Forest Service: Information on Appeals and Litigation Involving Fuels Reduction Activities
Published: 2003-10-24T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal fire community's decades old policy of suppressing wildland fires as soon as possible has caused a dangerous increase in vegetation density in our nation's forests. This density increase combined with severe drought over much of the United States has created a significant threat of catastrophic wildfires. In response to this threat, the Forest Service performs activities to reduce the buildup of brush, small trees, and other vegetation on national forest land. With the increased threat of catastrophic wildland fires, there have been concerns about delays in implementing activities to reduce these "forest fuels." Essentially, these concerns focus on the extent to which public appeals and litigation of Forest Service decisions to implement forest fuels reduction activities unnecessarily delay efforts to reduce fuels. The Forest Service does not keep a national database on the number of forest fuels reduction activities that are appealed or litigated. Accordingly, GAO was asked to develop this information for fiscal years 2001 and 2002. Among other things, GAO was asked to determine (1) the number of decisions involving fuels reduction activities and the number of acres affected, (2) the number of decisions that were appealed and/or litigated and the number of acres affected, (3) the outcomes of appealed and/or litigated decisions, and (4) the number of appeals that were processed within prescribed time frames.
section_title: What GAO Found
paragraphs: In a GAO survey of all national forests, forest managers reported that in fiscal years 2001 and 2002, 818 decisions involved fuels reduction activities covering 4.8 million acres. Of the 818 decisions involving fuels reduction activities, about 24 percent were appealed--affecting 954,000 acres. However, of the 818 decisions, more than half, 486 decisions, could not be appealed because they involved activities with little or no environmental impact. Of the 332 appealable decisions, 194 (about 58 percent) were appealed. There can be multiple appeals per decision. In addition, 25 decisions (3 percent) affecting about 111,000 acres were litigated. For 73 percent of the appealed decisions, the Forest Service allowed the fuels reduction activities to be implemented without changes; 8 percent required some changes before being implemented; and about 19 percent could not be implemented. Of the 25 litigated decisions, 19 have been resolved. About 79 percent of appeals were processed within the prescribed 90-day time frame. Of the remaining 21 percent, the processing times ranged from 91 days to 240 days. The Forest Service, in commenting on a draft of this report, generally agreed with the report's contents. Their specific comments and our evaluation of them are provided in the report.

section_title: Letter
paragraphs: Human activities—especially the federal government’s decades-old policy  of suppressing all wildland fires—have resulted in dangerous  accumulations of brush, small trees, and other vegetation on federal lands.  This vegetation has increasingly provided fuel for large, intense wildland  fires, particularly in the dry, interior western United States.
The scale and intensity of the fires in the 2000 wildland fire season made it  one of the worst in 50 years.  That season capped a decade characterized by  dramatic increases in the number of wildland fires and the costs of  suppressing them.  These fires have also posed special risks to  communities in the wildland-urban interface—where human development  meets or intermingles with undeveloped wildland—as well as to  watersheds and other resources, such as threatened and endangered  species, clean water, and clean air.
The centerpiece of the federal response to the growing threat of wildland  fires has been the development of the National Fire Plan.  This plan, jointly  developed by the Department of Agriculture and the Department of the  Interior, advocates a new approach to wildland fires by shifting emphasis  from the reactive to the proactive—from attempting to suppress wildland  fires to reducing the buildup of hazardous vegetation that fuels fires.  The  plan recognizes that unless these fuels are reduced, the number of severe  wildland fires and the costs associated with suppressing them will continue  to increase.  Implementation of the National Fire Plan began in fiscal year  2001; full implementation of the plan is expected to be a long-term,  multibillion-dollar effort.
Reducing the buildup of hazardous forest fuels is typically accomplished  through a number of treatment methods.  Most often, federal land  managers use controlled fires (prescribed burns) or mechanical treatments  such as chainsaws, chippers, mulchers, and bulldozers.  Other means of  reducing fuels buildup include using livestock grazing and herbicides.  On  federal lands, these activities are managed by five agencies—the National  Park Service, the Fish and Wildlife Service, the Bureau of Land  Management, and the Bureau of Indian Affairs—all within Interior, and the  Forest Service within Agriculture.
The first year that the National Fire Plan was in effect, the Congress  substantially increased funding for hazardous forest fuels reduction for  both the Forest Service and Interior agencies—from $117 million in fiscal  year 2000 to $400 million in fiscal year 2001.  The Congress continued this  increased funding level for 2002 and 2003.  Since the National Fire Plan  began emphasizing the need to reduce forest fuels buildup and the  Congress began to support this initiative with substantially increased  funding, questions have been raised about whether the agencies’ ability to  implement forest fuels reduction activities is being unnecessarily delayed  by administrative appeals and litigation of its land management decisions.  Concerns have focused on the Forest Service, which, among the federal  agencies involved in implementing the National Fire Plan, receives, by far,  the largest portion of the funding—over 50 percent in fiscal years 2001 and  2002.  Further, the scope of the Forest Service fuels reduction needs is  much broader than those of the other federal agencies.  Under current  rules, members of the public are permitted to appeal and/or litigate the  implementation of Forest Service decisions within certain prescribed time  frames and under certain circumstances.
In this context, you asked us to develop national data on Forest Service  fuels reduction activities.  Specifically, for fiscal years 2001 and 2002, you  asked us to determine (1) the number of decisions involving fuels reduction  activities and the number of acres affected; (2) the number of decisions  that were appealed and/or litigated and the number of acres affected; (3)  the outcomes of the appealed and/or litigated decisions and the identities  of the appellants and plaintiffs; (4) the number of appeals that were  processed within the prescribed time frames; (5) the types of fuels  reduction treatment methods identified in the decisions, the acreage  affected, and how frequently these decisions were appealed; (6) the types  of contracts used for implementing fuels reduction activities and how  frequently decisions, including each type of contract, were appealed; and  (7) the number of decisions involving fuels reduction activities in the  wildland-urban interface and inventoried roadless areas and how  frequently these decisions were appealed.  In addition to providing the  national data in response to each objective, you also asked us to provide  regional data.  This letter provides the national data.  The regional  breakdown for the seven objectives is shown in appendixes II through X.
In conducting our review, we used a Web-based survey of all 155 national  forests.  The survey focused on all Forest Service decisions with fuels  reduction activities that were issued in fiscal years 2001 and 2002.  We  obtained a 100 percent response rate from the national forests.  We also  tested the accuracy and reliability of the information provided in the  responses and found that the information was generally reliable.  Appendix  I provides details on the scope and methodology of our review.
