National Fire Plan Implementation:
Forest Service Failing to Protect
Forests and Communities


by the American Lands Alliance

726 7th St., SE, Washington, DC 20003
Phone 202-547-9400, Fax 202-547-9213
Email: wafcdc@americanlands.org
Website: www.americanlands.org

March 2002


BACKGROUND

Congress responded to the severe fire season of 2000 by dramatically increasing funding for federal wildland fire management programs in FY2001. The Clinton Administration requested and Congress approved an unprecedented $2.8 billion for what is now called the National Fire Plan NFP). For the U.S. Forest Service and Bureau of Land Management, this represented respectively a 95% and 115% increase in funding for fire management from FY2000 to FY2001.

A major portion of the funding increase was targeted to Hazardous Fuels Reduction (HFR). From FY1998 through FY2000, appropriations for HFR averaged less than $93 million, but after the 2000 fire season, this was increased to $401 million in FY2001, and another $395 million for FY2002. With scenes of homes burning down in Los Alamos, New Mexico and the Bitterroot Valley in Montana still fresh in mind, Congress directed that the majority of these additional funds be focused on reducing hazardous fuels in the wildland/urban interface (WUI) zone.

Despite these huge increases in funding for wildland fire management programs, problems of fiscal and environmental accountability threaten to undermine the National Fire Plan. Report language for the FY2001 and FY2002 Appropriations Acts had stated Congress' concern about the Forest Service's historic lack of accountability in managing its wildland fire programs. During congressional oversight hearings, the Forest Service's National Fire Plan Coordinator, Lyle Laverty, revealed that only 25% of the funds slated for HFR was spent in the WUI, despite clear language in the 2001 Appropriations Act to spend 100% of HFR monies to protect communities.

Not only is there a lack of accountability in managing the HFR program, but despite all the additional NFP funding for fire suppression, the Forest Service disclosed that during the 2001 fire season it overspent its suppression budget by an estimated $230 million. The 2001 fire season burned less than a quarter of the acreage of the 2000 fire season; nonetheless, fire suppression costs averaged $1,340 per acre -- an increase of 270% over the 2000 fire season's costs.

Now the General Accounting Office has recently issued a scathing report that concludes there is no data available to demonstrate whether or not the increased funding for the NFP is being spent in an efficient, effective, and timely manner. The question arises: will Congress continue to throw more good money after bad, or will steps be taken to enforce genuine fiscal and environmental accountability in federal wildland fire programs and implementation of the NFP?


WILDLAND FIRES ARE NATURAL, VITAL, INEVITABLE ECOSYSTEM PROCESSES

While some of the fires of 2000 were uncharacteristically severe due to past management abuses, other fires including some of the mammoth fires in Idaho and Montana burned at natural intensities, yielding ecologically beneficial effects. For time immemorial, fire has been an essential process in the evolution of western forest and rangeland ecosystems. As a natural disturbance agent responsible for recycling nutrients, regenerating plants, creating wildlife habitats, and enhancing biological, structural, and landscape diversity, fire is as vital as water, sunlight and soil in the sustainability of fire-dependent species and fire-adapted ecosystems.

The vast majority of wildfires are started by human beings (from 1991-1997, an average 88% of all wildfires were human-caused). Even if it were possible to prevent all human-caused wildfires, natural fires would still burn across America's wildlands as long as living biomass produces combustible fuel, and lightning storms provides ignition sources. Thus, policies intended to exclude fires from the landscape are both ecologically inappropriate and technically impossible. From a socioeconomic perspective, policies intended to attack all fires in all places at all times are becoming an expensive futility.

The issue is not why or even when fires will start, but how they will burn. In this respect, intelligent fire management policies can both protect at-risk communities and restore degraded ecosystems through reintroduction of low-intensity prescribed fires, and elimination of management practices that increase the risk of high-severity wildfires.

SCIENTISTS AGREE: COMMERCIAL EXTRACTION INCREASES FIRE HAZARDS

In numerous academic, independent, and government-sponsored scientific studies, scientists have concluded that the primary causes of increased fire risks and fuel hazards are the past century's federal land management policies promoting aggressive firefighting, commercial logging, livestock grazing, and road building. For example, the 1996 Sierra Nevada Ecosystem Project Report, a $7 million scientific study commissioned by Congress that involved some of the nation's top fire scientists, concluded that, "Timber harvest, through its effects on forest structure, local microclimate and fuel accumulation, has increased fire severity more than any other recent human activity."

In another major regional study of the Interior West, government scientists concluded that, "Fire severity has generally increased and fire frequency has generally decreased over the last 200 years. The primary causative factors behind fire regime changes are effective fire prevention and suppression strategies, selection and regeneration cutting, domestic livestock grazing, and the introduction of exotic plants." Finally, the Congressional Research Service issued a report analyzing the impact of the 2000 fires, and disclosed that, "Timber harvesting removes the relatively large diameter wood that can be converted into wood products, but leaves behind the small material, especially twigs and needles. The concentration of these 'fine fuels' on the forest floor increases the rate of spread of wildfires."

