sale contracts can be  readily competed and awarded.
At the 440,000-acre Cleveland National Forest, a mixed conifer and  hardwood forest in Southern California, Forest Service officials said  they prepared an EA or EIS infrequently for managing vegetation  because the projects were necessarily small, given the forest’s limited  size. Cleveland forest officials approved all of its 18 projects using  categorical exclusions for calendar years 2003 through 2005.
At the 28,000-acre Caribbean National Forest, a humid tropical forest in  Puerto Rico, no vegetation management projects were approved.  According to forest officials, the forest does not have an active  vegetation management program because the forest focuses more on  developing recreational sites and wildlife habitat and because the island  does not have a commercial infrastructure to support harvesting or  milling timber.
Appendixes III and IV provide detailed information on the number of  vegetation management projects and acres approved using different types  of environmental analyses for calendar years 2003 through 2005.
section_title: Categorical Exclusion for Improving Timber Stands or Wildlife Habitat Was Used the Most Frequently to Treat the Most Acreage
paragraphs: Of the almost 2,200 projects approved using categorical exclusions over the  3-year period, the Forest Service most frequently used the vegetation  management categorical exclusion for improving timber stands or wildlife  habitat; this categorical exclusion was used on half of the projects to treat  about 2.4 million acres. As can be seen in table 3, for the remaining  projects, the Forest Service primarily used the categorical exclusion for  reducing hazardous fuels, followed by salvaging dead or dying trees,  conducting limited timber harvests of live trees, and removal of trees to  control the spread of insects or disease; in all, these categorical exclusions  were used to approve treatments on about a half-million acres. In addition,  the size of approved projects varied depending on the categorical exclusion  and any associated acreage limitation.
According to Forest Service officials, a number of factors influenced why  the categorical exclusion for timber stand or wildlife habitat improvement  was the most frequently used for the most treatment acreage. For example,  Santa Fe National Forest officials said that the forest has relied heavily on  this exclusion because it does not have an acreage limitation. Also, officials  at the George Washington and Jefferson National Forests and the  Monongahela National Forest said they relied on this categorical exclusion  more than others because the use of this category was consistent with their  forest management plans, which dictate the types of activities that may  take place on their forests. Further, Okanogan-Wenatchee National Forests  officials said they rely primarily on the timber stand or wildlife habitat  improvement categorical exclusion because of its long-standing use and  the beneficial nature of projects being undertaken, which enhances their  public acceptability.
We also analyzed the categorical exclusion for timber stand or wildlife  habitat improvement to determine whether its lack of size limitation  resulted in projects that are larger than those undertaken using the other  four exclusions. As can be seen in table 4, we found that almost 92 percent  of the projects approved using the categorical exclusion for timber stand or  wildlife habitat improvement were smaller than 5,000 acres—which is the  approximate size limitation of the categorical exclusion for hazardous fuels  reduction, the largest size limitation of the four more recent categorical  exclusions.
Appendixes V and VI provide detailed information on the number of  vegetation management projects and acres approved using different  categorical exclusions for calendar years 2003 through 2005.
section_title: Primary Reasons for Not Using Categorical Exclusions Varied Depending on the Ranger District and Type of Categorical Exclusion Used
paragraphs: Of the 509 ranger districts, 11 percent had not used any of the five  vegetation management categorical exclusions during the 3-year period. As  can be seen in table 5, the percentage of ranger districts that did not use  specific categorical exclusions ranged widely, from 91 percent not using  the category for the removal of trees to control the spread of insects or  disease, to 32 percent not using the category for timber stand or wildlife  habitat improvement. Reasons cited by the ranger districts also varied: The  primary reasons cited for not using the category for the removal of trees to  control the spread of insects or disease were the lack of insect- or disease- infested trees and that projects that could have fit the category had already  been or were to be included in an EA or EIS. Similarly, the primary reasons  cited for not using the category for timber stand or wildlife habitat  improvement were that projects that could have fit the category had  already been or were to be included in an EA or EIS and no projects were  undertaken to improve timber stands or wildlife habitat.
Ranger district officials we interviewed offered some reasons why  vegetation management categorical exclusions may not be used:   The Laurentian Ranger District, located in northern Minnesota in the  Superior National Forest, did not use the categorical exclusion for the  removal of trees to control the spread of insects or disease because,  according to district officials, it had no insect- or disease-infested trees  suitable for harvest.
The Tonasket Ranger District, located in north-central Washington in the  Okanogan-Wenatchee National Forests, had not used the categorical  exclusion for the removal of trees to control the spread of insects or  disease because, according to district officials, the 250-acre size  limitation of the categorical exclusion constrains its use because the  district has huge areas infested with beetles and mistletoe. To be  effective, any salvage would have to cover a much larger area.
The Canyon Lakes Ranger District, located in north-central Colorado in  the Arapaho-Roosevelt National Forests, had not used the categorical  exclusion for timber stand or wildland habitat improvement. According  to ranger district officials, this categorical exclusion was not used  because project planning typically consists of conducting an EA or EIS.  These types of environmental analysis allow the district to better  evaluate multiple activities over larger geographic areas using a single  analysis—which is more efficient than approving different projects  using several vegetation management categorical exclusions.