When we provided you with preliminary information on the results of our  survey on May 14, 2003, we had not yet completed our data reliability  checks. Accordingly, we noted in that interim report that some of the  information could change in our final report.  In fact, now that our  reliability checks have been completed, some of the information provided  in our interim report has changed slightly.  However, the relationships  among the numbers have not materially changed.  In our interim report, we  also noted certain other limitations that still apply.  Specifically, the survey  information is self-reported.  Accordingly, we were not able to  independently ensure that all decisions were reported.  In addition, the  Forest Service does not have a common definition of “fuels reduction  activities.”  As a result, if the Forest Service documentation explicitly  stated that the purpose of an activity was fuels reduction, we included it; if  the documentation did not include an explicit discussion of fuels reduction  activities, we did not include the decision in our analysis.  Finally, the  Forest Service does not have a uniformly applied definition of the  “wildland-urban interface.”  Consequently, individual forests may have their  own definition or no definition at all, which could result in inconsistent  data.
subsections: section_title: Background
paragraphs: The 2000 and 2002 wildland fire seasons proved to be two of the worst in  over 50 years.  During the 2000 fire season, almost 123,000 fires burned  more than 8.4 million acres and cost the federal government over $1.3  billion.  In 2002, almost 89,000 fires burned about 7 million acres, an area  larger than the states of Maryland and Rhode Island combined.  For  decades, the federal wildland fire community pursued a policy of  suppressing all fires as soon as possible.  Over the years, suppressing fire in  areas where it naturally occurred has caused an increase in the volume of  brush, small trees, and other vegetation.  The increase in such “forest  fuels,” combined with a severe drought in much of the nation over the past  few years, has increased the severity of wildland fires.  The result in some  instances has been catastrophic.  In 2002, the Rodeo-Chediski fire in  Arizona, the Hayman fire in Colorado, and the Biscuit fire in Oregon and  California became the largest fires in those states in more than a century.
To deal with this threat, the administration asked the Forest Service and  Interior to recommend how best to respond and how to reduce the impacts  of such fires in the future.  The resulting report and the associated  implementation documents became known as the National Fire Plan.  This  blueprint recommended that the Congress substantially increase funding  for several key activities, such as suppressing wildland fires and reducing  the buildup of unwanted hazardous forest fuels.  Of the federal agencies  involved with helping to reduce the threat posed by wildland fires, the  Forest Service is by far the most significant in terms of the broad range of  forest activities that it is responsible for and the public attention it receives.  Compared with the other federal land management agencies in fiscal years  2001 and 2002, the Forest Service received more than half of all funding  provided for forest fuels reduction activities.  For these fiscal years, the  Congress provided the Forest Service with $414 million for reducing  hazardous fuels—the other land management agencies received $381  million combined.
The Forest Service is responsible for managing over 192 million acres of  public lands—nearly 9 percent of the nation’s total surface area and 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 nine regional offices, 155 national forests, 20 grasslands,  and over 600 ranger districts (each forest has several districts).  Figure 1  shows a map of the national forests and Forest Service regions.
The National Environmental Policy Act requires the Forest Service, and all  other federal agencies, to assess and report on the likely environmental  impacts of any land management activities they propose that significantly  impact environmental quality.  For example, certain proposed Forest  Service activities, such as fuels reduction projects, timber sales, and  grazing allotments, may require such environmental analysis and reporting.  More specifically, if a proposed activity is expected to significantly impact  the environment, the Forest Service is required to prepare an  environmental impact statement.  If, however, a proposed activity is  unlikely to have a significant effect on the environment, the Forest Service  is not required to prepare an environmental impact statement—such  activities are classified as categorical exclusions.  When the Forest Service  is not sure whether an activity will have a significant impact on the  environment, the agency prepares an intermediate-level analysis called an  environmental assessment.  If an environmental assessment determines  that the activity will significantly affect the environment, the Forest Service  prepares an environmental impact statement.  (See fig. 2).
Under certain circumstances, the public has a right to administratively  appeal Forest Service decisions.These appeals must be evaluated by the  Forest Service within prescribed time frames and could result in decisions  being reversed and the associated land management activities being  substantially revised or even cancelled.  Generally, the public can appeal  decisions associated with environmental impact statements or  environmental assessments.  Decisions associated with categorical  exclusions are generally not appealable.  Further, as a general rule, once  the administrative appeals process is complete, the public can litigate any  decision, including categorical exclusions, in federal court.
Controversy has surrounded this issue for some time.  On the one hand,  critics have asserted that administrative appeals and litigation are stopping  or unnecessarily slowing the decision-making processes of the Forest  Service and their efforts to reduce forest fuels on federal lands.  They  expressed the view that many appeals are “frivolous” and brought for the  purpose of frustrating, rather than improving, land management actions,  and that they greatly increase the costs of managing the national forests.  Supporters of the current process, on the other hand, have responded that  appeals have not been excessive or unwarranted, that few appeals are  frivolous, and that the current process for handling appeals is adequate.  Supporters further assert that the Congress intended the federal land  management process to include administrative reviews of agency decisions  to (1) ensure public participation in the decision-making process and (2)  ensure that agency managers adequately consider the various factors and  policies impacting the environmental health of the nation’s lands.
Recent administrative rule changes and legislative proposals modify or  would modify the current appeals process and exempt certain projects  from the process.  In August 2002, the administration announced the  Healthy Forest Initiative, which has been controversial as well; some  regarding it as an effort to reduce unnecessary red tape and needless delays  and others considering it a tool to increase logging activity.  The initiative is  intended to help reduce the threat of catastrophic wildfires and improve  the health of the national forests by, among other things, streamlining the  planning and appeals processes.  In particular, recent administrative rule  changes modify the appeal procedures and establish new categorical  exclusions for certain fuels reduction projects.  The Congress is also  considering legislation to, among other things, exempt certain fuels  reduction activities from the existing appeal requirements.  The bill would  require the Secretary of Agriculture to issue regulations establishing a  separate administrative process to address disputes concerning these  projects.
