INTRODUCTION

According to the 1995 Federal Wildland Fire Management Policy ("Fire Policy"), "Every area with burnable vegetation must have an approved Fire Management Plan (FMP)." Fire Management Plans (FMPs) are fundamental strategic documents that guide the full range of fire-related forest management activities in a given administrative unit. They are required for each and every National Forest (U.S. Forest Service), National Park (National Park Service), Indian Reservation (Bureau of Indian Affairs), Wildlife Refuge (U.S. Fish and Wildlife Service), Resource Area (Bureau of Land Management), and Military Base (Department of Defense). FMPs tier to their underlying Land and Resource Management Plans, which in the case of the Forest Service are called Forest Plans. FMPs are supplemented by operational plans such as fire preparedness and prevention plans, dispatch plans, prescribed burn plans, and wildland fire use plans. In short, FMPs are the implementation plans for translating the Fire Policy and individual fire programs into on-the-ground actions.

The concept of FMPs signifies a progressive evolution in thinking about working with fire disturbance processes in managing forest and rangeland ecosystems, rather than trying to exclude or extirpate fires from the landscape. Before FMPs, the Forest Service would put together Fire Management Action Plans (FMAPs) which had no link to ecological objectives, but were annual budget exercises exclusively tied to fire prevention and suppression programs. This one-side approach attempting to exclude and extinguish all fires from wildland ecosystems has failed on numerous ecological, economic, and social grounds, creating the conditions for recent large-scale severe wildfires.

Although it has been seven years since the Fire Policy was established, and Congress has been investing hundreds of millions of dollars in federal fire management programs, there has been little emphasis within the Forest Service to do required fire planning as mandated by the Fire Policy. Indeed, it is ironic how little fire planning has occurred under the National Fire Plan. Citizens should demand wise use of their tax dollars funding the National Fire Plan, and demands for National Forest FMPs are a critical first step in gaining better public and Congressional accountability, strategic prioritization of resources and projects, and collaboration between the agency and communities in dealing with fire issues.

FMPs should be an essential strategic first step in alleviating the crisis reaction approach to wildland fires, prioritizing effective protection for rural communities, and charting the course towards authentic restoration of degraded fire-adapted ecosystems. In the context of the Bush Administration’s so-called "Healthy Forests Initiative" and similar proposals calling for drastic changes in environmental protection laws and regulations governing general forest management planning and site-specific management projects-- allegedly to speed up fuels reduction projects to prevent "catastrophic wildfires" --it is imperative now more than ever that fire management and FMPs be elevated to priority importance.

This Citizen's Guide to Forest Service Fire Management Planning is intended to give readers a comprehensive understanding about the rationale, status, structure and process for developing FMPs. The goal is to help citizens become empowered advocates for, and informed participants in, the development of new scientifically-sound, community-based collaborative FMPs as the necessary first step in putting the progressive, restoration-oriented Fire Policy into practice.

ADVOCATING FOR FIRE MANAGEMENT PLANNING

Each year, Congress appropriates hundreds of millions of tax dollars for the Forest Service Fire Preparedness budget which should fund fire management planning. Since 2000, Congress has vastly increased this funding as part of the National Fire Plan; yet, ironically, there has been very little fire planning under the National Fire Plan. Despite this increased taxpayer largesse, the agency has systematically neglected to invest in proactive fire planning to implement the Fire Policy, and has chosen to spend the money on other things more tied to traditional firefighting and logging activities. The following provides four persuasive arguments for citizens to advocate for Fire Policy-compliant FMPs in order to increase firefighter safety and efficiency, and reduce firefighting costs and impacts:

Fire Management Plans Can Reduce Safety Hazards for Firefighters

Wildland firefighting is inherently hazardous duty, and individuals are exposed to health and safety risks on every firefighting incident. The lack of FMPs in the U.S. Forest Service compels the agency to engage in aggressive initial attack, extended attack, and total suppression on all fires. The agency must fight all fires without considering whether or not they occur in areas where the risks of fire to human communities are low, the ecological benefits of burning are high, and the hazards to firefighters may be high to extreme. Avoiding unnecessary fire suppression actions would decrease hazards to firefighters, but without these FMPs fire managers have only one option: total suppression. Thus, as was the case of the Biscuit Fire in Oregon—the nation’s largest wildfire in 2002—the lack of an approved FMP by the Siskiyou National Forest caused firefighters to be exposed to prolonged, unnecessary risks and hazards on a "siege-like" campaign fire that defied human control efforts and was eventually extinguished only by changes in the weather.

Fire Management Plans Can Increase Suppression Efficiency and Effectiveness

Fire Policy-compliant FMPs make a whole range of "appropriate management responses" to wildland fires possible. These responses can range from simple aerial monitoring of fires burning in remote roadless or wilderness areas, to aggressive fireline construction where fires threaten to encroach upon human communities. These options can exist even on the same wildfire incident. Consequently, managers may not need to waste resources trying to completely encircle and extinguish all fires in all places at all times at any cost, but instead can target suppression resources, and devise strategies and tactics to those sites and conditions where firefighters will be most safe, efficient, and effective.

Fire Management Plans Can Reduce Suppression Costs for Taxpayers

The Fire Policy was developed after officials were shocked by the expense of the 1994 fire season--an unprecedented $950 million—and the Policy Update was developed after the 2000 fire season cost a record $1.3 billion. The Fire Policy mandates that fires are to be suppressed at minimum cost; yet, the Forest Service has neglected to create guidelines or direction that would concretely lead to minimum-cost suppression strategies or tactics, with the result that suppression costs are rising at an annual average rate of 15.5%. Moreover, the agency has the authority to engage in deficit spending for fire suppression activities whenever it exceeds its annually appropriated budgets. Congress simply reimburses the agency through supplemental appropriations when it depletes its emergency firefighting fund, and rarely questions the expenditures of fire managers. Consequently, "The Forest Service manages emergency firefighting funds as if they were unbudgeted, unlimited, unallocated, and without benchmarks on acceptable spending levels. This environment provides the appearance of no accountability."

Despite hundreds of millions of tax dollars poured into the Forest Service fire budgets from the National Fire Plan, the 2002 fire season topped $1.5 billion. The lack of fiscal constraint and accountability is particularly acute on large wildfire incidents. For example, on the Biscuit Fire, the Forest Service spent over $150 million fighting the lightning-caused Biscuit Fire--fully 106% of the agency’s total budget for fire suppression operations--even though Biscuit was predominantly a low-to-moderate intensity fire that burned mainly in designated wilderness and inventoried roadless areas. Because FMPs and proactive fuels management projects must come out of fixed budgets, but reactive fire suppression actions have essentially no fixed budget, there is institutionally a perverse incentive for managers to favor reactive wildfire suppression over proactive fire planning and fuels management.

FMPs can reduce suppression costs by helping to focus firefighting actions to the times and places it is most safe, effective, and necessary. FMPs can also reduce suppression costs by setting the course for hazardous fuels reduction and ecosystem restoration that ultimately are the only viable, long-term solutions to reduce the adverse effects of severe wildfires.

Fire Management Plans Can Decrease Suppression Damages to Ecosystems

Fire suppression programs and practices have never undergone environmental analysis under the National Environmental Policy Act (NEPA); yet, there are significant direct, indirect, and cumulative environmental impacts caused by firefighting. In some cases, the impacts of firefighting can be more significant and enduring than the effects of wildfire alone. For example, bulldozers cutting firelines into steep erosive slopes or roadless areas can cause scars that last for decades. Backfires ignited under extreme weather conditions can increase the intensity and severity or wildfires, and in some cases, can start whole new wildfires. Some fire retardant chemicals degrade into cyanide at levels highly toxic to fish and frogs. And the presence of large numbers of firefighters and their equipment and vehicles can spread invasive weeds, harass wildlife, and damage sensitive lands. FMPs can prohibit certain aggressive suppression methods where they would be most damaging (e.g. bulldozers in roadless areas, chemical retardants in riparian areas). Alternately, FMPs can prescribe "Minimum Impact Suppression Tactics" where they would be more effective and less damaging to the environment. Without FMPs providing such guidance to fire managers, there are no constraints on the kinds of destructive practices that can occur while "fighting" fires. FMPs enable managers to set priorities for suppression in ways that decrease the short- and long-term damages that firefighting can inflict upon the landscape.

In sum, FMPs provide strategic guidance that can help increase the safety, efficiency and effectiveness of suppression actions while reducing their economic costs and environmental impacts. FMPs also provide critical strategic direction to pre-fire and post-fire activities such as prescribed burning, non-commercial thinning, other manual and mechanicals fuels reduction treatments. Given the basic underlying philosophical premise of the Fire Policy--that the key to protecting communities and the environment from severe wildfires requires fire reintroduction and ecological restoration of fire-adapted ecosystems--FMPs should offer key analysis and strategic guidance to all restoration-oriented fire and fuels management activities. The ultimate goal of FMPs should be to make aggressive wildfire suppression the exception and ecological fuels management the rule.

