|
An Introduction to the Fire Policy Reviews and Reforms of 2000 by Timothy Ingalsbee, Ph.D INTRODUCTION The fires of 2000 had a "millenial" effect on public consciousness about wildland fires and federal fire management policies. By most accounts it was the worst fire season of the past fifty years measured not in terms of acres burned, but in numbers of firefighters mobilized, amount of tax dollars spent on emergency suppression, and damages to private property and communities. In contrast to the news media's sensationalist portrayals of the wildfires as "catastrophes" causing a "crisis" among federal land management agencies, the federal government released a series of major reviews that proposed entirely rational and progressive reforms of federal wildland fire management policies. Some of these reviews started long before the flames began and others were completed long after the flames ended. On the whole, they represent a remarkable progressive change--almost on the level of a paradigm shift--of federal fire policies. In brief, most of the seven government documents discussed in this paper fully acknowledge the dire social, economic, and ecological consequences of fire exclusion policies predicated on systematic fire suppression, and offer rationale for restoring fire-adapted ecosystems by reducing hazardous fuel loads and reintroducing fire. Most of these documents emphasize the vital importance of fire management planning as the first essential step in implementing the new fire policies. Beginning with the 1995 Fire Policy, citizens have had unprecedented opportunities to engage in fire management planning which, under the new policy, must utilize the best available science and support fire reintroduction efforts. In most cases, citizens have not taken up this opportunity, in part because the Forest Service still believes that fire planning is an internal task not subject to NEPA or any other formal public process, and in part, conservationists are just now beginning to get involved in fire management issues in general. The following paper provides readers with a brief introduction to the recent fire policy-related documents, highlighting the central issue of fire management planning but also including other issues of importance for forest ecosystem protection, restoration, and conservation. By no means is this a comprehensive overview of these documents. For that, readers are strongly urged to analyze these documents for themselves. Conservationists and other concerned citizens need to become vocal advocates for full implementation of the Federal Wildland Fire Policy, and push the agencies to develop new Fire Management Plans that comply with the Fire Policy. Indeed, extensive quotes from the documents are provided in this paper because conservationists need to assume that, in general, forest managers and most agency employees will be largely ignorant of the contents including specific policies in these documents. For better or worse, it will be up to conservationists to educate the agency about its own policies. Thus, this paper is intended as educational resource and body of quotes for sending not only in "reactive" comment letters on fuels management projects, but also proactive letters urging completion of Fire Management Plans and implementation of the Federal Fire Policy.
In the wake of the disastrous 1994 fire season, the federal government embarked on the most sweeping interagency review and revision of its fire management policies in history. The Federal Wildland Fire Policy and Program Review (the "Fire Policy") involved nine different federal agencies: the USFS, USFWS, BLM, BIA, NPS, NBS, NOAA, FEMA, and the EPA. The development of the Fire Policy was prompted by the understanding that natural disturbance processes like wildland fire do not obey arbitrary anti-ecological management policies or political jurisdictional boundaries. The Fire Policy offered a key progressive premise: the best strategy for increasing firefighter and public safety, decreasing fire suppression costs and damages, and protecting ecosystems and communities from severe wildfire is to restore fire-adapted ecosystems that have been adversely altered by nearly a century of systematic fire suppression. The bottom line was that fire inclusion would compensate for past fire exclusion, and the Fire Policy gave agencies the tools needed to manage both prescribed and wildland fires in order to avoid the safety hazards, economic costs, and environmental impacts of aggressive fire suppression. In the first generation of USFS Forest Plans, fire management and fire ecology issues were underdeveloped or ignored. When fire issues were discussed at all, it was almost exclusively about firefighting or slash burning. Indeed, few, if any, current Forest Plans adequately comply with the National Environmental Policy Act (NEPA) on fire management issues, and the USFS has never subjected its fire suppression program to a programmatic NEPA analysis. Consequently, one of the Guiding Principles of the 1995 Fire Policy was "The role of wildland fire as an essential ecological process and natural change agent will be incorporated into the planning process." Further elaborating this point, "Fire, as a critical natural process, will be integrated into land and resource management plans and activities on a landscape scale...and will be used to protect, maintain, and enhance resources and, as nearly as possible, be allowed to function in its natural role." (emphasis added) This signified an intention to end the federal government’s longstanding demonization of all natural fires as "wildfires" which, by the old policy’s definition, could not be used for ecological benefits and had to be suppressed. One of the most progressive elements of the 1995 Fire Policy was its mandate to develop new Fire Management Plans (FMPs). The new policy stated that, "Every area with burnable vegetation must have an approved Fire Management Plan." The language committing the agency to action on FMPs could not be more precise or emphatic: "Federal agencies will develop Fire Management Plans for all areas subject to wildland fires. These plans will 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; and be linked closely to land and resource management plans." (emphasis added) The Fire Policy’s 1996 Implementation Action Plan Report clarified that, "Individual field units are responsible for Fire Management Plan development. They must involve their fire management partners and the public." (emphasis original) This offered an unprecedented opportunity for citizens to participate in fire planning. To further emphasize their importance, developing new FMPs was presented as the first Action Item (out of 83 total Action Items), and was listed under the heading, "Action Items to be Implemented Immediately." The federal government’s longstanding policy of suppressing all fires and excluding all citizens from fire planning seemed to have ended--on paper, at least.
