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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

March 2010: 

Forest Service: 

Information on Appeals, Objections, and Litigation Involving Fuel 
Reduction Activities, Fiscal Years 2006 through 2008: 

GAO-10-337: 

GAO Highlights: 

Highlights of GAO-10-337, a report to congressional requesters. 

Why GAO Did This Study: 

Increases in the number and intensity of wildland fires have led the 
Department of Agriculture’s Forest Service to place greater emphasis 
on thinning forests and rangelands to reduce the buildup of 
potentially hazardous vegetation that can fuel wildland fires. The 
public generally has an opportunity to challenge agency hazardous fuel 
reduction decisions with which it disagrees. Depending on the type of 
project being undertaken, the public can file a formal objection to a 
proposed decision, or can appeal a decision the agency has already 
made. Appeals and objections must be reviewed by the Forest Service 
within prescribed time frames. Final decisions may also generally be 
challenged in federal court. 

GAO was asked, among other things, to determine, for fiscal years 2006-
2008, (1) the number of Forest Service fuel reduction decisions and 
the associated acreage; (2) the number of decisions subject to appeal 
and objection, the number appealed, objected to, and litigated, and 
the associated acreage; and (3) the outcomes of appeals, objections, 
and litigation, and the extent to which appeals and objections were 
processed within prescribed time frames. In doing so, GAO conducted a 
nationwide survey of forest managers and staff, interviewed officials 
in the Forest Service’s regional offices, and reviewed documentation 
to corroborate agency responses. 

GAO requested, but did not receive, comments from the Forest Service 
on a draft of this report. 

What GAO Found: 

Through a GAO-administered survey and interviews, Forest Service 
officials reported the following information: 

* In fiscal years 2006 through 2008, the Forest Service issued 1,415 
decisions involving fuel reduction activities, covering 10.5 million 
acres. 

* Of this total, 1,191 decisions, covering about 9 million acres, were 
subject to appeal and 217—about 18 percent—were appealed. Another 121 
decisions, covering about 1.2 million acres, were subject to objection 
and 49—about 40 percent—were objected to. The remaining 103 decisions 
were exempt from both objection and appeal. Finally, 29 decisions—
about 2 percent of all decisions—were litigated, involving about 
124,000 acres. 

* For 54 percent of the appeals filed, the Forest Service allowed the 
project to proceed without changes; 7 percent required some changes 
before being implemented; and 8 percent were not allowed to be 
implemented. The remaining appeals were generally dismissed for 
procedural reasons or withdrawn before they could be resolved. 
Regarding objections, 37 percent of objections resulted in no change 
to a final decision; 35 percent resulted in a change to a final 
decision or additional analysis on the part of the Forest Service; and 
the remaining 28 percent were set aside from review for procedural 
reasons or addressed in some other way. And finally, of the 29 
decisions that were litigated, lawsuits on 21 decisions have been 
resolved, and 8 are ongoing. Of the lawsuits that have been resolved, 
the parties settled 3 decisions, 8 were decided in favor of the 
plaintiffs, and 10 were decided in favor of the Forest Service. All 
appeals and objections were processed within prescribed time frames—
generally, within 90 days of a decision (for appeals), or within 60 
days of the legal notice of a proposed decision (for objections). 

Table: Summary of Appeals of and Objections to Forest Service Fuel 
Reduction Decisions and Associated Acreage, Fiscal Years 2006-2008: 

Number of decisions: 
Subject to appeal: 1,191; 
Subject to objection: 121; 
Exempt from appeal and objection: 103; 
Total: 1,415. 

Number of decisions appealed or objected to: 
Subject to appeal: 217; 
Subject to objection: 49; 
Exempt from appeal and objection: Not applicable; 
Total: 266. 

Percentage of decisions appealed or objected to: 
Subject to appeal: 18%; 
Subject to objection: 40%; 
Exempt from appeal and objection: Not applicable;
Total: 19%. 

Acreage (in thousands): 
Subject to appeal: 9,143; 
Subject to objection: 1,215; 
Exempt from appeal and objection: 188; 
Total: 10,545. 

Acreage appealed or objected to (in thousands): 
Subject to appeal: 839; 
Subject to objection: 225; 
Exempt from appeal and objection: Not applicable; 
Total: 1,064. 

Percentage of acreage appealed or objected to: 
Subject to appeal: 9%; 
Subject to objection: 19%; 
Exempt from appeal and objection: Not applicable; 
Total: 10%. 

Source: GAO analysis of survey results. 

Note: Numbers may not total due to rounding. 

[End of table] 

View [hyperlink, http://www.gao.gov/products/GAO-10-337] or key 
components. For more information, contact Anu Mittal at (202) 512-3841 
or mittala@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Number and Type of Decisions Involving Hazardous Fuel Reduction 
Activities in Fiscal Years 2006 through 2008 and the Associated 
Acreage: 

Number of Decisions Involving Hazardous Fuel Reduction Activities That 
Were Subject to Appeal or Objection; Number of Decisions Appealed, 
Objected to, or Litigated; and Associated Acreage: 

Outcomes of Appeals, Objections, and Litigation of Decisions with 
Hazardous Fuel Reduction Activities; Associated Time Frames; and 
Identities of Appellants, Objectors, and Plaintiffs: 

Treatment Methods and Contract Types Associated with Fuel Reduction 
Decisions; the Number of Appeals, Objections, and Lawsuits by 
Treatment Method and Contract Type; and the Associated Acreage: 

Decisions Involving Fuel Reduction Activities in the Wildland-Urban 
Interface and Inventoried Roadless Areas; the Number of Appeals, 
Objections, and Lawsuits on Those Decisions; and the Associated 
Acreage: 

Concluding Observations: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Number of Fuel Reduction Decisions and Associated 
Acreage, by Forest Service Region: 

Appendix III: Number of Appeals, Objections, and Lawsuits of Fuel 
Reduction Decisions, by Forest Service Region: 

Appendix IV: Appeal Outcomes for Fuel Reduction Decisions, by Forest 
Service Region: 

Appendix V: Litigation Outcomes for Fuel Reduction Decisions, by 
Forest Service Region: 

Appendix VI: List of Appellants, Objectors and Litigants, by Forest 
Service Region: 

Appendix VII: Fuel Reduction Treatment Methods and Number of Appeals, 
Objections, and Lawsuits, by Forest Service Region: 

Appendix VIII: Contract Types and Number of Appeals, Objections, and 
Lawsuits, by Forest Service Region: 

Appendix IX: Fuel Reduction Decisions in the Wildland-Urban Interface 
and Inventoried Roadless Areas, by Forest Service Region: 

Appendix X: Types of Categorical Exclusions Authorized by the Forest 
Service and Represented in the GAO Survey: 

Appendix XI: Major Litigation Affecting Appeal Procedures for 
Categorical Exclusions: 

Appendix XII: Survey Questions to National Forests: 

Appendix XIII: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Traditional Project Appeals Process Compared with Healthy 
Forests Restoration Act Project Objection Process: 

Table 2: Forest Service Decisions with Fuel Reduction Activities and 
Acreage Affected, by Decision Type, Fiscal Years 2006 through 2008: 

Table 3: Forest Service Decisions with Hazardous Fuel Reduction 
Activities That Were Appealed, Objected to, Exempt, or Litigated, by 
Decision Type, and Associated Acreage, Fiscal Years 2006 through 2008: 

Table 4: Appeals, Objections, Exemptions, and Litigation Associated 
with Various Treatment Methods, and Associated Acreage, Fiscal Years 
2006 through 2008: 

Table 5: Number and Percentage of Appeals, Objections, Exemptions, and 
Litigation Associated with Various Contracting Types, Fiscal Years 
2006 through 2008: 

Table 6: Appeals, Objections, Exemptions, and Litigation of Decisions 
with Fuel Reduction Activities in the Wildland-Urban Interface and 
Inventoried Roadless Areas, and Associated Acreage, Fiscal Years 2006 
through 2008: 

Table 7: Appellants and Number of Appeals Filed, by Forest Service 
Region, Fiscal Years 2006 through 2008: 

Table 8: Objectors and Number of Objections Filed, by Forest Service 
Region, Fiscal Years 2006 through 2008: 

Table 9: Plaintiffs and Number of Lawsuits Filed, by Forest Service 
Region, Fiscal Years 2006 through 2008: 

Table 10: Types of Categorical Exclusions Authorized for Use by the 
Forest Service and Represented in the GAO Survey: 

Table 11: A Chronology of Litigation Concerning Regulation Exempting 
Decisions That Have Been Categorically Excluded from Appeals: 

Table 12: A Chronology of Litigation Concerning the Validity of the 
Fuels CE: 

Figures: 

Figure 1: Lands Managed by the Forest Service, by Region: 

Figure 2: Number of Fuel Reduction Decisions and Associated Acreage, 
by Forest Service Region: 

Figure 3: Number of Decisions Subject to Appeal and Objection, and the 
Number and Frequency of Appeals, Objections, Exemptions, and 
Litigation, by Forest Service Region: 

Figure 4: Outcomes of Appeals of Fuel Reduction Decisions, by Forest 
Service Region: 

Figure 5: Outcomes of Litigation of Fuel Reduction Decisions, by 
Forest Service Region: 

Figure 6: Number of Decisions Subject to Appeal and Objection, and the 
Number and Frequency of Appeals, Objections, Exemptions, and 
Litigation, by Treatment Method and Forest Service Region: 

Figure 7: Number of Decisions Subject to Appeal and Objection, and the 
Number and Frequency of Appeals, Objections, Exemptions, and 
Litigation, by Contract Type and Forest Service Region: 

Figure 8: Number of Fuel Reduction Decisions in the Wildland-urban 
Interface (WUI), and the Number and Frequency of Appeals, Objections, 
Exemptions, and Litigation, by Forest Service Region: 

Figure 9: Number of Fuel Reduction Decisions in Inventoried Roadless 
Areas (IRA), and the Number and Frequency of Appeals, Objections, 
Exemptions, and Litigation, by Forest Service Region: 

Abbreviations: 

CE: categorical exclusion: 

HFRA: Healthy Forests Restoration Act: 

IRA: inventoried roadless area: 

NEPA: National Environmental Policy Act of 1969: 

PALS: Planning, Appeals, and Litigation System: 

RARE: Roadless Area Review and Evaluation: 

WUI: wildland-urban interface: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 4, 2010: 

The Honorable Jeff Bingaman: 
Chairman: 
Committee on Energy and Natural Resources: 
United States Senate: 

The Honorable Nick J. Rahall, II: 
Chairman: 
Committee on Natural Resources: 
House of Representatives: 

Much attention has been paid in recent years to the condition of our 
nation's forests, in large part because of increases in the number and 
intensity of wildland fires. In an effort to reduce the risk of fire, 
federal land management agencies--including the Forest Service in the 
Department of Agriculture--are placing greater emphasis on thinning 
forests and rangelands to help reduce the buildup of potentially 
hazardous fuels. The agencies have placed particular emphasis on fuel 
reduction in areas where human development meets or intermixes with 
undeveloped wildland, known as the wildland-urban interface. 

Like many other land management activities, hazardous fuel reduction 
activities are typically subject to the National Environmental Policy 
Act of 1969 (NEPA).[Footnote 1] Under NEPA, federal agencies are to 
evaluate the likely environmental effects of proposed projects through 
an environmental assessment or, if projects are likely to 
significantly affect the environment, a more detailed environmental 
impact statement. If, however, the agency determines that activities 
of a proposed project fall within a category of activities the agency 
has already determined have no significant environmental impact--
called a categorical exclusion--then the agency generally need not 
prepare an environmental assessment or environmental impact statement. 
The Forest Service then generally issues a final decision for each 
project in the form of a Record of Decision, a Decision Notice, or a 
Decision Memo, depending on whether the decision stems from an 
environmental impact statement, environmental assessment, or 
categorical exclusion, respectively.[Footnote 2] During the early 
planning stage of these environmental reviews, the public has 
opportunities to get involved by, for example, submitting written 
comments on the proposed project. Depending on the type of project, 
the public can generally challenge either the proposed action or the 
final decision by filing an objection or an appeal, respectively, with 
the Forest Service. These objections or appeals must be reviewed by 
the Forest Service within prescribed time frames. Final decisions may 
also generally be challenged in federal court.[Footnote 3] 

Much debate has focused on the extent and frequency of appeals and 
litigation of fuel reduction activities and their effect on agency 
activities. On the one hand, critics have asserted that such 
challenges to agency activities are stopping or unnecessarily slowing 
the decision-making processes of the Forest Service and its efforts to 
reduce fuels on federal lands. This opposition to fuel reduction 
activities is sometimes viewed as "frivolous" and alleged to be 
greatly increasing the costs of managing the national forests. 
Supporters of the administrative appeals process, on the other hand, 
have indicated that appeals have not been excessive or unwarranted and 
that few appeals are frivolous. Supporters further assert that 
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 
affecting the environmental health of the nation's lands. 

In 2003, we issued a report on appeals and litigation of Forest 
Service fuel reduction projects during fiscal years 2001 and 2002. 
[Footnote 4] Since that time, however, the legal and procedural 
landscape has changed considerably. For example, at the time of our 
2003 report, fuel reduction decisions stemming from categorical 
exclusions were generally not subject to appeal; however, as the 
result of subsequent litigation, the Forest Service was required to 
allow appeals of these types of decisions. In addition, since the time 
period covered by that report, the Forest Service has introduced new 
categorical exclusions, including one specific to fuel reduction. And 
finally, in 2003, the Healthy Forests Restoration Act (HFRA) exempted 
certain fuel reduction projects from appeal, instead subjecting them 
to objection before the decision is final.[Footnote 5] 

In the context of these legal and procedural changes, you asked us to 
gather and report data on appeals, objections, and litigation related 
to Forest Service fuel reduction activities. This report provides 
information on (1) the number and type of Forest Service decisions 
involving hazardous fuel reduction activities signed in fiscal years 
2006 through 2008 and the acreage associated with those decisions; (2) 
the number of these decisions that were subject to the appeal or 
objection process; the number that were appealed, objected to, or 
litigated; and the acreage associated with those decisions; (3) the 
outcomes of these appeals, objections, and lawsuits, including whether 
they were processed within prescribed time frames, and the identities 
of the appellants, objectors, and plaintiffs; (4) the treatment 
methods and contract types associated with fuel reduction decisions, 
the associated acreage, and how frequently each treatment method and 
contract type was appealed, objected to, or litigated; and (5) the 
number of decisions involving hazardous fuel reduction activities in 
the wildland-urban interface[Footnote 6] and inventoried roadless 
areas,[Footnote 7] the associated acreage, and how frequently these 
decisions were appealed, objected to, or litigated. This letter 
provides national data on these issues, while appendixes II through IX 
provide information by Forest Service region. Appendixes X and XI 
provide more information on the nature and use of categorical 
exclusions related to fuel reduction decisions. 

In conducting our review, we administered a Web-based survey to all 
108 national forests that issued decisions that involved hazardous 
fuel reduction activities in fiscal years 2006 through 2008. The 
survey was used to gather information about each of the decisions, 
including the type of environmental analysis used, acres involved, 
treatment methods and contract types used, the extent to which the 
decisions included activities in the wildland-urban interface and 
inventoried roadless areas, and specific information about decisions 
subject to the predecisional objection process. We obtained a 100 
percent response rate from the national forests. To gather specific 
details about appeals and litigation of decisions with hazardous fuel 
reduction activities, we conducted semistructured interviews with 
officials in each of the Forest Service's nine regions. For both the 
Web-based survey and the semistructured interviews, to test the 
accuracy and reliability of the responses provided by officials, we 
verified the accuracy of a random sample of responses by comparing 
them with decision documents and found that the information was 
sufficiently reliable for our reporting purposes. Appendix I provides 
details on the scope and methodology of our review. Appendix XII 
includes a copy of the survey sent to national forests. 

We conducted our work from October 2008 through February 2010, in 
accordance with all sections of GAO's Quality Assurance Framework that 
are relevant to our objectives. The framework requires that we plan 
and perform the engagement to obtain sufficient and appropriate 
evidence to meet our stated objectives and to discuss any limitations 
in our work. We believe that the information and data obtained, and 
the analysis conducted, provide a reasonable basis for any findings 
and conclusions in this product. 

Results in Brief: 

In response to our survey and interviews, national forest and regional 
officials reported the following: 

* In fiscal years 2006 through 2008, 1,415 Forest Service land 
management decisions involved hazardous fuel reduction activities. 
These decisions involved 10.5 million acres. Of these decisions, 71--5 
percent--were based on environmental impact statements, 433--31 
percent--were based on environmental assessments, and 910--64 percent--
were based on categorical exclusions. (The remaining decision was a 
continuation of a previously authorized project and, according to the 
respondent, did not require an environmental impact statement, 
environmental assessment, or categorical exclusion.) Decisions based 
on environmental assessments covered the greatest acreage in our 
review--over 6.3 million acres--representing 61 percent of all acres. 

* Of the 1,415 decisions involving hazardous fuel reduction 
activities, 1,191 decisions, involving approximately 9 million acres, 
were subject to appeal, with 217--about 18 percent--appealed. An 
additional 121 decisions, involving approximately 1.2 million acres, 
were subject to objection, with 49--40 percent--objected to. The 
remaining 103 decisions, involving approximately 188,000 acres, were 
exempt from appeal and objection. And finally, of the 1,415 total 
decisions, 29--about 2 percent of all decisions--were litigated, 
involving approximately 124,000 acres. 

* The 217 decisions that were appealed received a total of 298 
appeals.[Footnote 8] Of these, the Forest Service ruled against the 
appellant in 160 instances (about 54 percent of all appeals), meaning 
that the project could be implemented without changes, and in another 
22 instances (7 percent) ruled that the project could be implemented 
with specific changes. In contrast, the agency reversed its initial 
decision (in whole or in part) in response to 24 appeals (8 percent). 
It dismissed 91 appeals (about 30 percent) for various reasons, 
including failure on the part of the appellant to meet procedural 
requirements, and instances in which the appellant withdrew the appeal 
or the Forest Service withdrew the decision before the appeal could be 
decided. According to regional officials, the outcome of 1 appeal 
could not be determined based on documentation in their files. Of the 
101 objections filed on 49 proposed decisions, 38 objections resulted 
in no change to a final decision. Another 31 objections resulted in a 
change to a final decision. An additional 4 objections resulted in the 
forest having to conduct additional analysis, and 13 were addressed in 
some other way, such as the objector agreeing to withdraw the 
objection if the Forest Service agreed to make changes to the final 
decision. The remaining 15 objections were removed from administrative 
review for a variety of reasons (also known as "set aside" from 
review). According to time frame information provided by survey 
respondents, the Forest Service processed all appeals and objections 
within prescribed time frames. Finally, of the 29 decisions that were 
litigated, lawsuits on 21 decisions have been resolved; the parties 
settled 3 decisions, 8 were decided in favor of the plaintiffs, and 10 
were decided in favor of the Forest Service. Most of the appellants, 
objectors, and plaintiffs were environmental organizations. 

* With respect to treatment methods, prescribed burning--where fires 
are deliberately set by land managers to reduce the buildup of 
potentially hazardous fuel--was the treatment most frequently 
associated with fuel reduction decisions, and was included in 1,076 of 
the 1,415 decisions. Mechanical treatment--in which equipment such as 
chain saws, chippers, bulldozers, and mowers is used to cut 
vegetation--was included in 973 decisions; and commercial logging--
where trees are harvested for commercial use such as lumber--was 
included in 661 decisions.[Footnote 9] Although decisions involving 
prescribed burning received the greatest number of challenges, 
decisions that used commercial logging were challenged at a higher 
rate than the other treatment methods, considering both appeals and 
objections. Regarding contract type, timber sale contracts were the 
most frequently used, and were included in 606 of the 1,415 decisions. 
Service contracts--where contractors are hired to perform specific 
tasks such as thinning--were included in 536 decisions, and 
stewardship contracts were included in 218 decisions.[Footnote 10] In 
addition to issuing contracts for the work, the Forest Service also 
issued forest products permits (for activities such as collecting 
firewood) in 236 decisions.[Footnote 11] Decisions that included 
commercial timber sale contracts were the most frequently appealed, 
objected to, and litigated. However the rate at which decisions were 
challenged was highest for decisions that included stewardship 
contracts. 

* There were 954 decisions involving fuel reduction activities in the 
wildland-urban interface, involving about 4 million acres. Of these 
decisions, 140 were appealed, 45 were objected to, and 13 were 
litigated. There were 169 decisions involving fuel reduction 
activities in inventoried roadless areas, involving about 750,000 
roadless acres. Of these decisions, 26 were appealed, 11 were objected 
to, and 4 were litigated. These figures represent a similar rate of 
appeals for both types of decision, with about 18 to 19 percent of 
appealable decisions appealed; however, decisions involving 
inventoried roadless areas were objected to at a higher rate (50 
percent) than those involving the wildland-urban interface (40 
percent). 

Background: 

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). The Forest Service's implementation, 
management, and oversight of fuel reduction activities tend to be 
decentralized and vary by region, although all activities must be 
carried out under applicable laws.[Footnote 12] Figure 1 shows a map 
of the national forests and Forest Service regions. 

Figure 1: Lands Managed by the Forest Service, by Region: 

[Refer to PDF for image: map of the US] 

The following regions are indicated on the map: 

Region 1: Northern; 
Region 2: Rocky Mountain; 
Region 3: Southwestern; 
Region 4: Intermountain; 
Region 5: Pacific Southwest; 
Region 6: Pacific Northwest; 
Region 8: Southern; 
Region 9: Eastern; 
Region 10: Alaska. 

Source: Forest Service. 

Note: The Forest Service does not have a Region 7. 

[End of figure] 

Forest Service projects intended to reduce fuels and restore or 
maintain desired vegetation conditions generally use prescribed 
burning, in which fires are deliberately set by land managers, and/or 
mechanical treatments, in which equipment such as chain saws, 
chippers, bulldozers, or mowers is used to cut vegetation. Such 
mechanical treatment may include logging to remove commercial timber. 
Other approaches include applying chemical herbicides, using grazing 
animals such as cattle and goats, and allowing the public to remove 
firewood by hand. To carry out its fuel reduction work, the Forest 
Service may use agency staff but more commonly contracts it out. The 
agency generally uses three types of contracts--timber sale contracts, 
service contracts, and stewardship contracts--to accomplish fuel 
reduction work. Timber sale contracts are awarded to individuals or 
companies to harvest and remove trees from federal lands under its 
jurisdiction. Service contracts are awarded to contractors to perform 
specific tasks, such as thinning trees or clearing underbrush. 
Stewardship contracts are generally awarded to contractors who perform 
both timber harvesting and service activities, and include contracts 
under which the agency uses the value of commercial products, such as 
timber, to offset the cost of services received, such as thinning, 
stream improvement, and other activities. 

Controversy has surrounded the issue of fuel reduction for some time, 
particularly in areas where federal lands surround or are adjacent to 
human development and communities--the wildland-urban interface--and 
in inventoried roadless areas. Roadless areas have received special 
attention for decades, as some argue that these areas should be 
available for appropriate development and timber harvesting, while 
others believe that the areas should remain roadless to preserve the 
special values that their condition provides, such as clean water and 
undeveloped wildlife habitats.[Footnote 13] 

Forest Service hazardous fuel reduction activities are typically 
subject to one of two different internal administrative review 
processes, each of which has a specific procedure through which the 
public can challenge the agency's decisions or proposed decisions to 
conduct the activities. Specifically: 

* Postdecisional administrative appeals process. The Forest Service 
has provided an administrative appeals system for review of agency 
decisions, under certain circumstances, for over 100 years. Although 
the specific requirements of the appeals system have changed over the 
years, the Appeals Reform Act of 1993 established the appeals process 
pertinent to fiscal years 2006 through 2008--the time period covered 
by our review.[Footnote 14] When the Forest Service issues a public 
notice in a newspaper of record of a proposed action, the public has 
either 30 or 45 days to comment, depending on the type of NEPA 
analysis document prepared. Once the agency issues a decision, the 
public has 45 days to file appeals; however, only those individuals 
who were involved in the public comment process through submission of 
written or oral comments or by otherwise notifying the Forest Service 
of their interest in the proposed action may file an appeal.[Footnote 
15] Once the 45-day time frame for filing appeals has expired, the 
Forest Service must review all appeals and issue a response to each 
within an additional 45 days. Appeals can result in decisions being 
affirmed, in which case the Forest Service can proceed with the 
project as planned, or in decisions being reversed in whole or in 
part, in which case the agency may revise or even cancel the affected 
activities. The official (known as the Appeal Deciding Officer) who 
determines the outcome of the appeal must be, at least, the next 
higher level supervisor of the individual who made the original 
decision. There is no further administrative review of the Appeal 
Deciding Officer's decision by any other Forest Service or Department 
of Agriculture official. 