Fire Management Plans Can Increase Effectiveness of Fuels Reduction and Forest Restoration Projects

The Fire Policy represented a dramatic shift away from reactive fire suppression towards proactive fuels reduction and ecosystem restoration. However, the Forest Service has been using the concepts of fuels reduction and forest restoration as justifications for business-as-usual commercial timber extraction without making essential connections between these timber sale projects and strategic fire management planning. Projects are typically planned in an ad hoc, opportunistic manner around commercial timber stands in defiance of science-based definitions of genuinely hazardous fuel loads. Even worse, most of the so-called fuels reduction or forest restoration timber sales have their management objectives to further fire exclusion and suppression goals in defiance of the letter and spirit of the Fire Policy. When such timber sale projects are proposed but are not tiered to a strategic FMP, it is not only a matter of "putting the cart before the horse," but the two are disconnected and heading in opposite directions! A Fire Policy-compliant Forest-wide FMP should provide the strategic guidance for all site-specific fuels reduction, fire reintroduction, and ecosystem restoration projects. Before the agency increases the number of fire/fuels projects, it must ensure that these conform to the Fire Policy and are based in the FMP.

POLICY MANDATES FOR FMPs

Policy mandates for development of FMPs come from two main sources: the Federal Wildland Fire Management Policy (1995 and 2001), and the Ten-Year Comprehensive Strategy (2002).

The 1995 Federal Wildland Fire Management Policy and Program Review

The 1995 Federal Wildland Fire Policy was developed in the wake of the terrible 1994 fire season in which 34 of the nation’s most elite trained and equipped firefighters died in the line of duty. The 1995 Fire Policy called for a fundamental shift in agency philosophy and cultural attitudes toward fire, the integration of fire management with forest and resource management objectives, and the full involvement of interagency partners and the public in fire management. This effectively expanded the mission of fire managers beyond their traditional duties of preventing or suppressing wildfires to include reducing fuel hazards and restoring fire-adapted ecosystems.

Concretely, the Fire Policy elevated the critical importance of proactive fire management planning, discussing FMPs in four of the Policy’s nine Guiding Principles. The implications of the Policy's mandate, "Develop FMPs for all areas subject to wildland fires," is that practically all of the federal landbase must rightfully undergo fire planning. The following interagency policies specifically detailed the role of FMPs in federal fire management programs:

* "Firefighter and public safety is the first priority. All Fire Management Plans and activities must reflect this commitment. (p.5)

* "Every area with burnable vegetation must have an approved Fire Management Plan. Fire Management Plans must be consistent with firefighter and public safety, values to be protected, and land and resource management plans and must address public health issues. Fire Management Plans must also address all potential wildland fire occurrences and include the full range of fire management actions." (emphasis added) (p.5)

* "Fire, as a critical natural process, will be integrated into land and resource management plans and activities on a landscape scale, across agency boundaries, and will be based on the best available science. All use of fire for resource management requires a formal prescription. Management actions taken on wildland fires will be consistent with approved Fire Management Plans." (p.5)

* "Fire management planning, preparedness, suppression, fire use, monitoring, and research will be conducted on an interagency basis with the involvement of all partners." (emphasis added) (p.5)


In addition to these broad Guiding Principles and Policies, the federal agencies pledged that FMPs will:

* use information about fire regimes, current conditions, and land management objectives as a basis to develop fire management goals and objectives;

* address all potential wildland fire occurrences and include a full range of fire management actions;

* use new knowledge and monitoring results to revise fire management goals, objectives, and actions;

* be linked closely to land and resource management plans." (p.10)


In May, 1996 an Implementation Action Plan Report ( the "Action Plan") was created in order to put the Fire Policy into practice. The development of FMPs for all areas subject to wildland fires was listed under the category of "Action Items to be Implemented Immediately," and put at the top of the list of 83 different Action Items. The Action Plan clarified an important point that "Individual field units are responsible for FMP development. They must involve their fire management partners and the public." (emphasis original)

The 2001 Review and Update of the Federal Wildland Fire Management Policy

The 2000 fire season was another episode of extreme drought conditions and large-scale, high-intensity wildfires that overwhelmed the capacity of federal agencies to adequately manage the fire situation. In response, the Secretaries of Interior and Agriculture ordered an intensive review of the status of the 1995 Fire Policy and its implementation. The 2001 Review and Update of the 1995 Federal Wildland Fire Management Policy (the "Policy Update") found no fundamental flaws with the Fire Policy, but it did find several critical deficiencies in the agency's incomplete and inconsistent implementation of the Policy. In a concurrent but independent review of the implementation status of the Fire Policy, the National Academy of Public Administration (NAPA) discovered that only two out of the 83 Action Items had been completed, more than 60% of the action items were still in the process of being implemented and needed more work, and almost 30% had either not been started or were seriously deficient. Not surprisingly, the NAPA report listed Policy-compliant FMPs under the category of "1995 Fire Policy Action Items Not Implemented." Indeed, the Policy Update found that many areas did not have FMPs that met the requirements of the Fire Policy, and that many existing FMPs needed updating and integration with underlying Forest Plans. The document noted that, "In some cases underlying land management plans require revisions before fire management plans can be fully written or revised" (p.47); but, the Update repeatedly stated that, "the existence of obsolete land management plans should not be reason for failure to complete or update FMPs." (p.26) The bottom line was that "(S)uccessful implementation of 2001 Federal Fire Policy depends on the development and implementation of high-quality FMPs by all land managing agencies."

The 2001 Update was supposed to replace the 1995 Fire Policy, and it reaffirmed the critical role of FMPs in four of the nine Guiding Principles, six of the 17 Policy Statements, and four of the 11 Implementation Actions. Accordingly, the Policy Update stated that
"Fire Management Plans that that implement Federal Fire Policy must be completed as soon as possible. All land management agencies should place a high priority on completion of these plans. If necessary, land management plans should be updated, revised, or amended to allow full implementation of Federal Fire Policy."


Some 2001 Update improved the 1995 Fire Policy by including additional rationale and mandates for fire planning:

* "FMPs and programs will be based on a foundation of sound science." (p.23)

* "FMPs and land management plans will appropriately incorporate mitigation, burned area rehabilitation, and fuels reduction and restoration activities that contribute to ecosystem sustainability." (p.24)

* "Base responses to wildland fires on approved FMPs and land management plans, regardless of ignition source or the location of the ignition. The management response to fires, regardless of source, must be based on the approved FMP. FMPs, based on land management objectives of the area, guide the appropriate response through criteria and prescriptions." (p.25)


This last item, a "strategic implementation action," is not being implemented because Forest Service officials philosophically oppose it, and want to preserve the power to sue private individuals who accidentally or intentionally start fires. Consequently, all human-caused ignitions unplanned and unwanted by the agency continue to be aggressively suppressed. If and when high-quality FMPs are developed in the future, they should contain the management parameters that would enable unplanned fires to burn under prescribed conditions for carefully planned ecological objectives--even if they are accidental human-caused fires. This would be a prime beneficial outcome of developing FMPs and a dramatic improvement in fire management.

A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment: 10-Year Comprehensive Strategy

Another response to the severe 2000 fire season was the effort spearheaded by the Western Governor's Association (WGA) to bring together the federal agencies, State and county governments, and private stakeholders to develop new fire management policies. The result was the policy document, "A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment: 10-Year Comprehensive Strategy" (the "Comprehensive Strategy") This effort was directed, in part, by the Congressional Conference Committee Report for the 2001 Interior Appropriations Act (Public Law 106-291) that funded the National Fire Plan. The four Goals of the 10-Year Strategy are:

* Improve Fire Prevention and Suppression
* Reduce Hazardous Fuels
* Restore Fire-Adapted Ecosystems
* Promote Community Assistance


The Guiding Principles of the 10-Year Strategy are:

* PRIORITY SETTING that emphasizes the protection of communities and other high-priority watersheds at risk.

* COLLABORATION among governments and broadly representative stakeholders.

* ACCOUNTABILITY through performance measures and monitoring for results.


In August, 2001, the Bush Administration formally endorsed the Comprehensive Strategy, making it a key component of implementing the National Fire Plan.

In May, 2002, Bush Administration formally endorsed an Implementation Plan and set of Performance Measures for the Comprehensive Strategy and National Fire Plan. Not surprisingly, planning was put at the top of the list of items needed to focus on in order to implement the Strategy's core principles, goals and actions.

