U.S. GOVERNMENT PUBLISHING OFFICE

36–422 WASHINGTON : 2019

AIR QUALITY IMPACTS OF WILDFIRES: 

MITIGATION AND MANAGEMENT STRATEGIES 

HEARING 

BEFORE THE

SUBCOMMITTEE ON ENVIRONMENT 

OF THE

COMMITTEE ON ENERGY AND 

COMMERCE 

HOUSE OF REPRESENTATIVES 

ONE HUNDRED FIFTEENTH CONGRESS 

SECOND SESSION 

SEPTEMBER 13, 2018 

Serial No. 115–165 

( 

Printed for the use of the Committee on Energy and Commerce 

energycommerce.house.gov 

(II) 

COMMITTEE ON ENERGY AND COMMERCE 

GREG WALDEN, Oregon 

Chairman 

JOE BARTON, Texas 

Vice Chairman 

FRED UPTON, Michigan 

JOHN SHIMKUS, Illinois 

MICHAEL C. BURGESS, Texas 

MARSHA BLACKBURN, Tennessee 

STEVE SCALISE, Louisiana 

ROBERT E. LATTA, Ohio 

CATHY MCMORRIS RODGERS, Washington 

GREGG HARPER, Mississippi 

LEONARD LANCE, New Jersey 

BRETT GUTHRIE, Kentucky 

PETE OLSON, Texas 

DAVID B. MCKINLEY, West Virginia 

ADAM KINZINGER, Illinois 

H. MORGAN GRIFFITH, Virginia 

GUS M. BILIRAKIS, Florida 

BILL JOHNSON, Ohio 

BILLY LONG, Missouri 

LARRY BUCSHON, Indiana 

BILL FLORES, Texas 

SUSAN W. BROOKS, Indiana 

MARKWAYNE MULLIN, Oklahoma 

RICHARD HUDSON, North Carolina 

CHRIS COLLINS, New York 

KEVIN CRAMER, North Dakota 

TIM WALBERG, Michigan 

MIMI WALTERS, California 

RYAN A. COSTELLO, Pennsylvania 

EARL L. ‘‘BUDDY’’ CARTER, Georgia 

JEFF DUNCAN, South Carolina 

FRANK PALLONE, JR., New Jersey 

Ranking Member 

BOBBY L. RUSH, Illinois 

ANNA G. ESHOO, California 

ELIOT L. ENGEL, New York 

GENE GREEN, Texas 

DIANA DEGETTE, Colorado 

MICHAEL F. DOYLE, Pennsylvania 

JANICE D. SCHAKOWSKY, Illinois 

G.K. BUTTERFIELD, North Carolina 

DORIS O. MATSUI, California 

KATHY CASTOR, Florida 

JOHN P. SARBANES, Maryland 

JERRY MCNERNEY, California 

PETER WELCH, Vermont 

BEN RAY LUJA ́ N, New Mexico 

PAUL TONKO, New York 

YVETTE D. CLARKE, New York 

DAVID LOEBSACK, Iowa 

KURT SCHRADER, Oregon 

JOSEPH P. KENNEDY, III, Massachusetts 

TONY CA ́ RDENAS, CaliforniaL RUIZ, 

California 

SCOTT H. PETERS, California 

DEBBIE DINGELL, Michigan 

SUBCOMMITTEE ON ENVIRONMENT

JOHN SHIMKUS, Illinois 

Chairman 

DAVID B. MCKINLEY, West Virginia 

Vice Chairman 

JOE BARTON, Texas 

TIM MURPHY, Pennsylvania 

MARSHA BLACKBURN, Tennessee 

GREGG HARPER, Mississippi 

PETE OLSON, Texas 

BILL JOHNSON, Ohio 

BILL FLORES, Texas 

RICHARD HUDSON, North Carolina 

KEVIN CRAMER, North Dakota 

TIM WALBERG, Michigan 

EARL L. ‘‘BUDDY’’ CARTER, Georgia 

JEFF DUNCAN, South Carolina 

GREG WALDEN, Oregon (ex officio) 

PAUL TONKO, New York 

Ranking Member 

RAUL RUIZ, California 

SCOTT H. PETERS, California 

GENE GREEN, Texas 

DIANA DEGETTE, Colorado 

JERRY MCNERNEY, California 

TONY CA ́ RDENAS, California 

DEBBIE DINGELL, Michigan 

DORIS O. MATSUI, California 

FRANK PALLONE, JR., New Jersey (ex 

officio) 

(III) 

C O N T E N T S 

Page 

Hon. John Shimkus, a Representative in Congress from the State of Illinois, 

opening statement ................................................................................................ 1 

Prepared statement .......................................................................................... 3 

Hon. Paul Tonko, a Representative in Congress from the State of New York, 

opening statement ................................................................................................ 4 

Hon. Greg Walden, a Representative in Congress from the State of Oregon, 

opening statement ................................................................................................ 15 

Prepared statement .......................................................................................... 16 