The types of decisions that can be appealed have changed since GAO 
last reported on this issue in 2003. In 2003, the Forest Service added 
several new categorical exclusions related to vegetation management 
(including one specific to hazardous fuel reduction) that it exempted 
from appeal. However, as the result of subsequent litigation 
challenging these exemptions, the Forest Service ultimately was 
required to allow the public to appeal many (though not all) of these 
decisions during fiscal years 2006 through 2008, the time period 
covered by our current review.[Footnote 16] 

* Predecisional administrative objection process. In 2003, HFRA 
required the Forest Service to establish an alternative process for 
authorizing certain hazardous fuel reduction projects, including an 
alternative predecisional objection process in lieu of the appeals 
process for certain projects.[Footnote 17] HFRA authorizes the public 
to file objections to a proposed project before the agency issues a 
final decision on the project, instead of the traditional appeals 
process where the administrative review occurs after the agency's 
final decision has been made. According to the Forest Service, this 
objection process was intended to expedite the implementation of fuel 
reduction projects and to encourage early public input during the 
planning process. Only those parties who have previously submitted 
written comments specific to the proposed project may file objections. 
(The public has an opportunity to provide these written comments 
during scoping or other public comment periods.) The public must file 
objections with the reviewing officer--the next higher level 
supervisor of the person responsible for the proposed action--within 
30 days following the publication date of the legal notice of the 
proposed environmental assessment or environmental impact statement. 
(Decisions that are subject to objection cannot use categorical 
exclusions as the basis for the decision.) If no objection is filed 
within the 30-day time period, the decision may be finalized on, but 
not before, the fifth business day following the end of the objection-
filing period. If an objection is filed, the Forest Service must issue 
a written response to the objector addressing the objection within 30 
days following the end of the objection-filing period. The reviewing 
officer may hold a meeting to discuss issues raised in the objection 
and any potential resolution. There are several ways the Forest 
Service addresses an objection. The objection can (1) be set aside 
from review, (2) be reviewed by the Forest Service resulting in a 
change to the final decision, (3) be reviewed by the Forest Service 
resulting in no change to the final decision, or (4) result in the 
reviewing officer directing the appropriate Forest Service official to 
complete additional analysis prior to issuing a final decision. An 
objection may be set aside from review for procedural reasons--if, for 
example, the objection is not received within the allowed 30-day time 
period, or the objecting individual or organization did not submit 
written comments during scoping or other public comment 
opportunities.[Footnote 18] There is no further administrative review 
by any other Forest Service or Department of Agriculture official of 
the reviewing officer's written response to an objection. 

Table 1 compares the appeals and objection processes. 

Table 1: Traditional Project Appeals Process Compared with Healthy 
Forests Restoration Act Project Objection Process: 

Authority for review process and corresponding regulation: 
Appeals process: Appeals Reform Act; 36 C.F.R. part 215; 
Objection process: Healthy Forests Restoration Act; 36 C.F.R. part 218. 

Timing of process: 
Appeals process: Appeal is filed after the project decision is made; 
Objection process: Objection filed before the project decision is made. 

Eligibility to appeal/object: 
Appeals process: Those who were involved in the public comment process 
for the project through submission of written or oral comments or by 
otherwise notifying the Forest Service of their interest in the 
proposed action; 
Objection process: Those who submitted specific written comments 
related to the project during the project comment period, the Draft 
Environmental Impact Statement comment period (if applicable), or any 
other public comment periods. 

Filing period: 
Appeals process: 45 days after legal notice of the decision is 
published in newspaper of record; 
Objection process: 30 days after legal notice of the Environmental 
Assessment or Final Environmental Impact Statement published in 
newspaper of record. 

Response/resolution period: 
Appeals process: Resolution of appeal within 45 days after end of 
appeal filing period; 
Objection process: Response to objection within 30 days after end of 
objection filing period. 

Source: GAO summary of Forest Service information. 

[End of table] 

Some decisions, however, were subject to neither the appeal nor the 
objection process during the time of our review. As noted, the Forest 
Service was required to allow appeals of many fuel reduction decisions 
based on categorical exclusions, but was not required to allow appeals 
on all such decisions--meaning that certain decisions based on 
categorical exclusions remained exempt from appeal. These decisions 
were also exempt from the objection process because HFRA requires that 
fuel reduction decisions subject to objection use environmental 
assessments or environmental impact statements rather than categorical 
exclusions. 

Number and Type of Decisions Involving Hazardous Fuel Reduction 
Activities in Fiscal Years 2006 through 2008 and the Associated 
Acreage: 

For fiscal years 2006 through 2008, national forest managers reported 
1,415 decisions involving hazardous fuel reduction activities, 
affecting 10.5 million acres of national forest land.[Footnote 19] 
Most of these decisions were based on categorical exclusions, although 
decisions based on environmental assessments represented the most 
acreage of all decision types. Table 2 shows the number of decisions 
and associated acreage, by decision type. 

Table 2: Forest Service Decisions with Fuel Reduction Activities and 
Acreage Affected, by Decision Type, Fiscal Years 2006 through 2008: 

Decisions/acres: Number of decisions; 
Categorical exclusions: 910; 
Environmental assessments: 433; 
Environmental impact statements: 71; 
Other: 1[A]; 
Total: 1,415. 

Decisions/acres: Percentage of total decisions; 
Categorical exclusions: 64; 
Environmental assessments: 31; 
Environmental impact statements: 5; 
Other: less than 1; 
Total: 100. 

Decisions/acres: Number of acres (in thousands); 
Categorical exclusions: 3,559; 
Environmental assessments: 6,397; 
Environmental impact statements: 586; 
Other: 3; 
Total: 10,545. 

Decisions/acres: Percentage of total acres; 
Categorical exclusions: 34; 
Environmental assessments: 61; 
Environmental impact statements: 6; 
Other: 0; 
Total: 100. 

Source: GAO analysis of survey results. 

Note: Numbers may not total because of rounding. Acreage data are not 
complete because some respondents did not report this information. In 
addition, depending on the status of the projects, some respondents 
reported the number of acres they planned to treat, while others 
reported the actual number of treated acres. 

[A] In one case, the survey respondent indicated that the decision was 
a continuation of a previously authorized project. According to this 
respondent, chapter 18 of the Forest Service Handbook allows such a 
decision to be made without the use of a categorical exclusion, 
environmental assessment, or environmental impact statement. 

[End of table] 

Appendix II provides greater detail on the number of decisions and 
associated acreage for each Forest Service region. 

Number of Decisions Involving Hazardous Fuel Reduction Activities That 
Were Subject to Appeal or Objection; Number of Decisions Appealed, 
Objected to, or Litigated; and Associated Acreage: 

Of the 1,415 decisions in our review, 1,191--about 84 percent--were 
subject to the appeals process. In contrast, only 121 decisions--8.5 
percent--were subject to the objection process. However, the rate at 
which decisions subject to the objection process were challenged was 
higher than for decisions under the appeals process. Specifically, 40 
percent of decisions subject to objection were objected to, compared 
with the 18 percent appeal rate for decisions subject to appeal. Table 
3 shows, for all decisions covered by our review for fiscal years 2006 
through 2008, the number of appeals, objections, and litigation 
associated with each decision type. 

Table 3: Forest Service Decisions with Hazardous Fuel Reduction 
Activities That Were Appealed, Objected to, Exempt, or Litigated, by 
Decision Type, and Associated Acreage, Fiscal Years 2006 through 2008 
(Acres in thousands): 

Decisions/acres: Total number of decisions; 
Categorical exclusions: 910; 
Environmental assessments: 433; 
Environmental impact statements: 71; 
Other[A]: 1; 
Total: 1,415. 

Decisions/acres: Total acreage; 
Categorical exclusions: 3,559; 
Environmental assessments: 6,397; 
Environmental impact statements: 586; 
Other[A]: 3; 
Total: 10,545. 

Decisions subject to appeal: Number of decisions subject to appeal[B]; 
Categorical exclusions: 808; 
Environmental assessments: 321; 
Environmental impact statements: 62; 
Other[A]: 0; 
Total: 1,191. 

Decisions subject to appeal: Number of decisions appealed; 
Categorical exclusions: 80; 
Environmental assessments: 90; 
Environmental impact statements: 47; 
Other[A]: 0; 
Total: 217[C]. 

Decisions subject to appeal: Percentage of appealable decisions 
appealed; 
Categorical exclusions: 10%; 
Environmental assessments: 28%; 
Environmental impact statements: 76%; 
Other[A]: n/a; 
Total: 18%. 

Decisions subject to appeal: Acreage subject to appeal; 
Categorical exclusions: 3,375; 
Environmental assessments: 5,285; 
Environmental impact statements: 483; 
Other[A]: 0; 
Total: 9,143. 

Decisions subject to appeal: Acreage appealed; 
Categorical exclusions: 116; 
Environmental assessments: 429; 
Environmental impact statements: 294; 
Other[A]: 0; 
Total: 839. 

Decisions subject to appeal: Percentage of appealable acreage appealed; 
Categorical exclusions: 3%; 
Environmental assessments: 8%; 
Environmental impact statements: 61%; 
Other[A]: n/a; 
Total: 9%. 

Decisions subject to objection[D]: Number of decisions subject to 
objection process; 
Categorical exclusions: n/a; 
Environmental assessments: 112; 
Environmental impact statements: 9; 
Other[A]: 0; 
Total: 121. 

Decisions subject to objection[D]: Number of decisions objected to; 
Categorical exclusions: n/a; 
Environmental assessments: 43; 
Environmental impact statements: 6; 
Other[A]: 0; 
Total: 49[E]. 

Decisions subject to objection[D]: Percentage of decisions objected to; 
Categorical exclusions: n/a; 
Environmental assessments: 38%; 
Environmental impact statements: 67%; 
Other[A]: 0; 
Total: 40%. 

Decisions subject to objection[D]: Acreage subject to objection; 
Categorical exclusions: n/a; 
Environmental assessments: 1,112; 
Environmental impact statements: 103; 
Other[A]: 0; 
Total: 1,215. 

Decisions subject to objection[D]: Acreage objected to; 
Categorical exclusions: n/a; 
Environmental assessments: 184; 
Environmental impact statements: 41; 
Other[A]: 0; 
Total: 225. 

Decisions subject to objection[D]: Percentage of acreage objected to; 
Categorical exclusions: n/a; 
Environmental assessments: 17%; 
Environmental impact statements: 40%; 
Other[A]: 0; 
Total: 19%. 

Exempt decisions: Number of decisions exempt from appeal and objection; 
Categorical exclusions: 102; 
Environmental assessments: 0; 
Environmental impact statements: 0; 
Other[A]: 1; 
Total: 103. 

Exempt decisions: Percentage of all decisions exempt from appeal and 
objection; 
Categorical exclusions: 11%; 
Environmental assessments: 0; 
Environmental impact statements: 0; 
Other[A]: 100%; 
Total: 7%. 

Exempt decisions: Acreage exempt from appeal and objection; 
Categorical exclusions: 185; 
Environmental assessments: 0; 
Environmental impact statements: 0; 
Other[A]: 3; 
Total: 188. 

Exempt decisions: Percentage of all acreage exempt from appeal and 
objection; 
Categorical exclusions: 5%; 
Environmental assessments: 0; 
Environmental impact statements: 0; 
Other[A]: 100%; 
Total: 2%. 

Litigation: Number of decisions litigated; 
Categorical exclusions: 4; 
Environmental assessments: 14; 
Environmental impact statements: 11; 
Other[A]: 0; 
Total: 29. 

Litigation: Percentage of all decisions litigated; 
Categorical exclusions: less than 1%; 
Environmental assessments: 3%; 
Environmental impact statements: 15%; 
Other[A]: n/a; 
Total: 2%. 

Litigation: Acreage litigated; 
Categorical exclusions: 2; 
Environmental assessments: 70; 
Environmental impact statements: 52; 
Other[A]: 0; 
Total: 124. 

Litigation: Percentage of acreage litigated; 
Categorical exclusions: less than 1%; 
Environmental assessments: 1%; 
Environmental impact statements: 9%; 
Other[A]: n/a; 
Total: 1%. 

Source: GAO analysis of survey results. 

Notes: n/a = not applicable. Numbers may not total because of 
rounding. Acreage data are not complete because some respondents did 
not report this information. In addition, depending on the status of 
the projects, some respondents reported the number of acres they 
planned to treat, while others reported the actual number of treated 
acres. 

[A] In one case, the survey respondent indicated that the decision was 
a continuation of a previously authorized project. According to this 
respondent, Chapter 18 of the Forest Service Handbook allows such a 
decision to be made without the use of a categorical exclusion, 
environmental assessment, or environmental impact statement. 

[B] One project in our study was authorized under HFRA and involved a 
fuel reduction activity, but did not qualify as an "authorized 
hazardous fuel reduction project" under HFRA and therefore was not 
subject to the objection process. According to the survey respondent 
for this decision, it implemented HFRA provisions related to insect 
and disease infestation, and was subject to the notice, comment, and 
appeals process found in 36 C.F.R. part 215 because it included a 
timber sale activity. As a result, it is included in our count of 
decisions subject to appeal. 

[C] These 217 decisions received a total of 298 appeals. The greatest 
number of appeals on a single decision was 9. 

[D] Only authorized hazardous fuel reduction projects under HFRA that 
are analyzed in an Environmental Assessment or Environmental Impact 
Statement are subject to the predecisional objection process. 

[E] These 49 decisions received a total of 101 objections. The 
greatest number of objections to a single decision was 22. 

[End of table] 

Appendix III provides greater detail on the number of appeals, 
objections, and litigation for each Forest Service region. 

In addition to the introduction of the objection process, our survey 
data reflect two important changes that have occurred since our 2003 
report: (1) the extent to which activities associated with categorical 
exclusions are subject to the appeals process and (2) the decrease in 
the use of the categorical exclusion for hazardous fuel reduction to 
authorize hazardous fuel reduction activities. Specifically: 

* Extent to which categorical exclusions were subject to appeal. At 
the time of our 2003 report, decisions using categorical exclusions 
were generally not subject to appeal, and in that report we noted that 
99 percent of fuel reduction decisions using categorical exclusions in 
fiscal years 2001 and 2002 were exempt from appeal. Also in 2003, the 
Forest Service introduced several new categorical exclusions that were 
exempt from appeal, including one categorical exclusion specific to 
fuel reduction activities. Beginning later that year, however, the 
agency's ability to exempt decisions using categorical exclusions from 
appeal was challenged in court.[Footnote 20] As a result of this 
litigation, the Forest Service was required to allow the public to 
appeal decisions containing any of 11 types of categorically excluded 
activities, including fuel reduction--and thus, most fuel reduction 
decisions in our survey that were made using categorical exclusions 
were appealable by the public. Specifically, 89 percent of the 
categorical exclusions identified in our survey were subject to appeal 
in fiscal years 2006 through 2008, in contrast to the 1 percent that 
were subject to appeal during our 2003 review. The remaining 11 
percent of categorical exclusions in our current review--a total of 
103 decisions--were identified by survey respondents as exempt from 
appeal because they did not contain the activities covered by the 
litigation. Subsequently, in 2009 the U.S. Supreme Court overturned 
the lower court's ruling on procedural grounds, allowing the Forest 
Service to utilize the provisions of its regulations that exempt 
categorically excluded decisions from appeal.[Footnote 21] Appendix X 
contains data on the type and frequency of the categorical exclusions 
represented in our survey. 

* Decrease in the use of the categorical exclusion for hazardous fuel 
reduction. Although Forest Service regulations contain a specific 
categorical exclusion under which hazardous fuel reduction activities 
can be authorized, this was not the most commonly reported categorical 
exclusion in our survey of decisions involving hazardous fuel 
reduction activities. Instead, the most commonly reported categorical 
exclusion was one intended for timber stand and/or wildlife habitat 
improvement. Our survey data show that the total number of decisions 
authorized under the categorical exclusion for hazardous fuel 
reduction decreased greatly over the period covered by our survey, 
while at the same time, the use of the categorical exclusion for 
timber stand and/or wildlife habitat improvement increased. 
Specifically, use of the categorical exclusion for hazardous fuel 
reduction decreased from 214 in fiscal year 2006 to 28 in fiscal year 
2008, while the use of the categorical exclusion for timber stand 
and/or wildlife habitat improvement increased from 145 in fiscal year 
2006 to 167 in fiscal year 2008. 

This decrease in the use of the categorical exclusion for hazardous 
fuel reduction may have resulted in large part from the chief of the 
Forest Service's response to a court order in 2007. In this response 
the chief directed that no new decisions should be made under the 
categorical exclusion for hazardous fuel reduction after December 
2007. Furthermore, he directed that no additional contracts be 
initiated to implement projects authorized under this authority--
meaning that projects that were not under way did not start, even if a 
final decision had already been issued. Under the chief's direction, 
projects that were near completion could proceed. Of the 379 decisions 
in our survey originally authorized under the categorical exclusion 
for hazardous fuel reduction, respondents reported that 207--or about 
55 percent--were affected by the chief's directive. Although we did 
not systematically gather information on what happened to projects 
subject to the court decision, respondents indicated that they took a 
variety of approaches, including the following: 

* using a different categorical exclusion, such as the categorical 
exclusion for timber stand and/or wildlife habitat improvement, to 
authorize the project; 

* preparing an environmental assessment subject to the appeals process; 

* stopping or slowing project implementation; and: 

* preparing an environmental assessment subject to the predecisional 
objection process, under HFRA. 

Additionally, the rate at which decisions were litigated was about the 
same--2 percent--for decisions that were subject to the Forest 
Service's traditional appeals process as for decisions authorized 
under HFRA--even though the agency's expectation was that HFRA would 
reduce the likelihood of litigation. Of the 29 litigated decisions in 
our study, 26 had been subject to appeal, representing 2 percent of 
the 1,191 decisions subject to appeal; the remaining 3 litigated 
decisions had been subject to objection, likewise representing 2 
percent of the 121 decisions subject to objection. 

Outcomes of Appeals, Objections, and Litigation of Decisions with 
Hazardous Fuel Reduction Activities; Associated Time Frames; and 
Identities of Appellants, Objectors, and Plaintiffs: 

In fiscal years 2006 through 2008, of the 298 appeals filed, the 
Forest Service upheld its earlier decision in the majority of the 
cases without requiring any changes to the decision. Of the 101 
objections submitted, the outcome was more evenly divided between 
those objections resulting in a change to the decision and those that 
did not. According to time frame information provided by survey 
respondents, all appeals and objections were processed within the 
prescribed time frames. For litigated decisions resolved at the time 
of our review, the Forest Service prevailed slightly more often than 
the plaintiffs. 

Outcomes of Appeals, Time Frames, and Identities of Appellants: 

Of the 298 appeals filed on appealable decisions from fiscal years 
2006 through 2008, 

* For 160 appeals, the decisions were affirmed--that is, allowed to 
proceed--with no changes. 

* For 22 appeals, the decisions were affirmed with specified changes. 

* For 24 appeals, the decisions were reversed --that is, not allowed 
to proceed--based on issues raised by the appellants. 

* A total of 91 appeals were dismissed for various reasons, including: 

- 38 appeals that were resolved informally, of which 30 appeals were 
withdrawn by the appellant and 8 decisions were withdrawn by the 
agency (when an appeal is resolved informally, changes may or may not 
be made to the decision); 

- 53 appeals that were dismissed without review, mostly for failing to 
meet procedural requirements, such as timeliness--however, 23 of these 
appeals were dismissed without review because, subsequent to receiving 
the appeal, the agency official who made the decision decided to 
withdraw the decision;[Footnote 22] 

* For 1 appeal, the outcome could not be determined based on 
documentation in the agency's regional files, according to an agency 
official. 

According to time frame information provided by Forest Service 
officials, all appeals of fiscal year 2006 through 2008 decisions were 
processed within the time frames prescribed in applicable laws and 
regulations.[Footnote 23] See appendix IV for detailed information on 
appeal outcomes for each Forest Service region. 

The 298 appeals were filed by 217 appellants. This total includes 
appeals by 88 different interest groups, mostly environmental groups, 
and 129 individuals.[Footnote 24] Of the 88 interest groups, 10-- 
Alliance for the Wild Rockies, Biodiversity Conservation Alliance, 
John Muir Project of the Earth Island Institute, Native Ecosystems 
Council, Oregon Wild, Ouachita Watch League, Sierra Club, The Lands 
Council, Utah Environmental Congress, and the WildWest Institute--each 
appealed 10 or more decisions. Appendix VI lists each interest group 
that appeared as an appellant in fiscal years 2006 through 2008 and 
the number of decisions for which each appellant filed appeals in each 
region. To protect the privacy of individual appellants, we do not 
list their names, but in appendix VI we provide information on the 
number of decisions appealed by individuals in each region. 

Outcomes of Objections, Time Frames, and Identities of Objectors: 

Of the 101 objections filed for 49 decisions from fiscal years 2006 
through 2008, 

* 38 objections resulted in no change to the final decision. 

* 31 objections resulted in a change to the final decision.[Footnote 
25] 

* 4 objections resulted in the Forest Service having to conduct 
additional analysis. 

* 15 objections were set aside from review. 

* 13 objections were addressed some other way; for example, several 
agency respondents explained that they addressed objector's concerns 
by both agreeing to make a change to the final decision and by setting 
the objection aside from review. Rather than setting it aside from 
review for procedural reasons, however, the decisions were set aside 
because the objector withdrew the objection after the Forest Service 
agreed to make changes to the final decisions. 

For objections that the Forest Service does not set aside, the Forest 
Service reviewing officer is required to respond in writing. Prior to 
issuing a written response, the objector or reviewing officer may 
request a meeting to discuss the issues that were raised in the 
objection and a possible resolution. According to some Forest Service 
officials we spoke with, these meetings have been used to further 
satisfy public concerns; however, because meetings are at the 
discretion of the reviewer, objectors with whom the reviewer decides 
not to meet may feel that their concerns were not adequately 
addressed, regardless of the outcome. For example, the Forest Service 
received 22 objections to the Middle East Fork Hazardous Fuel 
Reduction decision on the Bitterroot National Forest in west central 
Montana and east central Idaho, one of the first and, according to 
Forest Service officials, most contentious decisions authorized under 
HFRA authority in the Northern Region. One objector requested a 
meeting with the Forest Service and others expressed a willingness to 
meet, but the reviewing officer chose not to hold meetings, stating 
that their objections did not require additional clarification and 
that a private consultant with whom the forest contracted had 
determined that additional discussions would not resolve the 
objector's concerns. The decision was ultimately litigated. In other 
cases, however, respondents reported that such meetings successfully 
addressed objectors' concerns, sometimes resulting in objectors 
withdrawing their objections. 

However, we also determined that different regions follow different 
approaches in addressing objectors' concerns. For example, an official 
in the Pacific Southwest Region told us that officials generally meet 
with the objectors associated with valid objections (those that are 
not set aside for procedural reasons), with the goal of informally 
resolving the objections and having them subsequently withdrawn by the 
objectors. In contrast, an official in the Northern Region told us 
that while the region seeks to resolve objections informally, unlike 
the Pacific Southwest Region, it does not seek to have objectors 
subsequently withdraw their objections, and none have done so. Seeking 
to have objectors withdraw their objections, as the Pacific Southwest 
Region has done, may have important implications for subsequent 
litigation because, according to Forest Service officials, under HFRA 
and its implementing regulations, an objector that withdraws an 
objection has no standing to obtain judicial review of the Forest 
Service's final decision. 

According to time frame information provided by survey respondents, 
the final decisions for all proposals subject to the objection process 
from fiscal year 2006 through 2008 were signed in accordance with the 
time frames set forth by applicable laws and regulations.[Footnote 26] 
However, while officials are required to respond to objections within 
certain time frames, there is no limitation on the amount of time 
allowed to make a final decision. Of the 49 decisions for which 
objections were filed, 25 were signed between 35 days and 3 months of 
legal publication date of the proposed action. The remaining 24 were 
signed more than 3 months after the legal publication date, including 
3 cases in which the final decision was signed more than a year after 
the legal publication date of the proposed action. 

