S. HRG. 114–337 

A REVIEW OF PAST WILDFIRE SEASONS TO 

INFORM AND IMPROVE FUTURE FEDERAL 

WILDLAND FIRE MANAGEMENT STRATEGIES 

HEARING 

BEFORE THE 

COMMITTEE ON 

ENERGY AND NATURAL RESOURCES 

UNITED STATES SENATE 

ONE HUNDRED FOURTEENTH CONGRESS 

FIRST SESSION 

NOVEMBER 17, 2015 

( 

Printed for the use of the 

Committee on Energy and Natural Resources 

Available via the World Wide Web: http://fdsys.gov 
A REVIEW OF PAST WILDFIRE SEASONS TO INFORM AND IMPROVE FUTURE 

FEDERAL WILDLAND FIRE MANAGEMENT STRATEGIES 
U.S. GOVERNMENT PUBLISHING OFFICE

WASHINGTON : 

For sale by the Superintendent of Documents, U.S. Government Publishing Office

Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800

Fax: (202) 512–2104 Mail: Stop IDCC, Washington, DC 20402–0001

98–946 2016

S. HRG. 114–337 

A REVIEW OF PAST WILDFIRE SEASONS TO 

INFORM AND IMPROVE FUTURE FEDERAL 

WILDLAND FIRE MANAGEMENT STRATEGIES 

HEARING 

BEFORE THE 

COMMITTEE ON 

ENERGY AND NATURAL RESOURCES 

UNITED STATES SENATE 

ONE HUNDRED FOURTEENTH CONGRESS 

FIRST SESSION 

NOVEMBER 17, 2015 

( 

Printed for the use of the 

Committee on Energy and Natural Resources 
(II) 

COMMITTEE ON ENERGY AND NATURAL RESOURCES 

LISA MURKOWSKI, Alaska, Chairman 

JOHN BARRASSO, Wyoming 

JAMES E. RISCH, Idaho 

MIKE LEE, Utah 

JEFF FLAKE, Arizona 

STEVE DAINES, Montana 

BILL CASSIDY, Louisiana 

CORY GARDNER, Colorado 

ROB PORTMAN, Ohio 

JOHN HOEVEN, North Dakota 

LAMAR ALEXANDER, Tennessee 

SHELLEY MOORE CAPITO, West Virginia 

MARIA CANTWELL, Washington 

RON WYDEN, Oregon 

BERNARD SANDERS, Vermont 

DEBBIE STABENOW, Michigan 

AL FRANKEN, Minnesota 

JOE MANCHIN III, West Virginia 

MARTIN HEINRICH, New Mexico 

MAZIE K. HIRONO, Hawaii 

ANGUS S. KING, JR., Maine 

ELIZABETH WARREN, Massachusetts 

KAREN K. BILLUPS, Staff Director 

PATRICK J. MCCORMICK III, Chief Counsel 

LUCY MURFITT, Senior Counsel and Natural Resources Policy Director 

ANGELA BECKER-DIPPMANN, Democratic Staff Director 

SAM E. FOWLER, Democratic Chief Counsel 

BRYAN PETIT, Democratic Senior Professional Staff Member 
(III) 

C O N T E N T S 

OPENING STATEMENTS 

Page 

Murkowski, Hon. Lisa, Chairman and a U.S. Senator from Alaska ................... 1 

Cantwell, Hon. Maria, Ranking Member and a U.S. Senator from Washington .................................................................................................................... 3 

WITNESSES 

Fennell, Anne-Marie, Director, Natural Resources and Environment, U.S. 

Government Accountability Office ...................................................................... 6 

Maisch, John ‘‘Chris’’, State Forester and Director, Division of Forestry, Alaska Department of Natural Resources ................................................................. 26 

Covington, Dr. William Wallace, Regents’ Professor of Forest Ecology and 

Director, Ecological Restoration Institute, Northern Arizona University ....... 43 

Zerkel, Richard, President, Lynden Air Cargo, LLC ............................................ 52 

Burnett, Mike, Fire Chief, Chelan County Fire District 1 ................................... 57 

Wyss, Jon, Chairman, Okanogan County Long Term Recovery Group .............. 64 

ALPHABETICAL LISTING AND APPENDIX MATERIAL SUBMITTED 

Burnett, Mike: 

Opening Statement ........................................................................................... 57 

Written Statement ............................................................................................ 59 

Responses to Questions for the Record ........................................................... 128 

(The) California Forest and Watershed Alliance: 

Statement for the Record ................................................................................. 278 

Cantwell, Hon. Maria: 

Opening Statement ........................................................................................... 3 

Chart 1–Wenatchee Complex in 2012 ............................................................. 87 

Chart 2–Behive Reservoir ................................................................................ 89 

Chart 3–Fire Treated Road .............................................................................. 91 

(The) Corps Network: 

Letter for the Record ........................................................................................ 283 

Covington, Dr. William Wallace: 

Opening Statement ........................................................................................... 43 

Written Testimony ............................................................................................ 45 

Responses to Questions for the Record ........................................................... 119 

Fennell, Anne-Marie: 

Opening Statement ........................................................................................... 6 

Written Testimony ............................................................................................ 8 

Responses to Questions for the Record ........................................................... 114 

GAO–13–684 Wildland Fire Management: Improvements Needed in Information, Collaboration, and Planning to Enhance Federal Fire Aviation 

Program Success dated August 2013 .......................................................... 144 

GAO–15–772 Wildland Fire Management: Agencies Have Made Several 

Key Changes but Could Benefit From More Information About Effectiveness dated September 2015 ................................................................... 199 

Maisch, John ‘‘Chris’’: 

Opening Statement ........................................................................................... 26 

Written Testimony ............................................................................................ 28 

Murkowski, Hon. Lisa: 

Opening Statement ........................................................................................... 1 

Wyss, Jon: 

Opening Statement ........................................................................................... 64 

Written Testimony ............................................................................................ 67 
Page

IV 

Wyss, Jon—Continued 

Responses to Questions for the Record ........................................................... 129 

Zerkel, Richard: 

Opening Statement ........................................................................................... 52 

Written Testimony ............................................................................................ 54 
(1) 

A REVIEW OF PAST WILDFIRE SEASONS TO 

INFORM AND IMPROVE FUTURE FEDERAL 

WILDLAND FIRE MANAGEMENT STRATEGIES 

TUESDAY, NOVEMBER 17, 2015 

U.S. SENATE, 

COMMITTEE ON ENERGY AND NATURAL RESOURCES, 

Washington, DC. 

The Committee met, pursuant to notice, at 10:01 a.m. in Room 

SD–366, Dirksen Senate Office Building, Hon. Lisa Murkowski, 

Chairman of the Committee, presiding. 

OPENING STATEMENT OF HON. LISA MURKOWSKI, 

U.S. SENATOR FROM ALASKA 

The CHAIRMAN. I call to order the meeting of Energy and Natural 

Resources Committee. 

Before we commence with the hearing, I think it is appropriate, 

and I know that on the floor of the Senate at this appointed hour, 

ten o’clock, a 1-minute moment of silence is being observed for 

those that were the victims of the horrible tragedy in Paris. So at 

this moment I would like to observe a 1-minute moment of silence. 

[Moment of silence.] 

The CHAIRMAN. Thank you. 

This is a pretty somber way to begin, and it is also a very somber 

subject this morning as we talk about the 2015 fire season. It was 

a tragic one. It was punctuated by some fatalities. We lost residents who could not escape the flames and the brave firefighters 

who gave their lives to keep our communities safe. 

The Okanogan Complex fire in Washington claimed the lives of 

three heroes, Thomas Zbyszewski, Andrew Zajac and Richard 

Wheeler. I want to start by acknowledging them and offering prayers to their families. 

Each year the wildfire season seems to include new worsts and 

historical records. For its part 2015 has been marked by a relentless wildfire season that has stretched nearly all year. According to 

the National Interagency Fire Center more than 9.4 million acres 

have burned through October 30. This year’s season is among the 

most devastating years for wildfires since reliable records began in 

1960, coming close to 2006 when an all time high of nearly 9.9 million acres burned. 

Mega fires, which are the fires over 100,000 acres in size and incomprehensible just decades ago, are becoming the new norm. Five 

mega fires were burning at the same time in September alone. 
2 

The majority of our nation’s fires continue to occur in my State 

of Alaska, and this year was no exception. We had over five million 

acres burned in Alaska. This is an area the size of the State of 

Connecticut. Only the 2004 fire season, where nearly 6.6 million 

acres burned, was worse for us. 

This year the fire season in Alaska was also unique and not in 

a good way. We did not have much snow over the winter and the 

spring featured record warm temperatures creating some unusually 

dry conditions and then came the lightning. On one day alone, near 

the summer solstice, lightning struck our state around 15,000 

times, so over 15,000 strikes in one day. Ultimately lightning 

caused more than half of the more than 700 fires in Alaska this 

season. 

At one point this summer more than 200 fires were burning in 

the state, all over the state and all at once. Numerous Native Alaskan villages were evacuated because of fires that threatened air 

quality and structures. The thick smoke in Fairbanks pushed air 

quality to hazardous levels, forcing outdoor activities to be canceled. Dozens of homes north and south of Anchorage were lost. 

Anchorage spent 24 days at preparedness level five. You all on the 

panel here clearly know what level five is, but for those who are 

unfamiliar, it is the highest level. These wildfires drained budgets 

and required so much manpower to battle that officials enlisted the 

help of international crews at times. 

Unfortunately there is no easy solution. We cannot simply match 

the increasing wildfire threat with greater and greater suppression 

force and call it a day. Wildfire suppression and its escalating costs 

are economically, ecologically, and socially unsustainable, and the 

2015 fire season underscores that point. 

We must recognize that many of the same factors that are increasing the size, frequency and intensity of wildfires are also driving up wildfire suppression costs both in actual dollars and as a 

portion of the Forest Service total budget. These factors include excessive fuel loads, due in part to decades of fire exclusion, a changing climate, insect and disease infestation, severe drought, the 

spread of invasive species and expanding wildland urban interface. 

But that is not all. Operational factors associated with wildfire 

management, our objectives, strategies and tactics, all have significant cost implications. This includes the aviation assets that we deploy today. 

We spent $2.1 billion fighting fires this season and $4.2 billion 

in total on wildfire management. It is not even clear where these 

dollars were spent and whether they were well spent. That is due, 

in part, to the fact that the agencies do not bother to conduct reviews of the large, expensive fires. 

The Forest Service has claimed that the wildfire problem is a 

budget problem, but that is probably an oversimplification. We all 

agree that Congress must end the practice of fire borrowing, but 

we just cannot throw money at the problem. 

In the Interior Appropriations bill that I chair the Subcommittee 

on, we provide a fiscally responsible approach to end fire borrowing. It would budget for 100 percent of the 10-year average for 

fire suppression and provide a limited emergency reserve, or contingency fund, for fire fighting in the above average years. I think 
3 

that is part of the solution, but the wildfire problem is not just a 

budgeting problem. It is also a management problem, and we have 

failed to appropriately manage our fire dependent forests and fire 

prone landscapes and that has predisposed our forests to mega 

fires. 

We must work with our state agencies, our local communities 

and the public to increase community preparedness and make our 

forests healthy again. Healthy, resilient forests are fire resistant 

forests. Yet, despite knowing the value of fuel reduction treatments 

in mitigating wildfire risks, increasing fire fighter safety and restoring the health of our forests, active management is still often 

met with a series of discouraging and near insurmountable obstacles. High upfront costs, long planning horizons and regulatory environment requirements, including what seem like unending environmental reviews, are impeding our ability to implement treatments at the pace and the scale these wildfires are occurring. 

These are big problems that will take cooperation and commitment to solve. Senator Cantwell and I have agreed to work together and with members of this Committee to develop a better 

wildfire management strategy for our country. I think it is fair to 

say that Senator Cantwell and I share the view that this is strategy that should be guided by some principles. 

The principles include responsibly funding wildfire suppression, 

ending the unsustainable practice of fire borrowing, improving 

operational efficiencies to ensure the availability and effectiveness 

of the aviation fleet and fire fighter safety, increasing community 

preparedness through Fire Wise activities and implementing community wildfire protection plans, making the necessary investments in a full array of fuel treatments to include not just prescribed fire but also mechanical thinning, increasing the use of 

technology on wildfires and reducing paperwork to get needed 

projects implemented in a timely manner. 

We know this type of strategy is necessary because we have just 

endured another terrible fire season that has affected many of our 

home states, many of the people that we know and many of the 

lands and the landscapes that we treasure. 

So this is not just any Tuesday morning here at the Energy Committee. This cannot be a review without a purpose where we turn 

the page, close the book and consider our responsibility is met for 

another year. We have a lot of work to do, and we need to work 

together to develop real solutions to the wildfire problem. 

With that, I turn to Senator Cantwell. 

STATEMENT OF HON. MARIA CANTWELL, 

U.S. SENATOR FROM WASHINGTON 

Senator CANTWELL. Well thank you, Madam Chairman, and 

thank you for holding this important hearing. Thank you for the 

witnesses coming today. We look forward to hearing from all of 

you. 

I also want to thank the Chair for allowing us to do a field hearing last August in Seattle, Washington that our colleague, Senator 

Barrasso, came out for. We certainly appreciate both the field hearing and him joining us for that. 
4 

We learned many things from the hearings that we have had so 

far, and we are going to learn more today. We have learned there 

are actions that agencies can take and that communities can take 

to decrease the risk of forest fires. We learned about the benefits 

of creating surge capacity to respond in these cases when we do 

have extreme events. But what has stood out most for me, from one 

of the witnesses that we had in Seattle, Dr. Medler from Western 

Washington University, was that he explained we have not seen 

the worst yet. This is something that requires immediate action. 

I want to thank Jon Wyss and Chief Burnett for being here today 

from the State of Washington. These are two people who are intimately familiar with these issues surrounding wildfires, particularly given our experience over the past two summers. 

In 2014 our state experienced the Carlton Complex, the worst 

fire in our state history. So earlier this year when the Committee 

began work on fire and discussing what we learned from that tragedy, we were scheduling listening sessions all across the State of 

Washington about what the Federal Government could do better 

and what we could do to help local communities. What we did not 

realize at the time that we had scheduled those meetings is that 

2015 was going to be an even more dramatic fire season. 

Almost one million acres in my state burned in about a month. 

That is an area the size of Delaware. So in addition to severe economic loss to the timber industry, the recreational economy, tribes, 

and the fire fighters in Washington State, who suffered a tragic 

loss, these impacts are unbelievable. 

I want to say that the three Forest Service fire fighters that were 

killed in the line of duty while protecting the communities in which 

they live were the best among us, Andrew Zajac, Richard Wheeler 

and Tom Zbyszewski. A fourth fire fighter, Daniel Lyon, was severely burned in the entrapment and has been going through recovery. Clearly 2015 was a tragedy. 

As I have traveled across the state looking at various issues I 

heard compelling stories from fire fighters, business owners and 

residents who lost their homes or had to evacuate that what we 

needed to do was to do better. Fire fighters, county commissioners, 

Forest Service people, legislators, all came forward with issues 

about coordination, response, making sure that fewer homes 

burned, making sure our fire fighters are safer, and proactively decreasing the intensity of these fires so that they can be better managed. I know that the colleagues that are present here today have 

experienced similar fire seasons in their states, as Chairman Murkowski just mentioned. 

Unfortunately, there are only so many spots available on the witness table, or I am sure that every one of us could have filled the 

whole table with people from our state who are stakeholders in this 

discussion. So before we begin I would just like to recognize a couple people who are not at the table. 

From Aero-Flite, Mike, if he is here he can wave his hand, a company that is in Spokane, Washington. The air tanker fleet is very 

important to how we fight fires and continuing to improve that 

service with the Forest Service giving contracts, I think is very important. 
5 

I want to recognize Brian Gunn from the Colville Tribe, who is 

also here. This summer wildfires spread into the reservation and 

destroyed 20 percent of their timber. A quarter of the tribe’s economy is generated from timber, so to say that this was a big deal 

is an understatement. They lost upwards of $1 billion of standing 

timber. 

This hearing is the third in our Committee that we have had so 

far since the wildfires of 2015. I am pretty sure that makes a 

record for the Committee. I think it shows that we are serious 

about getting something done, and I want to thank Senator Murkowski for outlining some of the things that she and I believe that 

should be in a bill. Ending the practice of fire borrowing so that 

we actually do more in prevention and preparedness up front, improving the efficiencies of our operation, ensuring that the fire 

fighters have the best equipment and those in communities that 

are challenged by how broad the map has become have every resource available to them, increasing community preparedness 

through activities such as Fire Wise and risk mapping, and investing in fuel treatments that we know will make a difference such 

as prescribed burn or mechanical thinning. 

Dr. Covington, I cannot wait to hear from you today about this 

issue particularly because I am very interested and will show some 

maps about thinning success in Washington State and where it 

mattered in prevention. But also just this overlay as it relates to 

where our fires are with ponderosa pine. I really want to understand how we are going to protect our forests. 

Increasing our use of technology and including unmanned aerial 

vehicles to give us more information, and for us in the central part 

of the state, it is clear we need a new Doppler system to talk about 

high wind incidents which we certainly experienced the day that 

our fire fighters lost their lives. 

All these are very, very important issues, and I am pleased to be 

working with the Chair on this. We have also had many conversations with our colleague, Cathy McMorris-Rodgers in the House of 

Representatives, since her legislative district has been front and 

center in all of this. 

I also want to just say that I know that while we have put out 

a white paper that we discussed in Seattle at our hearing, that 

there are many inputs that we have received along with what we 

are going to hear today. 

I hope, Madam Chairman, that all of us on this Committee of 

Western States can work together, because I think we see that 

those who are represented here today understand that we do not 

want to face the 2016 fire season without better tools, without better processes, without better operations to help our communities 

and help our states. 

Thank you very much. 

The CHAIRMAN. Well said. Thank you, Senator Cantwell. 

With that we will go to the panel before us. Again we appreciate 

you coming to the Committee this morning and giving us your perspective. 

The Committee will be led off this morning by Anne-Marie 

Fennell, who is the Director for the Natural Resources and Envi-
6 

ronment Team at the U.S. Government Accountability Office. We 

appreciate you being here. 

Next we have Mr. Chris Maisch. Chris is the State Forester and 

Director for the Division of Forestry with the State of Alaska, very 

skilled and very much an expert in so many of these issues. So we 

appreciate you traveling to be with us this morning. 

Next we have Dr. William Wallace Covington, who is the Regents’ Professor of Forest Ecology, the Executive Director for the 

Ecological Restoration Institute at Northern Arizona University. 

Thank you for being before the Committee this morning. 

Next we have another Alaskan, who will speak to us from the air 

tankers perspective and how we deal with these suppression efforts 

from the air, Mr. Richard Zerkel, who is President of Lynden Air 

Cargo. Thank you for being here this morning. 

We also have Mr. Mike Burnett, who is the Fire Chief from the 

Chelan County Fire. 

Rounding out the panel we have Mr. Jon Wyss, who is the Chairman of the Okanogan and Carlton Complex Long Term Recovery. 

We have a lot of expertise here this morning before the Committee, and we thank you for being with us. 

Ms. Fennell, if you would like to lead off? Please keep your oral 

testimony to five minutes and your full testimony will be incorporated as part of the record. 

STATEMENT OF ANNE-MARIE FENNELL, DIRECTOR, NATURAL 

RESOURCES AND ENVIRONMENT, U.S. GOVERNMENT ACCOUNTABILITY OFFICE 

Ms. FENNELL. Chairman Murkowski, Ranking Member Cantwell 

and members of the Committee, I’m pleased to be here today to discuss our recent work on wildland fires. 

Wildland fires play an important ecological role but cost billions 

each year and result in damage and loss of life. As you know the 

2015 fire season has been especially severe with over nine million 

acres burned. 

The Forest Service and Interior are responsible for wildland fire 

management on Federal lands including contracting for aircraft to 

help suppress fires. Increased fire intensity has prompted agency 

efforts to try to better manage fires. Understanding the effectiveness of these efforts takes on a heightened importance since these 

agencies have obligated $8.3 million over 6 years to suppress fires. 

My statement today focuses on one, how the Forest Service and 

Interior assess the effectiveness of their wildland fire management 

programs, and two, the Forest Service efforts to modernize the 

large air tanker fleet and challenges in doing so. My testimony is 

based on reports we issued in September 2015 and August 2013. 

First, Forest Service and Interior assess the effectiveness of their 

wildland programs in several ways including through performance 

measures, efforts to assess particular activities and reviews of fires. 

In our September report we found that the Forest Service and Interior acknowledged their performance measures needed improvement and were developing new ones. In addition the agencies are 

undertaking efforts to assess activities to reduce hazardous vegetation that can fuel fires. 
7 

However, the Forest Service and Interior have not consistently 

followed agency policy in selecting and reviewing the fires to determine agency effectiveness in responding to fires. Their policies generally direct them to review each fire involving Federal expenditures of $10 million or more. Agency officials told us that these 

policies over emphasize cost rather than effectiveness in responding 

to fires. 

The agencies, though, have not developed specific criteria for selecting fires. For example, Forest Service officials told us that they 

judgmentally select fires based on such broad criteria as national 

significance. Accordingly, the Forest Service reviewed five fires that 

occurred in 2012 and ten that occurred in 2013. But given its broad 

criteria it’s not clear why the Forest Service selected these fires 

and not others such as the 2013 Rim Fire which burned more than 

250,000 acres and was the costliest fire to suppress that year. 

We concluded that by developing criteria for selecting and reviewing fires the agencies may obtain useful information about effectively responding to fires. As a result we recommended in our 

September report that the Forest Service and Interior develop specific criteria for selecting and reviewing fires and update their policies accordingly. The agencies generally agreed. 

Second, in our 2013 report we found that the Forest Service 

faced challenges in modernizing its fleet of large air tankers which 

declined from 44 in 2002 to eight in 2013. Specifically we found 

that the Forest planned to modernize its fleet by obtaining aircraft 

from various sources over the near, medium and long term but 

each component of this approach faced challenges. Some of these 

challenges persist while others are less relevant today. 

For example, the Forest Service had awarded contracts for seven 

next generation large air tankers but as of 2013 only one had completed necessary Federal approval and certification processes. 

Agency officials told us that they now have 20 privately-owned, 

large air tankers under contract and another seven air tankers 

transferring from the Coast Guard. 

In conclusion, the increasing severity and cost of wildland fires 

highlights the importance of Federal agencies continuously and 

systematically assessing the effectiveness of their approaches so as 

to identify possible improvements in combating wildland fires in an 

ever changing landscape. 

Chairman Murkowski, Ranking Member Cantwell and members 

of the Committee, this concludes my prepared statement. I’m 

happy to respond to questions. 

[The prepared statement of Ms. Fennell follows:] 
8 

For Release on Delivery 

Expected at 10:00 a.m. ET 

Tuesday, November 17, 2015 

GA0-16-217T 

United States Government Accountability Office 

Testimony 

Before the Committee on Energy and 

Natural Resources, U.S. Senate 

WILDLAND FIRE 

MANAGEMENT 

Agencies' Efforts to 

Assess Program 

Effectiveness and 

Modernize the Firefighting 

Aviation Fleet 

Statement of Anne-Marie Fennell, Director 

Natural Resources and Environment 
9 

WILDLAND FIRE MANAGEMENT 

Agencies' Efforts to Assess Program Effectiveness 

and Modernize the Firefighting Aviation Fleet 

What GAO Found 

As GAO found in its September 2015 report, the Department of Agriculture's 

Forest Service and the Department of the Interior assess the effectiveness of 

their wildland fire management programs in several ways, including through 

performance measures, evaluations of particular activities, and reviews of 

specific wildland fires. Forest Service and Interior officials told GAO their 

performance measures need to be improved and that they are working to do so. 

For example, in fiscal year 2014, the Forest Service began developing a 

performance measure intended to reflect that, in some cases, allowing 

natura!ly~ignited fires to burn can provide natural resource benefits at a lower 

cost and lower risk to personnel than fully suppressing the fire as quickly as 

possible. Officials told GAO they plan to finalize the measure and use it in 2017. 

In addition. Forest Service and Interior have undertaken efforts to evaluate 

particular wildland fire management activities, such as efforts to reduce 

potentially hazardous vegetation that can fuel fires, known as fuel reduction, and 

assess the periormance offirefighting aircraft. However, GAO's 2015 report 

found that the Forest Service and Interior conducted reviews to assess their 

effectiveness in responding to wildland fire, but did not consistently follow agency 

policy which generally directs them to review each fire involving federal 

expenditures of $10 million or more. Forest Service and Interior officials told GAO 

that this policy overly emphasized the cost of wildland fire suppression rather 

than the effectiveness of their response to fires. However, the Forest Service and 

Interior have not established specific criteria for selecting fires for review and 

conducting the reviews. For example Forest Service officials told GAO the 

agency judgmentally selects incidents to review based on broad criteria such as 

complexity and national significance. By developing specific criteria, GAO 

concluded that the agencies may enhance their ability to help ensure that their 

fire reviews provide useful information about the effectiveness of their wildland 

fire activities. 

In its August 2013 report, GAO found that the Forest Service faced challenges in 

modernizing the government's fleet of large airtankers-which had declined from 

44 in 2002 to 8 in 2013-but since that report the agency has increased the 

availability of such aircraft GAO found in 2013 that the Forest Service, which is 

responsible for contracting for large airtankers, planned to modernize the fleet by 

obtaining large airtankers from various sources over the near, medium, and long 

term, but that each component of that approach faced challenges, making the 

continued availability of such aircraft to meet fire suppression needs uncertain. 

For example, for the medium term, the Forest Service had awarded contracts for 

seven "next~generation" large airtankers, but as of August 2013 only one had 

completed necessary federal approval and certification processes. Since that 

report, Forest Service officials told GAO that the agency has increased the 

availability of large airtankers. Specifically, as of November 2015, the agency had 

contracted for 20 privately~owned large airtankers, and another 7 large airtankers 

are to be transferred to Forest Service ownership from the Coast Guard. 

-------------United States Government Accountability Office 
10 

Chairman Murkowski, Ranking Member Cantwell, and Members of the 

Committee: 

I am pleased to be here today to discuss our recent work on federal 

wildland fire management. As you know, wildland fires have resulted in 

tragic loss of life and damage to homes, infrastructure, and important 

cultural and natural resources. The 2015 fire season has been especially 

severe, with over 9 million acres burned to date-well over the annual 

average of about 6.5 million acres burned during each of the last 10 

years. However, wildland fire also plays an important ecological role in 

maintaining healthy ecosystems, with many ecosystems being adapted to 

or dependent upon fire. Balancing the need to suppress unwanted 

wildland fires to protect people and resources with the need to recognize 

fire's natural role on the landscape is a complex task, particularly given 

the current condition of the nation's landscape, increased development in 

and around wildlands (an area often called the wildland-urban interface), 

and the future outlook for wildland fires. For example, changing climate 

conditions, including drier conditions in certain parts of the country, have 

increased the length and severity of wildfire seasons, according to many 

scientists and researchers; in the western United States, the average 

number of days in the fire season has increased from approximately 200 

in 1980 to approximately 300 in 2013. 1 

Five federal land management agencies-the Forest Service within the 

Department of Agriculture and the Bureau of Indian Affairs, Bureau of 

Land Management, Fish and Wildlife Service, and National Park Service 

within the Department of the Interior-are responsible for managing 

wildland fires on federal lands. The agencies' wildland fire management 

program has three primary components: preparedness, suppression, and 

fuel reduction-' To prepare for a wildland fire season, the agencies 

acquire firefighting assets-including firefighters, fire engines, aircraft, 

Hamilton, 2014 Quadrennial Fire Review (Washington, D.C .. May 2015). The 

states included in this statistic were Alaska, Arizona, California, Colorado, Idaho, 

Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming. See also 

National Research Council, Climate Change: Evidence, Impacts, and Choices. Answers to 

Common Questions about the Science of Climate Change (Washington, D.C .. 2012) and 

U.S. Climate Change Science Program, The Effects of Climate Change on Agriculture, 

Land Resources, Water Resources, and Biodiversity in the United States {Washington, 

D.C .. May 2008). 

2

0ther fire program components include prevention; science, research, and development; 

site rehabilitation; and assistance to nonfederal entities 

Page 1 
11 

and other equipment-and station them at individual federal land 

management units or at centralized dispatch locations in advance of 

expected wildland fire activity. 'Nhen a fire starts, interagency policy calls 

for the agencies to consider land management objectives and the 

structures and resources at risk when determining whether or how to 

suppress it. A wide spectrum of strategies is available to choose from, 

and the land manager at the affected local unit is responsible for 

determining which strategy to use-from conducting all-out suppression 

efforts to monitoring fires within predetermined areas in order to provide 

natural resource benefits. Fuel reduction refers to agencies' efforts to 

reduce potentially hazardous vegetation that can fuel fires, in an effort to 

reduce the potential for severe wildland fires, lessen the damage they 

cause, limit the spread of flammable invasive species, and restore and 

maintain healthy ecosystems. The agencies use multiple approaches for 

reducing this vegetation, including setting fires under controlled conditions 

(prescribed burns), mechanical thinning, herbicides, certain grazing 

methods, or combinations of these and other approaches. 

As part of their wildland fire management efforts, the agencies rely on 

firefighting aircraft-including fixed-wing airtankers, helicopters, and other 

aircraft-to assist in wildland fire suppression activities. Aircraft are used 

to conduct surveillance, deliver supplies, and drop retardant or water to 

extinguish or slow the growth of fires. In using aircraft, the agencies 

largely rely on private vendors that own and operate the aircraft under 

contract to the government. Among firefighting aircraft, large airtankersthose able to carry at least 1,800 gallons of fire retardant-are key 

resources for the agencies because of their ability to fly to remote areas 

and quickly assist in containing small fires before they become larger, 

costlier, and more dangerous. The Forest Service is responsible for 

contracting for large airtankers, although they may be used by any of the 

agencies. However, the number of large airtankers available under 

federal contract decreased substantially from 2002, when 44 large 

airtankers were available, to 2013, when 8 were available. The decrease 

in large airtankers was, in part, the result of aircraft being retired due to 

their age-in 2013, the average large airtanker was more than 50 years 

old-as well as agencies' concerns about the airtankers' safety and 

capability to perform the demanding fire aviation mission. 

In recent decades, increased wildland fire intensity has prompted new 

policies and efforts aimed at implementing more effective management 

strategies to manage wildland fire. For example, in response to significant 

fire events, the agencies developed the Federal Wildland Fire 

Management Policy of 1995, under which the agencies continued to 

Page 2 
12 

move away from their earlier emphasis on suppressing every wildland 

fire, seeking instead, among other things, to respond to fires in ways that 

protect communities and important resources while considering both the 

cost and long-term effects of the response. The most recent guidance for 

the implementation of this policy was issued in 2009. As we found in our 

September 2015 report,' this guidance provided managers with more 

flexibility in responding to wildland fires by allowing them to consider 

different options for response. According to agency documents, the 

guidance was intended to reduce barriers to risk-informed decision 

making, allowing the response to be more commensurate with the risk 

posed by the fire, the resources to be protected, and the agencies' land 

management objectives. The issuance of the 2009 guidance was one of 

several key changes the agencies had made in their approach to wildland 

fire management, in part to reflect this risk-based approach. Also, in that 

report we found that the agencies were working to distribute their fire 

management resources in ways that better reflect current conditions 

rather than continuing to rely primarily on historical funding amounts. 

These efforts take on greater importance in light of constrained budgets 

and the amount spent by federal agencies on wildland fire management 

For example, the Forest Service and Interior obligated $8.3 billion to 

suppress wildland fires in fiscal years 2009 through 2014. In addiUon, 

according to a 2015 report by Forest Service researchers, the amount the 

Forest Service spends on wildland fire management has increased from 

17 percent of the agency's total funds in 1995 to 51 percent of funds in 

20144-highlighting the importance of the agencies understanding the 

effectiveness of their wildland fire management programs. 

My statement today focuses on (1) how the federal wildland fire 

management agencies assess the effectiveness of their wildland fire 

management programs and (2) the Forest Service's efforts to modernize 

the large airtanker fleet and challenges it has faced in doing so. This 

testimony is based primarily on reports we issued in September 2015 and 

Wildland Fire Management: Agencies Have Made Several Key Changes but Could 

More Information about Effectiveness, GA0-15-772 (Washington, D.C .. Sept 

16, 2015). 

4David E. Calkin, Matthew P. Thompson, and Mark A Finney, "Negative Consequences of 

Positive Feedbacks in U.S. WJ!dfire Management," Forest Ecosystems, val. 2, no. 9 

(2015). 

Page 3 
13 

August 2013.5 To examine how federal wildland fire management 

agencies assess program effectiveness, we reviewed documents, such 

as agency strategic plans, budget justifications, agency studies and 

strategy documents related to fire aviation, and reports resulting from fire 

reviews conducted by the agencies since 2009. We interviewed agency 

officials to identify key performance measures and other mechanisms the 

agencies use to determine the effectiveness of their wildland fire 

management programs and to understand agency efforts to identify their 

firefighting aircraft needs, including their use of information on 

performance and effectiveness. We also reviewed legislative and agency 

direction related to fire reviews and compared agency practices for 

conducting fire reviews with direction contained in relevant agency policy. 

To examine the Forest Service's efforts to modernize the large airtanker 

fleet, we reviewed agency documents related to large airtanker 

acquisition, management, and operations, as well as planning and 

acquisition documents. We also interviewed members of the fire aviation 

stakeholder community, including state officials, vendors that own and 

operate large airtankers, and national trade organizations. More details 

on the scope and methodology for this work can be found in each of our 

issued reports. In addition, this testimony includes selected updates we 

conducted in November 2015 on actions the agencies have taken since 

our 2013 report. To conduct the updates, we reviewed agency 

documentation, including documents related to firefighting aircraft, and 

interviewed Forest Service and Interior officials. 

We conducted the work on which this testimony is based in accordance 

with generally accepted government auditing standards. Those standards 

require that we plan and perform the audit to obtain sufficient, appropriate 

evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on 

our audit objectives. 

5GA0-15-772 and GAO, Wildland Fire Management: Improvements Needed in 

Information, Collaboration, and Planning to Enhance Federal Fire Aviation Program 

Success, GA0-13-684 (Washington, D.C .. Aug. 20, 2013) 

Page 4 GA0-16-217T 
14 

Agencies Assess the 

Effectiveness of Their 

Programs in Several 

Ways but Have Not 

Consistently 

Conducted Reviews 

That Could Improve 

Responses to Fires 

Agencies Use Various 

Performance Measures to 

Assess Wildland Fire 

Management 

In our September 2015 report, we found that the agencies assess the 

effectiveness of their wildland fire management programs in several 

ways, including through performance measures, efforts to assess specific 

activities, and reviews of specific wildland fire incidents. We found that 

both the Forest Service and Interior were developing new performance 

measures, in part to help better assess the results of their current 

emphasis on risk-based management, according to agency officials.' In 

addition, the agencies have undertaken multiple efforts to assess the 

effectiveness of activities such as fuel reduction treatments and aerial 

firefighting. We also found that the agencies had conducted reviews of 

their responses to wildland fires, but that they did not consistently follow 

agency policy in doing so or use specific criteria for selecting the fires 

they reviewed, limiting their ability to help ensure that their fire reviews 

provided useful information and meaningful results. 

As we found in our September 2015 report, both the Forest Service and 

Interior use various performance measures, such as the number of acres 

treated to reduce fuels and the percentage of wildland fires contained 

during initial attack,' to assess their wildland fire management 

effectiveness. These measures are reported in, among other things, the 

agencies' annual congressional budget justifications. Officials from both 

the Forest Service and Interior, however, told us their performance 

measures need improvement to more appropriately reflect their emphasis 

on a risk-based approach to wildland fire management and, in June 2015, 

officials from both agencies told us that they were working to improve 

them. For example, in fiscal year 2014, the Forest Service began 

developing a performance measure intended to reflect that, in some 

cases, allowing naturally-ignited fires to burn can provide natural resource 

benefits at a lower cost and lower risk to personnel than fully suppressing 

the fire as quickly as possible8 Forest Service officials told us they are 

working with field units to evaluate whether this measure will effectively 

assess their efforts to implement a risk-based approach to fire 

management, and said they will adjust it as needed. The officials told us 

7"1nitlal attack" refers to the initial efforts to suppress a wildland fire, generally 

encompassing the first 24 hours after a fire is reported 

8

The performance measure is 'Percent of acres burned by natural ignition with resource 

benefits." 

Page 5 
15 

Agencies Have 

Undertaken Multiple 

Efforts to Assess 

Effectiveness of Specific 

Activities 

they plan to finalize the measure and use it in 2017. Similarly, in fiscal 

year 2014 Interior began using a new performance measure intended to 

better reflect the variety of strategies, in addition to all-out suppression 

efforts, available to respond to wildland fires.' 

The agencies have also undertaken multiple efforts to assess the 

effectiveness of particular wildland fire management activities, such as 

fuel reduction and aerial firefighting. Regarding fuel reduction activities, in 

prior work we found that demonstrating the effectiveness of fuel reduction 

treatments is inherently complex and that the agencies did not have 

sufficient information to evaluate fuel treatment effectiveness, such as the 

extent to which treatments changed fire behavior. 10 Without such 

information, we concluded that the agencies could not ensure that fuel 

reduction funds were directed to the areas where they can best minimize 

risk to communities and natural and cultural resources. Accordingly, we 

recommended in 2007 that the agencies take actions to develop 

additional information on fuel treatment effectiveness. The agencies 

agreed with this recommendation and have taken steps to address it. In 

our September 2015 report, we found that the agencies are continuing 

efforts to improve their understanding of fuel treatment effectiveness. For 

example, the Forest Service and Interior agencies use a system called 

Fuel Treatment Effectiveness Monitoring to assess fuel reduction 

treatment effectiveness. 11 The Forest Service began requiring such 

assessments in 2011, and Interior requested such assessments be 

9The performance measure Is «Percent of Wildfires on [Department of the lnterior]-

managed landscapes where the initial strategy (ies) ful!y succeeded during the initial 

response phase " 

10GAO, Vl/ifdland Fire Management: Better Information and a Systematic Process Could 

Improve Agencies' Approach to Allocating Fuef Reduction Funds and Selecting Projects, 

GA0-07-1168 (Washington, D.C .. Sept 28, 2007) and GAO, \Midland Fire Management: 

Federal Agencies Have Taken Important Steps Forward, but Additional, Strategic Action Is 

Needed to CapHafize on Those Steps, GA0-09-877 (Washington, D.C .. Sept 9, 2009) 

11 Fuel Treatment Effectiveness Monitoring is a program to evaluate the effectiveness of 

prescribed fire and mechanical treatments designed to reduce the risk of wildfire_ Forest 

Service and Interior agencies conduct assessments in instances where a wildfire either 

starts within or burns into an area that has been treated, to evaluate the resulting impacts 

on fire behavior and fire suppression actions. We have not assessed the agencies' 

implementation of this effort 

Page 6 
16 

completed starting in 201212 Under this approach, the agencies are to 

complete a monitoring report whenever a wildfire interacts with an area 

where a fuel reduction treatment was previously conducted. 

Regarding aerial firefighting, in our August 2013 report, we found that 

Forest Service and Interior had not collected information on the 

performance and effectiveness of firefighting aircraft as part of their 

efforts to identify their firefighting aircraft needs. 13 Specifically, we found 

that the agencies had not established data collection mechanisms to track 

the specific tactical uses of firefighting aircraft-for example, where 

retardant or water is dropped in relation to a fire as well as the objective 

of a drop, such as protecting a structure-or measure their performance 

and effectiveness in those uses. Since the 1960s, multiple reviews of 

federal fire aviation programs have called for the Forest Service and 

Interior to collect information on the perfonmance offirefighting aircraft. At 

the time of our 2013 report, the Forest Service had recently begun an 

effort known as the Aerial Firefighting Use and Effectiveness Study to 

address this concern. We noted, however, that this study focused on 

large airtankers (which, as noted, are managed by the Forest Service) 

and that Interior did not have plans to collect performance information on 

the types of firefighting aircraft it manages. Accordingly, in that report we 

recommended that the agencies expand efforts to collect information on 

aircraft performance and effectiveness to include all types of firefighting 

aircraft in the federal fteet. The agencies generally agreed with our 

recommendation. 

In our September 2015 report, we found that the Forest Service and 

Interior were jointly implementing the Aerial Firefighting Use and 

Effectiveness Study begun in 2012. According to the study website and 

agency officials, the agencies are collecting information on how aerial 

retardant and suppressant delivery affects fire behavior, and they plan to 

use this and other collected information to track the performance of 

Interior agencies each issued their own guidance related to Fuel Treatment 

Effectiveness Monitoring. The National Park Service issued guidance in 2012, Bureau of 

Indian Affairs in 2013, Bureau of Land Management in 2014, and Fish and WHd!ife Service 

in 2015. 

13GA0-13-684 

Page 7 GA0·16-217T 
17 

The Forest Service and 

Interior Agencies Have Not 

Consistently Conducted 

Reviews of Wildland Fire 

Incidents to Assess their 

Effectiveness 

specific aircraft types. 14 As of November 2015, according to agency 

officials, the agencies had collected data on aircraft use in more than 100 

fires as part of the study. In addition, according to these officials, as part 

of the study the agencies are developing specific ways to assess 

firefighting aircraft performance effectiveness to be used during the 2016 

fire season. Agency officials told us the study is not a one-time activity but 

is an ongoing effort to continually provide infonmation to help improve 

their use of firefighting resources. 15 

As detailed in our September 2015 report, the Forest Service and the 

Interior agencies have conducted reviews to assess their effectiveness in 

responding to wildland fires, but have not consistently followed agency 

policy in doing so and did not always use specific criteria for selecting the 

fires they reviewed. Congressional committee reports and agency policy 

have generally called for the agencies to review their responses to 

wildland fires involving federal expenditures of $10 million or more, in part 

to help understand how to better contain suppression costs. 16 The 

agencies, in turn, have each developed their own policies that generally 

direct them to review each fire that exceeds the $10 million threshold and, 

in some cases, those policies note that fire reviews may be conducted for 

other purposes, such as where the fire raised significant political, social, 

natural resource, or policy concerns. 

The agencies have not consistently conducted reviews of fire incidents 

meeting the $10 million threshold, in part because, according to officials, 

doing so does not reflect the agencies' focus on assessing the 

effectiveness of their response to fire. However, the agencies have not 

developed specific criteria for selecting fire incidents for review. Forest 

Service officials told us that rather than selecting all fires with federal 

aircraft 

accessed July 31, 2015. Aircraft types 

in the study include fixed-wing airtankers, certain types of helicopters, and other 

15As of November 2015, we had not obtained documentation to determine the extent to 

which the agencies' actions are responsive to our 2013 recommendation 

161n fiscal years 2003 through 2010, congressional committee reports directed the Forest 

Service and Interior to conduct reviews of large fire incidents generally for the purpose of 

understanding how to better contain suppression costs; beginning in fiscal year 2006, 

these reports included a cost threshold, specifying that such reviews be conducted for 

fires involving federal expenditures of $10 million or more. 

Page 8 
18 

expenditures of $10 million or more to review, they changed their 

selection approach. These officials told us that focusing exclusively on 

suppression costs when selecting fires may keep the agency from 

choosing those fires where it can obtain important information and best 

assess management actions and ensure they are appropriate, risk-based, 

and effective. Instead, Forest Service officials told us the agency 

judgmentally selects incidents to review based on a range of broad 

criteria, such as complexity and national significance, taking into account 

political, social, natural resource, or policy concerns. Using these broad 

selection criteria, the Forest Service reviewed 5 wildland fires that 

occurred in 2012 and 10 that occurred in 2013. However, with these 

broad criteria it is not clear why the Forest Service selected those 

particular fires and not others. For example, the 2013 Rim Fire, which 

burned more than 250,000 acres and cost more than $100 million to 

suppress-by far the costliest fire to suppress that year-was not among 

the 2013 fires selected for review. 17 Moreover, the reviews completed for 

each of those years did not use consistent or specific criteria for 

conducting the reviews. As of July 2015, the agency had not selected 

fires to review from the 2014 wildland fire season and, when asked, 

agency officials did not indicate a time frame for doing so. 

Forest Service officials told us they believe it is appropriate to 

judgmentally select fires to provide them flexibility in identifying which 

fires to review and which elements of the fire response to analyze. 

Nevertheless, Forest Service officials also acknowledged the need to 

develop more specific criteria for selecting fires to review and conducting 

the reviews. In July 2015, officials told us they were working to update 

their criteria for doing so. They provided us a draft update of the Forest 

Service policy manual, but this draft did not contain specific criteria for 

selecting fires for review or conducting the reviews. Moreover, officials did 

not provide a time frame for completing their update. 

Within Interior, Bureau of Land Management officials told us that the 

agency completed its last fire review based on significant cost (i.e., 

federal expenditures of $10 million or more) in 2013. These officials told 

us that the Bureau of Land Management, similar to the Forest Service, 

plans to shift the emphasis of its fire reviews to evaluate management 

17The Rim Fire burned about 154,000 acres of Forest Service land, about 79,000 acres of 

National Park Serv1ce land, and about 23,000 acres of private !and. 

Page 9 
19 

actions rather than focusing on cost, and that officials are working to 

determine criteria for selecting fires for review. Interior headquarters 

officials told us that the Fish and Wildlife Service and National Park 

Service have continued to follow the direction provided through their 

policies regarding reviews of fires that met the $10 million threshold. 

Interior headquarters officials, however, acknowledged the need to 

improve Interior's approach to selecting fires for review to focus more on 

information about decision making rather than fire costs. In July 2015, the 

officials told us they planned to develop criteria other than cost for use by 

all Interior agencies in selecting fires to review, and that they planned to 

develop standard criteria for implementing the reviews, but they did not 

provide information about how they planned to develop such criteria or 

the factors they would consider. 

Agency reports have likewise cited the need to improve both the 

processes for selecting fires for review and the implementation of the 

reviews. A 2010 report, for example, noted the importance of improving 

the selection of fires to review and stated that the agencies would benefit 

from a more productive review strategy. 18 The report said the agencies' 

existing approach to conducting reviews tended to produce isolated 

efforts and unrelated recommendations rather than establishing a 

consistent foundation for continuous improvement. A 2013 report 

assessing the usefulness of the Forest Service's five reviews of 2012 fires 

noted shortcomings in consistency across the reviews, including unclear 

criteria for selecting fires and conducting reviews, as well as limitations in 

the specificity of the resulting reports and recommendations'' Our 

previous body of work on performance management has shown that it is 

important for agencies to collect performance information to inform key 

management decisions, such as how to identify problems and take 

corrective actions and how to identify and share effective approaches20 

We concluded that, by developing specific criteria for selecting fires for 

18U.S. Department of Agriculture Independent Large Fire Cost Review Panel and 

Guidance Group, Inc., Large Fire Cost Review for 2009 (August 2010) 

19Wildland Fire Lessons Learned Center, Lessons From Recent Large Fire Reviews 

Briefing Paper{August 7, 2013). There was no similar analysis performed ofthe Forest 

Service's 10 reviews of fires occurring in 2013 

20See GAO, Managing for Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GA0-05-927 (Washington, D.C .. Sept 9, 2005); GAO, 

Nanotechnology: Improved Pel1ormance Information Needed for Environmental, Health, 

and Safety Research, GA0-12-427 (Washington, D.C .. May 21, 2012); and GA0-13-684 

Page 10 
20 

The Forest Service 

Has Faced 

Challenges in Its 

Efforts to Modernize 

the Large Airtanker 

Fleet, but Has 

Increased the 

Availability of Large 

Airtankers Since Our 

2013 Report 

review and conducting the reviews, the agencies may enhance their 

ability to obtain useful, comparable information about their effectiveness 

in responding to wildland fires, which, in turn, may help them identify 

needed improvements in their wildland fire approach. As a result, we 

recommended in our September 2015 report that the Secretaries of 

Agriculture and the Interior direct the Chief of the Forest Service and the 

Director of Interior's Office of Wildland Fire to (1) develop specific criteria 

for selecting wildland fires for review and for conducting the reviews as 

part of their efforts to improve their approach to reviewing fires and 

(2) once such criteria are established, revise agency policies to align with 

the specific criteria developed by the agencies. In their written comments 

on our report, the agencies generally agreed with our recommendations 

and stated that they were developing criteria for selecting fires to review 

and conducting reviews. 

In our August 2013 report, we found that the Forest Service faced 

challenges in modernizing the government's fleet of large airtankerswhich had declined from 44 in 2002 to 8 in 2013-but since that report 

the agency has increased the availability of such aircraft, with some 

challenges remaining. Specifically, we found that the Forest Service 

planned to modernize the large airtanker fleet by obtaining large 

airtankers from various sources over the near, medium, and long terms, 

but that each component of this approach faced challenges that made the 

continued availability of such aircraft to meet national fire suppression 

needs uncertain." Since that report, some of these challenges remain, 

while others are no longer relevant. In addition, the Forest Service has 

increased the availability of large airtankers, in part by increasing the 

number of airtankers under contract. 

We found in our 2013 report that, in the near term, the agency planned to 

rely on a mix of contracted "legacy" airtankers, including several P-2V 

Neptune aircraft-Korean War-era maritime patrol aircraft-as well as 

supplemental aircraft available through additional contracts and 

agreements with the military and with other governments." However, 

22The Forest Service and Interior have established agreements with the military and with 

other governments, such as those of Canada and the State of Alaska, to augment the 

national firefighting aircraft fleet during periods of heavy fire activity. 

Page 11 
21 

agency concerns existed regarding the availability, capability, and costs 

of these resources. For example, the agency had seven P-2V Neptune 

aircraft under contract, the ages of which made their availability 

throughout the entire 5-year contract period uncertain. Specifically, 

aircraft vendors told us they might need to retire some aircraft prior to the 

end of the contract period because of the cost of maintaining the aging 

aircraft. As of November 2015, six P-2V Neptune aircraft remained under 

contract to the Forest Service23 

For the medium term, the Forest Service had awarded contracts for 

seven "next-generation" large airtankers that were expected to be faster 

and more up-to-date than the legacy aircraft. However, at the time of our 

2013 report, it was uncertain when those aircraft would begin supporting 

fire suppression activities, in part because bid protests had delayed 

contract issuance and, at the time of that report, only one had completed 

necessary federal approval and certification processes to support fire 

suppression activities. Since then, according to Forest Service officials, 

six of these seven aircraft have completed the needed approval and 

certification processes." The Forest Service has issued additional 

contracts for next-generation aircraft and, as of November 2015, the 

agency had a total of 20 privately-owned large airtankers under contract, 

according to Forest Service officials." Seven of these airtankers were 

added under contract in September 2015. 

For the long term, the Forest Service's plan included a shift from the 

agency's long-standing practice of contracting for, rather than owning, 

aircraft. Specifically, the Forest Service had indicated its long-term 

intention to obtain up to 14 Alenia C-27 J Spartan transport aircraft 

through intergovernmental transfer at no initial cost if they were declared 

surplus by the military and to purchase other airtankers. In our 2013 

report, however, we found that challenges existed regarding the retardant 

23The seventh P-2V was damaged during a landing in 2014 and is no longer under 

contract, according to a Forest Service official 

24Two of the aircraft received interim certification and are awaiting final certification, 

according to a Forest Service official 

25The Forest Service contracted for these aircraft using exclusive-use contracts, which 

require a vendor to provide an aircraft for service on any day covered by a "mandatory 

availability period" stipulated by the contract. The agency can access additional aircraft 

using call-when-needed contracts, which allows the government to pay for firefighting 

aircraft only when they are used. 

Page 12 
22 

capacity and operating cost of the C-27 J transport aircraft the Forest 

Service was to obtain through intergovernmental transfer, and that the 

Forest Service had been unable to justify previous plans for purchasing 

large airtankers to the Office of Management and Budget. Regarding 

intergovernmental transfer, the Forest Service had expressed interest in 

obtaining up to 14 Alenia C-27 J Spartan transport aircraft from the 

Department of Defense if they were declared surplus equipment. Since 

our report, the National Defense Authorization Act of 2014 required a 

different intergovernmental transfer than that anticipated by the Forest 

Service-thereby making the challenge we identified with the C-27J 

transport aircraft no longer relevant. 26 Rather than transferring the C-27J 

transport aircraft to the Forest Service, section 1098 of the act directs the 

Coast Guard to transfer seven Lockheed Martin HC-130H Hercules 

aircraft to the Forest Service for use in wildfire suppression. 27 According 

to Forest Service officials, none of these aircraft have been transferred as 

of November 2015; these officials told us they expect the aircraft will be 

transferred to the Forest Service between 2017 and 2019. One aircraft, 

however, was used by the Forest Service during the 2015 wildland fire 

season under an agreement with the Coast Guard, according to Forest 

Service officials. The Forest Service equipped that aircraft with a Modular 

Airborne Firefighting System (MAFFS) unit-a portable, pressurized 

retardant delivery system. 28 However, as we found in our 2013 report, 

Forest Service and Interior officials expressed concern that MAFFS 

performance can be inadequate in some circumstances 29 Forest Service 

officials told us the agency intends to operate one HC-130H aircraft with 

26 Pub. L. No. 113-66, 127 Stat 881 (2013) 

27The law directed that the aircraft first be transferred to the Air Force for certain needed 

modifications. Once these modifications are completed, the aircraft are then to be 

transferred to the Forest Service 

28The Forest Service has used MAFFS units to temporarily convert military C-130 aircraft 

into large airtankers when additional aerial firefighting capacity is needed, under an 

agreement w1th the Department of Defense. For more details on the MAFFS program, see 

GA0-13-684 

29We noted in our 2013 report that some federal and state fire aviation officials told us that 

the retardant line dispersed by the MAFFS system is generally narrower than firefighters 

prefer, which can either allow a fire to jump across the retardant line or necessitate an 

additional drop to widen the line, if another aircraft is available. Additionally, some officials 

said the system is unable to penetrate dense forest canopies, thereby preventing the 

retardant from being effective when used in heavy timber. However, some federal and 

state officials told us that MAFFS can be used effectively on rangeland where grasses are 

the predominant fuel type. 

Page 13 
23 

GAO Contact and 

Staff 

Acknowledgments 

(10040S) 

the MAFFS unit through the 2016 fire season, but the agency plans to 

equip all seven HC-130H aircraft with traditional gravity-fed retardant 

delivery systems. Forest Service officials told us that the expected service 

life of these aircraft is 6 to 12 years, after which time the F crest Service 

would likely need to invest in significant maintenance given the demands 

placed on the aircraft by the firefighting mission. 

In another development since our 2013 report, the Consolidated and 

Further Continuing Appropriations Act, 2015, 30 included $65 million "for 

the purpose of acquiring aircraft for the next-generation airtanker fleet to 

enhance firefighting mobility, effectiveness, efficiency, and safety." In 

August 2015, the Forest Service issued draft specifications for aircraft it 

would consider purchasing in accordance with the act. In November 

2015, Forest Service officials told us the Department of Agriculture is 

preparing a business case to demonstrate the feasibility of such a 

purchase as required by Office of Management and Budget guidance, but 

did not provide a time frame for its submission. 

Chairman Murkowski, Ranking Member Cantwell, and Members of the 

Committee, this completes my prepared statement. I would be pleased to 

respond to any questions that you may have at this time. 

If you or your staff members have any questions about this testimony, 

please contact me at (202) 512-3841 or fennella@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this statement. Other individuals who made 

key contributions to this testimony include Steve Gaty (Assistant 

Director), Ulana M. Bihun, Mark Braza, Richard P. Johnson, Kyle M. 

Stetler, and Kiki Theodoropoulos. 

30Pub. L. No. 113-235, 128 Stat 2130 (2014). 

Page 14 
24 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted tmages or other matena!, permission from the copyright holder may be 

necessary if you wish to reproduce th!s materia! separately 
25 

GAO's Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Phone 

Connect with GAO 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO's commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO's website (http://www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select "E-mail Updates." 

The price of each GAO publication reflects GAO's actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO's website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TOO (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information. 

Connect with GAO on Facebook, Flickr, Twitter, and YouTube. 

Subscribe to our RSS Feeds or E-mail Updates. 

Listen to our Podcasts and read The Watchblog. 

Visit GAO on the web at www.gao.gov. 

Contact: 

Website: http://www.gao.gov/fraudnetlfraudnet.htm 

E-mail: fraudnet@gao.gov 

Automated answering system: (800) 424-5454 or (202) 512-7470 

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548 

Chuck Young, Managing Director, youngc1 @gao.gov, (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548 

~". ,. ... Please Print on Recycled Paper. 
26 

The CHAIRMAN. Thank you, Ms. Fennell. 

Mr. Maisch, welcome. 

STATEMENT OF JOHN ‘‘CHRIS’’ MAISCH, STATE FORESTER 

AND DIRECTOR, DIVISION OF FORESTRY, ALASKA DEPARTMENT OF NATURAL RESOURCES 

Mr. MAISCH. Good morning, Chairman Murkowski and Ranking 

Member Cantwell and members of the Committee. My name is 

Chris Maisch. I’m the State Forester and Director of the Alaska 

Department of Natural Resources Division of Forestry and past 

president of the National Association of State Foresters (NASF). 

The NASF represents the directors of the state forestry agencies in 

all 50 states, eight territories and the District of Columbia. 

This was another difficult wildland fire season for us nationally, 

and in Alaska it will go down in the record books as the second 

worst season for acres burned. Approximately 5.1 million acres or 

about 54 percent of the 9.4 million acres that burned nationally 

this year were in Alaska. The worst fire season on record for Alaska occurred just over a decade ago at 6.4 million acres a year. 

And if you would, please look at Figure 1 in your handout. As 

you examine the graph you will see a dashed line that indicates the 

rolling 11-year average for acres burned, and you can see that 2004 

was the tipping point for the state. The workload, as represented 

by acres burned, has doubled from the previous long term average 

and this past season underscored the type of wildland fire season 

we are faced with on a more frequent basis. 

I also have to tell you a personal story. It was the year my red 

beard turned grey in 2004. [Laughter.] 

Our season began this year with two large urban interface fires, 

the Sockeye near Willow and the Card Street near Soldotna. The 

Sockeye fire was initially attacked at two acres and was 1,000 

acres by the end of the day, and by the end of the second day it 

was 9,000 acres. Unfortunately over 100 structures were lost including 55 primary residents. 

These incidents were a sign of things to come, and in mid-June 

in a 7-day period over 61,000 lightning strikes ignited 295 fires. 

And that’s Figure 2 in your handout. By the end of the season 45 

states and two Canadian provinces had provided resources to Alaska fires. 

While all this activity was taking place in Alaska, the lower 48 

season began to develop into a more active and challenging series 

of incidents. Many of the Western states, particularly Oregon, 

Washington and California, were having another difficult fire year. 

So what did we learn from this past season and what can we do 

to address these growing problems? 

Communities at risk. In FY2013 the total number of communities at risk from wildland fire in the U.S. was 72,000. The NASF 

is a key partner in the development and implementation of the National Cohesive Wildland Fire Management Strategy and its three 

primary goals: restore and maintain resilient landscapes, develop 

fire adapted communities, and provide efficient and effective responses to wildfires. 

I’d like to illustrate the importance of these objectives by sharing 

a story about the Funny River fire from the 2014 Alaska fire sea-
27 

son. The Kenai National Wildlife Refuge has been creating fuel 

breaks. These are large landscape level projects designed to protect 

homes, businesses and other values at risk should a fire start on 

the refuge and move toward the community. Take a look at Figure 

4 for a picture of one. 

These advanced preparations paid off and in the spring of 2004 

a lightning initiated fire threatened the outskirts of Soldotna. The 

fuel breaks made all the difference. The call came in around midnight that the fire was going to hit the Funny River Road. By the 

time crews arrived there was not much time to start a burn out 

to rob the approaching fire of fuel. The fuel breaks slowed the fire 

and allowed crews to safely and successfully light a burn out. Over 

2,400 structures were protected with an assessed value of more 

than $250 million. 

Next I’d like to talk briefly about another topic, and this topic 

has to do with our aviation programs. An ongoing problem for 

many states with wildland fire aviation programs is the issue of 

carding both individual pilots and aviation platforms. 

Both the Forest Service and the Department of Interior, through 

their Office of Aircraft Services, require additional verification of 

any aviation assets that will be used on a Federal fire. The two 

agencies are not well coordinated in this effort despite using the 

same carding standards for certification and this caused some real 

problems during the fire season. 

In my written testimony I’ve listed several specific examples to 

illustrate the issue, but I’d like to share two with you from my 

home state. A State of Alaska contract helicopter that is based out 

of California had been carded at the beginning of the fire season 

by the Forest Service and had to be re-carded by OAS when it reported to Alaska for work later in the summer. Also in Alaska two 

National Guard Blackhawk helicopters doing bucket work on a Forest Service fire were not utilized for a second mission when it was 

determined they were not carded. 

These examples illustrate some of the challenges faced by states 

this season and the Federal agencies should engage State forest 

agencies as equal partners to update the National Wildland Fire 

Aviation Strategy with an efficient and consistently implemented 

approval process. 

I see my time is short so I’d encourage you to examine two other 

general topics in my written testimony where I’ve made some recommendations for improving or maintaining programs that help 

grow and maintain response capacity and the need for more 

proactive forest management to help address some of the underlying causes of this problem. 

In conclusion, thank you for the opportunity to appear before the 

Committee today. My fellow state foresters and I stand ready to assist the Committee at finding ways to address the challenges we 

all face as the wildland fire problem continues to grow and consume larger and larger portions of our State and Federal budgets. 

Thank you. 

[The prepared statement of Mr. Maisch follows:] 
28 

Testimony of John "Chris" Maisch, Alaska State Forester 

On Behalf of the Alaska Division of Forestry and 

The National Association of State Foresters 

Submitted to the U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 

Good morning, Ms. Chairman Murkowski, Ranking Member Cantwell, and Members of the 

Committee. My name is Chris Maisch, State Forester and Director of the Alaska Department of 

Natural Resources, Division of Forestry (DOF) and past President of the National Association of 

State Foresters (NASF). l appreciate the opportunity to speak with you today and submit 

written testimony as the Committee entertains an after action review of the 2015 fire season and 

the complex issues surrounding wildland fire management. The mission of the DOF is to 

proudly serve Alaskans through forest management and wildland fire protection. The DOF is the 

lead agency for wildland fire management services on 150 million acres ofland with a primary 

goal to protect life and property. In addition, the agency oversees the management of 4 7 million 

acres afforests on state land, including approximately two million acres in three designated state 

forests. The Division also regulates commercial forestry practices on private, municipal and 

state lands with a mandate of protecting fish habitat and water quality during timber management 

activities. 

The NASF represents the directors of the state forestry agencies in all 50 states, eight territories, 

and the District of Columbia. State Foresters deliver technical and financial assistance, along 

with protection afforest health, water and wildfire for more than two-thirds of the nation's 

forests. While the duties of state agencies vary from state to state, all share common forest 

management and protection missions and most have statutory responsibilities to provide 

wildland fire protection on all lands, public and private. ln fiscal year (FY) 2014, state forestry 

agencies provided this service on approximately 1.5 billion acres and helped train nearly 102,000 

firefighters via funding from the USDA Forest Service (Forest Service), State Fire Assistance 

(SFA) and Volunteer Fire Assistance (VF A) programs. State Foresters work closely with federal 

partners to deliver forestry programs and wildfire protection. 

2015 Wildland Fire Season 

This was another difficult wildland fire season nationally, and in Alaska it will go down in the 

record books as our second worst fire season for acres burned. Approximately 5.1 million (M) 

acres or about 54 percent of the 9.4M acres that burned nationally this year were in Alaska. The 

worst fire season on record for Alaska occurred just over a decade ago (2004) at 6.4M acres 

(Figure 1 ). As you examine the graph, you will see a dashed line that indicates the rolling 11-

year average of acres burned and you can see that 2004 was a tipping point for the state. The 

workload as represented by acres burned has doubled from the previous long-term average and 

this past season underscored the type of wildland fire season we are faced with on a more 

frequent basis. 

11 P g e 
29 

The Alaska season unfolded with a very dry and warm spring that cured the fuels and set-up the 

potential for a significant fire event should ignition sources develop, which for Alaska is usually 

lightning in June. Many of our fire/tuel indices were at record or near record levels around the 

state. The season started in earnest with two large, urban interface tires, one in the Matsu Valley 

near the community of Willow, called the Sockeye fire, and the other on the Kenai Peninsula 

near the town of Soldotna, called the Card Street fire. Both of these incidents occurred during 

fire weather red flag warnings, which was primarily due to predicted high winds. The Card 

Street fire was reported at one acre and grew to 1,000 acres on the first day- 9,000 acres by the 

second day. The Sockeye fire was initially attacked at two acres and by the second day the fire 

had grown to 6,500 acres. Unfortunately, there were 59 primary residences lost, mainly in the 

Sockeye fire. These incidents were a sign of things to come and in mid-June a seven-day 

lighting event ignited 295 fires (30 to 50 per day) when over 61,000 lighting strikes occurred 

(Figure 2). Needless to say, the Alaska wildland fire suppression resources were down to nil by 

the end of this unprecedented seven day run, despite the pre-positioning of resources that had 

been done in anticipation of a large fire event. 

Assistance was corning from the Lower 48 states (L-48) and Canada, but it takes several days for 

resources to arrive. On June !7'h there were 999 staff assigned to fires, 2,000 by June 23rd and 

3,174 staff by June 29'h By the end of the season, 45 states and two Canadian provinces had 

provided resources to Alaskan fires. Roughly speaking, about 48 percent of the resources used 

were Alaskan based with the balance (52 percent) corning from other state, federal and Canadian 

sources. This example underscores the importance of the sharing of wildland fire resources and 

building capacity of both state and local cooperators to respond nationally during extreme events. 

As the season progressed, over 90 fires merged, with the largest being the Big Creek Two fire, 

which joined with four other fires that totaled 433,685 acres. At one point, two rural 

communities, Tanana and Koyukuk on the Yukon River, were surrounded by a complex of fires. 

At the time I was reminded of the town of Wallace, idaho that was destroyed in the infamous 

1910 fire known as the "Big Burn." Fortunately in this case, losses were kept to a minimum by a 

key interagency partner the Alaska Fire Service, but many of the residents of these two villages 

were evacuated for an extended period of time. In the end, there were 766 fires statewide and the 

state was at planning level five for 24 days - the highest level of activity. Luckily, the month of 

August had abundant rainfall in many locations around the state and there were few new fire 

starts. However, there was plenty of fire on the landscape, and fire fighters were continuously 

assigned to fires from May 161

h until September 101

h, a very long fire season for Alaska. The last 

major fire of the season was on Kodiak Island, another wind driven fire that reached 5,000 acres 

in just two days. The fire burned all the way to the ocean, where it finally stopped! (Figure 3). 

While all this activity was taking place in Alaska the L-48 fire season began to develop into a 

more active and challenging series of incidents. Many of the Western states, particularly 

Oregon, Washington and California were having another difficult fire year and this was on the 

heels of a record-breaking year for two of these states in 2014 (WA and OR). There were 53,798 

wildfires reported nationally between January 1'1 and October 30tl' with the number of acres 

burned exceeding the ten-year average (6.5M acres) by almost 3.0M acres. My colleague, 

California State Forester Ken Pimlott, has indicated to me that due to drought in his state, they 

2 I P g e 
30 

now have a year round fire season. The issue ofwildland fire is not just a Western U.S. problem. 

As you look around the nation you have difficult and challenging fire seasons from all 

jurisdictions but fortunately so far, not usually in the same years. So, what did we learn from 

this past season and what can we do to address this growing problem? 

Communities at Risk 

In FY 2013, the total number of communities at risk from wildland fire in the U.S. was more 

than 72,000. During the same year approximately 17,000 communities have completed 

Community Wildfire Protection Plans (CWPP). Last week there was a fire chiefs White House 

roundtable on climate change and the impacts at the wildland urban interface (WUI). There is a 

growing recognition that what was once considered unusual or extreme for an individual fire, or 

the duration and intensity of a fire season, is becoming more common place. 

The NASF is a key partner in the development and implementation of the National Cohesive 

Wildland Fire Management Strategy (Cohesive Strategy) and its three primary goals: 

• Restore and Maintain Resilient Landscapes 

• Develop Fire Adapted Communities 

• Provide Efficient and Effective Response to Wildfires 

l believe members of this Committee are familiar with these concepts and you will hear from 

other speakers today on some of the details of these three goals, so I'd like to illustrate the 

importance of these objectives by sharing a story about the Funny River fire from the 2014 

Alaska fire season. I think many of my fellow State Foresters could share similar stories from 

their experiences. I don't believe this is a unique example. 