Two Implementation Tasks related to FMPs and Hazardous Fuels Reduction were:

* "Develop a FMP template that incorporates the objectives and priorities established through the 10-Year Strategy and determine a schedule for implementation." (p.12)

* "Utilize, as appropriate, the USDA Forest Service’s and Department of Interior’s combined Cohesive Strategy for all FMPs." (p.12)

Additionally, two Performance Measures were developed that would reward fire managers for increasing:

* "percent of burnable acres covered in federal FMPs in compliance with Federal Wildland Fire Policy" ( p.10)

* "percent of communities-at-risk with completed and current FMPs or risk assessments" (p.15)

Development of collaborative FMPs was an essential implementation task and performance measure for accomplishing the goals of improving suppression, reducing hazardous fuels, restoring fire-adapted ecosystems, and promoting community assistance. The fact that the Comprehensive Strategy was developed, in part, under Congressional direction gives the document more of the status of a legal mandate. Citizens should feel empowered to cite the Comprehensive Strategy and enlist the support of their State and local governments to advocate for developing collaborative, community-based FMPs that prioritize community protection and hold agencies accountable for implementing the Fire Policy.

LEGAL MANDATES FOR FMPs

There are unresolved questions as to whether or not the Forest Service is legally obligated to implement the Fire Policy, and what laws or regulations govern the development of FMPs. The following is not intended to answer those questions, but merely to introduce important information and arguments for further exploration of this issue.

The Forest Service Manual and Handbook and FMPs

The clearest thing approaching a legal requirement for developing FMPs comes from several directives written in the 5100 series of the Forest Service Manual (FSM), and the 5108 and 5109.19 sections of the Forest Service Handbook (FSH). The Manual and Handbook codifies the agency’s fire policies, practices, and procedures. FSM Directive 5120.42b requires line officers to prepare a Forest Fire Management Plan which is defined as "A strategic plan that defines a program to manage wildland and prescribed fires and documents the fire management program in the approved land use plan." According to FSM Directive 5141.2, "the FMP tiers directly from the direction in the Forest Plan, and guides achievement of resource objectives through the use of fire."

Other specific Forest-wide directives for FMPs include:

* "Develop a fire management plan based on direction in land and resource management plans and interagency plans and assessments. Amend Forest plans where necessary to meet fire management objectives. Use the best available science to assess and plan on a landscape scale, across agency boundaries." (FSM 5103.2)

* "Conduct fire management planning, preparedness, suppression, monitoring, and research, and fire use on an interagency basis and involve affected partners. Integrate with forest planning whenever possible." (FSM 5103.3)


Some FMP-related directives in the 5130 series that discuss Forest-wide wildland fire suppression policy are:

* "Ensure a prompt and appropriate response to each wildfire that exceeds the parameters in the fire management plan (FSM 5121). Initial response should comply with direction contained in the Fire Management Plan." (FSM 5131.03)

* "Make timely decisions regarding management of a wildland fire. If a wildfire that is not caused by humans is burning in an area with an approved land and resource management plan and an approved fire management plan, and the objectives of the plans are being met, document the response decision and take appropriate action. If events cause a delay in the decision, and this delay may result in an increased risk to firefighter or public safety, the only appropriate response is to control the fire." (FSM 5131.03)


There are also some FMP-related directives in the 2324 series of the Manual that are specific to designated Wilderness Areas, currently the only places the Forest Service allows wildland fire use:

* "Document specific objectives, standards, and guidelines for the control of wildfire and the use of prescribed fire within each wilderness (FSM 5100, 5150, and 5190) in a forest plan or, where the forest planning process has not been completed, in either an interim wilderness management or fire management area plan. Document specific direction for fire program implementation in the forest fire management action plan." (FSH 5109.19) (FSM 2324.22,3).

* "No fire may be ignited or allowed to burn without documented, preplanned, specified conditions." (FSM 2324.22,3).

* "Fire ignited by lightning may be permitted to burn if prescribed in an approved plan." (FSM 2324.22,5 and 5150).


Regional Foresters are responsible for:

* "Approving the use of prescribed fire on a wilderness by wilderness basis through approval of the appropriate management plan. The management plan sets forth the standards and guidelines for the use and application of prescribed fire and the methods of monitoring results." (FSM 2324.04b)


Forest Supervisors are specifically assigned the responsibility to:

* "Plan, organize, and implement a preparedness program that is documented in the Forest's Fire Management Plan, including a mobilization guide, preparedness actions, wildland fire prescriptions, appropriate management response for all wildland fires, a schedule of reviews, and a wildfire suppression training and qualifications program. (FSM 5120.43.1)

* Ensure that the plan is adjusted annually to reflect current conditions, budget, or other significant considerations. (FSM 5120.43.2)

* Providing specific direction on fire use through annual approval of the Fire Management Plan consistent with the approved forest plan. (FSM 5140.42)


District Rangers are assigned the responsibility to:

* Ensure an Operations Fire Plan is prepared as required (FSM 5120.44.1)

* Maintain an adequate organization to implement the actions defined in the Fire Management Plan. (FSM 5120.44.2)

* Implement the Fire Management Plan when conditions make it necessary. (FSM 5120.44.3)

* Safely suppress wildfires at minimum cost consistent with land and resource management objectives and fire management direction as stated in Fire Management Plans. (FSM 5130.2)


Despite these directives in the Forest Service’s Manual and Handbook, line officers have not been held accountable for failure to complete FMPs, and there are few apparent consequences for this failure. The directives in the Forest Service Manual and Handbook are not, by themselves, enforceable by citizen lawsuits, either. Other environmental protection laws and regulations must be utilized to press a case for the legal obligation of federal agencies to develop FMPs and implement the Fire Policy.

The National Environmental Policy Act and FMPs

The National Environmental Policy Act (NEPA) does not require FMPs, but the argument can be made that FMPs should require NEPA. According to the federal Wildland and Prescribed Fire Management Policy Implementation Procedures Reference Guide, "The FMP will strive to satisfy NEPA requirements." The National Academy of Public Administration also declared that, "Fire-related plans and proposals, including FMPs, are subject to NEPA and ESA requirements," as well as other legal environmental regulations. In a special interagency teleconference broadcast on April 8, 1998, "Managing Wildland Fire: From Policy To Implementation," top federal officials repeatedly emphasized the critical importance of public involvement and NEPA in fire management planning and implementation of the Fire Policy.

The teleconference announcer instructed federal employees across the nation that,

"Planning is key to implementing Fire Policy on the ground. Good planning is the cornerstone of all Nine Guiding Principles and all 13 Policies contained in this report…and of course, the public must be a key player from the earliest stages of planning if we’re to have the benefit of their input and support, which is critical to the success of our land management programs. We must ensure that a fire management plan is developed and continuously updated for all areas subject to wildland fire...The Plan and Project must also meet NEPA requirements before the Project begins." (emphasis added)


Several high-level officials from all federal land management agencies reinforced the critical importance and proper means of developing FMPs:

* Arch Wells, Chief Forester of the Bureau of Indian Affairs, said:
"The affected public must be involved in development of the land use plans and associated fire management plans for maximum ownership, cooperation (and) coordination through understanding and participation...Good plans result in sound, efficient decisions. The bottom line is this: without approved quality fire management plans, the only option available is total suppression with associated risks, costs, and unplanned resource loss." (emphasis added)

* Sheryl Maddux, Forest Service District Ranger from Tennessee said:
"Without an approved fire management plan that complies with NEPA, smoke management and public involvement, we only have one management option for wildfire and that is total suppression. Agency administrators need to take an active role in developing a common understanding of fire management plans both to agency employees and to the affected public. The public must be brought along throughout the planning process and their input, both positive and negative, must be addressed. This is a prime opportunity for agency administrators to explain and provide positive support for the new Fire Policy and the fire management plan or program on their unit." (emphasis added)

* Rick Coleman from the Washington Office of the U.S. Fish and Wildlife Service said:
"Teamwork is vital to successful planning. By including land managers and neighbors and stakeholders and resource specialists and fire specialists and the public, we gather all those important perspectives necessary to write the best fire management plan...Resource management specialists and the public need to help the fire staff develop the fire management plan...Agency administrators and staff specialists should not be shy about working with any group." (emphasis added)

* Elaine Marquis-Brong from the Bureau of Land Management in California said:
"Fire Planning is a must tied to the Fire Policy. That includes NEPA. The NEPA process is an extremely important process not only for the effects of fire, but the effects of accumulated fuels on the ecosystem and what impacts and tradeoffs (there) are. I’m going to say it: NEPA is an integral part of the Fire Land Policy."
(emphasis added)


Unfortunately, despite these clear, affirmative statements, the Forest Service as an institution is adamantly opposed to using NEPA for fire planning. The agency's official position is that, "A site-specific NEPA document is not prepared prior to the approval of the FMP because a FMP does not propose, authorize, or permit site-specific federal actions." The agency insists that the only role for NEPA in fire planning is at the general Forest Plan stage or a site-specific Project stage; the agency does not do "middle tier NEPA" for FMPs. Thus, several Forests have delayed implementation of the Fire Policy and development of new FMPs until scheduled Forest Plan revisions, which in some cases are several years away from getting started.

Most existing Forest Plans contain sparse fire-related scientific analysis or disclosure of impacts, especially fire exclusion and suppression impacts, and do not include pertinent new information from the Fire Policy, the National Fire Plan, and Comprehensive Strategy. This makes nearly all Forest Plans obsolete from the standpoint of fire management. Regardless, this should not deter efforts to do fire planning, for as the 2001 Policy Update repeatedly stated, "(T)he existence of obsolete land management plans should not be reason for failure to complete or update FMPs."