The debate surrounding the Healthy Forest Initiative centers on the extent  and frequency of appeals and litigation of fuels reduction activities.  However, because the Forest Service does not have a national database to  track both its decisions involving forest fuels reduction activities and the  extent to which they were appealed or litigated, we were asked to develop  this information.  The information in this report provides these data for  fiscal years 2001 and 2002.
section_title: The Number of Decisions Involving Forest Fuels Reduction Activities and the Number of Acres Affected
paragraphs: For fiscal years 2001 and 2002, the national forest managers reported that  there were 818 decisions involving forest fuels reduction activities.  These  decisions affected almost 4.8 million acres of national forest land.  Most of  these decisions were excluded from detailed environmental impact  analysis because the Forest Service determined that they had little or no  significant impact on the land.
subsections: section_title: Number of Decisions
paragraphs: Of the 818 decisions involving forest fuels reduction activities, the forest  managers reported that 52 of the decisions (about 6 percent) were  expected to have significant environmental impacts, thus requiring the  preparation of environmental impact statements.  About 280 of the  decisions (about 34 percent) initially had the potential for some  environmental impact and required the preparation of environmental  assessments.  All of the remaining decisions (486 or about 59 percent)  involved activities that had no or only minor environmental impacts and, as  such, were categorically excluded from documentation in an  environmental assessment or an environmental impact statement.
In reporting these data, it is important to emphasize that the Forest Service  does not have a uniform definition of a fuels reduction activity.  The lack of  a uniform definition is an important limitation because it could affect the  consistency of the data reported to us by the national forests in terms of  which activities are identified as fuels reduction projects.  Accordingly, if  the supporting Forest Service decision documents explicitly stated that the  purpose of the activities was fuels reduction, we accepted the decision.  However, if the decision documents did not include an explicit discussion  of fuels reduction, we did not accept the decision.  Many activities have the  practical effect of reducing forest fuels, but the purpose may be for  something other than fuels reduction.  For example, a tree thinning activity  may reduce fuels, but the stated purpose of the project may be to treat an  insect infestation.  If so, fuels reduction would not be a designated purpose  of the activity, and the decision was not included in our analysis.  In  addition, a commercial timber harvest will reduce fuels by removing trees,  but the stated purpose may be commodity production.  If so, the decision  was not included in our analysis.  If the commercial timber sale or thinning  activities included a stated purpose of reducing fuels, the decision was  included in our analysis.
Amount of Acreage Affected	 The forest fuels reduction decisions for fiscal years 2001 and 2002 covered  almost 4.8 million acres of national forest land.  Of the 4.8 million acres, the  forest managers reported that 0.3 million acres (about 7 percent) involved  activities that were expected to have significant environmental impacts,  thus requiring the preparation of environmental impact statements.  About  1.5 million acres (about 31 percent) involved activities that initially had the  potential for some environmental impact and required the preparation of  environmental assessments.  All of the remaining acreage (3.0 million or  about 62 percent) involved activities that had no or only minor  environmental impacts and, as such, were categorically excluded from  preparation of a detailed environmental impact analysis.
There are a few limitations to the acreage data.  The 4.8 million acres does  not correspond to the number of acres actually treated in fiscal years 2001  and 2002.  Once a decision is made and documented, there are many  reasons that activities covered by decision may be delayed or not  implemented, including funding availability, personnel availability, weather  conditions, and administrative appeals or litigation.  In addition, the  national forests may have submitted more than one decision with activities  on the same area of land.  Therefore, the 4.8 million acres may include  overlapping acreage.  Further, the national forest managers reported  decisions involving personal firewood activities, including one large  project from the Tonto National Forest in Arizona that could potentially  skew the acreage data.  Under the personal firewood program, forest  managers designate areas where the public can obtain a wood cutting  permit and gather firewood for personal use.  Forest managers can identify  all of the acreage available for firewood removal under this program as  fuels reduction activities.  However, it is possible that the public may  collect only firewood that is easily accessible, such as near roads and trails,  rather than covering the entire designated area.  One decision from the  Tonto National Forest in Arizona designates 1 million acres as eligible for  firewood removal.  These 1 million acres are 21 percent of the total acreage  reported as treated or planned to be treated for fuels reduction activities  for all national forests.  According to Forest Service officials, it is unlikely  that the public will remove fuels from all 1 million acres.
Table 1 shows the number of decisions with forest fuels reduction  activities, the amount of acreage affected, and their environmental impact  significance.
section_title: The Number of Decisions Involving Forest Fuels Reduction Activities Appealed and Litigated and the Amount of Acreage Affected
paragraphs: Of the 818 decisions involving forest fuels reduction activities, 24 percent  were appealed.  However, more than half were not subject to appeal  because they were categorically excluded from documentation in an  environmental impact statement or environmental assessment.  Overall, of  the 818 total decisions, 332 were appealable because they had  environmental impacts that were either uncertain or significant and  required the preparation of an environmental assessment or environmental  impact statement.  Of these 194 (58 percent) were appealed.  These  appealed decisions affected about 950,000 acres.  In addition, 25 decisions  (about 3 percent of all decisions) were litigated.  The litigated decisions  affected about 111,000 acres.
subsections: section_title: Number of Decisions and Amount of Acreage Appealed
paragraphs: In fiscal years 2001 and 2002, 486 (59 percent) of all decision involving fuels  reduction activities were not subject to appeal. The remaining 332  decisions involved forest fuels reduction activities that were generally  more controversial because they were expected to have significant  environmental impact or initially had the potential for significant  environmental impacts.  Of the 332 appealable decisions, 194 were  appealed affecting over 950,000 acres.  Table 2 summarizes the number of  decisions appealed by decision type and the number of acres affected.
In reviewing the appeals data in table 2, it is important to point out that  many types of land management activities may be analyzed and included as  part of one decision.  A single decision may include activities such as  timber sales, road construction, grazing permits, and habitat improvement  in addition to fuels reduction activities.  As a result, when an appeal is  pursued, it may or may not be based on concerns about fuels reduction  activities.  Under the Forest Service appeal regulations, the entire decision  is appealed, not the individual activities.  Therefore, the public may object  to only one activity in a decision but all land management activities covered  by the decision will be affected by an appeal.  For example, a single  decision may contain activities involving commercial thinning, prescribed  burning, stream improvements, road construction, and a trail closure.  An  appellant may object to the road construction activity but not the forest  thinning activities.  However, all of the activities covered by a decision will  be affected until the appeal is resolved.
There is no limit to the number of appeals that can be filed on an individual  decision.  In total, appellants filed 285 appeals on the 197 appealed  decisions.  One hundred and thirty-four decisions had 1 appeal, 48  decisions had 2 appeals, 10 decisions had 3 appeals, 3 decisions had 4  appeals, 1 decision had 5 appeals, and 1 decision had 8 appeals.