Unfortunately, despite Secretary Babbitt and Glickman’s signatures on the Fire Policy that directed all agencies to implement the principles, policies, and recommendations in the 1995 Fire Policy, it languished from lack of implementation, especially by the USFS. To call attention to this apparent neglect of duty, a national interagency teleconference, "Managing Wildland Fires: From Policy to Implementation," was broadcast on April 8, 1998. Speakers from several federal and state agencies extolled the benefits and necessity of implementing the Fire Policy, and provided over two dozen messages emphasizing the critical importance of fire management planning with full public involvement.(see Appendix A: Fire Policy teleconference excerpts). For example, "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. Land and Resource Management Plans must give direction for wildland fire management. Plans must identify opportunities to use fire to achieve resource management objectives and analyze the potential impacts, both positive and negative of fire use or exclusion. All land, resource, and fire management planning must be done across agency boundaries and include early involvement of adjacent land managers...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) Unfortunately, for a variety of reasons such as lack of funds budgeted for fire planning and a lack of willpower to do it under the new fire use philosophy, USFS managers simply did not develop new FMPs or engage their employees or the public in implementing the Fire Policy. An FMP that complies with the Fire Policy gives managers a full range of options for appropriate management responses to wildland fires. These responses can vary from aerial monitoring to low-impact confinement to full-scale containment and control strategies--and all responses can be employed on different portions of the same fire. However, without an approved FMP, the only option available is aggressive initial attack and total suppression. Despite the Fire Policy’s mandates, forest managers have a perverse financial disincentive to do develop FMPs. Emergency fire suppression is operated as a deficit-funded program, with almost non-existent fiscal accountability or constraints at the Congressional or Administrative level. Proactive fire planning, prescribed burning, and wildland fire use operations, on the other hand, all must be funded by fixed appropriated budgets. Essentially, the agency’s budgetary system financially rewards reactive, unplanned, emergency fire suppression and penalizes proactive fire management planning. Born out of crisis situation in which 34 of the nation’s most elite firefighters were killed and suppression costs soared over $1 billion during the 1994 season, the 1995 Fire Policy was the most progressive reform of federal fire policies in history. Much like the preceding reforms of fire management policies that began in the early 1970s, this visionary policy reform meant nothing more than words on paper because, with but one exception, the agency was not committed to translating words into actions that affect on-the-ground fire management practices. The 2001 Review and Update of the Federal Fire Policy (see below) did note that, "When there was organizational will and commitment about an element of the 1995 Federal Fire Policy, that element was successfully implemented." The single and perhaps most important element of the 1995 Fire Policy that managers did choose to implement was the commitment to firefighter and public safety as the top priority on all wildland fire incidents. Firefighter deaths were dramatically reduced in the subsequent fire seasons, primarily due to widespread adoption of "indirect attack" strategies which often relied on extensive backfiring, an element partially accounting for increased acreage of severely burned land. Tragically, in attempting to make firefighting safer for people, opportunistic federal managers made forest ecosystems more hazardous for native vegetation and wildlife by using just one item from the Fire Policy to propose one commercial logging scheme after another, all under the guise of "fuels reduction/forest restoration for firefighter safety and efficiency." The rest of the Fire Policy and its mandate for genuine forest restoration through carefully planned fire reintroduction was systematically ignored. 2) POLICY IMPLICATIONS OF LARGE FIRE MANAGEMENT: A STRATEGIC ASSESSMENT OF FACTORS INFLUENCING COSTS Large-scale wildfires continued to burn throughout the U.S. with severe fire seasons in 1996, 1999, and 2000. During the 1999 season, the Forest Service spent $178 million--fully 30% of its annual suppression budget for the entire country--trying to suppress just two of the 93,702 total fires 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 California. These massive "siege-like" suppression operations failed to contain or control these fires until fall rain and snow storms put the fire out. The agency commissioned a team to investigate the factors that were driving up the costs of fire suppression in the 1990s, examining in-depth these two fire suppression incidents as case studies. The investigation revealed that none of the affected National Forests had completed required FMPs, and that if they had completed FMPs these would have made significant differences in the effectiveness and costs of the suppression efforts. An FMP that allowed wildland fire use in the wilderness and roadless areas might have prevented some of the more expensive and aggressive suppression actions that caused significant damage to these pristine areas. In response to this report, California Senator, Barbara Boxer, and other representatives requested the Forest Service to complete a fire management strategy for the wilderness areas on the Los Padres National Forest (scene of the Kirk Fire Complex). At the time of this writing (February 2001) the affected Forests have refused to do so. Instead of doing fire planning, the Shasta-Trinity National Forest has decided to prioritize fire salvage logging, planning a number of sales in the roadless areas containing old-growth, late-successional reserves, and critical habitat for endangered species. As case studies that were selected to represent the rest of the National Forest system, the "Policy Implications" report revealed 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." (emphasis added) In order to improve the fire management program nationally, the investigative team recommended, The team added that, "community involvement and education is important." However, the report also included a sober admission that, "The adequacy of recommendations is not the issue. The agency does not seem to have the will to make the necessary policy, funding, and organizational adjustments to ensure that fire management is positioned to be the effective, cost-efficient program it needs to be for the 21st Century." In response to the report, the Office of the Chief of the Forest Service issued a directive in March, 2000, requiring all National Forests to complete and approve new FMPs "for every burnable acre" by December, 2001. 