However, as the NAPA Report noted, there is a problem that without adequate Forest Plans, "the potential exists for the FMP to drive decisions about how to manage the land, even though the FMP does not have the same level of public involvement, regulatory scrutiny, and other inputs." Thus, for example, grandiose fire management strategies such as constructing a fuelbreak system over an entire National Forest may have been outlined in the FMP, but was never even mentioned in the Forest Plan or any other programmatic NEPA document, thereby evading full environmental impact analysis and public input until the Project stage in which citizens may critique the impacts of commercial timber extraction, but the underlying fire management strategy is an untouchable foregone conclusion.

The net effect is that the Forest Service is failing to develop high-quality FMPs that comply with the Fire Policy and NEPA--an obvious effect of the failure to include the public as partners in fire planning. For those National Forests that do have current, approved FMPs, the NAPA study revealed that federal agencies have not identified what would constitute a "good" FMP that complies with the Fire Policy, and thus FMPs differ greatly in quality from place-to-place and agency-to-agency. A serious argument could be made that there is not a Forest Service FMP in the country that fully complies with the Fire Policy, particularly its mandates for the use of the best available science and public involvement. While vigorously opposing the use of NEPA, the Forest Service has not provided any guidelines for involving non-Forest Service personnel and the public in developing FMPs. Instead, there is a basic institutional insularity that enables the agency to evade public input and legal accountability in FMPs. Explicit legislation and/or litigation will probably be required in order to clarify the legal requirements for developing FMPs, including defining the public’s rights and responsibilities under NEPA to get involved in fire planning.

STATUS REPORTS OF FMPs

The 1999 GAO Report on Western National Forests

The 1999 General Accounting Office (GAO) Report, "Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats," gave the first public notification that strategic fire and fuels planning was being systematically neglected by the Forest Service. The report was a broad-scale critique of the agency’s lack of a national strategy and numerous institutional barriers preventing effective hazardous fuels reduction. Since FMPs are supposed to provide strategic guidance for implementing fuels reduction and fire reintroduction efforts, the disclosure that the Forest Service lacks a cohesive fire and fuels strategy applies not only on a national, but also on a local level in those National Forests without current adequate FMPs.

The GAO Report coming just prior to the severe 2000 fire season helped initiate a "firestorm" of fire policy development over the next two years, including the Fire Policy Update, the Report to the President and National Fire Plan, the Comprehensive Strategy, and the Joint Cohesive Strategy (still in draft stage). Indeed, the Forest Service responded soon after the GAO report with a document drafted in 2000: "Protecting People and Sustaining Resources in Fire-Adapted Ecosystems: A Cohesive Strategy." In the Forest Service’s draft cohesive strategy it mandated that:

"Consistent with Land and Resource Management Plans, develop fire management plans that provide for suppressing fires that would threaten public safety, communities, species habitat, or degrade ecosystems. Increase the management of natural ignitions for resource benefits where values and resources will be increased or improved."

However, the Forest Service’s Cohesive Strategy was never finished or approved, and instead, the agency has been working with the Department of Interior agencies to develop a new Joint Cohesive Strategy. In the this latter document, discussion of FMPs has moved from a clear mandate to become simply a brief definitional description, although important new language extolling the vital role of public outreach and community-based collaboration in FMPs is presented.

The 2000 Rains Report on Large Fire Management

The next public acknowledgement of the poor status of the Fire Policy and FMPs came in the 2000 Forest Service Report, "Policy Implications of Large Fire Management: A Strategic Assessment of Factors Influencing Costs," (a.k.a. the "Rains Report" in reference to the report’s team leader, Michael Rains). The Rains Report was commissioned after the agency spent $178 million in 1999--fully 30% of its annual suppression budget—attempting to suppress just two of the 93,702 fires that burned that year. The Big Bar and Kirk Fire Complexes were two lightning-caused fires that burned mainly in remote designated wilderness and inventoried roadless areas in northern California. Despite massive "siege-like" suppression operations, the agency failed to contain or control these fires until fall rain and snow storms put the fires out.

The Rains Report disclosed that, "Fire management planning has not been a priority, with less than five percent of the National Forests having current, approved fire plans. The agency is not in compliance with the National Fire Management Policy." The Report further revealed that neither of the National Forests they investigated had completed required FMPs, and that if they had done so, these FMPs could have made significant differences in the effectiveness and costs of the suppression efforts. For example, Policy-compliant FMP that allowed wildland fire use in the wilderness and roadless areas might have prevented some of the more costly and damaging suppression actions to these pristine areas. In order to improve the fire management program nationally, the investigative team made the following recommendation to the Forest Service:

"Implement fire management planning on a large scale, consistent basis. This includes tiering fire management planning to the Forest Land Management Plans and placing fire as an equal resource in the land management process."

In response to the findings and recommendations of the Rains Report, Forest Service Chief, Mike Dombeck, issued a directive in March, 2000 requiring all National Forests to complete and approve new FMPs "for every burnable acre" by December, 2001.

Forest Service Interval Survey of FMPs and the Fire Policy

Chief Dombeck's directive had sparked similar requests as to the status of FMPs by members of Congress, the General Accounting Office, the Office of the Inspector General, the Office of Management and Budget, and the public. Consequently, the agency conducted its own internal survey of FMPs and the Fire Policy in the summer of 2001. A simple spreadsheet was developed with two basic questions:

* Does the Forest Plan provide decisions and direction necessary to implement the 1995 Fire Policy in your FMP? (yes or no)

* Has a FMP been completed? (yes or no)

According to the agency's own survey, 94% of the National Forests had completed FMPs, but only 43% of existing FMPs complied with the 1995 Fire Policy. These results were quite surprising --and in the opinion of this author highly suspect--because they so dramatically differed from the earlier findings of the Rains Report (completed a year earlier) that disclosed over 95% of the National Forest lands had not completed FMPs in compliance with the Fire Policy. Moreover, even though the agency's internal survey data was later used in the GAO and NAPA reports on the status of fire planning among the federal agencies, their figures did not come out the same.

Lingering questions and uncertainty over the validity and reliability of the Forest Service’s internal survey make citizen analysis of FMPs even more necessary. It seems that many FMAPs were modestly updated and then labeled as FMPs but the latter, if compliant with the Fire Policy, are qualitatively different kinds of documents. For example, FMAPs do not plan wildland fire use for resource benefits or interagency landscape-scale fuels treatments across jurisdictional boundaries. The case for citizen advocacy and involvement in developing new Policy-compliant FMPs is even more compelling since, despite Chief Dombeck's directive for all National Forests to complete needed FMPs by December, 2001, the agency’s survey revealed that several Forests would not be able to comply with this order until December 2003.

The 2001 NAPA Report on Managing Wildland Fire

In yet another review of federal fire policies in the wake of the severe 2000 fire season, the National Academy of Public Administration, an independent non-profit organization chartered by Congress to help analyze and improve government operations, completed an intensive review and critique of the lack of implementation of the Fire Policy. The NAPA report explained that "FMPs are the cornerstone for meeting Fire Policy goals to reintroduce fire into ecosystem management." Not surprisingly, FMPs were at the top of NAPA’s list of "Fire Policy Action Items Not Implemented." Specifically, the report charged that: "A significant number of FMPs remain out of date or inconsistent with the 1995 Federal Fire Policy."

NAPA researchers interviewed several federal officials, asking them why were FMPs still incomplete or nonexistent several years after the Policy had been approved. Below are some of the excuses that were given. These excuses are followed by the author’s responses:

* "There has been more to do than there is time and staff available, and competing priorities have delayed completion or updating FMPs." (p.48)

Response: FMPs were the highest priority for implementing the Fire Policy. The agency has consistently chosen to prioritize commercial timber extraction over community fire protection, fuels management, and strategic fire planning. Congress has greatly increased funding for federal fire management programs via the Appropriations Acts for the National Fire Plan. The Forest Service has hired thousands of new employees with this money; unfortunately, almost all of them were hired as traditional firefighters rather than fire planners, ecologists, researchers, or educators.


* "Land units are not held accountable for completing them. There was no final due date for completing them and there were few consequences for not having a current FMP." (p.48)

Response: FMPs are the responsibility of line officers as mandated by the Forest Service Manual and Handbook, and should have been part of their annual job performance evaluations. Following the 1999 Rains Report, Forest Service Chief Mike Dombeck imposed a December 2001 deadline for all National Forests to complete FMPs, but this deadline was not met. In testimony before the House Subcommittee on Forests and Forest Health on July 31, 2001, Forest Service Chief, Dale Bosworth, promised that all National Forests should have Policy-compliant FMPs by July, 2003.


* "Lack of adequate data has hampered some land units from preparing FMPs." (p.49)

Response: Congress has appropriated millions of dollars for the Joint Fire Sciences Program which has been collecting data and developing science products for use by managers in fire and fuels planning. One of the necessary duties in developing FMPs is to generate the local data needed for them; indeed, data collection is not a prerequisite but rather is part of the process of crafting FMPs.