Appendix III provides information on appeal rates for each Forest Service  region.
section_title: Number of Litigated Decisions with Fuels Reduction Activities and Acreage Affected
paragraphs: All decisions can be litigated.  In fiscal years 2001 and 2002, 25 decisions  (about 3 percent) were litigated. These litigated decisions affected about  111,000 acres (about 2 percent).  Not surprisingly, decisions with significant  environmental impacts were litigated more often.  Of the 52 decisions  where the Forest Service was required to prepare environmental impact  statements, 15 (29 percent) were litigated.  Table 3 provides a summary of  the decisions litigated and the acres affected by the litigation.
Appendix III provides information on the number of litigated decisions, by  Forest Service region.
section_title: Outcomes of Appealed and Litigated Decisions and the Identities of Appellants and Plaintiffs
paragraphs: Of the 197 appealed decisions the Forest Service reviewed, 144 (about 73  percent) were allowed to be implemented without any changes.  However,  the Forest Service did not allow 38 decisions (about 19 percent) to be  implemented.  The Forest Service required the remaining 15 decisions  (about 8 percent) to be changed prior to implementation.  Of the 25  litigated decisions, 19 have been resolved and 6 were still ongoing at the  time of our review.  Most of the appellants and plaintiffs were interest  groups.
subsections: section_title: Outcomes of the Appeals and the Identities of Appellants
paragraphs: Generally, appealed decisions have one of three outcomes.  First, the  Forest Service can allow a decision to be implemented without any  changes.  Second, the Forest Service can allow a decision to be  implemented, but only if certain, specified changes are made.  Third, the  Forest Service can prevent a decision from being implemented.  There are a  variety of factors that can affect the disposition of an appeal and lead to  these outcomes.  Each of these factors is specified in Forest Service  regulations.  Some of these factors are procedural and have little or nothing  to do with the merit of an appeal, and some are based on the merit of the  appeal.  Table 4 provides a brief summary of the three basic decision  outcomes and an explanation of the factors that can lead to various appeal  outcomes.
Figure 3 shows the disposition of each of the 197 appealed decisions for  fiscal years 2001 and 2002.
Decisions proceed with changes (15)
Decisions do not proceed (38)
Appendix IV provides a summary of the appeal outcomes, by region.
Under certain circumstances, members of the public, including private  individuals and interest groups, can appeal decisions of Forest Service  officers.A decision can be appealed multiple times and multiple  appellants can be parties to an appeal.  For example, the Little Blacktail  Ecosystem Restoration Project Record of Decision issued in the Kaniksu  National Forest in Idaho had three appeals; the Ecology Center, Lands  Council, Kootenai Environmental Alliance, and Friends of the Pond joined  in one appeal; the Alliance for the Wild Rockies filed another appeal; and a  private individual filed the third appeal.  In these instances, each interest  group and the private individual counted as appellants—6 total  appellants—even though they were appealing 1 decision and had filed 3  appeals.  Due to these situations, there were 285 appeals on the 197  appealed decisions.  The 285 appeals had 559 appellants.  The 559  appellants included 482 appeals by 85 different interest groups, mostly  environmental groups, and 77 appeals by 53 private individuals.  Table 10 of  appendix V lists each interest group that appeared as an appellant in fiscal  years 2001 and 2002 and the number times they appeared.  Of the interest  groups, 7 appeared as appellants 20 or more times.  These groups include  the Alliance for the Wild Rockies, Ecology Center, Forest Conservation  Council, Lands Council, National Forest Protection Alliance, Oregon  Natural Resources Council, and Sierra Club.
section_title: Outcomes of Litigated Decisions and the Identities of Plaintiffs
paragraphs: Following a final decision by the Forest Service on an appeal, members of  the public, can file a lawsuit and seek a review of the decision from a  federal district court.  Plaintiffs are usually the same parties who  previously appealed the decisions with the Forest Service.  It may take  weeks to years to resolve a case once a decision is litigated.  Of the 25  litigated decisions, 6 were continuing at the time of our analysis.  For the  remaining 19 cases, lawsuits for 5 decisions were dismissed because the  plaintiffs and the Forest Service agreed to settle their claims.  District  courts reached an outcome on the 14 remaining decisions—9 decisions  were decided favorably to the plaintiffs, and 5 decisions were decided  favorably to the Forest Service.  Both plaintiffs and the Forest Service have  the option of appealing the decisions of the district court to the relevant  federal court of appeals.  We did not collect information on whether the  decisions were appealed to a higher court.
Appendix V provides information on the outcomes of litigated decisions, by  region.
Multiple plaintiffs can be parties to a lawsuit.  Of the 25 litigated decisions,  26 different interest groups and one private individual were plaintiffs.  The  interest groups were primarily environmental groups.  Five groups were  plaintiffs in 4 or more decisions:  the Ecology Center, Sierra Club, Oregon  Natural Resources Council, Hell’s Canyon Preservation Council, and Native  Ecosystems Council.
section_title: The Number of Decisions That Were Processed Within Prescribed Time Frames
paragraphs: Most of the appeals that occurred in fiscal years 2001 and 2002 were  processed within the prescribed time frames.  Specifically, of the 285  appeals that were filed, about 79 percent were processed within the  prescribed 90 days.
The applicable laws and regulations establish procedures for public notice  of a decision and the time frames for appeal. Once the public is given  notice of a decision, appellants have 45 days to file an appeal.  If an appeal  is filed, the Forest Service has 45 days from the close of the appeal period  to determine the outcome of the appeal.  In total, the Forest Service has up  to 90 days to resolve an appeal once the agency notifies the public of a  decision.  While the agency is determining the disposition of an appeal, a  Forest Service official is required to contact an appellant and offer to meet  informally to dispose of the appeal. Figure 4 provides a flowchart showing  the appeals process that applied during fiscal years 2001 and 2002.
Of the 285 appeals filed in fiscal years 2001 and 2002, 226 (79 percent) were  processed within 90 days of the date that the decisions were made and  published.  In contrast, 59 appeals (about 21 percent) were not processed  within 90 days.  For those appeals that were not processed within the 90- day limit, the appeal processing times ranged from 91 to 240 days, with a  median processing time of 119 days. The Forest Service offered several  reasons for not processing the 59 appeals within the 45-day formal  disposition period.  These reasons included inadequate staffing, the  unavailability of staff around the holiday season, and appeal backlog.  We  did not verify or analyze the support for the reasons that the Forest Service  provided.