The Kenai National Wildlife Refuge has been creating fuelbreaks these are large landscape 

level projects. These projects were part of an interagency and multi-landowner effort to design 

and construct fuel breaks that would protect homes, businesses and other values at risk should a 

fire start on the refuge and move toward the community (Figure 4-5). The DOF was a key 

partner and completed the on-the-ground treatments over the course of several years. At the 

same time, individual fuel mitigation projects were pursued with homeowners utilizing the 

Fire Wise program as part of the overall implementation of the communities CWPP. These 

advanced preparations paid off and in the spring of 2014 a lighting initiated fire threatened the 

outskirts of the town of Soldotna, in an area called the Funny River Road. 

On the Funny River thick plumes of smoke dominated the skyline as firefighters dispersed 

through subdivisions. Some people had already been evacuated and the entire area was now 

under an evacuation order. People streamed out the one highway that leads into the area. The 

community was sandwiched between the approaching fire and the Kenai River, with only one 

way in and out. It was also the start of the Memorial Day weekend and this was the last thing 

most people had on their minds a few days earlier. Now they were wondering if they would 

have a home to which they could return. Moving fast on multiple fronts, firefighters were 

looking for any break they could get. 

3 I P g e 
31 

The fuelbreaks made all the difference. The call came in around midnight that the fire was going 

to hit the Funny River Road. By the time crews arrived, there was not much time to start a burn 

out to rob the approaching fire of fuel. For the Incident Commander the question was where to 

start? "Suddenly I realized I was in an area that was thinned of trees; they had built a fuelbreak!" 

he said. "The fuelbreak slowed the fire down enough for crews to safely and successfully light 

the burnout." Over 2,400 structures were protected with an assessed value of more than $250M. 

This incident illustrates a number of key elements of successful fire management: advanced 

preparations made by communities and individual homeowners, proactive management of high 

risk fuels by state and federal agencies, and an interagency "all hands, all lands" approach. 

Nationally and in Alaska, there is not enough funding being allocated for high risk fuels 

mitigation work. Each year in rural Alaska there is at least one fire in the wildland that is caused 

by burning at the local land fill. This year, there were two and these types of ignition sources are 

preventable, but only if humans cooperate. To improve the odds of eliminating these types of 

ignitions, every land fill in rural Alaska should have fuel mitigation projects completed around 

the facilities and a CWPP for the community completed. This investment would be paid back 

rapidly; consider that the two fires from this season alone cost over $7.0M to control. 

Aviation and Wildland Fire 

The national shortage of air tankers is finally moving in the right direction with the development 

of new platforms and resources, including next generation air tankers (Figure 5). These aviation 

assets are a key part of initial attack operations, to keep fires small, but are also deployed on 

larger project fires. The key to using air tankers in this role is using the right tool for the job and 

ensuring there are ground forces available to back-up the use of retardant and water drops. 

Attempting to build line with air tankers might look good, but this is an expensive resource and 

operation staffs on the fire line need to ensure the impact on control efforts is worth the cost 

(Figure 6). 

An ongoing problem for many states with wildland fire aviation programs is the issue of 

"carding" individual pilots and aviation platforms. Both the Forest Service and the Department 

oflnterior (DOl) fire suppression agencies, thru their Oftice of Aircraft Services (OAS), require 

additional verification of any aviation asset that will be used on a federal tire. The two agencies 

are not well coordinated in this effort, despite using the same carding standards for certifications. 

States have a combined aviation fleet of 197 fix wing aircraft and 184 helicopters in addition to 

their National Guard assets and this inter-agency situation has caused some real problems during 

the fire season and I've highlighted several here: 

• A state of Alaska (AK) contract helicopter that is based out of California (CA) had been 

carded at the beginning of the fire season by the Forest Service and had to be re-carded 

by OAS when it reported to AK for work. 

• Colorado sent its multi-mission aircraft (infrared mapping), which was approved by the 

Forest Service in its Region-2, to Oregon (OR) where it had to be carded again by Forest 

41 ge 
32 

Service Region-6. It was approved within a couple of days, but this second action should 

not be required. 

• Nevada was required by OAS to add a second digital radio to an aircraft, which is not in 

the current standards. 

• In OR, additional issues included delays in receiving a tanker identification number for a 

state Single Engine Air Tanker (SEAT) and National Interagency Fire Center (NIFC) 

staff initially refusing to load NTFC radios onto an OR state aircraft to transport back to 

OR An email authorization was required from the Forest Service, Region-6. This was a 

time sensitive issue due to ongoing wildfires. 

• In Montana (MT), state FEPP helicopters can't be carded due to interpretation on 

maintenance practices (i.e. Ex-military vs. Federal Aviation Administration standards). 

• In AK, two National Guard Black Hawk helicopters doing bucket work on a Forest 

Service fire were not utilized for a second mission when it was determined they were not 

carded. 

• Multiple states including CA, OR, W A, Idaho and MT activated numerous National 

Guard Type I and Type 2 helicopters this past summer. 

These examples illustrate some ofthe challenges faced by states this season and the federal 

agencies should engage state forestry agencies as equal partners to update the National 

Wildland Fire Aviation Strategy, and clarify language in the memorandums of understanding, 

cooperator standards and mobilization guides to facilitate continued interagency use of state 

aircraft with an efficient and consistently implemented cooperative approval process. 

State and Local Wildland Fire Responders 

The Forest Service (SF A) and (VF A) programs are the fundamental federal assistance programs 

that states and local fire departments use to develop preparedness and response capabilities for 

wildland fire management. They provide crucial financial and technical assistance to support 

state and local fire management activities, including preparedness, planning, training, hazardous 

fuels treatments, and the purchase and maintenance of equipment. 

Continued support and sufficient funding is needed for the SF A and VF A programs. These 

programs' recognize the essential role of state and local government in responding to and 

managing wildland fires and help to ensure these entities can respond effectively to wildland 

fires on all jurisdictions. 

In FY 2014, the SPA program directly funded hazardous fuel treatments on 111,002 acres (with 

another 120,241 acres treated with leveraged funding) and provided assistance to communities 

around the country, supporting 3,117 risk assessment and fire management planning projects and 

9,972 prevention and education programs. However in many states and localities, funding cuts 

have drastically impacted wildfire emergency response and preparedness capacities. Recent 

changes to the national VF A funding allocation methodology caused a 75 percent decrease in 

grants to rural Alaska fire departments. 

sIr 
33 

There are two additional programs critical for supporting the capacity of state and local agencies; 

the Federal Excess Personal Property (FEPP) program and the Firefighter Property Program 

(FFP). Over a five-year period (2008-2012) this program delivered more than $150M annually 

in equipment used to fight wildfires. 

The FEPP Program loans federally owned property to state forestry organizations and their 

cooperators for use in responding to wildfire. This includes equipment such as trucks, fire tools, 

hoses, vehicle parts, nozzles, generators, air compressors, fire protection clothing, aircraft, and 

aircraft parts. While the FFP gives firefighters access to Department of Defense property for use 

in firefighting and other emergency services. Further, FFP allows ownership to pass from the 

federal government following a specified period of use. 

These two programs are crucial to rural communities and for many small fire departments as 

federal excess equipment may be the only affordable equipment available to them. States and 

local fire departments are more often the first responders to fires they utilize the equipment 

these federal excess property programs provide to keep wildfires small and contained, provide 

major cost-savings to states and their cooperators, and offer the critical protection for adjacent 

communities. 

Continued federal assistance is needed so that all these programs will continue to help the many 

thousands of communities at risk to prepare for and mitigate the risks associated with wildland 

fire. 

Proactive Forest Management and Cost of Wildland Fire Suppression 

While not a focus for this hearing, members of this Committee are aware the Forest Service once 

again exhausted its available fire suppression funds to fight wildfires and was forced to transfer 

$700M in FY 2015 from non-fire programs to pay for fire suppression costs. This interferes with 

ongoing work in the field and delays or completely stops new contracts for all types of activities 

including those that contribute to reduced wildfire risk across forested and rangeland landscapes. 

This is the eighth time since 2002 that the Forest Service has needed to invoke its transfer 

authority to pay for shortfalls in fire suppression needs. In total, the agency spent $1.7 billion on 

fire suppression in FY 2015 and in Alaska the state spent a record $82M to $84M this fire season 

Meanwhile, the DOl has had to transfer funds from non-fire programs to pay for fire suppression 

six times since 2002, though fortunately DOl did not have to carry out fire transfers in FY 2015. 

Fire transfers represent just one pait of the broader wildfire funding problem. In recent years, the 

portion of the Forest Service and DOI budgets allocated to fire programs has grown while the 

overall budgets for the agencies have remained relatively flat. As more funding is allocated to 

fight fires, less is allocated to other areas of the Forest Service and DOl budgets. Suppressing 

fires is becoming more expensive and complex as a result of prolonged drought, lack of active 

forest management, and more people moving into WUI areas. As an example, in 1995 the Forest 

Service's fire programs budget represented 16 percent of the agency's total budget; in 2015, over 

50 percent of the agency's total budget was dedicated to fire. 

61 a 
34 

The NASF urges Congress to enact a permanent solution this year to resolve the wildfire funding 

problem. Specifically, NASF supports a solution that allows access to disaster funding, 

eliminates the negative impacts of transfers on other programs, and addresses the increasing 

costs of fire suppression. NASF supports the bipartisan Wildfire Disaster Funding Act (S.235, 

H.R.l67) along with a diverse group of over 260 other organizations. NASF greatly appreciates 

the recognition by members of this Committee and others in Congress that the current budgeting 

framework and status quo for wildfire suppression funding is broken. We welcome the 

opportunity to work with Congress to identify a bipartisan solution. 

Conclusion 

Thank you for the opportunity to appear before the Committee today on behalf of the Alaska 

Division of Forestry and the National Association of State Foresters. Wildland fire response is 

one of the most challenging facets of our jobs. The NASF and I stand ready to assist the 

Committee in finding ways to address the challenges we all face as the wildland fire problem 

continues to grow and consume larger and larger portions of our state and federal budgets. 

Finally, I would like to thank the Committee for its continued leadership and support of efforts to 

both respond to wildland fire and to take the necessary actions to address the underlying causes 

through increasing active management of all forestlands. 

71 p g E' 
35 

Attachments 

Figures l-7 

Sl r g e 
Acres burned 1950-2015 with 11-yearroliing average 

Fi&ure 1,- History ofacresburned by year if! Alaska average b'{elevenyea

increments. Note the significantjump in the running average that began in 2:004• 
I 6/20 I 6/25 

Figure 2."' Number oflighting,strikes (61KJ Alaska cluri.ng a critical seven day 

period in the 2015 fire season and the number of new fire starts .each day. 
38 
39 
40 
41 
42 
43 

The CHAIRMAN. Thank you, Mr. Maisch. 

Dr. Covington, welcome. 

STATEMENT OF DR. WILLIAM WALLACE COVINGTON, REGENTS’ PROFESSOR OF FOREST ECOLOGY, AND DIRECTOR, 

ECOLOGICAL RESTORATION INSTITUTE, NORTHERN ARIZONA UNIVERSITY 

Dr. COVINGTON. Chairman Murkowski, Senator Cantwell, members of the Committee, thank you so much for the opportunity to 

testify before you today about a problem that’s important to all of 

us. It’s been important to me for almost 50 years now. 

My name is Wally Covington. I’m Regents’ Professor of Forest 

Ecology at Northern Arizona University (NAU) and Executive Director of the Ecological Restoration Institute which was established 

in 2004 by Federal authorizing legislation. We have three institutes, one at Arizona, one at Colorado and one at New Mexico. All 

of them, working together to provide the best available information 

that can be had for restoring forest health and preventing the 

kinds of devastating fires that we’re talking about today. 

Being at NAU for over 40 years now I have had the opportunity 

to teach fire ecology and management, wildlife forest operations, 

virtually any topic in the area of forestry and I’ve also conducted 

research, primarily fire-based research, confronting the problem of 

steadily increasing wildfires. 

In 1976 I’d been there for just a year when my house was threatened by a fire which was then called the biggest and most devastating fire in Arizona history. It was almost 4,700 acres. And 

then during this 40 years I’ve seen these increasing gradually, you 

know, to 10,000, 20,000, 50,000, and now hundreds of thousands of 

acres. 

At no great surprise we’ve seen a couple of things happening. 

One is that we see fuel building up in the understory of frequent 

fire forests, like Ponderosa Pine forests. And then in forests that 

naturally have catastrophic fires like Lodgepole Pine, Spruce, Fir, 

interior Alaska forests, we see landscapes becoming more and more 

homogonous. So larger and larger patches of the land are available 

to burning. 

The other thing that has driven this clearly has been an increase 

in the severity and duration of fires, of the fire season. We’re now 

seeing fires burn in at times of the year that are completely unprecedented. We have fires now, we’ve had fires in Arizona called 

the January fire and the February fire because we never had fires 

during that period of time. And now they’re coming. They can burn 

just about any time of year. 

So my testimony then has five major points, and I’m just going 

to highlight that briefly. 

The disruption of natural fires has resulted in a shift in fire regimes and frequent forest types like Ponderosa Pine from surface 

fires to crown fires. The attempted suppression of fire in areas that 

are naturally catastrophic fires, like I mentioned before, has resulted in more homogonous landscapes that require heroic efforts 

to try to suppress. 

My final point is that the research has shown that there are 

things we can do about it. One in crown fire regimes where fires 
44 

are natural, we can break up fuel continuity with fire breaks. You 

thin it out. You make it so that instead of a million acres being 

available to burn, maybe you have 50,000 acres available to burn. 

That’s one approach. 

In frequent fire forests you need to thin across the landscape and 

remove the excess trees that have come in since fire suppression, 

conserve the old growth trees and then start burning on a natural 

cycle. In that way these forests are consistent with their evolutionary environment, no threat to endangered species. Watersheds are 

protected and so on. 

We’ve looked at fires post fire. We’ve had, as you know, some 

very large fires in Arizona, half million acres plus. And one of the 

projects that has been particularly instructive to us was to look at 

the wall of fire, post wall of fire, look at what happened there and 

then use a Forest Service developed fire behavior models to determine what the fire behavior would have been had treatments been 

put in place beforehand, different treatments then we had. 

What we found was that if you just focused on urban wildland 

interface treatments, you could reduce the fire size by about 12 

percent. You could reduce flame lengths by about 6 percent. However, if you strategically located these treatments across the entire 

landscape, you could reduce the size of the area burned under high 

severity by 40 percent and flame lengths by 30 percent. 

So in closing I’d just like to say that there is strong science available to help inform how we can do these preventive treatments, 

and using that science we have demonstrated, as have others, time 

and again that an ounce of prevention is worth a pound of pure. 

If you invest up front you can save houses, you can protect lives, 

and you can restore landscapes for current and future generations. 

Thank you. 

[The prepared statement of Dr. Covington follows:] 
45 

William Wallace Covington 

Regents' Professor of Forest Ecology and 

Director, Ecological Restoration Institute 

Northern Arizona University 

Testimony before the Committee on 

Energy and Natural Resources 

U.S. Senate 

Hearing to Review Past Wildfire Seasons to Inform and 

Improve Future Federal Wildland Fire Management Strategies 

November 17, 201S 

Chairman Murkowski, Senator Cantwell, and members of the Committee, thank you for this 

opportunity to testify on a subject of personal importance to me and of critical importance to 

the health of our nation's forests and the people and communities that depend upon them. 

My name is Wally Covington. I am Regents' Professor of Forest Ecology at Northern Arizona 

University and Director of the Ecological Restoration Institute. 

I have a Ph.D. in forest ecosystem analysis from Yale University and have been a forestry 

professor at NAU since 197S. 

Over the past 40 years I have taught graduate and undergraduate courses in ecological 

restoration, ecosystem management, fire ecology and management, forest management, range 

management, wildlife management, watershed management, and forest operations research. 

During that same period I have worked on long-term research in fire ecology and management 

in ponderosa pine, mixed conifer and related ecosystems. In addition to my publications on 

forest restoration, I have co-authored numerous scientific papers on a broad variety of topics in 

forest ecology and resource management including research on fire effects, prescribed burning, 

thinning, range management, wildlife, forest health, and natural resource conservation. 

My testimony has five main points: 

1. The disruption of natural fire regimes across the western U.S. has created excess fuels 

and the rise of megafires; 

2. A restoration-based approach including thinning and prescribed burning is imperative to 

safely reduce fuels and restore forest health-it's too late for fire alone to restore most 

ofthe landscape; 

3. We must act at the pace and scale ofthe problem if we are to restore our forests and 

protect communities from devastating and costly wildfires; 

1 
46 

4. Best-available science and comprehensive analysis is necessary for informed decisions 

that address current fire and forest health problems; and 

5. Strategic location of restoration treatments across landscapes and across jurisdictions is 

required. 

Although the general principles that I will discuss apply to the vast majority of the West's dryer 

forest types, I will focus my testimony on ponderosa pine and dry mixed conifer landscapes. As 

the GAO has pointed out, over 90 percent of the severe crown fire damage nationally is in this 

forest type. 

Megafires-unnatural fires that burn entire landscapes at scales of 100,000 to 1,000,000 acres 

are becoming the norm. Over the next 40 years the outlook is for increasingly large and severe 

fires with ever more devastating impacts on people and the rest of nature. Large scale 

restoration and management is absolutely essential for minimizing costs and maximizing 

benefits for current and future generations. 

The Ecological Restoration Institute: Bridging the gap between science and action 

The Ecological Restoration Institute at Northern Arizona University is a nationally recognized 

leader in forest restoration and wildfire. It was authorized by Congress in 2004 {PL108-317) to 

assist land managers and diverse stakeholders to understand, implement and monitor practical 

science-based forest restoration treatments designed to reduce the risk of severe wildfires, 

improve the health of dry forest and woodland ecosystems, enhance watershed function, 

provide jobs, and improve the quality of life for communities and citizens in the West. 

Conducting scientific research, transferring the best available science, and reaching out to land 

managers and stakeholders are core functions ofthe ERI. 

The cause of megafires 

Wildfires in dry forest types have changed in size and severity to levels that would have been 

unthinkable even 15 years ago. Due to past management practices, dense, unhealthy forests 

are overstocked with flammable debris and provide ample fuel for high-severity crown fires 

that kill old-growth trees. These catastrophic fires are difficult and costly to contain, and can 

ignite hundreds of spot fires as far as 2 to 4 miles ahead of a blaze in high winds. 

Research shows that, in addition to excess fuels, climate change is influencing the frequency 

and size offires. One of the ways this is playing out is in the boom and bust of wet and dry 

seasons. During wetter years, fuels build up. As drought conditions set in during drier years, the 

abundant fuels become tinder dry, and when they ignite, the fires take off. 

Disruption of natural fire regimes has caused a shift from natural surface fires to unnatural 

crown fires 

2 
47 

Frequent low intensity surface fires, fires that burn through grassy understories with 2-3 foot 

flame lengths, shaped the plants and animals that constitute the dry forest types of the West. 

Over eons these natural fires occurred once every 2-20 years preventing tree population 

irruptions and excessive fuel accumulation and maintaining open, park-like landscapes 

maintained by frequent low intensity fires. Such fires are the central self-regulating mechanism 

in these landscapes. 

Fire exclusion in frequent fire forests has resulted in tree population irruptions and steadily 

accumulating hazardous fuels over vast landscapes. Before settlement frequent fire forests 

typically supported stand densities of 15-75 trees per acre and fuel loads of 2-5 tons per acre. 

Today those same stands are choked with 300 to 1000 trees per acre in dense forests and have 

fuel loads of 20-80 tons per acre. These unnaturally dense forests with excess fuel accumulation 

now support unnatural crown fires-fires that burn through the tops of the trees killing them 

and stripping the land of protective cover that would otherwise prevent soil erosion and 

downstream flooding. 

Crown fires are not consistent with the evolutionary environment of frequent fire landscapes. 

As such they pose the greatest threat to biological diversity, natural resource values, and the 

communities of the West. 

It's too late for controlled burning alone to protect communities and restore forest health 

These deleterious changes in dry forests were well known to ecologists and foresters since the 

1940s. However, with few exceptions, little was done to reverse the trend of deteriorating 

forest conditions. In the 19S0s, prescribed burning (controlled fires set by managers under 

specific conditions) showed promising results. But fuel accumulations were already so great in 

the 19S0s that many of those fires were very difficult to contain. 

By the 1970s when I started my research into how to reduce crown fire threats and restore 

forest health, I worked with the Forest Service, the Bureau of Land Management, and the 

National Park Service to initiate a set of long-term research and application projects designed to 

remedy the fuel accumulation problem. For the first six years we focused on trying to develop 

controlled burning prescriptions that would reduce surface fuels and thin out excess postsettlement trees. The results of these experiments were very disheartening. Although we were 

able to use controlled burns to reduce surface fuels, we could not find any conditions that 

would allow fire to thin post-settlement trees safely. In fact, instead of killing post-settlement 

trees, many of these fires killed the old growth trees which we sought to protect. Follow up 

research showed that smoldering combustion at the base of the old growth trees heated the 

base of the trees to lethal temperatures, girdling and killing them over time. Perhaps even more 

alarmingly, in several of the burns, fires climbed into the tree tops, threatening to escape. On 

several occasions it occurred to me that an escape fire might result in me becoming one of the 

shortest term appointments to the School of Forestry at NAU since its founding. 

3 
48 

The discovery that controlled burning alone could not safely reduce fuels and restore forest 

health led us to develop a more comprehensive approach, one based on ecological restoration 

principles. Accordingly, we focused our efforts on an integrated research program that had two 

major components. First, we used historical ecology techniques and converging lines of 

evidence to determine what the natural forest densities and patterns were and what the fire 

regime was before settlement. Second, we initiated a set of controlled experiments consisting 

of mechanically thinning and removing the unnaturally high densities of post-settlement trees, 

protecting old growth trees, and then introducing surface fire. 

The results of these restoration experiments were stunning. Old-growth trees which had 

become stagnated over the past century by competition with post-settlement trees began 

growing like teenagers. Previously sparse understories of grasses and wildflowers burst forth 

with a startling abundance of production and flowering, so much so that we had to install 

electric fences to keep elk and deer from hammering these small islands of lush vegetation. 

Butterfly and songbird abundance tracked increases in grass, wildflower, and shrub production. 

Importantly, hydrologic studies showed that snow pack increased (due to reduction of 

interception by excessive tree canopies), soil moisture improved, and more water made it 

beyond the rooting zone indicating that more could be available for spring and steam flow as 

well as ground water recharge. We are now working at watershed scales to quantify those 

effects. 

Our ongoing work examines how different levels and patterns of thinning impacts fire behavior 

and resource conditions. Both published results and those in process indicate that restorationbased thinning-thinning that closely follows pre-settlement tree densities and patterns-and 

recurring fire approximating natural fire return periods provides the best overall results for 

simultaneously restoring forest health, enhancing watershed function, conserving biological 

diversity, and protecting communities. However, as more and more trees are left in departure 

from natural densities, the risks of unwanted effects increases markedly. 

Naturally ignited wildland fires have potential for complementing mechanical thinning and 

prescribed fire to meet fuels reduction and restoration goals. However, at present there isn't 

adequate scientific evidence to support use of naturally ignited fires in dense forests as a 

reliable option for restoration at landscape scales. With the state of decline in forest health, 

current fuels accumulation, and uncharacteristic crown fire problems across the West, more 

research is needed to better understand strategies that bolster success of wildland fires for 

meeting ecological objectives across the landscape at all scales. 

Another major emphasis of our work at ERI is developing research to support wood utilization, 

as well as biomass utilization, as ways to help offset the cost of restoration for some portions of 

landscapes. In general, we are examining how we can convert excess post-settlement trees and 

biomass which are a liability, into assets that can help rebuild natural resource-based 

economies (and jobs) for the West. 

4 
49 

Strategic location of restoration-based fuel reduction treatments is essential 

These results indicate that under ideal circumstances, comprehensive restoration based on 

localized knowledge of pre-settlement conditions would produce the most beneficial outcomes 

in landscapes dominated by dry forests. However, ideal conditions do not exist across large 

landscapes. In most circumstances, lack offunding, inadequate access, and lack of biomass or 

commercial wood utilization infrastructure dictates that comprehensive restoration will be 

limited in many circumstances to only 20-30 percent of the landscape. 

This is where strategic location of treatments becomes paramount. Landscape modeling and 

analysis indicates that locating comprehensive restoration treatments to break up landscape 

fuel continuity is the best strategy. In such a manner highly valued landscape elements such as 

communities, critical wildlife habitats, key watersheds, and other vulnerable landscape 

elements can be protected by strategic allocation offire suppression forces when an ignition 

occurs under extreme fire weather conditions. 

Evidence exists that such an approach works. 

Evidence from Arizona 

Arizona is no stranger to megafires. The 2002 Rodeo-Chediski Fire and the 2011 Wallow Fire 

were two oft he country's first massive wildfires to make national headlines-each burned 

nearly 500,000 acres of forest. Over the past five years, megafires have threatened many 

Arizona communities, particularly during the driest months of May and June. 

Working with State and Private Forestry in the Washington Office ofthe Forest Service, 

Research Station researchers, and local Forest Service staff in 2012, we conducted an analysis 

ofthe Wallow Fire to estimate how strategic allocation oftreatments might have changed fire 

behavior across the 538,000-acre Wallow Fire footprint. We already knew that Wildland Urban 

Interface, or WUI, treatments implemented by the Apache-Sitgreaves National Forest had 

saved several communities from catastrophic fire, but we also wanted to know whether 

implementation of nationally developed Forest Service fuel reduction priorities would have 

changed wildfire outcomes across the landscape. 

Using a GIS based modeling approach based on fire hazard outputs and communities-at-risk we 

simulated Wallow Fire behavior under A) pre-fire existing conditions, B) conditions that would 

have existed with protection of communities-at-risk (WUI only) treatments, and C) conditions 

that would have existed with implementation oftreatments in all high fire risk areas across the 

entire landscape. 

The results indicate that treatment scenario 8 (treatments only in WUI) would have reduced 

crown fire potential across the landscape by 12 percent and flame lengths by 6 percent. In 

contrast, treatment scenario C (treatments in all high risk areas) would have reduced crown fire 

potential by 40 percent and flame length by 30 percent. This analysis supports the conclusion 

5 
50 

that the risk of megafires is best addressed by not only treating around communities, but by 

treating away from them as well in the greater landscape as a whole. 

How Arizona dodged two bullets during the 2014 wildfire season 

In 2014, two fires had the conditions, and the chance, to burn hundreds of houses and destroy 

some of the state's most coveted recreational tourist attractions, but they didn't. Unlike the 

Rodeo Chediski and Wallow fires, these are the fires that didn't make the headlines. 

Arizona's Slide Fire and San Juan Fire of 2014-which burned about 21,000 and 7,000 acres, 

respectively-are considered small, and almost insignificant by today's media standards. But 

they also provide examples of what the consequences of doing nothing could have been. Given 

the dry, hot, windy conditions at the times of ignition and the amount of fuel on the ground, 

both were poised to be record-breaking in severity and damage to property and resource 

values. However, fire crews and post-fire recovery teams have touted that strategically placed 

treatment areas provided critical fire breaks and helped fire crews prevent the megafire 

catastrophes that we have come to expect. 

The Slide Fire, in particular, could have burned ten times as many acres as well as hundreds of 

homes in the greater Flagstaff area. What helped prevent that from happening was the 

foresight ofthe Greater Flagstaff Forests Partnership and the U.S. Forest Service managers of 

the Coconino National Forest, which in years prior to the fire, implemented restoration-based 

hazardous-fuel reduction treatments. Based on the long-standing research at the Ecological 

Restoration Institute of Northern Arizona University, these treatments included protecting the 

older trees, mechanically thinning small, young trees in areas around the community to remove 

unnaturally high densities oftrees, and burning slash and ground litter to restore natural forest 

conditions-conditions that would not support catastrophic crown fires. The fact that there 

were treatments between Flagstaff area homes and the Slide Fire accomplished several things, 

perhaps the most important of which was that it enabled fire crews to safely conduct burnout 

operations and eliminated the threat of the devastating fire. 

The San Juan Fire also provided lessons about how treated areas did what they were designed 

to do: slow a fire's advance and restore a forest's natural ability to self-regulate. How a wildfire 

behaves when it reaches a treatment area is a good test of how those treatments work and 

would work over large landscapes. Fire crews and incident management teams reported that 

when the fire burned into areas that had been restored, it burned with low severity and on the 

ground, not in treetops. The dry, frequent-fire forests of the West evolved with this type of fire, 

a slow-moving, low severity surface fire that would remove young trees and revitalize 

understory grasses and forbs. Evidence from the San Juan Fire also suggests that the previously 

treated areas allowed fire crews to safely conduct burnout operations, thus enabling them to 

manage and control the fire. 

6 
51 

Landscape-scale forest restoration is vital to solving fire and forest health problems in the 

West 

While the San Juan and Slide fires and other examples in the West provide evidence that 

restoration-based fuel management treatments work, they are also clear indications that we 

cannot afford to be complacent. Forest conditions throughout the West are dominated by 

drought conditions across very large areas. For example in Arizona alone, we still have 15 

million to 20 million acres of forest, including ponderosa pine, pinyon juniper and mixed 

conifer-all primed to burn. It is not a matter of if they will burn, but when. 

Meanwhile, on a regional scale, forest health treatments and community protection projects 

are just dots on the landscape. They are not enough to save forests on a large scale. Research 

shows that more needs to be done than simply reducing fuel loadings around the WUI, where 

forested lands meet urban homes. The results from work at the Ecological Restoration 

Institute and elsewhere indicate that without conducting broader, strategically located 

restoration and hazardous fuel reduction treatments outside of the WUI, landscape-scale fires 

will continue to occur with devastating impacts on watersheds, wildlife habitat, and other 

natural resource values. Such fires under severe conditions can lob firebrands into communities 

even though the fires themselves may be several miles away. 

In the face of global climate change, the best hope for those of us in fire-prone dry forest 

landscapes is to have ecosystems restored to more natural and self-regulating conditions. Such 

systems are ready to cope with the changes likely to come our way. Just like in human 

medicine, a person has the best chance to fight off and recover from an illness when they are 

healthy. It is important to make sure our forests are in their most natural, healthy condition so 

they, too, are resilient to disturbances like fire, insects, disease, and climate change. 

Unless concerted actions across large multijurisdictionallandscapes are taken to reverse 

ongoing ecosystem degradation, the prospects look grim for the quality of life-not only for the 

forest and woodland ecosystems of the region, but also for the human populations that rely on 

them. 

As forests across the West continue to burn hotter and longer than ever before, it is clear we 

don't have much time left. By acting quickly and at larger scales, we can restore forest health 

and build resiliency, protect homes, save lives, and provide jobs. Not only that, but doing so will 

help prepare forested landscapes for whatever changes may occur in the future. 

7 
52 

The CHAIRMAN. Thank you, Dr. Covington. 

Mr. Zerkel, welcome. 

STATEMENT OF RICHARD ZERKEL, PRESIDENT, 

LYNDEN AIR CARGO, LLC 

Mr. ZERKEL. Madam Chairman, members of the Committee, 

thank you for this opportunity to discuss aerial firefighting policy 

with you today. 

My name is Rick Zerkel, and I’m the President of Lynden Air 

Cargo, an all cargo operator of L382G aircraft based in Anchorage, 

Alaska. 

Lynden’s seven aircraft are the civilian version of the Lockheed 

C130 and are operated under Federal Aviation Administration Part 

121 Air Carrier Regulations, the same requirements followed by all 

major U.S. airlines including Delta, American and United. This is 

the highest safety standard under FAA regulations. 

The U.S. Forest Service is currently operating one C130H under 

public aircraft rules and plans to add more. This is in direct conflict with the findings of the 2002 Blue Ribbon panel report to the 

Forest Service titled, ‘‘Federal Aerial Firefighting: Assessing Safety 

and Effectiveness.’’ And I’d like to read a couple of those findings 

real briefly. 

Under Finding 3, Aircraft. Under the current system of aircraft 

certification, contracting and operation key elements of the aerial 

wildland firefighting fleet are unsustainable. The FAA has essentially said. ‘‘It’s a public use aircraft. You’re on your own.’’ 

Under Finding 6, Certification. The Federal Aviation Administration has abrogated any responsibility to ensure the continued airworthiness of public use aircraft including ex military aircraft converted to firefighting air tankers. Although these aircraft are 

awarded FAA type certificates, the associated certifications do not 

require testing and inspection to ensure the aircraft are air worthy 

to prepare for their intended missions. The panel found that the 

Forest Service and BLM leaders do not have a good understanding 

of the FAA certification and oversight rule regarding public use aircraft. Just like the Blue Ribbon panel, we are opposed to the U.S. 

Forest Service operating a government-owned airline under public 

aircraft format for the purpose of fighting wildfires when qualified 

civilian aircraft are available. Lynden spent substantial capital in 

one year complying with the regulatory, technical and physical conversion of one of our Hercules in order to lease to a qualified operator under the next generation 2.0 solicitation. A very tight timetable and rigid requirements resulted in our aircraft being rejected 

while the U.S. Forest Service operated the first of seven C130H aircraft equipped with an obsolete dispersion system and operated 

without FAA oversight. By necessity the Lynden aircraft was deployed to Australia where it is in service to the National Aerial 

Firefighting Center. 

Our message this morning can be summarized in three main 

points. 

First, the commercial aerial firefighting industry is entirely capable of providing all of the Forest Service large air tanker requirements at considerably less expense than the current planned use 

of the C130H aircraft. 
53 

Second, the acquisition and use of the C130H, in this depends on 

the structure of the program, may be in conflict with Federal acquisition regulations and the Economy Act. 

Most importantly though, the non-regulated, public aircraft format proposed for the government-owned large air tanker fleet is inherently less safe than the rigorous standards a commercial fleet 

must adhere to and has set an unfair double standard. This double 

standard resulted in the most capable and safest firefighting aircraft being deployed elsewhere while an unregulated and expensive 

government aircraft fought fires in our country. 

More importantly we believe that regulatory certification and 

safety standards mandated by the FAA been established for a 

sound reason, to mitigate the possibility of loss of life and property. 

These standards should be applied to all aircraft operating in the 

harsh environment of aerial firefighting without exception. 

As we speak it appears the Forest Service intends to operate the 

C130Hs under the public aircraft category accepting responsibility 

for their continuing airworthiness and for certifying the design 

safety of the retardant tank installation. If the Coast Guard is retained as the engineering authority, the expertise of the FAA is 

completely removed from the process. 

The Forest Service has been very specific that all commercial 

large air tankers be modified in accordance with the very demanding and time consuming FAA certification process. Now the industry accepts these parameters and the time and expense it involve, 

but we strongly disagree the Forest Service should waive this requirement for itself and opt for the less stringent public aircraft option. There should be one safety standard for all aircraft involved 

in aerial firefighting and it should be the most robust safety standards contained in the FAA regulations. 

Lynden Air Cargo provides the following recommendations. Number one, commercial aircraft operators, including Lynden and others, are available and ready to meet aerial firefighting requirements of the Forest Service. We urge the Committee to provide direction to the Forest Service to utilize available and qualified aircraft prior to employing any government-owned aircraft. The U.S. 

Forest Service should be required to certify any aircraft they do operate, certify and maintain the aircraft and dispersant systems to 

the same rigorous standards as industry. And Number three, no 

funds should be authorized or appropriated to the Forest Service 

to acquire or upgrade additional aircraft until private industry has 

had an opportunity to respond to a final round of the next generation solicitation. As long as commercial operatives can meet the 

Forest Service requirements the Forest Service should refrain from 

competing. 

Madam Chairman and members of the Committee, I welcome 

your questions. 

[The prepared statement of Mr. Zerkel follows:] 
54 

Richard Zerkel 

President 

Lynden Air Cargo, LLC 

Testimony before the U.S. Senate Committee on Energy and Natural Resources 

Hearing to Review Past Wildfire Seasons to Inform and Improve Future Federal 

Wildland Fire Management Strategies 

November 17,2015 

Madam Chairman, members of the committee. Thank you for this opportunity to discuss 

Aerial firefighting policy with you today. 

My name is Rick Zerkel. I am the president of Lynden Air Cargo, an all-cargo operator 

ofL 382G Hercules aircraft, based in Anchorage, Alaska. 

Lynden's seven aircraft are the civilian version of the Lockheed C-130 and are operated 

under Federal Aviation Administration Part 121 Air Carrier regulations, the same 

requirements followed by all major US airlines; including Delta, American and United. 

This is the highest safety standard under FAA regulations. 

The USFS is currently operating one C-l30H under Public Aircraft rules and plans to add 

more. This is in direct conflict with the findings of the 2002 Blue Ribbon Panel Report to 

the USFS titled Federal Aerial Firefighting: Assessing Safety and Effectiveness -

FINDING 3-AIRCRAFT 

Under the current system of aircraft certification, contracting, and operation, key 

elements of the aerial wildland firefighting fleet are unsustainable. 

• FAA has essentially said, "It's a public-use aircraft. You're on your own." 

FINDING 6-CERTIFICATION 

The Federal Aviation Administration (FAA) has abrogated any responsibility to ensure 

the continued airworthiness of "public-use" aircraft, including ex-military aircraft 

converted to firefighting air tankers. Although these aircraft are awarded FAA type 

certificates, the associated certification processes do not require testing and inspection to 

ensure that the aircraft are airworthy to perform their intended missions. 

• The panel found that Forest Service and BLM leaders do not have a good 

understanding of the FAA's certification and oversight role regarding public-use 

aircraft. 

Just like the Blue Ribbon Panel, we are opposed to the USFS operating a Government 

owned airline, under the Public Aircraft format, for the purpose of fighting wild fires 

when qualified civilian aircraft are available. 
55 

Lynden spent substantial capital and one year complying with the regulatory, technical 

and the physical conversion of one of our Hercules in order to lease to a qualified 

operator under the Next Generation 2.0 solicitation. A very tight timetable and rigid 

requirements resulted in our aircraft being rejected while the USFS operated the first of 

seven C-130H aircraft, equipped with the obsolete MAFFS II dispersant system and 

operated without appropriate FAA oversight. By necessity, the Lynden aircraft was 

deployed to Australia where it is in service to the National Aerial Firefighting Centre 

(NAFC). 

Our message this morning can be summarized in three main points: 

• First, the commercial aerial firefighting industry is entirely capable of providing 

all of the Forest Service's Large Air Tanker requirements at considerably less 

expense than the current planned use ofC-130H aircraft. 

• The acquisition and use of the C-130H aircraft may be in conflict with the Federal 

Acquisition Regulations and the Economy Act. 

• And most importantly, the non- regulated, public aircraft format, proposed for the 

government owned large air tanker fleet is inherently less safe than the rigorous 

standards the commercial fleet must adhere to and has set an unfair double 

standard. This double standard resulted in the most capable and safest firefighting 

aircraft in the world being deployed elsewhere, while an unregulated, unqualified 

and expensive Government aircraft fought fires in our country. 

More importantly, we believe the regulatory, certification and safety standards mandated 

by the FAA have been established for a sound reason; to mitigate the possibility of loss of 

life and property. These standards should be applied to all aircraft operating in the harsh 

environment of aerial firefighting without exception. As we speak, it appears the Forest 

Service intends to operate the C-130H's under the public aircraft category, accepting 

responsibility for their continuing airworthiness and for certifying the design safety of the 

retardant tank installation. If the Coast Guard is retained as the engineering authority the 

expertise of the FAA is completely removed from the process. 

The USFS has been very specific that all commercial Large Air Tankers be modified in 

accordance with the very demanding and time consuming FAA certification process. The 

industry accepts these parameters and the time and expense involved, but we strongly 

disagree that the Forest Service should waive this requirement for itself and opt for the 

less stringent public aircraft option. There should be one standard for all aircraft 
56 

involved in aerial firefighting and it should be the robust safety standards contained in 

FAA regulations. 

We also contend that private enterprise is more experienced and efficient at meeting the 

demanding requirements including certification and operation of Large Air tanker 

aircraft. By default, this enables them to be more cost effective than Government 

managed operations. Congress realized this long ago and codified the idea that 

government should not compete with industry not only as a matter of policy but equally 

important, as a matter of efficiency. 

Lynden Air Cargo provides the following recommendations: 

1. Commercial aircraft operators, including Lynden and others, are available and 

ready to meet the aerial firefighting requirements of the USFS. We urge that this 

committee provide direction to the USFS to utilize available and qualified aircraft 

prior to employing any Government owned aircraft. 

2. The USFS should be required to certify and maintain the aircraft and dispersant 

systems to the same rigorous standards as industry. 

3. No funds should be authorized or appropriated for the Forest Service to acquire or 

upgrade additional aircraft until private industry has had an opportunity to 

respond to a final round of the Next Generation solicitation. As long as 

commercial operators can meet the Forest Service's requirements, the USFS 

should refrain from competing. 

Madame Chairman and members of the Committee I would welcome your questions. 
57 

The CHAIRMAN. Thank you, Mr. Zerkel. 

Mr. Burnett, welcome. 

STATEMENT OF MIKE BURNETT, FIRE CHIEF, 

CHELAN COUNTY FIRE DISTRICT 1 

Mr. BURNETT. Thank you very much, Madam Chair and Senators. Thank you for the opportunity to offer this testimony to the 

Committee. 

My perspective comes from that of a Fire Chief in North Central 

Washington as well as an incident management team member as 

a planning section chief, one of the type one teams that are put together on a national basis. 

The fire season for us in our county started in late June with the 

Sleepy Hollow fire in Wenatchee. We had 30 homes that were lost 

and three warehouses. Followed by the next tragic fire which was 

the Reach fire in Lake Chelan. The Reach fire combined with the 

other fires in the area became part of the Chelan Complex that 

grew to almost 90,000 acres and destroyed 51 homes and an additional three warehouses. Five days later we had the tragic loss of 

three firefighters outside of Twist, all that’s happened in North 

Central Washington. 

The 2015 fire season was also my busiest year as an incident 

management team member. Our team was deployed to four different fires, the Newby Lake fire which came out of Canada into 

Northern Washington, the National Creek Complex fire in Crater 

Lake National Park and then North Central Washington again for 

the North Star fire and the Tunk Block fire. 

Efforts are being made to address the growing costs and 

severities of wildfires. On a regional level the Okanogan/Wenatchee 

National Forest, BLM, the Washington Department of Natural Resources and all of the local fire districts have worked together to 

ensure that we work more collaboratively when a fire occurs. 

Recently our community hosted a one day summit titled, ‘‘The 

Wildfire and Us.’’ The goal of the summit was to develop a regional 

approach to reduce the risk of wildfires. Attended by approximately 

500 residents it was a great success and illustrated the interest 

that people in our region have on the subject. 

Locally Chelan County Fire District 1 has established a connection with the Forest Ridge Wildfire Coalition. Our department has 

partnered with the Forest Ridge Coalition to assist them with 

grant funding for fuel reduction projects, participates with their 

Fire Wise community outreach and has initiated an alert system 

to notify their board members who in turn activate their phone 

tree. 

From a local perspective if we’re to improve our ability to respond to wildfires, I believe that we need to address four issues: 

increase our efforts on education and prevention, support quicker 

initial attack, continue fuel reduction efforts, and allow for earlier 

utilization of air resources. 

Education and prevention needs to occur on a local level. Our 

firefighters are part of our community and they’re trusted, respected and capable of providing the education to the public. The 

problem is most rural fire districts have limited staffing due to 

funding. The Sleepy Hollow fire that I referenced earlier had ap-
58 

proximately 150 firefighters assigned to it, of which 120 of them 

were volunteers. 

Any Federal funding to support a wildfire education and prevention program would pay substantial dividends. Training local firefighters to perform home assessments, cost shares on hardening 

homes, conducting evacuation preparedness drills and education on 

the value of beneficial fires are all examples of a good prevention 

program. The value of a prepared community translates directly to 

a safer environment for firefighters. 

Next we need to augment the initial attack capabilities of local 

resources. I measure initial attack response times in minutes and 

catching a wildfire in hours. Local jurisdictions need resources 

available to them and much quicker than what wildland agencies 

are currently able to provide. We have—we need funding for the 

seasonal firefighters to be available on a local level so that the initial attack can be more robust and more rapid. These seasonal 

hires could also be used to enhance the community’s outreach with 

a focus on building a more fire adapted community. 

We need to continue the fuel modification efforts. The treatment 

area near the Beehive Reservoir just outside of Wenatchee is a 

great example of how it can reduce the impacts of wildfire. The 

Peavine fire in 2012 burned through the area, stayed on the ground 

as a surface fire and was stopped on a Forest Service road system. 

And last, the use of aviation resources early on can keep a small 

fire from becoming another expensive, large fire. Unfortunately as 

an incident commander from a local fire district I have to rely on 

the Forest Service or a state duty officer to arrive on the scene, 

make a determination if the fire is in their jurisdiction or a threat 

to their jurisdiction before a helicopter can be ordered. Most fire 

districts cannot afford the cost of air attack resources. If the State 

and Federal Government want the fire extinguished when they are 

small and manageable, we need the resources to do the job. Give 

the local fire chief the authority to call for them when they’re needed and have the State or Federal Government pay for it so that the 

local fire district is not financially devastated. 

I provided my perception of the complex issue. By no means do 

I feel that the system is broken; however, there are opportunities 

to improve our efforts via the funding for rural fire departments, 

enhancing education and prevention strategies and continuing fuel 

reduction efforts. 

In closing I want to thank the Committee again for hearing my 

testimony and I appreciate the opportunity to provide a voice in 

this important discussion. 

[The prepared statement of Mr. Burnett follows:] 
59 

November 13,2015 

To: US. Senate Committee on Energy and Natural Resources 

From: Fire Chief Mike Burnett, Chelan County Fire District 1 

Chairman Murkowski, Ranking Member Cantwell, and Committee Senators, 

Thank you for the opportunity to offer testimony to the Senate Committee on Energy and Natural 

Resources. It is an honor to represent the perspective of local fire chiefs in this extremely important 

discussion. In order to improve future wildland fire management strategies, the choices we make as 

individuals and at all levels of government need to be modified. It has been noted by experts in the field 

that fires are becoming more frequent with increased size and intensity. To address this fact we need to: 

• Allow natural fire on the landscape where it is not a threat to people and homes. 

• Increase education and prevention. 

o Enact codes and building standards for construction in the Wildland Urban Interface (WUT). 

o Create incentives for homeowners to ''fire harden" their homes. 

o Allocate funds and resources to increase education and prevention efforts. 

• Allow, and fund, prescribed fires and fuel reduction efforts. 

• Aggressively fight the fires "\-vhen they first start in order to keep them smaller and less expensive. 

• Better utilization of air resources. 

• Reprioritization of federal grants. 

The recommended solutions from subject matter experts will vary based on the individual's perception of 

the problem: facts are facts, but perception is reality. My desire today is to inform you of my perception, 

and hopefully add to the discussion, in order to frame a more common reality. 

lam a fire chief in North Central Washin!,.rton, which is home to Leavenworth, Chelan, Pateros, Brewster, 

and Wenatchee. Our area lost over 400 homes to wildfire in the last two fire seasons. Even more 

devastating is the loss of three firefighters who died this year trying to escape a fast moving fire outside of 

the town of Twisp. Chelan County Fire District I (CCFDI) is a combination fire department, which 

means we staff our stations with a combination of both career and volunteer firetighters. CCFDI 

encompasses the largest town in the area, the City ofWenatchee, and our entire jurisdictional boundary is 

truly WUI country. Our annual budget is approximately $6 million, which is more than twice any other 

fire district in the area. In the two neighboring counties, there are only 48 career firefighters. Of those 

firefighters, l1 are typically on duty at any given time with seven of them fi·om CCFD1. We, like many 

fire depatiments across the country, rely heavily on the support of volunteers to aid in the protection of 

our communities. 

Tam also fortunate enough to participate on one of the 16 National Type 1 Incident Management Teams 

(!MT) as the Planning Section Chief These teams are geographically located throughout the country and 

are deployed to incidents of national significance with the highest level of complexity_ This experience 

has allowed me to aid other communities in their battles against wildfires and has given me a better 

understanding of the values, complexities, and restraints of fighting wildfires where multiple agencies and 

1 
60 

jurisdictions are involved. On the less positive side, there are frequently competing interests, differing 

policies, and cost allocation issues. On the positive side, sharing of resources, combining of expertise, 

funding of aircraft, and development of common objectives are all extremely valuable to citizens. 

Every year, North Central Washington experiences a very active fire season. The intensity and duration of 

our fires has been increasing over the last few years. ln 2014, the Carlton Complex alone burned over 

250,000 acres and destroyed over 300 homes In 2015, over 900,000 acres burned with the largest fires 

being: 

Chelan Complex- 88,985 acres 

Carpenter Road- 63,972 acres 

• Okanogan Complex- 133,450 acres 

• North Star-218,138 acres 

• Tunk Block Fire 165,918 acres 

• Wolverine- 65,512 acres 

• Kettle Complex- 73,392 acres 

Thousands of firefighters were deployed and hundreds of millions of dollars spent, yet we still lost 

hundreds of structures and most importantly, we lost the lives of three young men. 

This past fire season started for us in June following multiple days of 100+ degree temperatures. On June 

28th at 2:16 in the afternoon, a small human-caused fire was reported at the base of a hilL The fire was 

very visible fi·om the nearby highway and our 911 center received multiple reports of the fire. The fire, 

named the Sleepy Hollow Fire, ultimately grew to 2,950 acres. The initial response came from local fire 

districts; all volunteer resources with one engine stafJed with career firefighters. The initial attack incident 

commander (lC) requested additional local resources and notified our State and Federal partners: 

Department of Natural Resources (DNR) and the Okanogan/Wenatchee National Forest (FS). By 4:00pm, 

the IC had called for a second alarm response, followed by a third alarm, which dispatches all ofthe 

predetermined resources in our region. He also had the Duty Officers from DNR and the FS on site 

assisting with coordinating efforts. Throughout the afternoon, firefighters worked in triple digit 

temperatures and were successful in protecting over 50 primary residences directly threatened by the fire 

in the Sleepy Hollow neighborhood. The fire travelled a little more than a mile in flVe hours, at which 

time we experienced an increase in wind and fire behavior. This caused the fire to travel an additional 

mile in about one hour. Unfortunately, at the end of that mile was a housing development built on top of a 

steep ravine, which was loaded with old-growth sagebrush. This resulted in the destruction of 30 homes. 

The fire also spotted more than a mile away into a commercial warehouse district. The spot-fire took hold 

on a roof of a chemical warehouse and then spread to the roofs of two additional fruit packing 

warehouses. Late into the evening, every available engine was assigned to the incident. For several hours, 

the only fire protection left for our area was a Crash Rescue truck from the airport. The estimated direct 

economic loss was over $110 million dollars. Indirect, long-term losses to the community have yet to be 

determined. 

Chelan County's next tragic event occurred on August !4 just outside of the town of Lake Chelan. A 

lightning-caused fire was reported on the hill behind the town. Shortly thereafter, several additional fires 

were reported in the area. These fires eventually became the Chelan Complex, which covered 88,985 

acres. Within hours of the first report of the fire, homes were being lost. Over the next 24 hours, 51 

structures and 3 fruit packing warehouses were destroyed by fire. 

Both of the fires described above, and the vast majority offtres in our region, are similar in nature; 

• The destroyed homes are inside of a fire protection district, or city, which is sunounded by State 

or Federal ground. 

2 
61 

• The fires start near an interface area and quickly threaten structures 

• The fire departments lack the funding to pay for air resources and the early use of air resources 

may have made a difference. 

• There are firefighters on scene in a short period of time but the fires quickly overrun the capacity 

of a rural volunteer, or combination, fire department. 

State and Federal resources engage, but due to their primary responsibilities as wildland 

firefighters, they are slower to react to urban interface fires, limited on initial attack capabilities, 

and are not as suited for structure protection. 

• Most of the homes are in vulnerable locations and are not fire hardened through building 

materials, design, or landscape modifications. 

Beside the Sleepy Hollow Fire, and multiple smaller fires within our tlre district, Twas deployed with our 

IMT to the Newby Lake Fire, which was the fire that started in Canada and grew into northem 

Washington. Later the IMT was deployed on a 30-day assignment, first to the National Creek Complex in 

the Crater Lake National Park followed by a reassignment to the North Star Fire and the Tunk Block Fire 

in North Central Washinbrton. In all cases, the basic objectives were the same; protect life and property, 

minimize acres burned, utilize cost containment best practices, enhance relationships with the community 

and stakeholders, and at all times base actions on a deliberate risk assessment. 

There has been a continuous effort to improve fighting wildfires in our region. We have improved the 

working relationship between all government agencies. Our local fire districts have a standardized 

Cooperators Agreement with the Okanogan/Wenatchee National Forest. Radio frequencies are 

standardized to improve our communication capabilities. Wildland certifications are reviewed and 

approved by a multijurisdictional panel with representation fi·om DNR, FS, BLM, and local fire districts. 

Annual training is conducted for all agencies utilizing a mixed cadre from all disciplines. We hold bimonthly meetings for all North Central Washington fire agencies including BLM, FS, and DNR. Yet, 

even with these practices in place, changing environmental conditions and increasing fire behavior make 

it imperative that we work collaboratively with partners and increase our community-wide efforts. 

There is a growing awareness that our community needs to do more to educate and inform residents on 

how to live with wildfires. Chelan County has two established wildfire coalitions, Forest Ridge outside of 

Wenatchee and the Chumstick outside of Leavenworth. Recently, active community members came 

together to put on the "Wildfire and Us Summit!! in Wenatchee. The summit was dedicated to exploring 

what can be done by everyone involved: landowners, cities and counties, and state and federal agencies. 

The goal was to develop a comprehensive, cooperative, and collaborative regional approach to reduce the 

risks of wild tire loss. The event was free to the public and an estimated 500 people attended. With the 

increase of severe wild tires, a conscious education effOJi like this Summit, and programs like Firewise, 

more neighborhoods are asking what they can do to make their area a Fire Adapted Community 

Partnerships between the fire districts and their communities are improving. Forest Ridge Wildfire 

Coalition (FRWC) and CCFDI have worked together to obtain grant funding for fuel reduction projects. 

DNR has provided cost share grants for chipping projects. CCFDI attends the FRWC board meetings and 

participates in their Firewise Community eftbrts. A direct aleti system to their board members has been 

established to facilitate rapid information transfer and evacuation. This system has been utilized several 

times for fire information and evacuation notices. 

From my perspective, there is still work to be done and areas that need to be strengthened. I believe in 

order to improve our ability to respond to the negative impacts of wildfire we need to address these 

issues: 
62 

• Increased education and prevention. 

• Continued fuel reduction. 

Quicker initial attack. 

• Better utilization of air resources. 

• Reprioritization of federal grants. 

In order to change the public's perception of wildfire and their involvement in the problem, we will need 

to increase our education and prevention etforts. Utilizing the "3-E1

S11 , Educate, Engineer, and Enforce, 

over time we can change behavior and attitudes; seatbelts are an excellent example. The construction 

industry has already engineered building materials and improved construction methods to make the home 

more fire resilient. We also have the WUI Codes ffom the International Code CounciL Communities need 

to adopt those codes and enforce those standards (the City of Wenatchee adopted them in 2011 ). 

Homeowners make a conscious decision to build in the WUI and therefore need to take appropriate action 

to make their home more fire resilient. lt is also our responsibility to educate that same homeowner on 

concepts such as: not all fire is bad, there wit! be times in the spring when we put smoke in the air through 

prescribed burns, we will not risk lives to save your home, and there are resources available to you to help 

make your home more defensible. 

Our firefighters are part of our community. They are trusted, respected, and capable of providing the 

education to the public. The problem is most rural fire districts have limited staffing due to funding. The 

Sleepy Hollow Fire referenced earlier had approximately 150 firefighters assigned to the fire, of which 

120 of them were volunteers. With very few career personnel available, the workload is focused on 

emergency response as opposed to proactive preventioR Any targeted federal funding to suppott a 

wildfire education and prevention program would pay substantial dividends. Training local firefighters to 

perform home assessments, cost shares on hardening homes (i.e.- changing out shake roofs), conducting 

evacuation preparedness drills, and education on the value of beneficial fires. are all examples of a good 

prevention program. The value of a prepared community translates directly to a safer environment for 

firefighters! 

We need to continue fuel modification etTorts. A portion of this effort involves correcting perceptions that 

fuel modification is a "scam'' by the government to harvest more trees or that government employees are 

not able to perform the operation safely. Fuel modification in the form of prescribed burns or shaded fuel 

breaks have proven to be effective in reducing the spread of wildfire. A treated area does not stop the fire 

but it can give us a chance to catch the fire. For example: over the last decade, the FS performed fuel 

treatments followed by prescribed burns around the Beehive Reservoir area just outside of Wenatchee. 

During the 2012 Wenatchee Complex there were over 60 tires burning. One of the larger fires was the 

Peavine Fire at over 19,000 acres. Fire personnel utilized this treatment area to safely control the 

perimeter of the fire heading towards the Forest Ridge subdivision less than two miles away. 

The initial attack is the best opportunity to catch a fire; statically most tires are caught on initial attack. 

From the perspective of a local fire chiet~ our initial attack response time is measured in minutes, and 

catching wildfires is measured in hours. The perspective of a wildland agency is different. The initial 

attack response time is measured in hours, and a fire being caught is measured in days. Local jurisdictions 

need resources available to them much quicker than the wildland agencies are currently able to provide. If 

a local fire district is involved in a wildland fire there will be a WUI component, and the option to not 

suppress the fire will not exist. We need more funding for seasonal firefighters to be available on a local 

level so the initial attack can be more robust and more rapid. We also need additional support from 

FEMA's Staffing for Adequate Fire and Emergency Response (SAFER) Grants. The SAFER program 

4 
63 

should be expanded to assist fire prone communities with seasonal hiring. These seasonal hires could also 

be used to enhance the community outreach with a focus on building a more fire adapted community 

The utilization of air resources is controversial and expensive. The homeowner believes a retardant drop 

alone will put out the fire and the fire chief knows the cost of retardant would cripple their budget. 

Frequently, a wildland fire is inaccessible to conventional fire department apparatus. The use of aviation 

resources early on could keep a small fire from becoming another expensive large fire. Currently an IC 

from a local fire district must rely on a FS or DNR Duty Officer to anive on the incident and make a 

detennination on the appropriateness of the use of helicopters or air tankers. As a rule of thumb, "the 

agency that calls for it, pays for it" so the Duty Officer needs to determine if the fire is either in their 

jurisdiction or is a threat to their jurisdiction. 

Here is an example: A five to ten acre brush fire across the Columbia River, with poor access, took 45 

minutes for the first fire apparatus to arrive. DNR was notif1ed and a helicopter was requested. The fire 

was outside ofDNR's jurisdiction and they couldn't/wouldn't authorize the expense. A helicopter 

operating for 1 0 hours in support of the ground firefighter would have cost, on the high side $30.000 ( 10 

hours x $3,000 an hour). Instead, the local fire department went through all their resources, all the 

available neighboring resources and then requested State I\.1obilization. The mobilization was authorized 

and the fire ended up costing the state around $!75,000, when it could have been handled t<1r around 

$30,000. Like the Sleepy Hollow Fire, which took almost two hours to get the first helicopter on it, this 

lire started out smalL Local fire districts in North Central Washington cannot alford one bill for $30,000 

let alone the cost of an entire fire season. If the State and Federal government want the Hres extinguished 

·when they are small and manageable, we need the resources to do the job, Provide funding for early 

helicopter (initial attack) use with state or federal funds. Give the local fire chiefs/IC's the authority to call 

for them when they are needed. Have the State or Federal government pay tOr it so the local fire district is 

not financially devastated from the cost. This process will save money by keeping the tires smaller and 

more manageable. 

Local fire departments have two major federal grants available to them, FEMNs SAFER grant, which 

was addressed above, and the Assistance to Firefighters Grant (AFG). The majority of the FEMA Grant 

awards go to larger organizations which arc much better funded, better staffed, and have strong 

neighboring departments to help them out during major emergencies. That is not the case in most of the 

communities where homes are being lost to wildfires. Many rural fire departments rely on used military 

equipment for their wildland apparatus. There should be a better method of prioritizing grant funds to 

rural departments. 

l have provided my perception of a complex issue. By no means do I feel the system is broken. There are 

many good efforts being performed with a common goal of reducing the risks from wildfires. However 

there are opportunities to improve our efforts via funding for rural fire departments, enhancing education 

and prevention strategies, and continued tllel reduction efforts. Our citizens recognize the need, and have 

the expectation, for us to address how we can improve our response to wildland fires. The problems we 

face are becoming more complex reinforcing the need for action 

In closing, I want to thank the Committee again tOr hearing my testimony and I appreciate the opportunity 

to provide a voice in this important discussion on how to improve future federal wildland fire 

management strategies. 

Sincerely, 

Mike Burnett, Fire Chief 
64 

The CHAIRMAN. Thank you, Chief. 

Mr. Wyss, welcome. 

STATEMENT OF JON WYSS, CHAIRMAN, OKANOGAN COUNTY 

LONG TERM RECOVERY GROUP 

Mr. WYSS. Senator Murkowski, Senator Cantwell and members 

of the Committee, thank you for holding this hearing today. 

I was born in Thermopolis, Wyoming, son of a seventh and 

eighth grade science teacher and raised in Worland, Wyoming just 

east of Yellowstone National Park. Growing up in Wyoming allowed me to have great respect for our natural environment, natural resources, natural parks and people. It also allowed me to see 

my first wildfire disaster in 1988 when Yellowstone was set ablaze 

by a lightning strike. Who knew 27 years later I’d be in the middle 

of back-to-back wildfires in Eastern Washington which have destroyed over 500 structures in a community with less than one percent vacancy rate. 

After graduating high school I attended college in Texas, and I 

worked for the U.S. Bankruptcy Trustee offices in four separate 

states, then served as a Chief Deputy Assessor in Spokane County 

and even served three days as a state senator when Senator Benson was on military leave. I now work for my wife’s family company, Gebbers Farms, who provided suppression resources in 2014 

and in 2015. We also lost 7,000 acres of our private timberlands 

that abut the Forest Service and DNR. 

My upbringing and background and Chair as the Long Term Recovery Group give me a perspective at looking how these fires disrupted our communities. The 2015 Washington wildfires consumed 

one million acres and consisted of eight fires. The fire storms called 

multiple level 3 evacuations including my own home. When it came 

time to evacuate not all the memories could be packed up, not all 

the animals could fit in one trailer and so gates swung open, fences 

were cut and animals were left to fend for themselves. 

When people could return some came back to their homes standing. Others lost everything including their animals, only to be 

known by the bangs tag in the dead animal’s ear. Then as the fires 

raged on and the winds picked up we heard over the radio a call 

that no firefighter ever wants to hear. We have seven firefighters 

trapped. 

On that fateful day the bell rang for the last time for three brave 

souls, excuse me, as they tried to escape. We pay our respects to 

the victims and their families where they sacrificed everything. 

At the time Washington State’s FEMA application, an estimated 

$123 million in suppression costs were expended. We question if 

some of these costs could have been avoided with better real time 

weather information. The National Weather Service Doppler radar 

network has a gap in coverage in our state where we can’t see 

below 10,000 feet in Chelan, Douglas or Okanogan Counties where 

most of these fires occurred. 

In Washington State the U.S. Forest Service has four times more 

land than that owned by the state. Over the last 27 years we’ve 

seen a change in forest management practices and a decline in timber harvest in our state. By not allowing fires to burn as they historically have or thinning out all the trees that have resulting 
65 

growing up we’ve increased the fuel load and lowered the timber 

value and increased chances for massive wildfire. 

After back-to-back fires many are saying log it, graze it or watch 

it burn. But we do not want to promote unabated logging and landscape alterations. Common ground can be found on these issues. 

A local rancher and forester told me, ‘‘We must remember, fire 

is good for the environment when it can burn along the ground in 

a controlled manner. Fire is not good when it races through untreated corridors of riparian area that have been untouched for 30 

years leading to bad fire. These conditions can be changed with 

proper management that isn’t paralyzed by incessant threats and 

appeals. It’s not a zero sum game where these disasters have to 

happen before we hit the reset button.’’ 

What lessons can and have we learned from the fires? 

Lesson one. It starts here, right here today is what decides it all. 

The Committee hearing and the comments from those testifying 

will be decided where we go in the future. It starts right here with 

you, the elected officials who can pass legislation and have oversight so this doesn’t happen again. It starts from the agencies 

wanting to make sure the changes that are needed are being bold 

in their choices to ensure this doesn’t happen again. 

For example, on this summer’s fire near me a state contracted 

CAT was being used to build a fire suppression line through state 

and private lands. When the CAT and driver hit the Forest Service 

grounds the CAT was stopped, stopping suppression activities because the CAT didn’t have a Federal certification. 

Lesson two. For the first time in decades Washington put out a 

call for volunteers to come help fight fires, but we didn’t have 

enough fire-trained bosses to lead those volunteers. 

Lesson three. The land is precious. What we can all agree is the 

land is precious. We’ve learned over the years that it’s expensive 

to manage lands, but even more so to repair them devastated by 

fire. 

It’s time we end fire borrowing and put the money back into the 

proper management of lands to make our lands healthier, our forests healthier and our national, our natural resource economy vibrant in our local and tribal communities. 

What are the cascading impacts of wildfire in our communities? 

As you heard 20 percent of the managed timber lands of the 

Colville Reservation burned with up to $1 billion in value. The Spokane Tribes estimated in the Carpenter Road fire they lost $1 million of timber. Citizens of this great nation are owners of the land. 

It ought to mean something. 

After the Carlton Complex fire the State House passed Representative Joel Kretz’s bill, House Bill 2093, unanimously. Passage of this bill was important as on August 14th the lightning 

strike struck in the Carlton Complex donut hole, as we call it. The 

Paradise fire was threatening 22,000 acres of which half was Forest Service ground. 

Gebbers Farm mobilized the necessary equipment to surround 

the fire, contain it from spreading, utilizing the new law. What 

could have been a 22,000 acre fire was 2.7 acres and out immediately. 
66 

I would be remiss if I didn’t thank the Forest Service, USDA, Department of Interior, FEMA and a host of other Federal agencies 

who have worked closely with our long term recovery group to assist our community in recovery efforts. 

Last, Senator Cantwell, we appreciate that you held the meeting 

in Wenatchee and then co-hosted a meeting in Spokane with Representative Morris Rogers. The meetings with various fire chiefs, 

industry leaders and elected officials kept this issue in the forefront 

and has led to ideas gathered that will lead to change. 

Right here today we can make a difference, and right now it’s up 

to us. 

Thank you for your time. 

[The prepared statement of Mr. Wyss follows:] 
67 

JON WYSS 

CHAIRMAN OKANOGAN COUNTY LONG TERM RECOVERY GROUP 

WRITIEN TESTIMONY SENATE ENERGY AND NATURAL RESOUCE COMMITIEE 

TUESDAY NOVEMBER 17, 2015 10:00 AM 

ROOM 366 DIRKSEN SENTATE OFFICE BUILDING 

Senator Murkowski, Senator Cantwell and members of the Committee, my testimony to 

you today is as Chairman of the Okanogan County Long Term Recovery Group, formerly 

known as the Carlton Complex Long Term Recovery Group. Chairing this organization 

has been one of the most challenging, and yet most rewarding things I have ever done. 

am grateful for the opportunity to lead this fine organization and thankful you have 

given us the opportunity to testify today. 

I was born in Thermopolis WYand raised in Worland, WY just east of Yellowstone 

National Park and near the beautiful Big Horn Mountains. Growing up in Wyoming 

allowed me to have great respect for our natural environment, our national forests, our 

national parks, and a great respect for people and their private property rights. 

It also allowed me to see my first Wildfire Disaster in 1988 when Yellowstone National 

Park was set ablaze by a lightning strike. I remember school being canceled because of 

air quality issues, one of my best friends who had asthma was forced to stay inside and 

wear a mask to ensure he could breath, and having to shovel ash off the car as if it were 

snow in the middle of winter. Who knew 27 years later I would be right in the middle of 

Washington States largest back-to-back wildfires in history and reliving these same 

issues. 

After graduating high school, I attended college in Texas. I worked for a variety US 

Bankruptcy Trustee Offices in four states over 11 years. I then served as the Chief 

Deputy Assessor for Spokane County and even served 3 days as a Washington State 

Senator when Senator Brad Benson was on military leave. 