Hon. Frank Pallone, Jr., a Representative in Congress from the State of 

New Jersey, opening statement .......................................................................... 27 

WITNESSES

Herman Baertschiger Jr., Senator, Oregon State Senate .................................... 6 

Prepared statement .......................................................................................... 8 

Answers to submitted questions ...................................................................... 198 

Mary Anderson, Mobile and Area Source Program Manager, Air Quality 

Division, Idaho Department of Environmental Quality .................................... 17 

Prepared statement .......................................................................................... 20 

Answers to submitted questions ...................................................................... 202 

Sonya Germann, State Forester, Montana Department of Natural Resources 

and Conservation, Forestry Division .................................................................. 28 

Prepared statement .......................................................................................... 30 

Answers to submitted questions ...................................................................... 207 

Collin O’Mara, President, National Wildlife Federation ...................................... 42 

Prepared statement .......................................................................................... 45 

Answers to submitted questions ...................................................................... 210 

Tom Boggus, State Forester, Director of Texas A&M Forest Service ................. 50 

Prepared statement .......................................................................................... 52 

Answers to submitted questions ...................................................................... 214 

SUBMITTED MATERIAL

Report entitled, ‘‘Prescribed Fire in North American Forest and Woodlands,’’ 

The Ecological Society of America, 2012 ............................................................ 86 

Report entitled, ‘‘Prescribed Fire Policy Barriers and Opportunities,’’ University of Oregon, 2018 ............................................................................................. 96 

Article entitled, ‘‘The Impact of Anthropogenic Climate Change on Wildfire 

Across Western U.S. Forests,’’ National Academy of Sciences, October 18, 

2016 ....................................................................................................................... 132

Article entitled, ‘‘Future Fire Impacts on Smoke Concentrations, Visibility, 

and Health in the Contiguous United States,’’ GeoHealth, 2018 ..................... 138 

Article entitled, ‘‘We won’t stop California’s wildfires if we don’t talk about 

climate change,’’ Washington Post editorial board, August 8, 2018 ................ 157 

Article entitled, ‘‘Trump Inaccurately Claims California is Wasting Waters 

as Fires Burn,’’ New York Times, August 6, 2018 ............................................ 159 

Article entitled, ‘‘Fueled by Climate Change, Wildfires Erode Air Quality 

Gains,’’ Scientific American, July 17, 2018 ........................................................ 163 

Article entitled, ‘‘Megafires: The growing risk to America’s forests, communities, and wildlife,’’ National Wildlife Federation, October 2017 ................... 174 

(1) 

AIR QUALITY IMPACTS OF WILDFIRES: 

MITIGATION AND MANAGEMENT STRATEGIES 

THURSDAY, SEPTEMBER 13, 2018 

HOUSE OF REPRESENTATIVES, SUBCOMMITTEE ON ENVIRONMENT, COMMITTEE ON ENERGY AND COMMERCE

Washington, DC. 

The subcommittee met, pursuant to call, at 1:15 p.m., in room 

2123, Rayburn House Office Building, Hon. John Shimkus, (chairman of the subcommittee) presiding. 

Present: Representatives Shimkus, McKinley, Harper, Johnson, 

Flores, Hudson, Walberg, Carter, Duncan, Walden (ex officio), 

Tonko, Ruiz, Peters, DeGette, McNerney, Ca ́ rdenas, Matsui, and 

Pallone (ex officio). 

Staff Present: Samantha Bopp, Staff Assistant; Karen Christian, 

General Counsel; Kelly Collins, Legislative Clerk, Energy and Environment; Wyatt Ellertson, Professional Staff, Energy and Environment; Margaret Tucker Fogarty, Staff Assistant; Theresa 

Gambo, Human Resources/Office Administrator; Jordan Haverly, 

Policy Coordinator, Environment; Mary Martin, Chief Counsel, Energy and Environment; Sarah Matthews, Press Secretary, Energy 

and Environment; Drew McDowell, Executive Assistant; Brannon 

Rains, Staff Assistant; Peter Spencer, Senior Professional Staff 

Member, Energy; Austin Stonebraker, Press Assistant; Hamlin 

Wade, Special Advisor, External Affairs; Everett Winnick, Director 

of Information Technology; Jean Fruci, Minority Energy and Environment Policy Advisor; Caitlin Haberman, Minority Professional 

Staff Member; Rick Kessler, Minority Senior Advisor and Staff Director, Energy and Environment; Alexander Ratner, Minority Policy Analyst; and Catherine Zander, Minority Environment Fellow. 

OPENING STATEMENT OF HON. JOHN SHIMKUS, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF ILLINOIS 

Mr. SHIMKUS. I am going to call the committee to order and 

make a brief statement before I give my opening statement, is that 

we will have the chairman and the ranking member both come in 

their due time, and then we will break and allow them to do their 

opening statements. At least we can get started on time, if that is 

agreeable with everybody, which it seems like it is. 

I now recognize myself 5 minutes for an opening statement. 