3) AN AGENCY STRATEGY FOR FIRE MANAGEMENT Coinciding with the "Policy Implications" study was a report from the Forest Service’s National Management Review Team. The tone of the report, "An Agency Strategy for Fire Management," was generally alarmist. The report warned of dire consequences if the structure and organization of the agency’s fire management organization was not fundamentally changed. Addressing the issue of rising suppression costs, the report disclosed that, "Emergency funding for firefighting lacks the rigor, discipline, and incentives for more efficient decision-making. The Forest Service manages emergency firefighting funds as if they are unbudgeted, unlimited, unallocated, and without benchmarks on acceptable spending levels. This environment provides the appearance of no accountability." However, instead of critically examining the fiscal, organizational, and cultural factors that propel Forest Service managers to attack all wildland fires regardless of their size, source, location, predicted behavior or effects, the Review Team did not question the assumed necessity of systematic suppression. Nor did the Team address the issue of the lack of fire management planning which played a critical role in the agency’s fire management crisis. The Team dramatically proposed an end to the so-called "militia" approach that required all Forest Service employees to make themselves available for emergency firefighting duties. Instead, they proposed the creation of a "Large Incident Management Organization’ (LIMO). Operation of the LIMO would cost an estimated $40 to 50 million per year, and its purpose would be to manage extended attack suppression operations on large, "siege-like" wildland fires without the need to use local Forest managers or employees. The implications of the LIMO is that this would create a de facto separate standing army of firefighters that would move across the country from one wildland fire to another, with even less input from or accountability to local communities than already minimally exists. Because most fire suppression actions occur under a purported "state of emergency," forest/fire managers are able to ignore existing environmental laws and regulations, agency standards and guidelines, and interagency conservation strategies yet not be held legally or publicly accountable. The LIMO could potentially greatly intensify this problem, and ironically, further drive up suppression costs and environmental damages. The agency has not formally proposed the LIMO to Congress or the Bush Administration yet, but there are a number of factors that point to this possibility in the near future. First, the bulk of the money in the 2001 Appropriations that funded the National Fire Plan was slated to fund new suppression resources. Accordingly, federal agencies are hiring thousands of new temporary and permanent firefighters for the 2001 fire season, and intend to fill their fire caches with purchases of expensive new vehicles, tools and equipment. The LIMO could easily be the vehicle for a permanent increase in suppression funding, and may be especially attractive to the Bush Administration and members of Congress who have an apparent affinity for steering tax dollars towards the "military-industrial complex." Thus, despite the Fire Policy and a plethora of scientific studies that are extremely critical of fire exclusion, the "Agency Strategy" represents a retrograde move by top-level managers to continue the agency’s entrenched commitment to systematic fire suppression.
The 2000 fire season effectively began when the Cerro Grande Prescribed Fire was ignited on May 5th in Bandelier National Monument . The prescribed fire soon escaped control and spread from onto the Santa Fe National Forest. From there, the wildfire whipped up into a high-intensity blaze, eventually burned across 48,000 acres, and destroying hundreds of homes in Los Alamos, New Mexico and other communities. Under searing political pressure fomented by an hysterical newsmedia that focused strictly on who lit the fire, Interior Department Secretary Babbitt accepted full responsibility for the disaster on behalf of the National Park Service. However, the U.S. Forest Service was deeply implicated in the disaster, as well. The Forest Service fire dispatch office delayed for several hours a request by the Park Service for contingency fire personnel, and then essentially coerced the Park Service into prematurely declaring the prescribed fire as a "wildfire" before sending them additional firefighters. The Fire Investigation Report revealed several facts which radically contradicted the newsmedia stories. For example, the prescribed fire was not ignited during high winds or dry conditions at the site of the burn. Moreover, despite the delay in getting additional firefighters, the crews were able to successfully contain the "slopovers" of the prescribed burn at 30 acres total in size. However, because the burn had been declared a wildfire, the prescribed burn plan had been abandoned, and more aggressive tactics were utilized. This included lighting a backfire in an area with extremely hazardous fuels. The Investigation Team’s fire behavior analyst later determined that it was the backfire ignited at the bottom of the hill, not the slopovers at the top of the hill, that ultimately escaped the project area and spread into the town of Los Alamos and beyond. In terms of policy implications, the Investigation Team discovered that, "Federal agencies have not fully completed manuals, guidelines, and procedures to fully implement (Fire) Policy along interagency lines." Consequently, one of the report’s major conclusions and final recommendations was, "Agencies must follow all policies set forth in the Federal Wildland Fire Management Policy and Program Review if we are to expect to continue to use fire as a critically important management tool to restore natural conditions, maintain forest health, provide wildlife habitat, reduce hazardous fuel buildup, protect watersheds, and improve range condition." Based on the fire Investigation Team’s report, an Independent Review Board report concluded that, "The Federal Wildland Fire Management Policy and its components are valid and provide an effective framework for guidance into the future. All agencies must have a clear understanding of the policy and a consistent approach to implementation. Moreover, in regards to the importance of FMPs--the critical means of implementing the Fire Policy on the ground--the Review Board concluded that, "To effectively implement fire management policies and achieve resource management objectives, Fire Management Plans need to be prepared in a collaborative framework. This should include appropriate public involvement and review, commensurate with the significance of the decisions to be made." The Review Board recommended that to ensure consistent implementation of the Fire Policy, the original interagency group that developed the 1995 Policy should be reconvened and establish new deadlines for completion of the implementation strategies. Secretaries Babbitt and Glickman agreed, and a thorough review and revision of the 1995 Fire Policy ensued over the fall of 2000, completing the Review and Update of the Federal Wildland Fire Policy in February, 2001.