I now work for my wife's family company, Gebbers Farms, which consists of apples, 

cherries, cattle, and timber that were all impacted by the 2014 and 2015 fires. Theses 

fires burned over 5,000 acres of our timberlands. Our company also provided fire 

suppression resources during both fires. 

My childhood upbringing and my employment background give me a unique perspective 

when looking at all of the environmental, financial and legislative impacts of the fires 

that have disrupted our communities. 

The 2015 Washington Wildfire Season consumed over 1 million acres and consisted of 8 

major fires and multiple smaller fires. The fires threatened homes, cabins, hotels, 

agricultural grazing lands (both government owned and private), small businesses, 
68 

critical infrastructure and lives. In all, the 2015 fires in Washington State impacted 13 

counties and four different Tribal Reservations. 

The Okanogan, Tunk Block and North Star Complex wildfires burned the largest amount 

of acreage in state history at 522,920 surpassing the previous record set in the 2014 

Carlton Complex Fire that burned 256,108 acres. The below chart gives additional 

information of acreages burned by area as of 9-18-2015: 

9 MILE 4,712 ac 

Chelan Complex-Okanogan 35,036 ac 

Lake 

ac 

ac 

ac 

11,119ac 

163 ac 

Total Okanogan County 509,739 ac 

Chelan Comp,lex-CI1el;ar 

Chelan Comp,lex-D<:>u~llas 

North st~•r-F'Art~' 

ac 

ac 

60,593ac 

Total Combined Fire 624,321 ac 

32-SFR 

36-SFR 

7-SFR 

40-Cabins 

46-Cabins 

3-Cabins 

3-MiSC HUIIII11!111S 

12-MiSC OUIIUIIllJti 

35-Misc Buildings 

50-Mlsc Buildings 

7 -Mise Buildings 

To put these fires in perspective the Carlton Complex Fire is four times the size of 

Seattle and the Okanogan Complex Fires would encompass Rhode Island. When you add 

in the Sleepy Hollow Fire near Wenatchee, WA and the Chelan Complex fires, the fire 

perimeter would be 1,261 miles which is from Washington DC to Denver, CO. 

The communities within Okanogan County and the Confederated Tribes of the Colville 

Reservation were struggling to recover from the physical, emotional, and economic 

damages of the 2014 Carlton Complex fires when the 2015 fires erupted. The Okanogan 

Complex fires caused level three immediate evacuations of more than 1900 residents, a 

near repeat of the 2014 Carlton Complex Fires. 

Chelan County had immediate level 3 evacuations for an additional 2900 residents, 

including residents in Douglas County. My own home was placed on a level 2-

evacuation notice. 

At one point all of Stevens County was placed on a level one evacuation because power 

outages, emergency alert outages, and lack of fire protection assets to carry out 

evacuations. While at the same time the cell towers went down, power went out, and 

internet lost within the Colville Reservation causing significant communication 

challenges. 
69 

Our local police, county sheriffs, other law enforcement personnel, and emergency 

management agencies in conjunction with our local firefighters did everything they 

could to notify people to leave as these massive fires exploded in each of the counties. 

Our community members, many of them ranchers, packed, taking only what they could 

fit in their vehicles. While the children loaded the cars and trucks, the parents were 

doing everything they could to load up livestock, horses and animals to get them away 

from harms way. When it came time to leave not all the memories were packed up and 

the animals could not all fit into one trailer, the families swung gates open and cut 

fences to let the animals out to fend for themselves. The families then gathered 

together to say a prayer that their animals and homes would be protected and drove 

away. 

When they could return, some came back to homes standing and animals still alive, 

while others lost their homes, all their belongings, and some of the animals could not 

outrun the fires and perished only to be known by the bangs tag number in the ear of 

the cow. 

Then, as the fires raged on and the winds picked up, we heard over the radio a call that 

no one fighting wildfires ever wants to hear, "we have 7 firefighters entrapped on the 

Twisp River Fire". On that fateful day August 19, the fire bell rang for the last time for 

three brave soles as they tried to escape the fires. We pay our respects to the victims 

and their families as they sacrificed everything to keep our communities safe. 

The 2014 fires destroyed 353 homes and caused an estimated $98 million dollars in 

damages. Then Mother Nature had one more punch for those that experienced the 

Carlton Complex Fires. On August 21, 2014, a rainstorm dropped one inch of rain on the 

land reduced to ash and bare soil causing a flash flood and massive mudslides that 

washed out small irrigation dams, houses off foundations, vehicles into creeks, and 

caused sections of the highway to wash away under 5 feet of mud that was 145' wide--

causing additional economic damage. We now wait, in each of the impacted counties 

and tribal reservations, for the impending mudslides and floods that could come as a 

result of the 2015 fires when the rains start and the snow pack melts. 

The 2015 fires burned 107 miscellaneous buildings, 89 Cabins, and 114 homes. Housing 

in the burn areas has become critical because of the loss of over 460 homes in an area: 

there was already less than a 1% vacancy rate before Carlton Complex destroyed the 

hundreds of houses in 2014. 

In total at the time of Washington State's FEMA Application, 29 fire mobilizations 

costing an estimated $28,845,000 in fire suppression costs were expended on local 

lands. Additionally the state incurred an estimated $94,872,860 in fire suppression 

costs on state lands. Could some of these costs been avoided if we had better real time 

weather information? 
70 

As you may or may not be aware, similar to portions of western Washington before 

2011, the National Weather Service (NWS) Doppler radar network has a gap or hole in 

coverage along the eastern slopes of the Cascades to the Canadian Border and down to 

the Columbia Basin outside of Yakima (Exhibit A). 

There are five (5) active Doppler radars that monitor real-time weather conditions for 

the state of Washington (Spokane, Pendelton, Langley Hill (Grays Harbor), Camano 

Island (Seattle), and Portland) that are utilized by the NWS to monitor hazardous 

weather conditions and predict weather. None of the five radars have coverage of 

weather conditions on lands below 10,000 feet in the north eastern slopes of the 

Cascades from the Canadian Border and down to the Columbia Basin outside of Yakima. 

This season's wildfires will leave many areas prone to severe debris flows, including 

areas that are heavily populated with substantial public and private infrastructure. 

Better, more accurate information will help agencies and private property owners 

prepare and respond to these events, potentially reducing the impacts and costs 

associated with clean up. 

In Washington State, the US Forest Service has over four times more land than that 

owned by the State of Washington. Over the last 27 years we have seen a change in 

forest management practices and a decline in timber harvest on Federal Lands. The 

Washington State DNR has harvested 30 times more volume than the USFS and has 

been 1283 times more profitable (Exhibit B). 

By not allowing fires to burn as they historically have or thinning out all the trees that 

have resultingly grown up, we have increased the fuel load, lowered the timber value, 

and increased the chance for massive wildfires. The current practice of fire borrowing 

has also led to a significant amount of challenges to managing the forest. Rather than 

performing the necessary treatments to keep fires smaller and more manageable, the 

funds are spent on fighting the fires. 

After back-to-backfires many are saying Log It, Graze It, or Watch it burn. With that 

said, we don't want to promote unabated logging and landscape alterations. Common 

ground can be found on these issues. A steady, manageable, and proper plan for 

treatment across the full landscape will lead to a healthy forest and less wildfire. 

A local rancher and forester told me: 

"We must remember fire is good for the environment when it can burn along the 

ground and in a controlled manner. Fire is not good when it races through the 

untreated corridors of riparian area that have been untouched for 30 years or 

more. These untreated forests and untreated riparian areas have built up fuel 

loads that lead to bad fire. This is not natural and simply out of balance, just as 

over harvesting of timber would be out of balance the other way. 
71 

These conditions can be changed with proper management that isn't paralyzed 

by incessant threats and appeals. It is not a zero-sum game where it all has to 

burn in a devastating and expensive way to hit the reset button". 

What lessons can and have we learned from these fires? 

Lesson one: It all starts right here! Right here is what decides it all. 

This committee hearing and the comments from those testifying will decide where we 

go in the future. It starts right here with you, the elected officials, who have oversight 

and can propose legislation to ensure these types of fire do not happen again. It starts 

from the agencies wanting to make the changes that are needed and being bold in the 

choices they make to ensure this never happens again. 

For example, on a fire this summer near me, a State-contracted Cat was being used to 

build a fire suppression line through state and private lands. When the Cat and driver 

reached Forest Service Grounds, they were stopped from continuing to build the fire 

suppression line due to the lack of the Cat not having the federal certifications and 

inspections. 

Lesson two: For the first time in decades, Washington put out a call for volunteers to 

come and help fight the fires as they were so wide-spread. With those volunteers came 

heavy equipment such as dozers, graders, water trucks, and people. The problem was 

that we did not have enough trained fire bosses and fire managers with the proper 

training to lead the volunteers for fire suppression. Therefore additional acreage 

burned. 

These two examples should never have happened. If the equipment is certified to fight 

fire on a State-level, in disasters such as ours, they should be accepted by the federallevel or vice-versa. 

It is imperative that we work to get more trained professionals to be able to lead 

suppression efforts in the future. This type of training should be done up front, not only 

to keep the volunteers safe but also the firefighters and emergency personnel who 

would be leading the fire suppression efforts. 

Lesson three: Land is precious. 

What we can all agree is that the land is precious. What we have learned over the years 

is that it is expensive to manage the lands, but even more so to repair the lands 

devastated by fire. The question is do you continue to take money out of proper 
72 

management, take away harvesting of the timber, take away recreational access, and 

take away grazing that assists in proper management of the forests only to have them 

burn up and expend twice the amount of money putting out a fire. 

It is time that we end fire borrowing and put that money back into the proper 

management of lands to keep our riparian areas healthier, our forests healthier, and our 

natural resource economy vibrant in the local communities. 

Lesson four: What are the cascading impacts of wildfire on our communities? 

Well in Washington State, we grow some of the best apples and cherries in the world. 

We also have some of the best cattlemen and women who have the best beef. On top 

of that we have some of the most pristine views and recreation spots in the nation. 

Our orchardists now face difficulties with wildlife coming into the orchards and eating 

the buds and limbs right off the tree causing a reduction of next years fruit production. 

Then, add to this the fire damage to the riparian areas; many feel that stream 

temperatures will rise and have a negative impact on salmon runs. This could lead to 

junior water right holders having their water turned off during the most critically 

growing time. This loss of production will cause additional economic harm to our area. 

In 2015 approximately 150,000 acres of deer winter range burned; that range supports 

10,000+ mule deer (Exhibit C). These deer now face an uncertain future without feed. 

In order to protect our agriculturists from further economic harm, requests for 

depredation tags could be made to reduce the herds and limit further economic 

damage. 

Additionally, the cattle are competing with the wildlife for native grasses in unburned 

pasture to feed. Ranchers are having to take additional measures protect their hay 

stacks from the wildlife. 

These same cattlemen and women have also lost the use of their range permits for 3-5 

years. The fires destroyed over 700 miles of fence at approximately $8,000/ a mile to 

restore. An additional125 miles of fence within the boundaries of the Colville 

Reservation must also be replaced at approximately $18,000 a mile due to the difficult 

of terrain. These additional costs placed onto our farmers and ranchers may leave family 

farms not able to financially recover and forced to sell. 

Much of the fence that was burned was on National Forest Service permitted grounds 

where cattle grazed. The US Forest Service does not qualify for FEMA's Public 

Assistance program to replace these burned fences utilized for grazing grounds as the 

local cattle ranchers maintain the fence. That leaves USDA's Emergency Conservation 

Program to assist these ranchers to replace burned fence on the Forest Service lands 

through a cost share before cattle can be put back out on the Forest Service Permit. 
73 

That fund, however, has been depleted and if the ranchers can't afford to put the fence 

back up, the Forest Service could lose that grazing revenue. 

These fires have also introduced a new challenge because the wildlife will be more 

concentrated in the unburned areas of the state along with livestock and other domestic 

animals. The concentration of the wildlife and other animals has brought Apex 

predators such as wolves, cougars, and bears closer to our towns and family farms. 

Bears have already been seen inside the city limits and one school had to keep kids from 

going to recess as a cougar was found near the school playground. 

To our friends and neighbors on the Confederated Tribes of the Colville Reservation and 

Spokane Tribes Reservation, these fires have added additional burdens and challenges. 

Twenty percent of the managed timberlands on the Colville Reservation burned during 

the 2015 firestorms. Timber revenues make up approximately 20-25% of the annual 

operating budget for the Colville Tribe. That could be upwards of $0.5-$1 billion of 

timber. The Spokane Tribe estimated that the Carpenter Road Fire in Stevens County 

impacted $1 million dollars of their timber, once again hitting another tribes' budget 

significantly. 

All of these compounding impacts have placed a significant financial burden on our rural 

communities and our reservations. 

Lesson five: "Citizens of this great nation are owners in the lands." It ought to mean 

something. 

The tax payers of this nation are owners of the public lands be they Forest Service, U.S. 

Fish and Wildlife, WDFW, or DNR or other agency; and it ought to mean something. 

After the Carlton Complex Fires, the Washington State House and Senate passed House 

Bill 2093, by Rep. Joel Kretz, unanimously. The Act: 

allows locals to access State land to help put out a fire without being held liable 

by the State, 

requires the Department of Natural Resources (DNR) to coordinate and share a 

list of locals who are qualified to fight fires and enter into agreements with them 

to use locals first during a fire, and 

requires the Commissioner of Public Lands to appoint both a fire liaison who will 

represent landowners and the public during a fire, and a Fire Advisory Committee 

to advise the commissioner on fire activities. 

Passage of this bill was important as in the early morning hours of Friday, August 14, 

2015, the same lighting storm that started the Black Canyon, Squaw Creek, Chelan 

(Reach), Lime Belt, and Tunk Block Fires, also started the Paradise Fire. The Paradise 
74 

fire, which you don't hear much about, was directly inside the center of the Carlton 

Complex fire--known as the "donut hole." The "donut hole" is just north of the town of 

Brewster, WA. The Paradise fire was threatening 680 acres of DNR land, 11,520 acres of 

Forest Service land and 10,240 acres of private lands that make up the donut hole. 

The Paradise fire was reported at 6:10AM to the DNR. DNR advised us that they had a 

number of lighting strikes and fires going in a number of other places and, therefore, 

would get to our area "as soon as possible." We advised the office that we had the 

necessary equipment to put the fire out. 

We were given the ok to send our equipment to the fire. Our staff mobilized the 

necessary equipment to surround the fire and contain it from spreading. What could 

have been another fire that burned over 22,000 acres, was limited to 2.7 acres and out 

within hours. 

This shows the bill worked. Utilizing local and available resources kept State-mobilized 

resources from being pulled away from other fires around the State and county. This 

also shows that local resources closer to the fires can respond quickly, effectively and 

efficiently. Having this same type of legislation Federally would be beneficial. 

Ownership and management of these lands ought to mean something. We can no 

longer afford to burn up the public and private lands at over 1,000,000 acres at a time. 

This year burning over 9 million acres. These policy changes should include better 

communications and cooperation with local citizens in the areas of potential impact. 

These policy changes must contain dollars for rehabilitation after the fires. The 

rehabilitation dollars should be used to ensure that re-seeding in the area is done, 

consistent with the BAER (Burned Area Emergency Response) reports. These efforts will 

also minimize the return of noxious weeds as well as provide for bank stabilization to 

prevent mudslides and floods. 

Theses fires have left our communities with massive challenges to recovery. How do 

you recover from the Carlton Complex Fire when your community has lost 353 homes, 

over 800 head of cattle, hundreds of miles of fence along with nearly $100 million 

dollars in damages? Most would answer FEMA. 

The Governor's office filed for federal assistance from FEMA to help recover from the 

2014 fires. FEMA arrived conducting an initial assessment for Individual and Public 

Assistance. Following the assessment the petition was denied for individual assistance 

but approved for public assistance. 

We were thankful for the public assistance declaration that helped our government and 

public agencies restore public infrastructure. However, those in our rural community, 

with limited income, no insurance and limited options questioned why the individual 
75 

assistance was denied. The main reason for the denial: "the damage was not 

concentrated enough". Upon learning of the reason for the denial, you can imagine we 

had a few choice words, but the public words were "no kidding the damage was not 

concentrated enough, we burned 4 times the size of Seattle". 

Now a year later, we have the 2015 firestorms of Washington State where nearly 2% of 

our State burned in one month. Again, we turned to FEMA and even after back-to-back 

incidents, the damage did not meet the subjective threshold by FEMA for individual 

assistance, but public assistance was granted. To say we are disappointed is an 

understatement. 

FEMA is seeking public comment on proposed changes to their regulation describing 

FEMA's Individual Assistance declarations criteria. FEMA published the proposed rule in 

the Federal Register and is seeking comments by January 11, 2016. You can be assured 

we will be providing written comments. 

While not granting individual assistance two years in a row has been a challenge, the 

citizens of Washington State are resourceful and resilient. The citizens have formed 

long term recovery groups to fill in the gaps. These long term recovery groups and 

committees are organized across multiple counties from Chelan to Stevens County, 

including organizations within the Kalispell, Spokane and Colville Reservations. We are 

all working together to support those who have lost and are in need. The main recovery 

group is the Okanogan Complex Long Term Recovery Group, formerly known as the 

Carlton Complex LTRG. 

These organizations have not been left high and dry, however, by our State and federal 

agencies. The Forest Service, USDA, HUD, FEMA, WA Department of Fish and Wildlife, 

and a host of other agencies have worked closely with us to assist our communities in 

recovery efforts. We appreciated the fact that Secretary of the Interior Sally Jewel came 

to Okanogan County during the fires to learn about the impacts of the fire on our 

communities and especially the Colville Indian Reservation. 

Each agency has played a role in ensuring our communities are prepared for the next 

disaster. They have held multiple conference calls with our organizations and hosted a 

number oftrainings to help us better understand how to put our communities in a 

better position. So while disappointed in the denial of individual assistance, we 

appreciate the doors that have been opened to help our community. 

One particular campaign that is moving forward is called Methow Ready. The Methow 

Valley Long Term Recovery Organization is implementing this campaign. The goal is to 

have residents throughout the area and the valley be prepared with supplies and to be 

self sufficient in case of disaster or loss of essential services. 
76 

Senator Cantwell I would like to thank you personally on behalf of the recovery groups 

for traveling to our community during the Carlton Complex Fires and for your attempt to 

get to our area during this year's fires to meet with citizens and community leaders 

before being turned around as highways were closed. 

We appreciate that you held a meeting in Wenatchee and then co-hosted a meeting 

with Rep. McMorris-Rodgers in Spokane. These meetings with various fire chiefs, 

industry leaders, and elected officials continuously keep the issue in the forefront and 

the ideas gathered, will lead to change. These meetings may not seem like a big issue 

but it has given people in our communities hope that we will recover and that our 

elected officials are listening. 

Right here and right now is our time to get it right. Thank you for your time. 
77 

EXHIBIT A 

http://www. co. chelan. wa. us/public-works/ pages/he I p-fill-the-radar-ga p 

With all of the technology today, how can a gap in radar coverage occur? 
78 

Eastern Washington and specifically communities along the eastern slopes 

of the Cascades are not immune to damaging weather events or even 

devastating natural disasters, which range from river flooding to forest fires 

to summer thunderstorm events triggering flash floods and debris flows, to 

name a few. The result of this gap in coverage creates a less reliable 

weather prediction system for the NWS, thus creating a vulnerability or 

uncertainty for the residents, businesses, and industries that lie along the 

eastern slopes of the Cascades and portions of Central Washington. 

This season's wildfires will leave many areas prone to severe debris flows, 

including areas below that are heavily populated with substantial public 
79 

and private infrastructure. Better, more accurate information will help 

agencies and private property owners prepare and respond to these 

events, potentially reducing the impacts and costs associated with clean 

up. 

The people who call Okanogan, Chelan, Douglas, Grant, Kittitas, or Yakima 

counties home. Simply put, by having the ability to provide more accurate 

weather forecasting and emergency weather alerts, the community as a 

whole will benefit. Some of those beneficiaries include: 

• Citizens of Okanogan, Chelan, Douglas, Grant, Kittitas, and Yakima, 

• agriculture community (apples, cherries, pears, grapes, wine, etc.), 

• recreational users, 

• regional airports (FAA), 

• National Weather Service, 

• WSDOT, 

• public utility districts, 

• public works departments, 

• port districts, 

• Washington State Patrol, 

• Burlington Northern Santa Fe, 

• delivery companies (UPS, FedEx, etc.), 

• USFS/DNR/BLM firefighting, 

• Emergency Management, 

• Department of Agriculture, 

• Corps of Engineers, 

• state universities, 

• regional news stations. 

-See more at: http://www.co.chelan.wa.us/public-works/pages/help-fillthe-radar-gap#sthash.StmmEXbE.dpuf 
80 

EXHIBITS 

(Produced by Okanogan County GIS Department) 
81 

- --~ 

_, 

.=.::.. II!!$ 

IS " I 

- ;;;; -.. 
82 

EXHIBIT C 

(PAGE 20 2015 PRESENTATION BY WASHINGTON DEPARTMENT OF FISH AND WILD LIFE 

TO WDFW COMMISSION) 
83 

2015 Fire Impacts: Wildlife 

• Approximately 150,000 

acres of deer winter range 

burned 

• Burned area supports 

10,000+ mule deer 

• Need to assess full extent of 

impacts to shrub forage 

base 
84 

The CHAIRMAN. Thank you, Mr. Wyss. Your testimony reminds 

us that there are true consequences, unfortunately, very tragic consequences when we fail to manage properly. There is a lot of discussion around these halls about needing to end fire borrowing, 

and it is more than just about money. We have to make sure that 

we have the resources, but I think we also recognize that we have 

some management issues that we have to deal with. We need to 

make sure these resources that we direct are spent wisely. 

So to listen to some of what you have just pointed out, what Mr. 

Maisch has pointed out, what Mr. Zerkel has pointed out, in terms 

of the lack of coordination, the double standards, the failure to 

manage some of what we are looking at, these are some of the concerns that I hope we will get out on the table today as we try to 

address the bigger picture that we are facing and again, the ever 

increasing threat to our forests. 

I wanted to ask a little bit about aviation coordination. Mr. 

Maisch, you brought it up initially, and I think, Ms. Fennell, you 

alluded to it a little bit with your discussion about the aviation assets. 

It is really discouraging, extraordinarily discouraging, to hear 

that you have different standards for aircraft used for fire suppression between the Forest Service and the Department of the Interior 

and that you can literally be poised to move in to address the fire 

and you are held back because you do not have the proper certification. You do not have the aircraft carded. 

How do we get around this? Mr. Maisch, you have been dealing 

with these different standards and you see how it impacts the efficiency and the ability of our agencies to effectively engage in these 

fire suppression efforts. What do we need to do here? It should not 

be this hard, and we have had hearings before this Committee that 

I have been part of where we say, particularly in a state like Alaska where you have got your BLM lands, you have your Forest Service lands, you have your State lands, and you have tribal lands. 

The fire does not care whose land it is. The fire is going to go 

where the fire is going to go. 

Why can’t we do a better job with this interagency coordination? 

What do we need to do? I will start with you, Mr. Maisch, and anyone else that would like to contribute is welcome to join. 

Mr. MAISCH. Ah yes, thank you, Senator, for the question. 

It’s a good question but unfortunately it’s not an easy solution. 

We’ve been working on this for several years to try and streamline 

and get the two agencies to basically have a seamless process that 

if one agency cards a ship, it’s good to go. It’s not another cooperator letter or another carding process that it has to go through. 

They are carding to the exact same standards, so it’s very perplexing. 

The CHAIRMAN. Then if they are carding to the same standards, 

why do you have to have multiple cards or multiple certifications? 

That makes no sense. 

Mr. MAISCH. That’s an excellent question. I wish I had an answer 

for you on that, but we’ve been frustrated for years. And you see 

the about eight examples we gave, specifically in the written testimony, about other examples around the country. Incidents hap-
85 

pened in Oregon, Nevada, Alaska, Montana. So it’s not just a one 

off situation, unfortunately. 

And the point I made about treating the states as equals and allowing them to basically modify the agreements we currently have 

with the Federal Government to reflect that if one agency does the 

process and approves the ship and the pilot, it’s basically good to 

go across the board. And it’s basically some bureaucracy there. 

The CHAIRMAN. Does anyone else have an answer for how we address it? I hear the frustration. We all have the frustration, but it 

ought not be this hard and recognizing that we do have the same 

standards that should be okay. 

What Mr. Zerkel raised with the standards that we have between 

the commercial aircraft and the government-owned aircraft that, to 

me, is absolutely unacceptable. You go with your highest standard, 

and those set by the FAA, it seems to me, makes sense. But to 

have safety standards that are less, if a government-owned aircraft 

verses a commercial aircraft, we have got to get that one worked 

out. 

Ms. Fennell, do you have any observations based on your reviews? 

Ms. FENNELL. We haven’t looked specifically at the carding issue 

that is mentioned here, but we did note in our reports that there 

are challenges associated with collaboration amongst the agencies. 

And in fact, for one of our reports we did have a recommendation 

where we called for enhanced collaboration amongst the agencies 

in terms of looking at the performance of aircraft. 

But to date— 

The CHAIRMAN. We have been doing that for years. This is not 

a case of first impression here. This has been going on for years. 

I am just stunned that we are not any better, not further along. 

Let me turn to Senator Cantwell and then we will come back for 

a second round of questions. 

Senator CANTWELL. Thank you, Madam Chairman. 

There are a couple things I wanted to mention before I ask questions. 

First of all, Mr. Wyss, thank you and Gebbers for everything you 

did in the Carlton Complex. I think you are talking in testimony 

about so many things. You mentioned it, but I do not think it really 

is crystal clear what you were saying that is that you and individual citizens and employees of Gebbers basically went out and 

held the line and really prevented a lot more acres from burning 

and did an incredible job of also helping the Town of Pateros. So 

thank you, and thanks for being here. 

Chief Burnett, thank you so much for everything that you have 

done over these fire seasons and for helping us illuminate some of 

the issues about what I have heard on the ground in Washington 

State that I just call hasty response, which is just how can we be 

more active in using people to jump on fires immediately when 

they start. So thank you for articulating that. 

I also want to mention that last night the Forest Service did announce $300,000 to Chelan for recovery. 

But I wanted to get to these handouts I gave my colleagues. So 

if we could put these up, there are handouts that actually show 

three slides. 
86 

One, the 2012 Wenatchee Complex and fires. 

[The information referred to follows:] 
87 

a) 

QJ 

..c 

u 

.. 

IV 

c:: 

QJ 

3: 

"'C 

QJ 

"'C 

c:: 

:::1 

0 

... 

... 

:::1 

II) 

N' 

t'"'l 

0 

N 

c:: 

X 

QJ 

c. 

E 

0 

u 

QJ 

QJ 

..c 

u 

.. 

IV 

c:: 

QJ 

3: 
88 

One thing, Mr. Burnett, you did not mention when you kept saying warehouses were burned down. Could you explain to people 

what was in these warehouses? 

Mr. BURNETT. Yes, the community of Wenatchee, we lost approxi- mately $110 million worth of assessed value. The fire spotted from 

the Broadview neighborhood over a mile into an industrial area, 

took hold initially in a recycling plant and spread to the roofs of 

a chemical warehouse storage building and then spread to two 

large fruit packing plants. 

So yes. 

Senator CANTWELL. All of this is the home to the apple industry 

in Washington State and why it is so—okay so the next chart demonstrates the Beehive Reservoir. 

[The information referred to follows:] 
89 
90 

So the red is encroaching fire from this season and the community that was trying to be protected. This Beehive Reservoir area 

is where you did actual treatment. Is that correct? 

Mr. BURNETT. Right. So you can barely see it there, but the Forest Ridge neighborhood is a Fire Wise community. They’ve taken 

a lot of efforts to protect the approximately 70 homes that are 

there, and we’ve done grant funding with them to do fuel modifications right around the neighborhood. We’ve tried to partner with 

the state agencies as well as the Federal agencies on choosing 

those areas where the fuel treatments would be best suited. 

The Beehive Reservoir has had a lot of fuel treatment around 

there by Forest Service and that fire that, you see the perimeter, 

is the Peavine fire that was coming into, threatening that area. It’s 

less than two miles away. The fuel treatment in Beehive Reservoir 

area was significant in controlling the fire. 

In 2012, the Wenatchee Complex had over 60 fires that we were 

dealing with and so being able to allocate a limited number of resources in that area on a fire suppression effort that took a minimal amount of resources was significant for us. 

Senator CANTWELL. Well and fuel treatment, you are saying that 

was a success in a year that we actually even saw places where the 

fire jumped the Columbia River. So we had extreme weather conditions blowing that up. 

Mr. BURNETT. Yes. 

Senator CANTWELL. So can you go to the last page which I actually wanted Dr. Covington or Mr. Wyss to comment on. This is an 

up close of the area that Bryan Petit from our staff was just there 

visiting. 

[The information referred to follows:] 
91 
92 

You can see on one side of the road the treated area, and on the 

other side the burned area, so basically it did not jump over to the 

other side of the road. 

I think one of the most important things that you said in your 

testimony is this issue about surface to crown. From our state 

agency, from our DNR Director and everybody, it is all about the 

crowns, right? The ferocity of our fires are from crown to crown. 

What we are talking about here is reducing the ability to get to 

crown level by basically reducing the surface timber. So if you 

wanted to further elaborate on the challenge that we have with all 

this Ponderosa Pine not having been treated for some time and 

what that means as far as the ability to go crown to crown and the 

kind of devastation we’re seeing? 

Dr. COVINGTON. Yes. So about 90 percent of our mega fires are 

in the dry forest types in the West. This last season we saw mega 

fires in areas where crown fires are normal, just not crown fires of 

that size, of the size that we encountered. So they are separate 

problems. 

On the one hand with frequent fire forests, like Ponderosa Pine, 

they were originally, before fire regime suppression, were open and 

park like. The fires naturally burned through the understory. The 

plants and animals were adapted to these fires. These fires are 

easy to control, if you want to control them, although it’s not always clear why you might want to control surface fires. 

As the forest filled in we moved from a frequent fire regime in 

Ponderosa Pine to a crown fire regime. So we essentially created 

the kinds of fuels that occur naturally in Spruce, Fir and Lodgepole 

Pine over tens of millions of acres throughout the West. So the solution in that type is restoration, is thinning out the post-settlement trees, conserving the old growth trees which are so important 

for wildlife and aesthetics, biodiversity and then reintroducing natural fires, fires that would burn on the two to maybe, 15 year interval. 

In the crown fire types, in Spruce, Fir, like in interior Alaska, 

Lodgepole Pine types, we have a different problem. There the fires 

have always been crown fires but they were smaller crown fires on 

the scale of like in the case of the Yellowstone ecosystem, somewhere on the order of 100,000 acres, 200,000 acres. But what we’ve 

seen over time with fire suppression is that we get an area that’s 

ready to burn now. Fifty years from now being adjacent to five 

other areas that have accumulated crown fuels to the point that 

they’ll support fires, it’s a lot easier to fight a 100,000 acre fire 

where you know that’s as far as it’s going to go than it is a million 

acre fire. 

When we’re dealing with mega fires we—this is very recent. We 

just don’t have the capability to deal with fires of that size, so the 

restoration in that area of sizes, it’s patch sizes, involves putting 

in fuel breaks. 

If you weren’t worried about aesthetics, it would probably be 

clear cut fuel breaks between these different patches to break them 

up so that they can then burn at a more normal size. 

Senator CANTWELL. Thank you. And thank you, Madam Chairman, I know my time is up. 

The CHAIRMAN. Senator Daines? 
93 

Senator DAINES. Thank you, Chairman Murkowski and Ranking 

Member Cantwell for holding this critically important hearing. 

I have got to say I am tired of talking about this. I want to see 

action out of Congress. We need to do something. 

Like much of the West, Montana had a very difficult fire season. 

Over 300,000 acres burned, multiple evacuations of populated communities were ordered. In fact one firefighter from Stevensville, 

Montana was the only survivor of that four member crew where 

three of them lost their lives in Western Washington that was referenced twice in this hearing already. 

This year’s fire season demonstrated the need for a strong wildfire funding solution that is a support of the Wildfire Disaster 

Funding Act. I strongly believe Congress should relieve the Forest 

Service of the suppression costs of fires that are truly natural disasters, but at the same time the fire season also demonstrated the 

urgent need for restoration work to be done in Montana and other 

parts of the country. 

Consider, for example, lessons of the Bear Creek fire in the Flathead National Forest. I was up at the Incident Command Center 

of West Glacier here when the big fires in Glacier were burning 

this summer. Bear Creek is not too far away. 

It was incredibly hot with flame lengths reaching 100 feet. As 

the fire progressed to the Meadow Creek trailhead, it went to a 

spot where we had a recently completed a thinning project. However, when it hit the recently completed thinning project, guess 

what happened? It settled down considerably. 

Local Forest Service officials said the thinning project really 

worked. That is the good news. Now here is the bad news. The 

thinning project was part of the larger Spotted River project that 

was hamstrung by litigation for several years. According to nonpartisan research done by the Bureau of Business and Economic 

Research at the University of Montana the case was in court for 

over 1,000 days. So instead of planning for a new forest restoration 

project, 18 Forest Service personnel spent nearly 2,000 hours responding to the lawsuit. 

Further, the study found that over 100 forest project jobs were 

threatened. It pointed out that the litigation delayed efforts to improve recreation access and wildlife habitat. I was chasing elk just 

this last weekend in Montana, and you hear both the quantitative 

as well as qualitative stories about when you thin the forest it improves the habitat for the wildlife. 

It is quite possible that the work that was upended by the litigation could have further mitigated the damage when that fierce, 

fierce, Bear Creek fire swept through. The Forest Service ultimately prevailed in court, but the impacts of litigation against this 

project and many, many others are extensive and they are severe 

and they should not be accepted. 

I urge my colleagues on both sides of the aisle, let’s come together and pass a wildfire funding solution as well as timber management that includes some litigation reform so we can move forward here and protect our forests, protect our jobs and protect the 

lives of the men and women who fight these fires. 

Dr. Covington, you talked about the importance of thinning and 

prescribed burns, you also talk about the dangers of excessive 
94 

stand densities. Do you think that providing the Forest Service 

with additional tools such as expanded categorical exclusion authorities could help the agency get substantially more restoration 

work done? 

Dr. COVINGTON. Yes, of course it could. One of the problems that 

we’ve solved, I think, in a lot of the collaborative work is that when 

you get local people together to support a project, if you have 

strong, local, political support, you can, kind of, head off legal action that might otherwise stop a project. 

So there’s the one approach that you’re describing is let’s have 

more categorical exclusions and that, obviously, if that could get 

through, you’d still have potential political blow back from it that 

could slow a project down. 

If you have local, political support that’s well organized and engaged in it, in many ways I think that would be more robust. 

Senator DAINES. Yes. 

Mr. Covington, in addition to, I think, that reform is needed, 

would include incentives for the collaborative efforts as well. 

It is working in Montana. The problem is the extreme environmental groups that litigate the collaborations are not part of the 

collaboration. They are waiting at the courthouse to file the lawsuit 

once the collaboration wants to move forward. 

Dr. COVINGTON. That’s right, and so it seems to me, Senator 

Daines, that there’s, just like there are variations across the landscape in fuel accumulation and forest types, there are variations 

across the political landscape that make different solutions more 

helpful in one area than in another. And we don’t typically analyze 

that. 

Senator DAINES. Right. 

Let me ask one last question, Ms. Fennell, because my time is 

out. 

Ms. Fennell, I think performance metrics and accountability are 

vital and thank you for being here. You note in your testimony that 

the Forest Service is beginning to improve at understanding fuel 

treatment effectiveness. 

Do you have any other thoughts on how Congress can further enhance accountability on the agency in terms of both finding the 

most effective fuels reduction treatment for a given area and in 

maximizing the amount of effective fuels reduction projects it does 

each year? 

Ms. FENNELL. Senator, I think it would be important to continue 

oversight in terms of the new efforts that they are putting into 

place regarding looking at the effectiveness of their fuel treatment 

program. They—we noted in 2007 that, they did not have sufficient 

information by which to evaluate the effectiveness of the fuel treatment programs, and therefore had impacts in terms of how they 

would allocate the resources accordingly. 

Since that time they have established a new system called the 

Fuel Treatment Effectiveness Monitoring Program. It is in process, 

and I think it would be important to continue oversight over it to 

see how it’s progressing and whether it’s getting the information 

that’s needed to evaluate the effectiveness of the fuel treatment 

program. 

Senator DAINES. Thank you. I am out of time. 
95 

The CHAIRMAN. Senator Heinrich? 

Senator HEINRICH. Thank you, Madam Chairman. 

Dr. Covington, I want to start with you, and I want to start with 

a thank you actually because I think in oh, seven years of Natural 

Resources Committee meetings on both sides of the Capitol in both 

the House and the Senate, I think you are probably the first person 

to succinctly articulate that we need different strategies for different forest types and that what works in a Ponderosa Pine forest 

that should be burning every 2 to 15 years is not exactly the same 

prescription that we are going to need in a closed canopy forest, be 

it Spruce, Fir, or Lodgepole Pine further north. I think that is really helpful. 

I think we tend to oversimplify things here in Washington, but 

I think that comes with the territory. 

You said you used the phrase, ‘‘an ounce of prevention is worth 

a pound of cure.’’ I think we all wish that everyone agreed with 

that approach, but one of the challenges we have had has simply 

been being able to show and justify the restoration efforts and 

show that they actually do pay off economically in the long run. 

And that goes back to the question that Senator Daines was raising 

as well about evaluation of those. 

Can you talk a little bit about data capture and particularly one 

you are able to wrap things in like the potential impacts to municipal water supplies and soil impacts, about the cost effectiveness of 

being able to do, especially these Ponderosa Pine, restoration 

projects rather than waiting for these areas to burn and starting 

from scratch? 

Dr. COVINGTON. So quickly then there. We have studies where 

we’ve approached this two ways. 

One is looking at areas that have already burned over, large 

landscapes and then examining the portions of those landscapes 

that had been treated before with restoration treatments. And repeatedly what we see is that in areas where the forest had been 

restored to more natural conditions they stand up, even under the 

most severe fire conditions. 

Senator HEINRICH. Right. 

Dr. COVINGTON. They survive well. Fires burn through the understory, and then once they get out of the treatment they get up 

in the crowns again and run. 

These kinds of fuel breaks, restoration-based fuel breaks in Ponderosa Pine, we see have saved houses, have saved entire communities as well. In the back country this works also to protect Mexican spotted owl nest sites and other highly-valued portions of the 

landscape. So one way is an ex post facto is to go out there, see 

what happens and the evidence is overwhelming. It works. 

The other thing that we’ve done is what I mentioned in my testimony, is we’ve looked at fires and then analyzed what the potential 

fire behavior would have been had treatments been put in elsewhere. When we do that sort of analysis what we see is, by breaking up landscape scale fuel community, continuity. 

Senator HEINRICH. Right. 

Dr. COVINGTON. You can protect values at risk, including homes, 

where if embers are coming two to four miles away. 

Senator HEINRICH. Gotcha. 
96 

Dr. COVINGTON. Being dropped into communities. 

Senator HEINRICH. Thank you. 

I want to shift real quick to Ms. Fennell. I want to start by just 

saying that I think it is clear that at this point using the 10-year 

average to budget for fires is no longer working for us. If you look 

back at the last 9 of 11 years, using the 10-year average has underestimated the Forest Service’s suppression costs 9 out of those 11 

years and it was actually 40 percent below actual costs during that 

period. 

With the climate shifting that we are seeing we do not see that 

trend exactly slowing down, so the ten-year average standard was 

created at a time to ensure that in most years the agencies would 

have the funds that they needed to cover those costs. That is not 

what we are seeing work out today. 

So if that no longer works as a construct do you have advice for 

how we should be budgeting for something that can be as variable 

as fire suppression costs from year to year? 

Ms. FENNELL. Senator, we haven’t specifically looked at that particular issue as part of our current effort. I think the last time we 

looked at various options available for legislative action was about 

2004. We noted that there are various pros and cons with each approach that’s taken, but we haven’t specifically looked at the current issue that you’re raising as part of our current work. 

Senator HEINRICH. Does anyone else have a comment? 

Mr. MAISCH. Yes, I’d like to respond to that. 

We do much the same in the state. We talk about a 10-year average and budget for that but what we found, as you alluded to because of changing weather patterns and climate, you have these extreme events much more frequently. And it’s hard for a 10-year average to fit to that kind of a scenario. 

So you really need the flexibility from an agency perspective to 

do a disaster declaration which is what we do in our state and the 

supplement suppression accounts when those kinds of events have 

occurred. You’ve got to have some kind of system that allows that 

flexibility because it’s hard to anticipate the kinds of events that 

we’re seeing. 

Senator HEINRICH. That is helpful, thank you very much. 

The CHAIRMAN. Thank you. 

Senator Barrasso? 

Senator BARRASSO. Thank you very much, Madam Chairman. 

You know this year is another example why it is a necessity to 

conduct more prescribed fires, perform more fuel reduction treatments and undertake more vegetation management projects to thin 

our unnaturally, overcrowded forests. According to the Forest Service between 62 and 82 million acres are in need of treatment and 

are at risk of catastrophic wildfire over 40 percent of the entire National Forest system and the number is growing. 

We simply cannot allow the status quo to continue. That is why 

I have introduced S. 1691, a bill called the National Forest Ecosystem Improvement Act. It is designed to make treating our forests a priority it needs to be. 

The Forest Service also states specifically there are about 12 and 

a half million acres in need of mechanical treatment such as 

thinning. With these numbers in mind do each of you agree that 
97 

Congress must take action to increase the pace of treatment using 

both prescribed fire and mechanical methods to restore forest 

health and reduce the severity and the size of wildfires? 

Everyone agrees with that? [Witnesses shaking heads yes, simultaneously.] 

Senator BARRASSO. Alright. 

Dr. Covington, in your written testimony you say it is too late 

to use controlled burning alone to protect communities and restore 

forest health. You then explain why first thinning and removing 

unnaturally high tree densities and then introducing fire produced 

stunning results. Would you elaborate on why you think it is too 

late to just use controlled burns alone and what are some of the 

stunning results that you are seeing? 

Dr. COVINGTON. Okay. So when I first started out in this work 

back in ‘75/’76 I was pretty much thinking that if fire exclusion had 

caused this problem you just put fire back in. It ought to solve the 

problem, and so I embarked on a 6-year program of study working 

with cooperatives with the Forest Service to try this. 

What we found in dense forests of Ponderosa Pine which is 95 

percent of the Ponderosa Pine type is that we could not develop a 

safe prescription. On several circumstances we had fires get into 

the canopy, become independent crown fires and fortunately we 

had enough suppression force around to knock them down again. 

But I was on the verge of becoming the shortest lived professor in 

the school of forestry. I would have been fired if we’d burned up 

the San Francisco Peaks from those early experiments. 

Then that caused us to look at thinning out the post settlement 

trees to try to restore natural conditions, and those first experiments have just been so stunning. We’ve now done this throughout 

areas in the West, especially Arizona, New Mexico and Colorado. 

What we see is old growth trees that have put on no growth at all 

for decades start growing like teenagers. We see abundant grass 

production and wildfire production understory, a tremendous blossoming of birds, songbirds, butterflies and everything. So every aspect that we look at in forest health shows that these work. 

The difficulty that we’ve got, Senator Barrasso, is not all areas 

are accessible for being able to remove all of the biomass and the 

thin material. So a problem that we’re dealing with right now is 

trying to figure out how can you do onsite disposal of some of these 

materials while not creating excessive fire hazard or dumping a lot 

of smoke into the atmosphere. We’re talking about putting a lot of 

treatments down there around urban interface areas, and that’s 

where people live and people have asthma and they have lung diseases and they like to breathe clean air. So right now we’re putting 

a lot of focus on how we can deal with that biomass issue. 

Senator BARRASSO. In terms of this wildland urban interface that 

you just made reference to, you also write about the reduced mega 

fire potential when treatments in all high risk areas were performed verses treatments only in the wildland urban interface. 

Why are the risks of the mega fires reduced when treatment is not 

limited to around communities only but also treating the greater 

landscape as a whole? 

Dr. COVINGTON. Well, thank you for the question. 
98 

The treatments around communities are designed to protect 

houses, primarily, you know, to help out with fire department operations. When you’re talking about mega fires across the landscape, 

that’s only 5 percent or less of the landscape in most circumstances. In the back country is where we have our natural resource values, the watershed function, biological diversity, wildlife, 

recreation opportunities and so on. So I don’t think anyone wants 

just the houses in burned over landscapes. 

I had one study area over in Los Alamos back with the Cerro 

Grande fire. This one elderly couple had a brick home. They had 

cleared out around their house. It survived the Cerro Grande fire. 

They got smoke damage payments. All the houses around them 

burned, but they didn’t want to live in a burned over landscape. 

Out back, you know, from their door was a wonderful little canyon 

that just burned to a crisp, killed all the old growth trees. And 

ironically on their property there was an old growth tree that had 

been labeled in Forest Service research in 1911—it was 480 years 

old—that had survived. It had fire scars on it. It survived 40, 50 

fires, and then in that one fire it burned up. 

So most people that are living in this country don’t want their 

cabin or their house or their subdivision in a burned over landscape. So we’ve got to look at it in the whole habitat point of view, 

I think. 

Senator BARRASSO. Thank you. 

Thank you, Madam Chairman. 

The CHAIRMAN. Senator Stabenow? 

Senator STABENOW. Thank you very much, Madam Chairman 

and our Ranking Member for holding this hearing. These are very, 

very important issues and it is interesting to me that I find myself 

on the Agriculture, Nutrition and Forestry Committee, Energy 

Committee and Budget Committee, I am, I think, the only member 

on all three committees that are touching all of this, and it is incredibly important. 

Let me start out by saying we just held a hearing in the Agriculture, Nutrition and Forestry Committee a few weeks ago, and 

we found amazing consensus around the issue on the budget and 

on Senators Crapo and Wyden’s bill. In fact it was interesting. 

Every single person that testified from across the political spectrum was saying that we needed to start the wildfire discussion by 

fixing the Forest Service budget and the Wildfire Disaster Funding 

Act. So I want to applaud Senator Wyden and Senator Crapo for 

that because I do think when we are looking at mega fires, like you 

have been talking about today and natural disasters, that it is incredibly important that we understand what is coming and more 

and more and deal with it in a different way. 

I would like though to start, Mr. Maisch, with talking about 

what happens, because we are taking all the funding. I mean, we 

passed a Farm bill in 2014 with the most robust funding we have 

ever had in a forestry title to try to get ahead of things by doing 

it and creating a number of tools to deal with prevention and so 

on. All that money is going to fight the fires, so we are not able 

to get ahead of it. 

Because you concluded in your written testimony support for the 

Wildfire Disaster Funding Act, I wonder if you might talk some 
99 

about the basic Forest Service functions and programs in Alaska 

that are suffering because the agency is forced to spend so much 

of their budget on wildfire suppression? 

Mr. MAISCH. Ah yes, thank you for that question, Senator. 

It’s not as much in Alaska as in other parts of the country because, of course, the Tongass is not a fire driven ecosystem. So 

there’s different issues affecting the Tongass of which I’m sure we 

don’t have time to go into. But I can speak to the issue of more 

active management on Forest Service lands. 

When they have to divert funds, essentially borrow funds, to pay 

for suppression costs it takes away from all the proactive activities, 

pre-commercial thinning, commercial thinning, restoration work. 

You can almost name the type of activity. It restricts the funds 

available for that type of work. 

I think you heard from everyone on this panel and as you alluded from other panels that you’ve heard from that you have to 

get in front of this problem. You have to be proactive, and you can’t 

just pay for fighting fire. We need to pay to prevent fire where we 

don’t want fire. 

Senator STABENOW. Thank you. 

To that point, Mr. Burnett, I wondered if you might speak a little 

bit more to the fact that our forests are not just on Federal lands, 

as we have all said, or even on state lands, there is private land 

as well. And our private landowners and states have a huge role 

in making forests more resilient to wildfire, both to protect lives 

and property and safeguard drinking water and so on, all the 

issues we have talked about today. 

We have worked again back into what we did in the forestry title 

of the Farm bill to expand what is called Good Neighbor Authority 

a couple of years ago, and we have seen some Good Neighbor 

Agreements signed recently in Wisconsin and Michigan that are 

positive. 

I wonder if you could speak a bit from your experience to the importance of forest health efforts between Federal, State, and private land boundaries and what types of policies and concepts 

should we be thinking about as we build on the Good Neighbor Authority? 

Mr. BURNETT. Thank you, Senator. 

So it is not just a Federal issue. The local fire districts are your 

first line of defense in protecting those homes that are in the 

wildland urban interface. The homeowners also have to understand 

that they have a responsibility to help harden their homes and to 

take the efforts to reduce the fuel around their homes. They need 

to work as a community. 

The Sleepy Hollow fire, part of the neighborhoods that were affected, had defensible spaces around them and we were able to 

steer the fire around that. It got into the Broadview neighborhood 

and those homes are tightly packed together and they’re sitting 

right on top of a ravine that has old growth sage in it. When the 

fire hit that it came up over the homes and was basically a tidal 

wave of flames, and there’s nothing that we could have done to protect those homes. It is not just the Federal efforts, but it is the 

local efforts as well. The city of Wenatchee has enacted the WUI 

fire codes from ICC, and those types of efforts need to happen both 
100 

on a city and a county level to help us give us the tools to be successful when the fire does come into a WUI interface area. 

Senator STABENOW. Thank you very much, Madam Chairman. 

Senator RISCH [presiding]: Thank you, Senator Stabenow. 

Senator Gardner, you are up. 

Senator GARDNER. Thank you, Senator Risch. And to the panelists, thank you for being here. 

According to the Congressional Research Service, since 2000 we 

have had an average of about 74,000 wildfires burning an average 

of 6.6 million acres. We have talked about the numbers and how 

7 of the past 11 years have been beyond that. During the 1990’s 

the annual average of burned acres was 3.6 million acres. 

So I appreciate the work Dr. Covington is doing and appreciate 

the presence in Colorado at the Institute. We have obviously felt 

the burn as well in Colorado in terms of the forest fires and the 

destruction that has occurred. 

In June 2013 the Black Forest fire, northeast of Colorado 

Springs, saw 14,280 acres and 488 structures destroyed. A year 

earlier in June 2012 the Wallow Canyon fire, outside of Colorado 

Springs, saw 18,000, nearly 19,000 acres burned and 346 homes destroyed. In 2012 we saw the High Park fire in Larimer County destroy nearly 87,000 acres and 259 structures. In 2010 the Four 

Mile Canyon, northwest of Boulder, saw 6,000 acres burned and 

170 structures burned down. And of course, one of the most infamous wildfires in Colorado history occurred in June 2002 when the 

Hayman fire burned 136,000 acres and saw the destruction of 600 

structures. 

While we have experienced significant wildfires over the past 15 

years, our state’s development, like the rest of the country with an 

interest to fire developing in the wildland urban interface, as we 

have talked about here this morning. According to a 2007 Colorado 

State University study between 2000 and 2030 there will be a 300 

percent increase in Colorado’s WUI interface from 715,000 acres to 

more than 2.1 million acres. 

Building upon that study in late October of this year the American Forest Foundation came out with a report on wildfires that 

highlights areas of our nation that are most at risk for wildfires 

and threat to watersheds. The analysis found that there are 52 million acres at high risk for fire on private land, on family forest land 

in addition to the 93 million acres on public land. Of these 52 million acres, 1.3 million of them are in Colorado. 

And so, Mr. Burnett, I have a question for you. Given that you 

serve in an area of Washington with significant fire risk that also 

has considerable wildland urban interface, what steps do you think 

we should take to address the risk to private or family forest land? 

Mr. BURNETT. As I said before, the rural fire departments are 

staffed with primarily volunteers, and there’s a need for additional 

resources to make an initial attack and keep the fires small and 

prevent it from becoming one of the larger fires. The ability for us 

to extinguish the fire on that initial attack is critical. 

I mentioned the fact that we need the ability to activate air resources in order to fight those fires and not wait for the Federal 

or State agencies to come in to assist us with that and to call for 

those assets. I think that’s my answer. 
101 

Senator GARDNER. Yes and I think at the beginning of your testimony you talked about four points. I think you talked about education, quick attack, fuel reduction, and aerial response. 

Mr. BURNETT. Yes. 

Senator GARDNER. When it comes to aerial response in Colorado 

there has been significant debate about whether or not there 

should be a state aerial firefighting fleet. Is that something that 

you have seen in Washington or other states looking at that? 

Mr. BURNETT. Yes. The Washington State Department of Natural 

Resources has eight helicopters available for deployment. Chelan 

County Fire District One actually has a UH1 medium helicopter 

that we acquired years and years ago. It was leased to DNR for 

many years and then they built up their fleet and decided that 

they no longer needed it. 

As you’ve heard in testimony here, our helicopter is not available 

to be utilized on State and Federal fires because our pilots aren’t 

carded for long line operations. The helicopter itself is carded but 

not our pilots. 

Senator GARDNER. That is something I think that we have seen 

in Colorado too, because down in the Southwest corner of the state 

where you have the narrow gauge railroads and you have a privately-owned railroad that draws thousands of tourists every year. 

The railroad company has a firefighting fleet but they are restricted to activities within 50, I cannot remember the number of 

feet, the right of way that they are allowed to act in, but if they 

go beyond that they get in trouble from the Forest Service for trying to put out a fire. 

I understand the Forest Service has to try and protect themselves and make sure that people are taking safety into account 

and doing the right thing, but do you see the Forest Service willing 

to work with you and others on this certification issue so that we 

can address questions like this railroad issue to allow more private 

resources to be brought to bear, to allow the state to be able to provide resources more timely when available? 

Mr. BURNETT. There have been efforts regionally for us to be able 

to utilize our helicopter, for example. Two years ago we would have 

to set down when the State or Federal helicopters entered into the 

air space. Last year we were allowed to actually continue flying 

when they entered into the air space, but they will not call or utilize our helicopter. 

Senator GARDNER. I know I am running out of time. 

Ms. Fennell, has GAO taken a look at some of the ways that our 

Federal disaster designations work? Here is what I mean by that 

question. If you have a significant burn we know that any significant moisture event after that fire is going to result in flooding because of hydrophobic soil conditions and other problems that occur. 

Oftentimes though that next or that secondary disaster is not included in that first disaster and people have to go back and reapply, resubmit, adding cost when if they were able to address the 

damage done to the soil conditions to prevent that flood from occurring which you know will occur because of the next moisture event, 

you would have saved money in the first place. Has the GAO done 

any kind of look into whether we could be more efficient and effec-
102 

tive with the initial disaster dollars by preventing the secondary 

disaster that comes from a fire? 

Ms. FENNELL. We haven’t specifically looked at that particular 

issue, but we would be happy to work with the Committee staff in 

terms of any interest in terms of looking at other, perhaps relevant 

GAO disaster work that could be applicable to this particular situation. 

Senator GARDNER. Very good, thank you. 

Senator RISCH. Thank you, Senator Gardner. 

I am going to exercise the Chairman’s prerogative here and just 

say that I think, probably, Mr. Zerkel might have some thoughts 

on that exchange between Mr. Burnett and Senator Gardner. 

Would I be correct on that? 

Mr. ZERKEL. Pertaining to? 

Senator RISCH. The aerial firefighting that was referred to in the 

exchange between the Senator and Mr. Burnett. 

Mr. ZERKEL. Well I can say that from our perspective the method 

by which the Forest Service wants to operate the C130’s that 

they’re designated is probably not the best way to go about it, that 

public use format. And that’s really our message today is it is a 

poor way to go about operating aircraft. 

Industry has very rigid standards that must be met in order to 

modify an aircraft, such as putting a tanker into it. Under that 

public use aircraft format those rules are not applicable. I’m not 

saying that they don’t do a good job of engineering or whoever they 

get to do it wouldn’t do a good job of engineering, but there is not 

prescribed process to make sure there’s no pieces missing, no holes 

that haven’t been filled, and that’s the real danger of that type of 

operation. 

Senator RISCH. Thank you for thoughts, Mr. Zerkel. 

Mr. MAISCH. Senator, might I add to that answer? 

Senator RISCH. Please. 

Mr. MAISCH. Yes, thank you. 

I didn’t answer a question earlier from Senator Murkowski as 

well as I could have on this topic of carding, but you did have an 

excellent example in Colorado this year of this which illustrates 

this problem. You have a multi-mission aircraft the State owns. It 

was requested on an infrared mission in Oregon. The aircraft had 

been carded in Region 2, the Forest Service region, in your area 

and then it went over there to Region 6 and had to be re-carded 

again. So that’s the situation, and I think the way to get at fixing 

this is we have various memorandums of understanding, cooperator 

standards, and mobilization guides that the agencies use to move 

things like this around the country. We need to ensure that those 

agreements with the states and the agencies recognize each other’s 

standards and will accept them right up front, so there’s no more 

of this back and forth well, it’s Region 2, it’s Region 6, it’s OAS. 

Those agreements have to explicitly state if it’s carded in one jurisdiction, it’s good to go nationally. I think that would really help. 

Senator RISCH. That unfortunately makes too much sense. 

[Laughter.] 

Senator Franken? 

Senator FRANKEN. Thank you, Mr. Chairman. 
103 

I heard Senator Gardner say that Colorado felt the burn, and I 

was actually at the HELP Committee with Senator Sanders and 

apologize for not being here but I am sure that he appreciated the 

shout out. [Laughter.] 

And— 

Senator GARDNER. I was hoping nobody was paying attention as 

those words left. [Laughter.] 

Senator FRANKEN. I did. 

Last night I read a lot of the testimony, and we are hearing common themes about the balance that is spent of suppression as opposed to prevention, the balance shifting, of course, to suppression. 

Also in prevention you are trying to get rid of hazardous materials 

as part of that. And then we heard just a lot of talk, a lot of testimony about the wildland urban interface. I would like to see and 

I think this is an opportunity for helping to pay for the removal 

of hazardous fuels from the, especially from the wildland urban 

interface, if we use this waste as a source for electricity because 

this would put a value to that biomass and also reduce the risk of 

fire in that space which as all the testimony says is growing. We 

can utilize this in terms of combined heat and power and other facilities that use woody biomass. 

Dr. Covington, let me ask you, are there places where forest 

waste is being used for biomass electricity generation, and what 

are the benefits of that from a forestry perspective? 

Dr. COVINGTON. Yes, there are a number of places throughout 

the West where biomass, the slash material that’s not suitable for 

making traditional dimension lumber or engineered forest products 

are being converted to electricity. So that technology exists. It’s 

mostly an older technology that’s there. 

So for example, in Arizona we have a plant that takes biomass 

from within about a 50 mile radius and generates electricity. That 

plant has contracts with a couple of the universities, I mean, the 

electrical providers in Arizona to buy that. 

One of the problems we’ve got is that with the decrease in the 

price of fossil fuels there’s a disincentive then to use biomass which 

now is more expensive, even than solar. 

But still as part of a comprehensive package it’s important. We’re 

talking about health a few minutes ago. That biomass that’s 

burned in a plant generates very little smoke and other items in 

smoke that threaten human health. So instead of burning it out in 

the woods if you can burn it in a facility, a biomass conversion facility, you can solve that problem. 

Right now the biomass part of this is a major stumbling block 

to how we can pay for and do effective landscape scale restoration, 

more work needs to be done. We’ve got ecological restoration institutes, state foresters and University of Idaho are working together 

in February to examine this biomass issue to try to look at innovative ways to do that, both for onsite disposal back in the woods 

without generating as much smoke and then being able to use it 

actually for electricity. 

Senator FRANKEN. Now I have great interest in that and have. 

Ms. Fennell, last May Chief Tidwell testified to this Committee 

on the interaction wildfire and climate change and has done this 

a number of times. This is, in a way, I think that climate change, 
104 

we have seen a change in the duration of the wildfire season. We 

have seen the change in the intensity of these fires and the size 

of these fires. This is now the new normal. 

I am supporting Senator Wyden’s bill, the Wildfire Disaster 

Funding Act of 2015 because, and Mr. Chairman I am just going 

to go a little bit over, if that is okay, just a minute or so. 

Senator RISCH. Do I have any choice? [Laughter.] 

Senator FRANKEN. Actually, you do. 

Senator RISCH. Go ahead. 

Senator FRANKEN. Okay, thank you. Thank you for exercising 

your option to give me the minute or so. 

It seems to me that we have so much, that we are doing so much 

fire borrowing that we should be treating this as the new normal 

and that is disastrous. 

Superstorm Sandy caused about $60 billion in damage, or at 

least the cost to Federal Government that this, I think, should be 

treated as a new normal. I think we should be treating these as 

disasters, especially these super huge fires, and about 30 percent 

of the cost comes from that. 

So I would just make a plea for Senator Wyden’s act which would 

use 30 percent as a disaster fund and treat it in that way because 

I think that is what it is. 

Thank you. Thank you, Mr. Chairman. 

Senator RISCH. Thank you, Senator Franken. 

Let me help you out a little bit with your interest in biomass. 

This is not new, particularly in Idaho. They have been running 

at this for over ten years, and they have been notoriously unsuccessful in doing it. 

Dr. Covington, rightly pointed out there’s additional research 

going on it. I would disagree a little bit with Dr. Covington in that 

one of the real challenges is the fumes and smoke and what have 

you that is put off by the burning of the biomass. Now certainly, 

it is better in a controlled atmosphere than it is in the woods. But 

having said that, the EPA would probably disagree a bit with you, 

Dr. Covington, that this is something that needs additional work 

because the private companies that have tried to do this have not 

been successful at it. 

There have been some successes but they are very, very limited. 

The only way, I think, that is it is going to be done, at least under 

present circumstances, is with subsidies from the Federal Government. I know that does not particularly trouble you, but there are 

those of us who are not looking down that road very favorably, 

but— 

Senator FRANKEN. May I respond very quickly? 

Senator RISCH. Please. 

Senator FRANKEN. We have a combined heat and power plant in 

St. Paul, Minnesota that generates electricity and also does the 

end, does the heat and cooling for downtown St. Paul. I think they 

have been successful and that this has been done successfully in 

other places. 

Senator RISCH. That is correct, and in the old days it was very, 

very common. Every small town in Idaho had a sawmill, and that 

sawmill had what they called a tepee right next to it. The tepee 

was a co-gen facility that generated heat and steam and electricity, 
105 

and it was very, very, common. Every small town had one. They 

are all gone. 

I don’t know, do you guys have tepees left in your states? They 

are gone from Idaho. But Senator Franken, you were correct. It 

was very, very common, but because of the cost of it and because 

of the environmental challenges they have been wiped out. They 

are gone. 

I am not saying it should not continue to be pursued. The University of Idaho is doing some great work in that regard. 

Senator FRANKEN. It is a great university. 

Senator RISCH. It is. It is my alma mater, I might add. [Laughter.] 

As long as we have mentioned that, my undergrad, as most of 

you know, was in Forest Management. A little over half a century 

ago I sat in the classroom. I took a couple of semesters of fire behaviors. If it was not the class, it was at least part of the studies 

in that particular class. 

But really, with all due respect, the things I have heard here 

today and the things I have heard over the many, many hearings 

we have had on this have really not put anything new on the table. 

Back then, half a century ago, we were only 53 years from the Big 

Burn in Idaho. Now we are over a century but back then it was 

only a half a century ago. The professors who taught, the people 

who worked in the woods, they all knew the Big Burn and they 

knew what had happened and they knew how fire behaved and 

what caused it and what the problems were. So this is not new. 

The problem here is not the problems that you, all of you, have 

described. Those problems have been known for a long, long time. 

The problem here is very, very political, and I do not mean republican versus democrat. With all due respect to our colleagues that 

live east of the Mississippi River, they really do not have an understanding of what fire is like in the ecosystem that we live in the 

West. And with all due respect to Senator Stabenow, who talked 

about private lands, look, in Idaho two out of every three acres is 

owned by the Federal Government. We never had a major fire in 

Idaho that it was not the Federal Government that was in it up 

to their ears and a lot of it due to poor management. 

The Good Neighbor laws or policies Senator Stabenow talked 

about, the people in Idaho do not particularly look at the Federal 

Government as a good neighbor when it comes to management of 

their yard. They do not cleanup their yard, and the result of that 

is we have major, major catastrophic fires and are sitting on the 

edge of it. 

When I was Governor we had a summer that had particularly 

bad fires, so I spent a lot of time in an airplane looking at those 

fires from the air. It was stunning to me. I knew this before this 

happened and it is not rocket science, but it was stunning what 

happens when a fire comes up against land that has been treated 

or even land that has been harvested, just harvested, or and more 

commonly and we have it in Idaho very commonly, and that is it 

comes against an area that had been burned within recent years 

and the fire just stops. It changes, its character changes, everything changes and the fire is much more containable. 
106 

So the problem, I guess I am following the camp with Senator 

Daines, and that is I am just tired of talking about this, you know? 

We all know what the problem is, and assent of the Crapo/Wyden 

bill is a really, really important and good response to this. What 

it does so simply, it tells the Forest Service that you should be 

using your prevention money for prevention instead of putting the 

fire out. 

If we did that one of you said, and I do not remember who it was, 

that this whole thing starts right here with this Committee. You 

are absolutely right. This is where it starts, and we really need to 

get it done. 

Thank you for holding the hearing, again, Madam Chairman. 

One would hope that at some point in time we are going to be able 

to move forward on this. So, thank you. 

Mr. WYSS. Senator Risch, if I may? 

The Chairman [presiding]: Mr. Wyss? 

Mr. WYSS. The one thing that is not being discussed in all of this, 

we’re talking about pretreatment and treatments. My job is to do 

long-term recovery for all the fires that have occurred in our state 

and around, and it comes with post-treatment as well. 

Once the timber has burned and it is still standing, cleaning up 

the fuel load of the burned timber which if not done will fall and 

become the next fire, and coming up with options for that including 

bio-char are significant items that we can look at. Because the 

market becomes so flooded with the burned timber, we have to find 

alternative options. And our state is looking significantly at biochar and other options with that burned timber to get it out of the 

forest so it doesn’t become fire again and fuel for the next fire. So 

I think we have to look at it not only as pretreatment, but posttreatment as well. 

Senator RISCH. Thank you very much, I appreciate it. 

Madam Chairman, thanks. 

The CHAIRMAN. Thank you, Senator Risch. 

There has been a lot of discussion about the need to do more 

treatment either pre- or post- and I certainly understand that. Of 

course it does come down, to a certain extent, to the dollars, the 

resources that are made available. But we also know that we have 

got some obstacles just in doing that and obtaining the necessary 

permits. I think Senator Daines was one who mentioned it. 

I would throw this out to you, Mr. Maisch, maybe to Chief Burnett or Mr. Wyss as well. In terms of those obstacles that keep us 

from really carrying out the hazardous fuels reduction program, 

what is in our way? Is it just a matter of dollars? Are there more 

politics to it that we need to address? Can you outline some of that 

for me? 

Mr. MAISCH. Yes, I’d be happy to. 

I think it is a suite of things. It is, in part, funding but probably 

the bigger part is at least on Federal lands, as we had some discussion here in the Committee, on the litigation side of this issue. 

Do you get at it through some kind of categorical exclusion process that would help with some of that? Do you do programmatic 

level NEPA that would clear very large projects on a landscape 

level so there’s only one NEPA process and then you implement 

projects that are covered by that, in that umbrella NEPA project? 
107 

So the potential litigants only get one bite at the apple instead of 

repeated bites every time we do smaller scale projects across the 

landscape. 

I think we have to start thinking in bigger terms and a broader, 

all hands, all lands. I think you’ve probably heard that term from 

previous committees. It’s not just the Federal lands. It’s the State. 

It’s local jurisdictions. 

But we do have to get a handle on that Federal piece, because 

that’s where the road block often is right now. 

The CHAIRMAN. Any other comments? 

Mr. WYSS. I would concur that in getting a handle on that. We 

have a DNR section of state land owned in the Carlton Complex 

fire that was cleared for treatment. NEPA, CEPA were both done, 

and the DNR was going to clear the burned timber. That is still 

tied up in litigation, and that timber is now falling to the ground 

and the wind storms and unable to clean it up or even recover dollars from that. So the litigation piece is a significant challenge to 

it. 

But it’s not only litigation. We have another track that’s above 

Highway 20 in between Twist, Washington and Okanogan, Washington where it’s a multiple jurisdiction ownership. The BLM has 

ownership, and the Forest Service has some ownership. Trying to 

do the necessary treatment, post-fire, has been slowed down because the two agencies do not work together. 

