Status Reports of Fire Management Plans

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.


	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.