In August, 2000, at the peak of the fire season and a crisis atmosphere in the federal government, President Clinton asked Secretaries Babbitt and Glickman to prepare a report with recommendations on "how best to respond to this year’s fires, reduce the impacts of these wildland fires on rural communities, and ensure sufficient firefighting resources in the future." The report, which came to be known as "the National Fire Plan," provided a strategic framework and rationale for a massive, unprecedented increase in the wildland fire programs for the USDI and USDA. Congress ultimately approved a Fiscal Year 2001 budget of $2.8 billion for federal fire management programs, fully $1.6 billion above the Administration’s original 2001 budget request. The short-term goal of the National Fire Plan was to provide all the money needed to maintain firefighting resources, rehabilitate burned lands, and rebuild affected communities. Other more long-term goals were to fund landscape-level fuels treatments to reduce fire risks and restore landscapes adversely affected by past fire exclusion policies. Remarkably, in the face of blistering criticisms by the timber industry and their Congressional allies who were opportunistically using the wildfires to attack the Clinton Administration’s forest management policies, especially the proposed Roadless Area conservation Rule, the report repeatedly stated that the focus of fuels reduction work would be to reduce small-diameter trees and underbrush, not large-diameter commercial-grade trees. Indeed, the Fire Plan almost proudly declared that, "Notably, the Administration’s wildland fire policy does not rely on commercial logging or new road-building to reduce fire risks and can be implemented under its current forest and land management policies. The removal of large, merchantable trees from forests does not reduce fire risk and may, in fact, increase such risk…Targeting smaller trees and leaving both large trees and snags standing addresses the core of the fuels problem. A timely report by the non-partisan Congressional Research Service bolstered the Administration’s claims by disputing any connection between declining timber sales and increasing wildfire incidents. On the contrary, the CRS report disclosed some of the adverse effects of commercial logging that resulted in increased fire risks and fuel hazards. Additionally, to counter the propaganda waged by political opponents of the Administration’s proposed new roadless policy, the report stated that, "…all available evidence suggests that fire starts may be fewer in unroaded than in previously roaded forests. Fires are almost twice as likely to occur in roaded areas as they are in roadless areas." Moreover, the report disclosed that out of 89 million acres of National Forest lands that had been identified as having a moderate to high risk of catastrophic fire, less than 16% of these acres are located in inventoried roadless areas. Consequently, the report revealed that, "(T)he Forest Service would prioritize efforts to reduce fuels in areas that have already been roaded because these areas tend to be much closer to communities and have higher fire risks. Indeed, given current funding levels and the scope of the fuels issue, the Forest Service would do fuels reduction work for 15 years in roaded areas." Independent research by conservation organizations such as the Pacific Biodiversity Institute also confirmed that the majority of the fires burned on previously roaded and logged lands, and surprisingly, the majority of these burned acres were located on state and private lands, not federal lands. Finally, in line with the Federal Fire Policy and its underlying goal of increasing the pace and scale of fire reintroduction, the National Fire Plan extolled the virtues of fire: "The prudent use of fire, either alone or in combination with other means, can be one of the most effective means of reducing such hazardous fuels." The report even cited the example of a prescribed fire conducted by the National Park Service in Jewel Cave National Park that, by reducing the intensity and severity of the Jasper Fire, saved the Park’s visitor center and employee housing area from damage. Using this example, the report audaciously boasted that the 2000 fire season was providing some evidence that the controlled reintroduction of fire was beginning to bear fruit in terms of reducing the severity of wildfires, although it also noted that the Cerro Grande Fire, one of the biggest wildfire disasters of 2000, had began as a poorly planned and executed prescribed burn. POTENTIAL COMMERCIAL EXTRACTION ACTIVITIES UNDER THE NATIONAL FIRE PLAN The National Fire Plan strongly advocated wildland fire use, however, the Plan did not entirely rule out the use of commercial logging for fire hazard reduction. For example, it acknowledged the use of post-fire salvage logging, but took great pains to discredit the possibility of another "Salvage Rider:" Additionally, the Fire Plan calls for developing and expanding markets for small-diameter wood and other biomass that is removed for fire hazard reduction purposes. Finally, the Fire Plan calls for expanding the participation of local communities and collaborative