* "There is some reluctance to update the FMP when the Land Management Plan to which it is supposed to be tied is scheduled for revision." (p.49)

Response: The 2002 Policy Update clearly and repeatedly warned that an obsolete Forest Plan was not a valid reason to delay developing FMPs. On the other hand, all six National Forests in Utah decided to undergo a joint Forest Plan Amendment--even though some of the Forests had revisions scheduled just a few years away—so that they could come into compliance with the Fire Policy and begin developing FMPs as soon as possible. It is unknown why the rest of the National Forests have not followed the example of Utah’s National Forests.


* "Other disciplines perceive FMPs, and the Fire Policy in general, as the fire program’s priority, and they often do not consider them a high priority." (p.49)

Response: In the context of the perceived national wildfire crisis and the huge appropriations for the National Fire Plan, this excuse is rapidly losing its strength. In fact, fire management is becoming almost the dominant management theme in some Forests and Regions; for example, nearly every commercial timber sale project in Region Five (California) has fire or fuels management as its primary purpose and need.


The NAPA Report concluded with several major findings and recommendations. The Report found that there was insufficient involvement by federal agencies and non-governmental parties (e.g. conservation organizations, general public) in fire management planning, and that this was a serious impediment to implementing the Fire Policy. The Report recommended that
"(L)and management agencies use existing state and community-based organizations to the greatest extent possible to involve a wide range of governmental and non-governmental stakeholders in land management and fire management planning…"

The 2002 GAO Report on Wildland Fire Management

In March, 2002, the GAO produced the report, "Wildland Fire Management: Improved Planning Will Help Agencies Better Identify Fire-Fighting Preparedness Needs," for members of Congress. The report reviewed the agencies’ fire preparedness programs funded by the National Fire Plan, and attempted to clarify the relationship between the National Fire Plan, the Federal Fire Policy, and FMPs. FMPs are funded through the Fire Preparedness portions of the agencies’ appropriated budgets. The GAO reported that,
"As of September 30, 2001, six years after the national Fire Policy was developed, over 50% of all federal areas that were to have a fire management plan consistent with the requirements of the national Fire Policy were without a plan. These areas did not meet the Policy’s requirements because they either had no plans or had plans that were out of date with the Policy requirements…"

The Forest Service reported that it had 137 units without a compliant FMP, with 57% of existing FMPs failing to comply with the Fire Policy. The area affected by nonexistent or non-compliant FMPs totaled nearly 75 million acres, or 41% of the National Forest landbase.

When the GAO asked fire managers why FMPs were out of date or nonexistent, the common response was that the agencies and/or individual managers had "higher priorities." The GAO explained that,

"Without a compliant FMP, some of these managers told us that their local unit was following a full suppression strategy in fighting wildland fires, as the current Policy requires. That is, they extinguish all wildland fires as quickly as possible, regardless of where they are, without considering other fire management options that may be more efficient and less costly."

The GAO recommended that in order to meet the objectives of the National Fire Plan, the Secretaries of Agriculture and Interior should "ensure that fire management plans are completed expeditiously for all burnable acres and are consistent with the national Fire Policy."


To summarize, the above status reports on completion of FMPs and implementation of the Fire Policy raise more questions than answers. It is clear that the Forest Service has been failing to implement essential components of the Fire Policy , beginning with completion of FMPs. Without Policy-compliant FMPs, the Forest Service is essentially blindly fighting all fires in all places at all times—thereby increasing risks to firefighters, costs to taxpayers, and damages to ecosystems. Both the Fire Policy and fire planning give forest managers a broader range of tools and options for managing fire and fuels. This would seemingly be attractive to managers; however, the Fire Policy also compels them to think about wildland fire in more ecological terms, and to change their traditional mission from fire control to genuine fire management. This philosophical change has been policy on paper since 1978 but still has yet to be systematically put into practice on-the-ground. Consequently, it will be up to citizens to advocate for new FMPs, to push for inclusion of citizen stakeholders in their development, and to monitor their use in wildland fire incidents and fuels management projects.

The Forest Service touts FMPs as "dynamic, living documents that will be updated annually or whenever better information is provided." This clearly has not happened except minor updates for routine budgetary purposes (e.g. staffing of initial attack fire crews). However, with the additional resources provided by the National Fire Plan, the plethora of new fire policy documents and fire science data, and the political context of the "wildfire crisis," the interest and ability in developing high-quality Fire Policy-compliant FMPs is greater than ever. An additional impetus is that an interagency template for FMPs in the Forest Service and Department of Interior agencies has been approved in Spring, 2002, prompting the need for all existing FMPs to be revised in order to conform to the new format. Whenever the Joint Cohesive Strategy is finally approved, it may also compel significant revisions of FMPs in accordance with the Implementation Tasks for the Ten-Year Comprehensive Strategy. Below is a detailed description of this new interagency template, and some analytical tips for citizens to use in critiquing both existing and future revised FMPs.

THE INTERAGENCY FMP TEMPLATE

The Fire Policy calls for an interagency and multidisciplinary approach to managing wildland fires, since fires respect no jurisdictional boundaries. The ultimate goal is a fully integrated fire management program with uniform policies and practices providing for a seamless, cross-boundary approach to wildland fire management between the Forest Service and Department of Interior agencies. Recognizing the fire planning procedures were different among all federal land management agencies, a National Fire Planner was hired in 1998 and stationed at the National Interagency Fire Center in Boise in order to come up with a common template for fire management planning. After numerous drafts and revisions, a common interagency template was finally approved in May, 2002. Reflecting the interagency spirit and letter of the Fire Policy, a new definition of FMPs and its objective was created:
"FMPs identify and integrate all wildland fire management and related activities within the context of approved land management plans. Wildland fire management goals and components must be coordinated across administrative boundaries on a landscape basis. Bureau or agency fire management decisions must be consistent or compatible across administrative lines."
The result is that all future FMPs must utilize the new template, and all existing FMPs must be revised in the next few years to conform to the new standards. Although at present there are very few interagency FMPs, and those that exist are usually joint USFS/BLM plans, hopefully there will be more interagency and collaborative FMPs developed in the near future. Below are the sections or chapters that each FMP should contain, along with tips on what to look for in analyzing individual FMPs specifically developed by or for Forest Service units.


Section I: Introduction

The Introduction states the needs and reasons for developing the FMP in the given administrative unit--a National Forest, National Park, Wildlife Refuge, Indian Reservation, Resource Area, etc. The Introduction states how the FMP will help achieve the unit's land and resource management objectives, and will meet requirements of environmental and cultural protection laws and regulations. It identifies the authorities under which the FMP is developed (e.g. the organic acts for each agency). The Intro will describe the collaborative processes used to develop underlying land management plans and the FMP, as well as additional collaborative opportunities that will be available as the FMP is implemented.

Analytical Tips:
One of the most problematic aspects of FMPs is their lack of compliance with NEPA. The agency will argue that FMPs comply with NEPA by tiering to the Forest Plan, but it is likely that there may be significant new information and programmatic direction disclosed in the FMP that was never presented in the Forest Plan. As well, compliance with NFMA and ESA regulations may be problematic on species viability requirements. Many species on the ESA list are fire-adapted or fire-dependent; arguably, one of the reasons they are threatened or endangered is through habitat alteration by systematic fire exclusion policies and suppression practices.


Section II: Relationship to Land Management Planning / Fire Policy

The Land Management Planning/Fire Policy section references and cites agency management policies concerning fire management. This section relates the FMP to the enabling legislation and the purpose of the administrative unit, and summarizes the significant resources and values of the unit. It identifies in broad programmatic terms the fire management direction found in Forest Plans, such as goals, objectives, standards, guidelines, and/or desired future condition(s).

Analytical Tips:
The most problematic aspect of Forest Service FMPs in each section will be the inherent contradictions between the Forest Plan and FMP. The original round of forest planning in the mid 1980s was woefully inept on fire issues. Forest Plans almost exclusively dealt with fire simply as a suppression issue, or as a slash reduction activity. In a few cases, some discretion for Prescribed Natural Fires (PNFs) were written into some plans in the 1990s, but these were mainly restricted to designated Wilderness Areas. Forest Service FMPs will not permit WFURBs, if at all, beyond the wilderness areas where PNFs were permitted in their respective Forest Plans. The Fire Policy's expansive concepts of managing wildland fires for resource benefits or wildland fire use (WFURBs or WFU), simply does not exist in current Forest Plans, and this severely constrains the development of high-quality, Policy-compliant FMPs. Citizens will likely need to advocate for Forest Plan amendments in order to increase WFURBs and WFU opportunities.


Section III: Wildland Fire Management Strategies

Subsection A: General Management Considerations

This section briefly describes how wildland fire will be managed, and identifies any area-wide considerations, such as interagency partnerships, regional strategies, collaborators and collaborative processes that should be incorporated in fire management strategies. The core principles of the 10-Year Comprehensive Strategy should be considered, including collaboration, priority-setting, and accountability.