The Mountainair Ranger District, located in central New Mexico in the  Cibola National Forest, had not used the categorical exclusion for  limited timber harvests of live trees primarily because, according to  district officials, the state lacked a commercial timber industry that is  capable of harvesting and milling timber. District officials also said that  timber harvests would have to be much larger than 70 acres and include  much larger diameter trees, to be profitable and attract timber  companies from out of state.
Appendix VII provides more detailed information on the primary reasons  cited by the ranger districts for not using vegetation management  categorical exclusions for calendar years 2003 through 2005.
section_title: Observations
paragraphs: Because four of the five categorical exclusions have been available only for  the past 3 years, it is premature to draw any conclusions about trends in  their use. More information, over a longer period of time, is necessary to  better determine how the agency is using categorical exclusions, what  types of projects are being approved, and which forests are using them.  More importantly, such information will be useful in addressing some of the  controversial issues surrounding the use of categorical exclusions in  approving projects, such as whether these projects, individually or  cumulatively, have any significant effect on the environment or whether  their use is enabling more timely Forest Service vegetation management.
section_title: Agency Comments and Our Evaluation
paragraphs: We received written comments on a draft of this report from the Forest  Service. The Forest Service generally agreed with our findings and  observations, and specifically that it is premature to extrapolate trends  given the studied categorical exclusions’ limited period of use. The agency  provided us with technical comments that we have incorporated, as  appropriate. The Forest Service’s letter is reprinted in appendix VIII.
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If you or your staff have any questions about this report, please contact me  at (202) 512-3841 or nazzaror@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix IX.
section_title: Scope and Methodology
paragraphs: We were asked to determine how many vegetation management projects  the Forest Service approved for calendar years 2003 through 2005,  including those approved using categorical exclusions, and the number of  associated acres proposed for treatment. To obtain this information, we  developed a questionnaire addressed to forest supervisors. A questionnaire  was used because the Forest Service has no centralized data on the (1)  number of vegetation management projects that were undertaken for  calendar years 2003 through 2005, or how many acres were proposed for  treatment under these projects; (2) projects that were approved using  categorical exclusions, which categorical exclusions were used and the  associated acres being treated; or (3) reasons why categorical exclusions  were not used. While the Forest Service has a national database—the  Planning, Appeals, and Litigation System—that provides some information  on projects and the types of environmental analysis used in approving the  projects, the system does not generally include data prior to January 2005  or the number of treatment acres. Because information about individual  vegetation management projects is located primarily at the district offices,  we asked forest supervisors to coordinate the completion of the  questionnaire through each forest’s environmental planning coordinator,  who is familiar with National Environmental Policy Act (NEPA)  requirements. We also asked that the environmental planning coordinator  work with other forest officials, such as ranger district officials, to respond  to the questionnaire. After developing the questionnaire, we pretested it at  the Cibola and Santa Fe National Forests in New Mexico, Humboldt- Toiyabe National Forests in Nevada, George Washington and Jefferson  National Forests in Virginia, Monongahela National Forest in West Virginia,  and Ouachita National Forest in Arkansas.
For this report, we defined a vegetation management project as any project  that may include, but is not limited to, activities such as timber sales;  salvage sales; and the lopping, dropping, chipping, shredding, burning,  masticating, or otherwise thinning of trees, scrub, shrub, grass, weeds,  other understory, or brush for multiple purposes. We defined activities as  discrete actions or tasks that are intended to accomplish decision  objectives. Activities included, for example, stream improvements,  precommercial thinning, commercial thinning, slash piling and burning  harvest units, timber harvests, and underburning outside harvest units. For  each vegetation management project approved, we asked forest officials to  identify what type of decision document was used. Decision documents  include records of decision for environmental impact statements, decision  notices for environmental assessments, and decision memos in the case of  categorical exclusions. We also asked Forest Service officials to provide  data on the total number of acres proposed for vegetation management or  to indicate if the acreage was unknown. We asked forest officials not to  double-count acreage when multiple treatments were to occur on the same  acreage. In reporting acreage data, the number of acres proposed for  treatment may not necessarily correspond to the number of acres treated.
For projects approved using categorical exclusions, we asked Forest  Service officials to identify the associated acreage proposed for treatment  and which of the following five Forest Service Handbook categorical  exclusions were used:  timber stand or wildlife habitat improvement activities,  hazardous fuels reduction activities using prescribed fire not to exceed  4,500 acres and mechanical treatments not to exceed 1,000 acres,   harvest of live trees not to exceed 70 acres,   salvage of dead or dying trees not to exceed 250 acres, or  commercial and noncommercial harvest of trees to control insects or  disease not to exceed 250 acres.
We asked only for information on the use of these five categorical  exclusions. Thus, our evaluation does not include projects that the Forest  Service approved using other categorical exclusions which may have  included vegetation management activities. For example, the Forest  Service has a categorical exclusion for the repair and maintenance of  roads, trails, and land-line boundaries that could include vegetation  management activities but the primary purpose of the projects is not  vegetation management. We also did not include categorical exclusions for  regeneration and postfire rehabilitation—both of which could include  vegetation management in the form of planting seedlings or trees. These  types of activities, however, may have been included in projects that were  approved using the five categorical exclusions we evaluated.