processes to reduce fire hazards. Especially within the context of the Bush Administration, conservationists should be wary of statements endorsing salvage logging, biomass extraction, and vague "collaborative" processes given that these practices have usually privileged industry desires for commodity outputs above community protection and ecosystem restoration needs. In sum, the National Fire Plan was basically a special emergency supplemental funding request for the 2001 Appropriations Bill. It incorporated the Domenici Amendment, and federal agencies received $120 million for hazardous fuels reduction focused on the wildland/urban interface. The National Fire Plan also generated $608 million appropriated for the Forest Service and $315 million for the USDI fire preparedness budgets. Conservationists will have to closely monitor expenditures in both these programs to ensure that hazardous fuels reduction is not used as an excuse for proposing inappropriate timber sales, and that managers invest public funds in proactive fire planning, research, and education programs and projects rather than spend all the money on reactive emergency fire suppression forces. It will be up to conservationists to hold agency managers accountable to the progressive features of the National Fire Plan and the Federal Fire Policy, and demand adequate funding for the development of new FMPs--for every acre of federal land containing burnable vegetation--as required by the Fire Policy and the Chief’s directive. Additionally, conservationists should insist that the thousands of newly hired firefighters not simply be used to fight fires, but should be put to work doing low-impact, labor-intensive hazardous fuels reduction to facilitate fire reintroduction for ecosystem restoration. 6) PROTECTING PEOPLE AND SUSTAINING RESOURCES IN FIRE-ADAPTED ECOSYSTEMS: The Cohesive Strategy ("the Strategy") was intended to be the official Forest Service response to the 1999 General Accounting Office Report on "Western National Forests." That GAO Report had condemned the agency for its lack of a "cohesive strategy" for reducing threats of catastrophic wildfire across millions of acres of the interior West. When an early draft of the Strategy was inadvertently posted on the Forest Service’s web page, opponents of the Clinton Administration’s forest management policies howled in protest. Consequently, as a means of harassing the Clinton Administration, the Domenici amendment to the 2001 Appropriations bill required the Strategy to be published in the Federal Register 30 days after the Appropriations bill had passed. Thus, the Strategy assumed greater importance than perhaps was originally intended. The Strategy is an important document in that it provides the rationale for conducting hazardous fuels reduction and ecosystem restoration, and offers a framework for prioritizing that work. The Strategy is based on the premise that, "within fire-adapted ecosystems, fire-maintained forests and grasslands are inherently safer for firefighters and the public than ecosystems in which fire is excluded." Accordingly,"…within fire-adapted ecosystems, fire—at the right intensities, frequency, and season—is fundamentally essential for healthy, sustainable resources and the protection of nearby human communities." The Strategy thus represents yet another policy statement clearly signaling a philosophical shift away from fire exclusion towards greater fire inclusion, and active restoration of fire-adapted ecosystems.
The focus of the Strategy is on restoring ecosystems that evolved with frequent, low-intensity fires. This is predominantly in the interior West. The Strategy prioritizes hazardous reduction in the following areas: 1) Wildland/Urban Interface; 2) Readily accessible municipal watersheds; 3) Threatened and endangered species habitat; and 4) Maintenance of existing low-risk Condition Class I areas. The Wildland/Urban Interface (WUI) is simply defined as "those areas where flammable wildland fuels are adjacent to homes and communities." Pro-timber members of Congress seek an expansive definition and location of the WUI, presumably in order to maximize the acreage of commercial timber extraction and livestock grazing conducted in the name of "fire hazard reduction." However, the Strategy disclosed that, This narrow 200 foot band surrounding structures is almost always privately-owned, not public land. Thus, the Strategy noted that, "Efforts to reduce hazardous fuels on federal lands must be coupled with efforts to assist private landowners to take preventative action in their own communities. Creating defensible perimeters around homes, improving building codes, and employing fire resistant landscaping will help reduce fire risk to communities." Conservationists will have to assert Cohen’s research on home ignitability factors as the best available science--in accordance with the Fire Policy. Moreover, they must demand that hazard reduction activities be restricted to the WUI where it would be most effective, and avoid such activities in remote wildlands where it would be most inefficient. The odd phrase, "readily accessible municipal watersheds," is an implicit acknowledgement that hazard reduction