Further, to fully understand the appeals process, it is important to  understand that under certain circumstances, appellants may have more  than one opportunity to appeal a decision.  Once a decision is reversed or  withdrawn by the Forest Service as a result of an appeal, the agency can  revise and reissue the decision.  This is usually done to accommodate  concerns that have been raised during an initial appeal.  Moreover, the  Forest Service also has the option of not reissuing the decision.  In our  analysis, 32 decisions had been reissued.  Of those reissuances, 30 were  appealed again and 2 were implemented without appeal.  Once a decision is  reissued, the permitted processing times for handling appeals begin again.
Appendix VII provides a summary of the appeals processing times for each  Forest Service region.
section_title: The Types of Fuels Reduction Treatment Methods Identified in the Decisions, the Acreage Affected, and How Frequently These Decisions Were Appealed
paragraphs: Reducing the buildup of vegetation that fuels severe fires requires  vegetation management, or fuels reduction. There are four basic fuels  treatment methods. These are prescribed burning, mechanical thinning,  the application of chemicals/herbicides, and grazing.  Prescribed burning is  the most frequently used method to reduce the accumulation of dangerous  fuels on forested acres.  Decisions involving the two main types of fuels  treatment methods, prescribed burning and mechanical treatment, were  appealed at about the same rate.
subsections: section_title: Frequency of Use and Scope of Treatment Methods
paragraphs: A prescribed fire is one that is intentionally ignited to meet specific land  management objectives.  In addition to reducing the risk of wildfires,  prescribed fires also are used to prepare areas for reforestation or to  improve wildlife habitat.  How and when a prescribed fire can be  successfully conducted is influenced by many conditions, such as the type  and moisture levels of vegetation, topography, temperature, wind speed,  and humidity.  All of these factors are to be considered and documented by  fire management personnel prior to initiating a prescribed burn.  Figures 5  and 6 show examples of a prescribed burn.
Prescribed burning was the most frequently used fuels treatment method  during fiscal years 2001 and 2002—in terms of both the number of  decisions that included prescribed burning activities and the number of  acres affected.  Of the 818 decisions with fuels reduction activities, 570  (about 70 percent) included prescribed burns.  Of the total 4.8 million acres  covered by all decisions, 3.2 million acres (about 67 percent) had been or  were to be treated using this method.
There is a range of mechanical treatments that can be used to reduce forest  fuels.  Harvesting timber and removing smaller noncommercial trees and  brush can accomplish fuels reduction.  In addition, thinning stands of trees  to reduce competition for light, moisture, and nutrients may improve forest  health.  Mechanical thinning is typically done using power equipment, such  as bulldozers, chain saws, chippers, and mulchers.  Figures 7 and 8 show  examples of mechanical thinning projects.
Mechanical thinning is the second most utilized method for reducing forest  fuels.  Of the 818 decisions with fuels reduction activities, 491 (about 60  percent) included mechanical treatment methods.  These treatments  involved 0.8 million acres—about 17 percent of all the acreage treated or  planned for treatment in fiscal years 2001 and 2002.
Chemical treatments are herbicides used to control and remove the  hazardous buildup of forest vegetation.  Herbicides are usually applied as  liquids mixed with water or oil and then sprayed on the soil surface to be  absorbed by the plant roots.  Generally, there are four methods of applying  herbicides: (1) aerial application, using helicopters or other aircraft; (2)  mechanical equipment, using truck-mounted or truck-towed wand or  broom sprayers; (3) backpack equipment, generally a pressurized container  with an agitation device; and (4) hand application by injection, daubing cut  surfaces, or application of granular formulations to the soil.
Grazing animals, such as cattle and goats, can also be used to reduce the  buildup of hazardous forest fuels.  However, grazing is less utilized because  it is increasingly competing with other uses of public lands, such as  recreation, wildlife habitat, riparian management, endangered species  management, mining, hunting, cultural resource protection, wilderness,  and a wide variety of other uses.
Chemical treatments and grazing are the least utilized treatment methods.  Of the 818 fuels reduction decisions reported, 3 (less than 1 percent)  included chemical/herbicide treatments, and 2 (less than 1 percent)  included grazing.  These two types of treatment methods affected about  700 acres—less than 1 percent of the total acres treated or planned for  treatment in fiscal years 2001 and 2002.
In addition to the four basic hazardous fuels treatment methods, there are  other methods that are sometimes used.  These other methods include  activities such as cutting underbrush by hand or the public’s removal of  firewood by hand.  One hundred and twelve (14 percent) of all fuels  reduction decisions in fiscal years 2001 and 2002 included these other kinds  of treatments.  However, while the use of the other methods was relatively  infrequent, the amount of acreage affected was considerable—mostly due  to the 1 million acre personal fire wood removal program from the Tonto  National Forest in Arizona.  There are two important points that need to be  highlighted regarding this fire wood removal program.  First, while the  project covers 1 million acres, it does not necessarily mean that firewood  will be removed from all of these acres.  It simply means that these acres  are available for the removal of firewood.  Accordingly, the extent of fuels  reduction on these acres is not clear.  It is possible that the number of acres  actually reported for the project can be significantly overstated.  Second,  even though officials at the Tonto National Forest reported this as part of  the forest fuels reduction program, Forest Service headquarters officials  questioned the merit of including it in our report because they believed it  skewed the data by increasing the amount of acreage having fuels  reduction activities.  In the final analysis, we reported this project as a fuels  reduction activity because the Tonto forest officials identified it as such in  their decision documents.  Table 5 summarizes the fuels reduction methods  used by the Forest Service in fiscal years 2001 and 2002.
The columns in the table 5 do not add to the total number of decisions  (818) or the total amount of acreage affected (4.8 million).  This occurs for  two reasons.  First, a decision can include prescribed burning on some  acreage and another treatment method on other acreage.  Second, the same  acreage can be treated by more than one method.  For example, an area can  be thinned using prescribed burning and then be further thinned using  mechanical means.  Forest managers reported that 280 decisions with fuels  reduction activities included acres treated or planned for treatment by both  prescribed burning and mechanical methods.
section_title: Rate of Appeals for Each Type of Fuels Treatment Method
paragraphs: Appeal rates for the two main types of treatments, prescribed burning and  mechanical, were about the same.  Appealable decisions with a mechanical  treatment component were appealed about 64 percent of the time.  Appealable decisions with prescribed burning activities were appealed at  about the same rate—63 percent of the time.  Similarly, 34 percent of all  decisions with mechanical treatment methods were appealed, and 29  percent of all decisions with prescribed burning activities were appealed.  Table 6 provides a summary of the appeal rates for decisions with the  different treatment methods.
An analysis of the data shown in table 7, on the basis of the amount of  acreage affected, shows that decisions with prescribed burning covered the  most acreage appealed.
