FRIENDLY FIRE: THE FEDERAL WILDFIRE POLICY REVIEW

by Timothy Ingalsbee, Ph.D.

With little fanfare and even less public input, the U.S. government has initiated the most sweeping review and revision of its fire management policies in history. The Federal Wildland Fire Management Policy and Program Review (for brevity, the ÒReviewÓ or the ÒReportÓ) was prompted by the deadly and disastrous 1994 fire season. Now, with a clear mandate for change coming from the informed public below and the Clinton Administration above, federal fire management policies are undergoing some dramatic changes. Public lands managers must now recognize the beneficial role of fire in healthy ecosystems and support fire reintroduction efforts. Additionally, every area of federal land containing burnable vegetation must have a new fire management plan that includes a full range of fire management actions including monitoring burns as Prescribed Natural Fires (PNF). These new fire management plans must include the public and agency partners---and here offers an exciting once-in-a-century opportunity to help shift federal land management agencies away from resource extraction towards ecological restoration with fire. This window of opportunity is relatively narrow, though, so it is urgent that environmentalists educate themselves on fire management issues and get involved in the Review process with utmost urgency.

Draft Report Draws a Backdraft

Based on the understanding that natural ecological processes like wildfire do not adhere to arbitrary management boundaries, nearly every federal agency having anything to do with wildland fires was involved: the USFS, USFWS, BLM, BIA, NPS, NBS, NOAA, FEMA, and the EPA. The main goal of the Review was to establish uniform policies across all federal lands in order to create a totally mobile federal firefighting force. The amount of government resources and personnel involved in the Review process, and the political repercussions likely to result from genuine reform of fire policies, should have led citizens to expect that the Review would be a widely-publicized affair strongly encouraging their participation. On the contrary, the Review was conducted almost like a covert operation with the barest amount of public involvement necessary to satisfy NEPA.

The timing of the Review process seemed almost deliberately calculated to avoid press attention and public input. The Review was first announced in the Federal Register on January 3, 1995 when many people were still recovering from their New Year’s hangovers. A quick 30 day scoping period garnered only a couple dozen comments from across the country, and most of these came from agency insiders. Then the ReviewÕs Draft Report was released on June 25th, with a minimal 30 day public comment period. A worse time of year could not have been picked for rational thought and informed discussion of fire policy reform. First, this was during the heat of fire season, when the public’s conditioned fear of forest fires tends to be highly aroused due to the normal newsmedia hype and hysteria about ÒcatastrophicÓ wildfires burning across the West. Fortunately, the press failed to pick up the story about the Wildfire Policy Review. Secondly, the ÒstakeholdersÓ with the most stakes in reforming fire management policies--firefighters--were off in the field chasing wildfires, and thus were unable to receive, read, or comment on the Draft Report.

Most environmentalists also failed to submit comments because the notorious Salvage Rider was signed into law just two days after the release of the Draft Report. If they had commented on it, they likely would have opposed the many progressive ecological reforms presented in the Report because the Salvage Rider effectively negated the benefits of reintroducing fire into wildlands. In effect, what the Left hand gave in the form of prescribed burning, the Right wing could chop off in the form of salvage logging. Thus, despite Clinton’s command for all federal agencies to “speak with one voice” on forest policies, this voice spoke with a forked tongue. Consequently, for better and worse, less than 90 people from across the country submitted letters critiquing the Draft Report at the close of the initial comment period.

CFEEP Says FACA You to the Review

Some stakeholders got their opinions across early and often, both before and after the release of the Draft Report. Although public interest and environmental advocacy groups were all but excluded from the Review process, members of the ÒInsurance Institute for Property Loss Reduction,” representing insurance corporations, held private meetings with the Review’s Steering Group. The Cascadia Fire Ecology Education Project (CFEEP) wrote a letter to the Steering Group protesting this unfair, unequal treatment of stakeholders, and pointed out that the private meetings with insurance representatives violated the Federal Advisory Committee Act (FACA) for open meetings among all sectors of the public. CFEEP requested an extension of the Draft comment period in order to gather more input from firefighters, fire ecologists, and environmentalists. Much to our surprise, the government completely reopened the comment period for an additional 45 days. With this extra time, over 300 comment letters were sent in---a big improvement, but far less than one would expect from a precedent-setting document with such a far-reaching, national scope.