Analytical Tips:
The notion of collaborative fire planning with non-governmental stakeholders is a brand new concept from both the Fire Policy and the Comprehensive Strategy. Fire planning within the Forest Service has traditionally been an exclusively internal if not insular activity by agency fire staff. While a few Forests have recently made some gestures toward public involvement, such as convening "open houses" and posting web pages to announce development of FMPs, the information flow is largely top-down and one-way from the agency to the community. Strategic direction in FMPs are still overly influenced by commodity resource extraction values and objectives, at the expense of other public values and concerns, such as the desire to prioritize protection of homes and communities, and avoid the costs and impacts of aggressive suppression actions. Consequently, there is little to no accountability of Forests to the public when FMPs fail to plan for a full range of strategies and tactics for managing fire, as mandated by the Fire Policy.


Subsection B: Wildland Fire Management Goals

This section lists the wildland fire management goals which provide programmatic direction for the fire program. These goals should be stated in broad, programmatic terms. Ideally, these are found in approved Forest Plans; thus, this section describes how the FMP will safely and effectively contribute to achieving the Forest Plan's fire management goals and objectives. Also, this section identifies how these FMP goals contribute to accomplishing regional or national strategic plans such as the 10-Year Comprehensive Strategy, National Fire Plan, Cohesive Strategy, as well as the Federal Fire Policy. Fire program goals reflect the core principles and goals of the Comprehensive Strategy and the Cohesive Strategy where they are supported by Forest Plans.

Analytical Tips:
Revealingly, directives say "ideally" programmatic direction for fire management will be found in Forest Plans. Again, most existing Forest Plans are woefully inadequate in fire-related information and analysis, and are obsolete from the standpoint of current federal policies and national strategies. There may be significant gaps or contradictions between Forest Plans and FMPs, and this section may attempt to gloss over these differences. Copies of the fire and fuels management portions of the Forest Plan FEIS and ROD will be required in order to document these differences. If these differences are significant, i.e. if the FMP makes programmatic decisions that are not supported by the Forest Plan, then a potential NEPA violation exists, and this provides an excellent argument for a Forest Plan amendment or revision process.

FMPs will be required to tier to key national strategic documents, but currently only some of these are available. The Comprehensive Strategy and its supporting Implementation Plan and Performance Measures have been finalized, but the Cohesive Strategy is still undergoing the laborious process of internal agency approval. The founding document for the National Fire Plan, the "Report to the President," is not really a new policy document as much as it is a funding request and schema for increased Congressional Appropriations. Consequently, concrete policies flowing from the National Fire Plan are dependent on Report language or other Congressional direction attached to annual Interior Appropriations Acts, and these can change from year to year along with changing political objectives in Congress.

It is quite revealing that the most significant national strategic document--the Federal Fire Policy--is the last item on the list of national strategic plans, and it is presented almost as an afterthought. The Fire Policy marks a fundamental shift in philosophy and practice, and has severely challenged the Forest Service's traditional fire suppression mission and culture. However, as the GAO and NAPA have argued repeatedly, the Fire Policy provides the philosophical and policy foundation for all federal interagency wildland fire management activities conducted under the National Fire Plan and related Comprehensive and Cohesive Strategies. Citizens interested in protecting, sustaining, and restoring fire-adapted ecosystems should advocate for the primacy of the Fire Policy in guiding FMP development.


Subsection C: Wildland Fire Management Options

This section briefly addresses the scope of wildland fire management program options that will be implemented and further developed through the FMP. It should include a brief and defensible rationale for all wildland fire management strategies that managers intend to apply in each Fire Management Unit (FMU) or Fire Management Zone (FMZ). It may include the full range of options authorized under the current Fire Policy, or a more limited range consistent with approved Forest Plans and resources to be protected.

Analytical Tips:
A significant change was made in the Fire Policy that replaced the term "Appropriate Suppression Response" with that of the "Appropriate Management Response." The Forest Service officially changed the fire mission from fire control to fire management in 1978, but this change in terminology on paper was not translated into change in actual on-the-ground practices, and approximately 99% of all wildland fires continue to be suppressed. The concept of the Appropriate Management Response to wildland fires is more than a semantic shift; it denotes a full range of options for managing wildland fires beyond the traditional reaction to contain and control. Instead, mangers can opt for confinement of fires within natural fire breaks (e.g. ridgelines, creeks, talus slopes, etc.) which would entail letting fires burn over time and space to reach those natural barriers instead of attempting to completely encircle and extinguish fires as soon and small as possible.

The options for the Appropriate Management Response range from aggressive containment and full control, to minimal-impact confinement and aerial monitoring of wildland fires. The full range of these responses can even be applied on a single fire incident. Formerly it was an absolutist decision to either allow a fire to burn as a Prescribed Natural Fire, or declare it a wildfire and totally suppress it. Accordingly, this section should provide some evidence that the full range of options outlined in the Fire Policy and its concept of the Appropriate Management Response will be applied.


Subsection D: Description of Wildland Fire Management Strategies by Units and Zones

Identification of fire management units(FMUs) and fire management zones (FMZs), and management strategies within each FMU/FMZ, is the cornerstone for fire planning. An FMU/FMZ is any land management area definable by objectives, management constraints, topographic features, access, values to be protected, political boundaries, fuel types, major fire regime groups, and so on, that set it apart from the management characteristics of an adjacent FMU/FMZ. The FMUs/FMZs may have dominant management objectives and pre-selected strategies assigned to accomplish these objectives. The development of FMUs/FMZs should avoid redundancy. Each FMU/FMZ should be unique as evidenced by management strategies, objectives, and attributes.

This section must tie directly to the decisions made in the Forest Plan for each specific Management Area, aggregated into FMUs/FMZs. This section identifies the objectives, standards, guidelines, and/or future desired conditions within each FMU/FMZ, and the wildland fire management strategies that will be used to accomplish them.

Analytical Tips:
This is the real core of the FMP where specific fire management strategies and tactics will be assigned to specific areas of the Forest. Here is where readers can apply their place-based knowledge of local features, resources, or values that may or may not be addressed in the FMP. Here is where readers can assess the rationale for assigning certain locations into specific FMUs/FMZs, and the strategies devised for them. For example, units or zones based on political boundaries may not be ecologically rational or technically feasible given that fire as a landscape disturbance process respects no ownership lines.

As noted above, nearly all existing Forest Plans are obsolete and inadequate in terms of fire management information and analysis. Relatedly, some land allocations may have undergone changes since the original Forest Plan was approved; thus, for example, some Management Areas originally allocated to commercial timber extraction may now be managed as wildlife or riparian reserves. Despite these changes, the original fire management strategy--normally fire exclusion and full suppression--may not have changed in accordance with new land management objectives. Areas that originally called for fire exclusion in order to maximize the number of trees per acre may now require fire reintroduction in order to increase wildlife forage, or reduce hazardous fuel loads, for example.

Defining FMUs and FMZs are similar in process, but different in product. FMZs focus on describing fire suppression capabilities needed for annual budgeting purposes used by the National Fire Management Analysis System (NFMAS). Thus, FMZs are based on such things as historical fire occurrences, initial attack response times, and other things related exclusively to suppression objectives. FMUs, on the other hand, are based on multi-resource management objectives outlined in the Forest Plan, and incorporate data beyond an exclusive suppression focus. Both the scope of issues and the spatial scale of FMUs and FMZs should differ. In Region Six (Pacific Northwest), for example, the scale of FMUs will be based on the U.S. Geological Service’s Fourth Order Hydrologic Unit Codes (HUCs), generally known as subbasins composed of multiple watersheds.


Section IV: Wildland Fire Management Program Components

Each FMP should be composed of the following fire management components that define and document the Forest's fire program: wildland fire suppression, wildland fire use, prescribed fire, non-fire fuel applications, emergency rehabilitation and restoration. Each of these components should be addressed in detail as they relate to the fire management considerations, goals, and options for each FMU/FMZ. A description of each component is presented below:


Subsection A: Wildland Fire Suppression

This section includes program direction for suppression actions taken on fires for which suppression is the appropriate management response (i.e. the fire is not be managed for resource benefits). A full range of suppression response is available consistent with objectives, constraints, or other direction for a FMU/FMZ. Suppression also includes program areas such as preparedness (including prevention and community education programs, community grant programs and assistance, training, qualifications, readiness, detection, and aviation), initial attack, extended attack, and other management considerations (e.g. air quality).

Analytical Tips:
The full range of suppression actions should be described. Given sufficient public input and demands, in some places specific suppression techniques or equipment should be explicitly prohibited, such as bulldozers in roadless areas, chemical retardants in riparian areas, etc. Suppression should strive for the least costly and least damaging actions required for each FMU/FMZ.