Appendix VIII provides data on treatment methods and appeal rates, by  Forest Service region.
section_title: Types of Contracts Used in Decisions with Fuels Reduction Activities and How Frequently Decisions Involving the Contract Types Were Appealed
paragraphs: Typically, the Forest Service contracts with other organizations to carry out  fuels reduction activities in the national forests.  In doing this, the agency  generally uses three types of contracting mechanisms—timber sale  contracts, service contracts, and stewardship contracts.  A decision can  use more than one type of contract to carry out fuels reduction activities.  The Forest Service awards timber sale contracts to individuals or  companies to harvest and remove trees from federal lands under its  jurisdiction.  Service contracts are awarded to contractors by the Forest  Service to perform specific tasks to reduce forest fuels, such as thinning  trees or clearing underbrush.  Stewardship contracts are used by the Forest  Service to conduct on-the-ground restoration and enhancement of  landscapes with public and private entities.  Service contracts are the most  frequent contracting method used.  Decisions using timber sale contracts  and stewardship contracts are the most frequently appealed.
subsections: section_title: Types of Contracts Used in Decisions with Fuels Reduction Activities
paragraphs: Forest Service timber sale contracts set forth specific terms and provisions  of a sale, including the estimated volume of timber to be removed, the time  period of the removal, the price to be paid to the government, and the  environmental protection measures to be taken.  Of the 818 total fuels  reduction decisions, 278 (34 percent) involved timber sale contracts.
The Forest Service also uses traditional service contracts to reduce the  accumulation of fuel loads.  Typically, a service contract identifies the tasks  to be performed, such as removing and treating the unmarketable, cut  materials.  The cut materials affect the fuel loads and can be left as is, piled  and burned, lopped and scattered to accelerate rotting, or removed from  the site.  Of the 818 total fuels reduction projects, 356 (44 percent) of the  decisions involved service contracts.
Stewardship contracts use a combination of service contracts and timber  sale contracts to care for national forest system land.  In 1998, the Forest  Service was given stewardship contracting authority so that the agency  could work with private and public entities to achieve federal management  goals. For example, this authority provided the Forest Service with the  ability to trade goods for services (such as timber in exchange for road  maintenance). A stewardship contract might include prescribed burning to  improve wildlife habitat or reduce forest fuels in conjunction with the sale  of forest products off the same piece of land.  Of the 818 total fuels  reduction decisions, 41 (5 percent) of the decisions involved stewardship  contracts.
Figure 9 shows the frequency of service, timber sale, and stewardship  contracts used in decisions with fuels reduction activities.
The total number of decisions in figure 9 does not total 818 because there  are also other means used to implement fuels reduction activities.  Forest  Service personnel are frequently used to perform the needed work.  Typically, Forest Service personnel are used in conjunction with different  contract types.  Of the 818 decisions, 673 (82 percent) involved some work  by Forest Service personnel.  Further, other means, such as contracts that  utilize prison labor and contracts that collaborate with other federal  agencies like the Bureau of Land Management, are also used to help reduce  forest fuels.  Eighty-three (10 percent) of all 818 decisions with fuels  reduction activities used these other mechanisms.
section_title: Appeal Rates for Decisions with Each Contracting Mechanism
paragraphs: Decisions that are implemented through the use of timber sale contracts  and stewardship contracts were the most frequently appealed.  Because of  the controversy that surrounds timber harvesting activities and their  impact on the environment, it is not surprising that contracts for this type  of activity would be scrutinized and challenged by the forest interest  groups or other stakeholders.
Appendix IX summarizes the contracting methods used and appeal rates,  by Forest Service region.
section_title: Number of Decisions with Fuels Reduction Activities in the Wildland-Urban Interface and Inventoried Roadless Areas and How Frequently the Decisions Were Appealed
paragraphs: Two areas of particular interest on national forest land where fuels  reduction activities can occur are in the wildland-urban interface and  inventoried roadless areas.  The wildland-urban interface areas are those  areas where federal lands surround or are adjacent to human development  and communities.  In contrast, inventoried roadless areas are undeveloped  areas with no or few roads.  Fuels reduction activities occur more on  wildland-urban interface areas than in inventoried roadless areas.  Of the  818 decisions involving fuels reduction activities, 462 decisions had  activities in the wildland-urban interface and 76 decisions had activities in  inventoried roadless areas.  Decisions with fuels reduction activities in the  inventoried roadless areas are appealed more frequently.
subsections: section_title: Decisions with Fuels Reduction Activities in the Wildland-Urban Interface and Appeal Rates
paragraphs: The Forest Service broadly defines the wildland-urban interface as areas  where humans and their development meet or intermix with wildland  forest fuels.  There are three categories of communities that meet its  definition:  (1) an interface community exists where structures directly  abut wildland fuels; (2) an intermix community exists where structures are  scattered throughout a wildland area; and (3) an occluded community  exists, often within a city, where structures abut an island of wildland fuels,  such as a park or open space.  Figure 10 shows an example of a  community in the wildland-urban interface.
Individual forest managers may or may not use the definition of wildland- urban interface that the Forest Service provides.  According to the  information provided by the national forests in response to our survey,  most forest managers reported that they used the Forest Service’s  definition or they developed their own definition.  Other managers reported  that they either did not have a definition or did not know if they had a  definition.  The inconsistent application of these definitions by forest  managers should be considered when using the information reported about  whether fuels reduction activities were in the wildland-urban interface.  An  August 2003 GAO report highlighted the fact that agencies need to define  which lands are part of the wildland-urban interface. Without doing so,  the Forest Service will be constrained in its ability to prioritize locations for  fuels reduction treatments and to allocate funding accordingly.  We  recommended in the August report that the Forest Service develop a  consistent, specific definition of the wildland-urban interface so that  detailed, comparable nationwide data could be collected to identify the  amount and location of lands in the wildland-urban interface.  Development of a consistent definition will facilitate the prioritization of  fuels reduction treatments.
Of the 818 decisions with fuels reduction activities, the national forest  managers reported 462 decisions (57 percent) had fuels reduction activities  in the wildland-urban interface.  Of these 462 decisions, 169 were  appealeable—that is, they were decisions analyzed in conjunction with  environmental assessments or environmental impact statements.  Of the  169 appealable decisions, 89 were appealed—that is, 53 percent of  appealable decisions and 19 percent of all decisions with fuels reduction  activities in the wildland-urban interface.