The 101 objections were filed by 37 organizations and 41 individuals. 
Of the 37 organizations, 3--the Center for Biological Diversity, the 
Idaho Conservation League, and the WildWest Institute[Footnote 27]-- 
each objected to 5 or more decisions. Appendix VI lists each group 
that filed objections in fiscal years 2006 through 2008 and the number 
of decisions for which objections were filed in each region. As with 
appeals, in appendix VI we do not list the names of individual 
objectors, but do show the number of proposed decisions objected to by 
individuals in each region. 

Outcomes of Litigation and Identities of Plaintiffs: 

Of the 29 decisions that were litigated from fiscal years 2006 through 
2008, we are able to report the outcome for 21 of the lawsuits because 
they had been resolved at the time of our review. According to 
regional officials, lawsuits for 3 of these 21 decisions were 
dismissed because the plaintiffs and the Forest Service agreed to 
settle their claims. District courts reached an outcome on the 18 
additional decisions, with 8 decided favorably to the plaintiffs and 
10 decided favorably to the Forest Service.[Footnote 28] Lawsuits on 
the remaining 8 decisions were continuing at the time of our review. 

In the 29 litigated decisions, 24 interest groups and 11 individuals 
were plaintiffs. The interest groups were primarily environmental 
groups, with three groups--Alliance for the Wild Rockies, Native 
Ecosystems Council, and the WildWest Institute--each acting as 
plaintiff in 5 or more decisions. Of the 29 litigated decisions, 
plaintiff groups and individuals had previously submitted appeals on 
24 of the decisions and objections on 3 of the decisions during the 
administrative process. The remaining 2 litigated decisions were 
subject to appeal, but the plaintiffs did not submit an appeal during 
the administrative process. Appendix VI lists each group that acted as 
a plaintiff in fiscal years 2006 through 2008 and the number of 
decisions for which lawsuits were filed by each group within each 
Forest Service region. To protect the privacy of individual 
plaintiffs, we do not list their names, but in appendix VI provide 
information on the number of decisions litigated by individuals in 
each region. 

Treatment Methods and Contract Types Associated with Fuel Reduction 
Decisions; the Number of Appeals, Objections, and Lawsuits by 
Treatment Method and Contract Type; and the Associated Acreage: 

Prescribed burning was the most frequently used treatment method 
associated with the fuel reduction decisions included in our study, 
followed by mechanical treatment and commercial logging. Of these 
three methods, prescribed burning was the method most often challenged 
through appeals and objections; however, commercial logging was 
challenged at the highest rate, considering both appeals and 
objections. Table 4 shows, for all treatment methods in our study, the 
number and percentage of, and acreage associated with, appeals, 
objections, and litigation. 

Table 4: Appeals, Objections, Exemptions, and Litigation Associated 
with Various Treatment Methods, and Associated Acreage, Fiscal Years 
2006 through 2008 (Acres in thousands): 

Decisions/acres: Total number of decisions[A]; 
Prescribed burning: 1,076; 
Mechanical treatment: 973; 
Commercial logging: 661; 
Construction/maintenance of fuel breaks: 279; 
Chemical/herbicide treatment: 57; 
Livestock grazing: 12. 

Decisions/acres: Total acreage[B]; 
Prescribed burning: 5,099; 
Mechanical treatment: 1,109; 
Commercial logging: 1,283; 
Construction/maintenance of fuel breaks: 111; 
Chemical/herbicide treatment: 336; 
Livestock grazing: 297. 

Decisions subject to appeal: Number of decisions subject to appeal[C]; 
Prescribed burning: 940; 
Mechanical treatment: 804; 
Commercial logging: 546; 
Construction/maintenance of fuel breaks: 225; 
Chemical/herbicide treatment: 50; 
Livestock grazing: 7. 

Decisions subject to appeal: Number of decisions appealed; 
Prescribed burning: 187; 
Mechanical treatment: 167; 
Commercial logging: 162; 
Construction/maintenance of fuel breaks: 64; 
Chemical/herbicide treatment: 18; 
Livestock grazing: 2. 

Decisions subject to appeal: Percentage of appealable decisions 
appealed; 
Prescribed burning: 20%; 
Mechanical treatment: 21%; 
Commercial logging: 30%; 
Construction/maintenance of fuel breaks: 28%; 
Chemical/herbicide treatment: 36%; 
Livestock grazing: 29%. 

Decisions subject to appeal: Acreage subject to appeal; 
Prescribed burning: 4,344; 
Mechanical treatment: 787; 
Commercial logging: 704; 
Construction/maintenance of fuel breaks: 85; 
Chemical/herbicide treatment: 328; 
Livestock grazing: 229. 

Decisions subject to appeal: Acreage appealed; 
Prescribed burning: 512; 
Mechanical treatment: 266; 
Commercial logging: 315; 
Construction/maintenance of fuel breaks: 59; 
Chemical/herbicide treatment: 12; 
Livestock grazing: 42. 

Decisions subject to appeal: Percentage of appealable acreage appealed; 
Prescribed burning: 12%; 
Mechanical treatment: 34%; 
Commercial logging: 45%; 
Construction/maintenance of fuel breaks: 69%; 
Chemical/herbicide treatment: 4%; 
Livestock grazing: 18%. 

Decisions subject to objection: Number of decisions subject to 
objection; 
Prescribed burning: 87; 
Mechanical treatment: 101; 
Commercial logging: 96; 
Construction/maintenance of fuel breaks: 41; 
Chemical/herbicide treatment: 7; 
Livestock grazing: 3. 

Decisions subject to objection: Number of decisions objected to; 
Prescribed burning: 41; 
Mechanical treatment: 46; 
Commercial logging: 41; 
Construction/maintenance of fuel breaks: 16; 
Chemical/herbicide treatment: 1; 
Livestock grazing: 2. 

Decisions subject to objection: Percentage of decisions objected to; 
Prescribed burning: 47%; 
Mechanical treatment: 46%; 
Commercial logging: 43%; 
Construction/maintenance of fuel breaks: 39%; 
Chemical/herbicide treatment: 14%; 
Livestock grazing: 67%. 

Decisions subject to objection: Acreage subject to objection; 
Prescribed burning: 588; 
Mechanical treatment: 306; 
Commercial logging: 577; 
Construction/maintenance of fuel breaks: 26; 
Chemical/herbicide treatment: 7; 
Livestock grazing: 64. 

Decisions subject to objection: Acreage objected to; 
Prescribed burning: 123; 
Mechanical treatment: 114; 
Commercial logging: 89; 
Construction/maintenance of fuel breaks: 11; 
Chemical/herbicide treatment: 1; 
Livestock grazing: 20. 

Decisions subject to objection: Percentage of acreage objected to; 
Prescribed burning: 21%; 
Mechanical treatment: 37%; 
Commercial logging: 15%; 
Construction/maintenance of fuel breaks: 42%; 
Chemical/herbicide treatment: 14%; 
Livestock grazing: 31%. 

Exempt decisions: Number of decisions exempt from appeal and objection; 
Prescribed burning: 49; 
Mechanical treatment: 68; 
Commercial logging: 19; 
Construction/maintenance of fuel breaks: 13; 
Chemical/herbicide treatment: 0; 
Livestock grazing: 2. 

Exempt decisions: Percentage of decisions exempt from appeal and 
objection; 
Prescribed burning: 5%; 
Mechanical treatment: 7%; 
Commercial logging: 3%; 
Construction/maintenance of fuel breaks: 5%; 
Chemical/herbicide treatment: 0; 
Livestock grazing: 17%. 

Exempt decisions: Acreage exempt from appeal and objection; 
Prescribed burning: 168; 
Mechanical treatment: 16; 
Commercial logging: 2; 
Construction/maintenance of fuel breaks: 1; 
Chemical/herbicide treatment: 0; 
Livestock grazing: 4. 

Exempt decisions: Percentage of acreage exempt from appeal and 
objection; 
Prescribed burning: 3%; 
Mechanical treatment: 1%; 
Commercial logging: less than 1%; 
Construction/maintenance of fuel breaks: less than 1%; 
Chemical/herbicide treatment: 0; 
Livestock grazing: 1%. 

Litigation: Number of decisions litigated; 
Prescribed burning: 27; 
Mechanical treatment: 24; 
Commercial logging: 25; 
Construction/maintenance of fuel breaks: 7; 
Chemical/herbicide treatment: 3; 
Livestock grazing: 0. 

Litigation: Percentage of decisions litigated; 
Prescribed burning: 3%; 
Mechanical treatment: 2%; 
Commercial logging: 4%; 
Construction/maintenance of fuel breaks: 3%; 
Chemical/herbicide treatment: 5%; 
Livestock grazing: 0. 

Litigation: Acreage litigated; 
Prescribed burning: 78; 
Mechanical treatment: 37; 
Commercial logging: 58; 
Construction/maintenance of fuel breaks: 8; 
Chemical/herbicide treatment: less than 1; 
Livestock grazing: 0. 

Litigation: Percentage of acreage litigated; 
Prescribed burning: 2%; 
Mechanical treatment: 3%; 
Commercial logging: 5%; 
Construction/maintenance of fuel breaks: 7%; 
Chemical/herbicide treatment: less than 1%; 
Livestock grazing: 0. 

Source: GAO analysis of survey results. 

Note: Numbers may not total because of rounding. Acreage data are not 
complete because some respondents did not report this information. In 
addition, depending on the status of the projects, some respondents 
reported the number of acres they planned to treat, while others 
reported the actual number of treated acres. 

[A] Because land management projects may involve multiple treatment 
methods, the sum of decisions involving each treatment method exceeds 
the total of 1,415 decisions in our review. In addition to the 
treatment methods listed in the table, survey respondents selected 
"other" as a treatment method used for 95 decisions. 

[B] Land management projects may treat the same acreage more than once 
using different treatment methods. 

[C] One project in our study was authorized under HFRA and involved a 
fuel reduction activity, but did not qualify as an "authorized 
hazardous fuel reduction project" under HFRA and therefore was not 
subject to the objection process. According to the survey respondent 
for this decision, it implemented HFRA provisions related to insect 
and disease infestation, and was subject to the notice, comment, and 
appeals process found in 36 C.F.R. part 215 because it included a 
timber sale activity. As a result, it is included in our count of 
decisions subject to appeal. 

[End of table] 

Appendix VII provides additional information on fuel reduction methods 
used and the number of appeals, objections and lawsuits by treatment 
method, for each Forest Service region. 

Commercial timber sale contracts were the most frequent contract type 
used to implement the decisions included in our study, and were the 
type most often challenged through appeals and objections. Decisions 
using stewardship contracting, however, were challenged at a higher 
rate than the other contract types, considering both appeals and 
objections. Table 5 shows, for all the decisions included in our 
study, the number and percentage of contract types, and acreage 
associated with, appeals, objections, and litigation.[Footnote 29] 

Table 5: Number and Percentage of Appeals, Objections, Exemptions, and 
Litigation Associated with Various Contracting Types, Fiscal Years 
2006 through 2008: 

Decisions: Total number of decisions[B]; 
Timber sale contract: 606; 
Service contract: 536; 
Stewardship contract: 218; 
Forest products permits[A]: 236. 

Decisions subject to appeal: Number of decisions subject to appeal[C]; 
Timber sale contract: 503; 
Service contract: 446; 
Stewardship contract: 166; 
Forest products permits[A]: 196. 

Decisions subject to appeal: Number of decisions appealed; 
Timber sale contract: 151; 
Service contract: 86; 
Stewardship contract: 55; 
Forest products permits[A]: 49. 

Decisions subject to appeal: Percentage of appealable decisions 
appealed; 
Timber sale contract: 30%; 
Service contract: 19%; 
Stewardship contract: 33%; 
Forest products permits[A]: 25%. 

Decisions subject to objection: Number of decisions subject to 
objection; 
Timber sale contract: 82; 
Service contract: 59; 
Stewardship contract: 48; 
Forest products permits[A]: 29. 

Decisions subject to objection: Number of decisions objected to; 
Timber sale contract: 32; 
Service contract: 22; 
Stewardship contract: 24; 
Forest products permits[A]: 11. 

Decisions subject to objection: Percentage of decisions objected to; 
Timber sale contract: 39%; 
Service contract: 37%; 
Stewardship contract: 50%; 
Forest products permits[A]: 38%. 

Exempt decisions: Number of decisions exempt from appeal and objection; 
Timber sale contract: 21; 
Service contract: 31; 
Stewardship contract: 4; 
Forest products permits[A]: 11. 

Exempt decisions: Percentage of decisions exempt from appeal and 
objection; 
Timber sale contract: 3%; 
Service contract: 6%; 
Stewardship contract: 2%; 
Forest products permits[A]: 5%. 

Litigation: Number of decisions litigated; 
Timber sale contract: 22; 
Service contract: 13; 
Stewardship contract: 5; 
Forest products permits[A]: 9. 

Litigation: Percentage of decisions litigated; 
Timber sale contract: 4%; 
Service contract: 2%; 
Stewardship contract: 2%; 
Forest products permits[A]: 4%. 

Source: GAO analysis of survey results. 

Note: We did not collect acreage information by contract type. 

[A] Forest products permits are often issued for such purposes as 
Christmas tree cutting and firewood gathering. 

[B] A total of 1,085 decisions also included the use of Forest Service 
personnel to carry out fuel reduction activities. In addition to the 
contract types listed in the table, survey respondents selected 
"other" as a contract method used for 75 decisions. Because land 
management projects may involve multiple contracts and may also use 
agency personnel in addition to contracts, the sum of decisions 
involving each contracting type exceeds the total of 1,415 decisions 
in our review. 

[C] One project in our study was authorized under HFRA and involved a 
fuel reduction activity, but did not qualify as an "authorized 
hazardous fuel reduction project" under HFRA and therefore was not 
subject to the objection process. According to the survey respondent 
for this decision, it implemented HFRA provisions related to insect 
and disease infestation, and was subject to the notice, comment, and 
appeals process found in 36 C.F.R. part 215 because it included a 
timber sale activity. As a result, it is included in our count of 
decisions subject to appeal. 

[End of table] 

Appendix VIII provides additional information on the contracting 
methods used for decisions included in our study and the appeal, 
objection, and litigation rates for each Forest Service region. 

Decisions Involving Fuel Reduction Activities in the Wildland-Urban 
Interface and Inventoried Roadless Areas; the Number of Appeals, 
Objections, and Lawsuits on Those Decisions; and the Associated 
Acreage: 

Of the 1,415 decisions in our review, respondents identified 954 
decisions that included activities in the wildland-urban interface and 
169 decisions that included activities in inventoried roadless areas. 
Both types of decision were appealed at about the same rate, while 
decisions involving inventoried roadless areas were objected to at a 
slightly higher rate than those involving the wildland-urban 
interface. Table 6 shows, for both wildland-urban interface and 
inventoried roadless areas, the number and percentage of, and acreage 
associated with, appeals, objections, and litigation. 

Table 6: Appeals, Objections, Exemptions, and Litigation of Decisions 
with Fuel Reduction Activities in the Wildland-Urban Interface and 
Inventoried Roadless Areas, and Associated Acreage, Fiscal Years 2006 
through 2008 (Acres in thousands): 

Decisions: Total number of decisions; 
Wildland-urban interface: 954; 
Inventoried roadless areas: 169. 

Decisions: Total acreage; 
Wildland-urban interface: 4,062; 
Inventoried roadless areas: 748. 

Appeals: Decisions subject to appeal; 
Wildland-urban interface: 772; 
Inventoried roadless areas: 138. 

Appeals: Number of decisions appealed; 
Wildland-urban interface: 140; 
Inventoried roadless areas: 26. 

Appeals: Percentage of appealable decisions appealed; 
Wildland-urban interface: 18%; 
Inventoried roadless areas: 19%. 

Appeals: Acreage subject to appeal; 
Wildland-urban interface: 2,764; 
Inventoried roadless areas: 709. 

Appeals: Acreage appealed; 
Wildland-urban interface: 335; 
Inventoried roadless areas: 26. 

Appeals: Percentage of appealable acreage appealed; 
Wildland-urban interface: 12%; 
Inventoried roadless areas: 4%. 

Objections: Decisions subject to objection; 
Wildland-urban interface: 113; 
Inventoried roadless areas: 22. 

Objections: Number of decisions objected to; 
Wildland-urban interface: 45; 
Inventoried roadless areas: 11. 

Objections: Percentage of decisions objected to; 
Wildland-urban interface: 40; 
Inventoried roadless areas: 50. 

Objections: Acreage subject to objection; 
Wildland-urban interface: 1,249; 
Inventoried roadless areas: 36. 

Objections: Acreage objected to; 
Wildland-urban interface: 159; 
Inventoried roadless areas: 14. 

Objections: Percentage of acreage objected to; 
Wildland-urban interface: 13%; 
Inventoried roadless areas: 39%. 

Exempt decisions: Number of decisions exempt from appeal and objection; 
Wildland-urban interface: 69; 
Inventoried roadless areas: 6. 

Exempt decisions: Percentage of decisions exempt from appeal and 
objection; 
Wildland-urban interface: 7%; 
Inventoried roadless areas: 4%. 

Exempt decisions: Acreage exempt from appeal and objection; 
Wildland-urban interface: 50; 
Inventoried roadless areas: 5. 

Exempt decisions: Percentage of acreage exempt from appeal and 
objection; 
Wildland-urban interface: 1%; 
Inventoried roadless areas: 1%. 

Litigation: Number of decisions litigated; 
Wildland-urban interface: 13; 
Inventoried roadless areas: 4. 

Litigation: Percentage of decisions litigated; 
Wildland-urban interface: 1; 
Inventoried roadless areas: 2. 

Litigation: Acreage litigated; 
Wildland-urban interface: 48; 
Inventoried roadless areas: 1. 

Litigation: Percentage of acreage litigated; 
Wildland-urban interface: 1%; 
Inventoried roadless areas: less than 1%. 

Source: GAO analysis of survey results. 

Note: Numbers may not total due to rounding. Acreage data are not 
complete because some respondents did not report this information. In 
addition, depending on the status of the projects, some respondents 
reported the number of acres they planned to treat, while others 
reported the actual number of treated acres. 

[End of table] 

Appendix IX provides information on the number of decisions with fuel 
reduction activities in the wildland-urban interface and the number of 
appeals, objections, and lawsuits for such decisions in each Forest 
Service region; this appendix also contains information on the various 
definitions used by field managers in responding to our survey. 

Regarding fuel reduction activities in inventoried roadless areas, the 
majority of decisions in our study involved no road construction in 
the roadless area--which is a primary concern related to hazardous 
fuel reduction activities in roadless areas. About 10 percent included 
temporary road construction or other road construction activity, with 
one decision involving the construction of a permanent road in an 
inventoried roadless area. Appendix IX provides information on the 
number of decisions with fuel reduction activities in inventoried 
roadless areas and the number of appeals, objections, and lawsuits for 
such decisions in each Forest Service region. 

Concluding Observations: 

Much has changed since we last reported on appeals and litigation of 
fuel reduction activities 7 years ago. One of the most significant 
changes to the process has been the passage of HFRA, which has 
provided a new approach for public challenges of fuel reduction 
projects by allowing the opportunity to formally object to decisions 
before they become final, rather than waiting to file appeals until 
after the decisions are made. Although the passage of HFRA was seen as 
an important new tool for streamlining fuel reduction decisions, our 
review indicates that the impact of the act appears to be limited. 
Most notably, fuel reduction decisions that used HFRA authority 
represented less than 10 percent of decisions signed during fiscal 
years 2006 through 2008. As a result, despite the opportunities HFRA 
introduced for a new approach to the administrative review process, in 
practice most decisions remained subject to the Forest Service's 
traditional postdecisional appeals process. In addition, although the 
agency's expectation was that HFRA would reduce litigation of fuel 
reduction decisions, our review shows that HFRA and non-HFRA decisions 
were litigated at about the same rate of 2 percent. 

Another area of ongoing change is the dispute over the Forest 
Service's ability to exempt categorically excluded decisions from 
appeal. Although most of these decisions were subject to appeal during 
the years we examined, the Supreme Court's 2009 ruling means that the 
regulation exempting categorically excluded decisions from appeal is 
once again in effect. However, two factors suggest ongoing uncertainty 
about this issue. First, the Supreme Court's ruling was made on 
procedural grounds rather than on the merits of the case--meaning that 
the court did not rule on whether the regulation is consistent with 
the Appeals Reform Act, allowing for the possibility of future 
challenges to the regulation. Second, even though the regulation 
survived the recent lawsuit, the Forest Service is considering changes 
to it in light of, among other things, the litigation it has 
engendered. Thus, the ultimate fate of the regulation--and the 
public's ability to appeal categorically excluded decisions--remains 
uncertain. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to the Forest Service for comment. 
The Forest Service did not provide comments, although it did provide 
technical corrections which we incorporated as appropriate. 

We are sending copies of this report to the Secretary of Agriculture; 
the Chief of the Forest Service; appropriate congressional committees; 
and other interested parties. The report also will be available at no 
charge on the GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff members have questions about this report, please 
contact me at (202) 512-3841 or mittala@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Key contributors to this report are 
listed in appendix XIII. 

Signed by: 

Anu K. Mittal: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

We examined (1) the number and type of Forest Service decisions 
involving hazardous fuel reduction activities signed in fiscal years 
2006 through 2008; (2) the number of these decisions that were 
objected to, appealed, or litigated, and the acreage associated with 
those decisions; (3) the outcomes of these objections, appeals, and 
lawsuits, including whether they were processed within prescribed time 
frames, and the identities of the objectors, appellants, and 
plaintiffs; (4) the treatment methods and contract types associated 
with fuel reduction decisions, and how frequently the different 
methods and types were objected to, appealed, and litigated; and (5) 
the number of decisions involving hazardous fuel reduction activities 
in the wildland-urban interface (WUI) and inventoried roadless areas 
(IRA), and how frequently these decisions were objected to, appealed, 
and litigated. To address our objectives, we implemented a nationwide, 
Web-based survey of Forest Service officials, to collect information 
about all fuel reduction decisions signed in fiscal years 2006 through 
2008 (See appendix XII for a copy of the survey). We supplemented the 
survey with a semistructured interview of officials in all nine Forest 
Service regions to gather additional details about time frames, 
outcomes and identities related to appeals and litigation of fuel 
reduction decisions. Details about this process are described below. 

To identify Forest Service decisions involving hazardous fuel 
reduction activities signed in fiscal years 2006 through 2008, we 
asked the agency's Ecosystem Management Coordinator to query a Forest 
Service database designed to track decision planning, appeals, and 
litigation for all Forest Service decisions---the Planning, Appeals, 
and Litigation System (PALS). This official queried the PALS database 
using the following criteria: (1) decisions signed in fiscal years 
2006 through 2008, and (2) decisions that included fuels management as 
a purpose and/or one or more fuel treatment activities. This initial 
query identified 1,437 decisions in 108 national forest system units. 

Because PALS was not designed to include all information we sought as 
part of our review--including information on the number of acres 
treated, treatment methods and contract types used, and decisions 
involving activities in the wildland-urban interface or in inventoried 
roadless areas--we determined that a nationwide survey would be 
necessary. We began our survey effort by ensuring that we had 
identified the correct universe of fuel reduction decisions. After 
reviewing the list of fuel reduction decisions from PALS and 
correcting for any obvious duplication and other errors, we sent a 
list of each national forest's fuel reduction decisions to the 
corresponding forest supervisor's office. We asked the supervisor or 
cognizant official to verify the accuracy of our list, removing any 
decisions that did not meet our criteria (i.e, that were not signed in 
fiscal years 2006 through 2008, or that did not involve any hazardous 
fuel reduction activities), and adding decisions that met our criteria 
but did not appear in PALS. At this time, we also asked the supervisor 
or cognizant official to identify Forest Service employees most 
knowledgeable about these decisions. A total of 1,415 decisions, 
issued by 108 national forests, were determined to fit our criteria. 
We gave recipients 3 weeks to respond to our request for information 
and granted extensions as needed. We obtained a 100 percent response 
rate from the national forests. 