Subsection B: Wildland Fire Use

This section includes direction for managing wildland fires used for resource benefits (WFURBs) It includes direction for such things as decision criteria, implementation procedures, identifying objectives, constraints (air quality, etc.), required personnel, public interaction, and documentation and reporting requirements (e.g. costs).

Analytical Tips:
Planning for WFU opportunities is one of the most important functions of a FMP that complies with the Fire Policy. According to the 2001 Fire Policy Update, it is the conditions under which a given fire is burning, not its ignition source or location, that should determine the appropriate management response. Theoretically, even accidental human-caused fires in non-wilderness, general forest areas could be managed for resource benefits if they are burning under prescribed conditions, are accomplishing desired effects, and are authorized by the given FMP. Considering the amount of land that needs reintroduction of fire in order to restore ecological health, every ignition, be it natural or human-caused, ought to be considered for a potential WFU opportunity. The FMP should facilitate these opportunities as much as possible, giving discretion for WFU over as much land base as necessary, by developing site-specific burning prescriptions for each FMU/FMZ. Thus, provisions for WFU should be a major element of and argument for developing new FMPs that comply with the Fire Policy.


Subsection C: Prescribed Fire

This section describes planning and implementation for prescribed fire. It includes direction for annual activities for implementation, long-term prescribed fire program, required qualified personnel, prescription requirements, prescribed fire plan requirements, air quality and smoke management, treatment maps, documentation and reporting requirements.

Analytical Tips:
Most existing Forest Plans and FMPs discuss prescribed burning mainly in relation to disposing activity fuels, i.e. logging "slash." Broadcast prescribed underburning is also a proven effective method for managing natural fuels accumulations. Compared to other mechanical or chemical fuels treatments, prescribed burning is the most effective method for reducing surface fuel hazards and the most ecologically sound means for restoring fire disturbance processes. Like WFU, FMPs should provide as much discretion for prescribed burning as possible in areas suitable for reintroduction of fire.


Subsection D: Non-Fire Fuel Treatments

This section describes planning and implementation for non-fire fuel treatments. It includes direction for annual activities for implementation, equipment and seasonal use restrictions, effects monitoring requirements, documentation and reporting.

Analytical Tips:
Non-fire fuel treatments include mechanical, chemical, or biological methods. Mechanical fuels treatments may include non-commercial/pre-commercial thinning and commercial logging with chainsaws and/or heavy equipment; chemical treatments include the use of herbicides. Mechanical and chemical treatments are typically the tools of choice by the Forest Service, timber and chemical industries, and their allies in Congress because these methods involve the transfer of commodity resources and cash from the public to the private sector. Arguments for mechanical/chemical treatments fail to acknowledge the best available science, though. There simply are no mechanical or chemical substitutes capable of performing all of the vital ecological functions that fire performs in sustaining ecosystem health and biological diversity. Due to political and institutional pressures, however, FMPs will now require more emphasis on non-fire fuels treatments, perhaps even reserving whole FMUs/FMZs for these methods while continuing fire exclusion objectives.
Ironically, one of the Forest Service's most popular "mechanical treatments" to allegedly reduce hazardous fuel loads--salvage logging--is not discussed in FMPs. Post-fire salvage timber sales are routinely portrayed as fire/fuels hazard reduction projects; yet, they have no basis in strategic FMPs. Instead, the Forest Service plans these timber sales in an ad hoc, opportunistic fashion. Citizens should strongly advocate that post-fire salvage logging procedures—as an alleged hazardous fuels reduction technique—should be included in FMPs and fit within the Forest’s overall strategic management of fire and fuels hazards. Moreover, FMPs should specify sensitive sites and areas where salvage logging should be prohibited, such as:

* severely burned areas (areas with litter destruction)

* erosive sites

* fragile soils

* roadless areas

* riparian areas

* steep slopes

* any site where accelerated erosion is possible

* old-growth stands

* designated wilderness and inventoried roadless areas


Other potential topics in this section include fuelbreak construction. Fuelbreaks are supposed to be strategically located strips or blocks of land on which vegetation and fuel is modified in order to reduce fire behavior potential. Fuelbreaks do not stop fires on their own, but rather, are pre-suppression installations intended to facilitate firefighters’ efforts to construct firelines, conduct firing operations, and engage in other activities to contain and control wildland fires. Fuelbreaks are often constructed in conjunction with commercial timber sales. Theoretically, fuelbreaks could also be designed to support large-scale prescribed burning and wildland fire use, but this is not a common purpose or use presented in Forest Service fuelbreak proposals. Fuelbreaks designed for prescribed controlled burning would be constructed differently than those intended for emergency wildfire suppression.

Fuelbreaks are gaining in popularity with Forest Service timber managers, but are also increasing in controversy, for there are several ecological reasons to oppose the construction of large-scale fuelbreak systems with commercial timber extraction. One of the most critical arguments against fuelbreaks is that they fragment forests, thereby causing adverse impacts on sensitive wildlife species. Another critical argument is that they require extensive, expensive periodic maintenance, which often leads to herbicide spraying. Check the Western Fire Ecology Center webpage for other arguments to critique specific fuelbreak timber sale proposals:
http://www.fire-ecology.org/citizen/fire_fuels_arguments.html.

FMPs must discuss fuelbreak-related issues and locations, but readers should check to see if the related Forest Plans support such efforts. If not, then the FMP is making programmatic decisions to support fuelbreaks, that go beyond analysis and disclosure in Forest Plans, exposing likely NEPA violations.


Subsection E: Emergency Rehabilitation and Restoration

This section references post-fire emergency rehabilitation (stabilization) and restoration planning and implementation. Refer to the Interagency Burned Area Emergency Stabilization and Rehabilitation Handbook.

Analytical Tips:
Emergency rehabilitation and restoration are activities funded by suppression budgets that are intended to mitigate some of the damage caused by suppression actions, and to mitigate some of the potential soil erosion and watershed impacts caused by precipitation events on burned slopes. There is growing controversy over whether or not these costly rehab techniques actually work effectively to mitigate damages, and whether they cause adverse impacts of their own. For example, installing "water bars" in firelines may not effectively prevent gully erosion, and spraying exotic grass seeds on burned slopes competes with native plant recovery and creates a short-term flashy fuel hazard. For a more thorough discussion of the problematics of post-fire rehab and restoration techniques, see the recent Forest Service report by Robichaud, et.al. (2000) available on the Western Fire Ecology Center webpage (http://www.fire-ecology.org/science/Postfire_Rehab.pdf]. FMPs must discuss where and under what conditions emergency rehabilitation and restoration activities will occur.


Section V: Organization and Budget

This section contains information pertaining to the wildland fire management organization and budget. It identifies the fire organization and budget needed to achieve the goals and objectives identified in the Forest Plan and FMP. It includes such things as the number, timing and location of the workforce and necessary equipment. The wildland fire management organization is normally based on analytical tools such as the Interagency Initial Attack Assessment (IIAA). This section also identifies the budget level to support the fire management organization. It identifies both the desired and current fiscal year organizations and budget levels if they are different. Contract resources, and supplemental and cooperative agreements should be identified and referenced here.

Analytical Tips:
According to Forest Service Manual, wildland fire use opportunities cannot be allowed if individual Forests do not have trained and qualified personnel to perform essential duties. (FSM 5145.1) The organization and budget section should detail the fire staff positions, and readers should look specifically for such positions as Fire Use Manager (FUMA), Long-Term Fire Analyst (LTAN), Fire Behavior Analyst (FBAN) that need to be staffed, funded, and available to the given National Forest.

Also, examination of the organization and budget may reveal the institutional bias that favors fire suppression over fire use and prescribed fire management. Citizens will have to advocate for more parity in the fire organization and budget—which reflect deliberate choices by line officers who develop and approve the budget. Taxpayers should demand full accountability that the investments and expenditures made with National Fire Plan funds go exactly where they were intended: strategic, proactive, long-term approaches towards reducing the threats of severe wildfire on communities and the environment, reducing hazardous fuel loads, and reducing the hazards, costs, and impacts of fire suppression activities. Fire management planning in accordance with the Fire Policy is an essential prerequisite to these long-term goals, and FMPs should be fully funded on an annual basis.


Section VI: Monitoring and Evaluation

This section outlines monitoring and evaluation requirements. It identifies components, procedures, time frames, responsibilities and reporting requirements for monitoring and evaluating whether the FMP is being implemented as planned and whether fire-related goals and objectives are being achieved. Information obtained from monitoring and evaluations is used to update the FMP as well as land use plans. Monitoring and reporting of national wildland fire performance measures will also be addressed.

Analytical Tips:
Monitoring of forest management activities has traditionally been neglected and under-funded. Citizens should review this section to ensure that the Forest is committed to implementation and effectiveness monitoring of fire and fuels management projects including fuels reduction projects (both prescribed burning and mechanical treatments), post-fire rehabilitation and restoration projects, and monitoring of natural post-fire recovery processes. Citizens should advocate for collaborative processes to ensure multi-party monitoring with citizen involvement of all fire and fuels management projects, and that procedures of these public input processes be included in the FMP.