The 462 decisions covered 1.5 million acres—that is, 31 percent of the total  acreage (4.8 million) for all reported fuels reduction activities.
section_title: Decisions with Fuels Reduction Activities in Inventoried Roadless Areas and Appeal Rates
paragraphs: Inventoried roadless areas, as the name implies, are undeveloped areas  generally without roads, which the Forest Service has specifically  defined. The intent of the roadless designation is to conserve these  natural areas by limiting road building and logging activities.  Figure 11 shows an example of an inventoried roadless area on national forest land.
In contrast to the wildland-urban interface areas, roadless areas have  specific boundaries, which make it much easier for forest managers to  report on decisions with treatments in these areas.  Of the 818 decisions,  the national forests reported 76 decisions—about 9 percent of all  decisions—with fuels reduction activities in roadless areas.  Of these 76  decisions, 41 were appealable and 26 were appealed—that is, 34 percent of  all decisions with treatments in roadless areas and 63 percent of appealable  decisions.
The 76 decisions covered 240,000 acres—about 5 percent of all acreage  treated or planned for treatment in fiscal years 2001 and 2002.
Appendix X provides information on the number of decisions involving  fuels reduction activities in the wildland-urban interface and inventoried  roadless areas and the frequency of appeals for each Forest Service region.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Forest Service for review and  comment.  The agency generally agreed with the information presented in  the report.  However, the agency did offer a few comments that it believed  would help clarify some of this information.  Specifically, the Forest  Service believes that we should not have included information on a 1  million acre personal use firewood program at one forest because, in their  opinion, doing so unnecessarily skews the data by increasing the amount of  acreage with fuels reduction activities.  We did not change the report to  omit this information because, as the Forest Service agrees, it was reported  and documented as a fuels reduction project by the agency.  Nonetheless,  to ensure clarity, we highlighted in the report the unique nature of the  project, where appropriate.
The agency suggested that we highlight the fact that a single decision can  be appealed multiple times, and that the Forest Service’s workload  increases accordingly.  In its comments, the agency commented that we  should provide additional information on that point in the body of the  report to emphasize the impact of multiple appeals on the workload of the  agency.  We believe this point was already addressed in the body where we  noted that there were 285 appeals on the 197 appealed decisions.  In  addition, we also provided a breakdown of the number of appeals per  decision.  Nonetheless, we did add language to the Results in Brief section  of the report and the Highlights section, noting that decisions can be  appealed multiple times.
The Forest Service also commented that because appeal rates vary widely  throughout the nation, we should add language in the narrative regarding  local perceptions of appeal rates and how they can differ from the national  data.  The agency noted that when local groups or individuals state that  many projects are held up by appeals, they are more likely referring to their  experience at the local level.  We believe the information needed to discern  regional differences was already presented in the report; therefore, we did  not make changes to the report.
The Forest Service’s written comments are presented in appendix XII.
As arranged with your offices, unless you publicly announce its 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 to the Secretary of  Agriculture, the Chief of the Forest Service, and other interested parties.  We will make copies available to others upon request.  This report will also  be available on the GAO Web site 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 were Cliff Fowler, Curtis  Groves, Richard Johnson, Roy Judy, Nicole Shivers, Patrick Sigl, and Shana Wallace.
section_title: Scope and Methodology
paragraphs: The Forest Service does not maintain its own database on the number of  decisions or appeals throughout the national forest system.  Accordingly, to  address each of the objectives, we had to develop a national database.  To  do this, we used a Web-based survey of all 155 national forests.  The survey  focused on all Forest Service decisions in fiscal years 2001 and 2002 with a  forest fuels reduction component, including those that were categorically  excluded from preparation of an environmental impact statement, that  were issued in fiscal years 2001 and 2002. The specific information we  needed to satisfy our objectives was located at several organizational  levels—headquarters, regional offices, individual forests, and district  offices within each forest.  For instance, information on the individual  decisions, particularly the environmental impact statements and  environmental assessments, was located at the forest-level.  Information on  categorical exclusions was primarily located only at the district offices.  Our survey was addressed to forest supervisors.  We asked forest  supervisors to gather the necessary information from the other  organizational units within the Forest Service, as needed, to complete the  survey.  We also asked each forest supervisor for a contact person at the  forest who was familiar with the National Environmental Policy Act  process requirements, since it guides land management decision-making  and planning activities.  This contact person served as our focal point at  each forest and was responsible for providing us with survey responses and  addressing the follow-up questions and documents that we requested.
We developed a data collection instrument to obtain the relevant  information.  Appendix XI contains a copy of the instrument used to gather  these data.  To help us understand the decision-making and appeals and  litigation processes and to help us formulate the questions for our survey  instrument, we met with Forest Service personnel at headquarters in  Washington, D.C.; the region 5 office in Vallejo, California; the Stanislaus  and Tahoe National Forests in California; and the George Washington and  Jefferson National Forests in Virginia.  Once we developed the questions,  we pretested the instrument at the Kootenai National Forest in Montana,  the Payette and Boise National Forests in Idaho, and the Monongahela  National Forest in West Virginia.
We gave the forests 3 weeks to respond to the survey and granted  extensions as needed.  We obtained a 100 percent response rate from the  forest managers.  We verified the accuracy of about 10 percent of the  survey responses submitted.  We used a random number to identify the first  decision to be verified and then selected every 10th decision submitted by  the forests.  After selecting a decision, we obtained the supporting decision  documents, National Environmental Policy Act documents, and appeals  information from the forests and verified the information submitted for the  randomly selected decisions. Using this approach, we verified 85 total  decisions.  Any discrepancies between the survey responses and our data  verification were discussed and resolved with the responsible forest  official.  Through our data verification process, we determined that the  data submitted were generally reliable.
In addition to our verification of the information supporting the 85  randomly selected decisions, we also reviewed the data to determine  whether there were any aberrations in the submitted data (e.g., illogical  dates or inconsistent responses).  We contacted the appropriate forest  officials and corrected many aberrations in the data.  As a result of our  review and verification, we identified 42 decisions that were eliminated  from the information provided by the forest managers.  These decisions  were eliminated for a variety of reasons.  For example, the decisions (1)  were not issued within fiscal years 2001 and 2002 or (2) lacked clear  documentation that the activities had a fuels reduction purpose.
There are some limitations to the data we gathered.  As with any survey, the  information obtained from the national forests was self-reported, and we  were not able to independently ensure that all decisions were reported.  In  particular, we had no way to determine if forests were underreporting their  activities.  To get some indication of whether this might be occurring, we  contacted eight environmental groups to review the decisions submitted by  selected forests in order to determine if there was any indication that the  forests were underreporting decisions. These groups did not identify any  instances of underreporting.