They need to streamline that piece to get, I mean, it’s all approved. But the BLM and the Forest Service are still having a 

slight disagreement, so on the best way to manage the removal of 

the timber. And that’s what’s causing our challenges of not being 

able to get this done. 

The CHAIRMAN. Ms. Fennell, you have in your report looked at 

the, just the reviews, the fire reviews and the concerns that we are 

seeing that we have not been doing the reviews as has been directed. Are some of the things, for instance, that Mr. Wyss just 

mentioned in terms of the agencies not coordinating well with one 

another? Is that something that we need to beef up or make sure 

are included as part of these reviews is what happens after the 

fire? 

Ms. FENNELL. We think that the reviews are a very important 

way of assessing the effectiveness of their ability to respond to fires 

and to suppress fires. And we called for, specifically, that they consider specific, clear criteria that they can use to select fires and 

then to conduct the fires and update their policies accordingly. We 

think that they can consider a multitude of criteria in selecting 

those fires and look for reducing how they are going to implement 

our recommendation to do so. 

The CHAIRMAN. This might not be a fair question, but I am going 

to ask it anyway. Is there one agency—does Forest Service do a 

better job than BLM or a State? Can you give me an indicator as 

to whether or not there is one model that might be working better 

than others or are all of these equally fraught with problems? 

Ms. FENNELL. Our work has shown that both Forest Service and 

Interior could benefit from greater information to make informed 

decisions. And we’ve noted in our recent work that both are looking 

to implement a number of different efforts to improve the way that 
108 

they are fighting wildland fire. But there has been a lot of studies 

that have gone before these particular reports and we still think 

that they need to target better information in terms of what the 

large fire reviews have shown, what the performance of different 

aircraft to fight fires has shown and also better ways to deal with 

preparedness and effectiveness. So we think there are opportunities for both agencies. 

The CHAIRMAN. Well coming from a state where we have got a 

lot of land that goes up in smoke every year and as a state we feel 

like we are pretty in tuned with what is going on with fires, and 

the state is a pretty good example to look to of how you bring all 

hands in to address threats, not only to communities, property, but 

just to the land itself. 

Are our Federal agencies not synching in sufficiently with our 

States and our local fire experts here? Is this part of our problem? 

Chief Burnett, you are smiling. 

Mr. BURNETT. You’re asking the tough question. I can’t tell you 

why it doesn’t happen. I can tell you that it needs to happen and 

that the benefits are clearly articulated in this panel. 

So, you know, Forest Ridge Wildfire Coalition has received 

grants from the Department of Natural Resources to do fuel modification efforts around there. We coordinate with the State agencies 

as well as the Federal agencies to do fuel treatments in that prescribed or in that general jurisdiction or geographical area. 

We’re working well with our partners as far as the restrictions 

that they have to go through in order to make it happen. You 

know, that’s and it’s, I think it’s a political issue and a logistic or 

a litigious concern. 

The CHAIRMAN. I appreciate that. 

I am going to ask Senator Cantwell to wrap up with the final 

questions, but I do not want to conclude without a final question 

to you, Mr. Zerkel, because you have raised the issue of aviation 

assets and where we are. You have questioned, very clearly, I 

think, the wisdom of the government-owned tankers and the proposal going forward with these next gen air tankers. You have 

noted, very clearly, I think, for the record that what we have is not 

only an inconsistency. You call it a double standard between the 

government-owned aircraft like the C130Hs and the fact that you 

have a different standard that is held toward the commercial aircraft that are stepping up. 

Do you think that the private air tanker industry can meet the 

need for 18 to 28 next gen air tankers with the specifications that 

the Forest Service has called for? 

Mr. ZERKEL. Senator, given a specific defined requirement and a 

specific contractual procedure I have no doubt that industry can 

meet any requirement that the Forest Service might have for large 

air tankers. 

We have a large amount of experience. The industry has been at 

it for an awful long time, but the problem in the past has been a 

mixture and an undefined set of qualifications that industry faces. 

We’re not going to spend a whole lot of capital if we don’t know exactly what it is the Forest Service requires and for how long they 

require it. 
109 

The CHAIRMAN. So you would not only need specific criteria for 

standards, although you are saying look, we just go by the FAA 

standards. You also need some definition in terms of how long that 

commitment from Forest Service would be to whether it is Lynden 

or other operators that would provide such aircraft. 

Mr. ZERKEL. That’s correct for the industry at large. 

First of all the range of tankers that they think they require. The 

18 to 28 is a little difficult for industry to comprehend. Is it 18? 

Is it 20? Is it 25? Is it 40, which it was before 2002. So that’s what 

I mean by defined set of requirements in terms of the numbers of 

large air tankers and then clear, concise contracting procedures. 

The CHAIRMAN. Just for the record, you had indicated you had 

stepped up to make the build out for your Hercules so it could meet 

the requirements that had been set forth by Forest Service, but because of tight timeframes, you were not accepted into that pool of 

eligible aircraft for contracting. What does it cost to basically outfit 

an aircraft to meet these standards in terms of investment that you 

made to prepare for this what was the commitment there? Because 

I understand now this aircraft is not even being used here in the 

country, and it is being used for fire fighting in Australia, I think 

you said? 

Mr. ZERKEL. That’s correct. 

Lynden spent about $4.5 million in the procurement of a retardant tank drop system, the installation and the training of our personnel to bid for that next gen 2.0 contract. We were not successful 

in the bid and maybe rightfully so because of one portion of our 

supplemental type certificate was incomplete. We accepted that. 

We’re going to fix that, and we are going to bid at the next opportunity. But the point is that we have those requirements, all of industry, not just Lynden, not just any of the other ones. 

The Forest Service, under this program, the public format program, would not have that. They could basically do whatever they 

wanted to do. Now I’m not saying they wouldn’t do a good job or 

the Coast Guard or a vendor or whatever that they get to do it 

wouldn’t do a good job. But the fact is they don’t have to whereas 

the rest of industry does. And it’s— 

The CHAIRMAN. So it is— 

Mr. ZERKEL. Yes. 

The CHAIRMAN. A different standard. 

Mr. ZERKEL. Absolutely. 

The CHAIRMAN. Thank you. 

Senator Cantwell? 

Senator CANTWELL. Thank you, Madam Chairman. 

I wanted to go back Chief Burnett and Mr. Wyss about the after 

effects because we are talking a lot here about obviously the economic loss of timber lands. But I am not sure we have given everybody a clear picture of how long it takes to recover. And one thing 

I mentioned earlier, the $300,000 from the Forest Service to help 

restore the impacts from the Wolverine fire-but can we talk about 

where we are one year after the Carlton Complex? 

Mr. WYSS. Sure. 

Senator CANTWELL. And what we need to do and what happens 

when the money runs out? What happens? Chief Burnett, if you 

wanted to comment on that as well. 
110 

Mr. WYSS. Okay. 

So one year after the Carlton Complex, I mean, we had $100 million worth of damage in a community and a county that’s the 13th 

largest county in the United States and 39,000 people. So 39,000 

people are trying to dig out of $100 million hole. 

It makes it challenging when you lose 500 structures. Our community took a significant financial impact to the loss of value. 20 

percent of our school district value is gone, 20 percent of our hospital district value is gone, and that drives significant cost factors. 

When you lose 50 people out of the community in Pateros because 34 homes burned inside the city limits, you no longer have 

people paying into the water system and the water fees go up double because there’s less people paying into the system and it has 

to be repaired. 

Our communities, our small businesses, when including in Chelan this year with the Wolverine fire in Chelan and the Reach fire, 

for 10 days were closed, completely. Our small businesses paid the 

credit card impact fees for the reservation in and the reservation 

out which are non-reimbursable. 

The communities and the small businesses who rely on tourism 

lost $1 million a day in the Winthrop and Twist area and $2.5 million in Chelan because the tourists were not allowed to come in because we were under immediate evacuations. 

When you look at the forestry and timber, the value of timber 

has dropped in half because the timber that was marketable 

burned and now there’s limited market. When you burn 200,000 

acres last year and then 500,000 acres this year and then millions 

of acres in Alaska, the timber market starts to get pretty flooded 

with burned timber and you have to get that off within a short period of time before it blue stains. 

Then you look at our reservations where, you know, they’re going 

to face 20 to 25 percent of their budget comes from timber and a 

billion dollar hole comes over a span. So our long-term recovery efforts are going to be 10 to 15 years in our small community to try 

to recover. 

For the rebuilding of homes and construction, only 40 people 

qualified, who were the most needy of needy to have homes rebuilt 

by volunteers through the VOAD partners and the national VOAD 

partners in donations. So we have 11 of those homes completed and 

done, and we were thinking we were on the upward trend when 

this fire hit and we lost 100 more homes. 

So back-to-back impacts have really hit our economy hard, our 

budgets hard, our roads, our transportation and infrastructure, but 

not only that, we’re going to suffer ramifications of unintended consequences with flood. We actually washed out a highway with just 

one inch of rain this last year because the trees couldn’t absorb it, 

and we’ll have it again this year with floods and snow pack. 

And we have 10,000 wildlife without a place to eat because we’ve 

burned all their habitat which then goes, Senator Stabenow talked 

about agriculture and Senator Cantwell you know we have the best 

apples and cherries in the world in our state. Well those deer eating the limbs and the buds off the trees which are impacting the 

agriculturalist’s future because they don’t have anything to eat. 
111 

So our ramifications and long-term impacts are going to be felt 

for a number of years, and it’s going to cause some of our folks to 

lose their businesses, their farms and ranches. And we will recover. 

I mean, that is my job as the lead recovery efforts, and we will do 

it. But we will come out of it stronger, more efficient and better. 

We just thank you, Senator Cantwell and Senator Murkowski, 

for holding these hearings to bring these issues to the forefront. 

Senator CANTWELL. Mr. Burnett, did you want to say anything 

about, you had a concern about logs, potentially, you know, more 

trees falling and potentially putting more at risk in the future? 

Mr. BURNETT. Right. 

As Jon was speaking that there is a lot of timber that’s harvested 

afterwards. But back to the competing interests of how to best deal 

with the wildfires and post-wildfires there’s a lot of logs that are 

not, a lot of standing timber, that is not allowed to be logged postfire. And it creates a significant danger with hazard trees. We’ve 

lost many wildland firefighters from tree hazards. 

The burn scars area that we look at for trying to catch a fire, as 

an incident management team we’ll look out ahead for any kind of 

natural barriers or manmade barriers. The natural barriers are, 

you know, rocks, trees, rivers or previous fire scars. If those previous fire scars are left untreated that is a hazard area that we 

can’t send our fire fighters into in order to gain access to other 

areas or to fight the fire in that area. 

Senator CANTWELL. Well Madam Chairman, thank you for this 

hearing. I want to thank all the witnesses, and obviously each of 

you have been dealing with this from one or more facets so we 

thank you for that. 

That is why, Madam Chairman, I want to work with you and see 

what we can do to move forward. 

I think the thing that might be different than some of the discussions that we have had before is the fact that, as Mr. Wyss said, 

the economic impacts here are something that we are going to feel 

for a long time. I think the threat that we see coming at us, that 

these are not the two worst years we are going to see, that the 

worst is still yet to come, I think demands us to think in new ways 

and figure out how to better prepare our nation for the economic, 

incredible economic, damage and loss that is going to occur and figure out a strategy for prevention and preparedness. 

So I look forward to working with you on that. 

The CHAIRMAN. Thank you, Senator Cantwell, and know that we 

both agree we have got a lot of work to do. I do think that we 

gained some good insight from the panel this morning and from the 

questions that were raised by other colleagues. 

You speak to the economic damage and the economic impact, 

post-disaster, post-fire, and you clearly have seen that in your 

state. Typically in Alaska we will see more acreage burned and 

very little lost in terms of property value. This year was different 

losing 55 homes in and around the south central area. 

I think that causes us to recognize that when we think about the 

economic impact, the loss, not only from a financial, but really from 

an emotional perspective is something that we need to be very, 

very cognizant of, but we also then need to be very wise, very 

smart and very strategic in how we manage these fires and finding 
112 

these levels of efficiency because, as you and I both know, the Federal dollars here are not getting that much more generous. 

I know in my state we have made dramatic reductions in our 

state’s budget this year which further restricts the ability of our 

state to be engaged. We need to be smart in how we are managing 

this, so to hear that we have assets that are either being held back 

or are somehow or other just not being as efficient as we need them 

to be, when you have agencies that are not coordinating, when you 

have differing standards, when you have inefficiencies that are 

built into this system, that is something that we can control. 

You and I cannot stop that fire today, but we can make sure that 

as we are dealing with these fires we are working smart and we 

are working efficiently and collaboratively. 

So I look forward to working with you and all of you. 

We appreciate the time this morning. 

Thank you. 

[Whereupon, at 12:16 p.m. the hearing was adjourned.] 
(113) 

APPENDIX MATERIAL SUBMITTED 
114 

Response to Post-Hearing Questions for the Record 

"Future Federal Wildland Fire Management Strategies" 

Committee on Energy and Natural Resources 

U.S. Senate 

Hearing held November 17, 2015 

Questions for Anne-Marie Fennell, Director 

Natural Resources and Environment 

U.S. Government Accountability Office 

1. What actions, if any, has GAO seen the Forest Service and DOl agencies take to 

prioritize hazardous fuel reduction funding to the areas of the country with the 

greatest need and risk of wildfires? 

GAO Response: Since our 2007 report highlighting the need for improved approaches to 

prioritizing fuel reduction funding, the agencies have developed several fuel reduction funding 

distribution tools. In our September 2007 report, we recommended that the agencies develop a 

systematic approach to allocating fuel reduction funding. 1 Beginning in 2009, the Forest Service 

and Interior both used systems collectively known as the Hazardous Fuels Prioritization and 

Allocation System (HFPAS) to distribute fuel reduction funds. Officials from both agencies told 

us these systems were developed to provide an interagency process for distributing fuel 

reduction funding to the highest-priority projects. According to Forest Service officials, however, 

in some cases HFPAS prioritized funding for areas where important resources existed but 

where the potential for wildland fires was low. Starting in 2014, the Forest Service instead 

began using a new system, which, according to officials, allows the agency to more effectively 

distribute fuel reduction funds based on areas where the highest probability of wildland fire 

intersects with important resources, such as residential areas and watersheds critical to 

municipal water supplies. 

Interior continues to distribute fuel reduction funding to its four agencies responsible for wildland 

fire management-the Bureau of Indian Affairs, Bureau of Land Management, Fish and Wildlife 

Service, and National Park Service-based on funding amounts derived from HFPAS, using 

results last generated in 2013. Officials told us, however, that Interior plans to develop a new 

system for distributing funds to reflect more current conditions and risks. Interior documents 

state that the new proposed model will assess the probability and likely intensity of wildland fire, 

the values at risk from fire, and the expected value of acres likely to burn. Until the model is 

developed, each Interior agency is relying on its own approach to distribute fuel reduction 

funding. For example, the Bureau of Land Management has created a tool that, similar to the 

Forest Service, accounts for both the highest probability of wildland fire and the presence of 

important resources. 

1GAO, '.Midland Fire Management: Better Information and a Systematic Process Could Improve Agencies' Approach 

to Allocating Fuel Reduction Funds and Selecting Projects, GA0-07-1168 (Washington, D.C.. Sept 28, 2007). 

GAO Questions for the Record 11117115 
115 

2. Currently, how do these agencies allocate funds to the field for hazardous fuel 

reduction? 

GAO Response: As detailed in our September 2015 report, 2 Forest Service officials told us 

their new system identifies locations where the highest probability of wildland fire intersects with 

important resources, such as residential areas and watersheds critical to municipal water 

supplies. These officials told us the new system allows the agency to invest its fuel reduction 

funds in areas having both a high probability of wildland fires and important resources at risk. In 

contrast, according to officials, HFPAS in some cases prioritized funding for areas where 

important resources existed but where the potential for wildland fires was low. The new system 

has also identified locations for funding adjustments to Forest Service regions. For example, in 

2015, the agency's Eastern and Southern Regions received a smaller proportion of fuel 

reduction funding than they had previously received. In contrast, some western regions saw 

increases, because results from the system showed that the western regions had more areas 

with both important resources and high wildland fire potentiaL 

Interior continues to distribute fuel reduction funding to its four agencies using HFPAS results 

that were last generated in 2013. Within Interior, officials from the four agencies told us they 

have developed, or are in the process of developing, funding distribution systems and tools 

while they wait for Interior to complete its new system for distributing funds. The Bureau of Land 

Management, for example, uses a fuel reduction funding distribution tool that maps values at 

risk, including critical infrastructure, sagebrush habitat, and invasive species data. It combines 

this information with data on wildland fire probability to create a spatial illustration of the values 

at risk relative to potential fire occurrence, and then use the results of this analysis to fund its 

state offices. The Bureau of Indian Affairs uses its own tool to distribute fuel reduction funding to 

its regions based on wildland fire potential data, combined with fire occurrence history and 

workload capacity, to generate a model that shows potential fire risk and capacity across its 

units. Officials from the Fish and Wildlife Service told us they are developing a fuel reduction 

funding distribution tool, expected to be used for fiscal year 2016, which considers fire risks 

associated with each unit Officials from the National Park Service told us the agency uses an 

approach that relies on historical amounts, based largely on HFPAS, under which it distributes 

funding for specific projects identified at the headquarters leveL 

3. One of the areas GAO reviewed in this latest report was whether agencies were 

conducting post-fire reviews. Are the Forest Service and the DOl agencies conducting 

post-fire reviews consistent with Congressional direction and agency policy? 

GAO Response: As detailed in our September 2015 report, the Forest Service and Interior 

agencies have conducted reviews to assess their effectiveness in responding to wildland fires, 

but have not consistently followed agency policy in doing so. For fiscal years 2003 through 

2010, congressional committee reports directed the Forest Service and Interior to conduct 

reviews of large fire incidents. Beginning in fiscal year 2006, these reports included a cost 

threshold, specifying that such reviews be conducted for fires involving federal expenditures of 

$10 million or more. The agencies, in turn, have each developed their own policies that 

generally direct them to review each fire that exceeds the $10 million threshold. The agencies 

have not consistently conducted reviews meeting the $10 million threshold, in part because, 

according to officials, doing so does not reflect the agencies' focus on assessing the 

2

GAO, !Midland Fire Management: Agencies Have Made Several Key Changes but Could Benefit from More 

Information about Effectiveness, GA0-15-772 (Washington, D.C.: Sept. 16, 2015). 

GAO Questions for the Record 11117/15 2 
116 

effectiveness of their response to fire. For example, Forest Service officials told us that focusing 

exclusively on suppression costs when selecting fires limits the agency in choosing those fires 

where it can obtain important information and best assess management actions and ensure 

they are appropriate, risk-based and effective. Forest Service officials acknowledged the need 

to develop more specific criteria for selecting fires to review, and in July 2015 told us they are 

working to update their criteria for doing so. 

Within Interior, Bureau of Land Management officials told us the agency completed its last fire 

review based on the $10 million threshold in 2013. These officials told us that the agency, 

similar to the Forest Service, plans to shift the emphasis of its reviews to evaluate management 

actions rather than focusing on cost, and both are working to determine criteria for selecting 

fires for review. Interior headquarters officials told us that the Fish and Wildlife Service and 

National Park Service have continued to follow the direction provided through their policies 

regarding reviews that met the $10 million threshold. However, these officials acknowledged the 

need to improve Interior's approach to selecting fires for review, and in July 2015, told us they 

plan to develop new criteria for use by all Interior agencies in selecting fires to review and 

expected the effort to be completed by the end of calendar year 2015. Since that time, however, 

Interior officials told us they expected the effort to extend beyond calendar year 2015. 

4. Currently, what criteria do the Forest Service and the DOl agencies use to select fires 

for post-fire reviews? What do the Forest service and the DOl agencies look at in a 

post-fire review? What do they do with the information gathered in a post fire review? 

GAO Response: As noted in our September 2015 report, Forest Service and Interior officials 

told us they are working to improve their criteria for selecting fires to review. Forest Service 

officials told us the agency judgmentally selects incidents to review based on a range of broad 

criteria, such as complexity and national significance, taking into account political, social, natural 

resource, or policy concerns. Using these broad selection criteria, the Forest Service reviewed 5 

wildland fire that occurred in 2012 and 10 that occurred in 2013. 3 We found, however, that given 

these broad criteria, it is not clear why the Forest Service selected those particular fires to 

review, and not others. 

In conducting the reviews for those 2 years, the Forest Service did not use consistent or specific 

criteria. In both 2012 and 2013, the reviews included four common objectives, which were to 

identify (1) best business practices used on fires the past fire season, (2) how social and 

political issued factored into agency decision making, (3) which current procedures can be 

enhanced or expanded, and (4) improvements that can be made in sharing and clarifying 

expectations. In 2013, the reviews included two additional objectives: (1) examine actions taken 

by the incident management team and the local agency administrator to meet the direction 

provided by the Forest Service Chief, 4 and (2) assess the consideration and effectiveness of 

applying risk management concepts to incident cost through the associated decisions and 

expenditures as an outcome. A 2013 report assessing the usefulness of the F crest Service's 

five reviews of 2012 fires noted shortcomings in consistency across the reviews, including 

3

As of July 2015, the Forest Service had not selected fires to review from the 2014 wildland fire season. 

41ncident management teams are specialized teams mobilized to respond to wildland fires, with the size and 

composition of the team determined by the complexity of the fire. The agency administrator is generally the official in 

charge of a field unit, such as a national forest supervisor or national park superintendent, having responsibility for 

managing the fire. These officials must approve major decisions that incident management teams make during a fire 

response. 

GAO Questions for the Record 11/17/15 3 
117 

unclear criteria for selecting fires and conducting reviews, as well as limitations in the specificity 

of the resulting reports and recommendationss 

In the most recent review done by the Interior agencies-BLM's review of a 2013 fire in 

Alaska-the review objectives included, among others, examining (1) the strategic decisions 

made on the fire with respect to relevant land management plans, (2) whether appropriate line 

officers were involved in financial oversight and strategic decisions, (3) whether cost-saving 

actions were effectively implemented on the incident, and (4) costs as they related to fire 

suppression strategies and tactics, social and political issues, and the effective use of 

personnel, equipment, and aircraft. In November 2015, Interior officials reported that Interior is 

completing an analysis of Large Fire Cost Reviews from 2007 to 2014, and that it will share the 

findings and recommendations from that analysis with the Interior Fire Executive Council. The 

Council is then to advise Interior regarding specific criteria for use in reviewing wildland fires. 

We did not review the agencies' use of information provided through the completed fire reviews. 

5. Your written testimony states that "changing climate conditions ... have increased the 

length and severity of wildfire seasons, according to many scientists and 

researchers." Could you describe the scientific evidence regarding the link between 

human-caused climate change and wildfire risks? 

GAO Response: As described in our September 2015 report, according to the U.S. Global 

Change Research Program's 2014 National Climate Assessment, projected climate changes 

suggest that western forests in the United States will be increasingly affected by large and 

intense fires that occur more frequently. 6 According to the 2014 Assessment, climate change is 

increasing the vulnerability of many forests to ecosystem changes and tree mortality through 

fire, insect infestations, drought, and disease outbreaks. The 2014 Assessment also stated that 

in some regions, prolonged periods of high temperatures associated with droughts contribute to 

conditions that lead to larger wildfires and longer fire seasons. The increasing prevalence of 

extreme conditions that encourage wildfires can convert some forests to shrublands and 

meadows or permanently reduce the amount of carbon stored in existing forests if fires occur 

more frequently, according to the 2014 Assessment. 

We also noted in our 2015 report that changing climate conditions, including drier conditions in 

certain parts of the country, have increased the length and severity of wildfire seasons, 

according to many scientists and researchers. For example, in the western United States, the 

average number of days in the fire season has increased from approximately 200 in 1980 to 

approximately 300 in 2013, according to the 2014 Quadrennial Fire Review. In Texas and 

Oklahoma this increase was even greater, with the average fire season increasing from fewer 

than 100 days to more than 300 during this time. 

5Wildland Fire Lessons Learned Center, Lessons From Recent Large Fire Reviews: Brieffng Paper(August 7, 2013). 

There was no similar analysis performed of the Forest Service's 10 reviews of fires occurring in 2013. 

6 Melillo, Jerry M., Terese (T.C.) Richmond, and Gary W. Yohe, eds., Climate Change Impacts in the United States: 

The Third National Climate Assessment. U.S. Global Change Research Program (Washington, D.C .. U.S. 

Government Printing Office, 2014). The U.S. Global Change Research Program coordinates and integrates federal 

research on changes in the global environment and their implications for society. The 13 federal agencies that 

participate in the program are the Departments of Agriculture, Commerce, Defense, Energy, Health and Human 

Services, Interior, State, and Transportation; the Environmental Protection Agency; the National Aeronautics and 

Space Administration; the National Science Foundation; the Smithsonian Institution; and the U.S. Agency for 

International Development. 

GAO Questions for the Record 11117115 4 
118 

6. Looking forward, what does the scientific research indicate about what a changing 

climate will mean for wildfire damage in future decades? 

GAO Response: According to the United States Global Change Research Program's May 2014 

National Climate Assessment, given strong relationships between climate and fire, projected 

climate changes suggest that western forests in the United States-even when modified by land 

use and rnanagernent activities, such as fuel treatments-will be increasingly affected by large 

and intense fires that occur rnore frequently. Eastern forests, according to the Assessment, are 

less likely to experience irnrnediate increases in wildfire, unless a point is reached at which 

rising temperatures cornbine with seasonal dry periods, rnore protracted drought, and/or insect 

outbreaks to trigger wildfires. 

GAO Questions for the Record 11/17115 5 
119 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

Complete references cited in these responses can be found at tbe end of responses. 

Questions from Chairman Lisa Murkowski 

Ouestion 1: Recognizing that budget constraints exist and that we cannot treat every acre, what does an 

effective fuels management program, in your view, look like? 

An effective fuels management program in frequent-fire forest types requires several elements: 

I. Treatments should be effective at restoring forest health and resiliency (Covington et aL 1994). To the 

extent practicable, and understanding that treatments must comply witb federal laws and regulations, 

it is ecologically and economically most effective to use restoration-based approaches to reduce 

excess fuels-not single objective treatments that are only focused on reducing hazardous fuels. 

Restoration-based treatments will reduce tree densities to within scientifically established levels and 

will emulate forest pattem and composition and restore self-regulatory processes (Covington ct al. 

1999). Using a restoration approach will concurrently enhance and protect otbcr resource values such 

as wildlife habitat, watershed function, and recreational values, while restoring self-regulatory 

mechanisms important for adaptation to climate change. This approach also increases the long-term 

effectiveness of treatments and enables low-cost maintenance through the use of prescribed fire, 

therefore improving the economic retum on investment (Ecological Restoration Institute 20 13) 

2. Treatments should be strategically placed to reduce the risk of mega fire (sec question 2). 

3. Treatments should be prioritized to protect values at risk (see question 3). 

Ouestion 2: Where should fuel reduction treatments occur to reduce tl1c size and severity of expensive 

mcgatircs'l Why? 

Federal lands arc managed to meet multiple objectives. In response to increased large fire in tbe 

Soutlnvcst, however, tbc ERI conducted scenario analysis research (Waltz 2012) to evaluate tbe 

effectiveness of the United States Forest Service (USFS) fuel reduction priorities based on fire hazard 

alone, as modeled by potential to crown, or bum, tbrough tree tops. We examined the half-million acre 

landscape bumcd in tbc 2011 Wallow Fire in eastem Arizona. The goal was to determine what the 

outcomes of a Wallow-like fire would have been had forest treatments been conducted on all high hazard 

areas, if implemented prior to 20 II. High fire hazard areas were mapped in wildland-urban interfaces 

(WUis), tbc greater landscape outside of the WUI, and wildemess areas based on pre-Wallow conditions. 

Treatments were simulated in the WUI areas and in the entire landscape. The simulated modeling results 

showed that: 

Simulated treatments implemented only in WUI areas reduced the modeled potential active crown fire 

threat by 12% and reduced flame lengths by 6%. 

T rcatmcnt simulations nm on all high fire hazard areas resulted in an active crown fire reduction of 

40% and flame lengths by 30%. 

WUI-only treatments result in losses in ecological integrity across the landscape because high fuel 

loadings, which lead to uncharacteristically high fire severities and intensities, continue over tl1e 

broader landscape. 

In summary, in order to reduce the size and severity of mega fire, treatments are needed outside tbe WUL 

Treating only in tbe WUI will not prevent megafires. Caveat: public lands are not managed for one goal 
120 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

(e.g., to reduce size and severity of mega fires) mtd have limitations on treatment opportunities dependent 

on management designation and other uses. 

Question 3: In your opinion, how should the Forest Service and DOI agencies prioritize their hazardous 

fuels reduction progrmn ftmds to maximize the benefit in creating resilient forests and reduce the risk of 

mcgafires? 

The federal research labs. including the USFS Research Stations, futcragcncy Fire Labs, and 11trcat 

Assessment Centers, have developed tools and spatial products to identify and categorize risk of fire with 

other priorities to best inform federal allocation offucls reduction treatments to protect values and 

resources (summarized in Dillon ct al. 2015, additional references listed below, and see 

http://www.forestsandrangclands.gov/stratcgy/index.shtml). 

In addition, a 2013 Ecological Restoration Institute report by Crouse and Waltz described methods to 

identify treatment priority areas to meet dry-forest restoration goals across the Apachc-Sitgrcaves 

National Forests in eastern Arizona. In historically frequent-fire forests, like ponderosa pine, restoration 

strategies and priorities cart reduce large-scale, uncharacteristically severe wildfire. In these systems, the 

report recommends using variables such as vegetation type and structure, topography, land-usc 

designation, watershed health, m1d WUI to prioritize treatment area as follows: 

WUI areas at risk of fire. 

Frequent-fire forest types that have had fire exclusion and demonstrate stmctural alterations resulting 

in stands that arc more dense thm1 historically found. 

Watersheds that have been determined to be functioning at risk or having impaired function might be 

considered priority treatment areas. 

Slopes that arc operationally feasible for restoration thinning (the slope limitations vary by forest and 

region depending on available industry mtd other management designations). 

It is critical to note that existing land-use designations may limit where treatments can be conducted 

(sec report). 

Question 4: The Forest Service and the DOI agencies talk about managing some wildland fires for 

resource benefits. In your experience can wildfires be managed for resource benefits? What resource 

benefits are there to allowing a wildfire to bum'> 

Reported benefits fi·om the literature: 

Reduce surface fuels (Larson ct al. 20 13) 

Reduce canopy fuel loads (Hunter et al. 2011) 

Reduce potential fire behavior m1d subsequent bum severity (Hunter et aL 2011, Parks ct al. 2013) 

Reduce tree density (Fuk and Laughlin 2007, Taylor 2010. Hunter et aL 2011, Larson et al. 20 13) 

Reduce stmtd basal area (Hunter ct aL 2011) 

Reduce density of fire-intolerant tree species (Fuk and Laughlin 2007) 

2 
121 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

Conditions and limitations: 

Studies are commonly limited to individual fires or wilderness landscapes. 

Benefits are found to be related to bum severity: there are limited benefits to areas that bum with too 

low or too high severity fire (Hw1ter et al. 2011, ERI unpublished data). 

o Areas burned in low severity fire can still have high stand density and fuel loading (Hunter et 

al. 20 II, ERl unpublished data) 

o Areas burned in high severity fire can result in a vegetation type conversion and ecological 

deterioration (van Wagtendonk et al. 20 12). 

Fires can change understory plant community composition, but effects on plant abundance and 

species richness (the number of different species) is uncertain (Laughlin and Fulc 2008). 

First-entry fires on general-usc forested public lands cm1 be dominated by low severity areas that 

show little benefit at reducing fuels or tree densities (ERI unpublished data). 

First-entry fires em1 produce a regeneration pulse, which may lead to vegetation type conversion or 

continued poor ecological condition (Taylor 2010, Larson et al. 20 13). 

Multiple entries with fire have variable results: In some cases severity in areas previously burned by 

resource benefit fires is lower than the initial (first-entry) bums. In other cases, bum severity is higher 

with repeated entry and this can lead to an increase in high-severity areas and decreased ecological 

integrity (Hunter eta!. 2011, van Wagtcndonk eta!. 2012, Larson et al. 2013). 

Effects of wildland fire management on old trees are not well studied (but sec Taylor 20 I 0). 

o Thinning small trees has been reported, which could increase the health of old trees (Fule and 

Laughlin 2007, Taylor 2010, Larson ct a!. 20 13). 

o However, mortality of old trees has also been reported in managed fires (Taylor 2010). 

Effects on tree and stand spatial pattcms and relationships to ecosystem health arc uncertain (but sec 

Taylor 2010). 

Effects on landscape structure and relationship to ecosystem health are uncertain. 

Questions from Senator John Barrasso 

Ouestion 1: Across the West, there is a particular! y devastating one-two punch destroying sage-grouse 

habitat. When rangeland fire destroys sagebrush habitat for sage grouse, quick moving invasive species 

such as cheatgrass dominate the landscape before sagebrush can return. Cheatgrass creates a lack of 

biodiversity and increases the risk of future catastrophic wildfire dmnage. This cycle creates a downward 

spiral where both rangeland fire and invasive species fuel the loss of sage-grouse habitat. 

In your experience, how big of a role do invasive species play when considering future wildfire risks') 

The scope of the invasive problem in some areas is on a scale unprecedented since the last icc age and 

is likely to continue to worsen as invasive species continue to spread and fires in some invaded 

ecosystems become more frequent (Betancourt 20 15). 

1l1c invasion of mm1y western ecosystems, including deserts, grasslm1ds, and shrub lands, by invasive 

plant species, particularly non-native annual grasses such as chcatgrass (Bromus tectorum) m1d 

medusal1ead-rye (Taeniathemm canput-medusae), is well-researched and documented (Brooks et al. 

2004, Zauhar eta!. 2008, Pierson et al. 20 II). At the landscape level, wildfire frequency and 

magnitude have increased due to invasive annual grasses, particularly following disturbance (Coates 

eta!. 20 15). 

3 
122 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

Many of these alterations can lead to new and novel fire regimes and ecosystems. Difficulties in 

management occur when novel ecosvstcms, never before seen, arise following changes in ecological 

pattems and processes (including species invasions) (Williams and Jackson 2007). 

Interactions between wildfire, drought, and invasive annual grasses can drive shifts in ecosystem 

structure and function and change fire regimes, resulting in habitat fragmentation, habitat degradation, 

increased probability of fire, lengthening of the fire season and loss of plant communities (Brooks et 

a!. 2004, Davies and Nafus 2013, Betancourt 2015, Brooks eta!. 2015), and loss of wildlife species 

diversity, including losses to greater sage grouse (Centrocercus urophasianus), and species such as 

black-tailed jackrabbit (Lepus calif<>rnicus) and Paiute ground squirrel (Spermophilus mol/is), which 

arc key prey for golden eagles (Aquila chrysaetos) and prairie falcons (Falco mexicanus) (Knick eta!. 

2003) 

Question 2: In May the Energy and Natural Resources Committee held a wildland fire hearing. During 

the hearing, one of the witoesses, Mr. Bob Eisele, a retired Watershed and Fire Analyst witoess spoke 

about his concem with the amount of time needed to complete the Santa Ana Watershed Environmental 

Impact Statement. In his testimony he stated that "to do nothing is to doom the forest to a stand 

replacementfire .. , 

In your view, if we do not complete environmental reviews for needed treatment activities in a more 

timely fashion and on a larger scaler, are we indeed dooming our forests to more mega.fires? 

Conducting NEP A at the scale of the problem (in the case of megafire, at the scale of I 00,000 acres or 

more) is one approach for accelerating landscape scale restoration to address mega fires. The recent 

completion of the first Environmental Impact Statement (EIS) for the Four Forest Restoration Initiative 

(4FRI) in Arizona proves that the NEPA process can successfully analyze one million acres of forest. 1l1e 

final Record of Decision for that assessment was signed in April 2015 and clears almost 600,000 acres for 

treatment (USDA Forest Service 2015). 

Accelerating the time line for completion of the environmental review process is possible with adequate 

human and financial resources. Another factor that influences our ability to solve the problem of mega 

fire is to prioritize and strategically place treatments where they arc most effective (see questions 2 and 3 

answered in response to Senator Murkowski). 

Questions from Senator Elizabeth Warren 

Nationwide. 9.8 million acres of land have already bumcd in the 2015 fire season, making it one of the 

most devastating years on record. And although specific numbers can fluctuate dramatically from year to 

year, the long-term trend is clear- wildfires arc becoming more frequent and more dangerous. Since 

1980, the typical fire season in the West has grown by about 100 days. Fires of every size on westem 

federal lands arc more common than they were in the 1980s. with fires of more than 25,000 acres 

exhibiting the biggest change; they are now more than three times as frequent as they were just three 

decades ago. 

1l1ere is no one factor that completely explains all of this increase. But given the scientific consensus that 

anthropogenic climate change is exacerbating the risks of extreme weather, it is important that we fully 

understand the connection between climate change and wildfires. 

4 
123 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

Question 1: Your written testimony states that "research shows that. .. climate change is influencing the 

frequency and size of fires." Could you describe the scientific evidence regarding the link between 

human-caused climate change and wildfire risks? 

Research has shown that the observed increase in frequency and severity of drought and wildfire are 

interrelated and numerous studies have directly linked these increases in frequency and severity of 

disturbance to climate change (Grissino-Mayer and Swetnam 2000, Westerling et al. 2006, Allen ct al. 

2010, Willian1s et al. 2010, Williams et al. 2014a, Williams et al. 2014b).Scientists attribute extreme fire 

behavior principally to regional and localized fire weather (McKenzie et al. 2004). Specific cxan1plcs of 

studies suggesting that climate change is already affecting wildfire frequency and severity include: 

Wcsterling et al. (2006) showed that wildland fire activity in the wcstem U.S. has recently increased 

and documented increases in large uncharacteristic fire frequency, longer fire durations, and longer 

fire seasons. 

Across Forest Service lands in the Sierra Nevada and the southem Cascade Mountains in Califomia 

and Nevada, Miller et al. (2009) found that the area burned annually, the size of the fires, and the 

extent of high severity stand-replacing fires had increased noticeably since the 1980s. 

In Yosemite National Park, Lutz ct al. (2009) found that the average annual area bumcd by lightningignited fires since the 1980s had double compared to the prior decade. 

Without restoration based fuel reduction, as climate continues to shift toward more arid conditions in the 

southwcstem U.S. (Williams et al. 2010, Kunkel et al. 2013, Garfin et al. 2014), existing frequent-fire 

forested ecosystems arc projected to undergo large contractions and potential transitions to woodland 

and/or grassland ecosystems, and degraded ecosystem structure and function (Covington ct al. 1994, 

Allen and Breshears 1998, Rehfeldt et al. 2009, Laughlin ct al. 2011, Bagdon and Huang 2014. Stoddard 

et al. 2015) contributing to an overall net loss (when combined with loss due to disturbances) of forested 

ecosystems. 

Question 2: Looking fmward, what does the scientific research indicate about what a changing climate 

will mean for wildfire damage in future decades? 

Globally, increasing temperature and more extreme fire weather is projected to drive future fire 

regimes. Temperatures exponentially int1uence atmospheric evaporation demands; as temperatures go 

up. tl1c atmosphere takes up more water, thereby the system gets drier. The number of large fires is 

correlated with wam1cr temperatures and earlier spring snomnelt (Pechony and Shin dell 20 l 0, 

Williams ct al. 20\2, Westcrling et al. 2006) 

The number of large wildfires in tl1e westcm U.S. has been increasing since the mid-1980s. Eightyfour fires greater than 100,000 acres have been reported since 2005. 2015 is second only to 2006 for 

the number of acres bumed (Westerling et al. 2006, more at http://www.nifc.gov/fireh1fo/nfn.htm). 

The National Research Council estimated that each degree Celsius of additional warming will 

increase the area bumed by 200-400% in parts of the westem U.S. According to Janos Pasztor, 

United Nations Assistant Secretary-General on Climate Change, the commitments made to date still 

equate to a projected 3 degrees C increase in mean global temperature by the year 2\00. 

(http://www.nationalacademies.org/includes/StabilizationTargetsFinal.pdf) 

Anticipated post-\vildfire forest trajectories concluded tl1at severe climate change may lead to nonforest conditions, loss of critical habitat and loss of \Yater quality and supply (Coyington et al. 1994. 

Azpclcta ct al. 2014, Brusca ct al. 2013, Smith et al. 2011). 

5 
124 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

References and additional information: 

Senator Murkowski Question 1 

Covington, W.W., Everett, R.L, Steele, R., Irwin, L.L., Daer, T.A., and Allen, N.D. 1994. Historical and 

Anticipated Changes in Forest Ecosystems of the Inland West of the United States. Journal ol 

Sustainable Forest!)!, 2:13-63. 

Covington, W.W., Niering, W.A., Starkey, E., and Walker, J. 1999. Ecosystem Restoration and 

Management: Scientific Principles and Concepts. Pp. 599-617 in R.C. Szaro, N.C. Johnson, W.T. 

Sexton, and A.J. Malk (cds.). Ecological Stewardship: A common reference for ecosystem 

management. Volume 11. Elsevier Science. Oxford, U.K., 741 p. 

Ecological Restoration Institute. 2013. TI1c efficacy of hazardous fuel treatments: A rapid assessment of 

the economic and ecologic consequences of alternative hazardous fuel treatments: A summary 

document for policy makers. Northern Arizona University. 28 pp. 

Senator Murkowski Question 2 

Crouse, J.. and A.E.M. Waltz. 2013. Identifying priority treatment areas across the Apachc-Sitgreaves 

National Forests. Ecological Restoration Institute Report. www.nau.edu/cri/librarv. 

Waltz, A.E.M. 2012. lnlpacts of fire hazard assessment and fuel reduction priorities on mega-fire 

outcomes. Ecological Restoration Institute Fact Sheet. www.nau.edu/eri/libraw 

Senator Murkowski Question 3 

Agcr, A.A., Valliant, N.M., and Finney, M.A. 20 I 0. A comparison of landscape fuel treatment strategies 

to mitigate wildland fire risk in the urban interface and preserve old forest structure. Forest Ecology 

and Management, 259(8), 1556-1570. doi:l0.1016/j.forcco.2010.01.032 

Calkin, D.E., Ager, A.A., and Gilbertson-Day, J. 2010. Wildfire risk and hazard: Proceduresjor thefirst 

approximation. (General Technical Report No. GTR-RMRS-235). Ft. Collins, CO: U.S. Department 

of Agriculture, Forest Service, Rocky Mountain Research Station. 

Cochrane, M.A., Moran, C.J., Wimberly, M.C., Bacr, A.D., Finney, M.A., Bechcndorf, K.L., ... Zhu. Z. 

2012. Estimation of wildfire size and risk changes due to fuels treatments. International Journal ol 

Wildland Fire, doi:IO.l07l/WF11079 

Dillon, G.K, Menakis, J., and Fay, F. 2015. Wildland Fire Potential: A tool for assessing wildfire risk and 

fuels management needs. USDA FS Proceedings RMRS-P-73. 

Jones, J.G .. Chung, W., Scielstad, C., Sullivan, J., and Krueger, K. 2010. Optimizing spatial and temporal 

treatments to maintain ejjective .fire and non,jire fi<els treatments at landscape scales. (Final Report, 

Joint Fire Science Program No. JFSP Project 06-3-3-14). Washington, D.C.: U.S. U.S. Department 

of Agriculture/U.S. Department of the Interior, Joint Fire Science Progran1. 

Stephens, S.L., Mciver, J.D., Boerner, E.J., Fettig, C.J., Fontaine, J.B., Hartsough, B.R., .... Schwilk, D. 

W. 2012. TI1e effects of forest fuel-reduction treatments in the United States. Bioscience. 62(6), 549. 

Syphard, A.D., Scheller, R.M., Ward, B.C., Spencer, W.O., and Strittholt, J.R. 2011. Simulating 

landscape-scale effects of fuels treatments in the Sierra Nevada, California, USA. International 

Journal of'Wildland Fire. 20,364-383. doi:l0.1071/WF09125 

Thompson, C .M., Zielinski. W.J., and Purcell, K.L. 2011. Evaluating management risks using landscape 

trajectory analysis: A case study ofCalifomia fisher. Journal of' Wildlife Management, 75(5), 1164-

1 I 76. doi: 10.1002~jwmg.l59 

Thompson, M.P., Calkin, D.E., Agcr, A.A., and Gilbertson-Day, J.W. 201 I. Advancing effects analysis 

for integrated, large-scale wildfire risk assessment. Environmental Monitoring and Assessment. 179, 

217-239. 

6 
125 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

Senator Murkowski Question 4 

ERI (Ecological Restoration Institute). Unpublished data. On file at Northem Arizona University, 

Flagstaff 

Pule, P.Z., Laughlin, D.C. 2007. Wildland fire effects on forest structure over an altitudinal gradient, 

Grand Canyon National Park, USA. Journal of Applied Ecology, 44:136-146. 

Hunter, M.E., Iniguez, J.M., Lentile, L.B. 2011. Short- and long-term effects on fuels, forest structure, 

and wildfire potential from prescribed fire and resource benefit fire in southwestcm forests, USA. 

Fire Ecology, 7: I 08-12!. 

Larson, AJ., Belote, R.T, Cansler, C.A., Parks, S.A., Dietz, M.S. 2013. Latent Resilience in Ponderosa 

Pine Forest: Effects of Resumed Frequent Fire. Ecological Applications, 23:1243-249. 

Laughlin, D.C.. Pule, P.Z. 2008. Wildland fire effects on understory plant communities in two fire-prone 

forests. Canadian Journal ojForest Research. 38:133-142. 

Parks, S.A., Miller, C., Nelson, C.R., Holder, Z.A. 2014. Previous fires moderate bum severity of 

subsequent wildland fires in two large westem US wildemcss areas. Ecosystems, DO 1: 

I 0 I 007/sl 0021-0 13-9704-x. 

Taylor, A.H. 2010. Fire disturbance and forest stmcturc in an old-gro"1h Pinus ponderosa forest, 

southem Cascades, USA. Journal a/Vegetation Science. 2!:561-572. 

van Wagtcndonk, J.W., van Wagtcndonk, KA., and Thode, A.E. 2012. Factors associated \Yith the 

severity of intersecting fires in Yosemite National Park, Califomia, USA. Fire Ecology, 8:11-32. 

Senator Barasso Question 1 

Betancourt, J.L 2015. Energy flow and the "grassification" of desert shmblands. PNAS, 112 (31) 9504-

9505. doi:IO.l073/pnas.l5!2078!!2 

Brooks, M.L, Matchett, J.R., Shinncman. OJ., and Coates, P.S., 2015, Fire pattems in the range of 

greater sage-grouse, 1984-2013-Tmplications for conservation and management: U.S. Geological 

Survey Open-File Report 2015-1167, 66 p., http://dx.doi.org/10.3133/ofr20!5!!67. 

Brooks, M.L, D'antonio, C.M., Richardson, D.M., Grace, J.B., Keeley, J.E., DiTomaso, J.M., and Pyke, 

D. 2004. Effects of invasive alien plants on fire regimes. BioScience, 54(7), 677-688. 

Bmsca, R.C., Wiens, J.P., Meyer, W.M., Edlc, 1. Franklin, K, Overpeck, J.T, Moore, W. 2013. Dramatic 

Response to Climate Change in the Southwest: Robert Whittaker's 1963 Arizona Mountain Plant 

Transect Revisited. Ecology and Evolution, 3, 3307-3319. 

Coates, P.S., Ricca, M.A., Prochazka, B.G., Doherty, KE., Brooks, M.L, and Casazza, M.L 2015. Longterm effects of wildfire on greater sage-grouse-Integrating population and ecosystem concepts for 

management in the Great Basin: U.S. Geological Survey Open-File Report 2015-1165,42 p., 

http://dx.doi.org/l 0.3133/ofr20!5!16. 

Davies, KW., and Nafus, A.M. 2013. Exotic annual grass invasion alters fuel amounts, continuity and 

moisture content. International Journal olWildland Fire, 22(3), 353-358. 

Knick S.T., Dobkin D.S., Rotenberry J.T., Schroeder M.A., VandcrHacgcn W.M., Van Riper, C, ITT. 

2003. Teetering on the edge or too late? Conservation and research issues for avifauna of sagebmsh 

habitats. 111e Condor 105: 611-634. 

Olsson, A.D., Betancourt, J., McClaran, M.P., and Marsh, S.E. 2012. Sonoran Desert Ecosystem 

transfonnation by a C4 grass without the grass/fire cycle. Diversity and Distributions, 18( 1 ), 1 0-2!. 

Pierson, F.B., Williams, C.L Hardegree, S.P., Weltz, M.A., Stone, JJ., and Clark, P.E. 201!. Fire, plant 

invasions, and erosion events on westcm rangelands. Rangeland Ecology and Management, 64(5), 

439-449. 

Suding, KN., Gross, KL., and Houseman, G.R. 2004. Altemativc states and positive feedbacks in 

restoration ecology. Trends in Ecology and Evolution, v. 19, p. 46-53. 

7 
126 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

Williams, J .W., and Jackson, S.T. 2007. Novel climates, no-analog communities, and ecological 

surprises. Frontiers in Ecology and the Environment, 5(9), 475-482. 

Zouhar, K., Smith, J.K., Sutherland, S., and Brooks, M.L. 2008. Wildland fire in ecosystems: fire and 

nonnative invasive plants. General technical report. RMRS-GTR-42-vol. 6. U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research Station, Ogden, UT. 

Sen a tor Barasso Question 2 

USDA Forest Service. Final Record of Decision: Four Forest Restoration Initiative. 2015. 

https:l/fs.usda.gov/Intemet/FSE DOCUMENTS/stelprd3836454.pdf 

Senator Warren Question 1 

Allen. C.D., and Breshears, D.O. (1998). Drought induced shift of a forest-woodland ecotones: rapid 

landscape response to climate variation. Proceedings of' the National Academy of'Sciences, 95: 

14389-14842. 

Allen, C. D., Macalady, A. K., Chenchouni, H., Bachelet, D., McDowell, N .. Vcnncticr. M., Kitzberger, 

T., Rigling, A., Breshears, D., Hogg, EH., Gonzalez, P., Fensham, R., Zhang, Z., Castro, J., 

Demidova, N., Lim. J., Allard, G., Running, S.W., Scmcrci, A., and Cobb, N. 2010. A global 

overview of drought and heat-induced tree mortality reveals emerging climate change risks for 

forests. Forest Ecology and Management, 259(4): 660-684. 

Bagdon, B., and Huang, C.H. 2014. Carbon Stocks and Climate Change: Management Implications in 

Northern Arizona Ponderosa Pine Forests. Forests, 5(4), 620-642. 

Covington, W.W., Everett, R.L, Steele, R., Irwin, L.L., Daer, T.A., and Allen, N.D. 1994. Historical and 

Anticipated Changes in Forest Ecosystems of the Inland West of the United States. Journal ol 

Sustainable Forestry. 2:13-63. 

Garfin, G .. Franco, G., Blanco, H., Comrie, A., Gonzalez, P., Piechota, T., Smyth, R., and Waskom, R. 

2014. Ch. 20: Southwest. Climate Change Impacts in the United States: The TI1ird National Climate 

Assessment, J.M. Melillo, Terese (T.C.) Richmond, and G.W. Yohc, Eds., U.S. Global Change 

Research Program, 462-486. doi: lO. 793 O/J08G8Hl'v1N. 

Grissino-Mayer, H.D., and Swetnam, T.W. 2000. Century-scale climate forcing of fire regimes in the 

American Southwest. Holocene, 10,213-229. 

Kunkel, K.E., Stevens, L.E., Stevens, S.E., Sun, L., Janssen, E., Wucbbles, D., Redmond, K.T., and 

Dobson, J.G. 2013. Regional Climate Trends and Scenarios for the U.S. National Climate 

Assessment: Part 5. Climate of the Southwest U.S. NOAA Technical ReportNESDIS 142-5. 87 pp., 

National Oceanic and Atmospheric Administration, National Environmental Satellite. Data, and 

Infonnation Service, Washington, D.C. 

Laughlin, D.C., Fule, P.Z., Hufftnan, D.W., Crouse, J., and Laliberte, E. 2011. Climatic constraints on 

trait-based forest assembly. Journal of' Ecology, 99, 1489-1499. 

Lutz, J.A., van Wagtcndonk, J.W., Thode, A.E., Miller, J.D., and Franklin, J.F. 2009. Climate, lightning 

ignitions, and fire severity in Yosemite National Park, California, USA. lnternariona! Journal of' 

Wildland Fire, 18: 765-774. doi:IO.I071/WF08117 

Lutz, J.A., van Wagtendonk, J.W., and Franklin, J.F. 2010. Climatic water deficit, tree species ranges, and 

climate change in Yosemite National Park, USA. Journal of' Biogeography. 37: 936-950. 

doi: lO.lll1/j.l365-2699.2009 02268 x 

Lutz, J.A., Key, CH., Kolden, C.A., Kane, J.T., and van Wagtendonk, J.W. 2011. Fire frequency, area 

burned, and severity: what is a nonnal fire year? Fire Ecology, 7(2): 51-65. doi: 

l 0.4996/fireccology.0702051 

McKenzie, D., Gedalof, Z.M., Peterson, D.L., and Mote, P. 2004. Climatic change, wildfire, and 

conservation. Conservation Biology, 18: 890-902. doi: l0.111l!j.l523-1739.2004.00492.x 

8 
127 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Dr. William Wallace Covington 

Miller, J.D., and TI10de, A.E .. 2007. Quantifying bum severity in a heterogeneous landscape with a 

relative version of the delta Nom1alized Bum Ratio (dNBR). Remote Sensing of Environment, 109: 

66-80. doi: I 0.10 16~j rse.2006.12 006 

Miller, J.D., Safford, H. D., Crimmins, M., and Thode, A.E. 2009. Quantitative evidence for increasing 

forest fire severity in the Sierra Nevada and Southern Cascade Mountains, California and Nevada, 

USA. Eco;y~tems, 12: 16-32. doi:IO.l007/sl002!-008-9201-9 

Rehfeldt, G.E., Crookston, N.L., Warwcll, M.V., and J.S. Evans. 2006. Empirical analyses of plantclimate relationships for the Western United-States. JnternarionalJournal of Plant Science, 167, 

1123-1150. 

Stoddard, M.T., Meador, A.S., Fulc, P.Z., and I.E. Korb. 2015. Five-year post-restoration conditions and 

simulated climate-change trajectories in a warm/dry mixed-conifer forest, southwestern Colorado, 

USA. Forest Ecology and Management. 

Wcstcrling, AL., Hidalgo, H.G., Cayan, D.R., and T.W. Swetnam. 2006. Wanning and earlier spring 

increase western US forest wildfire activity. Science. 313, 940-943. 

Williams, A.P., Allen, C. D., Macalady, A.K., Griffin, D., Woodhouse, C.A., Meko, D.M., Swetnam, 

T.W., Rauscher, S.A., Seager, R., Grissino-Maycr, H.D., Dean, J.S., Cook, E.R., Gangodagamagc, 

C., Cai, M .. and N.G. McDowell. 2012. Temperature as a potent driver of regional forest drought 

stress and tree mortality. Nature Climate Change, 3, 292-298. 

Williams, A.P., Seager, R., Macalady, AK., Bcrkelhammer, M., Crimmins, M.A., Swetnam, T.W., 

Trugman, A.T., Buenning, N., Noone, D., McDowell, N.G., Hryniw, N., Mora, C.!., and T. Rahn. 

20 14a. Correlations between components of the water balance and burned area reveal new insights 

for predicting fire activity in the southwest United States. International Journal of' Wildland Fire, 

24:14-26. 

Williams, A.P., Seager, R., Berkclhammer, M., Macalady, A.K., Crimmins, M.A., Swetnam. T.W., 

Trugman, A.T., Buenning, N., Hryniw, N., McDowell, N.G., Noone, D., Mora, C.!., and T. Rahn. 

2014b. Causes and Implications of Extreme Atmospheric Moisture Demand dming the RecordBreaking 2011 Wildfire Season in the Southwestern United States. Journal o(Applied Meteorology 

and Climatology, 53: 2671-2684. 

Senator Warren Question 2 

Azpeleta Taranc6n, A, Fu!C, P.Z., Shive, K.L., Sieg, C.H., Sanchez Meador, A, Strom. B .. 2014. 

Simulating post-wildfire forest trajectories under alternative climate and management scenarios. 

Ecological Applications doi: http://dx.doi.org/10.1890/13-1787.1 

Bmsca, R.C., Wiens, J.F., Meyer, W.M., Edlc, J. Franklin, K., Overpeck, J.T., Moore, W., 2013. 

Dramatic Response to Climate Change in the Southwest: Robert Whittaker's 1963 Arizona Mountain 

Plant Transect Revisited. Ecology and Evolution, 3, 3307-3319. 

Pechony, 0., and Shindell, D.T., 2010. Driving forces of global wildfires over the past millennium and 

the forthcoming century. Proc. Nat/. Acad. Sci., 107, 19167- 19170 

Smith, H. G., Sheridan, G.J., Lane, N.J., N}nlan, P., Haydon. S. 2011. Wildfire effects on water quality in 

forest catchments: A review with implications for water supply. Journal ojHydrology, 396 170-192. 

Westcrling, A.L., Hidalgo, H. G., Cayan, D.R., and Swetnam, T.W. 2006. Warming and earlier spring 

increases westcm U.S. forest wildfire activity. Science, 313:940-943. doi: 10.1 126/sciencc.ll28834 

Willian1s, A.P., Allen, C.D., Macalady, AK., Griffin, D., Woodhouse, C.A., Mcko, D.M., Swetnam, 

T.W., Rauscher, S.A., Seager, R., Grissino-Mayer, H.D., Dean, J.S., Cook, E.R .. Gangodagamagc, 

C., Cai, M., and McDowell, N.G. 2012. Temperature as a potent driver of regional forest drought 

stress and tree mortality. Nature Climate Change, 3:292-297. 

9 
128 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Chief Mike Burnett 

Questions from Chairman Lisa Murkowski 

Ouestion 1: 1n your opinion, what steps does the Federal government need to take to 

accomplish more hazardous fuels reduction work? 

In my opinion, there are several steps the Federal government needs to take to improve 

their efforts towards hazardous fuels reduction work; 

• Adequately fund forest health collaboratives. 

• Increase the appropriations for mechanical thinning and prescribed burning. 

• Appropriately fund, and staff, vegetation and fuel management programs. 

• Work with local forests to re-establish small log sawmill infrastructure. 

Ouestion 2: What roadblocks, in your observation, are preventing the land management 

agencies from carrying out these much needed hazardous fuels reduction projects? 

I believe the land management agencies would be able to do more hazardous fuel 

reduction projects if; 

• There was a revision to smoke management policies. 

• There was better collaboration between State and Federal agencies with the 

inclusion of private landowners. 

• There was existing infrastructure to handle the thinning projects. 

• The Federal government would create a financial incentive, through funding, for 

forest to do hazardous fuel reduction. 

Ouestion 3: 1n your experience, do post-fire reviews conducted by the Forest Service or 

DOl agencies include the pre-fire forest condition or factors that may have predisposed 

the land to a large, costly fire, such as over accumulation of vegetation, or do the reviews 

just assess suppression actions and decisions? If the entire focus is on fire managers and 

suppression actions, do you think it puts too much focus on suppression activities and not 

enough on actions that could have been taken prior to the fire to address the pre-fire 

forest conditions? 

My experiences with post-fire reviews have been in the form of after action reviews and 

incident management team performance evaluations. In this setting, the focus is clearly 

on suppression actions and decisions. 

There are frequent discussions with Agency Administrators during the incident regarding 

planned strategies that take into consideration firefighter safety and opportunities for 

success based on multiple variables. An example would be the evaluation of areas with 

excessive fuel loading versus areas that have had fuel treatment. 
129 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

Senator Barrasso, 

Thank you for the opportunity to provide additional detail to the testimony 

and for your questions. Please accept these answers for the record. 

Questions from Senator John Barrasso 

Question 1: Very often those who oppose active management of our 

forests claim hazardous fuel removal projects, timber production or 

thinning activities will destroy watershed health and wildlife habitat. Your 

testimony illustrates the costs of not taking a balanced approach to treating 

the landscape. In your testimony you cite the negative long term impacts 

on salmon, wildlife, watersheds, infrastructure, and farmers, ranchers, and 

tribes that will extend many years into the future. 

What are some of these natural resource problems you are facing or will 

face in the future now that the fires are out? 

Answer: 

Given the size, scale, and intensity, of the fires, there is little or no natural 

regeneration of softwood forest species on large swaths of land. Brush will 

quickly dominate the native grasses in these burned areas, making them 

unsuitable for wildlife habitat, grazing, providing little shade for burned 

riparian areas, and ultimately creating yet another fuel source for future 

fires. 

Being left with a burned-out, sterile, landscape, leaves private landowners, 

government owned lands and our tribal lands with a number of 

unattractive choices. Do nothing, and you get the brush- and weed-laden 

land that is highly erodible, highly unproductive, and may or may not some 

day return to forest depending literally on the winds and the travels of 

birds and squirrels. 
130 

U.S. Senate Committee on Energy and Natural Resources 

November 17, 2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

This choice essentially ensures large areas of dead land for generations. If 

the choice is to replant, one will incur land preparation, salvage harvesting, 

brush removal, weed control, road construction and maintenance costs, as 

well as the cost of seedlings and planting, that will run into the hundreds, if 

not thousands, of dollars per acre. 

The return on this investment has such a long horizon that it really 

becomes a commitment based on faith that it is the right thing to do, 

because your descendants who have not been born will be the ones who 

either benefit or not from decisions you make today. 

The costs of any of these management approaches are real. Even if you are 

on the end of the spectrum that believes land and timber devastated by fire 

should be left alone to let nature take her course, our counties and 

reservations will require that you spray for noxious weeds (or have a lien 

attached to your property for lands outside the boundaries of the 

reservation). If your burned trees fall over a road, or ifthe salmon stream 

that runs through your place and is now filling in with silt from your 

formerly heavily timbered riparian zone, you are likely to face some or all of 

the costs of remediation of these problems. 

The loss of wildlife habitat is significant. We already have 10,000+ deer 

without winter feed, including the bitter brush that is a natural component 

of their diet. Bitterbrush must be hand replanted to be effective and no 

funds are available to do this work and it will take generations to re-grow. 

The true cost offire devastation needs to assessed in terms not only of 

salvage, replanting, brush and weed control, but of losing the productivity 

of the land over a very long term horizon, including the loss of jobs, 

recreation, and access to the lands. I have included as "Exhibit A" a photo 

of the devastation from these fire super storms and then below the 

devastation a picture of the noxious weeds that have returned causing 

additional ecological and natural resource challenges. 

2 
131 

U.S. Senate Committee on Energy and Natural Resources 

November 17, 2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

{/Exhibit B" shows mudslides that occurred on Forest Service lands within 

Okanogan County just outside of Pateros, Washington. The area is known 

as Black Canyon which burned in the 2014 Carlton Complex Fires and the 

2015 Chelan Complex Fires. The area burned in 2014 was not salvaged 

logged and was left to become the fuel for the 2015 fires in the same area. 

The back to back burning of this area by forest fires has made the ground 

sterile and subject to mudslides. The mudslide depicted in these photos 

occurred within a few days ofthe senate hearing. This damage will continue 

for years to come if not properly addressed by the Forest Service. 

Gene Shull, a fisheries biologist, discussed the Black Canyon mudslide in the 

Methow Valley News November 20, 2015 and said: 11The damage is 

extensive. Multiple failures occurred on Black Canyon Road about halfway 

up the drainage. Repairs to the road will be time-consuming and expensive 

and impacts to critical steelhead habitat from sediment deposits into Black 

Canyon Creek from the washout are severe. Thousands of cubic yards of 

fine sediment was delivered to Black Canyon Creek. Steelhead spawning 

and rearing habitat will be impacted for a few more years." 

The mudslides will have a negative impact on our tourism economy, limit 

access to national forests, and increases the costs from the fires. The costs 

may be so high, that the access area and roads are just left to nature which 

removes access to the lands all together. We know at this time that the 

road will remain closed to all wheeled and tracked vehicles through the 

winter and the groomed snowmobile route in the area will also be closed 

for the winter. 

Additionally, in {/Exhibit C" is a second example of mudslides from another 

burned area in Chelan County just outside of Entiat, Washington taken from 

the USFS Facebook webpage for the region. 

Last in regards to the tribal lands we have challenges facing some of the 

best subsistence gathering grounds. The western portion of the Colville 

Reservation that was in the Tunk Block and North Star fire are some of the 

3 
132 

U.S. Senate Committee on Energy and Natural Resources 

November 17, 2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

best grounds for gathering huckleberries, chokecherries, soapberries, and 

strawberries. These lands were destroyed and recently the tribal council 

voted to close tribal lands in the burn areas to subsistence hunting. 

The tribal lands will also need to replant as many of the burned and logged 

areas as possible. Cody Desautel, the tribe's natural resources director, 

said in the Seattle Times November 21, 2015 "The tribes will replant as 

much of the burned and logged land as they can. But on this scale of 

destruction, that too will be a struggle, with an estimated 30 million trees 

needed to replant so large an area. We do two or three million in our best 

year. We'll be extremely lucky to get half of that done." 

Assuming we are unable to get financial incentives put in place for the 

balanced active management approach that I espouse in the near future, 

we need a clear-eyed analysis of the true costs of allowing fires to become 

these super storms should be part of the national discussion. Everyone 

now understands that the USFS has to borrow from its other programs, and 

tap emergency programs, because the cost of firefighting has eaten up the 

budget in the first few weeks of the fire season, for several seasons 

running. The practice of fire borrowing should stop. 

4 
133 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

Question 2: In your testimony you state the U.S. Forest Service has four 

times more land that owned by the State of Washington. Yet, the 

Washington State Department of Natural Resources has harvested 30 times 

more volume and has been 1283 time more profitable than the Forest 

Service. 

In your view, which forests are healthier, have greater wildlife habitat 

diversity, or pose less of a wildfire risk, the state or national forests? 

Answer: 

At the current time I personally believe the State Department of Natural 

Resources (DNR) is better able to manage their properties because of local 

control and the financial incentives to optimize the productivity. This was 

not always the case. In my submitted testimony I had attached Exhibit B, 

which has been attached again here are "Exhibit D." The map clearly shows 

that during the mid 80's the Forest Service managed the lands better, but a 

shift occurred in 1991 to where the state began to manage the lands 

better, a trend that continues through today. 

We have seen opposition to DNR Forest practices by the environmental 

community but not every project is opposed. Many realize the part that 

DNR land plays in the funding of education and other programs is not lost 

on the population. The Forest Service, on the other hand, is burdened by 

it's size and a constituency that includes the largest and best-funded groups 

who wish to stop all logging. Without local input and some degree of local 

control, it is hard to see how the conflict is resolved. 

"Exhibit E" gives a real world example by Bob Schumacher of managed 

Forest Service Lands and non managed Forest Service Lands from this 

year's fires in Okanogan County. Bob Schumacher a consulting forester who 

works in both the southeastern and northwestern United States. He owns 

property in Okanogan County. 

The example in "Exhibit E" should resonate through all government 

agencies depicting successful management of Forest Service Lands, yet 

5 
134 

U.S. Senate Committee on Energy and Natural Resources 

November 17, 2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

shows the devastation when the Forest Service is unable to complete the 

necessary treatments. 

If we were to end fire borrowing, it could lead to reversing this trend of 

Forest Service lands being unmanaged and having the national forest lands 

managed at a comparable level to the state or even better than the state as 

they were in the 80's. 

I have included for you in "Exhibit F" pictures taken of lands within the 

Okanogan-Wenatchee National Forest detailing the unmanaged lands and 

what they looked like when ablaze during the 2015 fires. 

I then added a picture of lands managed by the local Department of Natural 

Resources within Washington State showing a tract that was logged, 

thinned, prescriptively burned, and grazed by cattle. This tract of land 

abuts the Okanogan-Wenatchee National Forest and clearly shows habitat 

that poses less wildfire risk and greater wildlife habitat diversity which was 

your question. 

The last photo in the exhibit is that of the National Forest lands burned in 

2006 as part of the Tri-Pod fire that burned over 240,00 acres. The photo 

clearly shows the logs have been left to become fuel for the next fire and 

little to no habitat on the ground has grown back since 2006, therefore 

increasing wildfire risk and less wildlife habitat diversity. 