“Final” Report: C+

The Final Review document was released on December 18, 1995, and again seemed calculated to avoid scrutiny by the press and public. Considering the media’s complicity in fomenting the current “forest health” hysteria, the Report’s many positive statements affirming the natural role of fire in maintaining healthy ecosystems should have raised some eyebrows, but didnÕt. Athough the New York Times and the Eugene Register-Guard ran front-page articles about the new fire policies, these were rare exceptions in what was mainly treated as a non-newsworthy event.

A point to be stressed, though, is that the “Final” Report does not represent a finalized plan at all, but rather, is an outline of an evolving and still unfolding process of policy change. Thus, there is plenty of opportunity for environmentalists to push the process further and argue for more progressive, ecologically-based reforms; conversely, there is opportunity for reactionaries to roll-back the process and return to the status quo. Some of the highlights of the Review’s Final Report are worth covering in some detail, along with some discussion about their broader implications for changing forest management policies. Most importantly, the Review process mandates that federal agencies include the public and a full range of ÒpartnersÓ in this unfolding process of policy reform. Thus, if you missed out in the earlier scoping or Draft comment periods, then you can more than make up for it by participating in upcoming fire management planning.

The Final Report’s Guiding Principles and Policy Proposals

The document is divided into into six main chapters: 1) Guiding Principles and Policies; 2) the Role of Wildland Fire in Resource Management; 3) Use of Wildland Fire; 4) Preparedness and Suppression; 5) Wildland/Urban Interface; and 6) Coordinated Program Management. Each chapter is further divided into three sections, the first being a discussion of the current ecological or political situation, the second section a list of recommended policy goals, and the final section of each chapter lists actual actions that federal agencies will do. Similar to the Final EIS for the Northwest Forest Plan, though, the Final Report for the Wildfire Policy Review exhibits a schizophrenic split between excellent scientific assessment of the current problematic situation, and tepid management goals and (in)actions offered to address those problems.

Safety First!, Earth Last?

There are nine new “Guiding Principles” for fire management. At the top of the list in bold-faced type is the statement that, “Firefighter and public safety is the first priority in every fire management activity.” This is a much overdue policy reform that greatly contrasts from the now-outdated Standard Firefighting Orders where safety is at the bottom of the list. A concern to be raised is the simple fact that “fighting” fire is an unnatural and inherently dangerous activity for human beings. It will be impossible to ever make firefighting completely safe for people; indeed, abstinence from firefighting is the only truly safe approach.

Possible negative implications of the new policy change is that in order to make firefighting safer for humans, agencies such as the Forest Service will likely make conditions more dangerous for trees and wildlife. Thus, firelines could be expected to be located further away from flame fronts, where trenches can be cut deeper and wider, whole areas can be cleared of all snags, and backfires can be lit at leisure. Throughout the West, timber sales are being presented as “fuel load reduction” or “fuelbreak construction” projects to prepare sites for “safe and efficient fire suppression.Ó Citizens should expect that Òfirefighter safetyÓ will soon become yet another excuse offered by the Forest Service for logging in forested wildlands. Environmentalists should oppose these projects not only because they are ecologically unsound, but also because they are unsafe. Logging slash mixed with young ÒreprodÓ is the most hazardous fuel type for firefighters, for it causes intense heat and rapid fire spread; indeed, firelines are never built in plantations. Environmentalists genuinely concerned about the safety of all species and the integrity of wild ecosystems should be wary of opportunistic timber managers attempting to use the new firefighter safety policies as justification for their bogus “fire protection” logging schemes.

Friendly Fire

Second on the list of Guiding Principles is the statement that, “The role of wildland fire as an essential ecological process and natural change agent will be incorporated into the [forest] planning process.” Furthermore,

“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.Ó

In the context of the agency’s longstanding pyro-phobia, these are truly remarkable statements! An important change in terminology symbolizes the government’s new openness to manage the land with fire: the old term “wildfire” is being replaced with the new generic term Òwildland fire.Ó Formerly, by definition and as a matter of policy, all wildfires had to be suppressed. Now, managers have the option either to suppress wildland fires or manage them as prescribed burns.

The new policies now permit both lightning and unplanned human-caused ignitions--even arson fires--to be managed as prescribed burns. Theoretically, this might reduce incentives for unscrupulous contract firefighters to commit arson in order to gain employment (a growing problem in the Pacific Northwest). However, another policy in the Report states that, “To the maximum extent possible” the government will use “the concept of closest initial attack forces...optimizing the use of Federal and non-Federal work force.” This policy makes sense only if the Forest Service’s knee-jerk suppression (and salvage) reactions are curtailed. On paper, at least, the new fire policies represent a radically new approach to managing forests with fire instead of against fire. It remains to be seen if and when these policies will be put into practice, especially since they challenge management policies oriented to serving private logging and firefighting interests.