activities for the sake of protecting communities should be prioritized in areas already roaded and nearest to communities, not in remote roadless wildlands. Indeed, the Strategy was developed at the same time the Roadless Area Conservation Rule was being finalized, and fully anticipated its outcome: "The first priority for restoration will be the millions of acres of already roaded and managed landscapes that are in close proximity to communities. Constructing roads in municipal watersheds in order to reduce fuel hazards or fight fires would be counterproductive, for erosion and siltation caused by wildfire effects is relatively short-term, lasting until ground cover is restored, while erosion and siltation caused by roads is long-term, essentially lasting the lifespan of the road. The priority of reducing fuels in Threatened, Sensitive, and Endangered (T,S,E) habitats is risky because most of the species on the ESA list are there because of habitat loss from urban, industrial, or agricultural developments and related intensive management activities. Any further imperilment of these species could function to curtail those economic activities. In several NEPA documents for timber sales or regional forest plan amendments, the agency has been making the argument that some T,S,E, species such as the California and Northern Spotted Owl populations are threatened more by "catastrophic wildfire" than by commercial logging, and this line of thinking underlies one of the loopholes written into the final Roadless Area Conservation Rule. However, T,S,E species’ habitats are threatened more by the effects of fire exclusion, and need fire disturbance to create diverse habitats and suitable structures as well as reduce natural fuel loads. Finally, while the Strategy focuses on "restoration" in the interior West, it seeks "maintenance" of the existing low hazard areas located predominantly in the southeastern U.S. The southeastern region never fully adopted fire exclusion policies, and has a long tradition of prescribed burning. Moreover, considering that there is a year-round growing season in some areas of the Southeast and flammable fuels can accumulate at a rapid rate, conditions could deteriorate in relatively short time if burning were to cease. However, conservationists in the Southeast argue that the Forest Service uses prescribed fire too much, and is essentially "over-burning" public lands at a frequency and scale that are unnatural and are causing adverse impacts. They charge that the agency is prescribed burning for primarily agricultural not ecological reasons, and is failing to do necessary pre-burn surveys or post-burn monitoring to discover what are the effects of frequent burning on soils, vegetation and wildlife.
The Strategy makes a strong case for fire reintroduction using both prescribed and wildland fire to reduce hazardous fuels. However, a caveat to this pro-fire orientation is that in Condition Class III areas of high fire risk, especially near WUI areas, the Strategy "advocates mechanical thinning of small trees, brush and shrubs" to reduce fire intensities and smoke during prescribed burning. Importantly, the Strategy stated that, "ecologically sensitive areas, such as old-growth and late successional forests, will be avoided," but did agree to "conduct fuel treatments designed to protect older, larger trees while reducing unnatural buildups of understory vegetation. " The Strategy also urges efforts to "develop markets and ideas for small-diameter material utilization." These statements imply the intention to avoid controversial logging of large-diameter overstory trees, and instead, prioritize understory "thinning" with non-commercial mechanical methods as pre-treatments for prescribed burning. Considering the Forest Service’s longstanding cultural and institutional bias towards commercial timber extraction, and knowing that so-called "forest health/fire hazard reduction" has been the prime rationale for timber sales for most of the 1990s, it is foreseeable that forest managers will try to implement the Strategy with as much commercial logging as they think they can get away with. In sum, the Cohesive Strategy marks a potential shift away from traditional intensive management towards more "extensive management," proposing to treat several millions of acres per year for hazardous fuels reduction and fire ecosystem restoration. The Strategy reflects progressive fire policy change; however, the agency has had good fire policies in place for several years, but without clear direction or means of oversight or accountability, individual managers have been relatively free to ignore them. Considering the fact that the Bush Administration and majority in Congress are heavily promoting the use of "mechanical treatments" (a.k.a. commercial logging) to address the wildfire issue, it will be a difficult struggle for conservationists to prevent these methods from being abused by opportunistic forest managers. Nevertheless, the Strategy offers conservationists a powerful tool for arguing against using mechanical logging treatments in roadless areas and old-growth stands, and arguing for greater fire reintroduction and an end to systematic fire exclusion.