I would conclude by saying biofuel technology has been around since the 

60s, and although it is tantalizingly promising it has not become 

commercially viable over the past decades. It seems that a cold hard 

analysis of the true total costs imposed by the governments and private 

sector of these devastating fires would show that government subsidies 

and/or incentives to get contractors out into the woods thinning, cutting 

brush, maintaining roads and culverts, planting trees in riparian zones, etc., 

will likely be far less, over time, than the devastating wildfire, and provide a 

much better result, financially and culturally, than simply doing nothing and 

scrambling every year with these disastrous fire crises. 

6 
135 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

EXHIBIT A 

Fires Devastation to the Land 

NOXIOUS WEEDS AFTER THE FIRES -REGROWTH AFTER CARL TON 

COMPLEX FIRES OF 2014 

7 
136 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

EXHIBIT B 

U.S. Forest Service- Okanogan-Wenatchee National Forest added 3 new photos. 

November 18 at 5:53pm· 

A culvert on Black Canyon Road (Forest Road 4010 on the Methow Valley Ranger 

District) was plugged by debris during recent storms leading to road damage and a 

temporary closure. 

8 
137 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

EXHIBITC 

U.S. Forest Service- Okanogan-Wenatchee National Forest added 7 new photos. 

November 19 at !0:46am· 

Recent rains and the freeze-thaw cycle have created hazardous conditions on some 

national forest roads and trails on the Entiat, Wenatchee River, Cle Elum, and Methow 

Valley ranger districts. Rocks, mud, trees and other debris have impacted different areas 

of the national forest. 

Recreationists visiting campgrounds or trails located near streams, or riving forest roads, 

need to be cautious and alert for high and fast running water, woody debris or logjams, 

and fallen trees. 

Water across roadways could indicate a blocked culvert and increased potential for a road 

washout. Visitors are discouraged from walking or driving across sections or roadway 

that may have standing or flowing water or debris flows. Do not attempt to go around 

barricades. 

In areas where there have been recent large fires, people should be extra cautious because 

this may be the first major runoff the fire area has experienced and slopes could still be 

unstable. 

Forest Service employees will be checking forest roads and recreation areas for damage, 

unplugging culverts and removing trees from roadways. 

Before leaving home, the public is urged to check weather forecasts and contact local 

ranger stations to learn current road and trail conditions for the area where they will be 

recreating. Also, carry a map of the area and think about alternate exit routes in case the 

main route becomes inaccessible or blocked. 

These photos are of two separate mud and debris slides 25 miles up Entiat River Road 

just past the sno-park. Also see the earlier post about the Black Canyon Road washout. 

9 
138 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

10 
139 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

EXHIBIT D 

l'il'fiOOtfWv@S.tl!IWtihttlgtMSt.tU198S·~.U 

lw'.lllil lw•llN1tlllll 

II 
140 

U.S. Senate Committee on Energy and Natural Resources 

November 17, 2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

EXHIBIT E 

Spokesman Review November 15, 2015 

Guest opinion: Okanogan fires shows pre-emptive forest 

management works 

Bob Schumacher 

Tags:Aeneas Valleyfire managementNorth Star fireTunk Block fireu.s. forest service 

This past August and September, I gained more experience with wildfire than I ever 

cared to. I arrived at my off-the-grid cabin in the Aeneas Valley of Okanogan County just 

as the North Star fire broke out A few days later, the Tunk Block fire threatened from a 

different direction. I watched with apprehension as enormous columns of smoke billowed 

into the blue Washington skies, punching so high into the atmosphere that clouds formed 

above the convection columns. Each night I could see flames in the distance. Balls of fire 

flashed into view and faded, each representing trees being consumed in a crown fire. 

My property, some 800 feet in elevation above the valley floor, offered an excellent 

vantage point And as a professional forester, I could interpret what I saw, even though I 

had limited fire experience. I knew that some of the US. Forest Service land south of 

Aeneas Valley had recently been treated to reduce fuel loads. This is a two-step process. 

First, dense forests are thinned, removing enough trees and underbrush to disrupt the 

"ladder fuels" that encourage crown fires. Next, a controlled bum is conducted during 

cool weather. When the inevitable wildfire arrives, little fuel remains to be burned. That's 

the theory anyway; the test had come in the form of the North Star and Tunk Block fires. 

As the fires raged and the prospect of control was very much in doubt, I attended public 

meetings, studied fire maps, spoke with key personnel, and made my own observations. I 

specifically asked four fire bosses whether the fuel-treatment zones were helping. All of 

them enthusiastically said yes. In fact, the official fire report from Sept 5 says in part: 

"Benefit of fuel treatments: The forest thinning and fuels treatments in the south and east 

forested edges of Aeneas Valley modified fire behavior, slowing its spread as well as 

facilitating burnouts and allowing firefighters to establish effective containment lines that 

protected homes and land." 

Once the fires were contained and the woods reopened to the public, I made two trips into 

the burned areas. First, I visited the northwest reaches of the North Star fire, in the 

vicinity of Lyman Lake Road and Devils Canyon. Many of the managed forest stands 

displayed little damage at all, appearing much the same as I had seen them a year ago. A 

few treated areas had been lost, but considering the extreme conditions that prevailedhot windy days and low fuel moisture the survival of so much timber was impressive. 

12 
141 

U.S. Senate Committee on Energy and Natural Resources 

November 17, 2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for tbe Record Submitted to Mr. Jon Wyss 

My second foray into the woods took me to the northeastern part of the Tunk Block fire, 

near Peony Creek at the west end of Aeneas Valley. Here, the difference between treated 

and untreated forests was even clearer. Along Forest Service Road 3010, thinned forests 

stood green and healthy. Judging from the scarcely-burned ground vegetation, it was hard 

to imagine that a destructive wildfire had loomed nearby. When I turned the comer onto 

Road 3015, the destruction wrought by the Tunk Block fire came into view. On the south 

side of the road, where trees of all sizes and ages had been crowded together, little 

remained besides charred trunks. Virtually every needle on every tree had been 

vaporized. Ash coated the ground, and not a speck of green was to be seen. Trees that had 

taken root while Thomas Jefferson was president had been incinerated within seconds. 

To the north of the road, where ladder fuels had been removed, survival was nearly 100 

percent. Not only were the trees alive, they had barely even been scorched. The fire had 

burned so meekly that green seedlings still poked from the ground. 

And so it is, that within the boundaries of one of the largest wildfires in the state's recent 

history, in a month with some of the most extreme fire weather imaginable, large swaths 

of green forest remain; and the sprawling wildland-urban interface of Aeneas Valley was 

saved. This did not happen as a result of a bold stroke of genius or a previously unknown 

technology. Instead, it was the result of tried-and-true forest management practices that 

have been known for decades. 

Some environmental activists adamantly claim that fuel reduction projects do not work, 

and are merely a ploy to harvest more timber. I invite any doubters to go to the places 

that I went, and see what I have seen. Preemptive fire management saves forests and 

property. It can and should be widely employed in the Inland Northwest. 

Bob Schumacher a consulting forester who works in both the southeastern and 

northwestern United States. He owns property in Okanogan County. 

13 
142 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

EXHIBIT F 

Okanogan Wenatchee National Forest unmanaged and 

waiting for a high intensity burn. 

Picture taken 8/24/2015 

Okanogan Wenatchee National Forest unmanaged and high 

intensity burn. 

Picture taken 8/24/2015 

14 
143 

U.S. Senate Committee on Energy and Natural Resources 

November 17,2015 Hearing: Future Federal Wildland Fire Management Strategies 

Questions for the Record Submitted to Mr. Jon Wyss 

Washington State Department of Natural Resource Land that was 

logged, thinned, prescriptively burned, and grazed by cattle. 

Picture taken 10/0112015 

Tripod Fire 2006 burned approximately 240,000 acres. 

Picture taken 1 0/0112015 

15 
144 

August 2013 

GA0-13-684 

United States Government Accountability Office 

Report to Congressional Requesters 

WILDLAND FIRE 

MANAGEMENT 

Improvements Needed 

in Information, 

Collaboration, and 

Planning to Enhance 

Federal Fire Aviation 

Program Success 
145 

WILDLAND FIRE MANAGEMENT 

Improvements Needed in Information, 

Collaboration, and Planning to Enhance Federal Fire 

Aviation Program Success 

What GAO Found 

The Department of Agriculture's Forest Service and the Department of the 

Interior have undertaken nine major efforts since 1995 to identify the number and 

type of firefighting aircraft they need, but those efforts---<;onsisting of major 

studies and strategy documents-have been hampered by limited information 

and collaboration. Specifically, the studies and strategy documents did not 

incorporate information on the performance and effectiveness of fire fighting 

aircraft, primarily because neither agency collected such data. While government 

reports have long called for the Forest Service and Interior to collect aircraft 

performance information, neither agency did so until2012 when the Forest 

Service began a data collection effort. However, the Forest Service has collected 

!imrted data on large airtankers and no other aircraft, and Interior has not initiated 

a data collection effort. In addition, although firefighting aircraft are often shared 

by federal agencies and can be deployed to support firefighting operations on 

federal and nonfederallands, the agencies have not consistently collaborated 

with one another and other stakeholders to identify the firefighting aircraft they 

need. Many agency officials and stakeholders GAO contacted noted concerns 

about limited collaboration, and many cited shortcomings with the fonmal 

mechanism for collaboration--the National Interagency Aviation Committee. The 

committee has implemented some leading practices for collaboration such as 

defining and articulating a common purpose, but it has not taken additional steps 

to monitor and evaluate its collaborative activities, another leading practice. 

Collectively, additional information on aircraft performance and effectiveness and 

collaboration across agencies and with stakeholders could enhance agency 

estimates oftheirfirefighting aircraft needs to more accurately represent national 

needs for such aircraft, and as a result, better position the agencies to develop 

strategic planning documents that represent those needs. 

The Forest Service plans to modernize the large airtanker fleet by obtaining large 

airtankers from various sources over the near, medium, and long term, but each 

component of this approach faces challenges that make the continued availability 

of such aircraft to meet national fire suppression needs uncertain. In the near 

term, the agency plans to rely on a mix of contracted "legacy" airtankers as well 

as supplemental aircraft available through additional contracts and agreements 

with other governments and the military. However, agency concerns exist 

regarding the availability, capability, and costs of these resources. In the medium 

term, the Forest Service has awarded contracts for "next-generation" large 

airtankers that are faster and more up-to-date than most "legacy'' aircraft, but it is 

uncertain when all of these aircraft will begin supporting fire suppression 

activities. Specifically, bid protests delayed contract issuance, and most of the 

aircraft receiving awards have not been fully tested and approved. In the long 

term, the Forest Service's plan includes purchasing certain large airlankers and 

obtaining others through intergovernmental transfer at no initial cost if they are 

declared surplus by the military-a shift from its long-standing practice of 

contracting for rather than owning aircraft. However, the Forest Service was 

unable to justify its previous plans for purchasing large airtankers to the Office of 

Management and Budget and concerns exist regarding the retardant capacity 

and operating cost of the other airlankers it would obtain through 

intergovernmental transfer. 

-------------United States Government Accountability Office 
146 

Contents 

Letter 

Appendix I 

Appendix II 

Appendix III 

Appendix IV 

Appendix V 

Appendix VI 

Tables 

Background 

Agencies' Efforts to Identify F1refighting Aircraft Needs Have Been 

Hampered by Limited Information and Collaboration 11 

The Forest Service's Approach to Modernizing the Large Airtanker 

Fleet Faces Challenges) Resulting in Uncertainty over Continued 

Large Airtanker Availability 21 

Conclusions 36 

Recommendations for Executive Action 37 

Agency Comments and Our Evaluation 37 

Objectives, Scope, and Methodology 

2013 Forest Service and Interior Firefighting Aircraft 

Availability and Rates 

Summary of Agency Efforts Since 1995 to Identify Number 

and Type of Firefighting Aircraft They Need 

Comments from the Department of Agriculture 

Comments from the Department of the Interior 

GAO Contact and Staff Acknowledgments 

Table 1: F1refighting Aircraft Categories and Functions 

Table 2: Type, Number, and Cost Rates for Federally-Contracted 

39 

42 

44 

47 

49 

50 

Firefighting Aircraft 42 

Pagei GA0~1J.684 Wildland Fire Management 
147 

Figures 

Table 3: Purpose, Methodology, and Recommendations of Major 

Efforts to Identify Federal Firefighting Aircraft Needs, by 

~~ " 

Figure 1: Examples of Single-Engine and Large Airtankers Used in 

Wildland Fire Suppression 

Figure 2: Key Elements Included in Major Forest Service and 

Interior Efforts Since 1995 to Identify Number and Type 

of Firefighting Aircraft They Need 12 

Figure 3: Example of a DC-10 Very Large Airtanker Dropping 

Retardant 25 

Figure 4: Example of MAFFS-equipped C-130 28 

Figure 5: Example of a "Next-Generation" Large Airtanker (BAe146) 30 

Abbreviations 

CAL FIRE 

DOD 

MAFFS 

OMB 

California Department of Forestry and Fire Protection 

Department of Defense 

Modular Airborne Firefighting System 

Office of Management and Budget 

This Is a work of the U.S. government and 1s not subject to copynght protection 1n the 

United States, The published product may be reproduced and distributed 1n its entirety 

without further permission from GAO. However, because this work may contam 

copyrighted tmages or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 

Pageii GA0*13-684 Wildland Fire Management 
148 

Washington, DC 20548 

U.S. GOVERNMENT ACCOUNTABILITY OFFICE 

August 20, 2013 

The Honorable Ron Wyden 

Chairman 

The Honorable Usa Murkowski 

Ranking Member 

Committee on Energy and Natural Resources 

United States Senate 

The Honorable Dianne Feinstein 

United States Senate 

The Honorable Jon Tester 

United States Senate 

The Honorable Mark Udall 

United States Senate 

Over the last 5 decades, aircraft have played an important role in wildland 

fire suppression activities throughout the country by conducting aerial 

surveillance, delivering supplies and firefighters, and dropping retardant 

to slow fire grow1h or water to suppress fires. Federal, state, and local 

governments rely on firefighting aircraft-including fixed-wing airtankers, 

helicopters, and other aircraft-to help protect communities and natural 

resources from wildland fire, and experts project that, as fire seasons 

become longer and more severe, the need for firefighting aircraft will 

continue to grow. The federal government plays a central role in wildland 

fire response, including the use of firefighting aircraft, for which it largely 

relies on private vendors that own and operate the aircraft under contract 

to the government. 

Among firefighting aircraft, large airtankers-those able to carry at least 

1 ,BOO gallons of fire retardant-are key resources for the federal 

government because they have the ability to fly to remote areas and 

quickly assist in containing small fires before they become larger, costlier, 

and more dangerous. However, the number of large airtankers available 

under federal contract decreased substantially in the last decade, from 44 

in 2002 to 8 in early 2013. 1 The decrease of large airtankers in the federal 

1Unless otherwise specified, all years cited in this report refer to calendar years 

Page1 GAO« 13.684 Wildland Fire Management 
149 

fleet is, in part, the result of aircraft being retired due to their age-the 

average large airtanker is more than 50 years old-as well as agencies' 

concerns about the airtankers' safety and capability to perform a 

demanding fire aviation mission, which involves maneuvering aircraft at 

low speeds and altitude and enduring significant structural wing stress. 

Safety issues arose from two fatal crashes in 2002, both of which were 

caused by structural failures-specifically, wings separating from the 

aircraft during flight. These safety-related concerns led the government in 

2011 to terminate contracts for eight large airtankers, which represented 

more than 40 percent of the federally-contracted large airtanker fleet at 

the time. Three additional crashes in 2012, two of which resulted in 

fatalities, further increased public concerns regarding the federal 

government's ability to provide continued aerial support for wildland 

firefighting activities. 

Aircraft availability is also limited by the market characteristics for each 

type of aircraft. In particular, large airtankers are less available than other 

aircraft such as single-engine airtankers, helicopters, and surveillance 

aircraft. 2 Large airtankers have historically consisted of larger aircrafttypically surplus from the military-that were not designed to drop liquids 

and have undergone retrofitting to perform that mission. (See fig. 1 for 

examples of single-engine and large airtankers). According to the federal 

government's 2009 wildland fire aviation strategy, the availability of 

single-engine airtankers and helicopters is sufficient to meet national fire 

demands over the next 15 to 20 years, and the availability of aerial 

surveillance and smokejumper aircraft is adequate, but the Forest 

Service's recent large airtanker strategy notes that the economic difficulty 

for new vendors to enter the market or existing vendors to upgrade their 

fleets demonstrates the uncertainty regarding the continued availability of 

large airtankers. 

2Single-engine airtankers are often agricultural aircraft designed to operate at low altitudes 

and configured to drop retardant rather than pesticides or fertilizer. Helicopters can 

perform multiple roles-including oil and gas, logging, and fire suppression support-and 

surveillance aircraft are typ1caHy general-purpose civilian aircraft. 

Page2 GA0-13-684 Wildland Fire Management 
150 

Figure 1: Examples of SingleMEngine and Large Airtankers Used in Wildland Fire Suppression 

Air Tractor AT-802F single-engine airtanker 

Souroes A1rTractorlnc (left).GAO(nght) 

Korean War-era Lockheed P-2V Neptune owned by Neptune Aviation 

Services, originally a maritime patrol aircraft now converted to a large 

airtanker. 

Note: Large airtankers are defined by the agencies as aircraft with capacities of at least 1,800 

gallons. Small, single-engine airtankers generally have capacities of 500 to BOO ga!!ons 

The Department of Agriculture's Forest Service and the Department of 

the Interior's land management bureaus have a responsibility to respond 

to wildland fires on federal lands. 3 States and other entities-including 

tribal and local fire departments-have primary responsibility for 

responding to wildland fires on tribal, state, local, and private lands. 

Fighting wildland fires-which can burn across federal, state, and local 

jurisdictions-can require significant investments of personnel, aircraft, 

equipment, and supplies and can result in substantial fire suppression 

expenditures, with firefighting aircraft contributing to these costs. From 

2007 through 2012, these agencies reported that more than $2.4 billion 

was spent on federally-contracted firefighting aircraft, fuel, and retardant. 4 

In light of questions about the availability of needed aerial support for 

firefighting-in particular the decrease in large airtanker availability-you 

Department of the Interior includes four land management agencies: the Bureau of 

Indian Affairs, Bureau of Land Management, Fish and Wildlife Service, and National Park 

Service 

4

Th is amount includes expenditures for both federal and nonfederal use of these 

contracted aircraft 

Page3 GA0-13-684 Wildland Fire Management 
151 

asked us to review federal agencies' efforts to ensure the adequacy of the 

federal firefighting aircraft fleet. This report examines (1) Forest Service 

and Interior efforts to identify the number and type of firefighting aircraft 

they need, and (2) the Forest Service's approach to modernizing the large 

airtanker fleet and the challenges it faces in doing so. 

To examine Forest Service and Interior efforts to identify their firefighting 

aircraft needs, we identified and reviewed agency studies and strategy 

documents and interviewed agency officials responsible for managing fire 

aviation programs. We focused on those efforts conducted since 1995, 

when the Forest Service and Interior jointly conducted the first major 

study of their large airtanker needs. For each effort, we reviewed the 

methodologies used and identified the extent to which they included 

analysis of key elements, which we identified as important for 

understanding firefighting aircraft needs based on our reviews of multiple 

academic and agency studies and interviews with numerous stakeholders 

throughout the fire aviation community. The key elements we identified 

are: aircraft types, basing options, acquisition models, aircraft capabilities, 

suppression methods, and aircraft performance and effectiveness. We 

also interviewed agency officials about each effort to determine the extent 

of federal interagency collaboration involved. We compared the agencies' 

practices with GAO-identified leading practices for interagency 

collaboration 5 To examine the Forest Service's approach to modernizing 

the large airtanker fleet and any challenges it faces in doing so, we 

reviewed agency documents related to large airtanker acquisition, 

management, and operations as well as planning and acquisition 

documents, such as the 2009 Interagency Aviation Strategy, the Forest 

Service's 2012 Large Airlanker Modernization Strategy, and Forest 

Service airtanker contract solicitations, which lay out the agency's 

approach to obtaining large airtankers. For both objectives, we 

interviewed members of the fire aviation stakeholder community, 

including officials involved in the management and operations of aerial 

firefighting from the Forest Service, Interior and its four land management 

bureaus, the Department of Defense (DOD), and six state agencies that 

we selected based on input from federal agencies and the National 

Association of State Foresters; representatives from eight of the nine 

vendors we identified that own and operate large airtankers and that have 

5See GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GA0-06-15 (Washington, D.C .. Oct. 21, 2005). 

Page4 GA0-13-684 Wildland Fire Management 
152 

Background 

responded to the most recent Forest Service contract solicitations;' and 

two national trade organizations, which we identified based on 

conversations with agency officials and vendor representatives. We also 

conducted site visits to the National Interagency Fire Center in Boise, 

Idaho; 7 the facilities of the only two private vendors with active Forest 

Service "legacy" large airtanker contracts, located in Minden, Nevada and 

Missoula, Montana; and the headquarters of California's fire aviation 

program-part of the California Department of Forestry and Fire 

Protection (CAL FIRE) in Sacramento' The results of our interviews and 

site visits are not generalizable. Appendix I provides a more detailed 

description of our objectives, scope, and methodology. 

We conducted this performance audit from August 2012 to August 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

For decades, the federal government has relied on firefighting aircraft to 

assist in wildland fire suppression activities. These aircraft perform 

various firefighting activities, including gathering intelligence by detecting 

fires and conducting assessments of ongoing fires; delivering supplies 

such as water, food, and ground-based firefighting equipment; 

transporting firefighters; providing coordination and direction to aerial and 

ground-based firefighters; and delivering retardant or water to extinguish 

or slow the growth of fires. The federal government uses different types of 

firefighting aircraft, including large airtankers, very large airtankers, 

single-engine airtankers, amphibious fixed-wing water scoopers, 

helicopters, and fixed-wing surveillance and smokejumper aircraft to 

6Representatives of the nmth vendor did not respond to our attempts to contact them 

7The National Interagency Fire Center is the nation's logistical support center for 

contro!llng and extinguishing wildland fires and coordinates the mobilization offire 

suppression supplies, equipment, and personnel at the federal, regional, and local levels 

8

CAL FIRE operates a fleet of airtankers, helicopters, and surveillance aircraft to assist in 

fire suppression activities. The federal government reimburses the state of California when 

these aircraft support fire suppression activities on federal lands 

Page 5 GA0~13..S84 Wildland Fire Management 
153 

Single-engine a1rtankers 

Water scoopers 

Smokejumper aircraft 

perform these aerial fire suppression activities. Table 1 describes these 

firefighting aircraft and their functions. In general, multiple types of aircraft 

operate simultaneously to suppress fires. For example, airtankers that 

drop retardant or water often work in tandem with surveillance aircraftlead planes-that coordinate the firefighting operation and guide the 

airtankers in dropping the retardant or water in the correct location. The 

2013 Interagency Standards for Fire and Fire Aviation Operations defines 

several types of federal firefighting aircraft-including large and very large 

airtankers, large and medium helicopters, and surveillance and 

smokejumper aircraft-as national resources that can be deployed 

anywhere in the country and support fire suppression operations in any 

jurisdiction, including federal lands and nonfederallands in accordance 

with relevant intergovernmental agreements-' 

De!lver smaller amounts of retardant-currently, up to 800 gallons-to help suppress wildland 

fires; due to their small size and aerodynamics, they are capable of great accuracy in rough 

terrain 

as 

Provide command and control of aena! resources assigned to a f1re as well as coordmation and 

direction of ground forces engaged in fire suppression activities; one type-lead planes-guide 

airtankers over fires to assist in accurately targeting retardant delivery 

Deliver firefighters and supplies quickly to remote fires by paract1Ute; the aircraft's mobility allows 

for rapid support on emerging fires 

Source GAOanalys•sofagencydocwnents 

9

Single-engine airtankers and small helicopters are not defined as national resources by 

the Interagency Standards for Fire and Fire Aviation Operations. Officials told us that such 

aircraft are limited in their range and speed, and as a result, they are generally deployed 

within a specific geographic area 

PageS GA0-13-684 Wildland Fire Management 
154 

In most instances, firefighting aircraft that drop retardant or water do not 

extinguish wildland fires but instead slow the spread of fires or reduce 

their intensity as firefighters on the ground work to contain or suppress 

fires. Firefighting aircraft that deliver retardant or water support groundbased firefighters by performing two main functions: (1) dropping 

retardant around wildland fires to slow fire growth to provide groundbased firefighters additional time to build or reinforce fireline and (2) 

reducing the intensity of fires by dropping water directly on them. 10 In 

general, airtankers deliver retardant around fires to slow their spread, 

water scoopers drop water directly on fires to reduce their intensity, and 

helicopters can perform either function. Currently, all large and very large 

airtankers in the federal fleet are aircraft initially designed for other 

purposes-such as maritime patrol or civilian passenger transport-that 

have been retrofitted for the aerial fire suppression mission through the 

incorporation of retardant delivery systems-tanks affixed to aircraft that 

hold and release retardant 11 Conversely, single-engine airtankers and 

water scoopers are built to drop retardant and water, respectively, to fight 

wildland fires. 12 Traditionally, airtankers have used retardant delivery 

systems that rely on gravity to evacuate retardant via doors that open in 

the bottom of the aircraft. However, some systems have been developed 

that use compressed air to force retardant out of the aircraft through 

nozzles rather than doors. 

Fire suppression activities can generally be categorized as initial attack, 

extended attack, or large fire support. Initial attack activities include those 

conducted during the first "operational period" after the fire is reported, 

generally within 24 hours. 13 When fires are not controlled through initial 

attack, extended attack activities occur that generally involve the use of 

1

°Fireline is an area where vegetation is cleared in an effort to stop the fire's spread at that 

point or slow it sufficiently to allow firefighters to attack directly. Firefighters often 

incorporate geographic features such as roads, rocky areas, or ridgelines into firelines to 

mcrease their effectiveness. 

11 1n the United States, vendors have traditionally chosen retired military bombers, 

transport, and patrol aircraft to convert to large airtankers due to their availability and 

relatively low cost. 

12Some water scoopers are also capable of dropping suppressant foam, which is applied 

directly on fires to reduce their intensity 

13An operational period is the period of time scheduled for execution of a given set of 

tactical actions. Operational periods can be of various lengths, although usually not more 

than 24 hours. 

Page7 GA0~13-684 Wildland Fire Management 
155 

additional firefighting resources; when such fires grow large and complex, 

these activities may be referred to as large fire support. Federal and state 

wildland fire responders rely on a tiered interagency dispatch process for 

requesting and coordinating the use of firefighting resources, including 

aircraft, to respond to wildland fires. For example, when a wildland fire is 

reported, a local dispatch center identifies and dispatches, if available, fire 

response resources such as firefighters, aircraft, and equipment to 

perform initial attack activities. If sufficient resources are not available, 

local dispatch centers can request additional resources from the 

appropriate geographic area coordination center. 14 In the event that 

sufficient resources are not available within a geographic area, its 

geographic area coordination center can request additional resources 

from the National Interagency Coordination Center, which serves as the 

focal point for coordinating the mobilization of resources for wildland fire 

and other incidents throughout the United States. 15 

A number of interagency organizations develop interagency firefighting 

standards, including those pertaining to the development and use of 

firefighting aircraft, and coordinate federal firefighting efforts. To 

coordinate the overall firefighting efforts of the Forest Service and other 

federal land management agencies, the interagency National Wildfire 

Coordinating Group was established in 1974. 16 This interagency group 

develops and maintains standards, guidelines, and training and 

certification requirements for interagency wildland fire operations. Within 

this group, the National Interagency Aviation Committee is an interagency 

body of federal and state aviation operations managers responsible for 

providing common policy and direction for aviation resources involved in 

wildland firefighting. 17 This committee was established to serve as a body 

14Eieven regional dispatch centers, called geographic area coordination centers, are 

located nationwide, each of which serves a specific geographic portion of the United 

States. 

15The National Interagency Coordination Center is located at the National Interagency Fire 

Center in Boise, Idaho. 

16The National Wildfire Coordinating Group draws on representatives from the Forest 

Service and from Interior's Bureau of Indian Affairs, Bureau of Land Management, Fish 

and Wildlife Service, and National Park Service, as weH as the U.S. Fire Administration, 

National Association of State Foresters, and Intertribal T!mber Council 

17Prior to April2010, the National Interagency Aviation Committee was known as the 

National Interagency Aviation Council. We refer to the organization as the National 

Interagency Aviation Committee throughout this report 

PageS GAQ.13-684 Wildland Fire Management 
156 

of aviation experts, assisting the National Wildfire Coordinating Group 

with recognizing opportunities to enhance safety, effectiveness, and 

efficiency in aviation-related operations, procedures, programs, and 

coordination. In turn, the National Interagency Aviation Committee 

chartered the Interagency Airtanker Board to review and approve 

retardant and water delivery systems based on established performance 

criteria. The approval process-which includes an assessment of system 

design, testing of the systems' performance, and a physical inspection of 

the aircraft with system installed-ensures that the systems meet basic 

standards for delivery of retardant or water. Interagency Airtanker Board 

approval serves as a guide to participating federal and state agencies for 

identifying acceptable aircraft and retardant or water delivery systems that 

may compete for agency contracts. 

The federal firefighting aircraft fleet includes some aircraft that are 

government owned, but most are obtained through contracts with private 

industry vendors. For example, the federal government owns some 

surveillance and smokejumper aircraft and contracts for the remainder, 

along with helicopters and aircraft that deliver retardant or water, from 

private industry vendors that own, operate, and maintain them. Currently, 

the Forest Service issues contracts for large and very large airtankers, as 

well as large and medium helicopters, and Interior issues contracts for 

single-engine airtankers and water scoopers. 18 The agencies use two 

types of contracts for obtaining firefighting aircraft from vendors: 

exclusive-use and call-when-needed. 19 Exclusive-use contracts require a 

vendor to provide an aircraft for service on any day covered by the 

"mandatory availability period" stipulated in the contract. The agencies 

pay vendors a daily rate regardless of whether the aircraft is used and 

also pay a fee for each hour flown if the aircraft is used. Conversely, callwhen-needed contracts do not guarantee vendors any fee unless the 

aircraft is called upon to provide aerial fire support. This type of contract 

allows the government the flexibility to pay for firefighting aircraft only 

when they are used. However, the daily availability and flight hour rates 

for call-when-needed contracts are generally higher than those for 

18Both agencies contract for smal! helicopters as well as smokejumper and surveillance 

aircraft. 

19Forest Service uses the term "call-when-needed," and Interior uses the term "on-call" for 

contracts in which the agencies guarantee payment to the vendor contingent upon the 

aircraft being used. For the purposes of this report, we use the term call-when-needed to 

describe all such contracts. 

Page9 GA0-13-684 Wildland Fire Management 
157 

exclusive-use contracts. In contrast to large airtankers, other types of 

firefighting aircraft are generally more available for federal contracting. 

For example, the agencies plan to have over 100 helicopters available in 

2013 for fire suppression activities through exclusive-use contracts with 

hundreds more available through call-when-needed contracts. See 

appendix II for the number and types of aircraft in the federal firefighting 

aircraft fleet in 2013 and their associated cost rates. 

The Forest Service and Interior have also established agreements with 

other governments (i.e., cooperator governments), as well as the military, 

to augment the national firefighting aircraft fleet during periods of heavy 

fire activity. The United States and Canada have established a mutual aid 

agreement whereby the National Interagency Coordination Center and 

the Canadian Interagency Forest Fire Centre can request firefighting 

resources, including aircraft, from each other during periods of heavy fire 

activity20 Similarly, some U.S. states and Canadian provinces have 

established regional intergovernmental agreements to facilitate the 

sharing of firefighting resources: the Northwest Fire Protection 

Agreement, 21 the Great Lakes F crest Fire Com pact, 22 and the 

Northeastern Forest Fire Protection Compact. 23 Through these 

agreements, firefighting resources, including aircraft, can be dispatched 

from their contracted agency, state, or province to assist on fires on other 

lands covered by the agreement. The Forest Service can also obtain 

aerial firefighting support through the Modular Airborne Firefighting 

System (MAFFS) program under an agreement with DOD. Under this 

program, DOD provides Lockheed Martin C-130 Hercules aircraft as 

additional capacity for aerial firefighting when requested by the Forest 

Service. Each of the aircraft is equipped with a MAFFS unit-a portable, 

2

°Canada I United States Reciprocal Forest Fire Fighting Arrangement (May 7, 1982). The 

arrangement is implemented in a series of annual operating plans, the most recent of 

which was issued on January 15, 2013 

21Signatories to the Northwest Fire Protection Agreement include the states of Alaska, 

Idaho, Montana, Oregon, and Washington, as well as the Canadian provinces of Alberta, 

British Columbia, and the Northwest and Yukon Territories. 

22Members of the Great Lakes Forest Fire Compact include the states of Michigan, 

Minnesota, and Wisconsin, as wei! as the Canadian provinces of Manitoba and Ontario. 

23Signatories to the Northeastern Forest Fire Protection Compact include the states of 

Connecticut, Maine, Massachusetts, New Hampshire, New York, Rhode Island, and 

Vermont, as well as the Canadian provinces of New Brunswick, Newfoundland and 

Labrador, Nova Scotia, and Quebec 

Page 10 GA0~13~684 Wildland Fire Management 
158 

Agencies' Efforts to 

Identify Firefighting 

Aircraft Needs Have 

Been Hampered by 

Limited Information 

and Collaboration 

to 

Identify Firefighting 

Aircraft Needs Did Not 

Include Information on 

Performance and 

Effectiveness of 

Firefighting Aircraft 

pressurized retardant delivery system that can be inserted into military C130 aircraft to convert them into large airtankers when needed. The 

Forest Service owns the MAFFS units (eight in total) and provides the 

retardant, and DOD provides the C-130 aircraft, pilots, and maintenance 

and support personnel to fly the missions. 24 A new generation of MAFFS 

units became operational in February 2009, and the fleet has since 

transitioned to use this system exclusively. 

Since 1995, the Forest Service and Interior have cumulatively produced 

nine major studies and strategy documents related to their firefighting 

aviation needs, but the agencies' efforts to identify the number and type 

of firefighting aircraft needed have been hampered by limited information 

and collaboration. In particular, these efforts did not include information 

on the performance and effectiveness of firefighting aircraft and involved 

limited collaboration between agencies and with stakeholders in the fire 

aviation community. 

Forest Service and Interior efforts to identify the number and type of 

firefighting aircraft they need have largely consisted of developing major 

studies and strategy documents-nine since 1995. Based on reviews of 

academic and government studies and interviews with officials and 

representatives from across the fire aviation community, we identified the 

following key elements as important for understanding firefighting aircraft 

needs: 

Aircraft types -aircraft manufacturer, model, and size classification; 

Basing options- potential locations for aircraft bases; 

Acquisition models- options for obtaining aircraft, including 

purchasing aircraft or using vendor-owned aircraft; 

Aircraft capabilities - required capabilities of aircraft, such as 

retardant capacity and speed; 

Suppression methods- how to use aircraft to suppress fire, including 

initial attack and extended attack; and 

Aircraft performance and effectiveness- the results of using aircraft to 

support fire suppression activities. 

24These aircraft are operated by Air National Guard umts in California, North Carolina, and 

Wyoming, as well as an Alr Force Reserve unit in Colorado. 

Page 11 GAQ.1J.684 Wildland Fire Management 
159 

While the Forest Service and Interior studies and strategy documents 

contained various key elements, none included information on 

performance and effectiveness of aircraft in helping to suppress wildland 

fires because agencies have not collected such information. Figure 2 

identifies which key elements were included in each of the major studies 

and strategy documents we analyzed. (See app. Ill for additional 

information on each of these efforts.) 

Figure 2: Key Elements Included in Major Forest Service and Interior Efforts Since 1995 to Identify Number and Type of 

Firefighting Aircraft They Need 

Jitle of effort· .. 

NationaiStudyofAirtankersto Supportlmllal 

AttackandlargeFireSuppression· Phasei 

National Study of (Large) Airtankers to Support 

lnitiaiAttackandLargeFireSuppression. Phase2 

Aulhor(s) 

Fo<est Serv1ce 

and!nter.or 

Forest Service 

and!nter.or 

Year 

1995 

1996 

I Key efements I 

iWJtf;/%f I .# f ~ 

.I ~ t §~ # .f # u ~q, ·~ ~ §J ;f; 

~l I *

6 01 *~~ 

;Ill ;Ill 

@ 1)1) <!) 1!1 

National Study ofTacbcal Aena! Resource Managemertl 

to Support Initial Attack and Large Fire Suppress;on 

Forest Service 

andlnter:or 1998 Ill \'II Oil 9 Ill 

Wildland F1re Management Aenal Appl!cat1on Study" 