To determine the characteristics of each fuel reduction decision, we 
subsequently administered a Web-based survey to those Forest Service 
employees identified by each forest supervisor or cognizant official 
as most knowledgeable about the decisions at all 108 national forests 
that issued decisions with hazardous fuel reduction activities in 
fiscal years 2006 through 2008. Appendix XII contains a copy of the 
survey used to gather these data. The survey asked respondents to 
provide information about each of the decisions, including the type of 
environmental analysis used, acres involved, treatment methods and 
contract types used, the extent to which the decisions included 
activities in the wildland-urban interface and inventoried roadless 
areas, and detailed information about the outcomes of those decisions 
subject to the predecisional objection process. 

The Forest Service does not have a uniform definition of a hazardous 
fuel reduction activity, a fact that could affect the information that 
forest managers reported to us. Many activities have the practical 
effect of reducing fuels, but their stated purpose may be for 
something other than, or in addition to, fuel reduction. For example, 
the cutting and gathering of firewood or forest products to provide a 
product to the public may have the additional benefit of reducing 
hazardous fuels. Some forest managers may have included such projects 
among the decisions they reported in their responses to our survey, 
while other forest managers with similar decisions may not have 
included them. 

Similarly, there are a number of limitations to the acreage data. The 
data reported by forest managers include a mixture of planned, 
estimated, and actual treatment acres for decisions included in our 
review. In our survey, we did not limit responses to acres actually 
treated because once a decision is made and documented, there are many 
reasons that activities covered by the decision may be delayed or not 
implemented, including availability of funding or personnel, weather 
conditions, and administrative appeals or litigation. In addition, 
national forests may have submitted more than one decision with 
activities on the same area of land, or may have planned to use a 
series of different treatments on the same land. Therefore, the 10.5 
million acres covered by decisions in our review may include 
overlapping acreage. 

Because this was not a sample survey, there are no sampling errors. 
However, the practical difficulties of conducting any survey may 
introduce errors, commonly referred to as nonsampling errors. For 
example, differences in how a particular question is interpreted, in 
the sources of information that are available to respondents, or in 
how the data are entered into a database or were analyzed can 
introduce unwanted variability into the survey results. We took steps 
in the development of the survey, the data collection, and data 
analysis to minimize these nonsampling errors. For example, prior to 
developing the data collection instruments, we met with Forest Service 
personnel at the headquarters, regional, and national forest levels to 
discuss the Forest Service decision-making, appeal, objection, and 
litigation processes. We also reviewed current policies, legislation, 
and court cases that are relevant to our questions and the analysis of 
the survey responses. Survey specialists designed the questionnaire in 
conjunction with GAO staff with subject matter expertise. The draft 
survey was then pretested with officials from four national forests in 
four different regions to ensure that the questions were relevant, 
clearly stated, and easy to comprehend. 

Upon receiving survey responses, we verified the accuracy of 5 percent 
of the surveys by comparing the responses to three survey questions 
against the decision documents used to complete the surveys, which 
were provided by respondents at our request. Using this approach, we 
verified 70 randomly selected decisions. Discrepancies between the 
survey responses and our data verification were discussed and resolved 
with the responsible forest official. In addition, we conducted follow-
up to clarify ambiguous or incomplete responses that were identified 
through an internal logic test of all submitted responses. Through our 
data verification process, we determined that the data submitted were 
generally reliable. 

To gather specific details about the outcomes of appeals and 
litigation, we conducted semistructured interviews with regional 
appeals and litigation officials in each of the Forest Service's nine 
regions. The semistructured interviews were used to gather information 
about each of the decisions that were appealed or litigated, including 
related dates, status and outcomes of administrative and court 
decisions, and the identities of the appellants and litigants. 
Information collected through these semistructured interviews was also 
verified for a randomly selected sample of decisions. We verified the 
accuracy of about 10 percent of the appealed decisions and about 50 
percent of the litigated decisions by comparing the information 
provided in response to several interview questions against the 
administrative and court decision documents provided to us by 
interviewees at our request. Any discrepancies between the interview 
responses and the documents provided were discussed and resolved with 
the responsible regional official. Through our data verification 
process, we determined that the data gathered during the 
semistructured interviews were generally reliable. 

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 ensure that all decisions meeting 
our criteria were identified. In particular, we had no way to 
determine whether forests were fully reporting their hazardous fuel 
reduction activities. To get some indication of the completeness and 
accuracy of the data provided by Forest Service, we contacted several 
interest groups that, according to our data collection efforts, often 
appealed and objected to decisions or determinations. We asked these 
groups to verify the data pertaining to their appeals, objections, and 
litigation of Forest Service fiscal year 2006 through 2008 fuel 
reduction decisions and to identify any missing data. The groups 
generally agreed that the data provided by the agency were complete 
and accurate. In addition, during these interviews, we asked the 
groups for their perspectives on the administrative process for 
challenging decisions, including the objection process authorized 
under the Healthy Forests Restoration Act. The interviewees' comments 
and perspectives are incorporated in this report. 

We conducted our work from October 2008 through February 2010, in 
accordance with all sections of GAO's Quality Assurance Framework that 
are relevant to our objectives. The framework requires that we plan 
and perform the engagement to obtain sufficient and appropriate 
evidence to meet our stated objectives and to discuss any limitations 
in our work. We believe that the information and data obtained, and 
the analysis conducted, provide a reasonable basis for any findings 
and conclusions in this product. 

Upon receiving survey responses, we verified the accuracy of 5 percent 
of the surveys by comparing the responses to three survey questions 
against the decision documents used to complete the surveys, which 
were provided by respondents at our request. Using this approach, we 
verified 70 randomly selected decisions. Discrepancies between the 
survey responses and our data verification were discussed and resolved 
with the responsible forest official. In addition, we conducted follow-
up to clarify ambiguous or incomplete responses that were identified 
through an internal logic test of all submitted responses. Through our 
data verification process, we determined that the data submitted were 
generally reliable. 

To gather specific details about the outcomes of appeals and 
litigation, we conducted semistructured interviews with regional 
appeals and litigation officials in each of the Forest Service's nine 
regions. The semistructured interviews were used to gather information 
about each of the decisions that were appealed or litigated, including 
related dates, status and outcomes of administrative and court 
decisions, and the identities of the appellants and litigants. 
Information collected through these semistructured interviews was also 
verified for a randomly selected sample of decisions. We verified the 
accuracy of about 10 percent of the appealed decisions and about 50 
percent of the litigated decisions by comparing the information 
provided in response to several interview questions against the 
administrative and court decision documents provided to us by 
interviewees at our request. Any discrepancies between the interview 
responses and the documents provided were discussed and resolved with 
the responsible regional official. Through our data verification 
process, we determined that the data gathered during the 
semistructured interviews were generally reliable. 

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 ensure that all decisions meeting 
our criteria were identified. In particular, we had no way to 
determine whether forests were fully reporting their hazardous fuel 
reduction activities. To get some indication of the completeness and 
accuracy of the data provided by Forest Service, we contacted several 
interest groups that, according to our data collection efforts, often 
appealed and objected to decisions or determinations. We asked these 
groups to verify the data pertaining to their appeals, objections, and 
litigation of Forest Service fiscal year 2006 through 2008 fuel 
reduction decisions and to identify any missing data. The groups 
generally agreed that the data provided by the agency were complete 
and accurate. In addition, during these interviews, we asked the 
groups for their perspectives on the administrative process for 
challenging decisions, including the objection process authorized 
under the Healthy Forests Restoration Act. The interviewees' comments 
and perspectives are incorporated in this report. 

We conducted our work from October 2008 through February 2010, in 
accordance with all sections of GAO's Quality Assurance Framework that 
are relevant to our objectives. The framework requires that we plan 
and perform the engagement to obtain sufficient and appropriate 
evidence to meet our stated objectives and to discuss any limitations 
in our work. We believe that the information and data obtained, and 
the analysis conducted, provide a reasonable basis for any findings 
and conclusions in this product. 

[End of section] 

Appendix II: Number of Fuel Reduction Decisions and Associated 
Acreage, by Forest Service Region: 

Figure 2 shows, for each of the Forest Service's nine regions, the 
number of fuel reduction decisions and the total associated acreage. 
As shown, the Southern Region (Region 8) had the largest number of 
decisions and the largest acreage, while the Alaska Region (Region 10) 
had the fewest decisions and the smallest acreage. 

Figure 2: Number of Fuel Reduction Decisions and Associated Acreage, 
by Forest Service Region: 

[Refer to PDF for image: illustrated horizontal bar graph] 

For each region, the illustration highlights the regional boundaries 
on a map of the US. 

Region: 1, Northern; 
Decisions: Categorical exclusions (decision memo required): 79; 
Decisions: Categorical exclusions (decision memo not required): 3; 
Decisions: Environmental assessments: 33; 
Decisions: Environmental impact statements: 17; 
Decisions: Total: 132; 
Acres (in thousands): Categorical exclusions (decision memo required): 
1,045; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 0; 
Acres (in thousands): Environmental assessments: 72; 
Acres (in thousands): Environmental impact statements: 78; 
Acres (in thousands): Total: 1,195. 

Region: 2, Rocky Mountain; 
Decisions: Categorical exclusions (decision memo required): 85; 
Decisions: Categorical exclusions (decision memo not required): 2; 
Decisions: Environmental assessments: 50; 
Decisions: Environmental impact statements: 14; 
Decisions: Total: 151; 
Acres (in thousands): Categorical exclusions (decision memo required): 
100; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 0; 
Acres (in thousands): Environmental assessments: 440; 
Acres (in thousands): Environmental impact statements: 211; 
Acres (in thousands): Total: 751. 

Region: 3, Southwestern; 
Decisions: Categorical exclusions (decision memo required): 60; 
Decisions: Categorical exclusions (decision memo not required): 1; 
Decisions: Environmental assessments: 17; 
Decisions: Environmental impact statements: 1; 
Decisions: Total: 79. 
Acres (in thousands): Categorical exclusions (decision memo required): 
726; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 1; 
Acres (in thousands): Environmental assessments: 2,382; 
Acres (in thousands): Environmental impact statements: 5; 
Acres (in thousands): Total: 3,114. 

Region: 4, Intermountain; 
Decisions: Categorical exclusions (decision memo required): 117; 
Decisions: Categorical exclusions (decision memo not required): 0; 
Decisions: Environmental assessments: 32; 
Decisions: Environmental impact statements: 8; 
Decisions: Total: 157; 
Acres (in thousands): Categorical exclusions (decision memo required): 
168; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 0; 
Acres (in thousands): Environmental assessments: 63; 
Acres (in thousands): Environmental impact statements: 19; 
Acres (in thousands): Total: 251. 

Region: 5, Pacific Southwest; 
Decisions: Categorical exclusions (decision memo required): 161; 
Decisions: Categorical exclusions (decision memo not required): 8; 
Decisions: Environmental assessments: 67; 
Decisions: Environmental impact statements: 15; 
Decisions: Total: 251; 
Acres (in thousands): Categorical exclusions (decision memo required): 
107; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 3; 
Acres (in thousands): Environmental assessments: 134; 
Acres (in thousands): Environmental impact statements: 72; 
Acres (in thousands): Total: 316. 

Region: 6, Pacific Northwest; 
Decisions: Categorical exclusions (decision memo required): 107; 
Decisions: Categorical exclusions (decision memo not required): 2; 
Decisions: Environmental assessments: 63; 
Decisions: Environmental impact statements: 8; 
Decisions: Total: 180; 
Acres (in thousands): Categorical exclusions (decision memo required): 
200; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 1; 
Acres (in thousands): Environmental assessments: 319; 
Acres (in thousands): Environmental impact statements: 58; 
Acres (in thousands): Total: 578. 

Region: 8, Southern; 
Decisions: Categorical exclusions (decision memo required): 226; 
Decisions: Categorical exclusions (decision memo not required): 1; 
Decisions: Environmental assessments: 115; 
Decisions: Environmental impact statements: 1; 
Decisions: Total: 344; 
Acres (in thousands): Categorical exclusions (decision memo required): 
1,130; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 0; 
Acres (in thousands): Environmental assessments: 2,806; 
Acres (in thousands): Environmental impact statements: 117; 
Acres (in thousands): Total: 4,056. 

Region: 9, Eastern; 
Decisions: Categorical exclusions (decision memo required): 55; 
Decisions: Categorical exclusions (decision memo not required): 0; 
Decisions: Environmental assessments: 54; 
Decisions: Environmental impact statements: 7; 
Decisions: Total: 116; 
Acres (in thousands): Categorical exclusions (decision memo required): 
79; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 0; 
Acres (in thousands): Environmental assessments: 179; 
Acres (in thousands): Environmental impact statements: 26; 
Acres (in thousands): Total: 284. 

Region: 10, Alaska; 
Decisions: Categorical exclusions (decision memo required): 3; 
Decisions: Categorical exclusions (decision memo not required): 0; 
Decisions: Environmental assessments: 2; 
Decisions: Environmental impact statements: 0; 
Decisions: Total: 5; 
Acres (in thousands): Categorical exclusions (decision memo required): 
1; 
Acres (in thousands): Categorical exclusions (decision memo not 
required): 0; 
Acres (in thousands): Environmental assessments: 1; 
Acres (in thousands): Environmental impact statements: 0; 
Acres (in thousands): Total: 2. 

Source: GAO analysis of survey results. 

Note: In Region 8, the decisions by decision type and acres do not 
match the sum for the total because for one decision, the respondent 
indicated that the decision did not fall within any of our survey 
selection categories. Also, acreage data are not complete because some 
respondents did not report this information. In addition, depending on 
the status of the projects, some respondents reported the number of 
acres they planned to treat, while others reported the actual number 
of treated acres. 

[End of figure] 

[End of section] 

Appendix III: Number of Appeals, Objections, and Lawsuits of Fuel 
Reduction Decisions, by Forest Service Region: 

Figure 3 shows, for each of the Forest Service's regions, information 
on appeals, objections, and litigation of fuel reduction decisions, 
including the total number of appeals, objections, and litigation and 
the percentage of decisions appealed, objected to, and litigated. The 
Southern Region (Region 8) had the highest combined total of decisions 
subject to appeal and objection; however, decisions in the Northern 
Region (Region 1) were challenged at the highest rate, considering 
both appeals and objections. 

Figure 3: Number of Decisions Subject to Appeal and Objection, and the 
Number and Frequency of Appeals, Objections, Exemptions, and 
Litigation, by Forest Service Region: 

[Refer to PDF for image: illustrated table] 

For each region, the illustration highlights the regional boundaries 
on a map of the US. 

Region: 1, Northern; 
Total number of decisions: 132; 
Number of decisions: Subject to Appeal: 112; 
Number of decisions: Appealed: 40; 
Number of decisions: Percent appealed: 36%; 
Number of decisions: Subject to objection: 15; 
Number of decisions: Objected to: 13; 
Number of decisions: Percent objected to: 87%; 
Number of decisions: Exempt: 5; 
Number of decisions: Percent exempt: 4%; 
Number of decisions: Litigated: 11; 
Number of decisions: Percent litigated: 8%. 

Region: 2, Rocky Mountain; 
Total number of decisions: 151; 
Number of decisions: Subject to Appeal: 122; 
Number of decisions: Appealed: 22; 
Number of decisions: Percent appealed: 18%; 
Number of decisions: Subject to objection: 21; 
Number of decisions: Objected to: 6; 
Number of decisions: Percent objected to: 29%; 
Number of decisions: Exempt: 8; 
Number of decisions: Percent exempt: 5%; 
Number of decisions: Litigated: 0; 
Number of decisions: Percent litigated: 0. 

Region: 3, Southwestern; 
Total number of decisions: 79; 
Number of decisions: Subject to Appeal: 66; 
Number of decisions: Appealed: 7; 
Number of decisions: Percent appealed: 11%; 
Number of decisions: Subject to objection: 8; 
Number of decisions: Objected to: 3; 
Number of decisions: Percent objected to: 38%; 
Number of decisions: Exempt: 5; 
Number of decisions: Percent exempt: 6%; 
Number of decisions: Litigated: 0; 
Number of decisions: Percent litigated: 0. 

Region: 4, Intermountain; 
Total number of decisions: 157; 
Number of decisions: Subject to Appeal: 137; 
Number of decisions: Appealed: 37; 
Number of decisions: Percent appealed: 27%; 
Number of decisions: Subject to objection: 15; 
Number of decisions: Objected to: 7; 
Number of decisions: Percent objected to: 47%; 
Number of decisions: Exempt: 5; 
Number of decisions: Percent exempt: 3%; 
Number of decisions: Litigated: 6; 
Number of decisions: Percent litigated: 4%. 

Region: 5, Pacific Southwest; 
Total number of decisions: 251; 
Number of decisions: Subject to Appeal: 212; 
Number of decisions: Appealed: 35; 
Number of decisions: Percent appealed: 17%; 
Number of decisions: Subject to objection: 16; 
Number of decisions: Objected to: 8; 
Number of decisions: Percent objected to: 50%; 
Number of decisions: Exempt: 23; 
Number of decisions: Percent exempt: 9%; 
Number of decisions: Litigated: 5; 
Number of decisions: Percent litigated: @5. 

Region: 6, Pacific Northwest; 
Total number of decisions: 180; 
Number of decisions: Subject to Appeal: 139; 
Number of decisions: Appealed: 21; 
Number of decisions: Percent appealed: 15%; 
Number of decisions: Subject to objection: 19; 
Number of decisions: Objected to: 10; 
Number of decisions: Percent objected to: 53%; 
Number of decisions: Exempt: 22; 
Number of decisions: Percent exempt: 12%; 
Number of decisions: Litigated: 3; 
Number of decisions: Percent litigated: 2%. 

Region: 8, Southern; 
Total number of decisions: 344; 
Number of decisions: Subject to Appeal: 301; 
Number of decisions: Appealed: 31; 
Number of decisions: Percent appealed: 10%; 
Number of decisions: Subject to objection: 16; 
Number of decisions: Objected to: 1; 
Number of decisions: Percent objected to: 6%; 
Number of decisions: Exempt: 27; 
Number of decisions: Percent exempt: 8%; 
Number of decisions: Litigated: 1; 
Number of decisions: Percent litigated: 0. 

Region: 9, Eastern; 
Total number of decisions: 116; 
Number of decisions: Subject to Appeal: 100; 
Number of decisions: Appealed: 24; 
Number of decisions: Percent appealed: 24%; 
Number of decisions: Subject to objection: 9; 
Number of decisions: Objected to: 1; 
Number of decisions: Percent objected to: 11%; 
Number of decisions: Exempt: 7; 
Number of decisions: Percent exempt: 6%; 
Number of decisions: Litigated: 3; 
Number of decisions: Percent litigated: 3%. 

Region: 10, Alaska; 
Total number of decisions: 5; 
Number of decisions: Subject to Appeal: 2; 
Number of decisions: Appealed: 0; 
Number of decisions: Percent appealed: 0; 
Number of decisions: Subject to objection: 2; 
Number of decisions: Objected to: 0; 
Number of decisions: Percent objected to: 0; 
Number of decisions: Exempt: 1; 
Number of decisions: Percent exempt: 20%; 
Number of decisions: Litigated: 0; 
Number of decisions: Percent litigated: 0. 

Source: GAO analysis of survey and interview results. 

[End of figure] 

[End of section] 

Appendix IV: Appeal Outcomes for Fuel Reduction Decisions, by Forest 
Service Region: 

Figure 4 shows, for each Forest Service region, the outcomes of 
appeals filed on fuel reduction decisions within the region. While six 
of the eight regions reporting appeal activity allowed the majority of 
appealed decisions to proceed without changes, the Southwestern Region 
(Region 3) had no appealed decisions that were allowed to proceed 
without changes and the highest rate of reversed decisions. 

Figure 4: Outcomes of Appeals of Fuel Reduction Decisions, by Forest 
Service Region: 

[Refer to PDF for image: illustrated table with regional map and pie-
chart] 

For each region, the illustration highlights the regional boundaries 
on a map of the US. 

Region: 1, Northern; 
Total number of appeals: 60; 
Percent affirmed with no change: 52%; 
Number affirmed with no change: 31; 
Percent Affirmed with instructions: 12%; 
Number Affirmed with instructions: 7; 
Percent Reversed: 13%; 
Number Reversed: 8; 
Percent Dismissed without review: 15%; 
Number Dismissed without review: 9; 
Percent Resolved informally/decision withdrawn: 8%; 
Number Resolved informally/decision withdrawn: 5; 
Percent Resolved informally/appeal withdraw: 0; 
Number Resolved informally/appeal withdraw: 0. 

Region: 2, Rocky Mountain; 
Total number of appeals: 28; 
Percent affirmed with no change: 57%; 
Number affirmed with no change: 16; 
Percent Affirmed with instructions: 11%; 
Number Affirmed with instructions: 3; 
Percent Reversed: 4%; 
Number Reversed: 1; 
Percent Dismissed without review: 14%; 
Number Dismissed without review: 4; 
Percent Resolved informally/decision withdrawn: 14%; 
Number Resolved informally/decision withdrawn: 4; 
Percent Resolved informally/appeal withdraw: 0; 
Number Resolved informally/appeal withdraw: 0. 

Region: 3, Southwest; 
Total number of appeals: 12; 
Percent affirmed with no change: 0; 
Number affirmed with no change: 0; 
Percent Affirmed with instructions: 50%; 
Number Affirmed with instructions: 6; 
Percent Reversed: 42%; 
Number Reversed: 5; 
Percent Dismissed without review: 8%; 
Number Dismissed without review: 1; 
Percent Resolved informally/decision withdrawn: 0; 
Number Resolved informally/decision withdrawn: 0; 
Percent Resolved informally/appeal withdraw: 0; 
Number Resolved informally/appeal withdraw: 0. 

Region: 4, Intermountain; 
Total number of appeals: 47; 
Percent affirmed with no change: 43%; 
Number affirmed with no change: 20; 
Percent Affirmed with instructions: 0; 
Number Affirmed with instructions: 0; 
Percent Reversed: 6%; 
Number Reversed: 3; 
Percent Dismissed without review: 38%; 
Number Dismissed without review: 18; 
Percent Resolved informally/decision withdrawn: 6%; 
Number Resolved informally/decision withdrawn: 3; 
Percent Resolved informally/appeal withdraw: 10%; 
Number Resolved informally/appeal withdraw: 5. 

Region: 5, Pacific Southwest; 
Total number of appeals: 49; 
Percent affirmed with no change: 61%; 
Number affirmed with no change: 30; 
Percent Affirmed with instructions: 12%; 
Number Affirmed with instructions: 6; 
Percent Reversed: 8%; 
Number Reversed: 4; 
Percent Dismissed without review: 2%; 
Number Dismissed without review: 1; 
Percent Resolved informally/decision withdrawn: 6%; 
Number Resolved informally/decision withdrawn: 3; 
Percent Resolved informally/appeal withdraw: 10%; 
Number Resolved informally/appeal withdraw: 5. 

Region: 6, Pacific Northwest; 
Total number of appeals: 24; 
Percent affirmed with no change: 54%; 
Number affirmed with no change: 13; 
Percent Affirmed with instructions: 0; 
Number Affirmed with instructions: 0; 
Percent Reversed: 0; 
Number Reversed: 0; 
Percent Dismissed without review: 17%; 
Number Dismissed without review: 4; 
Percent Resolved informally/decision withdrawn: 25%; 
Number Resolved informally/decision withdrawn: 6%; 
Percent Resolved informally/appeal withdraw: 4%; 
Number Resolved informally/appeal withdraw: 1. 

Region: 8, Southern; 
Total number of appeals: 33; 
Percent affirmed with no change: 64%; 
Number affirmed with no change: 21; 
Percent Affirmed with instructions: 0; 
Number Affirmed with instructions: 0; 
Percent Reversed: 3%; 
Number Reversed: 1; 
Percent Dismissed without review: 12%; 
Number Dismissed without review: 4; 
Percent Resolved informally/decision withdrawn: 21%; 
Number Resolved informally/decision withdrawn: 7; 
Percent Resolved informally/appeal withdraw: 0; 
Number Resolved informally/appeal withdraw: 0. 

Region: 9, Eastern; 
Total number of appeals: 45; 
Percent affirmed with no change: 64%; 
Number affirmed with no change: 29; 
Percent Affirmed with instructions: 0; 
Number Affirmed with instructions: 0; 
Percent Reversed: 4%; 
Number Reversed: 2; 
Percent Dismissed without review: 27%; 
Number Dismissed without review: 12; 
Percent Resolved informally/decision withdrawn: 4%; 
Number Resolved informally/decision withdrawn: 2; 
Percent Resolved informally/appeal withdraw: 0; 
Number Resolved informally/appeal withdraw: 0. 