By most accounts, the 2000 fire season was the most costly and severe season in the last 50 years. The national newsmedia, Congress, and the Administration focused on federal fire management policies and programs like never before. Prompted into action by the disastrous Cerro Grande Fire, Secretaries Babbitt and Glickman ordered a thorough review of policies and implementation status of the 1995 Federal Wildland Fire Management Policy. The Working Group for the Fire Policy review included 13 federal agencies from seven different departments and the non-federal National Association of State Foresters. The Review and Update of the 1995 Federal Wildland Fire Management Policy (2001 Fire Policy) benefited from the Forest Service policy reviews and initiatives discussed above. Given the media-orchestrated hysteria about the 2000 fire season, and subsequent political attacks against the Clinton Administration’s forest policies, there was plenty of pretense for a significant rollback of the progressive 1995 Fire Policy. However, amazingly, the Review reaffirmed, improved, expanded and extended the 1995 policies to include almost every federal agency that has any responsibility related to fire management. The fire policy review concluded that the 1995 Fire Policy "had no fundamental flaws," was "generally sound," and was "still appropriate;" nevertheless, agencies had failed to fully implement the policy and that "the great majority" of action items were not completed. Moreover, the Working Group discovered that, In particular, the Working Group noted the fact that most units failed to adopt FMPs that meet the requirements of the 1995 Fire Policy, and agency administrators had failed to minimize costs of suppression on large project fires. Fire management planning was highlighted as one of the most critical items needing to be implemented. Thus, many of the problems of the 2000 fire season was not because the 1995 Fire Policy was misguided, but rather, because the Policy was not being implemented. Consequently, in order not to continue this lack of oversight and accountability, the Working Group stated that, "…we strongly recommend the creation of an interagency, interdisciplinary mechanism at the senior level to ensure that fire policy is implemented effectively, efficiently, and in a timely manner throughout the federal government." The systemic lack of accountability for implementation explains why there has been virtually no change in fire exclusion practices despite the policy reforms of the last thirty years. To further drive home this point, they stated that, "The problem is not one of finding new solutions to an old problem, but of implementing known solutions. Deferred decision-making is as much a problem as the fires themselves…(W)e must take on these issues now. To do anything less is to guarantee another review process in the aftermath of future severe fires." In all likelihood, it will take sustained public pressure especially by the conservation community to ensure that the 2001 Fire Policy is fully implemented in a timely manner. FIRE MANAGEMENT PLANNING Much like the 1995 Review, the 2001 Review repeatedly emphasized the critical importance and essential role of fire management planning. Indeed, "(S)uccessful implementation of the 2001 Federal Fire Policy depends on the development and implementation of high-quality Fire Management Plans by all land managing agencies." Indeed, "Fire Management Plans that address all aspects of fire management activities remain the foundation for implementing the 2001 Federal Fire Policy and must be completed as promptly as possible." Therefore, reaffirming the 1995 policy, the 2001 Policy mandates agencies to "Complete, or update, Fire Management Plans for all areas with burnable vegetation." (emphasis added) Moreover, continuing as one of the Fire Policy’s Guiding Principles was the policy that, "Fire Management Plans and activities are based upon the best available science." The 2001 Update added extra policy items concerning the role of science and science programs in providing the foundation for land and fire management plans and activities. And to address what is known as the "disconnect" between agency managers and scientists, the Fire Policy stated that, "Managers must ensure that land and fire management plans and actions actively incorporate and apply the new information." The implications of FMPs for ecosystem protection and restoration are significant. For one thing, if managers are held accountable for utilizing the best available science, they will be hard pressed to make rational ecological arguments in favor of continued fire exclusion in fire-dependent ecosystems. This dilemma may offer the first real opportunity to constrain systematic fire suppression. Additionally, managers will have to address rather than ignore the ways that commercial logging, livestock grazing, and other intensive management activities adversely affect fire management. On the other hand, those managers who genuinely desire to reintroduce fire on a landscape-level will be empowered with the authority to use the best of recent scientific research to make their case to the public. Additionally, the scale of necessary fire planning—"all areas with burnable vegetation"—is potentially enormous. FMPs must tier to Land and Resource Management Plans; consequently, the Working Group understood that, "In some cases agencies may need to update, amend, or otherwise revise underlying land management plans. However, the existence of obsolete land management plans should not be the reason for failure to complete or update Fire Management Plans." A tool that conservationists will have in their favor is that FMPs must be collaborative, interagency efforts. The influence of pro-fire USDI agencies such as the National Park Service and U.S. Fish and Wildlife Service may help the Forest Service adopt more fire-friendly FMPs. Conservationists will have to supply the necessary public pressure, too, in order to help the Forest Service "rise up" to the level of USDI agencies rather than have the USDI agencies "sink down" to the Forest Service’s level of general anti-ecological, anti-fire attitudes.
One of the most remarkable outcomes of the Policy Review was the new policy concerning responses to wildland fires. The Cerro Grande Fire investigation revealed that the Forest Service fire dispatch office delayed sending the Park Service additional firefighters when requested because Forest Service staff believed that a prescribed fire on Park Service lands should be treated as a lower priority than a wildfire on Forest Service lands. The new Policy states unequivocally: "Base responses to wildland fires on approved Fire Management Plans and land management plans, regardless of ignition source or the location of the ignition." Further elaborating, "…the context or circumstances of the fire are to dictate the appropriate response, based on an approved FMP…Emphasis is on pre-planning by agencies to determine the appropriate management response to the occurrence of fire, regardless of ignition source or location." The clear intent of this policy change will be to prevent another disaster like the Cerro Grande Fire which, as a shameful example of interagency rivalry and lack of cooperation, completely contradicted the letter and spirit of the Federal Fire Policy. Perhaps an unintended but fortunate implication of this policy change will be to also undercut the economic incentive for private contract firefighters to ignite arson fires as a means of gaining employment opportunities. Incidents of firefighters starting arson fires dramatically increased in the 1990s; indeed, known arson fires accounted for about 25% of all human-caused ignitions. A major flaw of the 1995 Policy was that it mandated aggressive initial attack against all unwanted human-caused fires. This despicable criminal activity will hopefully decline once it becomes publicly known that there will no longer be a guaranteed automatic suppression response to human-caused fires.