Management Efficiency Assessment on Avtallon 

Activitres in the USDA Forest ServiCe 

~~~~~~~~ ~~~~~;~cy Aviation Council Interagency 

Management 

~':l{ps~~~tedb 

National 

Interagency 

Av1allonCouncJI 

----

?.005 'II 

\'II 2006 

"' 2009 

'll " " 'll 

'II 

9 "" 1!1 'II 

Forest Servtoo LargeAirtanker Modermz_at1on Strategy Forest Serv1ce 2012 'II Ill 1111 

ArrAttackAgainstWildfires· Understanding U.S. Forest 

Servrce Re{lUJrements for Large Aircraft 2012 Ill 

FirefightingAircraftStudy AvrdLLCb 2013 Ill 

Source·GAOanaiysJsofagencyeffor\s 

Note: Other studies offireflghting aviation have been published but are not included here because 

they did Mot include efforts to identify the appropriate number or type offirefighting aircraft. See, for 

example, Blue Ribbon Pane!. Federal Aerial Fwefrghting: Assessing Safety and Effectiveness 

(December 2002). 

~The 2005 Wildland Fire Management Aerial Application Study is the third phase of the National 

Study of Airtankers to Support Initial Attack and Large Fire Suppression 

Page 12 GA0~13.684 Wildland Fire Management 
160 

0

The Forest Service contracted a private company to conduct this study 

cAs previously noted, the National Interagency Aviation Council became known as the National 

Interagency Aviation Committee in April 2010. The Forest Service, Interior, Bureau of Indian Affairs, 

Bureau of Land Management, Fish and Wildlife Service, National Park Service, and National 

Association of State Foresters participate in the National Interagency Aviation Committee and 

assisted in developing this strategy 

The agencies generally used cost- and efficiency-based metrics in these 

efforts, such as the potential cost of damage from wildland fires or the 

frequency with which requests for firefighting aircraft are unmet, to identify 

their firefighting aircraft needs. For example, the three-part National Study 

of Airtankers to Support Initial Attack and Large Fire Suppression, 

conducted from 1995 to 2005, estimated the number of large airtankers 

needed by comparing the cost of using large airtankers to help suppress 

wildland fires with the projected cost of the damage that could result from 

not suppressing the fires. In addition, the Forest Service's 2013 

Firefighting Aircraft Study focused on efficiency and identified the number 

of large airtankers needed by analyzing the annual number of requests 

for these aircraft that the Forest Service was unable to meet. 25 However, 

agency efforts to identify their firefighting aircraft needs have not included 

information on the performance and effectiveness of using aircraft to 

suppress wildfires primarily because neither the Forest Service nor 

Interior has collected data on these aspects of firefighting aircraft. 

Specifically, the agencies have not established data collection 

mechanisms to track the specific tactical uses of firefighting aircraft-for 

example, where retardant or water is dropped in relation to a fire as well 

as the objective of a drop, such as protecting a structure or preventing a 

fire from moving in a specific direction-or measure their performance 

and effectiveness in those uses. Moreover, a 2012 study by the Forest 

Service's Rocky Mountain Research Station found that the Forest Service 

did not collect information about the locations where airtankers drop 

retardant or the actual performance and effectiveness of these aircraft. 26 

this study analyzed requests submitted by incident commanders or other 

seeking f1refighting aircraft support on individual fires. Such requests 

are into an agency resource ordering system, which tracks the number of filled 

and unfilled requests. The study also analyzed the number of untitled requests for large 

helicopters, but it did not identify the number of large helicopters needed. 

26Matthew P. Thompson, David E. Calkin, Jason Herynk, Charles W. McHugh, and Karen 

C. Short, "Airtankers and Wildfire Management in the US Forest Service: Examining Data 

Availability and Exploring Usage and Cost Trends," International Journal of Wid/and Fire 

(August 2012). 

Page 13 GAQ.13.684 Wildland Fire Management 
161 

In May 2012, we reported on the importance of performance information 

in another context and found that such information can inform key 

management decisions, such as allocating resources, or it can help 

determine progress in meeting the goals of programs or operations. 27 

General agreement exists among wildland firefighters that, based on their 

experience, using aircraft can be beneficial to suppressing fires, but little 

empirical data exist to measure the performance and effectiveness of 

such aircraft use. For example, a 2007 study cited anecdotal evidence 

that firefighting aircraft saved homes, and a 2012 study that surveyed fire 

management officials found that these officials believed aircraft were 

effective in reducing the amount of time required to contain wildfires, 

particularly in the most difficult fire suppression conditions. 28 However, 

such views are not based on empirical data on aircraft performance and 

effectiveness, and other studies-including the Forest Service's 2013 

Firefighting Aircraft Study-found that no accurate information on the 

effectiveness of aerial fire suppression exists and noted that the factors 

contributing to the success of wildfire suppression efforts are poorly 

understood. 29 Further, the 2009 Interagency Aviation Strategy stated it is 

difficult to assess the relative value of delivering retardant or water 

through helicopters, large airtankers, and single-engine airtankers and 

called for analytic tools focusing on this area to be developed. In addition, 

the 1998 National Study of Tactical Aerial Resource Management 

identified the need for better information on the intended use of 

surveillance aircraft-such as support for initial attack or large fire 

suppression activities-to determine the specific types of aircraft that will 

meet federal needs for aerial surveillance during firefighting. 

Nanotechnology: Improved Performance Information Needed for Environmental, 

and Safety Research, GA0-12-427 (Washington, D.C .. May 21, 2012). 

28See M. Plucinski, J. Gould, G. McCarthy, and J. Hollis, "The Effectiveness and 

Efficiency of Aerial Firefighting in Australia, Part 1,'' Bushf1re Cooperative Research 

Centre, Technical Report A0701 (June 2007), and M. PlucinskL J. McCarthy, J. Hollis, and 

J. Gould, "The Effect of Aerial Suppression on the Containment Time of Australian 

W!ldfires Estimated by Fire Management Personnel," International Joumal of Wildland Fire 

21 (December 2011 ): 219-229. 

29See, for example, Avid, LLC, "Firefighting Aircraft Study," AG-0248-C-12-0006 

(Yorktown, VA Feb. 27, 2013) and Mark A. Finney, Isaac C. Grenfell, and Charles W 

McHugh, "Modeling Containment of Large Wildfires Using Generalized Linear MixedModel Analysis," Forest Science, 55, no. 3, (June 2009): 249-255 

Page 14 GA0-13-684 Wildland Fire Management 
162 

This limited availability of information on the performance and 

effectiveness of firefighting aircraft is an area of long-standing concern; 

since the 1960s, multiple reviews of federal fire aviation programs have 

called for the Forest Service and Interior to collect information on the 

performance of firefighting aircraft but neither agency has taken action 

until recently. 30 Specifically, in May 2012, the Forest Service recognized 

the need for an approach to evaluate the effective and efficient use of 

firefighting aircraft and began a project on aerial firefighting use and 

effectiveness to develop technology, evaluation criteria, and performance 

measures to quantify and assess the effective use of large airtankers, 

helicopters, and water scoopers in delivering retardant, water, and firesuppressing chemicals. 31 According to Forest Service documents, the 

agency plans to collect information including whether an aircraft was used 

for initial attack or extended attack; the aircraft's objective, such as 

building a line of retardant, directly suppressing fire, or protecting a 

specific structure; whether the fire is in grass, shrub, or timber; general 

weather conditions; and characteristics of the actual drop of retardant, 

such as the time, aircraft speed, retardant amount, and outcome. 32 The 

agency collected some of this information during 2012, but it has not 

developed incremental goals for assessing progress or timelines for 

completing the project. 

The Forest Service faces several challenges in carrying out its project on 

aerial firefighting use and effectiveness. For example, during 2012, the 

agency collected information on the performance and effectiveness of 

one type of aircraft-large airtankers-from about 25 fires but needs 

information on several hundred fires to perform useful analysis on large 

airtanker performance, according to Forest Service officials managing the 

data collection effort. These officials said that it will likely take several 

years for the agency to collect the information needed to analyze and 

30See, for example, Forest Setvice, Airlanker Retardant Drop Evaluation Study, 1964, and 

Department of Agriculture Office of Inspector General, Audit Report: Forest Service's 

Replacement Plan for Firefighting Aerial Resources, 08601-53-SF (Washington, D.C.. July 

16. 2009). 

31The working title of this project is the Aerial Firefighting Use and Effectiveness Study 

32The Forest Setvice plans to collect this information by using existing processes, such as 

gathering reports from aerial firefighters who obsetve aircraft dropping retardant or water 

to suppress fires. Forest Service officials told us that the agency also uses non-traditional 

processes to collect information, such as infrared imagery, ground photos, and aircraft 

tracking sensors. 

Page 15 GA0~13~684 Wildland Fire Management 
163 

understand the effectiveness of the three types of firefighting aircraftlarge airtankers, helicopters, and water scoopers-included in the project. 

Forest Service officials also told us that aerial firefighters have been 

reluctant to collect information on the results of using firefighting aircraft 

for several reasons, including safety concerns regarding adding to the 

workload of aerial firefighters while they are flying over fires, firefighters' 

concerns that Forest Service will use the information to criticize their 

performance, a firefighting culture that values experience and history over 

data and scientific analysis, and the challenges in finding time to 

complete data collection while fighting wildfires. Interior officials said that 

the department is assisting the Forest Service in this data collection 

project but does not currently have plans to collect performance 

information on the firefighting aircraft it manages. 

Large airtankers have been the focus of the Forest Service's current data 

collection effort as well as the agencies' prior studies and strategy 

documents, but few efforts have focused on other types of firefighting 

aircraft. Specifically, eight of the agencies' nine studies and strategy 

documents attempted to identify the appropriate number of large 

airtankers for the federal fleet. However, only three of the efforts-the 

1998 National Study of Tactical Aerial Resource Management, the 2009 

Interagency Aviation Strategy, and the 2012 Air Attack Against Wildfires: 

Understanding U.S. Forest Service Requirements for Large Aircraftidentified the number of other types of aircraft needed, 33 despite the fact 

that each type of firefighting aircraft provides unique capabilities to 

support fire suppression operations. For example, water scoopers can 

deliver large quantities of water when a fire ignites near a water source, 

smokejumper aircraft can quickly transport firefighters and supplies to 

fires in remote areas, and helicopters have the versatility to transport 

firefighters, supplies, or small quantities of water or retardant. As a result, 

performance and effectiveness information on all types of firefighting 

aircraft helps agencies identify the number and type of firefighting aircraft 

they need, including assessing any potential new firefighting aircraft 

platforms or technologies that vendors may propose; understand the 

strengths and limitations of each type of aircraft in different situations; and 

understand how firefighting aircraft could help achieve their wildfire 

33The 1998 study recommended the appropriate number of surveillance aircraft, the 2009 

study recommended the appropriate number for a !I aircraft types, and the 2012 study 

recommended the appropriate number of large airtankers, large helicopters, and water 

scoopers. 

Page 16 GA0.13~684 Wildland Fire Management 
164 

suppression goals. Obtaining information about aircraft performance and 

effectiveness could better inform agency estimates of firefighting aircraft 

needs to include in their strategies for obtaining aircraft, thus helping 

agencies better ensure the adequacy of the federal firefighting aircraft 

fleet 

In contrast to U.S. federal agencies, some foreign and U.S. state 

governments that operate aerial firefighting programs have employed 

various methods to collect and use performance and effectiveness 

information on their firefighting aircraft. 34 For example, in Canada, the 

British Columbia Forest Service requires aerial firefighters to complete an 

airtanker data report immediately after each airtanker flight Officials then 

compile information gathered through these reports with information from 

their dispatch system to evaluate airtanker performance using a set of key 

performance indicators, such as the amount of time from the initial report 

of a fire to the time that an airtanker request is entered into the dispatch 

system, the distance between available airtankers and the actual fire, and 

the change in the size of the fire from the time an aircraft arrives at the 

fire to the time the fire is contained. According to British Columbia Forest 

Service officials, the performance information and indicators have been 

integral to improving British Columbia's aerial firefighting program. For 

example, officials found that available aircraft were often over 100 miles 

from the wildfires where they dropped retardant Based on this analysis, 

the province made significant changes to its methods for pre-positioning 

firefighting aircraft and as a result, available aircraft are generally within 

60 miles of a wildfire. In addition, the Minnesota Department of Natural 

Resources requires officials to complete debriefing reports after each use 

of firefighting aircraft. The report includes information on the specific 

aircraft that were sent to the fire and gathers the firefighters' views on 

whether areas such as dispatch information, aircraft briefings, target 

descriptions, and communications were adequate or need improvement 

According to Minnesota Department of Natural Resources officials, 

34 in the United States, numerous state governments operate aerial firefighting programs 

of varying sizes that use numerous types of aircraft. Of the state officials we met Withrepresenting Alaska, California, Florida, Minnesota, New Hampshire, and TexasMinnesota state government officials reported collecting aircraft performance information 

While several foreign governments-including Australia, multiple Canadian provinces, 

France, and Italy-operate aerial firefighting programs, we spoke to British Columbia 

province officials because the Forest Service identified British Columbia's collection and 

use of airtanker performance information as a leading practice. 

Page 17 GA0.13.684 Wildland Fire Management 
165 

Consistently Collaborated 

with One Another or with 

Other Stakeholders to 

Identify Firefighting 

Aircraft Needs 

information from these reports may help determine the best methods for 

suppressing fires when a specific set of aircraft is available. 

In efforts to identify the number and type of firefighting aircraft they need, 

agencies have engaged in limited collaboration with one another or with 

other stakeholders in the fire aviation community. For example, the Forest 

Service developed its 2012 Large Airtanker Modernization Strategy 

without obtaining input from representatives of state fire aviation 

programs or the large airtanker industry and did not coordinate with 

Interior until after the development of an initial draft. According to several 

agency officials we spoke with, the Forest Service did not invite Interior 

officials to provide their input on the strategy until after the agency sent 

the draft version to the Office of Management and Budget (OMB) for 

review and approval. Similarly, regarding Interior, senior Interior officials 

told us that Interior generally does not involve other agencies or 

stakeholders in developing annual estimates of the number of each type 

of aircraft to obtain through contracts. Rather, Interior develops these 

estimates by asking relevant Interior bureaus to provide the number of 

each type of aircraft it needs, compiling these estimates, and adjusting 

them based on available funding. 

The importance of collaboration with stakeholders and agencies has been 

noted in several government reports. 35 For example, the interagency 

2009 Quadrennial Fire Review identified the need to engage agency 

leaders, partners, and industry in a strategic dialogue about the demands 

for firefighting resources, such as aircraft, and noted the importance of 

innovative and efficient ways to meet those demands. 36 Additionally, a 

2009 Department of Agriculture Inspector General's report recommended 

that the Forest Service collaborate with stakeholders in the fire aviation 

importance of collaboration was noted in a 2002 report by an expert panel that 

Forest Service and Interior convened to examine the safety and effectiveness of federal 

aerial firefighting. This report identified collaboration among agencies, contractors, and 

states as possibly the single largest aerial firefighting challenge facing federal agencies at 

the time. See Blue Ribbon Panel, Federal Aerial Firefighting: Assessing Safety and 

Effectiveness (December 2002) 

36The Quadrennial Fire Review is a strategic assessment process that is conducted every 

4 years to evaluate current mission strategies and capabilities against best estimates of 

the future environment for wildfire management This integrated review is a Joint effort of 

the five federal natural resource management agencies and their state, local, and tribal 

partners that constitute the wildland fire community. 

Page 18 GA0~13.684 Wildland Fire Management 
166 

community to develop goals and performance measures for the agency's 

aviation strategic plan. 37 Regarding collaboration with stakeholders, in 

April 2013, we reported that when agencies carry out activities in a 

fragmented and uncoordinated way, the resulting patchwork of programs 

can waste scarce funds, confuse and frustrate program customers, and 

limit the overall effectiveness of the federal effort. 38 In addition, we 

reported in October 2011 that successful organizations involve 

stakeholders in developing their mission, goals, and strategies to help 

ensure that they target the highest priorities. 39 In that report, we also 

stated that stakeholders can infiuence success or failure of agencies' 

programs. 

Many Forest Service and Interior officials, as well as other stakeholders, 

we spoke with expressed concerns about limited collaboration, and many 

cited shortcomings with the formal mechanism for interagency 

collaboration-the National Interagency Aviation Committee, which 

includes representatives from the Forest Service, Interior and its bureaus, 

and the National Association of State Foresters. Some stakeholders told 

us the committee has not always considered the needs of all agencies 

involved in firefighting efforts. For example, in 2008 committee members 

collaboratively developed a national firefighting aviation strategy, the 

Interagency Aviation Strategy. A year later, however, the Forest Service 

developed an appendix to the strategy that outlined the Forest Service's 

plans for replacing its large airtanker fleet, and the committee published 

an amended strategy-including that appendix-without providing 

member agencies the opportunity to review or contribute to it, according 

to agency officials. As a result, the large airtanker appendix does not 

reflect the opinions of all committee members, and consequently does not 

reflect the needs of the fire aviation community stakeholders that will 

require the use of large airtankers. In addition, Forest Service and Interior 

officials told us that agency staff who serve on the committee are 

generally firefighting operations staff and do not represent senior agency 

37Departrnent of Agriculture Office of Inspector General, Audit Report: Forest Service's 

Replacement Plan for Firefighting Aen·af Resources (Washington, D.C .. July 16, 2009). 

38GAO, 2013 Annual Report: Actions Needed to Reduce Fragmentation, Overlap, and 

Duplication and Achieve Other Financial Benefits, GA0-13-279SP (Washington, D. C 

Apr. 9, 2013) 

39GAO, Environmental Justice: EPA Needs to Tak.e Additional Actions to Help Ensure 

Effective Implementation, GA0-12-77 (Washington, D.C .. Oct. 6, 2011). 

Page 19 GA0-13-684 Wildland Fire Management 
167 

management. As a result, the collaboration that occurs through the 

committee is often limited to day-to-day operations activities rather than 

broader strategic efforts. 

The committee has implemented some leading practices that we 

previously reported can help enhance and sustain collaboration. 40 

Specifically, the committee's members have defined and articulated a 

common purpose and have agreed on agency roles and responsibilities. 

For example, the committee's charter identifies its purpose as serving as 

a body of aviation experts focused on identifying opportunities to enhance 

safety, effectiveness, and efficiency in aviation related operations, 

procedures, programs, and coordination. In addition, the committee's 

2009 Interagency Aviation Strategy defines the general aerial firefighting 

roles and responsibilities of federal and state agencies as well as aircraft 

contracting responsibilities of the Forest Service and Interior. However, 

we previously found that agencies often face a range of barriers, including 

concerns about controlling jurisdiction over missions and resources, when 

they attempt to collaborate with other agencies. 41 Interior officials told us 

that the division of firefighting aircraft contracting responsibilities among 

the Forest Service and Interior-under which Forest Service issues 

contracts for large and very large airtankers and large and medium 

helicopters, while Interior issues contracts for single-engine airtankers 

and water scoopers-may not foster a culture of collaboration since each 

agency is focused on its own aircraft of responsibility. Although the 

committee has implemented some leading practices for collaboration, it 

has not taken additional steps to reinforce agency accountability for 

collaboration, such as developing mechanisms to monitor, evaluate, and 

report the results of collaborative efforts. 42 We have reported that by 

creating the means to monitor, evaluate, and report the results of their 

collaborative efforts, federal agencies can better identify areas for 

improvement, although the specific ways in which this practice is 

implemented may differ based on the specific collaboration challenges 

agencies face. For example, mechanisms for monitoring the results of 

collaborative efforts may range from occasional meetings among agency 

officials to more formal periodic reviews where officials from each agency 

40GA0-06-15. 

41 GAO, Managing for Results: Barriers to Interagency Coordination, GAO/GGD-00-106 

(Washington, D. C .. Mar. 29, 2000) 

42GA0-06-15 

Page 20 GA0-13-684 Wildland Fire Management 
168 

The Forest Service's 

Approach to 

Modernizing the Large 

Airtanker Fleet Faces 

Challenges, Resulting 

in Uncertainty over 

Continued Large 

Airtanker Availability 

report on progress toward achieving the goals of interagency 

collaborative efforts. As we reported in August 2012, absent effective 

collaboration, interagency efforts could result in limited information being 

communicated and opportunities for incorporating stakeholder input being 

missed. 43 

Senior management in both the Forest Service and Interior told us they 

have begun discussions regarding how to improve their interagency 

collaboration. However, they said that these discussions have focused on 

obtaining firefighting aircraft for the 2013 fire season and have not yet 

addressed collaboration on strategic planning issues. Further, both Forest 

Service and Interior officials told us the Interagency Aviation Strategy is 

outdated and should be updated to more accurately refiect current 

firefighting aircraft needs. Engaging in effective collaboration to 

incorporate input from all fire aviation community stakeholders could 

better position the agencies in developing strategic planning documentsincluding any updates to the Interagency Aviation Strategy-that 

represent the national need for firefighting aircraft. 

The Forest Service plans to modernize the large airtanker fleet by 

obtaining large airtankers from various sources over the near, medium, 

and long terms, but each component of this approach faces challenges 

that make the continued availability of such aircraft to meet national fire 

suppression needs uncertain. The components of the agency's approach 

include: (1) in the near tenm, continuing to contract with private vendors 

for "legacy" large airtankers-generally aging aircraft with limited future 

service life spans-<Jn exclusive-use contracts and very large airtankers 

on call-when-needed contracts, as well as relying on agreements vvth 

cooperator governments and the military; (2) in the medium term, 

contracting with vendors for airtankers that are more modern and capable 

than those generally in use currently; and (3) in the long term, acquiring 

new federally-owned aircraft with expected service life spans of up to 30 

years. Additionally, some federal and state agencies are considering 

alternative plans to obtaining aerial fire suppression support to reduce 

reliance on large airtankers. 

43GAO, Housing Assistance: Opportunities Exist to Increase Collaboration and Consider 

Consolidation, GA0-12-554 (Washington, D.C .. Aug. 16, 2012). 

Page 21 GA0-13-684 Wildland Fire Management 
169 

The Forest Service's 

Near-term Approach 

Includes Using "Legacy" 

and Supplemental 

Airtankers but Concerns 

Exists Regarding Aircraft 

Availability, Performance, 

or Cost 

"Legacy" Large Aiitankers 

For the near-term, the Forest Service plans to primarily rely on exclusiveuse "legacy" contracts to obtain large airtankers. However, during periods 

of heavy fire activity, the agency plans to obtain supplemental airtankers 

through call-when-needed contracts for very large airtankers, agreements 

with cooperator governments, and military aircraft equipped with MAFFS. 

However, agency officials and vendor representatives told us about 

limitations and challenges-including availability, performance, and 

cost-regarding these resources. 

Over the next 5 years-including the 2013 fire season-the Forest 

Service plans to rely on aircraft obtained through its "legacy" exclusiveuse contracts, which has been the agency's traditional acquisition model 

for obtaining large airtankers. The agency in 2013 announced contract 

awards for nine aircraft: seven P-2V Neptunes-Korean War-era pistonengine maritime patrol aircraft-and two British Aerospace BAe-146sconverted versions of modern commercial jets. 44 However, the availability 

of the P-2V Neptunes in the short term is uncertain, and the Interagency 

Airtanker Board has documented concerns regarding performance of the 

retardant delivery systems on these BAe-146s. 

Lockheed P-2V Neptune. The age of the seven P-2V Neptunes-they 

average more than 50 years old-makes their availability throughout 

the entire 5-year contract period uncertain. Specifically, vendors told 

us they might need to retire some aircraft prior to the end of the 

current contract period because of the cost of maintaining the aging 

aircraft. In particular, they told us that the limited availability of 

replacement parts-and the difficulty of manufacturing new ones if no 

others exist-coupled with the requirements of increased 

maintenance and inspection standards make the P-2V Neptune 

difficult to operate in a cost-effective manner. Further, physical 

stresses on the aircraft could cause cracking of critical components 

during fire missions. For example, representatives from Neptune 

Aviation Services told us that the vendor retired one of its P-2V 

4

4-rhese contracts were awarded to tvvo vendors: Neptune Aviation Services (six P-2V 

Neptunes and tvvo BAe-146s) and Minden Air Corp (one P-2V Neptune).The Forest 

Service initially awarded a contract for a single BAe-146, but added another based on 

concerns regarding the overall availability of large airtankers for the 2013 fire season. The 

P-2V Neptunes are capable of delivering approximately 2,000 gallons of retardant and the 

BAe-146s approximately 2,600 gallons 

Page 22 GA0-13-684 Wildland Fire Management 
170 

Neptunes after the 2012 fire season due to structural problems 

discovered during routine maintenance. 45 They also said that the 

vendor probably could continue to operate approximately five P-2V 

Neptunes for the next 10 years but that the current heavy use of their 

fleet could shorten this timeframe. Ultimately, Neptune Aviation 

Services plans to retire its P-2V Neptune fleet and transition to 

operating modern aircraft exclusively. 

Neptune Aviation Services' British Aerospace 8Ae-146s. Concerns 

regarding the performance of the retardant delivery system on 

Neptune Aviation Services' BAe-146s have been documented during 

agency evaluations of the aircraft and were voiced by several agency 

officials we interviewed. 46 During initial assessment of the system in 

2011, the Interagency Airtanker Board determined that the retardant 

delivery system did not meet established performance criteria and 

identified problems regarding the system's design and performance. 47 

However, in September 2012, the board approved, on an interim 

basis, the use of the retardant delivery system through the 2012 fire 

season so that information on its operational effectiveness could be 

collected and design deficiencies addressed. During the 2012 fire 

season, the BAe-146s collectively made approximately 300 retardant 

drops, which the board considered sufficient to collect data needed to 

assess their operational effectiveness. 

In December 2012, the Interagency Airtanker Board declined to 

extend the interim approval of Neptune Aviation Services' BAe-146 

system, citing the problematic retardant delivery system design and 

deficient performance during the 2012 fire season. In February 2013, 

however, the National Interagency Aviation Committee determined 

that the need for aircraft to deliver retardant for the 2013 fire season 

was sufficiently important to override the board's decision. As a result, 

of Minden Air Corp told us that the company no longer operates one of 

P-2V Neptunes following damaged sustained from a controlled-crash landing 

caused by landing gear failure during the 2012 fire season 

46The retardant delivery system of this specific BAe-146 differs from traditional systems; it 

uses a series of tubes to evacuate retardant from the aircraft rather than doors. 

47Specifical!y, this initial assessment determined that the system did not have the range of 

variability of retardant flow rates normally found in proposed systems, the consistency of 

retardant flow trailed off as the retardant tank emptied, and the system was unable to 

predictably drop retardant while in a nose-down descent-a common flight profile for 

dropping retardant downhill 

Page 23 GA0-13-684 Wildland Fire Management 
171 

Very Large Airtankers 

the board, at the direction of the committee, granted an extension of 

its interim approval of the retardant delivery system through 

December 15, 2013. Representatives of Neptune Aviation Services 

acknowledged that the system has limitations, but they stated that the 

company is developing a revised retardant delivery system and plans 

to retrofit all of its BAe-146 aircraft with the updated design by the 

beginning of the 2014 fire season. However, the Interagency Airtanker 

Board has noted that the deficiencies may persist due to the inherent 

design of the system, and fire management officials from the Forest 

Service, Interior, and several states that are familiar with this aircraft 

told us they have reservations about the retardant delivery system's 

performance. 

The Forest Service announced call-when-needed contracts for two very 

large airtankers-converted versions of Boeing 7 4 7 and McDonnell 

Douglas DC-10 commercial jets-to provide extended attack and large 

fire support beginning in 2013 with durations of up to 3 years. However, 

some agency officials cited concerns about the aircrafts' role, suitability 

for operating over rugged terrain, limited compatibility with current 

airtanker base infrastructure, and high costs (see fig. 3 for an example of 

a very large airtanker)48 

48Two vendors developed very large airtankers during the early 2000s, with each 

retrofitting a different type of aircraft-10 Tanker Air Carrier converted two McDonnell 

Douglas DC-10s with retardant capacities of 11,600 gallons, and Evergreen International 

Aviation converted a Boeing 747 with a retardant capacity of 19,400 gallons 

Page 24 GAQ.13.684 Wildland Fire Management 
172 

Figure 3: Example of a DC~10 Very Large Airtanker Dropping Retardant 

The Forest Service previously contracted for very large airtankers, but 

according to Forest Service and Interior officials, firefighters were initially 

reluctant to request the very large airtankers for several reasons. For 

example, because of the size of these aircraft, some federal officials were 

uncertain whether they could safely operate in rugged terrain'' Some 

officials also told us that firefighters did not request very large airtankers 

because they were uncertain how best to use this new tooL For example, 

the Forest Service identifies the primary mission of large airtankers as 

initial attack, whereas the solicitation for the very large airtanker callwhen-needed contract stated that they will be used to provide support for 

49To evaluate the safety and utility of very large airtankers, m 2009 the Forest Service 

contracted with the National Aeronautics and Space Administration to conduct an 

operational test and evaluation of both types of very large airtanker. This evaluation 

concluded that the aircraft could probably operate with few restrictions over gently rolling 

terrain but that extra restrictions might be necessary in extremely steep or rugged terrain 

USFS Very Large Aerial Tanker Operational Test and Evaluation Summary Report, March 

2, 2009. Representatives from 10 Tanker Air Carrier, which operates the DC-10s, told us 

that their aircraft have successfully delivered retardant in rugged terrain since 2006 

Page 25 GA0-13-684 Wildland Fire Management 
173 

Cooperator Government 

Airtankers 

extended attack on large fires-leading to uncertainty about the best 

tactics for employing them 5° Despite early reluctance to use very large 

airtankers, officials noted increased reliance on these aircraft; 

nevertheless, some agency officials continue to disagree about the most 

effective role-initial attack or large fire support-for these aircraft as well 

as whether or not they are suited to operating above rugged terrain. 

Additionally, very large airtankers can operate out of a limited number of 

established airtanker bases because their weight and size are too great 

for some existing base infrastructure such as runways or aircraft parking 

areas. Specifically, about half of the large airtanker bases nationwide-35 

of67-are currently or potentially capable of supporting DC-10 

operations, according to a Forest Service official; 51 the ?47's compatibility 

with bases is even more limited in that it can operate from approximately 

12 locations, not all of which are airtanker bases. However, some agency 

officials told us that the speed of these aircraft can compensate for their 

limited compatibility with existing airtanker bases and associated 

increased distances that the aircraft might need to fly to respond to fires. 

Some officials also noted concerns about the high costs of using the 

aircraft. (See app. II for the current contract rates of firefighting aircraft.) 

The Forest Service plans to request large airtankers from two cooperator 

governments-Canada and the State of Alaska-during periods of high 

fire activity but these aircraft may not always be available. Under an 

agreement originally established in 1982, the Forest Service plans to rely 

on five Convair CV-580 large airtankers-converted commercial aircraft 

with retardant capacities of 2,100 gallons-provided by Canadian 

provinces as additional resources when additional large airtankers are 

needed. Additionally, Forest Service officials told us that, under a 

separate agreement, the agency can also request use of three CV-580s 

contracted by the State of Alaska. However, the use of these airtankers to 

supplement the federal large airtanker fleet is contingent upon the 

cooperator governments making them available. For example, such 

airtankers might already be committed to suppressing fires, which could 

prevent them from being released to assist other governments. 

very large airtanker vendors told us that their aircraft are capable of supporting 

initial attack operations 

51 The potential ability of21 airtanker bases to support DC~10 operations may be 

contingent upon the availability of mobile retardant loading equipment. 

Page 26 GA0~13~684 Wildland Fire Management 
174 

Modular Airborne Firefighting 

System (MAFFS) 

As it has periodically done since the program's inception in the early 

1970s, the Forest Service plans to rely on the military to provide surge 

aerial firefighting capacity through the deployment of up to eight MAFFSequipped C-130 aircraft (see fig. 4 for an example of a MAFFS-equipped 

C-130) 52 However, a number of officials from the Forest Service, Interior, 

and state fire agencies stated that MAFFS performance can be 

inadequate in some circumstances. For example, while a Forest Service 

official noted that the MAFFS system has been approved by the 

Interagency Airtanker Board, some federal and state fire aviation officials 

told us that the retardant line dispersed by the MAFFS system is 

generally narrower than firefighters prefer, which can either allow a fire to 

jump across the retardant line or necessitate an additional drop to widen 

the line, if another aircraft is available. Additionally, some officials said the 

system is unable to penetrate dense forest canopies, thereby preventing 

the retardant from being effective when used in heavy timber. However, 

some federal and state officials told us that MAFFS can be used 

effectively on rangeland where grasses are the predominant fuel type. 

Further, some fire officials expressed concern regarding the limited 

experience that MAFFS crews may have in the fire aviation mission 

because they are not full-time aerial firefighters. A DOD accident 

investigation report conducted in response to a 2012 fatal crash of a 

MAFFS-equipped C-130H found that the limited total firefighting 

experience of the crew-in particular, the number of drops accomplished 

prior to the accident-was a contributing factor to the accident. 53 The 

report also stated that the crew's training did not include essential 

components-including training on local terrain conditions and congested 

airtanker base operations-necessary to conduct MAFFS operations in 

the region where the crash occurred. A Forest Service official involved in 

managing MAFFS training told us that the agency has updated the 

training to better incorporate such components. 

52The Forest Service is responstb!e, through the National Interagency Fire Center, for 

reimbursing DOD for the actual costs of MAFFS activation_ DOD estimates the per-hour 

flight costs of MAFFS to be between about $4,700 and $8,000 dollars depending on the 

model of C-130 used, with variable daily availability costs depending on factors including 

the number of personnel required as well as the location of the activation. A Forest 

Service budget official told us that the combined reimbursements to DOD for MAFFS 

training and operational use from 2007 to 2012 totaled nearly $87 million 

53 United States Air Force Accident Investigation Board Report C-130H3, TIN 93-1458 

(Oct. 27, 2012) 

Page 27 GA0-13-684 Wildland Fire Management 
175 

The Forest Service's 

Medium-term Approach 

Includes Contracting for 

Newer Aircraft, but 

Implementation Has 

Been Delayed 

Figure 4: Example of MAFFS-equipped C~130 

Note: This figure depicts a MAFFS-equipped C-130 dropping water during training 

For nearly 2 years, the Forest Service has attempted to award "nextgeneration" contracts with durations of 5 to 10 years to modernize the 

fleet with faster and more up-to-date large airtankers. However, these 

efforts have been delayed by bid protests, and it is uncertain when some 

vendors will complete federal approval and certification processes for 

their aircraft, which are necessary prior to use as airtankers on federal 

contracts. As a result, it is uncertain when the "next-generation" large 

airtankers will be available to support fire suppression activities. 

Additionally, private vendors that are developing the "next-generation" 

large airtankers told us that concerns regarding the consistency of the 

Forest Service's approach to fleet modernization have increased the 

difficulty of making business decisions and could affect the number of 

aircraft they will be able to provide to the government. 

In November 2011, the Forest Service issued a solicitation for "nextgeneration" large airtankers in an effort to modernize the airtanker fleet 

Page 28 GA0-13-684 Wildland Fire Management 
176 

with more modern, capable, and safe large airtankers (see fig. 5). 54 1n 

June 2012 the Forest Service issued an initial notice of intent to award 

contracts for seven aircraft However, protests that challenged the 

announced awards were filed and consequently those contracts were not 

awarded. The Forest Service subsequently issued an amended 

solicitation, and in May 2013, the Forest Service announced contract 

awards for seven aircraft, 55 with the intent that these aircraft be available 

for use during the 2013 fire season. While the second round of "nextgeneration" large airtanker awards was also protested by a vendor, this 

protest was dropped in June 2013. 

"next-generation" large airtanker contract solicitation allowed for the award of up to 

seven exclusive-use contracts, each with up to five aircraft, with 5-year base durations 

followed by five 1-year option periods to be selected at the discretion of the Forest 

Service. !t stipulated that candidate aircraft be turbine-powered, capable of crwsing at 

speeds of at least 300 knots, and have a retardant capacity of at least 2,400 gallons, with 

a target capacity of 3,000 to 5,000 gallons. The solicitation indicated that aircraft with a 

capacity of 3,000 gallons or more would be evaluated higher than those aircraft offered 

with less capacity and would be considered first when determinmg awards. However, 

several vendors questioned the rationale behind the 3,000-5,000 gallon target, telling us 

that the aircraft available for the large airtanker mission with retardant capacities in the 

2,000 to 2,500 gallon range may be more capable, available, and less expensive to 

operate 

55Five vendors received contract awards for a total of seven aircraft. The seven aircraft 

were two Avro RJ85s, two McDonnell Douglas MD-87s, one BAe-146, one Lockheed 

Martin C-1300, and one DC-10. All of these aircraft can carry betw"een 3,000 and 5,000 

gallons of retardant, according to Forest Service officials, with the exception of the DC-1 0, 

a very large autanker capable of carrying 11,600 gallons. The DC-10 "next generation" 

contract flight hour rate includes the delivery of 5,000 gallons of retardant, although the 

aircraft can deliver its full capacity at a higher flight hour rate. 

Page 29 GA0-13-684 Wildland Fire Management 
177 

Figure 5: Example of a "Next-Generation" Large Airtanker (BAe-146) 

Note: Minden Air Corp. owns this BAe-146 and is modifying it with the addition of a traditional gravity- fed retardant delivery system 

It is uncertain when all of the "next-generation" large airtankers will be 

available to support fire suppression activities because only one of these 

aircraft has completed necessary federal approval and certification 

processes. Specifically, the DC-10 very large airtanker has completed the 

Interagency Airtanker Board's approval process, which the Forest Service 

considers a prerequisite for delivering retardant in support of fire 

suppression activities. According to Forest Service officials, the remaining 

vendors originally scheduled the testing of their aircraft and retardant 

delivery systems for spring 2013. However, Forest Service officials also 

told us that, as of August 8, 2013, none of these aircraft had completed 

testing, which is now scheduled to continue later into the year. 

Additionally, they told us that only the DC-10 had received Federal 

Aviation Administration certification to be modified for operation as an 

airtanker, which is required by the Forest Service prior to aircraft 

delivering retardant. 56 

56Such approval is granted through a "supplemental type certificate," which is issued when 

a vendor has received Federal Aviation Administration approval to modify an aircraft from 

its original design. 

Page 30 GA0-13-684 Wildland Fire Management 
178 

Based on their experience with the Forest Service over the last several 

years, large airtanker vendors told us that they have a limited 

understanding of the agency's approach to fleet modernization. 

Specifically, they stated that the Forest Service has varied in the number 

and ownership structure (i.e., vendor, government, or a mix of the two) of 

large airtankers it plans to have in its fieet As early as 2005, the Forest 

Service indicated it would rely on a fleet of government-owned Lockheed 

Martin C-130J Hercules aircraft, a substantial departure from the 

agency's longtime practice of relying on private vendors to supply 

firefighting aircraft The 2009 Interagency Aviation Strategy called for a 

government-owned fleet of 25 new C-130Js and stated that the future 

federal use of privately-owned large airtankers was highly unlikely due to 

concerns regarding safety, cost, and aircraft availability. Yet the Forest 

Service's 2012 Large Airtanker Modernization Strategy stated that the 

agency will rely on private vendors to provide at least a portion of the 

intended large airtanker fieet, which it noted is likely between 18 and 28 

aircraft 

Representatives of some large airtanker vendors we spoke with said that 

this inconsistency in the Forest Service's large airtanker approach has 

increased the difficulty of making business investment decisions. For 

example, some vendors told us that if they were confident that the Forest 

Service's long-term plans would include privately-owned large airtankers 

as a significant portion of its future large airtanker fleet, they might be 

more inclined to invest in the modification of additional aircraft Some 

vendors also told us that a 1 0-year contract term-rather than the current 

practice of awarding contracts with 5-year base terms and five 1-year 

options-would create greater stability in the large airtanker marlket and 

could result in lower costs for the federal government by allowing vendors 

to recoup their aircraft investment costs over 10 years instead of 557 

57The 2009/nteragency Aviation Strategy also identified the use of 10~year contracts as a 

goa! for federal firefighting aircraft acquisition programs. However, Forest Service officials 

noted that the agency does not currently have the statutory authority to issue 1 0-year 

aviation contracts and that the 5-year duration of the "next generation" contracts is longer 

than the agency has typically issued 

Page 31 GA0-13-684 Wildland Fire Management 
179 

Forest Service's Long-term 

Approach Includes 

Government-Owned 

Airtankers, but Concerns 

Exist Regarding Cost and 

Effectiveness 

Lockheed Martin C-130J 

Hercules 

The Forest Service's 2012 Large Airtanker Modernization Strategy stated 

that the agency must continue to explore different acquisition modelsincluding government-owned aircraft and vendor-owned aircraft under 

contract to the agency-to ensure the agency will have access to large 

airtankers over the long term. The strategy did not identify the agency's 

planned ratio of government-owned to vendor-owned aircraft, and Forest 

Service officials told us that such determinations have not yet been made. 

The strategy also did not specify the type of government-owned aircraft to 

be obtained, but a senior official in the Forest Service's Fire and Aviation 

Management program told us that the agency is planning to acquire a mix 

of Lockheed Martin C-130J Hercules and Alenia C-27J Spartan aircraft 

with expected service life spans of up to 30 years. However, potential 

acquisition or operational challenges are associated with both types of 

government-owned aircraft the Forest Service is proposing. 

While the Forest Service has indicated its long-term intention to rely on a 

government-owned fleet of C-130Js to meet some or all of its large 

airtanker needs, 58 the agency has been unable to demonstrate the 

feasibility of this approach to OMB, which would need to approve such an 

investment. The Forest Service estimates in its 2012 Large Airtanker 

Modernization Strategy that each new aircraft would cost $79 million, 59 

not including costs related to operations or maintenance. 60 Since 2005, 

the Forest Service has submitted two proposals for the government 

purchase of a large airtanker fleet to OMB for review and potential 

inclusion in budget requests. However, OMB officials told us that the 

agency rejected both of these proposals because they were incomplete 

and did not meet agency guidance. 61 After reviewing these proposals, the 

Department of Agriculture's Office of Inspector General concluded in a 

2009 audit report that the Forest Service needed to establish better 

58The Forest Service has also indicated that these would be used as murtirole mrcraft 

capable of transporting cargo and personnel when not in use as airtankers 

59This represents a $19 million increase over the $60 million per-aircraft cost estimate 

stated in the Forest Service's large airtanker appendix to the 2009 Interagency Aviation 

Strategy 

60Aithough the Forest Service proposed the acquisition of new C-130Js, a senior official 

told us the agency would also accept used C-130Js if they were declared surplus by DOD 

61 Guidance on such submissions is contained in OMB Circular A-11, "Preparation, 

Submission, and Execution of the Budget" (August 2012), and OMS Circular A-126, 

"Improving the Management and Use of Government Aircraft" (May 22, 1 992) 

Page 32 GA0-13-684 Wildland Fire Management 
180 

Alenia C-27 J Spartan 

performance measures in coordination with interagency stakeholders and 

collect performance data on the use and effectiveness of airtankers. 62 

According to Forest Service officials, another proposal has been 

submitted for Department of Agriculture management review, but the 

department has not established a time frame for submitting the proposal 

to OMB. However, it is unclear whether the Forest Service has resolved 

the concerns of both OMB and the Inspector General. Additionally, Forest 

Service and Interior officials stated that the effectiveness of the C-130J 

will largely depend on the type of retardant delivery system installed. In 

particular, the officials expressed concern that equipping the aircraft with 

MAFFS-Iike units similar to those used in military C-130 aircraft-which 

the agency has indicated is an option-could be problematic given the 

previously discussed limitations of that type of retardant delivery system. 

In addition, obtaining such units could be problematic because there is no 

existing manufacturer of MAFFS units, 63 although the Forest Service 

issued a request for information from potential manufacturers regarding 

the development of new retardant delivery system designs. 

The Forest Service has also expressed interest in obtaining up to 14 

Alenia C-27 J Spartan transport aircraft from DOD if they are declared 

surplus equipment. 64 Forest Service documents indicate that the agency 

would benefit from acquiring these aircraft for several reasons. 

Specifically, agency documents cited that the C-27 J aircraft would be 

safer and more reliable than "legacy" large airtankers, in part because 

they are newer and have improved structural designs; they could be used 

in multiple roles that include dropping retardant and carrying cargo or 

smokejumpers; their flight speed exceeds the 300-knot requirement under 

the "next-generation" contract; and the agency would not have to pay to 

acquire the aircraft-which officials described as a critical benefitalthough it would incur costs to convert the aircraft to firefighting use. 

Despite the advantages cited by the agency, several challenges may 

exist with operating the aircraft to support fire suppression activities, 

62Department of Agriculture Office of Inspector General, Audit Report: Forest SeJVice's 

Replacement Plan for Firefighting Aerial Resources (Washmgton, D.C .. July 16, 2009) 

63The manufacturer of the MAFFS units used by DOD ceased operating in 2011. 

64A provision in the Fiscal Year 2013 National Defense Authorization Act grants the Forest 

Service preference over other agencies in acquiring seven of these aircraft for use in the 

firefighting mission if the aircraft are declared surplus by DOD 

Page 33 GA0~13~684 Wildland Fire Management 
181 

including some related to the aircraft's capacity and capabilities. For 

example, an analysis conducted by a private consultant for the Forest 

Service indicated that the maximum retardant capacity of the C-27 J is 

expected to be about 1,850 gallons, which is below the minimum 2,400 

gallon retardant capacity the agency established for its "next-generation" 

large airtanker fleet. 65 Depending on how the aircraft are used, the actual 

capacity may be substantially lower. Specifically, the Forest Service has 

indicated that it would use the C-27 Js as multirole aircraft, transporting 

cargo and smokejumpers when they are not being used as airtankers. To 

do so, the agency initially stated that it expected to rely on removable, 

pressurized retardant delivery systems similar to MAFFS units described 

earlier to allow the aircraft to carry out this multirole mission. 66 However, 

according to the Forest Service consultant, such a system would carry 

about 1,100 gallons. Some agency officials told us that they are 

concerned about the retardant capacity of the aircraft, particularly if a 

removable, pressurized delivery system is used. Specifically, they 

questioned whether the C-27 J would be able to carry enough retardant to 

provide a useful resource to firefighters and noted that pressurized 

retardant delivery systems do not always provide adequate coverage on 

the ground to support fire suppression operations. More recently, Forest 

Service officials stated that the agency expects to use a removable, 

gravity-fed retardant delivery system rather than a pressurized system, 

which would likely alleviate some concerns regarding the system's 

capabilities. The agency stated that it is currently examining alternatives 

and will make a decision regarding the delivery system at the conclusion 

of that analysis. 

Other potential challenges relate to uncertainties about the costs of 

operating and maintaining the aircraft, which the Forest Service would be 

responsible for under the 2013 National Defense Authorization Act. For 

example, the consultant hired by the Forest Service to analyze the C27 Js reported that, although there is a significant advantage in having the 

aircraft transferred without acquisition cost, the costs to maintain and 

65C-27J Capabilities and Cost Analysis Reporl (undated), submitted in October 2012 to 

the Forest Service by Convergent Performance, LLC 

66The Chief of the Forest Service, in testimony before the Senate Committee on 

Appropriations, Subcommittee on Interior, Environment, and Related Agencies on May 22, 

2013 and the Senate Committee on Energy and Natura! Resources on June 4, 2013, 

stated that the agency was considering equipping any C-27Js obtained with MAFFS-!ike 

retardant delivery systems. 

Page 34 GA0~13~684 Wildland Fire Management 
182 

Some Federal and State 

Agencies Are Considering 

Alternatives to Relying on 

Federal Large Airtankers 

operate these aircraft are uncertain and could present challenges. A 

Forest Service official told us that the agency estimates the cost to modify 

each aircraft for the airtanker mission would range from $1 million to 

$4.25 million and delivery time frames would range from 6 months to 40 

months, but the actual figures depend on the type of system selected. 67 

Further, DOD officials responsible for managing the C-27 J told us they 

expect the cost to maintain the aircraft to rise at the conclusion of DOD's 

current contract with a private vendor and stated that the Forest Service 

would need to establish new maintenance and training contracts, which 

could be complex to manage. According to both DOD officials and the 

Forest Service consultant's analysis, domestic flight training for this 

aircraft is available from a single provider, which the consultant indicated 

is "time consuming ... and relatively expensive." Forest Service officials 

stated that they have not yet been able to access detailed information on 

DOD's experience with C-27 J operations and maintenance costs and 

have not obtained information from the manufacturer to fully understand 

and analyze the costs of operating the aircraft. 

Although the Forest Service has taken several steps to modernize the 

large airtanker fleet, as noted, the number of large airtankers available 

under federal contract decreased from 44 in 2002 to 8 in early 2013. As a 

result, some federal and state agencies are looking to alternative plans to 

suppress fires. For example, for the 2013 fire season, Interior increased 

the number of single-engine airtankers on exclusive-use contracts from 

14 to 28 in part due to concerns about the availability of large airtankers. 

Interior officials noted that the use of single-engine airtankers has 

increased over the last decade as fewer large airtankers have been 

available. Interior also plans to rely on the capabilities of an additional 46 

single-engine airtankers on call-when-needed contracts to provide 

additional support in 2013. 68 Following the termination of contracts for 8 

large airtankers in 2011 due to safety concerns, the Forest Service has 

increased the number of large helicopters available on exclusive-use 

contract by 8, for a total of 34, from fiscal year 2011 to fiscal year 2012. 

67 A Forest Service official told us that the agency estimates that the cost to refurbish and 

eqUip the aJrcraft for the smokejumper and cargo missions could be up to $900,000 per 

aircraft. 

68Because these aircraft are not on exc!usive~use contracts, their availability is not 

guaranteed 

Page 35 GAO~ 13~684 Wildland Fire Management 
183 

Conclusions 

Further, some states are taking actions to enhance their own abilities to 

obtain their own aerial firefighting support. For example, CAL FIRE 

officials told us that, as the result of concerns regarding the Forest 

Service's ability to consistently provide a large airtanker fleet to suppress 

fires in California, CAL FIRE may consider expanding its firefighting 

aircraft fleet to include large airtankers. 69 In the wake of similar concerns 

about aerial firefighting support for fires such as those that caused 

extensive damage in 2012, 70 Colorado has enacted legislation that 

authorizes a firefighting aircraft fleet for its state-" In addition, Nebraska 

has enacted a bill that authorizes the state to contract for two singleengine airtankers-" 

Recognizing the importance of aircraft to help fight wildland fires, the 

Forest Service and Interior have undertaken efforts to identify the number 

and type of firefighting aircraft they need over the years but have met with 

limited success. None of the agencies' studies and strategy documents 

contained information on aircraft performance and effectiveness in 

supporting firefighting operations, which limits the agencies' 

understanding of the strengths and limitations of each type of firefighting 

aircraft and their abilities to identify the number and type of aircraft they 

need. The Forest Service has started to collect some aircraft performance 

information, but it is limited and focused on large airtankers. Interior has 

no current plans to collect performance information on the aircraft it 

manages. Agencies have also engaged in limited collaboration with each 

other and with other stakeholders in the fire aviation communityincluding the private aircraft vendors on whom the Forest Service has 

traditionally relied to provide large airtankers. Incorporating input from all 

fire aviation community stakeholders in their strategic planning 

documents could better position the Forest Service and Interior in 

developing estimates of aircraft needs to include in their strategies that 

69CAL FIRE operates and mamtains 23 Grumman S-2T Tracker airtankers {former naval 

anti-submarine aircraft with retardant capacities of 1,200 gallons each), 16 North 

American-Rockwell OV-10 Bronco surveillance aircraft, and 11 Bell UH-1H Super Huey 

helicopters 

7

D-rhe 2012 Waldo Canyon and High Park fires cumulatively bumed a total of 105,531 

acres, cost nearly $56 million to suppress, and destroyed at least 605 homes 

71 C.R.S.A. §§ 24-33.5-1203(u); 24-33.5-1228. 

72N.R.S. §§ 81-825 to 81-828 

Page 36 GA0-13-684 Wildland Fire Management 
184 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

represent the national need for firefighting aircraft. This concern is 

illustrated by the variety of federal and state agencies taking steps to 

compensate for the decline in large airtankers, which highlights the 

number of parties affected by firefighting aircraft decisions and reinforces 

the need for collaboration. Overall, better knowledge about aircraft 

effectiveness-and more complete input from all involved parties-could 

inform Forest Service and Interior decisions and help them ensure the 

adequacy of the nation's firefighting aircraft fleet. The challenges faced by 

the Forest Service in each phase of its large airtanker approach, which 

includes the potential acquisition of aircraft the federal government would 

own and operate for decades, underscore the need for a complete and 

collective understanding of the nation's firefighting aircraft needs. 

To help the agencies enhance their abilities to identify their firefighting 

aircraft needs and better ensure they obtain aircraft that meet those 

needs, we recommend that the Secretaries of Agriculture and the Interior 

direct the Chief of the Forest Service and the Deputy Assistant Secretary 

for Public Safety, Resource Protection, and Emergency Services, 

respectively, to take the following three actions: 

Expand efforts to collect information on aircraft performance and 

effectiveness to include all types of firefighting aircraft in the federal 

fleet; 

Enhance collaboration between the agencies and with stakeholders in 

the fire aviation community to help ensure that agency efforts to 

identify the number and type of firefighting aircraft they need reflect 

the input of all stakeholders in the fire aviation community; and 

Subsequent to the completion of the first two recommendations, 

update the agencies' strategy documents for providing a national 

firefighting aircraft fleet to include analysis based on information on 

aircraft performance and effectiveness and to reflect input from 

stakeholders throughout the fire aviation community. 

We provided the Departments of Agriculture, Defense, and the Interior 

with a draft of this report for their review and comment. 

The Forest Service (responding on behalf of the Department of 

Agriculture) and Interior generally agreed with our findings and 

recommendations, and their written comments are reproduced in 

appendixes IV and V respectively. The Forest Service and Interior also 

provided technical comments which we incorporated as appropriate. The 

Department of Defense did not provide comments. 

Page 37 GA0~13~684 Wildland Fire Management 
185 

While the Forest Service generally agreed with our findings and 

recommendations and stated that it is committed to improving its 

collaboration efforts, it also reiterated its interest in obtaining C-27 Js to 

augment its aerial firefighting capabilities, citing the benefit of low initial 

investment for aircraft that could potentially function in multiple roles. As 

stated in our report, we acknowledge the Forest Service's incentive to 

obtain the C-27 Js free of acquisition cost and their potential use in 

multiple roles. We also note, however, that the agency may face 

challenges regarding the retardant capacity and operating costs 

associated with the airtankers. 

We are sending copies of this report to the Secretaries of Agriculture, 

Defense, and the Interior; the Chief of the Forest Service; the Directors of 

the Bureau of Indian Affairs, Bureau of Land Management, Fish and 

Wildlife Service, and National Park Service; appropriate congressional 

committees; and other interested parties. In addition, 

the report is available at no charge on the GAO website at 

http://www.gao.gov. 

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 orfennella@gao.gov. Contact points for 

our Office of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix VI. 

Anne-Marie Fennell 

Director, Natural Resources and Environment 

Page 38 GA0~13.684 Wildland Fire Management 
186 

Appendix I: Objectives, Scope, and 

Methodology 

This report examines (1) Forest Service and Department of the Interior 

efforts undertaken to identify the number and type of firefighting aircraft 

they need and (2) the Forest Service's approach to modernizing the large 

airtanker fleet and the challenges it faces in doing so. 

To examine Forest Service and Interior efforts to identify their firefighting 

aircraft needs, we reviewed major agency studies and strategy 

documents and interviewed agency officials responsible for managing fire 

aviation programs. We focused on those efforts conducted since 1995, 

when the Forest Service and Interior jointly conducted the first major 

study of their large airtanker needs. We reviewed the purpose, 

methodology, and results of each of these studies and strategy 

documents. We also reviewed seven academic and government studies 

on aerial firefighting and conducted interviews with agency officials, as 

well as officials representing stakeholders in the fire aviation community, 

including military, state, and international firefighting organizations, and 

companies that own and operate firefighting aircraft, to identify key 

elements that are important for understanding firefighting aircraft needs. 1 

(Information on the stakeholders included in our review is discussed in 

more detail later in this appendix.) Through these document reviews and 

interviews, and in consultation with internal GAO stakeholders including 

methodological specialists and staff knowledgeable about aviation 

contracting, we identified the following key elements: aircraft types, 

basing options, acquisition models, aircraft capabilities, suppression 

methods, and aircraft performance and effectiveness. We then reviewed 

the agency efforts to determine the extent to which each effort included 

analysis of these key elements. 

We also interviewed agency officials about the extent of collaboration 

involved in agency efforts to identify the number and type of firefighting 

aircraft they need. In light of the information collected, we reviewed our 

prior work on interagency collaboration and key practices that can help 

enhance and sustain collaborative efforts, and compared the practices of 

the formal body for coordination among aerial firefighting agencies-the 

National Interagency Aviation Committee-with key collaboration 

practices to determine the extent to which the committee's practices were 

1

We considered the methodologies of the academic and government studies that we 

reviewed and determined that the results of the studies were sufficiently reliable for the 

purpose of identifying key elements that are important for understanding firefighting 

aircraft needs. 

Page 39 GAQ.1J.684 Wildland Fire Management 
187 

Appendix 1: Objectives, Scope, and 

Methodology 

consistent with key practices we previously identified. The key practices 

we evaluated were: defining and articulating a common outcome; 

establishing mutually reinforcing or joint strategies to achieve the 

outcome; identifying and addressing needs by leveraging resources; 

agreeing upon agency roles and responsibilities; establishing compatible 

policies, procedures, and other means to operate across agency 

boundaries; developing mechanisms to monitor, evaluate, and report the 

results of collaborative efforts; and reinforcing agency accountability for 

collaborative efforts through agency plans and reports. 2 GAO has also 

identified reinforcing individual accountability for collaborative efforts 

through agency performance management systems as a best practice for 

coordination, but we did not consider this practice in our assessment 

because performance management systems fell outside the scope of this 

review. 

To examine the Forest Service's approach to modernizing the large 

airtanker fleet and the challenges it faces in doing so, we reviewed 

agency documents related to large airtanker acquisition, management, 

and operations and interviewed agency officials to identify the agency's 

approach to obtaining these aircraft. We reviewed agency planning and 

acquisition documents, such as the National Interagency Aviation 

Committee's 2009 Interagency Aviation Strategy, the Forest Service's 

2012 Large Airtanker Modernization Strategy, and Forest Service 

airtanker contract solicitations, which lay out the Forest Service's 

approach to obtaining large airtankers in the short, medium, and long 

terms. 

To collect information in support of both objectives, we interviewed 

members of the fire aviation stakeholder community, including officials 

involved in the management and operations of aerial firefighting from the 

Forest Service, Interior and its four land management bureaus, the 

Department of Defense, six state agencies that we selected based on 

input from federal agencies and the National Association of State 

Foresters, and the British Columbia Forest Service; representatives from 

eight of the nine vendors we identified that own, operate, and maintain 

large airtankers and that have responded to the most recent Forest 

Service contract solicitations;' and two national trade organizations-one 

2GAO-D6-15. We identified these practices through reviewing relevant literature and 

interviewing experts in the area of collaboration 

3Representatives of the ninth vendor did not respond to our attempts to contact them 

Page 40 GA0.1J.684 Wildland Fire Management 
188 

Appendix 1: Objectives, Scope, and 

Methodology 

that represents firefighting aircraft vendors and one that represents 

pilots-which we identified based on conversations with agency officials 

and vendor representatives. We also conducted site visits to the National 

Interagency Fire Center in Boise, Idaho; the facilities of the only two 

private vendors with current Forest Service "legacy" large airtanker 

contracts, located in Minden, Nevada, and Missoula, Montana; the 

manufacturing facility of a company that produces single-engine 

airtankers in Olney, Texas; and the headquarters of California's fire 

aviation program -part of the California Department of Forestry and Fire 

Protection (CAL FIRE) in Sacramento-which manages more airtankers 

than the Forest Service. The results of our interviews and site visits are 

not generalizable. 

We conducted this performance audit from August 2012 to August 2013 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

Page 41 GA0.13.684 Wildland Fire Management 
189 

Appendix II: 2013 Forest Service and Interior 

Firefighting Aircraft Availability and Rates 

The Forest Service and Interior contract for, and to a lesser extent own, a 

variety of aircraft used to help suppress wildland fires. Table 2 provides 

information, as reported by Forest Service and Interior contracting 

officials, on the federal firefighting aircraft fleet for the 2013 fire season, 

including aircraft type, number available, and cost rates. 

Table 2: Type, Number, and Cost Rates for Federally~Contracted Firefighting Aircraft 

Aircraft type 

Very large airtankef''b,c 

Large airtankel"-c 15 

Single-engine a/rtankef·e 28 

Water scoope( 

Large helicopter 34 

Medium helicopte{ 33 

Small helicopter 78 

Forest Service 53 

lntenor 25 

SurveH!ance aircraft9 50 

Forest Service 28 

Interior 22 

Smokejumper aircraft 14 

Forest Service 12 

Interior 

Flight hour rate Flight hour rate 

$26,750 $4,553-$12,500 $51,522-$75,000 $7,668-$12,000 

$10,700-$34,000 $4,400-$9,996 

$1,700-$4,076 $1,500-$3,988 46 $2,225-$4,150 $2,305-$4,242 

$9,859 $6,363-$7,918 $11,549 $7,158-$8,637 

$9,256-$25,942 $1,958-$7,828 85 $13,320-$46,900 $2,967-$23,300 

$4,050-$11,600 $1,748-$1,998 101 $3,600-$19,815 $1,732-$2,445 

$950-$5,775 $330-$2,350 $1,000-$12,975 $325-$2,691 

$950-$3,136 $860-$1' 193 195 $2,044-$5,320 $836-$1,768 

$1,750-$5,775 $330-$2,350 345 $1,000-$12,975 $325-$2,691 

$569-$5,861 $225-$4,934 90 $485-$3,850 $309-$2,419 

$1,806-$2,254 $598 

$569-$5,861 $225-$4,934 90 $485-$3,850 $309-$2,419 

$3,315-$5,597 $950-$2,020 $4,600 $1,300 

$3,330-$5,597 $950-$2,020 

$3,315-$3,400 $973-$1,026 $4,600 $1,300 

Sources ForestServ•ceandlntenorcontracttngolilcmls 

aF!ight hour r21!es do not include the cost of aircraft fuel 

0

The DC-1 0 available on exclusive-use was awarded a contract under the "next generation" large 

21irtanker soliCitation and has a flight hour rate of $4,553 for delivering 5,000 gallons and $12,500 for 

delivering 11,600 ga!!ons of retardant 

cThe Forest Service contracts for these aircraft 

d!ncludes one exclusive-use and three call-when needed amphibious, water-scooping single-engine 

airtankers. 

e!nterior contracts for these aircraft. 

'We did not determine the total number of aJrcrafl: available because some vendors may have a single 

aircraft available on call-when-needed contracts with both the Forest Service and Interior 

Page42 GA0-13-684 Wildland Fire Management 
190 

Appendix II: 2013 Forest Service and Interior 

Firefighting Aircraft Availability and Rates 

9

This category includes exc!usive+use and call+when-needed lead planes as well as two Forest 

Service-owned Infrared mapping aircraft; the availability costs of the Infrared fire mapping aircraft are 

calculated on a monthly basis and range from $23,064 to $29,174. 

hThis category mc!udes !he seven smokejumper aircraft owned by the Forest Service; the availability 

costs of these aircraft are calculated on a monthly basis and range from $11,972 to $23,476 

Page43 GA0~13~684 Wildland Fire Management 
191 

Appendix III: Summary of Agency Efforts 

Since 1995 to Identify Number and Type of 

Firefighting Aircraft They Need 

Since 1995, the Forest Service and Interior have conducted or contracted 

for nine major studies and strategy documents that identify firefighting 

aircraft needs. Table 3 provides information on major efforts conducted 

by, or on behalf of, the Forest Service and Interior to identify the number 

and type of firefighting aircraft they need. 

Table 3: Purpose, Methodology, and Recommendations of Major Efforts to Identify Federal Firefighting Aircraft Needs, 

by Date 

Author(s) Purpose Methodology used 

type of aircraft 

recommended 

1995, National Study of Airtankers to Support Initial Attack and Large Fire Suppression: Final Report Phase 1 

Forest 

Service and 

Interior 

Provide analytical support and develop models 

to identify the most effective and efficient 

utilization of airtankers and to optimize the 

currently available airtanker fleet and find the 

best base locations 

Compared the cost of the 19951arge airtanker 

program---41 airtankers-with a series of 

alternatives, including no airtanker program, a 

smaller airtanker program, and moving 

airtankers to different base locations to 

determine the most efficient basing of large 

airtankers 

41 large 

airtankersa,b 

1996, National Study of (Large) Airtankers to Support Initial Attack and Large Fire Suppression: Final Report Phase 2 

Forest 

Service and 

Interior 

Provide information on reasonable airtanker 

base locations and airtanker fleet possibilities 

to guide modernization of the airtanker 

program 

Analyzed potential airtankertypes and base 41large 

locations using set of evaluation criteria- airtankers01 b 

compatibility with airtanker bases, initial attack 

efficiency, large fire support, accuracy and 

performance, availability, viable vendors, and 

reality/professional judgment check-to 

determine the number and size of atrtankers to 

station at each base 

1998, National Study of Tactical Aerial Resource Management to Support Initial Attack and Large Fire Suppression: 

Final Committee Report 

Forest 

Service and 

lntenor 

Fire Program 

Solutions, 

LLC 

Determine the appropriate organization, 

locations, and aerial platforms to safely and 

cost effectively manage and direct aerial ftre 

suppression resources 

For Initial attack, recommend most cost 

efficient large aircraft type and number by 

base and recommend performance attributes 

for alrtankers and large helicopters to support 

cost efficient national program; for large fire 

support, determine airtanker and helicopter 

requirements 

Page 44 

Compared available surveillance aircraft against 41 

a set of evaluation criteria, such as required survell!ance 

technology, minimum speed, and minimum aircraf( 

personnel capacity to determine the appropriate 

type of surveillance aircraft, and Identified the 

number of surveillance aircraft needed based 

on the airtankers 

and 1996 studies 

Analyzed the most efficient locations to place 

airtankers, by geographic area, and identified 

the scenario with the lowest total fire 

suppression, airtanker program, and potentia! 

fire damage costs: identified the most efficient 

combination of exclusive-use and call-whenneeded large helicopters based on demand and 

cost 

GA0~13~684 Wildland Fire Management 
192 

Author(s) Purpose 

Appendix Ill: Summary of Agency Efforts Since 

1995 to Identify Number and Type of 

Fireftghting Aircraft They Need 

Methodology used 

2008, Management Efficiency Assessment on Aviation Activities in the USDA Forest Service 

Management Identify areas within the Forest Service Compared the "as-is" conditions w1th desired 

Analysis, aviation activities that can be improved through "to-be" conditions for six Forest Service areasIncorporated efficiencies in staffing, organization, aerial delivery of firefighters; aerial detection 

communications. technology, and procedures and command and control; aerial fire 

suppression-airtanker and large helicopter; 

aerial resources support; aviation contract 

management and quality assurance: and 

aviation program management-and conducted 

a costlbenefit analysis to identify 

recommendations for Improving efficiency within 

each area 

2009, National Interagency Aviation Council Interagency Aviation Strategy 

Forest 

Service, 

Bureau of 

Indian Affairs, 

Bureau of 

Land 

Management, 

Interior, F1sh 

and Wildlife 

Service, 

National Park 

Service, and 

National 

Association of 

State 

Foresters 

Develop an aviation strategy for federal 

wildland fire agencies, Including strategies for 

the organization, procurement, and 

management of aviation resources used in 

federal wildland firefightlng 

Identified the number of each type of aircraft 

needed in the national fireflghting aircraft fleet 

by using numbers from preceding aviation 

program studies, simple demand analysis, and 

current program aircraft totals 

2012, Forest Service Large Airtanker Modernization Strategy 

Forest 

Service 

Document the strategy for ensuring that the 

nation is equipped with a viable fleet of large 

airtankers 

Analyzed options for large airtankers, based on 

the large airtanker requirements identified in the 

1996 National Study of (Large) Airtankers to 

Support Initial Attack and Large Fire 

Suppression, Phase 2 and the 2009 National 

Interagency Aviation Council Interagency 

Aviation Strategy 

2012, Air Attack Against Wildfires: Understanding U.S. Forest Service Requirements for Large Aircraft 

Rand Determined the composition of a fleet of large Analyzed various compositions of a fleet of 

Corporation airtankers, water scooping aircraft, and large large airtankers, water scooping aircraft, and 

helicopters that would minimize the total costs large helicopters to determine which 

of wildfires, including the cost of large fires and composition would minimize the total costs of 

the cost of aircraft wildfires, including federal, and local 

suppression costs; post-fire 

insured losses; fatalities; future 

and the cost of the 

Number and 

type of aircraft 

recommended 

32 large 

antankers 

3 water scoopers 

35 single-engine 

airtankers 

45 

surveillance 

aircraft 

19 smokejumper 

aircraft 

34 large 

helicopters 

47 medium 

helicopters 

100 smaH 

helicopters 

1-9 large 

airtankersct 

14-55 water 

scoopers 

0-7 large 

helicopters 

Page 45 GA0-13-684 Wildland Fire Management 
193 

Author{s) Purpose 

Appendix Ill: Summary of Agency Efforts Since 

1995 to Identify Number and Type of 

Firefighting Aircraft They Need 

Methodology used 

Number and 

type of aircraft 

recommended 

2013, Firefighting Aircraft Study 

Avid LLC Develop a performance measure that directly 

demonstrated cost-impact of large airtankers 

and heavy helicopters in firefighting 

Source GAO<on81YsJ5 

Used a supply and demand model to determme 

the annual number of airtanker orders that the 

Forest Service has been unable to fill with its 

contracted large airtankers 

35 large 

airtankers are 

needed to fill 90 

percent of 

requests for 

large airtankers" 

aThis total of 41 includes 30 airtankers contracted by the Forest Service, 6 airtankers contracted by 

Interior, and 5 airtankers contracted by states 

bThis study recommended the appropriate number of large airtankers and did not recommend an 

appropriate number of other types of firefighting aircraft. 

"This study recommended the appropriate number of aerial surveillance aircraft and did not 

recommend an appropriate number of other types offirefighting aircraft 

dThis study focused on the Forest Service's large airtankers, water scoopers, and large helicopters, 

and did not recommend an appropriate number for other types offirefighting aircraft 

eThis study focused on the Forest Service's large airtankers and large helicopters and did not 

recommend an appropriate number of large helicopters. 

Page 46 GA0-13-684 Wildland Fire Management 
194 

Appendix IV: Comments from the 

Department of Agriculture 

Ms. Anne~ Marie Fennell 

Director. Natural Resources and Environment 

U.S. Government Accountability Office 

441 G. Street, N.W. 

W ashingwn. OC 20548 

Dear Ms. Fennell: 

Wniliingtoo 

om~ 

1401llndepClldeoceA";,-t~ue,SW 

WashiugtoJI.DC 20250 

Fii<.>Code: 1420 

Da1e: AUG 06 2013 

Thank you for the opportunity to review and comment on the draft U.S. Government 

Accountability Office (GAO) Repon: on "Wildland Fire Management: lmpwvements Needed in 

Information, Collaboration. and Planning to Enhance Federal Flrc Aviation Program Success" 

(GAO~lJ-684). The Forest Sel>'ice has revlewcd the drafl report and generally agn.·es with its 

findings and recommendations, wi1h some com:erns as noted. Technical comments are attached. 

The Forest Service works with lts partners and stakeholders on all aspects of the fire 

management program. and aviation is no exception. To develop the 2012 Large Airtankcr 

Modetnizatiort Strategy (Strategy), we took intl.trmation gathered from the National Interagency 

Aviation Committee (NIAC) and workl~d with the Department of the Interior's Office of 

Wildland Fire to rallor the Strategy for both Departments' needs. The awarding of contracts for 

seven nex:t generation large airtankers is a significant step forward towards implementing the 

Strategy. We know we have more work to do on collaboration, and we plan to do so. The 

Strategy wilt be updawd to reflect this work, and will include the results of the information we 

are collecting on aircraftdfcctivcncss 

Althongh it was not identified in earlier documentation, such as the Strategy, the Forest Service 

believes that the C-27J can fill a niche in the aerial fircfighting systl!m. TI1e availahility of a 

medium-sized aircraft. for little invc~tmcnt, provides the Forest Service with grMt capability. 

Even thongh this medium airtanker requirement was nO{ prevwusly identified. it is a very 

opporrune capability that comes with the DOD divestiture of the C-271. and offers ex:tra surge 

capacity in addition to Modular Airborne Firelighting System (MAFFS). The C-27J will allow 

the Fore'l.l Service to augment the large airtanker l:lcet with a capable medmm ainankel' as we!! as 

modernize the smokejnmpcr fleet and perform team and cargo tran~port. upe<~'"''"'P'""' m 

developed as part oftJJe process of transitioning n~w aircraft into the agency. 

case wHh the C-27J. and is expected to be very \imilar to the operational plan now in use by the 

comparable size P-2V airtanker ( 1.800 gal vs. 2.000 gal). 

('aringforthcLandandScrvingPcop!c 

Page 47 GA0-13-684 Wildland Fire Management 
195 

Appendix IV: Comments from the Department 

of Agriculture 

Ms. Anne-Marie Fennel!, Director of Natural Resource Environment, U.S. Government 

Accountability Office 

~~ ;;7 7 Jl__.t£ THOMAS L TIDWELL 

Chief 

Page 48 GA0~13-684 Wildland Fire Management 
196 

Appendix V: Comments from the 

Department of the Interior 

United States Department of the Interior 

lVfs. Annc-~1aric Fennell 

OFFlCE OF TilE SECRETARY 

Wa~hlng1qn,OC.20240 

AUG {I ZUi3 

Director, :-.iatuml Resources and 'Environment 

t.'.S. Government Accountahility Office 

441 G Street. :'-LW. 

Washlllgton. D.C. 20548 

Dear Ms. Fennell: 

will identify appropriate corrective twt1ons. 

s!WtRheaSuh 

Assi:,tant Secretilrv 

Policy, :'vfanagem~nt and Budget 

E11closure 

Page49 GA0-13-684 Wildland Fire Management 
197 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(361438) 

Anne-Marie Fennell, (202) 512-3841 or lennella@gao.gov 

In addition to the individual named above, Steve Gaty, Assistant Director; 

Kristin Hughes; Richard P. Johnson; and Matthew Tabbert made 

significant contributions to this report. Cheryl Arvidson, Steven Putansu, 

and Kiki Theodoropoulos provided technical assistance. 

Page 50 GA0~13.684 Wildland Fire Management 
198 

GAO's Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Phone 

Connect with GAO 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the perfonmance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding decisions. 

GAO's commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO's website (http:l/www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select "E-mail Updates." 

The price of each GAO publication reflects GAO's actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO's website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information. 

Connect with GAO on Facebook, Flickr, Twitter, and You Tube. 

Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts. 

Visit GAO on the web at www.gao.gov. 

Contact: 

Website: http:l/www.gao.gov/fraudnetlfraudnet.htm 

E-mail: fraudnet@gao.gov 

Automated answering system: (800) 424-5454 or (202) 512-7470 

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, Washington, DC 20548 

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548 

Please Print on Recycled Paper. 
199 

September 2015 

GA0-15-772 

United States Government Accountability Office 

Report to Congressional Requesters 

WILDLAND FIRE 

MANAGEMENT 

Agencies Have Made 

Several Key Changes 

but Could Benefit from 

More Information 

about Effectiveness 
200 

WILDLAND FIRE MANAGEMENT 

Agencies Have Made Several Key Changes but Could 

Benefit from More Information about Effectiveness 

What GAO Found 

Since 2009, the five federal agencies responsible for wildland fire managementthe Forest Service within the Department of Agriculture and the Bureau of Indian 

Affairs, Bureau of Land Management, Fish and Wildlife Service, and National 

Park Service in the Department of the Interior-have made several key changes 

in their approach to wildland fire management One key change was the 

issuance of agency guidance in 2009 that provided managers with more flexibility 

in responding to wildland fires. This change allowed managers to consider 

different options for response given land management objectives and the risk 

posed by the fire. The agencies also worked with nonfederal partners to develop 

a strategy aimed at coordinating wildland fire management activities around 

common goals. The extent to which the agencies' steps have resulted in on-theground changes varied across agencies and regions, however, and officials 

identified factors, such as proximity to populated areas, that may limit their 

implementation of some changes. 

The agencies assess the effectiveness of their wildland fire management 

programs in several ways, including through performance measures and reviews 

of specific wildland fires. The agencies are developing new performance 

measures, in part to help better assess the results of their current emphasis on 

risk-based management, according to agency officials. However, the agencies 

have not consistently followed agency policy regarding fire reviews, which calls 

for reviews of all fires resulting in federal suppression expenditures of $10 million 

or more, nor have they used specific criteria for the reviews they have conducted. 

GAO has previously found that it is important for agencies to collect performance 

information to inform key management decisions and to identify problems and 

take corrective actions. Forest Service and Interior officials said focusing only on 

suppression costs does not a !low them to identify the most useful fires for review, 

and they told GAO they are working to improve their crrteria for selecting fires to 

review and conducting these reviews. Forest Service officials did not indicate a 

time frame for their efforts, and while they provided a draft update of their policy 

manual, it did not contain specific criteria. Interior officials told GAO they expect 

to develop criteria by the end of2015, but did not provide information about how 

they planned to develop such criteria or the factors they would consider. By 

developing specific criteria for selecting fires to review and conducting reviews, 

and making commensurate changes to agency policies, the agencies may 

enhance their ability to help ensure that their fire reviews provide useful 

information about the effectiveness of their wildland fire activities. 

The Forest Service and Interior determine the distribution of fire management 

resources for three primary wildland fire activities of suppression, preparedness, 

and fuel reduction in part on the basis of historical funding amounts. For 

suppression, the Forest Service and Interior manage suppression funding as 

needed for responding to wildland fires, estimating required resources using the 

average of the previous 10 years of suppression obligations. For preparedness 

and fuel reduction, the Forest Service and Interior distribute resources based 

primarily on historical amounts. Both are working to distribute resources in ways 

that better reflect current conditions, including developing new systems that they 

stated they plan to begin using in fiscal year 2016. 

-------------United States Government Accountability Office 
201 

Contents 

Letter 

Appendix I 

Appendix II 

Appendix Ill 

Appendix IV 

Appendix V 

Appendix VI 

Related GAO Products 

Background 5 

Agencies Have Made Several Key Changes in Their Approach to 

Wildland Fire Management Since 2009 16 

Agencies Assess Effectiveness of Their Programs in Several 

Ways, but Have Not Consistently Conducted Reviews That 

Could Improve Responses to Wildland Fires 27 

Agencies Distribute Resources in Part on the Basis of Historical 

Amounts, but Are Developing New Methods Intended to Better 

Reflect Current Conditions 34 

Conclusions 43 

Recommendations for Executive Action 44 

Agency Comments and Our Evaluation 44 

Objectives, Scope, and Methodology 46 

Forest Service and Interior Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 2004 through 2014 50 

Differences in Forest Service and Department of the Interior Salary 

Payments Using Preparedness and Suppression Funding 

Comments from the Department of Agriculture 

Comments from the Department of the Interior 

GAO Contact and Staff Acknowledgments 

63 

64 

65 

68 

69 

Page i GA0~15~772 Wildland Fire Management 
202 

Tables 

Figures 

Table 1: Forest Service Wildland Fire Obligations for 

Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 53 

Table 2: Bureau of Indian Affairs Wildland Fire Obligations for 

Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 55 

Table 3: Bureau of Land Management Wildland Fire Obligations 

for Preparedness, Fuel Reduction, and Suppression, 

Fiscal Years 2004 through 2014 57 

Table 4: Fish and Wildlife Service Wildland Fire Obligations for 

Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 59 

Table 5: National Park Service Wildland Fire Obligations for 

Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 61 

Figure 1: Wildfire Hazard Potential for the Contiguous 48 States, 

2014 7 

Figure 2: Lands Managed by the Five Federal Land Management 

Agencies Responsible for Wildland Fire Management 9 

Figure 3: Obligations for Suppression, Fuel Reduction, and 

Preparedness, Forest Service and Department of the 

Interior, Fiscal Years 2004 through 2014 13 

Figure 4: Forest Service and Interior Agency Wildland Fire 

Preparedness Obligations, Fiscal Years 2004 through 

2014 50 

Figure 5: Forest Service and Interior Agency Fuel Reduction 

Obligations, Fiscal Years 2004 through 2014 51 

Figure 6: Forest Service and Interior Agency Wildland Fire 

Suppression Obligations, Fiscal Years 2004 through 

2014 52 

Figure 7: Forest Service Wildland Fire Obligations for 

Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 54 

Figure 8: Bureau of Indian Affairs Wildland Fire Obligations for 

Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 56 

Page ii GA0.15~772 Wildland Fire Management 
203 

Figure 9: Bureau of Land Management Wildland Fire Obligations 

for Preparedness, Fuel Reduction, and Suppression, 

Fiscal Years 2004 through 2014 58 

Figure 10: Fish and Wildlife Service Wildland Fire Obligations for 

Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 60 

Figure 11: National Park Service Wildland Fire Obligations for 

Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 62 

Abbreviations 

BIA 

BLM 

FLAME 

FWS 

HFPAS 

NFMAS 

NPS 

WFDSS 

WUI 

Bureau of Indian Affairs 

Bureau of Land Management 

Federal Land Assistance, Management, and Enhancement 

Act of 2009 

Fish and Wildlife Service 

Hazardous Fuels Prioritization and Allocation System 

National Fire Management Analysis System 

National Park Service 

Wildland Fire Decision Support System 

wildland-urban interface 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The pub!lshed product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted Images or other material, permission from the copyright holder may be 

necessary 1f you wish to reproduce this material separately 

Page iii GA0.15-772 Wildland Fire Management 
204 

U.S. GOVERNMENT ACCOUNTABILITY OFFICE 

September 16, 2015 

The Honorable Raul Grijalva 

Ranking Member 

Committee on Natural Resources 

House of Representatives 

The Honorable Alan Lowenthal 

Ranking Member 

Subcommittee on Energy and Mineral Resources 

Committee on Natural Resources 

House of Representatives 

The Honorable Peter DeFazio 

House of Representatives 

Wildland fire plays an important ecological role in maintaining healthy 

ecosystems, with many ecosystems being adapted to or dependent upon 

fire. However, over the past century, various land management practices, 

including fire suppression, have disrupted the normal frequency of fires in 

many forest and rangeland ecosystems across the United States, 

resulting in abnormally dense accumulations of vegetation. According to 

scientific reports, this altered landscape, combined with drought and other 

climate stressors, has contributed to larger and more severe wildland 

fires, and many scientists and researchers expect fires to become even 

larger and more severe in the future. 1 In addition, continued development 

occurring in and around wildlands, an area often called the wildland-urban 

interface (WUI), has placed more people, businesses, and other valuable 

infrastructure at risk from wildland fire. Wildland fires cost billions of 

dollars every year and have resulted in loss of life, both of residents as 

well as firefighters, and damage to homes and infrastructure. Wildland 

for example, National Research Council, Climate Change. Evidence, Impacts, and 

Answers to Common Questions about the Science of Climate Change 

(Washington, D.C .. 2012) and U.S. Climate Change Science Program, The Effects of 

Climate Cf1ange on Agn'culture, Land Resources, Water Resources, and Biodiversity in 

the United States (Washington, D.C .. May 2008). The National Resource Council report 

notes that the risk of wildland fire is expected to mcrease in many regions, such as the 

evergreen forests of the western United States, and may decrease in other areas, such as 

those dominated by shrubs and grasses 

Page 1 GA0~15.772 Wildland Fire Management 
205 

fires have also destroyed or damaged important cultural resources and 

critical natural resources, such as watersheds that provide drinking water 

to communities. 

Five federal agencies-the Forest Service within the Department of 

Agriculture and the Bureau of Indian Affairs (BIA), Bureau of Land 

Management (BLM), Fish and Wildlife Service (FWS), and National Park 

Service (NPS) within the Department of the Interior-are responsible for 

managing wildland fires on federal lands. State forestry agencies and 

other entities-including tribal, county, city, and rural fire departmentshave primary responsibility for managing wildland fires on nonfederal 

lands and share responsibility for protecting homes and other private 

structures. 

As noted in the 2014 Quadrennial Fire Review, an interagency report 

prepared for the federal wildland fire agencies, balancing the need to 

suppress unwanted wildland fires to protect people and resources with 

the need to recognize fire's natural role on the landscape is a complex 

task. 2 In recent decades, increased wildland fire intensity has placed 

greater demands on federal wildland fire management programs and 

prompted new policies and efforts aimed at implementing more effective 

management strategies to manage wildland fire. These efforts take on 

greater importance in light of constrained budgets and the amount spent 

by federal agencies on wildland fire management; in fiscal years 2009 

through 2014, for example, federal agencies reported obligating a total of 

$8.3 billion to suppress wildland fires. According to several agency 

reports, given the current condition of the nation's landscapes and the 

future outlook for wildland fires, increasing demands on federal wildland 

fire management programs are likely to persist. 3 

2

Booz Allen Hamilton, 2014 Quadrennial Fire Review (Washington, D.C .. May 2015). The 

Quadrennial Fire Review, prepared on behalf of the Forest Service and Interior, is a 

strategic assessment process conducted by the fire management agencies every 4 years 

to evaluate current wildland fire management strategies and capabilities against estimates 

of the future fire environment The first such review occurred in 2005 and the second in 

2009 

3

See, for example, Department of Agriculture and Department of the Interior, The National 

Strategy: The Final Phase in the Development of the National Cohesive Wildland Fire 

Management Strategy 0fVashington, D.C .. Apri! 2014), and Booz Allen Hamilton, 2014 

Quadrennial Fire Review(Washington, D.C.: May 2015) 

Page 2 GAQ.15.772 Wildland Fire Management 
206 

The five agencies' wildland fire management efforts have undergone 

multiple reviews, including by us and the Offices of Inspector General for 

Agriculture and Interior, to assess whether federal wildland fire activities 

and policies are appropriate and are being carried out in a cost-effective 

manner. We last conducted a comprehensive review of federal wildland 

fire management in 20094 The resulting report provided an overview of 

the agencies' efforts to address wildland fire issues, including the 

progress the agencies had made in managing wildland fire. 

You asked us to review multiple aspects of federal wildland fire 

management across the five federal land management agencies 

responsible for wildland fire management. This report examines (1) key 

changes the federal wildland fire agencies have made in their approach to 

wildland fire management since 2009, (2) how the agencies assess the 

effectiveness of their wildland fire management programs, and (3) how 

the agencies determine the distribution of their wildland fire management 

resources. 

To perform this work, we reviewed laws, policies, and guidance related to 

federal wildland fire management. We also interviewed headquarters 

officials from each of the five federal land management agencies 

responsible for wildland fire management (the Forest Service, BIA, BLM, 

FWS, and NPS), as well as Interior's Office of Wildland Fire. 5 We also 

conducted interviews of officials from each of the 9 Forest Service 

regional offices and 11 of BLM's 12 state offices," as well as from 

selected BIA, FWS, and NPS regions. 7 We focused these regional 

Wildland Fire Management: Federal Agencies Have Taken Important Steps 

Forward, but Additional, Strategic Action Is Needed to Capitalize on Those Steps, 

GA0-09-877 (Washington, D.C.. Sept 9, 2009). For a hst of GAO reports on topics related 

to federal wildland fire management, see the related products section at the end of this 

report 

5

The Department of the Interior's Office of Wildland Fire organizes the activities of the four 

Interior agencies that manage and operate wildland fire programs. Specifically, it 

manages, oversees, and coordinates the department's wildland fire management 

programs, policies, budgets, information technology systems, and decision support toots 

6

We did not inteNiew officials from the BLM Eastern States Office because its wildland fire 

management program is minima! 

7

The Forest SeNice, BIA, FWS, and NPS have regional offices, while BLM has state 

offices. For the purposes of this report, we refer to a!! of these as regional offices when we 

discuss the agencies collectively 

Page 3 GAQ.15.772 Wildland Fire Management 
207 

interviews primarily on the Forest Service and BLM because those 

agencies receive the greatest percentage of federal wildland fire funding. 

For BIA, FWS, and NPS, we selected the two regions from each agency 

that received the most funds-BIA's Northwest and Western Regions, 

FWS's Southwest and Southeast Regions, and NPS's Pacific West and 

Intermountain Regions. During these interviews, we asked about changes 

to the agencies' approach to wildland fire management, agency efforts to 

assess the effectiveness of their wildland fire management activities, and 

agency processes for determining the distribution of fire management 

resources. 

To address our first objective, we reviewed agency documents, including 

policies, guidance, and reports such as the Quadrennial Fire Review, to 

identify changes the agencies have made to their approach to managing 

wildland fire since 2009, efforts the agencies have undertaken to address 

wildland fire management challenges, and any agency-identified 

improvements resulting from those changes. To further our understanding 

of these issues, we interviewed agency headquarters and regional 

officials about these changes. In particular, we asked about the extent to 

which changes to the agencies' wildland fire management approaches 

have occurred or are planned and how the regions implemented national 

direction and policy. We analyzed the responses provided to us during 

the interviews to identify prominent changes since 2009 and challenges 

associated with implementing them. 

To address our second objective, we reviewed documents, such as 

agency strategic plans and budget justifications, and interviewed officials 

to identify key performance measures and other mechanisms the 

agencies use to determine the effectiveness of their wildland fire 

management programs, as well as any changes they are making in this 

area. We also reviewed legislative and agency direction related to fire 

reviews, including agency policies and the Interagency Standards for Fire 

and Fire Aviation Operations, and we reviewed reports resulting from fire 

reviews conducted by the agencies since 2009. We compared agency 

practices for conducting fire reviews to direction contained in relevant 

agency policy. To obtain additional insight into the use of performance 

information on the part of federal agencies, we also reviewed our 

previous reports related to agencies' use of performance information. 

To address our third objective, we reviewed relevant agency budget 

documentation, including annual budget justifications, as well as 

information about the tools and systems the agencies use to distribute 

funds and resources, to identify the agencies' distribution processes. We 

Page 4 GA0~15~772 Wildland Fire Management 
208 

Background 

did not assess the design or the use of these tools or systems. We 

interviewed agency officials about their agencies' processes for budget 

formulation and resource distribution, including any differences among 

agencies or regional offices in how funds and resources are distributed, 

as well as the extent to which distribution decisions have changed in 

recent years at the headquarters and regional levels for each of the five 

agencies. We also obtained and analyzed Forest Service and Interior 

data on wildland fire management obligations for fiscal years 2004 

through 2014, analyzing the data in both nominal (actual) and constant 

(adjusted for inflation) terms. We reviewed budget documents and 

obligation data provided by the agencies and interviewed agency officials 

knowledgeable about the data, and we found the data to be sufficiently 

reliable for the purposes of this report. Unless otherwise noted, dollar 

figures provided in this report represent obligations reported to us by the 

agencies and are presented in nominal dollars, unadjusted for inflation• 

Appendix I describes our objectives, scope, and methodology in more 

detail. 

We conducted this performance audit from August 2014 to September 

2015 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Wildland fires are both natural and inevitable and play an important 

ecological role on the nation's landscapes. These fires have long shaped 

the composition of forests and grasslands, periodically reduced 

vegetation densities, and stimulated seedling regeneration and growth in 

some species. Wildland fires can be ignited by lightning or by humans 

either accidentally or intentionally. As we have described in previous 

reports, however, various land use and management practices over the 

past century-including fire suppression, grazing, and timber 

8An obligation is a definite commitment that creates a legal liability of the government for 

the payment of goods and services ordered or received, or a legal duty on the part ofthe 

United States. Payment may be made immediately or in the future. An agency incurs an 

obligation, for example, when it places an order, signs a contract, awards a grant, or 

purchases a service 

Page 5 GA0~15~772 Wildland Fire Management 
209 

harvesting-have reduced the normal frequency of fires in many forest 

and rangeland ecosystems. 9 These practices contributed to abnormally 

dense, continuous accumulations of vegetation, which in turn can fuel 

uncharacteristically severe wildland fires in certain ecosystems. 

According to scientific reports, several other factors have contributed to 

overall changes to ecosystems and the landscapes on which they 

depend, altering natural fire regimes and contributing to an increased 

frequency or intensity of wildland fire in some areas. For example, the 

introduction and spread of highly fiammable invasive nonnative grasses, 

such as cheatgrass, along with the expanded range of certain flammable 

native species, such as western juniper, in the Great Basin region of the 

western United States-including portions of California, Idaho, Nevada, 

Oregon, and Utah- have increased the frequency and intensity of fire in 

the sagebrush steppe ecosystem. 1° Changing climate conditions, 

including drier conditions in certain parts of the country, have increased 

the length and severity of wildfire seasons, according to many scientists 

and researchers. 11 For example, in the western United States, the 

average number of days in the fire season has increased from 

approximately 200 in 1980 to approximately 300 in 2013, according to the 