To determine which Forest Service ranger districts were not using  categorical exclusions for managing vegetation and the primary reasons for  not doing so, we asked Forest Service officials whether ranger districts  within national forests used any of the five categorical exclusions for  calendar years 2003 through 2005. If a ranger district had not used one of  the five exclusions, we asked the forests to select a primary reason from  among a list of reasons that we provided. (If the primary reasons were not  included on our list, we also asked the forests to provide other reasons.) In  developing our list of reasons, we reviewed the conditions established by  the Forest Service that prevented the use of the categorical exclusions. We  also pretested the list with Forest Service officials at six national forest  units and ranger districts at those locations. While some ranger districts  may have had multiple reasons for not using a particular categorical  exclusion, we asked Forest Service officials to select the primary reason.
We verified the accuracy of the survey responses by randomly selecting  about 3 percent of the projects identified by the Forest Service on  completed questionnaires. After selecting a project, we requested  supporting decision documents—for example, the record of decision for  environmental impact statements, decision notices for environmental  assessments, or decision memos for projects approved using categorical  exclusions—and verified the documents’ information submitted on the  questionnaire. In total, we verified information for 84 projects and  determined that the data submitted were sufficiently reliable for our  purposes. We also examined the data for aberrations such as blank entries  and inconsistent responses and, as necessary, contacted the appropriate  forest officials for clarification.
The data we gathered have some limitations. The information obtained  from the national forests was self-reported, and we were unable to  independently ensure whether all vegetation management projects  approved during the 3-year period were reported. To gauge the accuracy of  the number of projects reported, we compared information on Forest  Service Schedule of Proposed Actions reports with information submitted  on our questionnaire. The action reports, which are prepared quarterly by  each of the national forests, summarize activities the forests plan to  undertake during the quarter, including proposed activities that have  approved decision documents, such as records of decision, decision  notices, or decision memos. These reports are available on individual  national forest Web sites and generally span at least two quarters. We  identified 113 projects that were listed on available quarterly proposed  action reports as projects the Forest Service approved using an  environmental assessment, environmental impact statement, or a  categorical exclusion and that appeared to be for vegetation management  but which were not included on the questionnaires. We randomly selected  12 of these projects for follow up with Forest Service officials to determine  why. We found that (1) six of the projects were not for vegetation  management and thus correctly should not have been included on the  questionnaires or in our data, (2) three of the projects were initially  excluded but were subsequently added to revised questionnaires and our  data as a result of our previous follow-up to clarify other issues, and (3)  three of the projects were erroneously omitted from the questionnaires and  should have been included in our data but were not. Forest Service officials  said the three projects were erroneously omitted because paperwork was  misfiled due to an administrative oversight or district office consolidation  or because of confusion over whether the project had been approved.  Based on this analysis, we found that the data are sufficiently reliable for  our reporting purposes.
Table 6 lists the 12 national forest units and 23 ranger districts we selected  for interviews, using a nonprobability sample, to better determine why  categorical exclusions may or may not have been used in approving  vegetation management projects. The table also lists the Forest Service  regions in which the forests and ranger districts are located, and their  geographic location.
We conducted our work from September 2005 through August 2006 in  accordance with generally accepted government auditing standards.
section_title: Forest Service Categorical Exclusions
paragraphs: As shown in table 7, the Forest Service has two types of categorical  exclusions: those that require the agency to prepare a decision memo for  each project approved using a categorical exclusion, and those that do not  require such documentation. The Forest Service Handbook provides  information on these categorical exclusions, as well as guidelines for  preparing decision memos.
section_title: Number of Projects and Acres by Type of Environmental Analysis and Forest Service Region (Calendar Years 2003 through 2005)
paragraphs: Acre (in thousand)
Acre (in thousand)
section_title: Number of Projects and Acres by Type of Categorical Exclusion and Forest Service Region (Calendar Years 2003 through 2005)
paragraphs: Acre (in thousand)
4 2 Acre (in thousand)
Fewer than 500 acres.
section_title: Comments from the U.S. Department of Agriculture
subsections: section_title: GAO Comments
paragraphs: 1. We have added language further explaining the Council on  Environmental Quality’s role in overseeing agencies’ actions to  implement the National Environmental Policy Act. 2. We have added language clarifying that, while decision memos may not  include all of the analyses performed by the Forest Service in support  of its decisions to use categorical exclusions, agency project files are to  include such information.  3. We have added language expanding on the court’s ruling on the nature  of projects subject to public notice, comment, and appeal under the  Appeals Reform Act. 4. We have added language further clarifying when the Forest Service can  use the hazardous fuels reduction categorical exclusion.  5. We have added language specifically identifying the categorical  exclusions for regeneration and postfire rehabilitation as ones that  were not included in our scope and methodology.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, David Bixler (Assistant Director),  Nancy Bowser, Rich Johnson, Marcia Brouns McWreath, Matthew  Reinhart, Jerry Sandau, Carol Herrnstadt Shulman, and Walter Vance made  major contributions to this report.