The Policy Review declared that, "The scope of the fire hazard problem in the Wildland Urban Interface is more complex and extensive than envisioned in 1995," and the problem "will escalate as the Nation moves into the 21st century." The Review defined the WUI as "the line, area, or zone where structures and other human development meet or intermingle with undeveloped or vegetative fuels." This definition is more precise than any other policy document has offered, but as conservationists are wary of, is still is sufficiently vague in spatial terms to enable managers to use the issue of WUI hazard reduction to promote intensive management projects in a wide area. A significant new policy change concerns priorities for fire protection in the WUI: "The 1995 Federal Fire Policy does not distinguish between the concepts of property and the concept of community and community infrastructure…While property may simply represent isolated structures, communities and their associated infrastructure are the social and economic fabric that supports life in rural areas. However, the primary responsibility for protecting private property and rural communities lies with individual property owners and local governments." The 2001 Fire Policy was clarified to state that, following the protection of human life, suppression decisions will prioritize communities rather than private property. Moreover, the role of federal wildland fire agencies will be "protecting structures, but not suppressing fires in them." This policy change for the WUI may have the positive effect of getting rural communities to assume collective responsibility for reducing wildland fire risks and fuel hazards, since the federal government will not guarantee suppression of private homes. However, conservationists should be wary of forest managers exploiting the "community infrastructure" concept to include such things as powerlines, roads, reservoirs and similar things located far away from communities, and could potentially open up extensive areas of public wildlands to aggressive fuels reduction projects in the name of "WUI protection."
The Policy Review succinctly stated the central problem and challenge of federal fire management: "Fire exclusion efforts, combined with other land-use practices, have in many places dramatically altered fire regimes so that today’s fires tend to be larger and more severe…To address these changes and the challenge they present, we must first understand and accept the role of wildland fire, and adopt land management practices that integrate fire as an essential ecosystem process." New policies were adopted to emphasize the critical importance of education about fire ecology processes, and communication about the Fire Policy. Importantly, communication and education programs would target both "internal" audiences (agency managers and employees) and "external audiences" (the general public and non-federal organizations). Implementation of the 1995 Fire Policy was undermined, in large part, due to ignorance about the policy by federal employees and the public. Conservationists should develop their own programs of public education, and if need be, educate public servants in the resource agencies, about the Fire Policy and its ecological importance. Considering the fact that there is no oversight or accountability mechanism in place to ensure implementation of the 2001 Fire Policy, it must be assumed that only sustained public pressure led by the conservation community will ensure full and timely agency compliance. CONCLUSION There is considerable overlap among the above policy documents. For example, the Cohesive Strategy provides a strategic plan for hazardous fuels reduction in key areas (e.g. the WUI) on Forest Service lands; the National Fire Plan incorporates the Cohesive Strategy and provides a political rationale and funding framework for implementing wildland fire programs in both the USDI and USDA; and the 2001 Fire Policy provides a broad philosophical orientation and policy foundation for implementing the Cohesive Strategy and National Fire Plan, and extends the scope of fire management responsibilities to 13 different agencies in eight different departments. It cannot be overemphasized the need for conservationists to read the above documents and gain knowledge of their potential implications to further their work advocating for forest ecosystem protection, restoration, and conservation. However, if there is a single most essential document to understand and utilize in conservation advocacy, it would be the 2001 Fire Policy. As the most "global" of interagency forest management policies ever, the 2001 Fire Policy holds tremendous promise for shifting the focus of the Forest Service from traditional resource extraction towards authentic ecosystem restoration and protection. Because fire management plans and activities must be conducted collaboratively with the public and other federal, state, and local agencies, conservationists may be able to solicit the support of other affected agencies whose missions are less focused on commodity extraction, more oriented toward ecosystem protection. The mandate to use the best available science in fire management is also an empowering tool to use for conservationist goals. Forest managers cannot restrict their use of the "best science" to just those papers dealing narrowly with the issue of fuels reduction for firefighter safety and efficiency, for example. Rather, as many of the policy documents proclaim, the long-term strategy to improve firefighter and public safety is to restore disturbance resiliency and ecological sustainability of fire-adapted ecosystems through reintroducing fire. The vast majority of the best available science does not endorse fire exclusion or systematic fire suppression as the means of fostering those restorationist goals. Finally, the historical pattern of federal fire policy changes since the early 1970s has been to have a severe fire season provoke Congress into massive funding increases into federal fire agencies, followed shortly thereafter by major policy reviews and reforms, but then as fire activity has historically declined following those severe fire seasons, Congressional funding has decreased and the policies have languished on paper for want of implementation on the ground--until the next severe fire season that starts the cycle all over again. If the 2001 Fire Policy, National Fire Plan, and Cohesive Strategy for federal wildland fire programs are to escape that "boom and bust" cycle of crisis response and systemic neglect, it all depends on conservationists embracing the Fire Policy and becoming vocal advocates for its full and timely implementation at every level of every agency in the federal government. |