Protection Priorities: Human Life, Private Property, and Natural Resources

Another set of policies worth highlighting are the new protection priorities. In order of priority, these are human life, property, and natural/cultural resources. Formerly, private property was valued over and above the natural environment or cultural resources in all cases. Now, fire managers must assess the relative values between property and natural/cultural resources, and factor in predicted suppression costs. This will hopefully prevent some of the incredible economic waste and environmental damage that has occurred when the Forest Service suppressed a wildfire in order to save a remote hunter’s cabin or miner’s shack from burning. The criteria to assess the relative values to be protected must now include (in order of presentation) “environmental, commodity, social, economic, political, public-health, and other values.Ó Factoring in non-commodity values into resource management decisions has continually defied the mental abilities of agency managers. The new fire policies now mandates that agencies include the public in helping to devise non-economic values worthy of protection.

Strategic Retreat from the Wildland/Urban Interface

Even more significant, the government has announced that it is getting out of the business of providing free structural fire protection in the wildland/urban interface. The new policy states that,

“Structural fire protection is the responsibility of Tribal, State, and local governments. Federal agencies may assist with exterior structural suppression activities under formal Fire Protection Agreements that specify the mutual responsibilities of the partners, including funding.Ó

Most of the 27 fatalities of the 1994 fire season, including those at Storm King Mountain, involved firefighters put at risk to save private property. In wildlands, firefighters can always sacrifice trees to the blaze in order to keep mobile and be safe. But in developed sites or suburban zones, firefighters are staged in front of fixed structures that cannot be so readily sacrificed. Now, unless your home is on wheels, you better think twice before building a home in fire-prone areas bordering public lands.

It will be amusing to see how the rural “Wise-Use” crowd reacts to the new federal policies for wildland/urban interface fires. Despite their frenzied pleas for government to “get off our backs,” Wise-Use ideologues have a basic hypocrisy to them: they want to eliminate all government regulations and any sense of public responsibilities, but they still want to keep all of their government-funded public subsidies (like deficit timber sales and below-market grazing fees) for their own private profit. The old federal policies offering free fire protection was a public subsidy for private homeowners and land developers who built in the “fire plain” of forests. Miraculously, the Federal government got this policy change past the Western GovernorÕs Association who were invited as ÒpartnersÓ in the Review process and is ideologically allied with the Wise Use movement.

Fire Management Planning: A New Public Process

Finally, the most exciting policy reform in the Final Report is the provision for new fire management plans. These have been called for ever since the Interagency Scientific Committee’s (ISC) Conservation Strategy for protection of the northern spotted owl. The ISC called for fire management planning in their system of HCAs, but what happened instead was timber sale planning, most prominently in the Warner Salvage Sale. The Northwest Forest Plan also calls for new fire management planning in the system of reserves; yet, such plans to date have been extremely brief and brutally simple: aggressive fire suppression in the RRs and LSRs. The Wildfire Policy Review hopefully will see that these new fire management plans are finally produced.

The language calling for new plans could not be more precise or forceful:

“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.Ó

A further elaboration of this policy was presented in a recently released document title the “Implementation Action Plan Report” (more on this below). In this document it is stated in italicized print for extra emphasis: “Individual field units are responsible for Fire Management Plan development. They must involve their fire management partners and the public.” Individual field units refer either to District Offices (USFS) or Resource Areas (BLM). Partners can either be formal or informal relationships; indeed, CFEEP was a volunteer partner in the Federal Wildfire Policy Review process, and a solicited partner in a separate review by the Western GovernorÕs Association. Interested persons can take the initiative in forming partnerships with agencies; regardless, any member of the general public everyone has the right (and responsibility) to get involved in developing new fire management plans.

Among battle-hardened environmentalists who have already invested enormous amounts of their volunteer time and energy in Forest planning processes only to be ignored by decisionmakers, the question naturally arises: why get involved in fire management planning? There are a number of good reasons. First of all, current fire management plans are grossly inadequate, leaving agencies extremely vulnerable to litigation for NEPA violations. While some Forest Plans address fire issues, most of them fail to properly analyze and disclose the direct, indirect, and cumulative environmental impacts of fire management policies including suppression practices. For example, in the five-inch thick Willamette National Forest Land and Resource Management Plan a mere five pages is devoted to discussion of fire management issues! Environmentalists can prevent a lot of resource damage by ensuring that a given Fire Management Action Plans places strict limits preventing the use of bulldozers and other heavy equipment in Roadless Areas and Reserves.