2014 Quadrennial Fire Review. 12 In Texas and Oklahoma this increase 

was even greater, with the average fire season increasing from fewer 

than 100 days to more than 300 during this time. According to the U.S. 

Global Change Research Program's 2014 National Climate Assessment, 

projected climate changes suggest that western forests in the United 

9

See, for example, GA0~09-877 and GAO, Wildland Fire Management: Lack of Clear 

Goals or a Strategy Hinders Federal Agencies' Efforts to Contain the Costs of Fighting 

Fires, GA0-07-655 (Washington, D.C .. June 1, 2007) 

10The sagebrush steppe ecosystem !s found in the western United States and western 

Canada. The sagebrush steppe name comes from the most dominant plant found in the 

ecosystem, the sagebrush, while steppe describes a largely treeless, dry, level grassland 

According to BLM, the majority of BLM-managed lands are in the sagebrush steppe 

ecosystem 

11 See, for example, National Research Council, Climate Change: Evidence, Impacts, and 

Choices_ Answers to Common Questions about the Science of Climate Change 

(Washington, D.C.. 2012) and U.S. Climate Change Science Program, The Effects of 

Climate Change on Agn·cu!ture, Land Resources, Water Resources, and Biodiversity in 

the United States (Washington, D.C.. May 2008). 

12Booz Allen Hamilton, 2014 Quadrennial Fire Review (Washington, D.C.. May 2015). The 

states included in this statistic were Alaska, Arizona, California, Colorado, Idaho, 

Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming 

Page 6 GA0~15~772 Wildland Fire Management 
210 

States will be increasingly affected by large and intense fires that occur 

more frequently. 13 Figure 1 shows the wildfire hazard potential across the 

country as of 2014. 

Figure 1: Wildfire Hazard Potential for the Contiguous 48 States, 2014 

Source· Forest SeMce l GAQ.15-772 

Note: According to the Forest Service, areas mapped with higher values of wildfire hazard potential 

represent fuels with a higher probability of extreme fire behavior under conducive weather conditions. 

The map does not represent a forecast or fire outlook for any particular season 

In addition, development in the wildland-urban interface (WUI) has 

continued to increase over the last several decades, increasing wildland 

fire's risk to life and property. According to the 2014 Quadrennial Fire 

Review, 60 percent of new homes built in the United States since 1990 

were built in the WUI, and the WUI includes 46 million single-family 

13U.S. Global Change Research Program, Climate Change Impacts in the United States: 

The Third National Climate Assessment (Washington, D.C.: May 2014) 

Page 7 GAQ.15.772 Wildland Fire Management 
211 

Primary Federal Land 

Management Agencies 

with Wildland Fire 

Management 

Responsibilities 

homes and an estimated population of more than 120 million. In addition 

to increased residential development, other types of infrastructure are 

located in the WUI, including power lines, campgrounds and other 

recreational facilities, communication towers, oil and gas wells, and 

roads. Some states, such as New Mexico and WYOming, have 

experienced significant increases in oil and gas development over the 

past decade, adding to the infrastructure agencies may need to protect. 

Under the National Forest Management Act and the Federal Land Policy 

and Management Act of 1976, respectively, the Forest Service and BLM 

manage their lands for multiple uses such as protection of fish and wildlife 

habitat, forage for livestock, recreation, timber harvesting, and energy 

production." FWS and NPS manage federal lands under legislation that 

primarily calls for conservation; management for activities such as 

harvesting timber for commercial use is generally precluded." BIA is 

responsible for the administration and management of lands held in trust 

by the United States for Indian tribes, individuals, and Alaska Natives. 

These five agencies manage about 700 million surface acres of land in 

the United States, including national forests and grasslands, national 

wildlife refuges, national parks, and Indian reservations. The Forest 

Service and BLM manage the majority of these lands. The Forest Service 

manages about 190 million acres; BLM manages about250 million acres; 

and BIA, FWS, and NPS manage 55, 89, and 80 million acres, 

respectively. Figure 2 shows the lands managed by each of these five 

agencies. 

acts require the agencies to develop land management plans that provide for 

multiple uses. A!! land management actions must conform to the approved plan governing 

the land management unit-such as a nat10nal forest-where the action is to take place 

15The National Wildlife Refuge System Improvement Act of 1997 directs FWS to 

administer a national network of lands and waters for the conservation, management, and, 

where appropriate, restoration of the fish, wildlife, and plant resources and their habitats 

within the United States for the benefit of present and future generations of Americans 

The National Park SefV!ce Organic Act of 1916 created the National Park Service to 

promote and regulate the use of national parks, monuments, and reservations with the 

purpose of conserving the scenery, natural and historic objects, and wildlife therein and to 

leave them "unimpaired" for the enjoyment of future generations. 

Page 8 GA0.15.772 Wildland Fire Management 
212 

Figure 2: Lands Managed by the Five Federal Land Management Agencies 

Responsible for Wildland Fire Management 

Sources. GAO analysis of U. S. Geological Survey's National Atlas web!lite data, Map Resources (map). ! GA0·15·772 

Severe wildland fires and the vegetation that fuels them may cross the 

administrative boundaries of the individual federal land management 

agencies or the boundaries between federal and nonfederallands. State 

forestry agencies and other entities-including tribal, county, city, and 

rural fire departments-share responsibility for protecting homes and 

other private structures and have primary responsibility for managing 

wildland fires on nonfederallands. Most of the increased development in 

Page 9 GAQ.15w772 Wildland Fire Management 
213 

Key Components of 

Wildland Fire 

Management 

the WUI occurs on nonfederallands, and approximately 70,000 

communities nationwide are considered to be at high risk from wildland 

fire. 16 Some of these communities have attempted to reduce risk of 

wildland fire through programs aimed at improving fire risk awareness 

and promoting steps to reduce their risk, such as the Firewise 

Communities program. 17 

Wildland fire management consists of three primary components: 

preparedness, suppression, and fuel reduction." 

Preparedness. To prepare for a wildland fire season, the five land 

management agencies acquire firefighting assets-including 

firefighters, fire engines, aircraft, and other equipment-and station 

them either at individual federal land management units or at 

centralized dispatch locations in advance of expected wildland fire 

activity. The primary purpose of acquiring these assets is to respond 

to fires before they become large-a response referred to as initial 

attack. The agencies fund the assets used for initial attack primarily 

from their wildland fire preparedness accounts. 

Suppression. When a fire starts, interagency policy calls for the 

agencies to consider land management objectives-identified in land 

and fire management plans developed by each land management 

unit-and the structures and resources at risk when determining 

whether or how to suppress the fire. A wide spectrum of strategies is 

available to choose from, and the land manager at the affected local 

16Booz Allen HamHton, 2014 Quadrennial Fire Review (Washington, D.C .. May 2015) 

17The Firewise Communities program is a nonregu!atory program administered by the 

National Fire Protection Association and sponsored by the Forest Service, lntenor, and 

state forestry organizations_ !tis designed to involve homeowners, community leaders, 

planners, developers, and others in efforts to protect people, property, and natural 

resources from the risk of wildland fire. Activities under the program include assisting 

individuals and residential communities with techniques to help protect homes and 

improve emergency preparedness in tile event of wildland fire. Communities til at take 

certain steps can become recognized as Firewise Communities sites. For more 

information on tile program, see GAO, Payments to Counties: More Clarity Could Help 

Ensure County Expenditures Are Consistent with Key Parts of the Secure Rural Schools 

Act, GA0-12-775 (Washington, D.C .. July 16, 2012) 

180ther fire program components include prevention; science, research, and 

development; site rehabilitation; and assistance to nonfederal entities. 

Page 10 GAQ.15.772 Wildland Fire Management 
214 

unit is responsible for determining which strategy to use-from 

conducting all-out suppression efforts to monitoring fires within 

predetermined areas in order to provide natural resource benefits. 

When a fire is reported, the agencies are to follow a principle of 

closest available resource, meaning that, regardless of jurisdiction, 

the closest available firefighting equipment and personnel respond. In 

instances when fires escape initial attack and grow large, the 

agencies respond using an interagency system that mobilizes 

additional firefighting assets from federal, state, and local agencies, 

as well as private contractors, regardless of which agency or agencies 

have jurisdiction over the burning lands. The agencies use an incident 

management system under which specialized teams are mobilized to 

respond to wildland fires, with the size and composition of the team 

determined by the complexity of the fire. Federal agencies typically 

fund the costs of these activities from their wildland fire suppression 

accounts. 

Fuel reduction. Fuel reduction refers to agencies' efforts to reduce 

potentially hazardous vegetation that can fuel fires, such as brush and 

"ladder fuels" (i.e., small trees and other vegetation that can carry fire 

vertically to taller vegetation such as large trees), in an effort to 

reduce the potential for severe wildland fires, lessen the damage 

caused by fires, limit the spread of flammable invasive species, and 

restore and maintain healthy ecosystems. 19 The agencies use 

multiple approaches for reducing this vegetation, including setting 

fires under controlled conditions (prescribed burns), mechanical 

thinning, herbicides, certain grazing methods, or combinations of 

these and other approaches. The agencies typically fund these 

activities from their fuel reduction accounts. 

Risk is an inherent element of wildland fire management. Federal 

agencies acknowledge this risk, and agency policies emphasize the 

importance of managing their programs accordingly. For example, Forest 

Service guidance states that "the wildland fire management environment 

is complex and possesses inherent hazards that can-even with 

reasonable mitigation-result in harm." According to a 2013 Forest 

Service report on decision making for wildfires, risk management is to be 

2015, Interior changed the name of its fuel reduction account to "fuel management" 

and now generally refers to this activity as fuel management rather than fuel reduction. 

However, for the purposes of this report, we refer to these activities and accounts 

collectively as fuel reduction 

Page 11 GA0.15.772 Wildland Fire Management 
215 

Funding for Federal 

Wildland Fire 

Management 

applied at all levels of wildfire decision making, from the individual 

firefighter on the ground facing changing environmental conditions to 

national leaders of the fire management agencies weighing limited 

budgets against increasingly active fire seasons. 20 For example, the 

report explains that, during individual wildland fires, risk can be defined as 

"a function of values, hazards, and probability." 21 

Congress, the Office of Management and Budget, federal agency 

officials, and others have raised questions about the growing cost of 

federal wildland fire management According to a 2015 report by Forest 

Service researchers, for example, the amount the Forest Service spends 

on wildland fire management has increased from 17 percent of the 

agency's total funds in 1995 to 51 percent of funds in 2014. 22 The report 

noted that this has come at the cost of other land management programs 

within the agency, such as vegetation and watershed management, some 

of which support activities intended to reduce future wildfire damage. 

From fiscal years 2004 through 2014, the Forest Service and Interior 

agencies obligated $14.9 billion for suppression, $13.4 billion for 

preparedness, and $5.7 billion for fuel reduction. Figure 3 shows the 

agencies' total obligations for these three components of wildland fire 

management for fiscal years 2004 through 2014. 

20Department of Agriculture, Forest Service, Rocky Mountain Research Station, Decision 

Making for \M!dfires: A Guide for Applying a Risk Management Process at the Incident 

Level, General Technical Report RMRS-GTR-298WV'vW (Ft. Collins, CO: June 2013) 

21 Values can include ecological, social, and economic values that could be lost or 

damaged due to fire, including people, property, infrastructure, natural and cultural 

resources, and air quality. Hazard is made up ofthe condition under which the fire burns, 

its abil1ty to spread, and the intensity and seventy it may present. For example, a fire that 

burns during extremely windy conditions may represent a greater hazard than a fire 

burning under less severe weather conditions Probability is the likelihood of a fire 

becoming an active event and adversely affecting values, such as the likelihood that a fire 

will reach a particular point within a specified time period. 

22David E. Calkin, Matthew P. Thompson, and Mark A. Finney, "Negative Consequences 

of Positive Feedbacks in U.S. Wildfire Management," Forest Ecosystems, val. 2, no. 9 

(2015) 

Page 12 GA0~15.772 Wildland Fire Management 
216 

Federal Wildland Fire 

Policy History 

Figure 3: Obligations for Suppression, Fuel Reduction, and Preparedness, Forest 

Service and Department of the Interior, Fiscal Years 2004 through 2014 Dollars in millions 

4,000 

3,500 

3,000 

2,500 

2,000 

1,500 

1,000 

500 

2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 20-14 

Fis~;alyear 

Suppression 

Fuel reduction 

Preparedness 

Sources GAO analysis of Forest Service ar.d lrrtenor d11ta. I GA0-15-772 

After receiving its annual appropriation, the Forest Service allocates 

preparedness and fuel reduction funds to its nine regional offices, and 

those offices in turn allocate funds to individual field units (national forests 

and grasslands). Interior's Office of Wildland Fire, upon receiving its 

annual appropriation, allocates preparedness and fuel reduction funds to 

BIA, BLM, FWS, and NPS. These agencies then allocate funds to their 

regional or state offices, which in turn allocate funds to individual field 

units (e.g. national parks or national wildlife refuges). The Forest Service 

and Interior agencies do not allocate suppression funding to their regions. 

These funds are managed at the national level. 

Federal wildland fire management policy has evolved over the past 

century in response to changing landscape conditions and greater 

recognition of fire's role in maintaining resilient and healthy ecosystems. 

According to wildland fire historians, in the late 1800s and early 1900s, 

the nation experienced a series of large and devastating fires that burned 

Page 13 GA0-15-772 Wildland Fire Management 
217 

millions of acres, including highly valued timber stands. In May 1908, 

federal legislation authorized the Forest Service to use any of its 

appropriations to fight fires. 23 During the following decades, the Forest 

Service and Interior agencies generally took the view that fires were 

damaging and should be suppressed quickly, with policies and practices 

evolving gradually. For example, in 1935, the Forest Service issued the 

"10 a.m. policy," which stated that whenever possible, every fire should 

be contained by 10 a.m. on the day after it was reported. In more remote 

areas, suppression policies had minimal effect until fire towers, lookout 

systems, and roads in the 1930s facilitated fire detection and fire 

deployment. 24 The use of aircraft to drop fire retardants-that is, 

chemicals designed to slow fire growth-began in the 1950s, according to 

agency documents. Subsequent to the introduction of the 10 a.m. policy, 

some changes to agency policies lessened the emphasis on suppressing 

all fires, as some federal land managers took note of the unintended 

consequences of suppression and took steps to address those effects. In 

1943, for example, the Chief of the Forest Service permitted national 

forests to use prescribed fire to reduce fuels on a case-by-case basis. In 

1968, NPS revised its fire policy, shifting its approach from suppressing 

all fires to managing fire by using prescribed burning and allowing fires 

started by lightning to burn in an effort to accomplish approved 

management objectives. 25 1n 1978, the Forest Service revised its policy to 

allow naturally ignited fires to burn in some cases, and formally 

abandoned the 10 a.m. policy. 

Two particularly significant fire events-the Yellowstone Fires of 1988, in 

which approximately 1.3 million acres burned, and the South Canyon Fire 

of 1994, in which 14 firefighters lost their lives-led the agencies to 

fundamentally reassess their approach to wildland fire management and 

develop the Federal Wildland Fire Management Policy of 1995. Under the 

1995 policy, the agencies continued to move away from their emphasis 

L_ No. 60-136, 35 Stat 259 (1908). This legislation also established that 25 percent 

of the revenue received from each national forest-through activities such as timber 

sales-must be paid to the relevant state for use on roads and schools in the counties 

where the national forest is located. 35 Stat 260. 

24Department of Agriculture, Forest Service, Pacific Northwest Research Station, 

Ecological Foundations for Fire Management in North American Forest and Shrub/and 

Ecosystems, PNW-GTR-779 (March 2009). 

25Administrative Policies for Natural Areas ofthe National Park System. 

Page 14 GA0-15-n2 Wildland Fire Management 
218 

on suppressing every wildland fire, seeking instead to (1) make 

communities and resources less susceptible to being damaged by 

wildland fire and (2) respond to fires so as to protect communities and 

important resources at risk while considering both the cost and long-term 

effects of that response. The policy was reaffirmed and updated in 2001, 

and guidance for its implementation was issued in 2003 and 2009. 

In 2000, after one of the worst wildland fire seasons in 50 years, the 

President asked the Secretaries of Agriculture and the Interior to submit a 

report on managing the impact of wildland fires on communities and the 

environment. The report, along with congressional approval of increased 

appropriations for wildland fire management for fiscal year 2001, as well 

as other related activities, formed the basis of what is known as the 

National Fire Plan. The National Fire Plan emphasized the importance of 

reducing the buildup of hazardous vegetation that fuels severe fires, 

stating that unless hazardous fuels are reduced, the number of severe 

wildland fires and the costs associated with suppressing them would 

continue to increase. In 2003, Congress passed the Healthy Forests 

Restoration Act, with the stated purpose of, among other things, reducing 

wildland fire risk to communities, municipal water supplies, and other atrisk federal land through a collaborative process of planning, setting 

priorities for, and implementing fuel reduction projects. 

Along with the development of policies governing their responses to fire, 

the agencies developed a basic operational framework within which they 

manage wildland fire incidents. For example, to respond to wildland fires 

affecting both federal and nonfederal jurisdictions, firefighting entities in 

the United States have, since the 1970s, used an interagency incident 

management system. This system provides an organizational structure 

that expands to meet a fire's complexity and demands, and allows entities 

to share firefighting personnel, aircraft, and equipment. Incident 

commanders who manage the response to each wildland fire may order 

firefighting assets through a three-tiered system of local, regional, and 

national dispatch centers. Federal, tribal, state, and local entities and 

private contractors supply the firefighting personnel, aircraft, equipment, 

and supplies which are dispatched through these centers. The agencies 

continue to use this framework as part of their approach to wildland fire 

management. 

Page 15 GA0~15~772 Wildland Fire Management 
219 

Agencies Have Made 

Several Key Changes 

in Their Approach to 

Wildland Fire 

Management Since 

2009 

Agencies Issued Guidance 

That Provided Greater 

Flexibility in Responding to 

Wildland Fire 

Since 2009, the five federal agencies have made several changes in their 

approach to wildland fire management. The agencies have issued fire 

management guidance which, among other things, gave their managers 

greater flexibility in responding to wildland fires by providing for responses 

other than full suppression of fires. In collaboration with nonfederal 

partners such as tribal and state governments, they have also developed 

a strategy aimed at coordinating federal and nonfederal wildland fire 

management activities around common goals, such as managing 

landscapes for resilience to fire-related disturbances. In addition, Interior, 

and BLM in particular, have placed a greater emphasis on wildland fire 

management efforts in the sagebrush steppe ecosystem by issuing 

guidance and developing strategies aimed at improving the condition of 

this landscape. The agencies have also taken steps to change other 

aspects of wildland fire management, including changes related to 

improving fire management technology, line officer training, and firefighter 

safety. Agency officials told us the agencies are moving toward a more 

risk-based approach to wildland fire management The extent to which 

the agencies' actions have resulted in on-the-ground changes varied 

across agencies and regions, however, and officials identified factors, 

such as proximity to populated areas, that may limit their implementation 

of some of these actions. 

The agencies have increased their emphasis on using wildland fire to 

provide natural resource benefits rather than seeking to suppress all fires, 

in particular through issuing the 2009 Guidance for Implementation of 

Federal Wildland Fire Management Policy Compared with interagency 

guidance issued in 2003, the 2009 guidance provided greater flexibility to 

managers in responding to wildland fire to achieve natural resource 

benefits for forests and grasslands, such as reducing vegetation densities 

and stimulating regeneration and growth in some species. The 2003 

guidance stated that only one "management objective" could be applied 

to a single wildland fire-meaning that wildland fires could either be 

managed to meet suppression objectives or managed for continued 

burning to provide natural resource benefits, but not both. The 2003 

guidance also restricted a manager's ability to switch between full 

suppression and management for natural resource benefits, even when 

fire conditions changed. In contrast, under the 2009 interagency 

guidance, managers may manage individual fires for multiple objectives, 

and may change the management objectives on a fire as it spreads 

across the landscape. For example, managers may simultaneously 

attempt to suppress part of a fire that is threatening infrastructure or 

valuable resources while allowing other parts of the same fire to burn to 

Page 16 GA0~15-772 Wildland Fire Management 
220 

achieve desired natural resource benefits. 26 According to agency 

documents, the 2009 guidance was intended to reduce barriers to riskinformed decision making, allowing the response to be more 

commensurate with the risk posed by the fire, the resources to be 

protected, and the agencies' land management objectives. 

However, agency officials varied in their opinions about the extent to 

which this guidance changed their management practices, with some 

telling us it marked a departure from their past practices, and others 

telling us it did not significantly change the way they managed wildland 

fire. Several headquarters and regional agency officials told us the 

guidance improved managers' ability to address natural resource needs 

when managing a fire, rather than simply suppressing all fires. For 

example, BIA officials told us that the flexibility provided through the 

guidance allowed managers on the San Carlos Apache Reservation in 

southeastern Arizona to use a variety of management strategies to 

manage the 2014 Skunk Fire. According to a BIA fire ecologist, managers 

were able to maximize firefighter safety while fostering desirable 

ecological benefits, including helping to restore the historical fire regime 

to the area. 27 In addition, Forest Service officials from several regions, 

including the Rocky Mountain and Intermountain Regions, told us they 

have used the full range of management options in the guidance more 

frequently over the last 5 years, and they credited the 2009 guidance for 

giving them the ability to manage fires and their associated risks. For 

example, during the 2011 Duckett Fire on the Pike-San Isabel National 

Forests in Colorado, managers attempted to contain part of the fire to 

protect a subdivision while allowing the portion of the fire uphill from the 

subdivision to burn into wilderness. Officials told us that, prior to the 2009 

guidance, they would likely have responded to this fire by attempting full 

guidance states that the use of fire will be based on land or resource management 

plans and associated fire management plans prepared by individual units such as national 

parks. Land or resource management plans identify, among other things, fire's role in a 

particular area, and the objectives in the plans provide the bas1s for development of fire 

management objectives in designated areas_ These fire-related objectives are contained 

in the units' fire management plans, which are intended to identify and integrate all 

wildland fire management and related activities within the context of approved land or 

resource management plans and assure that wildland fire management goals and 

components are coordinated. 

27 A fire regime describes the role fire plays in an ecosystem, including typical fire 

frequency, scale, intensity, and duration 

Page 17 GA0.15.772 Wildland Fire Management 
221 

suppression, which could have put firefighters at risk at the upper part of 

the fire because of the steep and rugged terrain. 

In contrast, other officials told us the effect of the guidance was minimal 

because certain factors-including proximity to populated areas, size of 

the land management unit, and concerns about resources necessary to 

monitor fires-limit their ability to manage wildland fire incidents for 

anything other than suppression. For example, Forest Service officials 

from the Eastern Region told us that they try to use fire to provide natural 

resource benefits where possible, but they have fewer opportunities for 

doing so because of the smaller size of Forest Service land units in this 

region, which makes it more likely the fires will cross into nonfederal land, 

and their proximity to many areas of WUI. Similarly, Forest Service 

officials from the Pacific Southwest Region told us they are limited in 

using the added flexibility provided through the 2009 interagency 

guidance in Southern California, in part because the forests there are so 

close to major cities. However, in other more remote areas of California, 

these officials said they have managed wildland fires concurrently for one 

or more objectives, and objectives can change as the fire spreads across 

the landscape. Officials from BLM's Utah State Office also told us that 

their changed landscape is a limiting factor in responding to wildland fire. 

Specifically, cheatgrass, a nonnative, highly flammable grass, has 

replaced much of the native vegetation of the sagebrush steppe 

ecosystem that used to exist on the lands they manage in western Utah. 

As a result, introducing fire into this area could be detrimental rather than 

helpful because cheatgrass's flammability makes fires difficult to control. 

Several officials also told us that managing wildland fires for objectives 

beyond full suppression, as provided for in the 2009 guidance, is highly 

dependent on circumstance. Officials told us that allowing fires to burn 

requires the agencies to devote assets to monitoring the fires to prevent 

them from escaping, which-especially for long-duration fires-can 

reduce the assets available to respond to other fires that may occur. For 

example, in 2012, in response to what it predicted to be an expensive and 

above-normal fire season, the Forest Service issued guidance to its 

regions limiting the use of any strategy other than full suppression (i.e., 

any strategy that involved allowing fires to burn for natural resource 

benefits) for the remainder of that year. The Forest Service noted that it 

was issuing this guidance because of concerns about committing the 

assets necessary to monitor long-duration fires that were allowed to burn 

in order to provide natural resource benefits. In 2015, during the Thunder 

Creek fire in North Cascades National Park, concerns about the 

resources needed to monitor the fire if it were allowed to burn to provide 

Page 18 GA0~15.772 Wildland Fire Management 
222 

Agencies Made Changes 

Intended to Formalize 

Collaboration with 

Nonfederal Partners 

natural resource benefits led NPS managers instead to order full 

suppression efforts to help ensure that the resources would be available 

for other fires. In a press release about the fire, NPS noted that experts 

anticipated a very high potential for wildfire in 2015, leading to agency 

concerns that significant fire activity throughout the west could leave few 

available firefighting resources later in the season. 

Another change since 2009 was the completion in 2014 of the National 

Cohesive Wildland Fire Management Strategy (Cohesive Strategy), 

developed in collaboration with partners from multiple jurisdictions (Le., 

tribal, state, and local governments, nongovernmental partners, and 

public stakeholders) and aimed at coordinating wildland fire management 

activities around common wildland fire management goals. 28 The 

agencies have a long history of collaboration with nonfederal partners in 

various aspects of wildland fire management, including mobilizing 

firefighting resources during wildland fire incidents and conducting fuel 

reduction projects across jurisdictions 29 The Cohesive Strategy is 

intended to set broad, strategic, nationwide direction for such 

collaboration. 

Specifically, the Cohesive Strategy provides a nationwide framework 

designed to more fully integrate fire management efforts across 

jurisdictions, manage risks, and protect firefighters, property, and 

landscapes by setting "broad, strategic, and national-level direction as a 

foundation for implementing actions and activities across the nation."30 

The vision of the Cohesive Strategy is "to safely and effectively extinguish 

fire, when needed; use fire where allowable; manage our natural 

Federal Land Assistance, Management, and Enhancement (FLAME) Act of2009 

required the Forest Service and Interior to complete and submit to Congress a report that 

contains a "cohesive wildfire management strategy." Pub L. No. 111-88 § 503, 123 Stat 

2971 (2009) 

29The Federal Wildland Fire Management Policy of 1995, updated in 2001, urged 

coordination, consistency, and agreement not only among the five federal land 

management agencies but also between these agencies and other federal agencies as 

well as tribal, state, and private stakeholders 

30As part of the development of the Cohesive Strategy, each of three regions of the 

country-Northeast, Southeast, and Western-identified regional goals, objectives, and 

challenges to be incorporated into the national strategy, and the regions created 

implementation plans to help attain the goals 

Page 19 GA0~15.772 Wildland Fire Management 
223 

resources; and as a nation, live with wildland fire." The Cohesive Strategy 

identified three goals: (1) landscapes across all jurisdictions are resilient 

to fire-related disturbances in accordance with management objectives; 

(2) human populations and infrastructure can withstand wildfire without 

loss of life or property; and (3) all jurisdictions participate in developing 

and implementing safe, effective, and efficient risk-based wildfire 

management decisions. According to a senior Forest Service official, the 

Wildland Fire Leadership Council is responsible for providing a national, 

intergovernmental platform for implementing the strategy. 31 In September 

2014, an interim National Cohesive Strategy Implementation Task Group 

completed an implementation framework that included potential roles, 

responsibilities, and membership for a "national strategic committee" that 

is intended to provide oversight and leadership on implementing the 

strategy. 

Agency officials differed in the extent to which they viewed the Cohesive 

Strategy as having a significant effect on their wildland fire management 

activities. On the one hand, several headquarters and regional agency 

officials told us the Cohesive Strategy has improved wildland fire 

management. For example, Forest Service officials from the Southern 

Region told us the Cohesive Strategy has reinforced existing work that 

better enabled them to collaborate on new projects, which they told us is 

important because nearly 85 percent of the land base in the region is 

privately owned, and little could be achieved without collaboration. Forest 

Service officials cited one instance in which they signed a regional level 

agreement that will cover several state chapters of The Nature 

Conservancy to exchange resources for fuel reduction treatment and to 

promote public understanding of its benefits-an action they said was 

supported by the Cohesive Strategy. 32 Similarly, Forest Service officials 

from the Intermountain Region told us about several efforts that have 

been implemented across their region that they attribute to the Cohesive 

31The Wildland Fire Leadership Council consists of senior officials from the Departments 

of Agriculture, Interior, and Homeland Security, including the Agriculture Undersecretary 

and Deputy Undersecretary for Natural Resources and Environment; the Interior Asststant 

Secretary for Policy, Management, and Budget; the Administrator of the U.S. Fire 

Administration; and the heads of the five federal firefighting agencies. Other members 

include representatives of the Intertribal Timber Council, the National Association of State 

Foresters, and the Western Governors' Association, along with a state forester and a local 

fire department chief. 

32According to its website, the Nature Conservancy is a nonprofit organization that works 

to protect ecologically important lands and waters. 

Page 20 GA0~15~772 Wildland Fire Management 
224 

Increased Emphasis by 

Interior on the Sagebrush 

Steppe Ecosystem 

Strategy. For example, in 2014, the Forest Service, the state of Utah, and 

other stakeholders collaborated on the implementation of Utah's 

Catastrophic Wildfire Reduction Strategy, which aims to identify where 

fuel treatment across the state would be most beneficial. In contrast, 

many officials told us they have collaborated with partners for years and 

did not find the additional direction provided through the Cohesive 

Strategy to be much different than how they already operated. For 

example, several regional BLM, FWS, and NPS officials told us they have 

long worked with nonfederal partners on issues related to wildland fire 

management and that the Cohesive Strategy did not change those 

relationships. 

However, implementation of collaborative actions stemming from the 

Cohesive Strategy may be limited by such factors as differences in laws 

and policies among federal, tribal, state, and local agencies. For example, 

while the 2009 federal interagency guidance provided federal managers 

with additional flexibility in managing a single fire for multiple purposes, 

laws and regulations at the state and local levels typically require full 

suppression of all fires, according to the 2014 Quadrennial Fire Review. 33 

For example, according to California state law, state forest officials in 

California are "charged with the duty of preventing and extinguishing 

forest fires." 34 

Since 2009, Interior and BLM have placed a greater emphasis on 

wildland fire management, restoration, and protection related to the 

sagebrush steppe ecosystem-particularly with respect to habitat for the 

greater sage-grouse. Several changes, including urbanization and 

increased infrastructure built in support of various activities (e.g., roads 

and power lines associated with oil, gas, or renewable energy projects), 

have altered the sagebrush steppe ecosystem in the Great Basin region 

33The Forest Servtce is required to "mall ways that are practicable, atd in the enforcement 

of the laws of the States or Territories ... for the prevention and extinguishment of forest 

fires[.]" 16 U.S.C. § 553. As noted in a 2006 report by the Department of Agriculture 

Inspector General, homeowner reliance on the federal government to provide suppression 

services in the WUI places a substantial financial burden on the Forest Service 

Department of Agriculture, Office of Inspector General Western Region, Audit Reporl 

Forest Sell/ice Large Fire Suppression Costs, Report No. 08601-44-SF (Washington, 

D.C .. November 2006). 

34Cal. Pub. Res. Code§ 4113. 

Page 21 GA0~15~772 Wildland Fire Management 
225 

of the western United States. 35 In addition, the introduction and spread of 

highly flammable invasive nonnative grasses such as cheatgrass have 

altered this ecosystem by increasing the frequency and intensity of fire. 

As of July 2015, FWS was evaluating whether to list the greater sagegrouse, a species reliant on the sagebrush steppe ecosystem, as a 

threatened and endangered species under the Endangered Species 

Act. 35 FWS has noted the importance of fire and fuel management 

activities in reducing the threat to sage-grouse habitat. 37 Beginning in 

2011, BLM issued guidance to its state offices emphasizing the 

importance of sage-grouse habitat in fire operations and the need for fuel 

reduction activities to address concerns about the habitat, more than half 

of which is located on BLM-managed lands. In 2014, the agency issued 

guidance reiterating this importance and stating that it would make 

changes in funding to allow field units to place greater focus on reducing 

fire's threats in sage-grouse habitat areas. 

In January 2015, the Secretary of the Interior issued a Secretarial Order 

to enhance policies and strategies "for preventing and suppressing 

rangeland fire and for restoring sagebrush landscapes impacted by fire 

across the West." 38 The order established the Rangeland Fire Task Force 

and directed it to, among other things, complete a report on activities to 

be implemented ahead of the 2016 Western fire season. Under the order, 

the task force also was to address longer term actions to implement the 

policy and strategy set forth by the order. In a report issued in May 2015, 

An Integrated Rangeland Fire Management Strategy, the task force called 

for prepositioning firefighting assets where priority sage-grouse habitat 

exists, including moving assets from other parts of the country as 

available. The goal is to improve preparedness and suppression 

capability during initial stages of a wildfire to increase the chances of 

keeping fires small and reduce the loss of sage-grouse habitat. 

35The Great Basin region includes parts of California, Idaho, Nevada, Oregon, and Utah. 

More than 350 spec1es of plants and animals are found in this region. 

361n 2011, FWS agreed to make a final listing decision concerning the greater sagegrouse by the end of fiscal year 2015 

3775 Fed. Reg. 13910, 13982 (March 23, 201 0) 

38Secretan·al Order 3336, Rangeland Fire Prevention, Management, and Restoration, 

January 5, 2015 

Page 22 GA0~15.772 Wildland Fire Management 
226 

Agencies Made Additional 

Changes in Other Areas of 

Wildland Fire 

Management 

Working to Improve 

Technology for Wildland Fire 

Planning and Response 

The report also identified actions aimed at improving the targeting of fuel 

reduction activities, including identifying priority landscapes and fuel 

management priorities within those landscapes. These actions are to be 

completed by the end of September 2015 and continuously improved 

upon in subsequent years. According to BLM state officials, the increased 

emphasis on sage-grouse habitat will significantly change how they 

manage their fuel reduction programs. BLM officials from states that 

include sage-grouse habitat said they expect a large increase in fuel 

reduction treatment funding and increased project approvals. In contrast, 

BLM officials from states without this habitat told us they expect 

significant funding decreases, limiting their capacity to address other 

resource issues important for nonsagebrush ecosystems. 

Since 2009, the agencies also have taken steps to change other areas of 

wildland fire management, including technology for wildland fire planning 

and response, line-officer training, and firefighter safety. 

Since 2009, the agencies have applied new technologies to improve 

wildland fire management planning and response. Prominent among 

them is the Wildland Fire Decision Support System (WFDSS), a Webbased decision-support tool that assists fire managers and analysts in 

making strategic and tactical decisions for fire incidents. WFDSS replaced 

older tools, some of which had been used for more than 30 years and 

were not meeting current fire management needs, according to the 

system's website. 39 According to this site, WFDSS has several 

advantages over the older systems, such as enabling spatial data 

layering,'0 increasing use of map displays, preloading information about 

field units' management objectives, and allowing for use in both single 

39https://wfdss.usgs.gov/wfdssAIVFDSS_About.shtml, accessed August 10, 2015 

40Geospatial data describe features or phenomena that can be referenced to specific 

locations relative to the earth's surface. For example, features such as buildings, rivers, 

and federal lands, and phenomena such as wildland fires, can all be tracked by their 

geographic locations in data !ayers. These data layers can then be !inked (or "layered") to 

display the combined information as maps with different layers of information, which may 

facilitate analysis of how the data in the various layers interrelate. See GAO, Geospatial 

Data: Progress Needed on Identifying Expenditures, Building and Utilizing a Data 

Infrastructure, and Reducing Duplicative Efforts, GA0-15-193 (Washmgton, D.C. Feb. 12, 

2015) 

Page 23 GA0-15-772 Wildland Fire Management 
227 

and multiple fire situations. Officials from several agencies told us that 

using WFDSS improved their ability to manage fires by allowing 

information from fire management plans to be loaded into WFDSS and 

providing substantial real-time fire information on which to make 

decisions. For example, one Forest Service official told us that, at one 

point in a recent particularly active fire season in the Pacific Northwest 

Region, the system processed information on approximately 20 

concurrent fires that managers could monitor in real time. As a result, 

they were able to make strategic and risk-informed decisions about the 

resource allocations needed for each fire, including decisions to let some 

fires burn to meet natural resource benefit objectives. According to Forest 

Service reviews of several fires that occurred in 2012, however, some 

managers said WFDSS did not provide effective decision support for 

firefighters because the system underestimated fire behavior or did not 

have current information. 41 

According to officials from several agencies, another example of updated 

wildland fire technology has been the replacement of traditional paperbased fire management plans with electronic geospatial-based plans. 

Federal wildland fire management policy directs each agency to develop 

a fire management plan for all areas they manage with burnable 

vegetation. A fire management plan, among other things, identifies fire 

management goals for different parts of a field unit. According to an 

interagency document describing geospatial-based plans, agency officials 

expect such plans to increase efficiency because the plans can more 

easily be updated to account for changes in the landscape resulting from 

fires, fuel reduction treatments, and other management activities. In 

addition, the electronic format is designed to allow plans to more easily be 

shared across multiple users, including personnel responding to wildland 

fires. Agency officials mentioned other technological improvements, such 

as the development of an "Enterprise Geospatial Portal" providing 

wildland fire data in geospatial form using a Web-based platform, 

although many officials also told us that additional improvements are 

needed in wildland fire technology overall. 

In addition to specific technologies, in 2012 the Forest Service and 

Interior issued a report titled "Wildland Fire Information and Technology: 

41 Wildland Fire Lessons Learned Center, Lessons From Recent Large Fire Reviews 

Briefing Paper(August 7, 2013)_ 

Page 24 GA0-15-772 Wildland Fire Management 
228 

Increasing Line-Officer 

Training 

Strategy, Governance, and Investments," representing the agencies' 

efforts to develop a common wildland fire information and technology 

vision and strategy. The agencies signed a Memorandum of 

Understanding later that same year intended to establish a common 

management approach for information and technology services. 

Nevertheless, the 2014 Quadrennial Fire Review concluded that the 

wildland fire management community does not have an agenda for 

innovation and technology adoption or a list of priorities, stating that the 

wildland fire community "sometimes struggles to define common 

technology priorities and implement integrated, enterprise-level solutions" 

and noting that there are more than 400 information technology systems 

in use by the wildland fire community. 42 The report provides 

recommendations on actions the agencies could consider for 

improvement; however, because it was issued in May 2015, it is too early 

to determine what, if any, actions the agencies have taken. In 

commenting on a draft of this report, Interior stated that the agencies are 

completing an investment strategy for wildland fire applications and 

supporting infrastructure, but did not provide an expected date for its 

completion. 

Officials from several agencies told us that, since 2009, the agencies 

have increased training efforts, particularly those aimed at improving line 

officers' knowledge about, and response to, wildland fires. Line officers 

are land unit managers such as national forest supervisors, BLM district 

managers, and national park superintendents. During a wildland fire, staff 

from "incident management teams" with specific wildland firefighting and 

management training manage the response, and line officers associated 

with the land unit where the fire is occurring must approve major 

decisions that incident management teams make during the response. 43 

Officials at BLM's Oregon/Washington State Office, for example, told us 

they provide line officers with day-long simulation exercises, as well as 

shadowing opportunities that give line officers experience on actual 

wildland fires. Beginning in 2007, the Forest Service initiated a Line 

Officer Certification Program and began a coaching and mentoring 

did not examine the agencies' information technology systems as part of this review 

43For large and complex fires, an incident management team comprising an incident 

commander and a cadre of personnel to handle command, planning, logistics, operations, 

and finance functions manages suppression operations. The incident management team 

orders firefighting assets-includmg personnel, aircraft, equipment, and supplies-through 

a three-tiered system of local, regional, and natJOnal dispatch centers. 

Page 25 GA0~15-n2 Wildland Fire Management 
229 

Emphasizing the Primacy of 

Firefighter Safety 

program to provide on-the-ground experience for preparing line officers to 

act as agency administrators during wildland fires or other critical 

incidents. This program is aimed at providing officials that do not have 

wildland fire experience the opportunity to work under the advisement of a 

coach with wildland fire experience. According to Forest Service 

documents, this program has evolved substantially, in part to address the 

increased demand for skills necessary to manage increasingly complex 

wildland fires. In May 2015, the Forest Service issued guidance for the 

program and called for each Forest Service regional office to administer it 

within the regions. 

Officials told us that, since 2009, the agencies have, in some cases, 

changed firefighting tactics to better protect firefighters, including making 

greater use of natural barriers to contain fire instead of attacking fires 

directly. The agencies have also issued additional guidance aimed at 

emphasizing the primacy of firefighter safety. In 2010, the agencies 

developed and issued the "Dutch Creek Protocol" (named after a wildland 

fire where a firefighter died), which provided a standard set of protocols 

for wildland firefighting teams to follow during an emergency medical 

response or wihen removing and transporting personnel from a location 

on a fire. Both the Forest Service and Interior have also issued agency 

direction stating that firefighter safety should be the priority of every fire 

manager." 

44See, for example, Departments of Agriculture and the Interior, 2015 Direction to 

Wildland Fire Leadership (Washington, D.C .. June 4, 2015), and Forest Service, Chiefs 

Letter offntent- 2015 Fire Management (Washington, D.C.: Jan. 28, 2015) 

Page 26 GA0~15.n2 Wildland Fire Management 
230 

Agencies Assess 

Effectiveness of Their 

Programs in Several 

Ways, but Have Not 

Consistently 

Conducted Reviews 

That Could Improve 

Responses to 

Wildland Fires 

Agencies Use Various 

Performance Measures to 

Assess Wildland Fire 

Management 

The agencies assess the effectiveness of their wildland fire management 

programs in several ways, including through performance measures, 

efforts to assess specific activities, and reviews of specific wildland fire 

incidents. Both the Forest Service and Interior are developing new 

performance measures and evaluations, in part to help better assess the 

results of their current emphasis on risk-based management, according to 

agency officials. In addition, the agencies have undertaken multiple 

efforts, such as studies, to assess the effectiveness of activities including 

fuel reduction treatments and aerial firefighting. The agencies also 

conduct reviews of their responses to wildland fires. However, they have 

not consistently followed agency policy in doing so or used specific 

criteria for selecting the fires they have reviewed, limiting their ability to 

help ensure that their fire reviews provide useful information and 

meaningful results. 

Both the Forest Service and Interior use various performance measures, 

such as the number ofWUI acres treated to reduce fuels and the 

percentage of wildland fires contained during initial attack, to assess their 

wildland fire management effectiveness. These measures are reported in, 

among other things, the agencies' annual congressional budget 

justifications. Officials from both the Forest Service and Interior told us 

their performance measures need improvement to more appropriately 

reflect their approach to wildland fire management and, in June 2015, 

officials from both agencies told us that they were working to improve 

them. For example, several performance measures for both agencies use 

a "stratified cost index" to help analyze suppression costs on wildfires. 

The index is based on a model that compares the suppression costs of 

fires that have similar characteristics, such as fire size, fuel types, and 

proximity to communities, and identifies the percentage of fires with 

suppression costs that exceeded the index. We found in a June 2007 

report, however, that the index was not entirely reliable and that using the 

index as the basis for comparison may not allow the agencies to 

accurately identify fires where more, or more-expensive, resources than 

needed were used. 45 The agencies continue to use the index, but have 

did not make a recommendation regarding this issue, noting that it would take 

several years, at the earliest, before the agencies could collect enough data for the model 

to be useful. See GA0-07 -655 

Page 27 GA0~15-772 Wildland Fire Management 
231 

acknowledged its shortcomings. 46 The Forest Service reported in its fiscal 

year 2016 budget justification to Congress that improvements were 

forthcoming. In April 2015, Forest Service officials told us they have 

incorporated detailed geospatial information into the model on which the 

index is based to help yield more accurate predictions of suppression 

expenditures and have submitted the model for peer review. Once that is 

complete, the agencies plan to begin to implement the updated model, 

but officials did not provide a time frame for doing so. 

Both agencies have also made efforts to improve their perfonmance 

measures to better reflect their emphasis on a risk-based approach to 

wildland fire management. In fiscal year 2014, Interior began using a new 

performance measure intended to better reflect a variety of strategies in 

addition to full suppression: "Percent of wildfires on DOl-managed 

landscapes where the initial strategy (ies) fully succeeded during the 

initial response phase." 47 The same year, the Forest Service began 

developing a performance measure intended to refiect that, in some 

cases, allowing naturally-ignited fires to burn can provide natural resource 

benefits at a lower cost and lower risk to personnel than fully suppressing 

the fire as quickly as possible: "Percent of acres burned by natural ignition 

with resource benefits." Forest Service officials told us they are working 

with field units to evaluate whether this measure will effectively assess 

their efforts to implement a risk-based approach to fire management and 

that they will adjust it as needed. The officials told us they plan to finalize 

the measure and use it in 2017. 

Also, in fiscal year 2014, the Forest Service began developing a 

performance measure that would assess the risk that wildland fire 

presents to highly valued resources such as communities and 

watersheds. This measure is known as the "National Forest System 

wildfire risk index." According to the agency's fiscal year 2016 budget 

justification, it would create an index of relative fire risk based on the 

46Specifically, the index does not account for two of the main factors that influence 

suppression costs. These factors are long-term ecological conditions and changing 

climatic conditions, both of which may have substantial effects on fire management 

strategies See Department of Agriculture, Forest Service, Fiscal Year 2016 Budget 

Justification (Washington, D.C .. February 2015). 

47 1nterior officials told us this measure is based on information supplied by the field units 

responsible for the initial fire response, and that these units are responsible for 

determining whether the initial strategies succeeded 

Page 28 GA0~15.772 Wildland Fire Management 
232 

Agencies Have 

Undertaken Multiple 

Efforts to Assess 

Effectiveness of Specific 

Activities 

likelihood of a large fire affecting these highly valued resources. It may 

also incorporate factors measuring the relative importance of these 

resources and the expected effects that might occur from fire. The Forest 

Service plans to establish a national baseline measure for this index in 

2015 and then periodically remeasure it, likely every 2 years, to determine 

if overall risk has been reduced, according to Forest Service officials. 

Changes that could affect the index include those resulting from fuel 

reduction treatments, wildland fire, forest management activities, 

vegetative growth, and increased WUI development, among others, 

according to the agency's 2016 budget justification. As with the 

performance measure described above, agency officials told us they will 

evaluate whether the measure meets their needs before adopting it; if it 

meets their needs, they plan to finalize the measure and use it in 2017. 

The agencies have also undertaken multiple efforts to assess the 

effectiveness of particular activities, such as fuel reduction and aerial 

firefighting. Regarding fuel reduction activities, we found in September 

2007 and September 2009 that demonstrating the effectiveness of fuel 

reduction treatments is inherently complex and that the agencies did not 

have sufficient information to evaluate fuel treatment effectiveness, such 

as the extent to which treatments changed fire behavior. 48 Without such 

information, we concluded that the agencies could not ensure that fuel 

reduction funds were directed to the areas where they can best minimize 

risk to communities and natural and cultural resources. Accordingly, we 

recommended that the agencies take actions to develop additional 

information on fuel treatment effectiveness. 49 While the agencies took 

steps to address this recommendation, they are continuing efforts to 

improve their understanding of fuel treatment effectiveness. For example, 

the Forest Service and Interior agencies use a system called Fuel 

Treatment Effectiveness Monitoring to document and assess fuel 

48GAO, Wildland Fjre Management: Better Information and a Systematic Process Could 

Improve Agencies' Approach to Allocating Fuel Reduction Funds and Selecting Projects, 

GA0-07-1168 (Washington, D.C Sept 28, 2007) and GA0-09-877. 

49See GA0-07-1168. 

Page 29 GA0-15-772 Wildland Fire Management 
233 

reduction treatment effectiveness. 50 The Forest Service began requiring 

such assessments in 2011 and Interior requested such assessments be 

completed starting in 2012. 51 Under this approach, the agencies are to 

complete a monitoring report whenever a wildfire interacts with a fuel 

treatment and enter the information into the system. Officials told us that 

additional efforts are under way to help understand other aspects of fuel 

treatment effectiveness. For example, in February 2015, the Joint Fire 

Science Program completed its strategy to implement the 2014 Fuel 

Treatment Science Plan. 52 It includes as one of its goals the 

"development of measures/metrics of effectiveness that incorporate 

ecological, social, resilience, and resource management objectives at the 

regional and national level." 

The Forest Service and Interior are also implementing an effort known as 

the Aerial Firefighting Use and Effectiveness Study, begun in 2012 to 

address concerns about limited performance information regarding the 

use of firefighting aircraft. As part of this effort, the agencies are collecting 

information on how aerial retardant and suppressant delivery affects fire 

behavior and plan to use this and other collected information to track the 

performance of specific aircraft types, according to the study website. 53 

This will help the agencies identify ways to improve their current fieet of 

aircraft and inform future aerial firefighting operations and aviation 

5

°Fuel Treatment Effectiveness Monitoring is a program to evaluate the effectiveness of 

prescribed fire and mechanical treatments designed to reduce the risk of wildfire. Forest 

Service and Interior agencies conduct assessments in instances where a wildfire e!ther 

starts within or burns into a fuel treatment area, to evaluate the resulting impacts on fire 

behavior and fire suppression actions. 

51 The Interior agencies each issued their own guidance related to Fuel Treatment 

Effectiveness Monitoring. NPS issued guidance in 2012, BIA in 2013, BLM in 2014, and 

FWS in 2015 

52The Joint Fire Science Program is an interagency program that funds scientific research 

on wildland fires and distributes results to help policymakers, fire managers, and 

practitioners make sound decisions_ The program is jointly funded by the Departments of 

Agriculture and the Interior and is governed by a 10-member board with 5 members from 

the Forest Service and 1 member each from BIA, BLM, FWS, NPS, and the U.S 

Geological Survey. According to the program website, it has funded more than 170 

studies examining the effectiveness of fuel reduction treatments in different locations since 

1998. 

53http://\rV\IVVo/.fs.fed.us/fire/aviation/afue/index.html, accessed July 31, 2015. 

Page 30 GA0-15-772 Wildland Fire Management 
234 

Forest Service and Interior 

Agencies Have Not 

Consistently Conducted 

Reviews of Wildland Fire 

Incidents to Assess their 

Effectiveness 

strategic planning, according to the website. 54 Agency officials told us the 

study is not a one-time activity, but is an ongoing effort to continually 

provide information to help improve their use of firefighting resources. 

The Forest Service and the Interior agencies have conducted reviews to 

assess their effectiveness in responding to wildland fires but have not 

consistently followed agency policy in doing so and did not always use 

specific criteria for selecting the fires they have reviewed. Officials from 

both the Forest Service and Interior told us that current agency policy 

regarding fire reviews overly emphasizes the cost of wildland fire 

suppression rather than the effectiveness of their response to fire. 

However, the agencies have neither updated their policies to better reflect 

their emphasis on effectiveness nor established specific criteria for 

selecting fires for review and conducting the reviews. By developing such 

criteria, the agencies may enhance their ability to obtain useful, 

comparable information about their effectiveness in responding to 

wildland fires, which, in turn, may help them identify needed 

improvements in their wildland fire approach. 

Congressional reports and agency policy have generally called for the 

agencies to review their responses to wildland fires involving federal 

expenditures of $10 million or more. For fiscal years 2003 through 2010, 

congressional committee reports directed the Forest Service and Interior 

to conduct reviews of large fire incidents, generally for the purpose of 

understanding how to better contain suppression costs; beginning in fiscal 

year 2006, these reports included a cost threshold, specifying that such 

reviews be conducted for fires involving federal expenditures of 

$10 million or more. The agencies, in turn, have each developed their 

own policies that generally direct them to review each fire that exceeds 

the $10 million threshold. 55 

2013, we recommended that the Forest Service and Interior expand efforts to collect 

information on aircraft performance and effectiveness to include all types of firef!ghting 

aircraft in the federal fleet, among other recommendations. See GAO, INildland Fire 

Management: Improvements Needed in Information, Collaboration, and Planning to 

Enhance Federal Fire Aviation Program Success, GA0-13-684 (Washington, D.C Aug. 

20, 2013). 

55 in some cases, those policies note that fire reviews may be conducted for other 

purposes, such as where the fire raised significant political, social, natural resource, or 

policy concerns. 

Page 31 GA0~15~772 Wildland Fire Management 
235 

The agencies, however, have not consistently conducted reviews of fire 

incidents meeting the $10 million threshold, in part because, according to 

officials, current agency policy that includes the $10 million threshold 

does not reflect the agencies' focus on assessing the effectiveness of 

their response to fire. However, the agencies have not developed specific 

criteria for selecting fire incidents for review. Forest Service officials told 

us that, rather than selecting all fires with federal expenditures of 

$10 million or more, they changed their approach to selecting fires to 

review. These officials told us that focusing exclusively on suppression 

costs when selecting fires limits the agency in choosing those fires where 

it can obtain important information and best assess management actions 

and ensure they are appropriate, risk-based, and effective. Forest Service 

officials told us the agency judgmentally selects incidents to review based 

on a range of broad criteria, such as complexity and national significance, 

taking into account political, social, natural resource, or policy concerns. 

Using these broad selection criteria, the Forest Service reviewed 5 

wildland fires that occurred in 2012 and 10 that occurred in 2013. 

However, with these broad criteria it is not clear why the Forest Service 

selected those particular fires and not others. For example, the 2013 Rim 

Fire, which cost over $100 million to suppress-by far the costliest fire to 

suppress that year-and burned over 250,000 acres of land, 56 was not 

among the 2013 fires selected for review. Moreover, the reviews 

completed for each of those years did not use consistent or specific 

criteria for conducting the reviews. As of July 2015, the agency had not 

selected the fires it will review from the 2014 wildland fire season and, 

when asked, agency officials did not indicate a time frame for doing so. 

Forest Service officials told us they believe it is appropriate to 

judgmentally select fires to provide them flexibility in identifying which 

fires to review and which elements of the fire response to analyze. 

Nevertheless, Forest Service officials also acknowledged the need to 

develop more specific criteria for selecting fires to review and conducting 

the reviews and, in July 2015, told us they are working to update their 

criteria for doing so. They provided us a draft update of the Forest Service 

policy manual, but this draft did not contain specific criteria for selecting 

fires for review or conducting the reviews. Moreover, officials did not 

provide a time frame for completing their update. 

56The Rim Fire burned about 154,000 acres of Forest Service land, about 79,000 acres of 

NPS land, and about 23,000 acres of pnvate land. 

Page 32 GA0.15.772 Wildland Fire Management 
236 

Within Interior, BLM officials told us BLM completed its last fire review 

based on significant cost (i.e., federal expenditures of $10 million or 

more) in 2013. These officials told us that BLM, similar to the Forest 

Service, plans to shift the emphasis of its fire reviews to evaluate 

management actions rather than focusing on cost, and that officials are 

working to determine criteria for selecting fires for review57 Interior 

headquarters officials told us that FWS and NPS have continued to follow 

the direction provided through their policies regarding reviews of fires that 

met the $10 million threshold. Interior headquarters officials, however, 

acknowledged the need to improve Interior's approach to selecting fires 

for review to focus more on information about decision making rather than 

fire costs. In July 2015, the officials told us they plan to develop criteria 

other than cost for use by all Interior agencies in selecting fires to review, 

and that they plan to develop standard criteria for implementing the 

reviews. They stated that they expect this department-wide effort to be 

completed by the end of calendar year 2015 but did not provide 

information about how they planned to develop such criteria or the factors 

they would consider. 

Agency reports have likewise cited the need to improve both the 

processes for selecting fires for review and the implementation of the 

reviews. A 2010 report, for example, noted the importance of improving 

the selection of fires to review and stated that the agencies would benefit 

from a more productive review strategy. 58 The report said the agencies' 

existing approach to conducting reviews tended to produce isolated 

efforts and unrelated recommendations rather than establishing a 

consistent foundation for continuous improvement. A 2013 report 

assessing the usefulness of the Forest Service's five reviews of 2012 fires 

noted shortcomings in consistency across the reviews, including unclear 

criteria for selecting fires and conducting reviews, as well as limitations in 

the specificity of the resulting reports and recommendations. 59 As noted, 

57 in June 2015, BLM issued guidance for reviewing fires occurring in sage-grouse habitat 

The guidance calls for reviews of fires occurring during the 2015 wildland fire season on 

BLM-administered lands containing at least 10,000 acres of specifically designated sagegrouse habitat 

58Department of Agriculture Independent Large Fire Cost Review Panel and Guidance 

Group, Inc., Large Fire Cost Review for Fiscal Year 2009 (August 2010) 

59Wildland Fire Lessons Learned Center, Lessons From Recent Large Fire Reviews 

Briefing Paper(August 7, 2013). There was no similar analysis performed of the Forest 

Service's 10 reviews of fires occurring in 2013 

Page 33 GAQ.15.772 Wildland Fire Management 
237 

Agencies Distribute 

Resources in Part on 

the Basis of Historical 

Amounts, but Are 

Developing New 

Methods Intended to 

Better Reflect Current 

Conditions 

both agencies have acknowledged the need to improve their criteria for 

selecting fires to review and conducting the reviews. By developing 

specific criteria in agency policies for selecting fires for review and 

conducting the reviews, the agencies may enhance their ability to help 

ensure that their fire reviews provide useful information and meaningful 

results. This is consistent with our previous body of work on performance 

management, which has shown that it is important for agencies to collect 

performance information to inform key management decisions, such as 

how to identify problems and take corrective actions and how to identify 

and share effective approaches. 60 By collecting such performance 

information, the agencies may be better positioned to identify needed 

improvements in their wildland fire approach and thereby use their limited 

resources more effectively. 

The Forest Service and Interior determine the distribution of fire 

management resources in part on the basis of historical amounts but are 

developing new methods intended to better reflect current conditions. For 

suppression, the Forest Service and Interior manage funding as needed 

for units to respond to individual wildland fires. For preparedness, the 

Forest Service and Interior distribute resources based, in part on 

historical funding levels generated by an obsolete system. 61 The agencies 

are working to replace the system and develop new tools to help them 

distribute resources to reflect current landscape conditions, values at 

risk,"' and the probability of wildland fire. For fuel reduction, until recently, 

the Forest Service and Interior both distributed funds using the same 

system. In 2014, the Forest Service began using a new system to help it 

distribute fuel reduction funding in ways that better refiect current 

GAO, Managing for Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GA0-05-927 (Washington, D.C .. Sept 9, 2005), GAO, 

Nanotechnology· Improved Performance Information Needed for Environmental, Health, 

and Safety Research, GA0-12-427 (Washington, D.C.: May 21, 2012), and GA0-13-684. 

61As noted, the Forest Service allocates preparedness and fuel reduction funding directly 

to its nine regions, while Interior allocates funds to its four agencies, which in turn a!locate 

to their respective regional offices. For both the Forest Service and the Interior agencies, 

once regional offices receive funding, they in turn allocate funds to individual units such as 

national forests or national parks 

62As noted, values can include ecological, social, and economic values that could be lost 

or damaged due to fire, including people, property, infrastructure, natural and cultural 

resources, and air quality 

Page 34 GA0~15-772 Wildland Fire Management 
238 

Agencies Fund 

Suppression as Needed 

for Responding to 

Wildland Fires 

conditions. Interior is working to develop a system that likewise reflects 

current conditions. 

The agencies manage funding for suppression at the national level as 

needed for field units to respond to individual wildland fires. The overall 

amount of suppression funding the agencies obligate is determined by the 

complexity and number of wildland fire responses over the course of the 

fiscal year and can vary considerably from year to year. For example, 

federal agencies obligated approximately $1.7 billion for suppression in 

fiscal year 2006, $809 million in fiscal year 2010, and $1.9 billion in fiscal 

year 2012. 63 (See app. II for more detailed information about suppression 

obligations by the Forest Service and the Interior agencies for fiscal years 

2004 through 2014.) 

Each year, the agencies estimate the expected level of funding for 

suppression activities using the average of the previous 10 years of 

suppression obligations. 64 The estimated amount, however, has often 

been less than the agencies' actual suppression obligations, particularly 

for the Forest Service. In all but 2 years since 2000, Forest Service 

suppression obligations have exceeded the 1 0-year average that forms 

the basis of the agency's annual appropriation. To pay for wildfire 

suppression activities when obligations are greater than the amount 

appropriated for suppression, the Forest Service and Interior may transfer 

funds from other programs within their respective agencies as permitted 

by law. 65 As we found in a prior report, these transfers can affect the 

agencies' ability to carry out other important land management functions 

that are key to meeting their missions, such as restoration of forest lands 

noted, unless otherwise specified, obligations are presented in nomtnal dollars, or 

actual dollars that are not adjusted for inflation 

64For example, to determine the fiscal year 2015 budget request for suppression, wllich 

the agencies submitted in fiscal year 2014, the agencies averaged obligations for 

suppression for fiscal years 2004 through 2013. 

65See, e.g., Pub. L. No. 113-76, Div. G, Interior, Environment, and Related Agencies 

Appropriations Act, 2014, Title I,§ 102, 128 Stat 309 (Interior); Title !!I, 128 Stat 325 

(Forest Service) 

Page 35 GA0~15~772 Wildland Fire Management 
239 

Forest Service and Interior 

Distribute Preparedness 

Funding Based in Part on 

an Obsolete System They 

Are Working to Replace 

and other improvements. 66 For example, according to a Forest Service 

report, funding transfers led to a canceled fuel reduction project on the 

Sante Fe National Forest and the deferral of critical habitat acquisition on 

the Cibola National Forest, both located in New Mexico. 67 

In their annual budget justifications for fiscal years 2015 and 2016, the 

agencies proposed an alternative mechanism to fund suppression 

activities. Under that proposal, the agencies would receive 70 percent of 

the standard 10-year average of suppression obligations as their 

appropriation for wildland fire suppression, which reflects the amount the 

agencies spend to suppress approximately 99 percent of wildland fires. 68 

If suppression obligations exceed this amount, additional funds would be 

made available from a disaster funding account. Forest Service and 

Interior officials told us this proposal would allow them to better account 

for the variable nature of wildland fire seasons and reduce or eliminate 

the need to transfer funds from other accounts to pay for suppression. In 

addition, legislation pending in Congress would change how certain 

wildland fire suppression operations are funded. 69 

The Forest Service and Interior distribute preparedness funding to their 

regions and agencies, respectively, based in part on information 

generated from a system that is now obsolete. The agencies attempted to 

develop a new system to distribute preparedness funding, but ended that 

effort in 2014 and are now working to develop different tools and systems. 

In distributing preparedness funds to individual forests, some Forest 

Funding Transfers Cause Project Cancellations and Delays, 

Ref,ationshios. and Management Disruptions, GA0-04-612 (Washington, D.C · 

June 2, 2004). In report, we suggested that Congress consider alternative funding 

approaches for wildfire suppression to reduce the potential need for the Forest Service 

and Interior to rely on transfernng funds from other programs to pay forw!ldfire 

suppression 

67Forest Service, Fire Transfer Impact by State and Tem'tory (Washington, D.C. June 

2014). 

68The remaining 1 percent of wildland fires typically account for the remaining 30 percent 

agencies spend on suppression, according to agency documents 

69For example, Title V of the Senate version of the Interior and Related Appropriations Act 

for Fiscal Year 2016 (S. 1645) would a !low certain wildland fire suppression activities to be 

funded m a manner consistent with other natural disasters, using a modification of the 

approach proposed in the budget request. 

Page 36 GA0~15~772 Wildland Fire Management 
240 

Forest Service and Interior 

Distribution of Preparedness 

Funds to Regions and 

Agencies 

Service regions have developed additional tools to help them distribute 

funds; similarly, three of the four Interior agencies have developed 

additional tools to help them distribute preparedness funds to their 

regions. 70 Overall preparedness obligations in 2014 totaled about 

$1.0 billion for the Forest Service and about $274 million for the Interior 

agencies. 71 (See app. II for detailed information on each of the agencies' 

obligations for preparedness for fiscal years 2004 through 2014.) 

To determine the distribution of preparedness funds from Forest Service 

headquarters to its regions, and from Interior to the department's four 

agencies with wildland fire management responsibilities, the Forest 

Service and Interior rely primarily on amounts that are based on results 

from a budgeting system known as the National Fire Management 

Analysis System (NFMAS). 72 That system, however, was terminated in 

the early 2000s, according to agency officials. Relying on the results from 

the last year NFMAS was used, and making only incremental changes 

from year to year, the Forest Service and Interior have not made 

significant shifts in the funding distribution across their respective regions 

and agencies over time, and they have generally maintained the same 

number and configuration of firefighting assets (e.g., fire engines and 

crews) in the same geographic areas from year to year. Several agency 

officials, however, told us that these amounts no longer reflect current 

conditions, in part because of changes to the landscape resulting from 

increased human development, climate change, and changes to land 

management policies that consider natural resource values differently 

than they did when NFMAS was in use. 

Beginning in 2002, the agencies attempted to replace NFMAS with an 

interagency system designed to help them determine the optimal mix and 

70As noted, we did not assess the design or use of any of the agencies' tools or systems 

for distributing funds. 

71 Part of the difference in obligation amounts may be attributed to differences in how the 

Forest Service and Interior use preparedness funds to pay firefighters' salaries. See 

appendix Ill for more information about these differences 

72NFMAS had tvvo primary components. One component provided historical weather and 

fire behavior data, and the other analyzed various fire-management scenarios, 

considering different combinations of firefighting resources, various potential wildfire 

conditions, and various resource values (such as the presence of timber or other 

commodity values), to help identify the most efficient level of preparedness resources for a 

given land management unit. 

Page 37 GA0.15.n2 Wildland Fire Management 
241 

location of firefighting assets and distribute funds accordingly. In 

developing this system, known as the Fire Program Analysis system, the 

agencies' goal was to develop "a comprehensive interagency process for 

fire planning and budget analysis identifying cost-effective programs to 

achieve the full range of fire management goals and objectives."" 

According to agency documents, this effort proved problematic because 

of the difficulty in modeling various aspects of wildland fire management. 

In addition, agency officials told us it is difficult to design a system that 

could account for multiple agencies' different needs and varying missions. 

After more than a decade of work, and investment that Forest Service 

officials estimated at approximately $50 million, the agencies terminated 

the system's development in September 2014. At that time, they stated 

that it "only delivered inconsistent and unacceptable results." 74 

Since the termination of the Fire Program Analysis system, the agencies 

have continued to rely on results based on the terminated NFMAS, but 

have begun working on new tools to help them distribute funding and 

assets based on current conditions and updated information. Forest 

Service headquarters officials told us the agency is developing a new tool 

called the Wildland Fire Investment Portfolio System. According to these 

officials, this proposed system is intended to model scenarios such as 

large shifts in firefighting assets, various potential dispatch procedures, 

and changes in fire behavior due to climate change, which will allow 

managers, both at the national and individual unit level, to conduct 

resource trade-off analyses and assess whether assets are being used 

effectively. Forest Service officials told us that the agency is in the early 

stages of developing this proposed system and anticipates using it for 

planning and analysis purposes in fiscal year 2016. 

Interior documents state that Interior is developing a system called the 

Risk-Based Wildland Fire Management model, which Interior will use to 

help support funding distribution decisions to the four Interior agencies for 

both preparedness and fuel reduction. The proposed system will assess 

the probability and likely intensity of wildland fire, values at risk, and the 

'

0 Den,,rtmentofthe Interior and Forest Service, FPA Closeout and Transition Plan 

D.C .. September 29, 2014) 

74Nevertheless, agency officials told us the effort resulted in some useful analytical 

products, including certain data sources and a large fire simulation modeling too! known 

as FSim 

Page 38 GA0~15.772 Wildland Fire Management 
242 

Forest Service Regions' 

Distribution to Individual 

National Forests 

Interior Agencies' Distribution 

to Regional Offices 

expected value of acres likely to burn. A key element of this system will 

be the development of strategic business plans by each of the four 

Interior agencies, detailing how each agency intends to distribute its 

preparedness and fuel reduction funding to reduce the risks from wildland 

fire on its lands. Interior officials said that, once the agencies provide 

these business plans, Interior will assess them in making funding 

distribution decisions among the agencies. According to several Interior 

agency officials, identifying priority values at risk across Interior's four 

agencies may be challenging given the variation in agency missions and 

the types of lands they manage. For example, a threatened species 

located primarily on BLM lands may be among BLM's highest priorities, 

but a forested area relied upon by an Indian tribe for its livelihood may be 

among BIAs' highest priorities. Interior officials told us that they expect to 

identify the prioritized values and issue guidance on the proposed system 

by the end of calendar year 2015, and then use its results to infonm their 

fiscal year 2016 funding distributions to the four agencies. 

Once the Forest Service distributes preparedness funding to regions, it 

gives regions discretion to determine how to subsequently distribute 

funding to individual national forests, as long as those determinations are 

consistent with policy and annual budget program direction. Forest 

Service headquarters officials told us they do not plan to direct regions to 

use any specific system to help inform distributions to national forests, so 

that regions can have flexibility in distributing their funds and take into 

account local conditions and priorities. According to agency officials, most 

regions distribute funding to individual national forests based on historical 

amounts resulting from NFMAS. However, two regions have changed the 

way they determine funding distribution to individual national forests to 

better reflect current landscape conditions. The Rocky Mountain Region 

uses a new system that ranks each of its forests according to a "risk 

priority score." According to regional officials, use of the system has 

resulted in shifts in funding across forests in the region; for example, the 

officials told us they have provided additional resources to forests along 

Colorado's Front Range because of increased development in the WUI. 

The Pacific Northwest Region also uses its own funding distribution tool, 

which considers elements such as fire occurrence and the number of 

available assets to develop a weighted value for each forest in the region. 

The region distributes the funding proportionally based on the values 

calculated for each forest. 

Once obtaining preparedness funds from Interior, each agency-which, 

as noted, have their own land management responsibilities and 

missions-distributes these funds to its units. Three of these agenciesPage 39 GA0~15.772 Wildland Fire Management 
243 

BLM, FWS, and NPS-use newer systems and current information, such 

as updated fuel characterization and fire occurrence data, to distribute 

funding to their regional offices. The fourth agency, BIA, generally uses 

historical-based amounts (i.e., NFMAS results), but has made some 

changes to reflect updated priorities. The regions subsequently distribute 

funding to individual land units, typically using the same systems. The 

four agencies' approaches are described below. 

BLM. Since 2010, BLM officials told us they have used results from 

the Fire Program Decision Support System to help determine funding 

distributions to state offices. The system analyzes BLM's fire workload 

and complexity using four components: fire suppression workload, 

fuel types, human risk, and additional fire resources, and assigns 

scores to state offices accordingly. Based on the resulting analyses, 

BLM has shifted funding across state offices to help better reflect 

current conditions. BLM officials told us that most states use the new 

system to help inform the distribution of funding to their units. BLM is 

also developing an additional component of the Fire Program 

Decision Support System to help offices determine the appropriate 

number of firefighting assets needed in each area. Officials expect to 

apply the new component with their overall system in the fall of 2015. 

FWS. In 2014, FWS began distributing its preparedness funding to 

regions using the Preparedness Allocation Tool. Officials told us that 

the tool uses information such as historical wildland fire occurrence, 

proximity to WUI areas, and other information, to inform preparedness 

funding distributions to regions. Agency officials told us that results 

from this tool did not generally identify the need for large funding shifts 

across units, but rather helped identify some smaller shifts to better 

reflect current landscape conditions. Officials with one FWS region 

told us that the tool has helped the agency provide better assurance 

that funding amounts are risk-based and transparent. 

NPS. Since 2013, primarily in response to their overall wildland fire 

management program funding reductions, NPS began using a system 

called the Planning Data System to determine what level of firefighting 

workforce the agency could afford under different budget distribution 

scenarios. The system generates personnel requirements for each 

NPS unit by establishing a minimum number of people for any unit 

that meets certain criteria. Those results are rolled up to also provide 

regional workforce requirements. The results generated from this 

Page 40 GA0~15~772 Wildland Fire Management 
244 

Agencies Are Working to 

Distribute Fuel Reduction 

Funding to Better Account 

for Current Conditions 

system showed that some NPS regions, as well as individual park 

units, had existing wildland fire organizations that they could no longer 

adequately support in light of reduced budgets. 75 

BIA. BIA relies primarily on historical funding amounts derived from a 

system similar to NFMAS. However, BIA officials told us they have 

made adjustments to the historical amounts using professional 

judgment. BIA officials told us that the regions also still primarily use 

historical-based amounts to distribute funding to their units. The 

officials told us they will wait until Interior finalizes its Risk Based 

Wildland Fire Management model before they develop a new funding 

distribution tool. 

Beginning in 2009, the Forest Service and Interior both used systems 

collectively known as the Hazardous Fuels Prioritization and Allocation 

System (HFPAS) to distribute fuel reduction funds. 76 Officials told us 

these systems, based on similar concepts and approaches, were 

developed by the agencies to provide an interagency process for 

distributing fuel reduction funding to the highest-priority projects. 77 

Starting in 2014, the Forest Service instead began using a new system, 

which, according to officials, allows the agency to more effectively 

distribute fuel reduction funds. Interior continues to distribute fuel 

reduction funding to the four agencies based on funding amounts derived 

from HFPAS, but it plans to develop a new system for distributing funds to 

refiect more current conditions and risks. Overall fuel reduction 

obligations in 2014 totaled about $302 million for the Forest Service and 

about $147 million for the Interior agencies. (See app. II for detailed 

information on the agencies' fuel reduction obligations for fiscal years 

2004 through 2014.) 

officials told us they are working to refine their funding aHocation process by 

combining results from the Planning Data System with outputs from a risk based fire 

occurrence and workload analysis tool that they are currently developing, the Strategic 

Allocation Model 

76As noted, Interior now refers to this activity as fuel management rather than fuel 

reduction 

77 1n 2007, we recommended that the agencies develop a systematic approach to 

allocating fuel reduction funding. See GA0-07-1168 

Page 41 GA0-15-772 Wildland Fire Management 
245 

Forest Service officials told us their new system identifies locations where 

the highest probability of wildland fire intersects with important resources, 

such as residential areas and watersheds critical to municipal water 

supplies. These officials told us the new system allows the agency to 

invest its fuel reduction funds in areas where there are both a high 

probability of wildland fires and important resources at risk. In contrast, 

according to officials, HFPAS in some cases prioritized funding for areas 

where important resources, such as extensive WUI, existed but where the 

potential for wildland fires was low. The new system has identified 

locations for funding adjustments to Forest Service regions. For example, 

in 2015 the agency's Eastern and Southern Regions received a smaller 

proportion of fuel reduction funding than they had previously received, 

and some western regions saw increases, because results from the 

system showed that the western regions had more areas with both 

important resources and high wildland fire potential. 

The Forest Service directs its regions to distribute fuel reduction funding 

to national forests using methods consistent with national information, as 

well as with specific local data. A senior Forest Service official told us 

that, as a result, most regions distribute funding to individual national 

forests based on information generated using HFPAS, augmented with 

local data. One region has developed a more updated distribution 

approach. Specifically, in 2012, the Rocky Mountain Region, in 

conjunction with the Rocky Mountain Research Station and Forest 

Service headquarters, developed a fuel reduction funding distribution tool 

that generates a risk priority score for each forest in the region. The risk 

priority score is based on fire probability, resources at risk from fire, 

potential fire intensity, and historical fire occurrence. Each forest's risk 

priority score is used to inform the region's distribution of funding to the 

national forests. 

Interior currently distributes fuel reduction funding to its agencies based 

on the funding amounts derived from HFPAS results that were last 

generated in 2013. Interior officials also told us they plan to stop using 

HFPAS results and are planning to use the new system they are 

developing, the Risk-Based Wildland Fire Management model, to reflect 

current information on conditions and risks in distributing fuel reduction 

funds. 

Within Interior, officials from the four agencies told us they have 

developed, or are in the process of developing, funding distribution 

systems and tools while they wait for Interior to complete the Risk-Based 

Wildland Fire Management model. BLM, for example, uses a fuel 

Page 42 GAQ.15.772 Wildland Fire Management 
246 

Conclusions 

reduction funding distribution tool that maps values at risk, including WUI, 

critical infrastructure, sagebrush habitat, and invasive species data. BLM 

combines this information with data on wildland fire probability to create a 

spatial illustration of the values at risk relative to potential fire occurrence. 

BLM then uses the results of this analysis to fund its state offices. BIA 

uses its own tool to distribute fuel reduction funding to its regions based 

on wildland fire potential data generated by the Forest Service. That 

information is then combined with fire occurrence history and workload 

capacity to generate a model that shows potential fire risk and capacity 

across BIA units. FWS officials told us they are developing a fuel 

reduction funding distribution tool, expected to be used for fiscal year 

2016, which considers fire risks associated with each FWS unit. FWS 

officials told us this tool will identify risk reduction over longer periods of 

time, contain an accountability function to monitor results, and will share 

many attributes with FWS' preparedness allocation tool. NPS officials told 

us the agency will continue to rely on historical amounts, based largely on 

HFPAS. Similar to the previous Interior distribution approach, NPS 

distributes funding for specific projects identified at the headquarters 

level. However, if a unit is not able to implement an identified project, the 

unit can substitute other projects, as necessary. 

Faced with the challenge of working to protect people and resources from 

the unwanted effects of wildland fire while also recognizing that fire is an 

inevitable part of the landscape, the federal wildland fire agencies have 

taken steps aimed at improving their approaches to wildland fire 

management. Their 2009 update to interagency guidance, for example, 

was designed to continue moving away from the agencies' decades-long 

emphasis on suppressing all fires, by giving fire managers more flexibility 

in responding to fires. In addition, the agencies are working to develop 

more up-to-date systems for distributing wildland fire resources. A central 

test of such changes, however, is the extent to which they help ensure 

appropriate and effective agency responses to fires when they occur. The 

agencies have acknowledged the importance of reviewing their 

responses to individual wildland fires to understand their effectiveness 

and identify possible improvements. However, the agencies have not 

systematically followed agency policy regarding such fire reviews and, in 

the reviews they have conducted, they have not used specific criteria in 

selecting fires and conducting the reviews. Officials from both the Forest 

Service and Interior told us cost alone should not be the basis for such 

reviews and have acknowledged the need to improve their criteria for 

selecting fires and conducting reviews. Draft guidance provided by the 

Forest Service did not contain specific criteria for such reviews, however, 

Page 43 GA0~15.772 Wildland Fire Management 
247 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

and Interior officials did not provide information about how they planned 

to develop criteria or the factors they would consider. By developing 

specific criteria for selecting fires to review and conducting the reviews, 

and making commensurate changes to agency policies to help ensure the 

criteria are consistently applied, the agencies may enhance their ability to 

ensure that their fire reviews provide useful information and meaningful 

results. This, in turn, could better position them to identify improvements 

in their approach to wildland fire management and thereby use their 

limited resources more effectively. 

To better ensure that the agencies have sufficient information to 

understand the effectiveness of their approach to wildland fires, and to 

better position them to develop appropriate and effective strategies for 

wildland fire management, we recommend that the Secretaries of 

Agriculture and the Interior direct the Chief of the Forest Service and the 

Director of the Office of Wildland Fire to take the following two actions: 

Develop specific criteria for selecting wildland fires for review and for 

conducting the reviews as part of their efforts to improve their 

approach to reviewing fires, and 

Once such criteria are established, revise agency policies to align with 

the specific criteria developed by the agencies. 

We provided a draft of this report for review and comment to the 

Departments of Agriculture and the Interior. The Forest Service 

(responding on behalf of the Department of Agriculture) and Interior 

generally agreed with our findings and recommendations, and their 

written comments are reproduced in appendixes IV and V respectively. 

Both agencies stated that they are developing criteria for selecting fires to 

review and conducting reviews. Both agencies also provided technical 

comments which we incorporated into our report as appropriate. Interior 

also provided additional information about wildland fire technology, which 

we likewise incorporated as appropriate. 

We are sending copies of this report to the appropriate congressional 

committees, the Secretaries of Agriculture and the Interior, and other 

interested parties. In addition, the report is available at no charge on the 

GAO website at http://www.gao.gov. 

Page 44 GA0~15~772 Wildland Fire Management 
248 

If you or your staff members have any questions regarding this report, 

please contact me at (202) 512-3841 orfennella@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. GAO staff who made key 

contributions to the report are listed in appendix VI. 

Anne-Marie Fennell 

Director, Natural Resources and Environment 

Page 45 GA0.15.772 Wildland Fire Management 
249 

Appendix 1: Objectives, Scope, and 

Methodology 

This report examines (1) key changes the federal wildland fire agencies 

have made in their approach to wildland fire management since 2009, 

(2) how the agencies assess the effectiveness of their wildland fire 

management programs, and (3) how the agencies determine the 

distribution of their wildland fire management resources. 

To perform this work, we reviewed laws, policies, guidance, academic 

literature, and reviews related to federal wildland fire management. These 

included the 1995 Federal Wildland Fire Management Policy and 

subsequent implementation guidance, the Interagency Standards for Fire 

and Fire Aviation Operations, and the 2009 and 2014 Quadrennial Fire 

Reviews. We also interviewed headquarters officials from each of the five 

federal land management agencies responsible for wildland fire 

management-the Forest Service in the Department of Agriculture and 

the Bureau of Indian Affairs (BIA), Bureau of Land Management (BLM), 

Fish and Wildlife Service (FWS), and National Park Service (NPS) in the 

Department of the Interior-as well as Interior's Office of Wildland Fire. 

We also conducted semistructured interviews of regional officials in each 

of the agencies to obtain information about issues specific to particular 

regions and understand differences across regions. 1 We interviewed 

wildland fire management program officials from each of the 9 Forest 

Service regional offices, 11 of BLM's 12 state offices,' and 2 regional 

offices each for BIA, FWS, and NPS. We focused these regional 

interviews primarily on the Forest Service and BLM because those 

agencies receive the greatest percentage of appropriated federal wildland 

fire funding. For BIA, FWS, and NPS, we selected the two regions from 

each agency that received the most funds in those agencies-BIA's 

Northwest and Western Regions, FWS's Southwest and Southeast 

Regions, and NPS's Pacific West and Intermountain Regions. We 

conducted a total of 25 semistructured interviews of regional offices. 3 

1

The Forest Serv1ce, BIA, FINS, and NPS have reg tonal offices, while BLM has state 

offices. For the purposes of this report, we refer to all of these as regional offices vvhen we 

discuss the agencies collectively 

2We did not interview officials from the BLM Eastern states Office because its wildland fire 

management program is minimal. 

3

The number of semistructured interviews we conducted does not match the number of 

regional offices identified because tvvo Forest Service regions were included in one 

interview. 

Page 46 GA0~15~772 Wildland Fire Management 
250 

Appendix 1: Objectives, Scope, and 

Methodology 

During these semistructured interviews we asked about (1) significant 

changes to the agencies' approach to wildland fire management, 

including regional efforts to implement the policy areas identified in the 

2009 interagency Guidance for Implementation of Federal Wildland Fire 

Management Policy, (2) agency efforts to assess the effectiveness of 

their wildland fire management activities, and (3) agency processes for 

determining the distribution of fire management resources. We focused 

our review on three primary components of wildland fire managementsuppression, preparedness, and fuel reduction-because they account 

for the highest spending amounts among wildland fire management 

activities. 4 

To address our first objective, we reviewed agency documents, such as 

policy and guidance, as well as other documents such as agency budget 

justifications, to identify changes the agencies have made to their 

approach to managing wildland fire since 2009, efforts the agencies have 

undertaken to address wildland fire management challenges, agencyidentified improvements resulting from those changes, and challenges 

associated with implementing them. Our review focuses on changes 

since 2009 because we last completed a comprehensive review of 

wildland fire management in that year, and because the agencies' last 

significant change to interagency wildland fire management guidance for 

implementing the Federal Wildland Fire Management Policy also 

occurred that year. To further our understanding of these issues, we also 

asked about these changes in our interviews with agency headquarters 

officials. In particular, we asked about the extent to which changes to the 

agencies' wildland fire management approaches have occurred or are 

planned, the effects of these changes, and associated challenges. In 

addition, we relied on the semistructured interviews of regional officials 

described above to understand how the regions implemented national 

direction and policy. We analyzed the responses provided to us during 

the interviews to identify common themes about prominent changes since 

2009, and challenges associated with implementing those changes. The 

information we report represents themes that occurred frequently in our 

interviews with both regional and headquarters officials. We did not report 

on changes described during our interviews that were not directly related 

40ther fire program components include prevention; science, research, and development; 

site rehabilitation; and assistance to nonfederal entities_ 

Page 47 GA0~15~772 Wildland Fire Management 
251 

Appendix 1: Objectives, Scope, and 

Methodology 

to wildland fire management, such as changes to general workforce 

management policies. 

To address our second objective, we reviewed agency strategic plans 

and budget justifications describing performance measures, as well as 

other documents associated with agency efforts to assess their programs, 

including fire reviews. We also reviewed legislative and agency direction 

related to fire reviews, including agency policies and the Interagency 

Standards for Fire and Fire Aviation Operations, and reviewed reports 

resulting from fire reviews conducted by the agencies since 2009. We 

compared agency practices for conducting fire reviews to direction 

contained in relevant agency policy. We also interviewed headquarters 

officials to identify the agencies' key performance measures and the 

extent to which those measures reflect changing approaches to wildland 

fire management. In our interviews with headquarters and regional 

officials, we also inquired about other mechanisms the agencies use to 

determine the effectiveness of their wildland fire management programs, 

as well as any changes they are making in this area. To obtain additional 

insight into the use of performance information on the part of federal 

agencies, we also reviewed our previous reports related to agencies' use 

of performance information. 

To address our third objective, we reviewed relevant agency budget 

documentation, including annual budget justifications and documentation 

of agency obligations, as well as information about the tools and systems 

the agencies use to distribute funds and resources. We did not assess 

the design or use of any of the agencies' tools or systems for distributing 

funds. We interviewed agency officials at the headquarters and regional 

levels to identify the processes they use for budget formulation and 

resource distribution. We asked about the extent to which these 

processes have changed in recent years at the headquarters and regional 

levels for each of the five agencies and the extent to which they have 

changed funding and resource amounts. We also obtained data from the 

Forest Service and from Interior's Office of Wildland Fire on obligations 

for each of the three primary wildland fire management componentssuppression, preparedness, and fuel reduction-from fiscal years 2004 

through 2014, analyzing the data in both nominal (actual) and constant 

(adjusted for inflation) terms. Adjusting nominal dollars to constant dollars 

allows the comparison of purchasing power across fiscal years. To adjust 

for inflation, we used the gross domestic product price index with 2014 as 

the base year. We reviewed budget documents and obligation data 

provided by the agencies, and interviewed agency officials 

Page 48 GAQ.15~n2 Wildland Fire Management 
252 

Appendix 1: Objectives, Scope, and 

Methodology 

knowledgeable about the data, and we found the data sufficiently reliable 

for the purposes of this report. 

We conducted this performance audit from August 2014 to September 

2015 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Page 49 GA0~15~772 Wildland Fire Management 
253 

Appendix II: Forest Service and Interior Agency 

Obligations for Preparedness, Fuel Reduction, 

and Suppression, Fiscal Years 2004 through 

2014 

This appendix provides information on preparedness, fuel reduction, and 

suppression obligations by the Forest Service and the Department of the 

Interior's four wildland fire agencies-the Bureau of Indian Affairs, 

Bureau of Land Management, Fish and Wildlife Service, and National 

Park Service--for fiscal years 2004 through 2014. 

Figures 4, 5, and 6 show overall agency obligations for preparedness, 

fuel reduction, and suppression for fiscal years 2004 through 2014. 

Individual agencies' obligations for each of the three programs are 

described later in this appendix. 

Figure 4: Forest Service and Interior Agency Wildland Fire Preparedness Obligations, Fiscal Years 2004 through 2014 

Dollars in millions 

2,000 

1,600 

1,200 

Total 

2,000 

1,600 

1,200 

~llllllllllll: 2004 

Fiscal year 

2005 

c=J ForestService 

2006 

~ Bureau of Land Management 

-BureauoflndianAffairs 

... National Park Service 

.. Fish and Wildlife Serv1ce 

--Total 

2007 2008 2009 2010 2<J11 2012 2013. 2014 

Souroos GAO analysis of Forest Service. Bureau of land Managem<.J'Il. Bureau of lr>diaOAff<H~. Naliooal Park Service, and Fish alld \1'/ildl•fe Serv<ca fUildl!lg data. J GA0-15-772 

Page 50 GA0-15-772 Wildland Fire Management 
254 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Figure 5: Forest Service and Interior Agency Fuel Reduction Obligations, Fiscal Years 2004 through 2014 

Dollars in milllo11s 

1,000 

800 

600 

Total 

1,000 

800 

600 

~lillilllllliLl~ 2004 2005 2006 2007 2008 2008 2010 2()11 2012 2013 2014 

Fiscal year 

D ForestServlce 

~ Bureau of Land Mar~agement 

!lllsureauoflndtar~Affairn 