Region: 10, Alaska; 
Total number of appeals: 0; 
Percent affirmed with no change: 0; 
Number affirmed with no change: 0; 
Percent Affirmed with instructions: 0; 
Number Affirmed with instructions: 0; 
Percent Reversed: 0; 
Number Reversed: 0; 
Percent Dismissed without review: 0; 
Number Dismissed without review: 0; 
Percent Resolved informally/decision withdrawn: 0; 
Number Resolved informally/decision withdrawn: 0; 
Percent Resolved informally/appeal withdraw: 0; 
Number Resolved informally/appeal withdraw: 0. 

Source: GAO analysis of interview results. 

Note: Numbers may not total because of rounding. 

[End of figure] 

[End of section] 

Appendix V: Litigation Outcomes for Fuel Reduction Decisions, by 
Forest Service Region: 

Figure 5 shows, for each Forest Service region, the outcomes of 
litigation filed on fuel reduction decisions within the region. Six of 
the nine regions experienced litigation during the period covered by 
our survey. The Northern Region (Region 1) had the highest number of 
decisions judicially challenged as well as the greatest number of 
ongoing lawsuits. 

Figure 5: Outcomes of Litigation of Fuel Reduction Decisions, by 
Forest Service Region: 

[Refer to PDF for image: illustrated table with regional map] 

For each region, the illustration highlights the regional boundaries 
on a map of the US. 

Region: 1, Northern; 
Total number of litigated decision: 11; 
Number of litigated outcomes: Won by Forest Service: 3; 
Number of litigated outcomes: Won by plaintiff: 4; 
Number of litigated outcomes: Continuing: 1; 
Number of litigated outcomes: Settled: 3. 

Region: 2, Rocky Mountain; 
Total number of litigated decision: 0; 
Number of litigated outcomes: Won by Forest Service: 0; 
Number of litigated outcomes: Won by plaintiff: 0; 
Number of litigated outcomes: Continuing: 0; 
Number of litigated outcomes: Settled: 0. 

Region: 3, Southwest; 
Total number of litigated decision: 0; 
Number of litigated outcomes: Won by Forest Service: 0; 
Number of litigated outcomes: Won by plaintiff: 0; 
Number of litigated outcomes: Continuing: 0; 
Number of litigated outcomes: Settled: 0. 

Region: 4, Intermountain; 
Total number of litigated decision: 6; 
Number of litigated outcomes: Won by Forest Service: 4; 
Number of litigated outcomes: Won by plaintiff: 0; 
Number of litigated outcomes: Continuing: 1; 
Number of litigated outcomes: Settled: 1. 

Region: 5, Pacific Southwest; 
Total number of litigated decision: 5; 
Number of litigated outcomes: Won by Forest Service: 1; 
Number of litigated outcomes: Won by plaintiff: 3; 
Number of litigated outcomes: Continuing: 0; 
Number of litigated outcomes: Settled: 1. 

Region: 6, Pacific Northwest; 
Total number of litigated decision: 3; 
Number of litigated outcomes: Won by Forest Service: 1; 
Number of litigated outcomes: Won by plaintiff: 0; 
Number of litigated outcomes: Continuing: 1; 
Number of litigated outcomes: Settled: 1. 

Region: 8, Southern; 
Total number of litigated decision: 1; 
Number of litigated outcomes: Won by Forest Service: 1; 
Number of litigated outcomes: Won by plaintiff: 0; 
Number of litigated outcomes: Continuing: 0; 
Number of litigated outcomes: Settled: 0. 

Region: 9, Eastern; 
Total number of litigated decision: 3; 
Number of litigated outcomes: Won by Forest Service: 0; 
Number of litigated outcomes: Won by plaintiff: 1; 
Number of litigated outcomes: Continuing: 0; 
Number of litigated outcomes: Settled: 2. 

Region: 10, Alaska; 
Total number of litigated decision: 0; 
Number of litigated outcomes: Won by Forest Service: 0; 
Number of litigated outcomes: Won by plaintiff: 0; 
Number of litigated outcomes: Continuing: 0; 
Number of litigated outcomes: Settled: 0. 

Source: GAO analysis of interview results. 

[End of figure] 

[End of section] 

Appendix VI: List of Appellants, Objectors and Litigants, by Forest 
Service Region: 

Tables 7, 8, and 9 list, by Forest Service region, the appellants, 
objectors, and litigants of fuel reduction decisions. We list the 
identities of organizations filing appeals, objections, and 
litigation, but summarize data on individuals to protect their 
privacy. As shown, organizations were most active in the Northern 
Region (Region 1) for appeals, objections, and litigation. Individuals 
were likewise most active in the Northern Region for objections, but 
were most active in the Eastern Region (Region 9) for appeals and 
litigation. 

Table 7: Appellants and Number of Appeals Filed, by Forest Service 
Region, Fiscal Years 2006 through 2008: 

Organization filing appeals: Alliance for the Wild Rockies; 
Number of appeals by region: 1: 32; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 10; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 42.
 
Organization filing appeals: American Forest Resource Council; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 2. 

Organization filing appeals: Attorney General, State of California; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Bark; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Biodiversity Conservation Alliance; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 11; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 11. 

Organization filing appeals: California Forest Association; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1.
 
Organization filing appeals: California Native Plants Society; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Carson Forest Watch; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 1; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1.
 
Organization filing appeals: Cascadia Wildlands Project; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Center for Biological Diversity; 
Number of appeals by region: 1: 1; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 3; 
Number of appeals by region: 4: 1; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 6. 

Organization filing appeals: Cherokee Forest Voices; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 3; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 3. 

Organization filing appeals: Citizens Assisted Monitoring; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Citizens for Better Forestry; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 2; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 2. 

Organization filing appeals: Clinch Coalition; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 1; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Colorado Wild; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 3; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 3. 

Organization filing appeals: Conservation Congress; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 4; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 4. 

Organization filing appeals: Defenders of Wildlife; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Environmental Law & Policy Center; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 3; 
Number of appeals by region: 10: 0; 
Total: 3. 

Organization filing appeals: Environmental Protection Information 
Center; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 5; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 5. 

Organization filing appeals: Ferry County Natural Resources Board; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Forest Guardians; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 4; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 4. 

Organization filing appeals: Forest Issues Group; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 4; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 4. 

Organization filing appeals: Forest Legacy; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Forest Service Employees for 
Environmental Ethics; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Forests Forever; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Friends of Boundary Waters Wilderness; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Friends of the Clearwater; 
Number of appeals by region: 1: 8; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 9. 

Organization filing appeals: Friends of the Wild Swan; 
Number of appeals by region: 1: 1; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Greater Yellowstone Coalition; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 2; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 2. 

Organization filing appeals: Habitat Education Center; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 3; 
Number of appeals by region: 10: 0; 
Total: 3. 

Organization filing appeals: Heartwood; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 9; 
Number of appeals by region: 10: 0; 
Total: 9. 

Organization filing appeals: Heartwood, Inc.; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 1; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Hells Canyon Preservation Council; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 4; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 4. 

Organization filing appeals: Idaho Conservation League; 
Number of appeals by region: 1: 5; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 1; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 6. 

Organization filing appeals: Idaho Sporting Congress; 
Number of appeals by region: 1: 2; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 3; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 5. 

Organization filing appeals: Indiana Forest Alliance; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Institute for Regeneration Agro Forestry; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: John Muir Project of the Earth Island 
Institute; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 12; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 12. 

Organization filing appeals: Keep the Sespe Wild Committee; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Kentucky Heartwood; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 1; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Kerncrest Audubon Society; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Klamath Forest Alliance; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 3; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 3. 

Organization filing appeals: Klamath-Siskiyou Wildlands Center; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 5; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 6. 

Organization filing appeals: Kootenai Environmental Alliance; 
Number of appeals by region: 1: 4; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 4. 

Organization filing appeals: Lassen Forest Preservation Group; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: League of Wilderness Defenders BMBP; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 6; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 6. 

Organization filing appeals: Leech Lake Band of Ojibwe; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Los Padres Forest Watch; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 2; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 2. 

Organization filing appeals: Minnesota Forest Industries, Inc.; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Montanans for Multiple Use; 
Number of appeals by region: 1: 1; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Native Ecosystems Council; 
Number of appeals by region: 1: 12; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 1; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 13. 

Organization filing appeals: Native Forest Network; 
Number of appeals by region: 1: 1; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: New Mexico Wilderness Alliance; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 1; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Newton County Wildlife Association; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 1; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Northwoods Wilderness Recovery; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: not documented, unknown; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 1; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 1; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 2. 

Organization filing appeals: Oregon Natural Resources Council; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 2; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 2. 

Organization filing appeals: Oregon Wild; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 10; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 10. 

Organization filing appeals: Ouachita Watch League; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 10; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 10. 

Organization filing appeals: Plumas Forest Project; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 5; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 5. 

Organization filing appeals: Prairie Hills Audubon Society; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 4; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 4. 

Organization filing appeals: Protect Our Woods; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Red Rock Forests; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 1; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Santa Fe Forest Watch; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 2; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 2. 

Organization filing appeals: Selkirk Conservation Alliance; 
Number of appeals by region: 1: 4; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 4. 

Organization filing appeals: Sequoia Forest Alliance; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Sequoia Forest Keeper; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Sierra Club; 
Number of appeals by region: 1: [Empty]; 
Number of appeals by region: 2: [Empty]; 
Number of appeals by region: 3: [Empty]; 
Number of appeals by region: 4: [Empty]; 
Number of appeals by region: 5: 13; 
Number of appeals by region: 6: 6; 
Number of appeals by region: 8: 6; 
Number of appeals by region: 9: 3; 
Number of appeals by region: 10: 0; 
Total: 28. 

Organization filing appeals: Sierra Forest Legacy; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 7; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 7. 

Organization filing appeals: Sierra Nevada Forest Protection Campaign; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 4; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 4. 

Organization filing appeals: Southern Appalachian Biodiversity Project; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 3; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 3. 

Organization filing appeals: Swan View Coalition; 
Number of appeals by region: 1: 1; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: The Clinch Coalition; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 1; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: The Ecology Center; 
Number of appeals by region: 1: 6; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 6. 

Organization filing appeals: The Lands Council; 
Number of appeals by region: 1: 22; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 23. 

Organization filing appeals: The Wilderness Society; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Tree of Life Alliance; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 1; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Tule River Conservancy; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 1; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Utah Environmental Congress; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 19; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 19. 

Organization filing appeals: Virginia Forest Watch; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 5; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 5. 

Organization filing appeals: Western Watersheds Project; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 1; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Wild Connections; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 1; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Wild South; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 5; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 5. 

Organization filing appeals: Wild Virginia; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 1; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: Wild Watershed; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 5; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 5. 

Organization filing appeals: WildSouth; 
Number of appeals by region: 1: 0; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 0; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 1; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 1. 

Organization filing appeals: WildWest Institute; 
Number of appeals by region: 1: 23; 
Number of appeals by region: 2: 0; 
Number of appeals by region: 3: 0; 
Number of appeals by region: 4: 12; 
Number of appeals by region: 5: 0; 
Number of appeals by region: 6: 0; 
Number of appeals by region: 8: 0; 
Number of appeals by region: 9: 0; 
Number of appeals by region: 10: 0; 
Total: 35. 

Total for organizational appellants: 
Number of appeals by region: 1: 123; 
Number of appeals by region: 2: 20; 
Number of appeals by region: 3: 16; 
Number of appeals by region: 4: 51; 
Number of appeals by region: 5: 81; 
Number of appeals by region: 6: 36; 
Number of appeals by region: 8: 40; 
Number of appeals by region: 9: 27; 
Number of appeals by region: 10: 0; 
Total: 394. 

Total for individual appellants: 
Number of appeals by region: 1: 6; 
Number of appeals by region: 2: 13; 
Number of appeals by region: 3: 7; 
Number of appeals by region: 4: 6; 
Number of appeals by region: 5: 5; 
Number of appeals by region: 6: 1; 
Number of appeals by region: 8: 8; 
Number of appeals by region: 9: 33; 
Number of appeals by region: 10: 0; 
Total: 79. 

Total for all appellants: 
Number of appeals by region: 1: 129; 
Number of appeals by region: 2: 33; 
Number of appeals by region: 3: 23; 
Number of appeals by region: 4: 57; 
Number of appeals by region: 5: 86; 
Number of appeals by region: 6: 37; 
Number of appeals by region: 8: 48; 
Number of appeals by region: 9: 60; 
Number of appeals by region: 10: 0; 
Total: Total: 473. 

Source: GAO analysis of interview results. 

Note: A decision can be appealed multiple times, and multiple 
appellants can be parties to an appeal. This table provides a list of 
the appellants who appeared in the 298 appeals of the 217 appealed 
decisions signed in fiscal years 2006 through 2008. 

[End of table] 

Table 8: Objectors and Number of Objections Filed, by Forest Service 
Region, Fiscal Years 2006 through 2008:
 
Organization filing objections: Alliance For the Wild Rockies; 
Number of objections by region: 1: 3; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 3.
 
Organization filing objections: American Forest Resource Council; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 1; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1.
 
Organization filing objections: Bark; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 1; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Biodiversity Conservation Alliance; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 2; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 2. 

Organization filing objections: Center for Biological Diversity; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 3; 
Number of objections by region: 4: 1; 
Number of objections by region: 5: 3; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 7.
 
Organization filing objections: Colorado Wild; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 2; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 2. 

Organization filing objections: Environmental Protection Information 
Center; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 1; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1.
 
Organization filing objections: Friends of the Bitterroot, Inc; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1.
 
Organization filing objections: Friends of the Wild Swan; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Great Old Broads for Wilderness; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 1; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Idaho Conservation League; 
Number of objections by region: 1: 5; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 3; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 8. 

Organization filing objections: Idaho Sporting Congress; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 1; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Idaho Transportation Department; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 1; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: John Muir Project of Earth Island 
Institute; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 1; 
Number of objections by region: 5: 3; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 4. 

Organization filing objections: Klamath Forest Alliance; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 2; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 2.
 
Organization filing objections: Klamath Riverkeeper; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 1; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Klamath-Siskiyou Wildlands Center; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 2; 
Number of objections by region: 6: 2; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 4. 

Organization filing objections: Kootenai Environmental Alliance; 
Number of objections by region: 1: 3; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 3. 

Organization filing objections: League of Wilderness Defenders-Blue 
Mountains Biodiversity Project; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 1; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Montana Logging Association; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Montana Wood Products Association; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Native Ecosystems Council; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Oregon Natural Resources Council; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 4; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 4. 

Organization filing objections: Oregon Wild; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 3; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 3. 

Organization filing objections: Pacific Rivers Council and American 
Wildlands; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Rocky Mountain Log Homes; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1.
 
Organization filing objections: Selkirk Conservation Alliance; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Sierra Club; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 1; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 3; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 4. 

Organization filing objections: Sierra Nevada Forest Protection 
Campaign; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 1; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Sinapu; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 1; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1.
 
Organization filing objections: South Carolina Native Plant Society; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 1; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: Southern Appalachian Biodiversity 
Project; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 1; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1.
 
Organization filing objections: The Lands Council; 
Number of objections by region: 1: 3; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 3. 

Organization filing objections: The Wilderness Society; 
Number of objections by region: 1: 2; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 2. 

Organization filing objections: Utah Environmental Congress; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 1; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: WildWest Institute; 
Number of objections by region: 1: 3; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 1; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 4. 

Organization filing objections: Native Forest Network; 
Number of objections by region: 1: 1; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Organization filing objections: The Ecology Center; 
Number of objections by region: 1: 2; 
Number of objections by region: 2: 0; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 2. 

Organization filing objections: Wilderness Workshop; 
Number of objections by region: 1: 0; 
Number of objections by region: 2: 1; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 0; 
Number of objections by region: 5: 0; 
Number of objections by region: 6: 0; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 1. 

Total for organizational objectors: 
Number of objections by region: 1: 30; 
Number of objections by region: 2: 8; 
Number of objections by region: 3: 3; 
Number of objections by region: 4: 10; 
Number of objections by region: 5: 13; 
Number of objections by region: 6: 14; 
Number of objections by region: 8: 2; 
Number of objections by region: 9: 0; 
Number of objections by region: 10: 0; 
Total: 80. 

Total for individual objectors: 
Number of objections by region: 1: 28; 
Number of objections by region: 2: 3; 
Number of objections by region: 3: 0; 
Number of objections by region: 4: 3; 
Number of objections by region: 5: 2; 
Number of objections by region: 6: 4; 
Number of objections by region: 8: 0; 
Number of objections by region: 9: 1; 
Number of objections by region: 10: 0; 
Total: 41. 

Total for all identified objectors: 
Number of objections by region: 1: 58; 
Number of objections by region: 2: 11; 
Number of objections by region: 3: 3; 
Number of objections by region: 4: 13; 
Number of objections by region: 5: 15; 
Number of objections by region: 6: 18; 
Number of objections by region: 8: 2; 
Number of objections by region: 9: 1; 
Number of objections by region: 10: 0; 
Total: Total: 121. 

Source: GAO analysis of survey results. 

Note: Proposed decisions can be the subject of multiple objections, 
and multiple objectors can be parties to an objection. This table 
provides a list of the objectors who appeared in the 101 objections 
filed on 49 proposed decisions that were signed in fiscal years 2006 
through 2008. 

[End of table] 

Table 9: Plaintiffs and Number of Lawsuits Filed, by Forest Service 
Region, Fiscal Years 2006 through 2008: 

Plaintiff: Alliance for the Wild Rockies; 
Number of lawsuits by region: 1: 8; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 1; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 9. 

Plaintiff: Bark; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 1; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: California Native Plant Society; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 1; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1.
 
Plaintiff: Cascadia Wildlands; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 1; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Citizens for Better Forestry; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 1; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Conservation Congress; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 2; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 2. 

Plaintiff: Earth Island Institute; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 3; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 3. 

Plaintiff: Environmental Law & Policy Center; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 2; 
Number of lawsuits by region: 10: 0; 
Total: 2. 

Plaintiff: Friends of the Bitterroot, Inc; 
Number of lawsuits by region: 1: 1; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Friends of the Boundary Waters Wilderness; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 1; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Habitat Education Center; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 2; 
Number of lawsuits by region: 10: 0; 
Total: 2. 

Plaintiff: Hell's Canyon Preservation Council; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 1; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Klamath Forest Alliance; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 1; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: League of Wilderness Defenders - BMBP; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 1; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Native Ecosystems Council; 
Number of lawsuits by region: 1: 7; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 7. 

Plaintiff: Northeastern Minnesotans for Wilderness; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 1; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Oregon Wild; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 1; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Sequoia Forest Keeper; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 1; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Sierra Club; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 1; 
Number of lawsuits by region: 6: 1; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 1; 
Number of lawsuits by region: 10: 0; 
Total: 3.
 
Plaintiff: Sierra Forest Legacy; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 1; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: The Lands Council; 
Number of lawsuits by region: 1: 1; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: The Wilderness Society; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 1; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: Utah Environmental Congress; 
Number of lawsuits by region: 1: 0; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 1; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 1. 

Plaintiff: WildWest Institute; 
Number of lawsuits by region: 1: 3; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 4; 
Number of lawsuits by region: 5: 0; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 0; 
Number of lawsuits by region: 10: 0; 
Total: 7. 

Total for organizational plaintiffs: 
Number of lawsuits by region: 1: 20; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 6; 
Number of lawsuits by region: 5: 11; 
Number of lawsuits by region: 6: 6; 
Number of lawsuits by region: 8: 0; 
Number of lawsuits by region: 9: 8; 
Number of lawsuits by region: 10: 0; 
Total: 51. 

Total for individual plaintiffs: 
Number of lawsuits by region: 1: 1; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 0; 
Number of lawsuits by region: 5: 1; 
Number of lawsuits by region: 6: 0; 
Number of lawsuits by region: 8: 1; 
Number of lawsuits by region: 9: 2; 
Number of lawsuits by region: 10: 0; 
Total: 5. 

Total for all plaintiffs; 
Number of lawsuits by region: 1: 21; 
Number of lawsuits by region: 2: 0; 
Number of lawsuits by region: 3: 0; 
Number of lawsuits by region: 4: 6; 
Number of lawsuits by region: 5: 12; 
Number of lawsuits by region: 6: 6; 
Number of lawsuits by region: 8: 1; 
Number of lawsuits by region: 9: 10; 
Number of lawsuits by region: 10: 0; 
Total: 56. 

Source: GAO analysis of interview results. 

Note: Multiple parties may serve as plaintiffs on a single lawsuit. 
This table provides a list of the plaintiffs who appeared in the 29 
lawsuits filed on decisions signed in fiscal years 2006 through 2008. 

[End of table] 

[End of section] 

Appendix VII: Fuel Reduction Treatment Methods and Number of Appeals, 
Objections, and Lawsuits, by Forest Service Region: 

Figure 6 shows, for each Forest Service region, the number of 
decisions using various fuel reduction treatment methods and the 
number and frequency of appeals, objections, and litigation by fuel 
reduction method. The rate at which treatment methods were used varied 
by region. For example, the Southern Region (Region 8) and the Eastern 
Region (Region 9) used prescribed burning more than any other 
treatment method, whereas the remaining regions used mechanical 
treatment the most. In addition, the Northern Region (Region 1) used 
commercial logging at a higher rate than any other region. 

Figure 6: Number of Decisions Subject to Appeal and Objection, and the 
Number and Frequency of Appeals, Objections, Exemptions, and 
Litigation, by Treatment Method and Forest Service Region: 

[Refer to PDF for image: illustrated table] 

For each region, the illustration highlights the regional boundaries 
on a map of the US. 

Region: 1, Northern; 
Total number of decisions: 132; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 86; 
* Number of decisions: Appealed: 30; 
* Number of decisions: Percent appealed: 35%; 
* Number of decisions: Subject to objection: 13; 
* Number of decisions: Objected to: 11; 
* Number of decisions: Percent objected to: 85%; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 11; 
* Number of decisions: Percent litigated: 8%; 
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 89; 
* Number of decisions: Appealed: 32; 
* Number of decisions: Percent appealed: 36%; 
* Number of decisions: Subject to objection: 15; 
* Number of decisions: Objected to: 13; 
* Number of decisions: Percent objected to: 87%; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 11; 
* Number of decisions: Percent litigated: 8%; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 79; 
* Number of decisions: Appealed: 34; 
* Number of decisions: Percent appealed: 43%; 
* Number of decisions: Subject to objection: 15; 
* Number of decisions: Objected to: 13; 
* Number of decisions: Percent objected to: 87%; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 11; 
* Number of decisions: Percent litigated: 8%; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 6; 
* Number of decisions: Appealed: 3; 
* Number of decisions: Percent appealed: 50%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 3; 
* Number of decisions: Percent objected to: 100%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 4; 
* Number of decisions: Appealed: 3; 
* Number of decisions: Percent appealed: 75%; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 2%. 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 12; 
* Number of decisions: Appealed: 5; 
* Number of decisions: Percent appealed: 42%; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 100%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%. 