Conversely, the scientific literature reveals that forests in un-roaded, un-logged areas are the least altered from historic conditions, have the greatest ecological integrity and most fire resiliency, and present a lower fire risk compared to areas altered by past intensive management. This is because, in general, roadless areas: 1) have not been subject to timber management activities that often increases hazardous fuel loads of highly-flammable small-diameter surface and ladder fuels; 2) have not been as altered by the effects of fire suppression, especially compared to previously roaded and logged lands, and 3) present the lowest risk of human-caused ignitions.

In summary, firefighting, logging, grazing, and roadbuilding are some of the sources of the problem of severe wildfires, not their solutions. Fire ecologists and most forest scientists agree that long term ecological restoration with careful fire reintroduction - not increased commodity resource extraction or aggressive fire suppression - holds the best hope of preventing future large-scale severe wildfires in fire-adapted ecosystems of the West.

CONGRESSIONAL AND AGENCY RESPONSES

For most federal programs, Congress sets an annual spending level that may not be exceeded by the federal agency. However, in the case of fire suppression and the federal budget, these rules do not apply. The Forest Service is permitted to take money from other agency programs and spend it on fire suppression. Then Congress routinely fully reimburses the Forest Service for the difference, with no questions asked. Due to this deficit-spending system Congress does not set a realistic budget for fire suppression, and the agency has little accountability or incentive to get serious about fire planning and preparedness. The Forest Service knows that Congress has a carte blanche policy for funding fire suppression, and thus implicitly opts to practice fire management by means of reactive emergency wildfire suppression rather than proactive planned fire restoration.

The HFR program was intended to be a proactive approach to prevent severe wildfires by offering funds for fuels reduction treatments in areas that had traditionally been neglected, either because these sites did not offer much valuable timber or other commodity outputs that would attract the attention of managers, or because they were considered high-risk sites for the use of prescribed burning. Unfortunately, Congress failed to establish explicit environmental safeguards to prevent agency managers from conducting business-as-usual commercial timber extraction under the guise of "hazard fuels reduction."

The Inspector General for the Department of Agriculture reprimanded the Forest Service for inappropriately using NFP monies intended for restoration projects to instead plan commercial timber sales. Using money intended to fund hazardous fuels reduction or forest restoration projects to conduct commercial logging in sensitive areas such as old-growth stands, roadless areas, riparian areas, sensitive wildlife habitats, etc. threatens the integrity of the HFR program, and could generate significant public opposition to the NFP.

Finally, despite Congress' clear interest in reducing severe wildfire threats to rural communities, federal agencies still do not have precise, science-based definitions of the WUI, nor have they prioritized communities for HFR treatments. This, too, threatens the integrity of the NFP. After billions of taxpayer dollars are spent, will members of Congress still be confronting the agony of their constituents whose homes are destroyed by wildfires caused, in part, by ecosystem mismanagement?

POLICY RECOMMENDATIONS

Congress and the Forest Service have an opportunity to reduce the exorbitant costs of wildfire suppression and to implement sensible fire management policies based on sound science. Unless changes are made in federal fire policy and practices, ecosystems will continue to be degraded, the costs of wildfires will continue to increase, firefighters' lives will be put in jeopardy, and homes will continue to be threatened. American Lands Alliance urges Congress and the Forest Service to adopt the following policy recommendations:

Implement the 1995 Wildland Fire Policy
Because the Forest Service and other federal agencies have not implemented the 1995 Federal Wildland Fire Management Policy, Congress should enact legislation directing the agency to do so, and immediately create fire management plans 'for every burnable' acre on the National Forests. Fuels reduction monies should be used for essential fire planning and preparedness to maximize the efficiency and effectiveness of fuels reduction.

Fire plans enable federal land managers to allow certain remote wildland areas to burn under carefully prescribed conditions in order to maximize ecological benefits while minimizing overall management costs, and preventing emergency firefighting expenditures. These fire plans should be collaborative, fully including the public and utilizing the best available science. Implementation of the Federal Fire Policy would encourage land managers to manage fires at a reasonable cost, while prioritizing firefighter safety and the protection of natural resources.

Discourage the Use of Commercial Timber Sales to Reduce the Risk of Fire
Congress should prohibit the use of commercial timber sales and stewardship contracts for hazardous fuels reduction projects. Commercial logging removes the most ecologically valuable, most fire-resistant trees, while leaving behind highly flammable small trees, brush, and logging debris. The use of "goods for services" stewardship contracts also encourages logging larger, more fire-resistant trees in order to make such projects attractive to timber purchasers. The results of such logging are to increase fire risks and fuel hazards, not to reduce them. The financial incentives for abusive logging under the guise of "thinning" must be eliminated.

Establish Separate Contracts for Fire Hazard Reduction Projects
All fuels reduction projects should be paid for with appropriated dollars. Any material of commercial value must be sold in a separate contract and all revenues must be returned to the Treasury. This would eliminate the current incentive to include larger, more valuable, fire-resistant trees in order to make timber sales a.k.a. "fuels reduction projects" more attractive to timber companies.

