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.