Region: 2, Rocky Mountain; 
Total number of decisions: 151; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 87; 
* Number of decisions: Appealed: 17; 
* Number of decisions: Percent appealed: 20%; 
* Number of decisions: Subject to objection: 11; 
* Number of decisions: Objected to: 3; 
* Number of decisions: Percent objected to: 27%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 1; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 109; 
* Number of decisions: Appealed: 22; 
* Number of decisions: Percent appealed: 20%; 
* Number of decisions: Subject to objection: 18; 
* Number of decisions: Objected to: 4; 
* Number of decisions: Percent objected to: 22%; 
* Number of decisions: Exempt: 8; 
* Number of decisions: Percent exempt: 5%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 64; 
* Number of decisions: Appealed: 16; 
* Number of decisions: Percent appealed: 25%; 
* Number of decisions: Subject to objection: 16; 
* Number of decisions: Objected to: 4; 
* Number of decisions: Percent objected to: 25%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 32; 
* Number of decisions: Appealed: 10; 
* Number of decisions: Percent appealed: 31%; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 25%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 3; 
* Number of decisions: Appealed: 2; 
* Number of decisions: Percent appealed: 67%; 
* Number of decisions: Subject to objection: 4; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 25%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 2; 
* Number of decisions: Appealed: 1; 
* Number of decisions: Percent appealed: 50%; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 6; 
* Number of decisions: Appealed: 1; 
* Number of decisions: Percent appealed: 17%; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 3, Southwest; 
Total number of decisions: 79; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 54; 
* Number of decisions: Appealed: 7; 
* Number of decisions: Percent appealed: 13%; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 3; 
* Number of decisions: Percent objected to: 38%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 54; 
* Number of decisions: Appealed: 7; 
* Number of decisions: Percent appealed: 13%; 
* Number of decisions: Subject to objection: 7; 
* Number of decisions: Objected to: 3; 
* Number of decisions: Percent objected to: 43%; 
* Number of decisions: Exempt: 4; 
* Number of decisions: Percent exempt: 5%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 10; 
* Number of decisions: Appealed: 4; 
* Number of decisions: Percent appealed: 40%; 
* Number of decisions: Subject to objection: 5; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 40%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 13; 
* Number of decisions: Appealed: 4; 
* Number of decisions: Percent appealed: 31%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 33%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 1; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 8; 
* Number of decisions: Appealed: 2; 
* Number of decisions: Percent appealed: 25%; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 4, Intermountain; 
Total number of decisions: 157; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 104; 
* Number of decisions: Appealed: 31; 
* Number of decisions: Percent appealed: 30%; 
* Number of decisions: Subject to objection: 11; 
* Number of decisions: Objected to: 7; 
* Number of decisions: Percent objected to: 64%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 6; 
* Number of decisions: Percent litigated: 4%; 
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 104; 
* Number of decisions: Appealed: 25; 
* Number of decisions: Percent appealed: 24%; 
* Number of decisions: Subject to objection: 14; 
* Number of decisions: Objected to: 7; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 4; 
* Number of decisions: Percent litigated: #5; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 57; 
* Number of decisions: Appealed: 27; 
* Number of decisions: Percent appealed: 47%; 
* Number of decisions: Subject to objection: 13; 
* Number of decisions: Objected to: 7; 
* Number of decisions: Percent objected to: 54%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 4; 
* Number of decisions: Percent litigated: 3%; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 13; 
* Number of decisions: Appealed: 7; 
* Number of decisions: Percent appealed: 54%; 
* Number of decisions: Subject to objection: 5; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 40%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 1; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 8; 
* Number of decisions: Appealed: 4; 
* Number of decisions: Percent appealed: 50%; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%. 

Region: 5; Pacific Southwest; 
Total number of decisions: 251; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 173; 
* Number of decisions: Appealed: 31; 
* Number of decisions: Percent appealed: 18%; 
* Number of decisions: Subject to objection: 14; 
* Number of decisions: Objected to: 7; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 7; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 5; 
* Number of decisions: Percent litigated: 2%; 
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 191; 
* Number of decisions: Appealed: 34; 
* Number of decisions: Percent appealed: 18%; 
* Number of decisions: Subject to objection: 16; 
* Number of decisions: Objected to: 8; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 20; 
* Number of decisions: Percent exempt: 8%; 
* Number of decisions: Litigated: 5; 
* Number of decisions: Percent litigated: 2%; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 96; 
* Number of decisions: Appealed: 30; 
* Number of decisions: Percent appealed: 31%; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 4; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 5; 
* Number of decisions: Percent litigated: 2%; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 50; 
* Number of decisions: Appealed: 21; 
* Number of decisions: Percent appealed: 42%; 
* Number of decisions: Subject to objection: 9; 
* Number of decisions: Objected to: 6; 
* Number of decisions: Percent objected to: 67%; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1%; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 1; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 8; 
* Number of decisions: Appealed: 4; 
* Number of decisions: Percent appealed: 50%; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%. 

Region: 6, Pacific Northwest; 
Total number of decisions: 180; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 105; 
* Number of decisions: Appealed: 20; 
* Number of decisions: Percent appealed: 19%; 
* Number of decisions: Subject to objection: 17; 
* Number of decisions: Objected to: 9; 
* Number of decisions: Percent objected to: 53%; 
* Number of decisions: Exempt: 10; 
* Number of decisions: Percent exempt: 6%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1%; 
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 122; 
* Number of decisions: Appealed: 20; 
* Number of decisions: Percent appealed: 16%; 
* Number of decisions: Subject to objection: 18; 
* Number of decisions: Objected to: 9; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 19; 
* Number of decisions: Percent exempt: 11%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1%; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 84; 
* Number of decisions: Appealed: 21; 
* Number of decisions: Percent appealed: 25%; 
* Number of decisions: Subject to objection: 18; 
* Number of decisions: Objected to: 9; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 6; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 3; 
* Number of decisions: Percent litigated: 2%; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 22; 
* Number of decisions: Appealed: 4; 
* Number of decisions: Percent appealed: 18%; 
* Number of decisions: Subject to objection: 6; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 33%; 
* Number of decisions: Exempt: 5; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1%; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 2; 
* Number of decisions: Appealed: 1; 
* Number of decisions: Percent appealed: 50%; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: -; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 100%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 11; 
* Number of decisions: Appealed: 1; 
* Number of decisions: Percent appealed: 9%; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 100%; 
* Number of decisions: Exempt: 7; 
* Number of decisions: Percent exempt: 4%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%. 

Region: 8, Southern; 
Total number of decisions: 344; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 251; 
* Number of decisions: Appealed: 30; 
* Number of decisions: Percent appealed: 12%; 
* Number of decisions: Subject to objection: 7; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 14%; 
* Number of decisions: Exempt: 21; 
* Number of decisions: Percent exempt: 6%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: less than 1%; 
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 67; 
* Number of decisions: Appealed: 12; 
* Number of decisions: Percent appealed: 18%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 33%; 
* Number of decisions: Exempt: 5; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 94; 
* Number of decisions: Appealed: 15; 
* Number of decisions: Percent appealed: 16%; 
* Number of decisions: Subject to objection: 13; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 8%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: less than 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 58; 
* Number of decisions: Appealed: 9; 
* Number of decisions: Percent appealed: 16%; 
* Number of decisions: Subject to objection: 4; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: less than 1%; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 28; 
* Number of decisions: Appealed: 6; 
* Number of decisions: Percent appealed: 21%; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: less than 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 9, Eastern; 
Total number of decisions: 116; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 80; 
* Number of decisions: Appealed: 21; 
* Number of decisions: Percent appealed: 26%; 
* Number of decisions: Subject to objection: 5; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 4; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 2%;
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 65; 
* Number of decisions: Appealed: 15; 
* Number of decisions: Percent appealed: 23%; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 13%; 
* Number of decisions: Exempt: 5; 
* Number of decisions: Percent exempt: 4%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 2%; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 62; 
* Number of decisions: Appealed: 15; 
* Number of decisions: Percent appealed: 24%; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 13%; 
* Number of decisions: Exempt: 4; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 3; 
* Number of decisions: Percent litigated: 2%; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 31; 
* Number of decisions: Appealed: 6; 
* Number of decisions: Percent appealed: 19%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 5; 
* Number of decisions: Appealed: 1; 
* Number of decisions: Percent appealed: 20%; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 3; 
* Number of decisions: Appealed: 1; 
* Number of decisions: Percent appealed: 33%; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 11; 
* Number of decisions: Appealed: 3; 
* Number of decisions: Percent appealed: 27%; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%. 

Region: 10, Alaska; 
Total number of decisions: 5; 
Treatment method: Prescribed burning: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Mechanical treatment: 
* Number of decisions: Subject to Appeal: 2; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 20%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Commercial logging: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Construction of fuel breaks: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Chemical/herbicide: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Livestock grazing: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Treatment method: Other method: 
* Number of decisions: Subject to Appeal: 1; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Source: GAO analysis of survey results. 

Notes: Hyphens represent zero divided by zero. Because decisions may 
involve multiple treatment methods, the sum of decisions involving 
each treatment method may exceed the total number of decisions for 
each region. 

[End of figure] 

[End of section] 

Appendix VIII: Contract Types and Number of Appeals, Objections, and 
Lawsuits, by Forest Service Region: 

Figure 7 shows, for each Forest Service region, the number of 
decisions using various contract types and the number and frequency of 
appeals, objections, and litigation by contract type. The use of 
different contract types varies among regions. The Eastern Region 
(Region 9) has the highest rate of commercial timber sale contract use 
compared with other regions, while the Rocky Mountain Region (Region 
2) has the highest rate of stewardship contracting use. 

Figure 7: Number of Decisions Subject to Appeal and Objection, and the 
Number and Frequency of Appeals, Objections, Exemptions, and 
Litigation, by Contract Type and Forest Service Region: 

[Refer to PDF for image: illustrated table] 

For each region, the illustration highlights the regional boundaries 
on a map of the US. 

Region: 1; Northern; 
Total number of decisions: 132; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 63; 
* Number of decisions: Appealed: 28; 
* Number of decisions: Percent appealed: 44%; 
* Number of decisions: Subject to objection: 10; 
* Number of decisions: Objected to: 9; 
* Number of decisions: Percent objected to: 90%; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 7; 
* Number of decisions: Percent litigated: 5%; 
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 24; 
* Number of decisions: Appealed: 8; 
* Number of decisions: Percent appealed: 33%; 
* Number of decisions: Subject to objection: 4; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 4; 
* Number of decisions: Percent litigated: 3%; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 23; 
* Number of decisions: Appealed: 13; 
* Number of decisions: Percent appealed: 57%; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 7; 
* Number of decisions: Percent objected to: 88%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 4; 
* Number of decisions: Percent litigated: 3%; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 68; 
* Number of decisions: Appealed: 21; 
* Number of decisions: Percent appealed: 31%; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 6; 
* Number of decisions: Percent objected to: 75%; 
* Number of decisions: Exempt: 4; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 9; 
* Number of decisions: Percent litigated: 7%; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 7; 
* Number of decisions: Appealed: 4; 
* Number of decisions: Percent appealed: 57%; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 2%; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 5; 
* Number of decisions: Appealed: 1; 
* Number of decisions: Percent appealed: 20%; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 100%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 2, Rocky Mountain; 
Total number of decisions: 151; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 59; 
* Number of decisions: Appealed: 15; 
* Number of decisions: Percent appealed: 25%; 
* Number of decisions: Subject to objection: 17; 
* Number of decisions: Objected to: 4; 
* Number of decisions: Percent objected to: 24%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 70; 
* Number of decisions: Appealed: 14; 
* Number of decisions: Percent appealed: 20%; 
* Number of decisions: Subject to objection: 15; 
* Number of decisions: Objected to: 4; 
* Number of decisions: Percent objected to: 27%; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 25; 
* Number of decisions: Appealed: 8; 
* Number of decisions: Percent appealed: 32%; 
* Number of decisions: Subject to objection: 12; 
* Number of decisions: Objected to: 4; 
* Number of decisions: Percent objected to: 33%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 94; 
* Number of decisions: Appealed: 17; 
* Number of decisions: Percent appealed: 18%; 
* Number of decisions: Subject to objection: 12; 
* Number of decisions: Objected to: 3; 
* Number of decisions: Percent objected to: 25%; 
* Number of decisions: Exempt: 5; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 24; 
* Number of decisions: Appealed: 5; 
* Number of decisions: Percent appealed: 21%; 
* Number of decisions: Subject to objection: 4; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 25%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 11; 
* Number of decisions: Appealed: 4; 
* Number of decisions: Percent appealed: 36%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 33%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 3, Southwest; 
Total number of decisions: 79; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 14; 
* Number of decisions: Appealed: 5; 
* Number of decisions: Percent appealed: 36%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 67%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 25; 
* Number of decisions: Appealed: 3; 
* Number of decisions: Percent appealed: 12%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 67%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 3; 
* Number of decisions: Appealed: 2; 
* Number of decisions: Percent appealed: 67%; 
* Number of decisions: Subject to objection: 5; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 40%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 52; 
* Number of decisions: Appealed: 5; 
* Number of decisions: Percent appealed: 10%; 
* Number of decisions: Subject to objection: 6; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 33%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 24; 
* Number of decisions: Appealed: 5; 
* Number of decisions: Percent appealed: 21%; 
* Number of decisions: Subject to objection: 4; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 25%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 11; 
* Number of decisions: Appealed: 3; 
* Number of decisions: Percent appealed: 27%; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 4, Intermountain; 
Total number of decisions: 157; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 54; 
* Number of decisions: Appealed: 28; 
* Number of decisions: Percent appealed: 52%; 
* Number of decisions: Subject to objection: 11; 
* Number of decisions: Objected to: 5; 
* Number of decisions: Percent objected to: 45%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 5; 
* Number of decisions: Percent litigated: 3%; 
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 45; 
* Number of decisions: Appealed: 9; 
* Number of decisions: Percent appealed: 20%; 
* Number of decisions: Subject to objection: 5; 
* Number of decisions: Objected to: 3; 
* Number of decisions: Percent objected to: 60%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 9; 
* Number of decisions: Appealed: 5; 
* Number of decisions: Percent appealed: 56%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 67%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 116; 
* Number of decisions: Appealed: 30; 
* Number of decisions: Percent appealed: 26%; 
* Number of decisions: Subject to objection: 14; 
* Number of decisions: Objected to: 7; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 6; 
* Number of decisions: Percent litigated: 4%; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 23; 
* Number of decisions: Appealed: 6; 
* Number of decisions: Percent appealed: 26%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 33%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1%; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 10; 
* Number of decisions: Appealed: 2; 
* Number of decisions: Percent appealed: 20%; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 5, Pacific Southwest; 
Total number of decisions: 251; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 87; 
* Number of decisions: Appealed: 27; 
* Number of decisions: Percent appealed: 31%; 
* Number of decisions: Subject to objection: 10; 
* Number of decisions: Objected to: 4; 
* Number of decisions: Percent objected to: 40%; 
* Number of decisions: Exempt: 4; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 5; 
* Number of decisions: Percent litigated: 2%; 
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 117; 
* Number of decisions: Appealed: 25; 
* Number of decisions: Percent appealed: 21%; 
* Number of decisions: Subject to objection: 10; 
* Number of decisions: Objected to: 4; 
* Number of decisions: Percent objected to: 40%; 
* Number of decisions: Exempt: 10; 
* Number of decisions: Percent exempt: 4%; 
* Number of decisions: Litigated: 4; 
* Number of decisions: Percent litigated: 2%; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 46; 
* Number of decisions: Appealed: 17; 
* Number of decisions: Percent appealed: 37%; 
* Number of decisions: Subject to objection: 4; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: less than 1%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: less than 1%; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 167; 
* Number of decisions: Appealed: 24; 
* Number of decisions: Percent appealed: 14%; 
* Number of decisions: Subject to objection: 13; 
* Number of decisions: Objected to: 5; 
* Number of decisions: Percent objected to: 38%; 
* Number of decisions: Exempt: 18; 
* Number of decisions: Percent exempt: 7%; 
* Number of decisions: Litigated: 4; 
* Number of decisions: Percent litigated: 2%; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 41; 
* Number of decisions: Appealed: 10; 
* Number of decisions: Percent appealed: 24%; 
* Number of decisions: Subject to objection: 5; 
* Number of decisions: Objected to: 3; 
* Number of decisions: Percent objected to: 60%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 3; 
* Number of decisions: Percent litigated: 1%; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 5; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 2; 
* Number of decisions: Percent objected to: 100%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: less than 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 6, Pacific Northwest; 
Total number of decisions: 180; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 70; 
* Number of decisions: Appealed: 20; 
* Number of decisions: Percent appealed: 29%; 
* Number of decisions: Subject to objection: 12; 
* Number of decisions: Objected to: 6; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 6; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 3; 
* Number of decisions: Percent litigated: 2%;
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 86; 
* Number of decisions: Appealed: 14; 
* Number of decisions: Percent appealed: 16%; 
* Number of decisions: Subject to objection: 14; 
* Number of decisions: Objected to: 7; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 11; 
* Number of decisions: Percent exempt: 6%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1%; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 32; 
* Number of decisions: Appealed: 6; 
* Number of decisions: Percent appealed: 19%; 
* Number of decisions: Subject to objection: 10; 
* Number of decisions: Objected to: 6; 
* Number of decisions: Percent objected to: 60%; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 109; 
* Number of decisions: Appealed: 16; 
* Number of decisions: Percent appealed: 15%; 
* Number of decisions: Subject to objection: 14; 
* Number of decisions: Objected to: 7; 
* Number of decisions: Percent objected to: 50%; 
* Number of decisions: Exempt: 18; 
* Number of decisions: Percent exempt: 10%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1%; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 31; 
* Number of decisions: Appealed: 7; 
* Number of decisions: Percent appealed: 23%; 
* Number of decisions: Subject to objection: 3; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 33%; 
* Number of decisions: Exempt: 4; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 1%; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 6; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 2%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 8, Southern; 
Total number of decisions: 344; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 97; 
* Number of decisions: Appealed: 15; 
* Number of decisions: Percent appealed: 15%; 
* Number of decisions: Subject to objection: 12; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 8%; 
* Number of decisions: Exempt: 2; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 51; 
* Number of decisions: Appealed: 5; 
* Number of decisions: Percent appealed: 10%; 
* Number of decisions: Subject to objection: 5; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 3; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 9; 
* Number of decisions: Appealed: 1; 
* Number of decisions: Percent appealed: 11%; 
* Number of decisions: Subject to objection: 4; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 25%; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 236; 
* Number of decisions: Appealed: 29; 
* Number of decisions: Percent appealed: 12%; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 13%; 
* Number of decisions: Exempt: 22; 
* Number of decisions: Percent exempt: 6%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 20; 
* Number of decisions: Appealed: 3; 
* Number of decisions: Percent appealed: 15%; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: less than 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 2; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: less than 1%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 0. 

Region: 9, Eastern; 
Total number of decisions: 116; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 59; 
* Number of decisions: Appealed: 13; 
* Number of decisions: Percent appealed: 22%; 
* Number of decisions: Subject to objection: 7; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 14%; 
* Number of decisions: Exempt: 4; 
* Number of decisions: Percent exempt: 3%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 2%; 
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 26; 
* Number of decisions: Appealed: 8; 
* Number of decisions: Percent appealed: 31%; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 1; 
* Number of decisions: Percent litigated: 1%; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 19; 
* Number of decisions: Appealed: 3; 
* Number of decisions: Percent appealed: 16%; 
* Number of decisions: Subject to objection: 2; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 79; 
* Number of decisions: Appealed: 21; 
* Number of decisions: Percent appealed: 27; 
* Number of decisions: Subject to objection: 8; 
* Number of decisions: Objected to: 1; 
* Number of decisions: Percent objected to: 13; 
* Number of decisions: Exempt: 7; 
* Number of decisions: Percent exempt: 6%; 
* Number of decisions: Litigated: 2; 
* Number of decisions: Percent litigated: 2%; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 14; 
* Number of decisions: Appealed: 3; 
* Number of decisions: Percent appealed: 21; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 4; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 1%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Region: 10, Alaska; 
Total number of decisions: 5; 
Contract type: Commercial timber sale contract: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Service contract: 
* Number of decisions: Subject to Appeal: 2; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 1; 
* Number of decisions: Percent exempt: 20%; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Stewardship contract: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest service personnel/force account: 
* Number of decisions: Subject to Appeal: 1; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: 0; 
* Number of decisions: Subject to objection: 1; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: 0; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Forest product permits: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0; 
Contract type: Other mechanism: 
* Number of decisions: Subject to Appeal: 0; 
* Number of decisions: Appealed: 0; 
* Number of decisions: Percent appealed: -; 
* Number of decisions: Subject to objection: 0; 
* Number of decisions: Objected to: 0; 
* Number of decisions: Percent objected to: -; 
* Number of decisions: Exempt: 0; 
* Number of decisions: Percent exempt: 0; 
* Number of decisions: Litigated: 0; 
* Number of decisions: Percent litigated: 0. 

Source: GAO analysis of survey results. 

Notes: Hyphens represent zero divided by zero. Because decisions may 
involve multiple contract types, the sum of decisions involving each 
type may exceed the total number of decisions for each region. 

[End of figure] 

[End of section] 

Appendix IX: Fuel Reduction Decisions in the Wildland-Urban Interface 
and Inventoried Roadless Areas, by Forest Service Region: 

In this appendix, Figures 8 and 9 provide information about appeals, 
objections, and litigation of fuel reduction activities in the 
wildland-urban interface and in inventoried roadless areas. Figure 8 
shows, for each Forest Service region, the number of decisions with 
fuel reduction activities in the wildland-urban interface and the 
number and frequency of appeals, objections, and litigation of such 
decisions by region. The Southern Region (Region 8) had the most 
decisions in the wildland-urban interface, while the Northern Region 
(Region 1) had the highest number of appeals and objections of such 
decisions, and the highest rate at which decisions were challenged, 
considering both appeals and objections. 

Figure 8: Number of Fuel Reduction Decisions in the Wildland-Urban 
Interface (WUI), and the Number and Frequency of Appeals, Objections, 
Exemptions, and Litigation, by Forest Service Region: 

[Refer to PDF for image: illustrated table with pie-charts] 

For each region, the illustration highlights the regional boundaries 
on a map of the US. 

Region: 1, Northern; 
Total number of decisions: 103; 
Number of WUI decisions: 
* Subject to appeal: 85; 
* Appealed: 31; 
* Percent appealed: 36%; 
* Subject to objection: 14; 
* Objected to: 12; 
* Percent objected to: 86%; 
* Exempt: 4; 
* Percent exempt: 4%; 
* Litigated: 8; 
* Percent litigated: 8%; 
Regional percentage of total WUI decisions nationwide: 11%. 

Region: 2, Rocky Mountain; 
Total number of decisions: 108; 
Number of WUI decisions: 
* Subject to appeal: 87; 
* Appealed: 17; 
* Percent appealed: 20%; 
* Subject to objection: 18; 
* Objected to: 4; 
* Percent objected to: 22%; 
* Exempt: 3; 
* Percent exempt: 3%; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total WUI decisions nationwide: 11%. 

Region: 3, Southwest; 
Total number of decisions: 60; 
Number of WUI decisions: 
* Subject to appeal: 49; 
* Appealed: 5; 
* Percent appealed: 10%; 
* Subject to objection: 8; 
* Objected to: 3; 
* Percent objected to: 38%; 
* Exempt: 3; 
* Percent exempt: 5%; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total WUI decisions nationwide: 6%. 

Region: 4, Intermountain; 
Total number of decisions: 104; 
Number of WUI decisions: 
* Subject to appeal: 84; 
* Appealed: 22; 
* Percent appealed: 26%; 
* Subject to objection: 15; 
* Objected to: 7; 
* Percent objected to: 47%; 
* Exempt: 5; 
* Percent exempt: 5%; 
* Litigated: 2; 
* Percent litigated: 2%; 
Regional percentage of total WUI decisions nationwide: 11%. 

Region: 5, Pacific Southwest; 
Total number of decisions: 172; 
Number of WUI decisions: 
* Subject to appeal: 145; 
* Appealed: 21; 
* Percent appealed: 14%; 
* Subject to objection: 14; 
* Objected to: 8; 
* Percent objected to: 57%; 
* Exempt: 13; 
* Percent exempt: 8%; 
* Litigated: 2; 
* Percent litigated: 2%; 
Regional percentage of total WUI decisions nationwide: 18%. 

Region: 6, Pacific Northwest; 
Total number of decisions: 97; 
Number of WUI decisions: 
* Subject to appeal: 68; 
* Appealed: 9; 
* Percent appealed: 13%; 
* Subject to objection: 18; 
* Objected to: 9; 
* Percent objected to: 50%; 
* Exempt: 11; 
* Percent exempt: 11%; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total WUI decisions nationwide: 10%. 

Region: 8, Southern; 
Total number of decisions: 226; 
Number of WUI decisions: 
* Subject to appeal: 189; 
* Appealed: 22; 
* Percent appealed: 12%; 
* Subject to objection: 15; 
* Objected to: 1; 
* Percent objected to: 7%; 
* Exempt: 22; 
* Percent exempt: 10%; 
* Litigated: 1; 
* Percent litigated: less than 1%; 
Regional percentage of total WUI decisions nationwide: 24%. 

Region: 9, Eastern; 
Total number of decisions: 81; 
Number of WUI decisions: 
* Subject to appeal: 65; 
* Appealed: 13; 
* Percent appealed: 20%; 
* Subject to objection: 9; 
* Objected to: 1; 
* Percent objected to: 11%; 
* Exempt: 7; 
* Percent exempt: 9%; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total WUI decisions nationwide: 8%. 