We conducted our work from September 2002 through September 2003 in  accordance with generally accepted government auditing standards.
section_title: Decisions and Acres, by Forest Service Region
paragraphs: The Forest Service consists of nine regions.  Figure 12 highlights the areas  covered by each region.  The Southern Region (region 8) had the largest  number of decisions with fuels reduction activities (180 decisions) with the  largest planned acreage—2.1 million acres.  The Alaska Region (region 10)  listed the least number of decisions with fuels activities (2) and the least   12 provides a summary of the  amount of acreage—1,408 acres.   number of decisions and acres planned in each Forest Service region.
section_title: Forest Service Appeals and Litigation of Decisions with Fuels Reduction Activities, by Forest Service Region
paragraphs: Figure 13 summarizes the appeals and litigation information by each Forest  Service region.  The Northern Region (region 1) had the highest appeal rate  for both all decisions and appealable decisions appealed.  The Northern  Region (region 1) had 48 percent of all decisions appealed and 90 percent  of appealable decisions appealed.  The Alaska Region (region 10) had no  decisions appealed.  The Southern Region (region 8) had the lowest appeal  rates for regions with recorded appeals—7 percent of all decisions and 36  percent of appealable decisions.  The Northern Region (region 1) had the  highest number of litigated decisions with 8.  The Southwestern (region 3),  Southern (region 8), and Alaska (region 10) Regions did not report any  litigated decisions with fuels reduction activities.
section_title: Appeal Outcomes for Decisions with Fuels Reduction Activities, by Forest Service Region
paragraphs: Figure 14 summarizes the appeal outcomes for decisions with fuels  reduction activities by Forest Service region.  All of the decisions in the  Southern Region (region 8) were permitted to proceed without changes.   The Eastern Region (region 9) had the lowest percentage of decisions that  were allowed to proceed without changes—50 percent.   hwestern  Region (region 3) had the highest percentage of decisions that were not  allowed to proceed due to appeals—38 percent.
section_title: Litigation Outcomes for Decisions with Fuels Reduction Activities, by Forest Service Region
paragraphs: Table 9 summarizes the number of litigated decisions and the outcomes for  each Forest Service region.  The Northern Region (region 1) had 8 litigated  decisions and 3 were settled or continuing.  Of those decided, 3 were in  favor of plaintiffs and 2 were in favor of the Forest Service.  The Pacific  Northwest Region (region 6) had all 5 of its litigated decisions resolved—4  in favor of plaintiffs and 1 in favor of the Forest Service.  Three regions—  Southwestern (region 3), Southern (region 8), and Alaska (region 10)—had  no decisions litigated.
section_title: List of Appellants and Litigants for Each Forest Service Region
subsections: section_title: Appellants, by Region
paragraphs: Table 10 provides a list of appellants by Forest Service region.  Interest  groups were most active in the Forest Service’s Northern (region 1), Pacific  Southwest (region 5), and Pacific Northwest (region 6) Regions.  Private  individuals were most active in the Rocky Mountain (region 2) and Pacific  Southwest (region 5) Regions.  Interest groups were the least active in the  Alaska (region 10), Southern (region 8), and the Southwestern (region 3)  Regions.
section_title: Litigants, by Region
paragraphs: Table 11 provides a list of litigants by Forest Service region.  Interest  groups were most active in the Forest Service’s Northern (region 1),  Intermountain (region 4), Pacific Southwest (region 5), and Pacific  Northwest (region 6) Regions.  The Southwestern (region 3), Southern  (region 8), and Alaska (region 10) Regions did not have any decisions  litigated.
section_title: Appeal Processing Time Frames for Decisions with Fuels Reduction Activities, by Region
paragraphs: Figure 15 summarizes the processing time frames for appeals of decisions  for each Forest Service region.  ntain Region (region 2) had The Rocky Mou the highest rate of appeals processed within the 90-day prescribed time  frame at a rate of 100 percent.   he Pacific Northwest Region (region 6) had T a rate below 50 percent by processing 17 of 49 appeals (about 35 percent)  within the 90-day prescribed time frame.
section_title: Fuels Reduction Methods and Appeals, by Forest Service Region
paragraphs: Figure 16 summarizes the fuels reduction methods used and how  frequently decisions with those methods were appealed by Forest Service  region.  The Southern Region (region 8) had the most decisions (166) with  prescribed burn activities.  The Pacific Southwest Region (region 5) had  the most decisions (126) with mechanical treatments.  The Northern  Region (region 1) experienced the highest appeal rates for decisions with  prescribed burning and mechanical treatment activities—95 percent of  appealable decisions and 55 percent of all decisions for prescribed burning;  and 93 percent of appealable decisions and 63 percent of all decisions for  mechanical treatment.
section_title: Types of Contracts Used in Decisions with Fuels Reduction Activities and How Frequently They Were Appealed, by Region
paragraphs: Figure 17 shows a summary of the types of contracts used for  implementing fuels reduction activities and how frequently decisions  involving the contract types were appealed by region.  The Pacific  Northwest Region (region 6) had the most decisions (75) that included  service contracts.  The Pacific Southwest Region (region 5) issued the most  decisions (65) with timber sale contracts.  The Northern Region (region 1)  had the most decisions (14) with stewardship contracts.  The  Intermountain (region 4), Pacific Southwest (region 5), and Eastern (region  9) Regions had all of their decisions with stewardship contracts appealed—  totaling 4 decisions for all three regions.
section_title: Decisions in Wildland-Urban Interface and Inventoried Roadless Areas
paragraphs: Figure 18 summarizes the number of decisions with fuels reduction  activities in the wildland-urban interface (WUI) and frequency of appeals  by region.  The Southern Region (region 8) had the most decisions (125) in  the WUI.  The Northern Region (region 1) had the most decisions (23) that  were appealed.  The highest appeal rate for all decisions (50 percent) was  the Eastern Region (region 9).  The highest rate for appealable decisions  (88 percent) was the Northern Region (region 1).
Figure 19 summarizes the number of decisions with fuels reduction  activities in inventoried roadless areas (IRA) and frequency of appeals by  region.  The Northern Region (region 1) had the most decisions (21) in  IRAs.  e Intermountain Region (region 4) had the most appealed Th decisions (8).  The highest appeal rate for all decisions (50 percent) was in  the Eastern Region (region 9).  The highest appeal rate for appealable  decisions (100 percent) was in the Eastern Region (region 9).
section_title: Survey Questions to National Forests
section_title: Comments from the U.S. Department of Agriculture
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