~~~~ Natior~al ParkServ1ce 

- Fish ar~dWi!dlife Service 

--Total 

Sources GAO annlysis of Forest Service, Bureau of Land Manageml'l,t, Bureau of lrld1anAffairs, National Park Servltu, and Fish and \'Jildlife Service> fll!1ding data l GA0-15-772 

Note: The increase in agency obligations for fuel reduction in fiscal year 2009 was due in part to 

additional appropriations provided by the American Recovery and Reinvestment Act of 2009 (Pub. 

L No.111-5) 

Page 51 GA0~15~772 Wildland Fire Management 
255 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Figure 6: Forest Service and Interior Agency Wildland Fire Suppression Obligations, Fiscal Years 2004 through 2014 

Dollars ln millions 

2,000 

1,600 

1,200 

800 

400 

2004 

Fiscal year 

2005 

UForestService 

2006 

D Bureau of Land Management 

llllsureauoflndianAffairs 

- National Park Serv1ce 

- Fish and Wildlife Service 

--Total 

2007 2008 2009 2010 2011 2012 2013 

Sources, GAO analys1s of Forest SeruJCe, Bureau of l!md Manage me,!. Bureau of Iridian Affairs, National Park Service. and Fish Md \Nildhfa S<!Nit.e fU!lding data. l GA0-15-772 

2014 

Total 

2,000 

1,600 

1,200 

800 

400 

Page 52 GAQ.15~772 Wildland Fire Management 
256 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Table 1 and figure 7 show annual Forest Service wildland fire 

management obligations for fiscal years 2004 through 2014. 

Preparedness obligations increased from nearly $760 million in fiscal 

year 2004 to about $1.0 billion in fiscal year 2014, an average increase 

of 3.2 percent per year, or 1.2 percent after adjusting for inflation. 1 Fuel 

reduction obligations increased from about $284 million in fiscal year 

2004 to about $302 million in fiscal year 2014, an average annual 

increase of 0.6 percent, or a 1.4 percent decrease after adjusting for 

inflation. Suppression obligations fiuctuated from year to year, with a 

high of about $1.4 billion in fiscal year 2012 and a low of about 

$525 million in fiscal year 2005. 

Table 1: Forest Service Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal Years 2004 

through 2014 

Dollars in millions 

Fiscal Inflationyear Nominal Nominal adjusted 

2004 $759.3 $284.2 $726 0 $1,769 6 $2,160.6 

2005 841.2 995.7 294.5 348.6 524.9 621.3 1,660.6 1.965.7 

2006 852.8 977.7 274.3 314.5 1,280.4 1,468.0 2,407.5 2,760.1 

2007 905.6 1,010.7 310.6 346.7 1,149.7 1,283.2 2,365.8 2,640.5 

2008 898 4 982 4 364.5 398.6 

Sour~e GAO anal~ts of Forest Serv,ce fundtng data I GA0·15·772 

Notes: Inflation-adjusted figures represent obligations in fiscal year 2014 dollars 

Totals may not add due to rounding 

1

According to Forest Service budget justifications, the Forest Service shifted aviation 

costs from the suppression account to the preparedness account beginning in fiscal year 

2012. The Forest Service has retroactively adjusted the figures in both of these accounts 

for fiscal years 2005 through f1sca! year 2011 to reflect this correction and allow 

comparability of numbers before and after this shift. 

Page 53 GA0-15-772 Wildland Fire Management 
257 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Figure 7: Forest Service Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal Years 2004 

through 2014 

Forest ~ervice (obhgations) 

Preparedness 

Dollars in millions 

1,600 

1,400 

1,200 

1,000 

800 

600 

400 

200 

2004 2006 

Fiscal year 

---Nominal 

lnflation-aajusted 

Suppression 

Dollars in millions 

1,600 

1,400 

1,200 

1,000 

BOD 

800 

400 

200 

2004 2008 

Fiscal year 

--- Nominal 

~lnflation-acjusted 

2008 2010 

2008 2010 

Source· GAO analysis of Forest Serv•ce 1\mding data ! GA0-15-772 

2012 2014 

2012 2014 

Fuel reduction 

Dollars in millions 

1,600 

1,400 

1,200 

1,000 

800 

600 

400 

200 

2004 2006 

Fiscal year 

---Nominal 

Inflation-adjusted 

2008 2010 

Note: lrTflat!on-adjusted figures represent obligations in fiscal year 2014 dollars, 

2012 2014 

Page 54 GA0-15-772 Wildland Fire Management 
258 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Table 2 and figure 8 show annual Bureau of Indian Affairs wildland fire 

management obligations for fiscal years 2004 through 2014. 

Preparedness obligations decreased from nearly $58 million in fiscal 

year 2004 to about $51 million in fiscal year 2014, an average annual 

decrease of 1.3 percent per year, or 3.2 percent after adjusting for 

inflation. Fuel reduction obligations decreased from about $39 million in 

fiscal year 2004 to about $30 million in fiscal year 2014, an average 

annual decrease of 2.6 percent, or 4.5 percent after adjusting for 

inflation. Suppression obligations fluctuated from year to year, with a 

high of about $105 million in fiscal year 2012 and a low of about 

$43 million in fiscal year 2010. 

Table 2: Bureau of Indian Affairs Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Preparedness Fuel reduction Suppression Total 

Fiscal Inflation~ Inflation~ Inflation- Inflationyear Nominal adjusted Nominal adjusted Nominal adjusted Nominal adjusted 

2004 $57 6 $70.3 $387 $47 2 $67.5 $82.4 $163.8 $200.0 

2005 53.0 62.8 41.8 49.5 62.4 73.9 157.3 186.2 

2006 48.5 55.6 41.7 47 8 82.9 95.1 173.1 198.5 

2007 477 53.2 41.5 46.3 83.1 927 172.2 192.2 

2008 55.0 60.1 41.7 45.6 87 9 96.2 184.6 201.8 

2009 52.3 56.5 44.6 48.2 51.1 55.2 147.9 159.9 

2010 54.4 58.3 43.2 46.3 43.2 46.3 140.8 150.8 

2011 56.2 59.1 397 41.7 58.5 61.4 154.5 162.2 

2012 54.8 56.6 33.0 34.0 105.4 108.7 193.1 199.2 

2013 49.3 50.0 26.1 26.5 63.6 64.6 139.0 141.2 

2014 50.8 50.8 297 297 53.2 53.2 133.7 133.7 

Source GAO analysiS of DepartrT<Jnt of the lntenor funding data j GA0-15-772 

Notes: Inflation-adjusted figures represent obligations in fiscal year 2014 dollars 

Totals may not add due to roundmg 

Page 55 GA0·15-772 Wildland Fire Management 
259 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Figure 8: Bureau of Indian Affairs Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 

Bureau of Indian Affairs (obligations) 

Preparedness 

Dollars in millions 

150 

100 

50 

2004 2006 

Fiscal year 

--- Nommal 

lnnmion-adjusted 

2008 2010 2012 2014 

Supp_~~!.?:::"---------------

Dollars in millions 

150 

100 

50 

2004 2006 

Fiscal year 

............ Nom1na! 

Inflation-adjusted 

2008 2010 2012 

Source· GAO analys"S of Department of We lnteriorfundmg dat.- 1 GA0-15-772 

2014 

Fuel reduction 

Dollars in millions 

150 

100 

50 

2004 2006 

Fiscal year 

............ Nominal 

lnfiation-adjusted 

2008 2010 

Note: Inflation-adjusted figures represent obligations in fiscal year 2014 dollars 

2012 2014 

Page 56 GA0~15~772 Wildland Fire Management 
260 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Table 3 and figure 9 show annual Bureau of Land Management wildland 

fire management obligations from fiscal years 2004 through 2014. 

Preparedness obligations increased from nearly $152 million in fiscal 

year 2004 to about $160 million in fiscal year 2014, an average annual 

increase of 0.6 percent per year, or a 1.4 percent decrease after 

adjusting for inflation. Fuel reduction obligations decreased from about 

$98 million in fiscal year 2004 to about $75 million in fiscal year 2014, an 

average annual decrease of 2.6 percent, or 4.6 percent after adjusting 

for inflation. Suppression obligations fluctuated from year to year, with a 

high of about $299 million in fiscal year 2007 and a low of about 

$130 million in fiscal year 2009. 

Table 3: Bureau of Land Management Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 

Preparedness Fuel reduction Suppression Total 

Inflation- Inflation- Inflation- InflationFiscal year Nominal adjusted Nominal adjusted Nominal adjusted Nominal adjusted 

2004 $1516 $185.1 $977 $119.3 $1705 $208.1 $419.8 $512.5 

2005 157.6 186.6 99.2 1174 184.4 218.2 441.2 522.2 

2006 162.2 185 9 97.2 111 4 262 7 301.2 522.1 598.5 

2007 168.7 188.3 96.6 107.8 298.5 333.1 563.8 629.3 

2008 163.3 178.6 109.4 119.6 198 0 216.5 470.7 514.7 

2009 169.6 183.3 96.8 104.6 129 9 140 5 396.3 428.3 

2010 166.2 178.0 98.3 1054 160.0 171.4 424.5 454.8 

2011 171 9 180.5 86.6 909 182.6 191.8 441.1 463.3 

2012 161.1 166.2 91.8 94.7 292.2 301.3 545.1 562.2 

2013 153.3 155.7 66.1 67.1 268.2 272.3 487.6 495.1 

2014 160.2 160.2 74.8 74.8 211.3 211.3 446.4 446.4 

Source GAO analysis of Department ol the intenorh.md1ng data 1 GA0-15-772 

Notes: Inflation-adjusted figures represent obligations in fiscal year 2014 dollars 

Totals may not add due to rounding. 

Page 57 GA0-15-n2 Wildland Fire Management 
261 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Figure 9: Bureau of Land Management Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 

Bure~u of Land Management (obligations) _____ _ 

Preparedness 

Dollars in millions 

400 

300 

200 

100 

2004 

Fiscal year 

2006 

--- Nominal 

~Inflation-adjusted 

Suppression 

Dollars in millions 

400 

300 

200 

100 

2004 2006 

Fiscal year 

--- Nominal 

Inflation-adjusted 

2008 2010 2012 

2008 2010 2012 

Source· GAO analysis of Department oftre Interior funding dah!l. I GA0-15-772. 

2014 

2014 

Fuel reduction 

Dollars in millions 

400 

300 

200 

100 

2004 2006 

Fiscal year 

---Nominal 

~ lnftatior·adjusted 

2008 2010 2012 2014 

Note: Inflation-adjusted figures represent obligations in fiscal year 2014 dollars. 

Page 58 GA0-15-772 Wildland Fire Management 
262 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Table 4 and figure 10 show annual Fish and Wildlife Service wildland fire 

management obligations for fiscal years 2004 through 2014. 

Preparedness obligations decreased from about $33 million in fiscal year 

2004 to about $27 million in fiscal year 2014, an average annual 

decrease of 2.1 percent per year, or 4.1 percent after adjusting for 

inflation. Fuel reduction obligations decreased from about $24 million in 

fiscal year 2004 to about $21 million in fiscal year 2014, an average 

annual decrease of 1.5 percent, or 3.5 percent after adjusting for 

inflation. Suppression obligations fluctuated from year to year, with a 

high of about $41 million in fiscal year 2011 and a low of about $4 million 

in fiscal year 2010. 

Table 4: Fish and Wildlife Service Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 

Preparedness Fuel reduction Suppression Total 

Fiscal Inflation~ Inflation- Inflation~ Inflationyear Nominal adjusted Nominal adjusted Nominal adjusted Nominal adjusted 

2004 $334 $407 $24.2 $29 6 $84 $10.3 $66.0 $806 

2005 26.8 31 7 27.9 33.0 14.3 16.9 69.0 817 

2006 25.6 29.3 33.0 37 8 19.9 229 785 90.0 

2007 27.7 30.9 33.0 36.8 31 4 35 1 921 102.8 

2008 284 31.1 33.9 37.1 22.5 24.6 84.9 92.8 

2009 28.2 30.5 34.8 37.6 15.0 16.2 78 0 844 

2010 29.4 31.5 32.6 34.9 4.3 46 66.3 71.0 

2011 29.0 304 27.5 28.8 40.5 42.6 97.0 101.8 

2012 27.9 28.8 25.5 26.3 20.8 21 4 74.2 76.5 

2013 25.9 26.3 20.2 20.5 14.1 14.3 60.2 61.1 

2014 26.9 26.9 207 20.7 94 94 57.0 57.0 

Sourc<> GAO analysis of Depsrtrrent ol the lntenor fund•flg data 1 GA0-15-772 

Notes: Inflation-adjusted figures represent obligations in fiscal year 2014 dollars 

Totals may not add due to rounding 

Page 59 GA0-15-772 Wildland Fire Management 
263 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Figure 10: Fish and Wildlife Service Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal 

Years 2004 through 2014 

Fish and Wildlife Service (obli'-'g':::tio:::n:::'i'---------------------------------

Preparedness 

Dollars in millions 

150 

100 

50 

2004 2006 

Fiscal year 

--- Nomma! 

Inflation-adjusted 

Suppression 

Dollars in millions 

150 

100 

50 

2008 

2004 2006 2008 

Fiscal year 

--- Nomina! 

~Inflation-adjusted 

2010 2012 

2010 2012 

Source· GAO analysis of Department oft~e Interior funding data. I GA0-15-772. 

2014 

2014 

Fuel reduction 

Dollars in millions 

150 

100 

50 

2004 

Fiscal year 

2006 

--- Nom1nal 

lnftatior--adjusted 

2008 2010 2012 2014 

Note: Inflation-adjusted figures represent obligations in fiscal year 2014 dollars. 

Page 60 GA0-15-772 Wildland Fire Management 
264 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Table 5 and figure 11 show annual National Park Service wildland fire 

management obligations for fiscal years 2004 through 2014. Obligations 

for preparedness increased from about $35 million in fiscal year 2004 to 

about $36 million in fiscal year 2014, an average annual increase of 

0.5 percent per year, or a 1.5 percent decrease after adjusting for 

inflation. Fuel reduction obligations decreased from about $31 million in 

fiscal year 2004 to about $21 million in fiscal year 2014, an average 

annual decrease of 3.7 percent, or 5.6 percent after adjusting for 

inflation. Suppression obligations fluctuated from year to year, with a 

high of about $58 million in fiscal year 2006 and a low of about 

$22 million in fiscal year 2009. 

Table 5: National Park Service Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Preparedness Fuel reduction Suppression Total 

Inflation- Inflation- Inflation- InflationFiscal year Nominal adjusted Nominal adjusted Nominal adjusted Nominal adjusted 

2004 $34.6 $42.2 $311 $38.0 $34.9 $42.6 $100.6 $122.8 

2005 31.5 37.3 31.8 37.7 32.9 39.0 96.3 114.0 

2006 31.9 366 30.9 35.4 58 5 67 0 121.2 139.0 

2007 34.1 381 28.6 31.9 57.4 64.1 120.1 134.1 

2008 33.9 37.1 33.9 37.0 44.3 48.5 112.1 122.6 

2009 34.4 37.2 33.9 36.6 22.4 24.2 90.6 98.0 

2010 39.7 42.5 34.4 36.8 23.7 25.4 97.8 104.7 

2011 36.4 38.2 30.3 31.8 37.0 38.9 103.7 108.9 

2012 39.3 40.6 30.4 31.3 47.4 48.9 117.1 120.8 

2013 31.0 31.5 210 21.3 53.1 53.9 105.2 106.8 

2014 36.2 36.2 21.4 21.4 52.2 52.2 109.8 109.8 

Sourc<> GAO analysts of Department of the !ntenor ftmd•ng data 1 GA0-15·772 

Notes: Inflation-adjusted figures represent obligations in fiscal year 2014 dollars 

Totals may not add due to rounding 

Page 61 GA0-15-772 Wildland Fire Management 
265 

Appendix II: Forest Service and Interior 

Agency Obligations for Preparedness, Fuel 

Reduction, and Suppression, Fiscal Years 

2004 through 2014 

Figure 11: National Park Service Wildland Fire Obligations for Preparedness, Fuel Reduction, and Suppression, Fiscal Years 

2004 through 2014 

National Park Service (obligatlo::::""')c_ _______________________ _ 

Preparedness 

Dollars in millions 

150 

100 

50 

2004 

Fiscal year 

2006 

--- Nom~nal 

~Inflation-adjusted 

Suppression 

Dollars in millions 

150 

100 

50 

2004 2008 

Fiscal year 

---Nominal 

~Inflation-adjusted 

2005 2010 2012 

2008 2010 2012 

Source· GAO analysis of Department oft~e Interior funding dato. I GA0-15-772 

2014 

2014 

Fuel reduction 

Dollars in millions 

150 

100 

50 

2004 2006 

Fiscalyesr 

---Nominal 

Inflation-adjusted 

2008 2010 

Note: Inflation--adjusted figures represent obligations in fiscal year 2014 do!!ars. 

2012 2014 

Page 62 GA0-15-772 Wildland Fire Management 
266 

Appendix Ill: Differences in Forest Service and 

Department of the Interior Salary Payments 

Using Preparedness and Suppression Funding 

The Forest Service and the Department of the Interior use different 

approaches for paying the base salaries of their staff during wildland fire 

incidents.' For periods when firefighters are dispatched to fight fires, the 

Forest Service generally pays its firefighters' base salaries using 

suppression funds, whereas Interior pays its firefighters' base salaries 

primarily using preparedness funds. 2 Forest Service officials told us that 

under this approach, regional offices, which are responsible for hiring 

firefighters in advance of the fire season, routinely hire more firefighters 

than their preparedness budgets will support, assuming they can rely on 

suppression funds to pay the difference. Forest Service officials told us 

that their funding approach helps the agency maintain its firefighting 

capability over longer periods of time during a season and accurately 

track the overall costs of fires. Interior officials told us they choose to use 

preparedness funds to pay their firefighters' base salaries during a 

wildland fire because it constitutes a good business practice. According 

to a Wildland Fire Leadership Council document, in 2003, the council 

agreed that the agencies would use a single, unified approach and pay 

firefighters' base salary using Interior's method of using preparedness 

funds. However, the council subsequently noted that in 2004 the Office 

of Management and Budget directed the Forest Service to continue 

using suppression funds to pay firefighters' base salaries. The agencies 

have used separate approaches since 2004. 

1 Base salary represents the salary paid for a standard 8~hour work shift 

21nterlor uses preparedness funds to pay for its firefighters' standard 8-hour work shift on 

a wildland fire, and suppression funds to pay for any overtime. The Forest Service uses 

suppression funds to pay for any time a firefighter spends on a wildland fire 

Page 63 GAQ.15.772 Wildland Fire Management 
267 

Appendix IV: Comments from the 

Department of Agriculture 

Forest 

Serviee 

Ms. Anne-Marie Fennell 

Washington Office 

Director, Natural Resources and Environment 

U.S. Government Accountability Office 

441 G Street, NW 

Washington, DC 20548 

Dear Ms. Fennell: 

l400lndependenceAvenue,SW 

Washingtl>n,DC 20250 

FileCode: 1420 

Date: St:t' 3 2G1S 

The U.S. Department of Agriculture (UDSA) appreciates the opportunity to respond to the U.S. 

Government Accountability Otlice (GAO) draft report "Wildland Fire Management: Agencies 

Have Made Several Key Changes, but Could Benefit fTom More Information about 

Effectiveness, {GA0-15-772)." The USDA generally agrees with the findings and 

recommendation in the GAO draft report. 

We value the GAO's assistance in reporting on key changes and effectiveness of the Federal 

Wildland Fire program. The Forest Service is currently developing criteria for selecting fires to 

be reviewed. These criteria may include things such as: 

Fires that posed a significant chal!enge, requiring a heavy resource commitment to meet 

objectives, or with complex ownership and critical values threatened. 

Fires where innovation or extraordinary events provide a learning opportunity. 

In addition, we are now developing criteria for the fire review process to ensure we are providing 

oversight of our decisions and investments as part of appropriate management and fiscal control. 

The reviews help us learn and improve, by challenging our assumptions and evaluating areas for 

gained efficiency and alignment with policy, doctrine and partners. 

Thank you again for the opportunity to review the draft report. If you have any questions, please 

contact Thelma Strong, Chief Financial Ofllcer, at 202~205-0429 or tstrong@fs.fcd.us. 

Sincerely, 

?Lc¥!'?'~ THOMAS L TIDWELL 

Chief 

Page 64 

CaringfortheLandandServingPeople 

GA0-15-772 Wildland Fire Management 
268 

Appendix V: Comments from the Department 

of the Interior 

United States Depanmenr of the Interior 

SEP 0 4 1015 

Ms,Anne-ll.-iarieFenllell 

Director, Natura! Resources and Environment 

L.S. Government AccountabihLy Office 

441 

DcarMs,FenncJl; 

I. Additiun to the factual portion nfthe Report 

Page 65 GAQ.15.772 Wildland Fire Management 
269 

Appendix V: Comments from the Department 

of the Interior 

2. Technical comm<':nt on "What GAO Found" in thO': summa I')' page 

We suggest tlw !O!Jowing to replace the second am! third sentences: 

3. Recommendations 

Page 66 GAQ.15.772 Wildland Fire Management 
270 

Appendix V: Comments from the Department 

of the Interior 

lfyol! h:J\canyque~tions. or need additional infOrmation, please contact me. 

Page 67 GA0~15.772 Wildland Fire Management 
271 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

Anne-Marie Fennell, (202) 512-3841 orfennella@gao.gov 

In addition to the individual named above, Steve Gaty (Assistant 

Director), Ulana M. Bihun, Richard P. Johnson, Lesley Rinner, and Kyle 

M. Stetler made key contributions to this report. Important contributions 

were also made by Cheryl Arvidson, Mark Braza, William Carrigg, Carol 

Henn, Benjamin T. Licht, Armetha Liles, and Kiki Theodoropoulos. 

Page 68 GA0~15~772 Wildland Fire Management 
272 

Related GAO Products 

Wildland Fire Management: Improvements Needed in Information, 

Collaboration, and Planning to Enhance Federal Fire Aviation Program 

Success. GA0-13-684. Washington, D.C.: August 20, 2013. 

Station Fire: Forest Service's Response Offers Potential Lessons for 

Future Wildland Fire Management. GA0-12-155. Washington, D.C.: 

December 16,2011. 

Arizona Border Region: Federal Agencies Could Better Utilize Law 

Enforcement Resources in Support of Wildland Fire Management 

Activities. GA0-12-73. Washington, D.C.: NovemberS, 2011. 

Wildland Fire Management: Federal Agencies Have Taken Important 

Steps Forward, but Additional Action Is Needed to Address Remaining 

Challenges. GA0-09-906T. Washington, D.C.: July 21, 2009. 

Wildland Fire Management: Federal Agencies Have Taken Important 

Steps Forward, but Additional, Strategic Action Is Needed to Capitalize 

on Those Steps. GA0-09-877. Washington, D.C.: September 9, 2009. 

Wildland Fire Management: Actions by Federal Agencies and Congress 

Could Mitigate Rising Fire Costs and Their Effects on Other Agency 

Programs. GA0-09-444T. Washington, D.C.: April1, 2009. 

Forest Service: Emerging Issues Highlight the Need to Address 

Persistent Management Challenges. GA0-09-443T. Washington, D.C .. 

March 11, 2009. 

Wildland Fire Management: Interagency Budget Tool Needs Further 

Development to Fully Meet Key Objectives. GA0-09-68. Washington, 

D.C.: November 24, 2008. 

Wildland Fire Management: Federal Agencies Lack Key Long- and 

Short-Term Management Strategies for Using Program Funds 

Effectively. GA0-08-433T. Washington, D.C.: February 12, 2008. 

Forest Service: Better Planning, Guidance, and Data Are Needed to 

Improve Management of the Competitive Sourcing Program. 

GA0-08-195. Washington, D.C.: January 22, 2008. 

Wildland Fire Management: Better Information and a Systematic Process 

Could Improve Agencies' Approach to Allocating Fuel Reduction Funds 

Page 69 GAQ.15.772 Wildland Fire Management 
273 

Related GAO Products 

and Selecting Projects. GA0-07-1168. Washington, D.C .. September 28, 

2007. 

Natural Hazard Mitigation: Various Mitigation Efforts Exist, but Federal 

Efforts Do Not Provide a Comprehensive Strategic Framework. 

GA0-07-403. Washington, D.C.: August 22, 2007. 

Wildland Fire: Management Improvements Could Enhance Federal 

Agencies' Efforts to Contain the Costs of Fighting Fires. GA0-07-922T. 

Washington, D.C.: June 26, 2007. 

Wildland Fire Management: A Cohesive Strategy and Clear CostContainment Goals Are Needed for Federal Agencies to Manage 

Wildland Fire Activities Effectively. GA0-07-1017T. Washington, D.C .. 

June 19, 2007. 

Wildland Fire Management: Lack of Clear Goals or a Strategy Hinders 

Federal Agencies' Efforts to Contain the Costs of Fighting Fires. 

GA0-07-655. Washington, D.C.: June 1, 2007. 

Department of the Interior: Major Management Challenges. 

GA0-07-502T. Washington, D.C.: February 16, 2007. 

Wildland Fire Management: Lack of a Cohesive Strategy Hinders 

Agencies' Cost-Containment Efforts. GA0-07-427T. Washington, D.C .. 

January 30, 2007. 

Biscuit Fire Recovery Project: Analysis of Project Development, Salvage 

Sales, and Other Activities. GA0-00-967. Washington, D.C.: September 

18, 2006. 

Wildland Fire Rehabilitation and Restoration: Forest Service and BLM 

Could Benefit from Improved Information on Status of Needed Work. 

GA0-06-670. Washington, D.C.: June 30, 2006. 

Wildland Fire Suppression: Better Guidance Needed to Clarify Sharing of 

Costs between Federal and Nonfederal Entities. GA0-06-896T. 

Washington, D.C.: June 21, 2006. 

Wildland Fire Suppression: Lack of Clear Guidance Raises Concerns 

about Cost Sharing between Federal and Nonfederal Entities. 

GA0-06-570. Washington, D.C.: May 30, 2006. 

Page 70 GA0~15~772 Wildland Fire Management 
274 

Related GAO Products 

Wildland Fire Management: Update on Federal Agency Efforts to 

Develop a Cohesive Strategy to Address Wildland Fire Threats. 

GA0-06-671R. Washington, D.C.: May 1, 2006. 

Natural Resources: Woody Biomass Users' Expariences Provide 

Insights for Ongoing Government Efforts to Promote Its Use. 

GA0-06-694T Washington, D.C.: April 27, 2006. 

Natural Resources: Woody Biomass Users' Expariences Offer Insights 

for Government Efforts Aimed at Promoting Its Use. GA0-06-336. 

Washington, D.C.: March 22, 2006. 

Wildland Fire Management: Timely Identification of Long-Term Options 

and Funding Needs Is Critical. GA0-05-923T Washington, D.C.: July 

14, 2005. 

Natural Resources: Federal Agencies Are Engaged in Numerous Woody 

Biomass Utilization Activities, but Significant Obstacles May Impede 

Their Efforts. GA0-05-741T Washington, D.C.: May 24, 2005. 

Natural Resources: Federal Agencies Are Engaged in Various Efforts to 

Promote the Utilization of Woody Biomass, but Significant Obstacles to 

Its Use Remain GA0-05-373. Washington, D.C.: May 13, 2005. 

Technology Assessment: Protecting Structures and Improving 

Communications during Wildland Fires. GA0-05-380. Washington, D.C.: 

April 26, 2005. 

Wildland Fire Management: Progress and Future Challenges, Protecting 

Structures, and Improving Communications. GA0-05-627T Washington, 

D.C.: April 26, 2005. 

Wildland Fire Management: Forest Service and Interior Need to Specify 

Steps and a Schedule for Identifying Long-Term Options and Their 

Costs. GA0-05-353T Washington, D.C.: February 17, 2005. 

Wildland Fire Management: Important Progress Has Been Made, but 

Challenges Remain to Completing a Cohesive Strategy GA0-05-147. 

Washington, D.C.: January 14, 2005. 

Wildland Fires: Forest Service and BLM Need Better Information and a 

Systematic Approach for Assessing the Risks of Environmental Effects. 

GA0-04-705. Washington, D.C.: June 24, 2004. 

Page 71 GA0~15~772 Wildland Fire Management 
275 

Related GAO Products 

Federal Land Management: Additional Guidance on Community 

Involvement Could Enhance Effectiveness of Stewardship Contracting. 

GA0-04-652. Washington, D.C.: June 14, 2004. 

Wildfire Suppression: Funding Transfers Cause Project Cancellations 

and Delays, Strained Relationships, and Management Disruptions. 

GA0-04-612. Washington, D.C.: June 2, 2004. 

Biscuit Fire: Analysis of Fire Response, Resource Availability, and 

Personnel Certification Standards. GA0-04-426. Washington, D.C.: April 

12, 2004. 

Forest Service: Information on Appeals and Litigation Involving Fuel 

Reduction Activities. GA0-04-52. Washington, D.C.: October 24, 2003. 

Geospatiallnformation: Technologies Hold Promise for Wildland Fire 

Management, but Challenges Remain. GA0-03-1047. Washington, D.C.: 

September 23, 2003. 

Geospatiallnformation: Technologies Hold Promise for Wildland Fire 

Management, but Challenges Remain. GA0-03-1114T. Washington, 

D.C.: August 28, 2003. 

Wildland Fire Management: Additional Actions Required to Better 

Identify and Prioritize Lands Needing Fuels Reduction. GA0-03-805. 

Washington, D.C.: August 15, 2003. 

Wildland Fires: Forest Service's Removal of Timber Burned by Wildland 

Fires. GA0-03-808R. Washington, D.C.: July 10, 2003. 

Forest Service: Information on Decisions Involving Fuels Reduction 

Activities. GA0-03-689R. Washington, D.C.: May 14, 2003. 

Wildland Fires: Better Information Needed on Effectiveness of 

Emergency Stabilization and Rehabilitation Treatments. GA0-03-430. 

Washington, D.C.: April 4, 2003. 

Major Management Challenges and Program Risks: Department of the 

Interior. GA0-03-104. Washington, D.C.: January 1, 2003. 

Results-Oriented Management: Agency Crosscutting Actions and Plans 

in Border Control, Flood Mitigation and Insurance, Wetlands, and 

Page 72 GA0-15-772 Wildland Fire Management 
276 

(361590) 

Related GAO Products 

Wildland Fire Management. GA0-03-321. Washington, D.C.: December 

20, 2002. 

Wildland Fire Management: Reducing the Threat of Wildland Fires 

Requires Sustained and Coordinated Effort. GA0-02-843T. Washington, 

D.C: June 13, 2002. 

Wildland Fire Management: Improved Planning Will Help Agencies 

Better Identify Fire-Fighting Preparedness Needs. GA0-02-158. 

Washington, D.C.: March 29, 2002. 

Severe Wildland Fires: Leadership and Accountability Needed to Reduce 

Risks to Communities and Resources. GA0-02-259. Washington, D.C.: 

January 31, 2002. 

Forest Service: Appeals and Litigation of Fuel Reduction Projects. 

GA0-01-1114R. Washington, D.C.: August 31, 2001. 

The National Fire Plan: Federal Agencies Are Not Organized to 

Effectively and Efficiently Implement the Plan. GA0-01-1 022T. 

Washington, D.C.: July 31, 2001. 

Reducing Wildfire Threats: Funds Should be Targeted to the Highest 

Risk Areas. GAO/T-RCED-00-296. Washington, D.C.: September 13, 

2000. 

Fire Management: Lessons Learned From the Cerro Grande (Los 

Alamos) Fire. GAO/T-RCED-00-257. Washington, D.C.: August 14, 

2000. 

Fire Management: Lessons Learned From the Cerro Grande (Los 

Alamos) Fire and Actions Needed to Reduce Fire Risks. 

GAO/T-RCED-00-273. Washington, D.C.: August 14, 2000. 

Page 73 GAQ.15~772 Wildland Fire Management 
277 

GAO's Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Connect with GAO 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

The Government Accountability Office, the audit, evaluation, and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and 

policies; and provides analyses, recommendations, and other assistance 

to help Congress make informed oversight, policy, and funding 

decisions. GAO's commitment to good government is reflected in its core 

values of accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no 

cost is through GAO's website (http://www.gao.gov). Each weekday 

afternoon, GAO posts on its website newly released reports, testimony, 

and correspondence. To have GAO e-mail you a list of newly posted 

products, go to http://www.gao.gov and select "E-mail Updates." 

The price of each GAO publication reflects GAO's actual cost of 

production and distribution and depends on the number of pages in the 

publication and whether the publication is printed in color or black and 

white. Pricing and ordering information is posted on GAO's website, 

http://www.gao.gov/ordering.htm. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or 

TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card, 

MasterCard, Visa, check, or money order. Call for additional information. 

Connect with GAO on Facebook, Flickr, Twitter, and You Tube. 

Subscribe to our RSS Feeds or E-mail Updates. 

Listen to our Podcasts and read The Watchblog. 

Visit GAO on the web at www.gao.gov. 

Contact: 

Website: http://www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov 

Automated answering system: (800) 424-5454 or (202) 512-7470 

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-

4400, U.S. Government Accountability Office, 441 G Street NW, Room 

7125, washington, DC 20548 

Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, DC 20548 

Please Print on Recycled Paper. 
278 

STATEMENT FOR THE SENATE COMMITTEE ON ENERGY AND NATURAL 

RESOURCES HEARING RECORD 

SUBMISSION MADE ON BEHALF OF THE CALIFORNIA FOREST AND 

WATERSHED ALLIANCE (CAFWA) 

November 17,2015 

ChaiiWoman Murkowski, Ranking Member Cantwell, and Committee Members, the California 

Forest and Watershed Alliance (CAFW A) is pleased to submit this statement for the record for 

the November 17, 2015 hearing to review past wildfire seasons to inform and improve future 

federal wildland fire management strategies. CAFW A is a unique alliance of disparate interests 

including organizations that represent water, environment, local government, timber, and 

agricultural interests all dedicated to finding a solution to California's ever-growing forest health 

and fire risk issues. The members of CAFW A, the Association of California Water Agencies, 

California Farm Bureau Federation, California Forestry Association, The Nature Conservancy 

California Chapter, and Rural County Representatives of California, are working together to seek 

new ways to promote proactive, science-based, and ecologically sound forest management 

practices that will reduce the risk of destructive megafires. Our goal is to protect our forests, our 

natural resources, and our local economies by accelerating the pace and scale of forest 

restoration. 

Background: Accelerating forest restoration and hazardous fuels reduction is essential to 

securing multiple benefits from our National Forests. These benefits include wildlife habitat, 

clean water supplies, recreation, forest products, carbon sequestration, forest health, reduced 

burned acres in wildfires and reduced fire severity, and healthy rural communities and 

economies. 

Inaction on forest health is contributing to catastrophic megafires. CAFW A encourages 

Congress and the U.S. Forest Service to quickly address the known budgetary and policy 

obstacles that are contributing to this crisis. 

CAFW A believes that any policy or legislative reforms that promote improvements to and 

expansion of forest restoration activities should be ecologically sound, and advance research to 

improve the state of scientific knowledge to better direct future land management decisions. 

Problem Statement: California forests, and other forests across the western United States, are at 

serious risk of large, high-severity wildfires that threaten lives, communities, water resources, 

wildlife habitat, and recreation. Recent examples, such as the Butte and Valley Fires which were 

both federally declared disasters, and together destroyed over 2200 homes, infrastructure, and 

unique habitats and have left behind communities which will remain fractured for years to come 

in their wakes. Although forest thinning and controlled burning are proven methods of reducing 

the risk of destructive megafires, the current pace and scale of forest management activities are 

inadequate given the scope of the problem. Our fire season is starting earlier and lasting longer 

with fires burning hotter than ever before. The growing cost of Forest Service fire suppression 
279 

activities is negatively impacting the budget available to carry out critical restoration projects 

that protect forests and will reduce firefighting costs over the long term. Severe drought in 

western states is also exacerbating the decline of forests due to beetle bark infestations. There is 

an urgent need to restore our forests to a more resilient condition to protect our water resources, 

communities, and ecological values. 

2015 Wildfire and Budget Impacts: According to the California Department of Forestry and 

Fire Protection (CAL FIRE), almost 306,000 acres of private and state land and another 400,000 

acres of federal lands have been affected by wildfires this year alone and the state estimates that 

$209 million will be spent, just in suppression costs. Similarly, at the national level, the U.S. 

Forest Service estimates that this year it will spend 52% of its entire budget on wildfires, with 

that amount expected to increase to 67% by 2025. Contrast that to 1995, when the Forest 

Service spent 16% of its budget on wildfire costs; such drastic increases in the percentage of 

their budget that is used for fighting fires cuts into non-fire programs such as restoration and land 

management, which, in turn, increases the likelihood of catastrophic wildfires the following 

year. 

CAFW A Statement of Purpose: CAFW A believes healthy forests matter, not just to those 

living in and around those forests, but to all Californians who rely on clean water, clean air and 

recreational opportunities. The impacts of forest wildfires on our water, energy, environment 

and economy are felt by Californians throughout the state. It is time to take a serious look at 

current forest management policies, and to expand programs to improve forest health. The 

members of CAFWA are working together to seek new ways to promote proactive, sciencebased, and ecologically sound forest management practices that will reduce the risk of 

destructive megafires. 

WHAT'S AT RISK? 

Water Supply and Storage: Unhealthy forests and catastrophic wildfires affect the short and 

long term management and sustainability of water supplies. Wildfires in untreated areas cause 

burned areas to produce increased loads of sediment, ash and debris which cause reservoirs to fill 

up faster and reduce the life and storage capacity of reservoirs. Burned watersheds without trees 

and ground cover will result in snowpack melting more quickly. The resulting runoff will be less 

predictable, and less timely, increasing the difficulty of managing water supply throughout the 

west. 

A recent study by The Nature Conservancy (TNC) analyzed the potential water yield benefits 

from ecologically-based forest management in the northern Sierra Nevada and concluded that, if 

conducted at a landscape scale, fuels reduction in Sierra forests can potentially increase water 

yield by up to 6 percent. Dr. Roger Bales (UC Merced) in his I l/29/2011 publication predicts 

that up to 16% could be increased in water yield. The TNC report also found that it makes 

economic sense for water suppliers and utilities to invest in ecologically based thinning. 

Increased water that comes from thinning small trees could have significant economic benefits 

for downstream hydropower and water users, potentially off-setting between one-third and the 

full cost of the thinning. 
280 

Water Quality: Post-fire flooding has short and long-tenn impacts throughout watersheds which 

can extend far beyond the area of the fire. Ash, sediment, nitrogen and phosphorus can severely 

impact the taste and purity of drinking water, and negatively impact fish and other aquatic 

species that require clear, oxygenated water. Increased sediment deposited behind reservoirs can 

impact the taste, clarity and odor of water as dissolved organics increase in the water, requiring 

elevated water treatment costs. 

Ecosystem and Wildlife: Destructive megafires have numerous impacts on the ecosystem and 

wildlife. High severity fire can scorch soils, removing valuable organic carbon on the surface and 

in the soil profile, reducing its water holding capacity. When this occurs on slopes, the firesterilized soil is more likely to be carried down-slope, causing erosion and reversing hundreds to 

thousands of years of natural soil building processes. Wildlife habitat is also impacted by high 

severity fire as ecosystems shift from cool, canopy covered refugia to hot, exposed, and eroded 

barrens. Some wildlife can exploit these newly disturbed areas and brush lands, while others 

may need to migrate elsewhere to survive. Newly disturbed sites are also prone to invasion by 

non-native plant species that grow quickly and take advantage of recently released nutrients and 

bare, mineral soil. Additionally, some treeless patches are so severely sterilized that new sources 

of seeds do not exist and the area must be replanted, incurring greater costs and raising 

uncertainty about success in a continuing drought. 

Rural Economies: The absence of forest management creates devastating economic hardship 

and danger for those living and working in California's rural communities. These megafires 

often result in millions of dollars worth of infrastructure damage and devastation to the landscape 

that require lengthy rehabilitation periods. Rural communities also rely on healthy forests for 

revenues generated from the multiple uses our National forests provide including, but not limited 

to, timber harvest, grazing, tourism, and recreation. 

OPPORTUNITIES 

Unfortunately, fuels reduction projects in overgrown forests continue to face numerous 

obstacles. Despite partnerships between stakeholders and federal, state and local governments, 

and science that clearly demonstrates the benefits of fuels reduction projects, the pace and scale 

of proactive forest management is not nearly keeping up with the increased size and severity of 

wildfires in our western forests. CAFWA believes there are opportunities to help accelerate 

forest restoration and is undertaking the following actions: 

• Building a diverse, bipartisan, urban-rural coalition in California to advocate for 

increasing the pace and scale of ecologically-based active management in California's 

forests and watersheds. 

• Communicating the importance of California's healthy forests by emphasizing the 

multiple values that they provide including, but not limited to, water resources. 

• Pursuing increased funding and new funding sources for forest management from federal, 

state, and private sources. 

• Advocating for policy and legislative reforms that will promote ecologically sound forest 

restoration. 
281 

• Advancing monitoring and research to improve the state of scientific knowledge to better 

direct future land management decisions. 

CAFWA encourages Congress to pass federal legislation that addresses the following 

issues: 

Promote Landscape-Scale Collaboration -- Congress should incentivize and reward 

landscape-scale collaboration with local governments and diverse stakeholders by expediting 

environmental review for collaboratively-based projects that address insect or disease 

infestation, reduction of hazardous fuels particularly near communities, forest health 

restoration, wildlife habitat improvement, or protection of municipal water sources. 

Fix "Fire Borrowing" -- The structure of wildfire funding desperately needs to be changed 

to prevent so-called "fire borrowing" - or the shift of dedicated forest management funds at 

the US. Department of Interior and the US. Department of Agriculture, to fund wildfire 

suppression activities - in addition to, addressing the increasing costs of suppression over 

time, which continues to erode program budgets. Currently, the Wildfire Disaster Funding 

Act is the only proposal positioned to address the multiple complexities of fire budgeting. 

Resolution of this issue, whether through the Wildfire Disaster Funding Act or an alternative 

methodology, is critical to the constituencies CAFW A represents. 

Expedite Forest Restoration -- Congress should consider providing additional direction and 

incentives to the Forest Service to undertake fuels reduction and forest management activities 

on a landscape scale, where supported by effective collaborations. This could include a 

combination of (1) financial incentives for landscape-scale forest management, possibly tied 

to a job-creation program to bolster rural economies and provide more certainty over 

multiple years, and (2) regulatory incentives. Regulatory incentives may include providing 

direction to the Forest Service to encourage management of the national forests on a 

landscape scale, including innovative approaches to complying with the National 

Environmental Policy Act (NEPA) that would meet the policy's goals while expediting forest 

management This approach might include, for example, increased use of landscape-scale 

Environmental Impact Statements (EIS) that consider environmental impacts and alternatives 

at a whole-watershed scale while allowing the Forest Service to implement site-specific 

projects without additional extensive NEPA review, as long as projects are ecologically 

sound. This may also significantly decrease per-acre analysis costs and expedite project 

implementation. 

Address Pace of Judicial Process -- CAFWA shares the concern that legal challenges can 

reduce the pace of forest management necessary to reduce wildfire risk and promote more 

resilient forest conditions. CAFW A recognizes there are several different approaches being 

debated on how best to address this concern. The goal should be to expedite collaborative, 

ecologically-based landscape-scale management--while still ensuring that agencies are held 

accountable and projects are ecologically sound. Congress should work on a solution that 

advances this goaL 
282 

Funding for Forest-Water Research and Demonstration Projects -- Congress should 

build upon the link between healthy forests, watersheds, and downstream water quality and 

quantity by funding landscape-scale research and demonstration projects. The goal of such 

research should be to document and quantify the extent to which landscape-scale forest 

management serves to safeguard water supply by reducing the risk of high-severity wildfires 

and resulting erosion and sedimentation, by increasing water yield, and in other respects. 

CONCLUSIONS 

Accelerating forest restoration and hazardous fuels reduction is essential to securing multiple 

benefits from our National Forests. These benefits include wildlife habitat, clean water supplies, 

recreation, forest products, carbon sequestration and healthy rural economies. 

Inaction on forest health is contributing to catastrophic megafires. CAFW A encourages 

Congress and the US. Forest Service to quickly address the known budgetary and other 

obstacles that are contributing to this crisis. 

If you would like to reach a member of CAFW A for further details on our position, please 

contact Erin Huston of the Farm Bureau at ehuston@cfbf.com, Dave Reynolds representing 

ACW A at dlreyns@sso.org. Thane Young representing RCRC at tyoung@vsadc.com, David 

Edelson at dedelson@tnc.org, or Steve Brink with CalForests at steveb@calforests.org. 
283 

The CorpsNetwork 

Strengthening America through 

service and conservation 

The Honorable Lisa Markowski 

Chairwoman 

Senate Committee on Energy & 

Natural Resources 

304 Dirksen Senate Building 

Washington, DC 20510 

November 10,2015 

Dear Chairwoman Markowski and Ranking Member Cantwell; 

www.co rpsn etwo rk. o rg 

The Honorable Maria Cantwell 

Ranking Member 

Senate Committee on Energy & 

Natural Resources 

304 Dirksen Senate Building 

Washington, DC 20510 

On behalf of The Corps Network's Service and Conservation Corps (Corps) across the country, we write 

to respectfully request your support for the Wildfire Disaster Funding Act, H.R. 167 and S. 235. This 

important legislation will reform how wildfire suppression is funded in order to significantly minimize 

the harmful practice of transferring tunds from critical programs to pay for wildfire suppression. The 

Wildfire Disaster Funding Act would fund response to the most disastrous wildfires similar to how the 

Federal Emergency Management Agency (FEMA) funds other disaster response under the Balanced 

Budget and Emergency Deficit Control Act of 1985. Instead of competing with funding for response to 

other natural disasters such as floods, tornadoes, and hurricanes, wildfire disasters would have their own 

relief mechanism. 

The Corps Network's 100+ Corps are diverse in mission and membership and strive to improve quality 

of life for our participants and in our communities. From building trails and campgrounds on our 

nation's iconic public lands, to responding to natural disasters and wildfire remediation and fighting, 

Corps provide communities with valuable services, improve lives, and the environment. Increasing 

disasters such as fires, risk the lives ofCorpsmembers as well as interrupt other recreation, maintenance, 

and economic development activities on public lands. 

Wildfire seasons are getting longer and major wildfires are becoming increasingly more costly to 

suppress. This national problem is causing a crippling burden on the Department of the Interior and the 

USDA Forest Service's land management functions as they shift resources to fund suppression 

activities. Federal wildfire suppression will always be fully funded by the government- even if it comes 

at the expense of programs that improve forest health and mitigate future wildfires. However, this 

current ad hoc process of funding wildfire is inefficient and ineffective in delivering on nationwide 

agency land management priorities set by Congress and virtually assures that overall federal outlays will 

increase. 

We believe a solution to fire tun ding should: 1) allow access to disaster funding; 2) minimize impacts 

from transfers; and 3) address the increasing costs of suppression over time. The WDFA, (S. 235, H.R. 

167) is a bipartisan proposal that addresses these three items. We encourage you to incorporate WDFA 

language in the FY20 16 appropriations or other related legislative vehicles moving through Congress to 

ensure this serious budgetary issue is addressed this year. 

Additionally, since the Land Water Conservation Fund (LWCF) was not reauthorized in the most recent 

Continuing Resolution and the fund continues to be used to pay for wildfire suppression, it is also 

1275 K Street, NW, Suite 1050, Washington, DC 20005 p: 202.737.6272 f: 202.737.6277 
284 

The CorpsNetwork 

Strengthening America through 

service and conservation 

www.corpsnetwork.org 

important that take action be taken to fully fund and reauthorize LWCF. Without LWCF, access to our 

public lands is diminished and proactive forest management provided through LWCF's Forest Legacy 

Program is reduced. We cannot afford for conservation programs like LWCF to bear the burden of 

wildfire suppression and fighting and need LWCF to be fully funded to help address the many 

conservation and recreation needs that exist. 

We again respectfully urge your support for Wildfire Disaster Funding Act (WDFA) language in the 

FY16 appropriations omnibus or passage through other must-pass legislative vehicles. The WDFA is a 

critical, important step to ensure the long-term sustainability of our nation's forests and other public 

lands and our Corps stand ready to continue helping manage and improve our nation's important natural 

resources and great outdoors. 

Sincerely, 

Ma1y Ellen Sprenkel 

CEO 

CORPS OF THE CORPS NETWORK 

ALASKA 

Anchorage Park Foundation (Youth Employment in 

Parks) 

Student Conservation Association (Anchorage 

Regional Office) 

ARIZONA 

ACE (American Conservation Experience) 

(Flagstaff) 

Arizona Conservation Corps (Flagstaff & Tucson) 

CALIFORNIA 

ACE (American Conservation Experience) (Santa 

Cruz) 

California Conservation Corps 

Civicorps 

Conservation Corps of Long Beach 

Conservation Corps North Bay 

Desert Restoration Corps (SCA) 

Fresno EOC Local Conservation Corps 

Kern Service and Conservation Corps 

Los Angeles Conservation Corps 

Orange County Conservation Corps 

Sacramento Regional Conservation Corps 

San Francisco Conservation Corps 

San Gabriel Valley Conservation Corps 

San Joaquin Regional Conservation Corps 

San Jose Conservation Corps & Charter School 

Sequoia Community Corps 

Student Conservation Association (Oakland 

Regional Office, Western Region Headquarters) 

Urban Conservation Corps (Southern California 

Mountains Foundation) 

Urban Corps of San Diego County 

COLORADO 

Conservation Legacy 

Larimer County Conservation Corps 

Mile High Youth Corps (Denver and Colorado 

Springs) 

Rocky Mountain Youth Corps (Steamboat Springs) 

Southwest Conservation Corps (Four 

Comers/Durango & Los Valles/Salida) 

Westcm Colorado Conservation Corps 

CONNECTICUT 

Knox Parks Foundation -Green Crew 

DISTRICT OF COLUMBIA 

1275 K Street, NW, Suite !050, Washington, DC 20005 p: 202.737.6272 f: 202.737.6277 
285 

The CorpsNetwork 

Strengthening America through 

service and conservation 

Student Conservation Association (Capital Region 

Office) 

FLORIDA 

Community Training Works, Inc. Young American 

Conservation Corps 

Greater Miami Service Corps 

GEORGIA 

Greening Youth Foundation 

HAWAII 

KUPU -Hawaii Youth Conservation Corps 

IDAHO 

SCA Idaho AmcriCorps 

ILLINOIS 

Stndcnt Conservation Association (Chicago 

Regional office, Central Region headquarters) 

Y outhBuild Lake County 

Youth Conservation Corps, Inc. 

IOWA 

Conservation Corps Mitmesota & Iowa 

LOUISIANA 

Limitless Vistas, Inc. 

MAINE 

Maine Conservation Corps 

MARYLAND 

Civic Works 

Montgomery County Conservation Corps (a 

program of Latin American Youth Center) 

MASSACHUSETTS 

Massachusetts Corps (SCA) 

MICHIGAN 

Michigan Civilian Conservation Corps 

SEEDS 

Stndent Conservation Association (Detroit Regional 

Office) 

MINNESOTA 

Conservation Corps Minnesota & Iowa 

www.corpsnetwork.org 

MISSISSIPPI 

Climb CDC Conservation Corps 

MISSOURI 

AmcriCorps St. Louis 

MONTANA 

Montana Conservation Corps 

NEVADA 

Nevada Conservation Corps (a program of the Great 

Basin Institute) 

NEW HAMPSHIRE 

New Hampshire Corps (SCA) 

NEW JERSEY 

New Jersey Youth Corps of Atlantic Cape May 

New Jersey Youth Corps of Camden County I The 

WorkGroup 

New Jersey Youth Corps of Elizabeth 

New Jersey Youth Corps of Jersey City 

New Jersey Youth Corps of Middlesex County 

New Jersey Youth Corps of Monmouth County I 

Interfaith Neighbors. Inc. 

Ne\Y Jersey Youth Corps of Newark I International 

Youth Organization 

New Jersey Youth Corps of Paterson 

New Jersey Youth Corps of Phillipsburg 

New Jersey Youth Corps of Trenton 

New Jersey Youth Corps of Vineland 

Student Conservation Association (New Jersey 

Regional office) 

NEW MEXICO 

Rocky Mountain Youth Corps 

Santa Fe Youth Works 

Southwest Conservation Corps Ancestral Lands 

(Pueblo of Acoma & Shiprock) 

NEW YORK 

Adirondack Corps (SCA) 

Excelsior Conservation Corps 

Green City Force 

Hudson Valley Corps (SCA) 

Bronx Justice Corps 

Harlem Justice Corps 

Brooklyn NY Justice Corps 

Queens Justice Corps 

1275 K Street, NW, Suite 1050, Washington, DC 20005 p: 202.737.6272 f: 202.737.6277 
286 

Æ 

The CorpsNetwork 

Strengthening America through 

service and cone:ervation 

New York Restoration Project 

Headwaters Youth Conservation Corps (a program 

of The Place) 

Onondaga Earth Corps 

The Service Collaborative ofWcstcm New York 

Student Conservation Association (New York City) 

NORTH CAROLINA 

ACE (American Conservation Experience) 

Northwest Piedmont Service Corps 

OHIO 

WSOS Community Action 

OREGON 

Heart of Oregon Corps 

Northwest Youth Corps 

PENNSYLVANIA 

PowcrCorps PHL 

Student Conservation Association 

(Philadelphia/Camden Regional office) 

Student Conservation Association (Pittsburgh 

Regional office) 

SOUTH CAROLINA 

TI1c Sustainability Institute Energy Conservation 

Corps 

TENNESSEE 

CAC AmcriCorps 

Soud1east Youth Corps 

TEXAS 

American Youth Works Texas Conservation Corps 

Student Conservation Association (Houston 

Regional Office) 

www.corpsn etwork. org 

UTAH 

ACE (American Conservation Experience) (Salt 

Lake City & St. George) 

Canyon Country Youth Corps 

Utah Conservation Corps 

VERMONT 

Green Mountain Club 

V emwnt Youth Conservation Corps 

VIRGINIA 

Student Conservation Association (HQ) 

WASHINGTON 

Eard1Corps 

Mt. Adams Institute 

Student Conservation Association (Seattle Regional 

Office) 

Washington Conservation Corps 

WEST VIRGINIA 

Citizens Conservation Corps ofWest Virginia 

WISCONSIN 

ADVOCAP (Fresh Start program) 

Great Lakes Community Conservation Corps 

Milwaukee Community Service Corps 

Operation Fresh Start 

Renewal Unlimited, Inc. (Fresh Start program) 

Student Conservation Association (Milwaukee 

Regional office) 

WisCorps -Wisconsin Conservation Corps 

WYOMING 

Wyoming Conservation Corps 

CC: The Honorable Tom Vilsack, Secretary, US Department of Agriculture 

The Honorable Sally Jewell, Secretary, US Department of the Interior 

The Honorable Robert Bonnie, Under Secretary of Natural Resources and Environment, US 

Department of Agriculture 

The Honorable Tom Tidwell, Chief, U.S. Forest Service 

Christy Goldfuss, Managing Director, White House Council on Environmental Quality 

1275 K Street, NW, Suite 1050, Washington, DC 20005 p: 202.737.6272 f: 202.737.6277