Region: 10, Alaska; 
Total number of decisions: 3; 
Number of WUI decisions: 
* Subject to appeal: 0; 
* Appealed: 0; 
* Percent appealed: 0; 
* Subject to objection: 2; 
* Objected to: 0; 
* Percent objected to: 0; 
* Exempt: 1; 
* Percent exempt: 33%; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total WUI decisions nationwide: less than 1%. 

Source: GAO analysis of survey results. 

[End of figure] 

According to survey respondents, over half of these decisions (696) 
contained definitions of wildland-urban interface that were based on 
the definition provided in the January 4, 2001, Federal Register as 
refined by HFRA. HFRA Section 101 (16) defines wildland-urban 
interface as an area within or adjacent to a community that is 
identified as at risk in a community wildfire protection plan. 
[Footnote 30] In addition, for areas for which a community wildfire 
protection plan is not in effect, the definition in HFRA includes 
areas (1) extending 1/2 mile from the boundary of an at-risk 
community, or (2) within 1 1/2 miles of the boundary of an at-risk 
community, including any land that has for example, a sustained steep 
slope, a geographic feature that could help when creating an effective 
firebreak, or Condition Class 3 land,[Footnote 31] or (3) is adjacent 
to an evacuation route.[Footnote 32] Further, while many additional 
survey respondents who did not select this definition provided their 
own definition of wildland-urban interface, we found that 36 such 
respondents had definitions very similar to that contained in HFRA. 

Other respondents said they defined wildland-urban interface as it is 
referenced in their forests' National Forest Land Management Plans. 
Others said they used a combination of definitions from multiple 
sources. For example, in the Pacific Southwest Region, several 
wildland-urban interface definitions were based on both the Federal 
Register and their forests' National Forest Land Management Plans. 
Still others defined wildland-urban interface as an area within some 
distance from private land, or private lands with structures. The 
remaining respondents either said they did not have a definition for 
wildland-urban interface (14) or did not know the definition they used 
to identify the wildland-urban interface (49). 

Figure 9 shows, for each Forest Service region, the number of 
decisions with fuel reduction activities in inventoried roadless areas 
and the number and frequency of appeals, objections, and litigation of 
such decisions by region. The Intermountain Region (Region 4) had the 
most decisions with activities occurring in inventoried roadless areas 
and also the highest number of appeals, objections, and cases 
litigated. However, the Pacific Northwest Region (Region 6) had the 
highest rate at which decisions were challenged, considering both 
appeals and objections. 

Figure 9: Number of Fuel Reduction Decisions in Inventoried Roadless 
Areas (IRA), and the Number and Frequency of Appeals, Objections, 
Exemptions, and Litigation, by Forest Service Region: 

[Refer to PDF for image: illustrated table with pie-charts] 

For each region, the illustration highlights the regional boundaries 
on a map of the US. 

Region: 1, Northern; 
Total number of decisions: 17; 
Number of IRA decisions: 
* Subject to appeal: 13; 
* Appealed: 3; 
* Percent appealed: 23%; 
* Subject to objection: 4; 
* Objected to: 3; 
* Percent objected to: 75%; 
* Exempt: 0; 
* Percent exempt: 0; 
* Litigated: 1; 
* Percent litigated: 6%; 
Regional percentage of total IRA decisions nationwide: 10%. 

Region: 2, Rocky Mountain; 
Total number of decisions: 30; 
Number of IRA decisions: 
* Subject to appeal: 24; 
* Appealed: 5; 
* Percent appealed: 21%; 
* Subject to objection: 6; 
* Objected to: 1; 
* Percent objected to: 176%; 
* Exempt: 0; 
* Percent exempt: 0; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total IRA decisions nationwide: 18%. 

Region: 3, Southwest; 
Total number of decisions: 12; 
Number of IRA decisions: 
* Subject to appeal: 11; 
* Appealed: 2; 
* Percent appealed: 18%; 
* Subject to objection: 8; 
* Objected to: 1; 
* Percent objected to: 0; 
* Exempt: 0; 
* Percent exempt: 0; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total IRA decisions nationwide: 7%. 

Region: 4, Intermountain; 
Total number of decisions: 71; 
Number of IRA decisions: 
* Subject to appeal: 61; 
* Appealed: 10; 
* Percent appealed: 16%; 
* Subject to objection: 8; 
* Objected to: 5; 
* Percent objected to: 63%; 
* Exempt: 2; 
* Percent exempt: 3%; 
* Litigated: 3; 
* Percent litigated: 5%; 
Regional percentage of total IRA decisions nationwide: 42%. 

Region: 5, Pacific Southwest; 
Total number of decisions: 9; 
Number of IRA decisions: 
* Subject to appeal: 9; 
* Appealed: 3; 
* Percent appealed: 33%; 
* Subject to objection: 0; 
* Objected to: 0; 
* Percent objected to: 0; 
* Exempt: 0; 
* Percent exempt: 0; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total IRA decisions nationwide: 5%. 

Region: 6, Pacific Northwest; 
Total number of decisions: 10; 
Number of IRA decisions: 
* Subject to appeal: 3; 
* Appealed: 1; 
* Percent appealed: 33%; 
* Subject to objection: 2; 
* Objected to: 2; 
* Percent objected to: 100%; 
* Exempt: 5; 
* Percent exempt: 30%; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total IRA decisions nationwide: 6%. 

Region: 8, Southern; 
Total number of decisions: 13; 
Number of IRA decisions: 
* Subject to appeal: 12; 
* Appealed: 2; 
* Percent appealed: 17%; 
* Subject to objection: 0; 
* Objected to: 0; 
* Percent objected to: 0; 
* Exempt: 1; 
* Percent exempt: 8%; 
* Litigated: 0; 
* Percent litigated: less than 0; 
Regional percentage of total IRA decisions nationwide: 8%. 

Region: 9, Eastern; 
Total number of decisions: 4; 
Number of IRA decisions: 
* Subject to appeal: 4; 
* Appealed: 0; 
* Percent appealed: 0%; 
* Subject to objection: 0; 
* Objected to: 0; 
* Percent objected to: 0; 
* Exempt: 0; 
* Percent exempt: 0; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total IRA decisions nationwide: 2%. 

Region: 10, Alaska; 
Total number of decisions: 3; 
Number of IRA decisions: 
* Subject to appeal: 1; 
* Appealed: 0; 
* Percent appealed: 0; 
* Subject to objection: 1; 
* Objected to: 0; 
* Percent objected to: 0; 
* Exempt: 1; 
* Percent exempt: 33%; 
* Litigated: 0; 
* Percent litigated: 0; 
Regional percentage of total IRA decisions nationwide: 2%. 

Source: GAO analysis of survey results. 

[End of figure] 

[End of section] 

Appendix X: Types of Categorical Exclusions Authorized by the Forest 
Service and Represented in the GAO Survey: 

A categorical exclusion (CE) is a category of actions for which 
neither an environmental assessment nor an environmental impact 
statement is required because the agency has determined that it does 
not individually or cumulatively have a significant effect on the 
quality of the human environment.[Footnote 33] Agencies develop a list 
of categorical exclusions specific to their operations when they 
develop or revise their implementing procedures for the National 
Environmental Policy Act (NEPA), in accordance with the Council on 
Environmental Quality's NEPA regulations. 

When the Forest Service determines that activities of a proposed 
decision fall within a category of activities the agency has already 
determined have no significant environmental impact, it approves it 
using one of the predetermined categorical exclusions established by 
the Secretary of Agriculture or the Chief of the Forest 
Service.[Footnote 34] Table 10 shows the types and frequency of 
categorical exclusions reported in our survey. They are divided into 
two types: those that require the agency to prepare a decision memo 
for each action approved using a categorical exclusion, and those that 
do not require such documentation.[Footnote 35] 

Table 10: Types of Categorical Exclusions Authorized for Use by the 
Forest Service and Represented in the GAO Survey: 

CE number: Categorical exclusions established by the Secretary, 
Department of Agriculture, not requiring a decision memo. 

Categorical exclusions established by the Secretary, Department of 
Agriculture, not requiring a decision memo: 

CE number: 1; 
CE description: Policy development; 
Total number in GAO survey: 0. 

CE number: 2; 
CE description: Program funding; 
Total number in GAO survey: 0. 

CE number: 3; 
CE description: Inventories, research activities, and studies; 
Total number in GAO survey: 1. 

CE number: 4; 
CE description: Educational and Informational Programs; 
Total number in GAO survey: 0. 

CE number: 5; 
CE description: Law enforcement; 
Total number in GAO survey: 0. 

CE number: 6; 
CE description: Legal counsel and representation; 
Total number in GAO survey: 0. 

CE number: 7; 
CE description: Trade and market development abroad; 
Total number in GAO survey: 0. 

Categorical exclusions established by the Chief of the Forest Service 
not requiring a decision memo: 

CE number: 1; 
CE description: Short-term resource protection, public health, and 
safety; 
Total number in GAO survey: 1. 

CE number: 2; 
CE description: Agencywide administrative rules, regulations, and 
policies; 
Total number in GAO survey: 0. 

CE number: 3; 
CE description: Repair and maintenance of administrative sites; 
Total number in GAO survey: 11. 

CE number: 4; 
CE description: Repair and maintenance of road, trails, and landline 
boundaries; 
Total number in GAO survey: 6. 

CE number: 5; 
CE description: Repair and maintenance of recreation sites and 
facilities; 
Total number in GAO survey: 9. 

CE number: 6; 
CE description: Acquisition of land or a land interest; 
Total number in GAO survey: 2. 

CE number: 7; 
CE description: Land or resource sales or exchanges; 
Total number in GAO survey: 0. 

CE number: 8; 
CE description: Approving, modifying or continuing minor, short-term 
special uses of Forest Service lands; 
Total number in GAO survey: 3. 

CE number: 9; 
CE description: Issuance of a ski area permit; 
Total number in GAO survey: 0. 

CE number: 10; 
CE description: Amending or replacing an existing special-use 
authorization; 
Total number in GAO survey: 0. 

Categorical exclusions established by the Chief of the Forest Service 
requiring a decision memo: 
CE number: 1; 
CE description: Construction and reconstruction of trails; 
Total number in GAO survey: 1. 

CE number: 2; 
CE description: Construction and reconstruction of utilities; 
Total number in GAO survey: 0. 

CE number: 3; 
CE description: Approval, modification, or continuation of minor 
special uses; 
Total number in GAO survey: 0. 

CE number: 4; 
CE description: Reserved; 
Total number in GAO survey: N/A. 

CE number: 5; 
CE description: Regeneration of native tree species; 
Total number in GAO survey: 21. 

CE number: 6; 
CE description: Timber stand and/or wildlife habitat improvement; 
Total number in GAO survey: 454. 

CE number: 7; 
CE description: Modification or maintenance of stream or aquatic 
habitat improvement structures; 
Total number in GAO survey: 2. 

CE number: 8; 
CE description: Short-term mineral, energy, or geophysical 
investigations; 
Total number in GAO survey: 0. 

CE number: 9; 
CE description: Allotment improvements; 
Total number in GAO survey: 0. 

CE number: 10; 
CE description: Hazardous fuel reduction activities; 
Total number in GAO survey: 379. 

CE number: 11; 
CE description: Postfire rehabilitation activities; 
Total number in GAO survey: 4. 

CE number: 12; 
CE description: Harvest of live trees; 
Total number in GAO survey: 38. 

CE number: 13; 
CE description: Salvage of dead and/or dying trees; 
Total number in GAO survey: 64. 

CE number: 14; 
CE description: Harvest of trees to control insects or disease; 
Total number in GAO survey: 18. 

CE number: 15; 
CE description: Issuance of a new special use authorization; 
Total number in GAO survey: 0. 

CE number: 16; 
CE description: Land management plans, amendments, and revisions; 
Total number in GAO survey: 0. 

CE number: 17; 
CE description: Approval of oil and gas exploration plans; 
Total number in GAO survey: 0. 

Categorical exclusion established by HFRA not requiring a decision 
memo: 

CE number: No number; 
CE description: Applied silvicultural assessments and research 
treatments; 
Total number in GAO survey: 1. 

Sources: (1) Forest Service National Environmental Policy Act 
Handbook, Chapter 30-Categorical Exclusion from Documentation. April 
15, 2009; (2) 16 U.S.C. § 6554(d)(1); and (3) GAO data (see citations 
above). 

[End of table] 

[End of section] 

Appendix XI: Major Litigation Affecting Appeal Procedures for 
Categorical Exclusions: 

A summary of the major litigation that affected the exemption of 
categorical exclusions from the requirements of the National 
Environmental Policy Act process is shown in table 11. Starting in 
late 2003, these exemptions were challenged in court and were the 
subject of a Supreme Court ruling. Table 12 summarizes the litigation 
centered specifically on the validity of the Hazardous Fuel Reduction 
categorical exclusion, or Fuels CE, also known as CE #10. 

Table 11: A Chronology of Litigation Concerning Regulation Exempting 
Decisions That Have Been Categorically Excluded from Appeals: 

Date: June 4, 2003; 
Major event: Forest Service published a final rule revising appeal 
procedures that, among other things, exempted decisions using 
categorical exclusions from appeal (CE appeals exemption). 

Date: June 5, 2003; 
Major event: Forest Service action created a new categorical exclusion 
for certain fuel reduction activities (Fuels CE). 

Date: September 8, 2003; 
Major event: Forest Service issued its Burnt Ridge Project decision 
memo approving a timber sale and treatment of 238 acres of postfire 
forest area, using the Fuels CE and the CE appeals exemption. 

Date: December 1, 2003; 
Major event: Earth Island filed a complaint against the Forest Service 
that, among other things, challenged the CE appeals exemption 
nationwide and as applied to the Burnt Ridge Project, arguing that the 
exemption violated the Appeal Reform Act. The Forest Service later 
withdrew the Burnt Ridge Project. 

Date: July 7, 2005; 
Major event: Federal district court invalidated the CE appeals 
exemption. Earth Island v. Pengilly, 376 F.Supp.2d 994 (E.D.Cal.2005). 

Date: September 16, 2005; 
Major event: District court clarified that the scope of the injunction 
was nationwide, precluding any enforcement and implementation of the 
invalidated regulations. The district court further clarified that the 
injunction would apply only prospectively, to decisions made after the 
July 7, 2005 order date. 

Date: August 10, 2006; 
Major event: Ninth Circuit affirmed the district court's invalidation 
of the CE appeals exemption and the nationwide injunction against its 
enforcement. Earth Island v. Ruthenbeck, 459 F.3d 954 (9th Cir. 2006), 
amended 490 F.3d 687 (2007). 

Date: March 3, 2009; 
Major event: In a 5-4 decision the Supreme Court reversed the Ninth 
Circuit, holding that because the Forest Service had withdrawn the 
Burnt Ridge Project, the plaintiffs lacked standing to challenge 
portions of the 36 C.F.R. appeal regulations that exempted categorical 
exclusions from notice, comment, and appeal. Summers v. Earth Island 
Institute, 555 U.S. ___, 129 S.Ct. 1142-50 (2009). 

Source: GAO analysis of relevant court cases. 

[End of table] 

Table 12: A Chronology of Litigation Concerning the Validity of the 
Fuels CE: 

Date: June 5, 2003; 
Major event: Forest Service action created a new categorical exclusion 
for certain fuel reduction activities (Fuels CE). 

Date: October 8, 2004; 
Major event: Sierra Club challenged the Fuels CE as applied to several 
projects in the Eldorado and Lassen National Forests, arguing, among 
other things, that the CE inappropriately included activities that 
have significant effects. 

Date: September 16, 2005; 
Major event: Federal district court rejected the Sierra Club's 
challenge, holding that the Forest Service provided reasoned 
explanations for its conclusion that the category of actions covered 
by the Fuels CE would not normally have a significant impact on the 
environment. Sierra Club v. Bosworth, 2005 WL 2281074 (E.D.Cal.) 

Date: December 5, 2007; 
Major event: Ninth Circuit held that the Forest Service failed to 
assess properly the significance of the hazardous fuels reduction 
categorical exclusion and thus it failed to demonstrate that it made a 
reasoned decision to promulgate the Fuels CE based on relevant factors 
and information. Accordingly, the court held that the agency's 
promulgation of the Fuels CE was arbitrary and capricious. Sierra Club 
v. Bosworth, 510 F.3d 1016 (9th Cir. 2007). 

Source: GAO analysis of relevant court cases. 

[End of table] 

[End of section] 

Appendix XII: Survey Questions to National Forests: 

Survey of National Forest Decisions Signed in FY2006 through FY2008 
with Fuel Reduction Activities: 

U.S. Government Accountability Office: 

Introduction: 

Welcome to GAO's survey on National Forest Decisions Signed in FY 2006 
through 2008 with Fuel Reduction Activities. The web-based survey that 
you are currently logged into covers the following decision made by 
your forest _____: 

As a reminder, the decision name shown above will appear at the top of 
each screen as you go through the survey. 

As noted in our e-mail to you, the survey for each individual decision 
is made up of two sections. The first section focuses on questions 
regarding the NEPA decision and its outcome. The second section 
includes questions about the activities included in the decision.
To learn more about completing the survey, printing your responses, 
and who to contact if you have questions, click here for help. 

Thank you in advance for your assistance in taking part in our survey. 

Definitions of Terms: 
The questions in this survey cover the following decision for the_____: 

These definitions have been reviewed by Forest Service management to 
ensure that they reflect current Forest Service policy. 

Click here to see these definitions. 

Respondent Information (Question 1): 

The questions in this survey cover the following decision for the_____: 

1. Who is primarily responsible for completing the survey for this 
decision, in case we need to contact you about your responses? 

Name (first and last): 
Title:
E-mail:
Telephone: (include area code): 
Forest: 
District: 
Region: 

General Information about this Decision (Questions 2-6): 

The questions in this survey cover the following decision for the_____: 

	
2. Does the decision indicated above include at least one fuel 
reduction purpose or activity? 

1. Yes - Continue with question 3.
2. No (Click here to skip to question 31). 
3. Unsure/Do not know - Click the link below to send an e-mail to GAO 
for clarification: forestservicesurvey@gao.gov. 
(or call Sandra Davis at 303-572-7337 or Ulana Bihun at 303-572-7310). 

3. What was the date the decision document associated with this 
decision was signed? Or, if the decision type is a categorical 
exclusion with no decision memo required, please enter the 
determination date, or the date the deciding official approved the 
action. 
(Note: Date entered must be between 10/01/2005 and 09/30/2008.)
Month: 
Day: 
Year: 

4. If available, please provide us with the Web link to the relevant 
documentation used to support the decision indicated above. Please 
also include the page number(s) of the relevant fuel reduction 
activity sections. 

Enter web link and page number: 
Click on the box below if Web link not available - then -
continue with question 5. 

5. What was the date the legal notice for this decision or 
determination was published in your district or forest's paper of 
record? 
(Note: Date entered must be after 10/01/2005.) 

Month: 
Day: 
Year: 
Click on the box below if the decision or determination was not 
published. 

6. What type of decision was this? 

1. Categorical exclusion/Decision memo required - Continue with 
question 7. 
2. Categorical exclusion/No decision memo required (Click here to skip 
to question 8). 
3. EA (Environmental Assessment)/Decision Notice (Click here to skip 
to question 9). 
4. EIS (Environmental Impact Statement)/Record of Decision (Click here
to skip to question 9). 
5. Unsure/Do not know - Click the link below to send an e-mail to GAO 
for clarification: forestservicesurvey@gao.gov. 
(or call Sandra Davis at 303-572-733 7 or Ulana Bihun at 303-572-7310). 

General Information about this Decision (Question 7): 

The questions in this survey cover the following decision for the_____: 
	
7. (If A Decision Memo Was Required) Which of the following CE 
categories described in Chapter 30 of the Forest Service's 
Environmental Policy and Procedures Handbook (FSH 1909.15) were used 
when approving the decision? 
(Please review all responses, then check all that apply.) 

1. CE#1: Construction and reconstruction of trails. 
2. CE#2: Additional construction or reconstruction of telephone or 
utility lines. 
3. CE#3: Minor special uses of NF system land. 
4. CE#5: Regeneration of native tree species not involving herbicides. 
5. CE#6: Timber stand and/or wildlife habitat improvement. 
6. CE#7: Stream or lake habitat improvement. 
7. CE#8: Short-term mineral, energy, or geophysical investigations. 
8. CE#9: Allotment or animal distribution improvements. 
9. CE#10: Hazardous fuel reduction activities (Answer question 7a 
below). 
10. CE#11: Post-fire rehabilitation activities. 
11. CE#12: Limited timber harvest of live trees. 
12. CE#13: Salvage of dead or dying trees. 
13. CE#14: Removal of insect-or disease-infested trees. 
14. CE#15: Issuance of a new special use authorization. 
15. CE#16: Land management plans developed per 36 C.F.R. Part 219. 
16. CE#17: Surface use plan approval for oil and gas activities. 

7a. If you answered CE#10: Hazardous fuel reduction activities in 
question 7 above, were the projects associated with this decision 
enjoined by Sierra Club v. Bosworth? 

For information about this case please click here. 

1. Yes (Click here to skip to question 9). 
2. No (Click here to skip to question 9). 
3. Do not know (Click here to skip to question 9). 

7b. If you were directed to answer question 7 above - answer "Yes" 
below and click on the link to skip to question 9. 

1. Yes (Click here to skip to question 9). 

General Information about this Decision (Questions 8-11): 

The questions in this survey cover the following decision for the_____: 
	
8. (If A Decision Memo Was Not Required) Which of the following CE 
categories described in Chapter 30 of the Forest Services 
Environmental Policy and Procedures Handbook (FSH 1909.15) were used 
when approving the decision? 
(Please review all responses, then check all that apply.) 

1. CE#1: Short-term public health/safety or resource protection orders. 
2. CE#2: Rules, regulations or policies related to administrative 
procedures. 
3. CE#3: Repair and maintenance of administrative sites. 
4. CE#4: Repair/maintenance of roads, trails and landline boundaries. 
5. CE#5: Repair/maintenance of recreation sites and facilities. 
6. CE#6: Land acquisition or interest in land. 
7. CE#7: Sale or exchange of land. 
8. CE#8: Minor, short-term special uses of NF system land. 
9. CE#9: Ski area permits. 
10. CE#10: Issuance of a new special use authorization. 

9. Was this decision subject to notice, comment, and appeal procedures 
for National Forest System projects and activities under 36 C.F.R. 
Part 215? 

1. Yes (Click here to skip to question 16) 
2. No, this decision was exempt because it was a decision of the 
Secretary of Agriculture or the Under Secretary, Natural Resources and 
Environment and therefore it was not subject to the notice, comment, 
and appeals procedures per 36 C.F.R. Part 215.20 -Continue with 
question 10.
3. No, this decision was exempt for another reason - Continue with 
question 10.
4. Do not know - Continue with question 10. 

10. Was this decision subject to predecisional administrative review 
(the "objection process") under the process called for by the Healthy 
Forest Restoration Act of 2003 (36 C.F.R. Part 218)?
1. Yes - Continue with question 11.
2. No, this decision was exempt because the Secretary of Agriculture 
or the Under Secretary, Natural Resources and Environment proposed the 
project and therefore it was not subject to the HFRA predecisional 
review process per 36 C.F.R. Part 218.13 (Click here to skip to 
Question 161). 
3. No, this decision was exempt for another reason (Click here to skip 
to question 16). 
4. Do not know (Click here to skip to question 16). 

11. Was an objection to this decision filed under the process called 
for by the Healthy Forest Restoration Act of 2003 (36 C.F.R. Part 218)? 

1. Yes - Continue with question 12.
2. No (Click here to skip to question 17). 
3. Do not know (Click here to skip to question 17). 

General Information about this Decision (Questions 12-15): 

The questions in this survey cover the following decision for the_____: 
	
12. How many objections were filed for this decision? (Enter number. 
If unknown, enter -99 (minus 99).) 

Objections: 

We will now ask you about how the objection (or objections) to this 
decision was addressed. 

13. In which way was the objection (or objections) to this decision 
addressed? 
(Select one answer in all rows, 13a-131 Please respond to this 
question by selecting the final action taken to address each 
objection. If number of objections is unknown, enter -99 (minus 99)). 

13a. The objections(s) was set aside from review.
Yes - See question to the right; If yes, how many objections stem 
addressed this way. (Enter number. If unknown, enter -99.)
No; 
Do not know. 