Increased Priority Needs to be Placed on Protecting Communities
Homeowners must be educated about their responsibilities associated with living in fire-prone environments, and the necessity to do their part to reduce wildfire risks. Jack Cohen, research scientist at the U.S. Forest Service's Fire Sciences Lab in Missoula, Montana, has demonstrated that to reduce fire risks in the urban/wildland interface zone, removing fuels from within 40 meters of a structure and reducing the flammability of the structures are more effective and efficient than landscape wide thinning.

According to Cohen, "The evidence suggests that wildland fuel reduction for reducing home losses may be inefficient and ineffective: inefficient because wildland fuel reduction for several hundred meters or more around homes is greater than necessary for reducing ignitions from flames; ineffective because it does not sufficiently reduce firebrand ignitions." Congress should encourage state and local governments to require homeowners living in the interface zone to protect their own private property through common-sense fire safety practices, such as the use of fire-resistant roofing material and the clearance of brush and other flammable materials near homes.

Conduct Ecological Assessments for all Fuel Reduction Projects
The Forest Service should be required to identify restoration priorities before any restoration or fuels reduction activities take place. This assessment should involve the public and provide a broad array of alternatives - not just commercial thinning - to address priority needs in the area. For many areas, removing roads, invasive species, and livestock combined with prescribed burning would the best prescription for ecological restoration.

Require that 90% of the Acres Treated Under the National Fire Plan be in the Wildland/Urban Interface Zone
For 2003, the BLM and Forest Service propose to target 1,191,886 acres in the wildland-urban interface for hazardous fuels treatment. Other hazardous fuels projects will target 1,678,871 acres outside the interface. This means that only 41% of the proposed hazardous fuels acreage is in the interface as broadly defined by the agency. In 2001, the agencies treated 2,284,983 including 774,242 in the interface (33%), and in 2002 the agencies expect to treat 2,470,766 acres with 771,302 in the interface (31%).

While the agency claims that a majority of fuel reduction dollars are being spent in the interface, in fact, most of the acreage being treated is outside of the interface zone. We urge Congress to require the agency to treat 90% of the targeted acres in the urban/wildlands interface zone.

Narrowly Redefine the Wildland/Urban Interface and Re-prioritize Communities at Risk
According the General Accounting Office, the Forest Service is spending fuel reduction funds in areas that are not prone to severe fires. "It is not possible to determine if the $796 million appropriated for hazardous fuels reduction is targeted to the communities and other areas at highest risk," said the GAO. In the wake of the GAO report, the Forest Service has conceded that at-risk communities were not consistently defined and that more work is needed to target areas truly at risk of wildfire.

The Forest Service is also using a very broad definition of the Wildland/Urban Interface which has been used to justify thinning projects miles from any community and in backcountry forest areas. According to Forest Service research by Dr. Jack Cohen, the emphasis should be placed on removing brush from the 200 feet around the home.

We urge Congress to require the Forest Service to re-prioritize communities and to use a narrower definition of the wildland urban interface zone to 200 feet around homes and a 1/8 mile defensible space around communities.

Prohibit Spending of National Fire Plan Funds Until Fire Management Plans (FMPs) Have Been Completed
These FMPs must fully comply with the federal Wildland fire policy, and must include the best available science and full public involvement in accordance with NEPA. Implementation of the Federal Fire Policy and FMPs offer the best hope for reducing unnecessary safety hazards to firefighters, costs to taxpayers, and suppression damages to ecosystems and resources. Until specific federal agency units have complied with the policy and approved FMPs, they should not be allocated National Fire Plan funds.

Prohibit Salvage Logging and Commercial Timber Sales for Fuels Reduction Projects
There is no scientific evidence that post-fire salvage logging reduces fire risks in the future and substantial evidence that salvage logging causes significant environmental harm. There is also growing evidence that allowing the Forest Service to conduct thinning and fuels reduction using timber sale contracts is leading to inappropriate and ineffective projects that do not accomplish fuels reduction. Commercial timber sales log the biggest, most valuable, fire resistant trees, which is counter to reducing fuel loads and often increases the risk of fire by leaving flammable logging slash behind. Controversial fuel reductions projects involving salvage logging and commercial logging are already generating public opposition, appeals and lawsuits.

Therefore, we urge Congress to steer the fuels reduction program into a less controversial and a more scientifically sound direction by prohibiting salvage logging and commercial logging under the National Fire Plan.

Reallocate Funding Within the Fire Preparedness Line Item
Money should be shifted from fire suppression equipment and supply purchases into fire management planning, firefighter training, community fire education, and fire science in order to build public understanding and program support for wildland fire use, prescribed fire, and homeowner fire protection activities. Using national fire plan funding, agencies have already hired thousands of new firefighters, purchased fleets of new suppression vehicles and equipment, and overstocked suppression supplies. Meanwhile, essential preparedness activities of planning, training, and education continue to be neglected. These traditionally underfunded and neglected activities would reduce firefighter and public hazards, reduce suppression costs, and reduce damages from emergency suppression operations.


For More Information Contact Timothy Ingalsbee, Ph.D., Director of the Western Fire Ecology Center for the American Lands Alliance at fire@efn.org or 541-302-6218