Secondly, as any experienced forest activist knows, the Forest Service has constructed a virtual fortress around its timber management policies. However, mere habit and a lot of hot air are the only things guarding the agency’s fire management policies. Until recently, the public had never seriously challenged the agency over its fire management policies, and the governmentÕs response was to conduct this sweeping interagency Review! By getting involved in the development of new fire management plans, and compelling the Forest Service and other federal agencies to implement the new fire policies, it may be possible to do an end-run around the normal defenses of the timber sale program and attack it from another angle.

To be clear, the main reason for environmentalists to push for as much public participation as possible is not solely for the sake of changing fire policies, but to change resource management policies. The new fire policies must be integrated into all resource and land management plans; conversely, all of these plans must conform to the new fire policies. Contradictions between current timber policies and proposed fire policies abound. For example, the Forest Service’s current justification for logging old-growth stands in Roadless Areas and Reserves is to protect these stands from fire; however, this rationale directly contradicts the new fire philosophy and policies. Environmentalists can help craft these fire management plans and force everything from ten-year Forest Plans to individual timber sale plans to comply with federal fire policies. Such an opportunity for change should not be passed up.

The Review’s Implementation (In)Action Report

The single most glaring ommission from the Final Report was any timetable for implementing the policy reforms. On May 23, 1996, the government issued the “Implementation Action Plan Report” which details how and when the proposed new policies will become officially established policies. The 83 separate proposals are divided up into three different categories of so-called Òaction itemsÓ: 1) those to be implemented immediately; 2) those that will require a long-term commitment, and cannot be accomplished without a prior commitment of budget and resources; and 3) those that depend on the interagency management review team. These categories are further divided into items for “partial” and “future” implementation. As can be clearly seen by even a cursory review of the document, despite its title it is long on planning but falls short on action. Indeed, the document is a bureaucrat’s ultimate fantasy that essentially sets up a plan for planning more plans. Still, the development of new fire management plans is at the top of the list for immediate implementation, and environmentalists should not delay in getting involved.

The best thing environmentalists have on their side is the knowledge that current (old) Forest Service fire policies are not supported by the Òbest science.Ó Land managers have both suppressed and repressed fire, resulting in a technocratic arrogance coupled with an institutional ignorance about the role of fire in native forest ecosystems. With minimal knowledge of general fire ecology principles, though, environmentalists can successfully counter the standard pyro-phobic propaganda spewed by the Forest Service and timber industry. Indeed, on the Warner Creek Fire Recovery Project, CFEEP confronted the Willamette Forest Supervisor with our own recovery plan. Dubbed “Alternative EF: Ecology of Fire,” it advocated the use of Prescribed Natural Fires to recover spotted owl habitat instead of the Supervisor’s proposed salvage clearcuts. It had the endorsement of some of the Pacific NorthwestÕs top forest ecologists who verified its scientific merits.

The Willamette Supervisor realized that he could not reject it from the project without appearing to act arbitrary and capricious, and therefore allowed it to be fully developed, analyzed, and published in the FEIS. Alternative EF was fundamentally a fire management plan that anticipated the new federal reforms. The agency could reject citizensÕs opinions about logging, but it could not reject CFEEPÕs ideas for managing fire---mainly because the agency had no credible plan of its own. We had to struggle to gain our role in fire management planning, now there is an open door invitation. Finally, Alternative EF not only helped to delegitimize the Supervisor’s resource extractionist “habitat recovery” plan, but helped galvanize citizen resistance to salvage logging by offering an inspiring alternative to our relationship with wildfire. Let CFEEP’s example be an inspiration to you: get in there, mix it up with agency fire managers, and get involved in this once-in-a-century opportunity to help develop ecologically-based, scientifically-sound fire management plans.

To receive the Federal Wildland Fire Management Policy and Program Review Final Report and Implementation Action Report, write the National Interagency Fire Center, ATTN: External Affairs Office, 3833 South Development Avenue, Boise, ID 83705-5354; or call (208) 387-5150, (208) 387-5457, or (208) 387-5585. DonÕt Delay, Do It Today!