13b. The objection(s) was returned with a request for further 
information. 
Yes - See question to the right; If yes, how many objections stem 
addressed this way. (Enter number. If unknown, enter -99.)
No; 
Do not know. 

13c. The objection(s) was reviewed and a written response prepared 
with no change to the decision. 

Yes - See question to the right; If yes, how many objections stem 
addressed this way. (Enter number. If unknown, enter -99.)
No; 
Do not know. 

13d. The objection(s) was reviewed, no written response was prepared
and no change was made to the decision. 
Yes - See question to the right; 
No; 
Do not know. 

13e. The objection(s) was reviewed, and a written response was 
prepared, with a change to the decision: (Please describe the change 
in question 14 below.)
Yes - See question to the right; If yes, how many objections stem 
addressed this way. (Enter number. If unknown, enter -99.)
No; 
Do not know. 

13f. The objection(s) was reviewed, no written response was prepared, 
but a change was made to the decision (Please describe the change in 
question 14 below.) 
Yes - See question to the right; If yes, how many objections stem 
addressed this way. (Enter number. If unknown, enter -99.)
No; 
Do not know. 

13g. The objection(s) was reviewed and a written response prepared 
specifying further analysis. 
Yes - See question to the right; If yes, how many objections stem 
addressed this way. (Enter number. If unknown, enter -99.)
No; 
Do not know. 

13h. The objection(s) was reviewed, no written response was prepared,
but further analysis was conducted. 
Yes - See question to the right; If yes, how many objections stem 
addressed this way. (Enter number. If unknown, enter -99.)
No; 
Do not know. 

13i. The objection(s) was addressed in another way. (Please describe
in question 14 below)
Yes - See question to the right; If yes, how many objections stem 
addressed this way. (Enter number. If unknown, enter -99.)
No; 
Do not know. 

14. If you answered "Yes" to item(s) 13e or 13f above, please describe 
the changes that were made to the proposed decision as a result of one 
or more of the objection(s). 

Also, if you answered "Yes" to item 13i (Addressed in another way), 
please describe how the objection(s) was addressed. 

If yes to question 13e, describe the changes to the decision: 

If yes to question 13f, describe the changes to the decision: 

If yes to question 13i, describe how the objection(s) was addressed: 

15. For each objection, please list the name(s) of the organizations, 
and individuals (that are not affiliated with organizations) that 
objected to this decision, even if the objection was set aside from 
review. 

Please list the name(s) of the organization(s) that objected here.
Please list the name(s of the individual(s) (not affiliated with 
organizations) that objected here. 

General Information about this Decision (Questions 16-17): 

The questions in this survey cover the following decision for the_____: 
	
16. Was this decision appealed under the rules contained in 36 C.P.A. 
Part 215? 
1. Yes; 
2. No; 
3. Do not know. 

17. Did any individual or group subsequently seek federal judicial 
review of the final decision? 
1. Yes; 
2. No; 
3. Do not know. 

Activities Conducted under this Decision (Questions 18-20): 

The questions in this survey cover the following decision for the_____: 
	
Now that we have collected information about the decision type, we 
need to collect information about the activities conducted under this 
decision that are intended to accomplish the decision objectives. When 
responding to the questions in this section, please consider all 
activities described in the decision including those activities that 
may not be specific to fuel reduction. 

As a reminder, we defined activities earlier as - discrete actions or 
tasks intended to accomplish decision objectives. 

18. Are the following purposes included in this decision? (Please 
review all responses, then check all that apply.) 
1. Facility management - FC. 
2. Forest Products - TM. 
3. Fuels management - HF.
4. Grazing management - RG.
5. Heritage resource management - HR. 
6. Land acquisition - LW. 
7. Land management planning - PN. 
8. Land ownership management - LM. 
9. Minerals and Geology - MG. 
10. Recreation management - RW. 
11. Regulations, Directives, Orders - RO. 
12. Research - FR. 
13. Road management - RD. 
14. Special area management - RU. 
15. Special use management - SU. 
16. Vegetation management - VM. 
17. Watershed management - WM. 
18. Wildlife, Fish, Rare Plants - WF. 
19. Travel management - TR. 
20. Other - Please describe any other purposes below. 

Please describe any other purposes here. 

19. Under this decision, were any of the following mechanisms used,
or expected to be used, to carry out hazardous fuel reduction 
activities? (Please review all responses, then check all that apply.)
1. Commercial timber sale contract. 
2. Service contract. 
3. Stewardship contract. 
4. Forest Service personnel/force account. 
5. Forest product permits (firewood, post and pole, miscellaneous 
products). 
6. Other mechanism(s) - Please describe below.
Please describe other mechanism(s) here. 

20. Did any of the activities that make up this decision include the 
following fuel treatment methods? 
(Please review all responses, then check all that apply.)
1. Prescribed burning. 
2. Mechanical treatment (machine or chainsaw). 
3. Commercial logging. 
4. Construction/maintenance of fuel breaks. 
5. Chemical/herbicide treatment. 
6. Livestock grazing. 
7. Other fuel treatment method(s) - Please describe below. 
Please describe other fuel treatment method(s) here. 

Activities Conducted under this Decision (Questions 21-22): 

The questions in this survey cover the following decision for the_____: 
	
21. What is the approximate total area, in acres, that was treated or 
is expected to be treated for fuel reduction by the activities in this 
decision? 

Example: A hypothetical decision lists fuel reduction as a purpose for 
the following three activities: Activity 1 is a commercial thinning 
activity to harvest trees on 3,000 acres. Activity 2 is a pre-
commercial thinning activity on 1,500 acres within the above harvest 
area Activity 3 combines underburning on 300 acres within the harvest 
area and 700 acres outside of the harvest area. The total area treated 
in question 23 is 3,700 acres: the harvested 3,000 acres plus 700 
acres outside the harvest area. Therefore, your entry for question 23 
would be 3,700 acres. 

Enter whole numeric digits only. Enter 0 (zero) if none. Enter -99 
(minus 99) if not available. 

Acres: 

22. For the following types of fuel treatment, how many acres have 
been, or are to be, treated by each of the following methods?
Enter numeric digits only. Enter 0 (zero) if none. Enter -99 (minus 
99) if not available. Note: Acres may overlap and not add to the 
answer given in question 21. 

Method: 
22a. Prescribed burn; 
Number of acres treated or to be treated (Please enter 0 (zero) if 
none): 

Method: 
22b. Mechanical treatment (machine or chainsaw); 
Number of acres treated or to be treated (Please enter 0 (zero) if 
none): 

Method: 
22c. Commercial logging; 
Number of acres treated or to be treated (Please enter 0 (zero) if 
none): 

Method: 
22d. Construction/maintenance of fuel breaks; 
Number of acres treated or to be treated (Please enter 0 (zero) if 
none): 

Method: 			
22e. Chemical/Herbicide treatment; 
Number of acres treated or to be treated (Please enter 0 (zero) if 
none): 

Method: 
22f. Livestock grazing; 
Number of acres treated or to be treated (Please enter 0 (zero) if 
none): 

Method: 
22g. Other method(s) --Please describe below: 
Number of acres treated or to be treated (Please enter 0 (zero) if 
none): 
				
Describe other method(s) used and indicate the number of acres treated 
by each method. 

Other method: 
Acres treated: 

Activities Conducted under this Decision (Questions 23-26): 

The questions in this survey cover the following decision for the_____: 
	
The following questions ask about the wildland-urban interface. 

23. At the time this decision was signed, was any portion of the 
approved fuel reduction activity or activities in the wildland-urban 
interface, as defined by your forest (regardless of whether they were 
described as such in the decision document or NEPA documents)?
1. Yes - Continue with question 24. 
2. No (Click here to skip to question 27). 
3. Do not know (Click here to skip to question 27). 

Please note: The following question refers to the definition of the 
wildland-urban interface contained in the Federal Register, dated 
January 4, 2001 as refined by HFRA Section 101(16) and an alternate 
definition in HFRA Section 101(16)(B(ii)) for certain at-risk 
communities. 

To review this definition, please click here. 

24. At the time this decision was signed, what definition of the 
wildland-urban interface did your forest use? 
1. The definition in the Federal Register dated January 4, 2001 as 
refined by HFRA Section 101 (16). (Click here to skip to question 26). 
2. The definition for at-risk communities that have not yet designated 
their WUIs as part of a Community Wildfire Protection Plan as defined 
by HFRA Section 101 (16) (B(ii)). (Click here to skip to question 26) 
3. A definition other than the one in the Federal Register dated 
January 4, 2001 - Please enter that definition in the box below and 
then (Click here to skip to question 26). 
4. Our forest did not have a definition - Continue with question 25.
5. Do not know - Continue with question 25. Enter the definition of 
wildland-urban interface used by your forest - then - skip to question 
26. 

25. If your forest did not have a definition of the wildland-urban 
interface at the time this decision was signed or you do not know of 
any definition, did your forest identify in the decision documents or 
NEPA documents whether any portion of the fuel reduction activities in 
this decision were to occur within the wildland-urban interface?
1. Yes; 
2. No; 
3. Do not know. 

26. Approximately how many total acres of the approved fuel-treatment 
related activity or activities that make up this decision are in a 
wildland-urban interface area? 
(Enter whole numeric digits only. Enter -99 (minus 99) if not 
available.) 

Acres: 

Activities Conducted under this Decision (Questions 27-29): 

The questions in this survey cover the following decision for the_____: 

The following questions ask about Inventoried Roadless Areas. 

27. At the time this decision was signed was any portion of the fuel 
reduction activity or activities to occur in an Inventoried Roadless 
Area? 

Note: To review the definition of Inventoried Roadless Area, please 
click here. 

1. Yes - Continue with question 28.
2. No (Click here to skip to question 30). 
3. Do not know (Click here to skip to question 30). 

28. Approximately how many total acres of the fuel reduction activity 
or activities that make up this decision occur in an Inventoried 
Roadless Area? 
(Enter whole numeric digits only. Enter -99 (minus 99) if not 
available.) 

Acres: 

29. Which activity or activities for road construction in the 
Inventoried Roadless Area did this decision include? (Please review 
all responses, then check all that apply.) 
1. No road construction. 
2. Temporary road construction. 
3. Forest Service system road construction, classified road. 
4. Forest Service system road construction, unclassified road. 
5. Other - Please specify below. 

Specify other road construction activities. 

Additional Comments and Survey Completion Question (Questions 30-31): 

The questions in this survey cover the following decision for the_____: 

30. If you have any additional comments concerning this decision, 
please enter them in the space below. 

Please continue to the survey completion question below. 

31. Have you finished GAO's survey for this decision? 

(Answering "Yes" to this question and clicking on the "Exit" button 
below will submit your responses for this decision to GAO.) 

1. Yes, my survey is complete. 
2. No, my survey is not yet complete. 

You may view and print your completed survey by clicking on the 
Summary link in the menu to the left. Please note that the name that 
will appear at the top of this summary of your responses is that of 
our primary survey contact for your forest (in most cases, the forest 
supervisor or NEPA Coordinator). 

When you exit this survey you will see the list of decisions. You may 
need to complete other surveys for other decisions on this list.
if you have completed all of the decisions you are responsible for, 
click on the "Cancel" button at the bottom of the screen listing the 
decisions. Note that even after you click on the "Cancel" button, you 
will still be able to log into the survey at any time to either change 
a response or complete a survey for another decision. 

Print this Page: 

Exit Survey: 

Definitions of Terms for Survey of National Forest Decisions Signed in 
FY2006 through FY2008 with Fuel Reduction Activities: 

Definitions of Terms (Pop-up link located in the "Definitions of 
Terms" Screen and in various other locations in the questionnaire when 
covered in various questions.) 

Activities: Activities or an activity are discrete actions or tasks 
intended to accomplish decision objectives. 

Decision: A decision is composed of one or more "activities", is 
intended to guide action on National Forest system land and is 
described in "NEPA documents" and/or "decision documents". The 
decision name should be the name used by your forest to refer to this 
action. 

Decision documents: Include records of decisions, decision notices and 
decision memoranda in the case of categorical exclusions. Decisions 
can also include letters to the file or other written forms of 
approving fuel reduction activities. 

Hazardous fuel reduction: Vegetative manipulation designed to create 
and maintain resilient and sustainable landscapes, including burning, 
mechanical treatments, and/or other methods that reduce the quantity 
or change the arrangement of living or dead fuel so that the 
intensity, severity, or effects of wildland fire are reduced within 
acceptable ecological parameters and consistent with land management 
plan objectives, or activities that maintain desired fuel conditions. 
These conditions should be measurable or predictable using fire 
behavior prediction models or fire effects models. 

Inventoried Roadless Areas: Generally refer to areas identified as 
such in the applicable Land and Resource Management Plan or in 2001 
Inventoried Roadless Area maps. These areas may also be identified as 
such in the Forest Service's Roadless Area Review and Evaluation 
(RARE) studies completed in the 1970s, excluding areas that have since 
been designated as part of the National Wilderness Preservation System 
by Congress. NEPA documents: Include environmental impact statements 
(EISs), environmental assessments (EAs) and findings of no significant 
impact (FONSIs). 

Wildland-urban interface (WUI): WUI has been defined in various ways 
over time and by forest location. 

One definition is contained in Federal Register Notice, Volume 66, 
page 751, dated January 4, 2001, which defines the WUI community as 
those areas where humans and their development meet or intermix with 
wildland fuel. This definition was refined in HFRA Section 101 (16). 
The HFRA provides expedited NEPA procedures for authorized fuel-
reduction projects on NFS and BLM lands in the WUIs of at-risk 
communities. Under HFRA Section 101(1), an at-risk community is one 
that: 

* Is an interface community as defined in the Federal Register notice 
of January 4, 2001 (66 FR 753), or a group of homes and other 
structures with basic infrastructure and services (such as utilities 
and collectively maintained transportation routes) in or adjacent to 
Federal land; 

* Has conditions conducive to a large-scale wildland fire; 

* Faces a significant threat to human life or property as a result of 
a wildland fire for at-risk communities that have not yet designated 
their WUIs as part of a Community Wildfire Protection Plan, the HFRA 
has a default definition of Wildland-urban Interface (Section 
101(16)(B (ii)). It is: 

- Extending 1/2 mile from the boundary of an at-risk community. 
Or: 
- Extending 1 1/2 miles from the boundary when other criteria are met, 
for example, a sustained steep slope, a geographic feature that could 
help when creating an effective firebreak, or Condition Class 3
land. 
Or: 
- Adjacent to an evacuation route. There is no distance limitation for 
evacuation routes. 

Pop-up — Sierra Club v. Bosworth (Pop-up link located in question #7a.) 

Sierra Club v. Bosworth: The case of Sierra Club v. Bosworth resulted 
in an injunction precluding the Forest Service from implementing 
CE#10. The injunction covered projects the Forest Service had not 
approved prior to the initiation of this lawsuit in October 2004, 
except for those projects the district court determined were already 
at or near completion. 

[End of section] 

Appendix XIII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Anu K. Mittal, 202-512-3841 or mittala@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Steve Gaty (Assistant 
Director), Ulana Bihun, Sandra Davis, Justin Fisher, Cathy Hurley, 
Richard P. Johnson, Stuart Kaufman, Armetha Liles, Diane Lund, Robin 
Nazzaro, Alison O'Neill, and Shana Wallace made key contributions to 
this report. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 91-190, 83 Stat. 852 (1970), as amended. 

[2] For some categorical exclusions, decision memos are not required. 
For example, a decision memo is not required for repair and 
maintenance of Forest Service administrative sites, roads, and 
recreation sites. 

[3] It is the position of the Department of Agriculture that any 
filing for federal judicial review of a decision subject to appeal is 
premature and inappropriate under 7 U.S.C. § 6912(e) unless the 
plaintiff has first sought to invoke and exhaust the appeal 
procedures. 36 C.F.R. § 215.21. See Forest Guardians v. U.S. Forest 
Service, 579 F.3d 1114, 1121-24 (10th Cir. 2009) (discussing 
exhaustion requirement). 

[4] GAO, Forest Service: Information on Appeals and Litigation 
Involving Fuels Reduction Activities, GAO-04-52 (Washington, D.C.: 
Oct. 24, 2003). 

[5] Pub. L. No. 108-148, Title I, § 105 (2003). 

[6] It should be noted that the Forest Service does not use a single, 
specific definition of wildland-urban interface, and that different 
definitions can be used depending on the authority under which fuel 
reduction projects are carried out. GAO has previously recommended 
that the Forest Service develop a consistent, specific definition of 
the wildland-urban interface. See GAO, Wildland Fire Management: 
Additional Actions Required to Better Identify and Prioritize Lands 
Needing Fuels Reduction, [hyperlink, 
http://www.gao.gov/products/GAO-03-805] (Washington, D.C.; Aug. 15, 
2003). 

[7] In this report, we use the term "inventoried roadless areas" to 
describe undeveloped areas with few or no roads that are identified as 
such in the applicable forest's Land and Resource Management Plan or 
in 2001 Inventoried Roadless Area maps. These areas may also be 
identified as such in the Forest Service's Roadless Area Review and 
Evaluation (RARE) studies completed in the 1970s, excluding areas that 
have since been designated as part of the National Wilderness 
Preservation System by Congress. 

[8] Because multiple appeals can be filed on a single decision, the 
number of appeals filed is greater than the number of decisions 
appealed. Similarly, proposed decisions can be the subject of multiple 
objections, and the number of objections filed is greater than the 
number of proposed decisions objected to. 

[9] Because each decision can be implemented using more than one 
treatment method, the sum of decisions by treatment method is greater 
than the total number of decisions. 

[10] Stewardship contracts include those under which the agency uses 
the value of commercial products, such as timber, to offset the cost 
of services received, such as thinning, stream improvement, and other 
activities. For more information about stewardship contracting, see 
GAO, Federal Land Management: Additional Guidance on Community 
Involvement Could Enhance Effectiveness of Stewardship Contracting, 
[hyperlink, http://www.gao.gov/products/GAO-04-652] (Washington, D.C.: 
June 14, 2004), and Federal Land Management: Use of Stewardship 
Contracting Is Increasing, but Agencies Could Benefit from Better Data 
and Contracting Strategies, [hyperlink, 
http://www.gao.gov/products/GAO-09-23] (Washington, D.C.: Nov. 13, 
2008). 

[11] Because each decision can be implemented using more than one 
contract type, the sum of decisions by contract type is greater than 
the total number of decisions. 

[12] For example, the National Forest Management Act of 1976, one of 
the major laws governing the Forest Service, requires the Forest 
Service to, among other things, (1) develop a plan to manage the lands 
and resources of each national forest in coordination with the land 
management planning process of other federal agencies, states, and 
localities and (2) revise each plan at least every 15 years. Each 
forest plan--called a Land and Resource Management Plan--establishes 
how land areas within a forest may be used and governs individual 
projects or activities that occur within the forest. Individual 
projects or activities, such as reducing fuels, may take place only if 
they are consistent with the plan and after site-specific 
environmental review, which often includes public notice, comment, and 
administrative appeal. 

[13] Regulations governing roadless areas have been extensively 
litigated, and Congress is considering legislation addressing these 
areas. For a full discussion of these issues, see Congressional 
Research Service, National Forest System Roadless Area Initiatives, 
RL30647 (Washington, D.C.: October 9, 2008). 

[14] 16 U.S.C. § 1612 nt; see 36 C.F.R. part 215, Notice, Comment, and 
Appeal Procedures for National Forest System Projects. 

[15] The Forest Service appeals regulations contain a provision 
stating that only a person who files "substantive" comments may file 
an appeal. 36 C.F.R. § 215.13(a). A federal district court has held 
that this requirement is invalid under the Appeal Reform Act. 
Wilderness Society v. Rey, D. Mont., Civ. No. 03-00119, April 24, 
2006. The case is on appeal in the Ninth Circuit. See Wilderness 
Society v. Rey, 06-35565, filed June 23, 2006. 

[16] See appendix XI for more information. 

[17] The agency's objection process appears at 36 C.F.R. part 218. 
Fuel reduction projects authorized under HFRA include those occurring 
on federal land in the following areas: the wildland-urban interface; 
certain municipal watersheds; areas where wind throw, blowdown, ice 
storm damage, or the existence or imminent risk of an insect or 
disease epidemic significantly threatens ecosystem components or 
resource values; and areas where wildland fire poses a threat to, and 
where the natural fire regimes are important for threatened and 
endangered species or their habitat. Actions implemented under HFRA 
are prohibited in wilderness areas, wilderness study areas, and 
federal lands where an act of Congress or presidential proclamation 
prohibits or restricts removal of vegetation. 

[18] Other reasons include the following: The decision is not subject 
to objection procedures; there is not enough information included in 
the objection for the reviewing officer to review; the objector 
withdraws the objection; an objector's identity is not provided or 
cannot be determined from the signature or a reasonable means of 
contact is not provided; or the objection is illegible for any reason, 
including submissions in an electronic format different from that 
specified in the legal notice of the proposed decision. 

[19] The Forest Service does not have a uniform definition of a 
hazardous fuel reduction activity, and many agency projects may 
involve fuel reduction activities that provide an ancillary benefit to 
a project conducted for another purpose--potentially affecting the 
information that forest managers reported to us. See appendix I for 
more information about our data collection methodology. 

[20] See appendix XI for a summary of the major litigation affecting 
the exemptions for categorical exclusions. 

[21] The Forest Service is considering amending this regulation in 
light of the litigation that challenged it, the agency's experience in 
implementing it, and possible changes in policy direction. 

[22] Decisions withdrawn in this manner are considered different from 
decisions the agency withdraws as a result of informal resolution. 
According to a regional official, withdrawn decisions that fall within 
the "Dismissed without Review" category avoid having to "daylight" to 
appellants what the flaws were in the decision. 

[23] To verify these responses, we collected and reviewed agency 
documentation for a randomly selected sample of appealed decisions. 
Our review of this documentation confirmed that, for each such 
decision, the agency had processed appeals within prescribed time 
frames. See appendix I for additional information on our survey and 
data verification methodologies. 

[24] Some of the individuals may have submitted an appeal on more than 
1 decision. Consequently, there may have been some double counting of 
specific individuals. 

[25] As a result of one objection to one decision, a change was made 
and no written response was provided to the objector. 

[26] 36 C.F.R. part 218.12. 

[27] Our data for the WildWest Institute include objections made by 
the Native Forest Network and Ecology Center. These two groups merged 
to form the WildWest Institute in April 2006. 

[28] 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. 

[29] For 32 of the decisions included in our study, the survey 
respondents did not provide information on the contract type. 

[30] Under HFRA Section 101(1), an at-risk community is one that is an 
interface community as defined in the Federal Register notice of 
January 4, 2001 (66 FR 753), or a group of homes and other structures 
with basic infrastructure and services (such as utilities and 
collectively maintained transportation routes) in or adjacent to 
federal land; has conditions conducive to a large-scale wildland fire; 
and faces a significant threat to human life or property as a result 
of a wildland fire. HFRA defines a community wildfire protection plan 
as a plan that is developed primarily by state and local agencies in 
consultation with interested parties and federal land management 
agencies, and that identifies and prioritizes areas in and near a 
community for fuel reduction treatments and recommends the types of 
treatments to be used. 

[31] The term "condition class 3" with respect to an area of federal 
land refers to the condition class description developed by the Rocky 
Mountain Research Station in the report Development of Coarse-Scale 
Spatial Data for Wildland Fire and Fuel Management, GTR RMRS-87 (Fort 
Collins, Colorado, U.S. Department of Agriculture, Forest Service 
Rocky Mountain Research Station: April 2002). 

[32] There is no distance limitation for evacuation routes. 

[33] 40 C.F.R. § 1508.4. 

[34] HFRA, Title IV--Insect Infestations and Related Diseases--also 
authorizes categorical exclusions for applied silvicultural 
assessments and research treatments provided the total number of acres 
does not exceed 250,000. Decisions authorized under Title IV are not 
subject to the predecisional administrative review process, but are 
subject to the notice, comment, and appeals process found in 36 C.F.R. 
215. 

[35] While a decision memo is not required for certain categories, one 
may be prepared at the discretion of the responsible Forest Service 
official. For more information, see GAO, Forest Service: Use of 
Categorical Exclusions for Vegetation Management Projects, Calendar 
Years 2003 through 2005, [hyperlink, 
http://www.gao.gov/products/GAO-07-99] (Washington, D.C.: Oct. 10, 
2006). 

[End of section] 

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