Sections VII and VIII: Glossary and Appendices

Analytical Tips:
In some cases, the appendices may take up more pages than the actual FMP. They can include copies of the numerous forms that fire managers must fill out for all their operations, ranging from the "Go/No Go Checklist" needed to fill out when considering whether or not to manage a WFU, to more innocuous documents like vehicle accident reporting forms. One of the more important documents to review that may be located in appendices is the "Incident Complexity Analysis" form. It contains some interesting items such as "External Political Factors" and "Resource Issues" that managers must consider before allowing WFU and prescribed fire opportunities. Citizens should question line officers and fire managers—preferably before fire season and specific fire incidents—that they are taking into consideration while devising the appropriate management responses to wildland fire.

In sum, all existing and future FMPs in all federal land management agencies must utilize the interagency template when updating, revising, or developing FMPs. Citizens should hold the Forest Service accountable to complete this task in a timely manner. Citizens should also compel legislators to insert explicit language into future Interior Appropriations Bills to ensure that the Forest Service makes development and approval of Policy-compliant FMPs a major priority in its Fire Preparedness program funded by the National Fire Plan. Finally, citizens should assert the appropriate laws and policies to ensure that FMPs are completed in a collaborative manner with full public involvement at each stage in their development process.

HOW TO READ AND ANALYZE FMPs

Where to Locate FMPs

The first step in analyzing FMPs is to get a physical copy of the document. In a recent survey of FMPs by the Western Fire Ecology Center, it was discovered that each National Forest keeps its copies stored in different places. The most common place to find them is in the Fire Dispatch Office. Fire Dispatch offices are open year-round; however, during fire season and especially when fires are active in the area, it is extremely difficult for employees to answer non-emergency phonecalls. It is quite revealing, though, to discover that some dispatch offices do not know where copies of the FMP can be located. Again, the initial management response to wildland fires should be based on the guidance provided by FMPs. In those cases where the FMP is not located in the Fire Dispatch office, the next place to look is in the office of the Fire Management Officer (FMO), who is the chief fire manager and planner for each Forest. Typically, the FMO will delegate public response work to their Assistant (AFMO). In some cases, your request may be handled by a Public Affairs Officer (PAO). The offices of the FMO, AFMO, and PAO are usually located in the Supervisor's Office for each National Forest.

Usually, friendly requests for copies of the FMP are the best way to get them, but some Forests will require you to make a formal Freedom of Information Act (FOIA) request in writing. FOIA requests may take up to a month to fully process. Citizens are allowed up to 200 pages of photocopies for free; the agency then charges 20 cents per page for documents over that page limit. Most FMPs are under the 200 page threshold for free photocopying. In some cases, individual Forests have put their FMPs onto compact disks, which are another option instead of hardcopy versions.

A boilerplate FOIA request letter that can be used to request FMPs can be found on the Western Fire Ecology Center’s webpage: http://www.fire-ecology.org/citizen/Fire_FOIA.html.

Requests for FMPs made during the heat of fire season can sometimes take a long time to respond since fire staff may be gone serving on wildfire incidents elsewhere. The best time to ask and receive copies is during the winter and spring months, but be sure to ask for the most recent, approved version, and ask if the FMP is currently undergoing revision. FMPs are supposed to be reviewed and updated annually, and in the next few years most or all FMPs may undergo significant revisions in order to comply with the Fire Policy and conform to the new interagency template.

General Arguments for Critiquing FMPs

A few FMPs revised in 2001 do utilize the terminology and language of the Fire Policy, but the most common problem you will encounter in reading existing FMPs is that most do not comply with the Fire Policy. Therefore, they will contain obsolete terminology and outdated strategies and tactics. The few FMPs that do exhibit some of the language of the Fire Policy will likely violate its fundamentally restorationist spirit, for most existing FMPs are still heavily biased toward fire suppression and prevention objectives while neglecting or underutilizing prescription burning and wildland use for ecological restoration purposes. At a minimum, critiques should argue on the basis of the Fire Policy's mandate for more parity between prevention, suppression, prescription, and wildland fire use activities, but should assertively promote restoration goals for fire management.

Another common problem will be the discovery of contradictions or gaps between Forest Plans and FMPs. In some cases, FMPs may make programmatic decisions that are not made in their respective Forest Plans. This violates NEPA regulations, and provides rationale for Forest Plan amendments or revisions in order to fully analyze and disclose the effects of new FMP strategies or tactics.

One of the Guiding Principles of the Fire Policy is that FMPs are supported by sound science, so another problem of existing FMPs is that they fail to utilize the best available science. This is particularly evident in FMPs that prescribe fire exclusion in fire-dependent or fire-adapted ecosystems--an inherent contradiction that precludes long-term ecological sustainability.

Another general critique is that FMPs fail to analyze the environmental impacts of standard fire suppression techniques. The agency argues that suppression is an emergency action not subject to NEPA. But in the case of FMPs that make programmatic decisions to engage in suppression actions, at a minimum there should be some kind of general description of the kinds of suppression activities that will occur in specific FMUs, and their predicted short-term environmental and long-term ecological effects. This kind of disclosure would facilitate a tradeoffs analysis of the impacts of fire suppression version wildland fire use, and would make a better case to the public for carefully planned proactive fire management projects as a means of avoiding unplanned reactive fire suppression actions.

Finally, another critique is that all existing FMPs failed to fully inform and involve the public. Some Forests are going through the motions of public involvement through hosting public meetings and posting web sites announcing the development of FMPs, but the information flow is unilinear and there is no effective means for public input in FMPs or oversight of the fire management program. Public involvement at each stage in the FMP development process is essential, both to ensure that the selected strategies conform to sound science and social values (especially the priority of community wildfire protection), and to gain long-term public and political support for fire management programs and budgets. The Comprehensive Strategy requires collaborative fire planning among all federal, state, and local agencies, and interested private stakeholders. The current situation, however, is that there is not a single FMP in the Forest Service that fully complies with the letter and spirit of the Fire Policy or the Comprehensive Strategy from the standpoint of public involvement in FMPs.

Where to Find Additional Help and Resources

For most of the past decade, the Forest Service has evaded public involvement in fire planning because it has positioned itself as the sole expert on fire, with a near-monopoly of the technical knowledge and expertise needed to understand and engage in fire management and planning. Unfortunately, this technocratic posture conflicts with basic democratic principles required for public lands management. Given that the agency admits that its past fire management philosophy, policies, and practices have failed to protect communities or sustain ecosystems, this provides a huge mandate for greater public involvement in fire planning. However, most common knowledge and "conventional wisdom" people have about wildland fire has been the product of decades of propaganda and social conditioning that has misinformed and mis-educated the public about the vital ecological role of fire. Consequently, many people may feel incapable of competently engaging in collaborative fire management planning as full partners with Forest Service fire staff.

In our experience teaching people about fire ecology and fire management issues over the last ten years, we have found that with some basic knowledge about general fire ecology principles, this is an adequate basis to critique the Forest Service's fundamentally anti-ecological fire policies and practices. In order expand one's knowledge base and analytical abilities, though, the following are suggested additional resources you can seek to help become public experts and persuasive advocates for ecological fire management planning.

Websites:

The Western Fire Ecology Center home page (www.fire-ecology.org) has lots of information about general fire and fuels management issues. Check out the "Hot Links" section (www.fire-ecology.org/links.html) for websites containing additional fire-related information and educational materials from conservation organizations, federal fire management agencies, and fire ecology research organizations.

Check out the American Lands Alliance Home page (www.americanlands.org) for the latest updates on developments in fire-related legislation and administration policies.

Books and Articles:

Anything written by Stephen J. Pyne will help readers understand the history, policies and practices of the Forest Service fire organization, but some favorites include:

* Fire in America: A Cultural History of Wildland and Rural Fire. 1982. Seattle: University of Washington Press.

* Year of the Fires: The Story of the Great Fires of 1910. 2001. New York: Viking Press.

Check out the Fire Science section of the Western Fire Ecology Center webpage in early 2003 for a list of the best available fire science articles for use is critiquing fire-related management projects as well as Forest and fire management planning.

Perhaps the best collection of the best available government-funded fire science is in:

* The Sierra Nevada Ecosystem Project: Final Report to Congress, Volume II. 1996. Status of the Sierra Nevada: Assessments and Scientific Basis for Management Options. Wildland Resources Center Report No. 37.

The SNEP Report is available on the web (http://ceres.ca.gov/snep) and is located in several university libraries.

CASE STUDIES: CRITICAL ANALYSES OF FMPs

Beginning in Spring, 2003, case studies and analyses of existing FMPs will be posted in the Citizen Action section of the webpage for the Western Fire Ecology Center (www.fire-ecology.org). These will offer general critiques highlighting a few key items of interest to conservationists. They should be viewed as examples and starting points for citizens to use in conducting their own reviews and critiques of specific FMPs. Check out the "What's New" section of the webpage for updates on new postings of FMP critiques.

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