A year ago, we took testimony to examine the air quality impacts 

of wildfires with the focus on stakeholder perspectives. Given the 

community’s jurisdiction over air quality policies and public health, 

the goal then, as it is today, was to develop a better understanding 

2 

of the health impacts of wildfires and what should be done to minimize those impacts. 

We return to the topic this afternoon to look closely at the mitigation and management strategies for reducing air quality risks 

from wildfire smoke. In large part, these strategies involve efforts 

to reduce the intensity and frequency of wildfires that threaten 

communities. 

The strategies also involve managing the inevitable smoke impacts, whether from wildfires or from what is known as prescribed 

burning. And they involve ensuring that effective actions are credited appropriately in air quality planning, air quality monitoring, 

and compliance activities, so States and localities are not punished 

for taking action that will improve public health. 

Last year, some 10 million acres were burned in the United 

States by wildfires, the second worst fire season since 1960. As of 

last week, this fire season has resulted in more than 7 million 

acres burned, with acute impacts of smoke lingering for extended 

periods of time throughout California and the Pacific Northwest. 

The urgency for reducing the severity of these fires is underscored by news reports and reports from this committee’s own 

members, including Chairman Walden, of the impacts of wildfire 

smoke. This smoke can smother communities with high levels of 

particulate matter and other respiratory irritants. These levels, 

which are manyfold over normal air quality, intensify asthma and 

chronic pulmonary diseases, and impact the lives of millions of people. 

Against this backdrop are a panel of witnesses who can speak to 

the complex set of strategies that are needed to more effectively address wildfires and smoke risks. 

We will hear today from two State foresters who oversee and implement fire management strategies in their States: Sonya 

Germann from the Montana Department of Natural Resources and 

Conservation, Tom—I hope this—Boggus. 

Mr. BOGGUS. Boggus. 

Mr. SHIMKUS. Boggus. Thank you. Bogus was a word we used at 

West Point. Boggus is better, so—the Texas State Forester and Director of Texas A&M Forest Service. 

While the general approaches among State forestry officials to 

mitigating risks are consistent, there are regional differences that 

affect what is put into practice and can inform future policymakers. 

We will hear a State air quality perspective. Mary Anderson, 

who is with the Idaho Department of Environmental Quality, can 

help us understand the practical challenges of managing wildfire 

smoke and how her agency works to address air quality risks. 

Collin O’Mara, President of the National Wildfire Federation, has 

been before the committee before, brings an environmental perspective, but is also experienced as a former head of the State of Delaware’s Department of Natural Resources and Environment Control. 

And finally, we will hear from Oregon State Senator Herman 

Baertschiger from southern Oregon, who has extensive experience 

in forestry and wildland firefighting. I am looking forward to his 

perspective on what to do and his perspective on the impacts of 

wildfires on his constituents. 

3 

Let me welcome the panelists. I look forward to understanding 

the challenges and the opportunities you face and what you can do 

to ensure our Federal air regulations accommodate these strategies. 

And with my remainder of time, I would like to yield to the gentleman of Texas, Mr. Flores. 

[The prepared statement of Mr. Shimkus follows:] 

PREPARED STATEMENT OF HON. JOHN SHIMKUS

A year ago, we took testimony to examine the air quality impacts of wildfires, 

with a focus on stake holder perspectives. Given the Committee’s jurisdiction over 

air quality policies and public health, the goal then, as it is today, was to develop 

a better understanding of the health impacts of wildfires and what should be done 

to minimize those impacts. 

We return to the topic this afternoon, to look closer at the mitigation and management strategies for reducing the air quality risks from wildfire smoke. In large part, 

these strategies involve efforts to reduce the intensity and frequency of wildfires 

that threaten communities. 

The strategies also involve managing the inevitable smoke impacts, whether from 

wildfires or from what is known as prescribed burning. And they involve ensuring 

that effective actions are credited appropriately in air quality planning, air quality 

monitoring, and compliance activities, so states and localities are not punished for 

taking action that will improve public health. 

Last year, some 10 million acres were burned in the United States by wildfires, 

the second worst fire season since 1960. As of last week, this fire season has resulted in more than 7 million acres burned, with acute impacts of smoke lingering 

for extended periods of time, throughout California and the Pacific Northwest. 

The urgency for reducing the severity of these fires is underscored by news reports—and reports from this Committee’s own members, including Chairman Walden—of the impacts of wildfire smoke. This smoke can smother communities with 

high levels of particulate matter and other respiratory irritants. These levels, which 

are many-fold over normal air quality, intensify asthma and chronic pulmonary diseases, and impact the daily lives of millions of people. 

Against this backdrop, our panel of witnesses can speak to the complex set of 

strategies that are needed to more effectively address wildfires and smoke risks. 

We will hear today from two state foresters, who oversee and implement fire management strategies in their States. Sonya Germann, from the Montana Department 

of Natural Resources and Conservation and Tom Boggus, the Texas State Forester 

and Director of the Texas A&M Forest Service. While the general approaches among 

state forestry officials to mitigating risks are consistent, there are regional differences that affect what is put into practice and can inform future policymaking. 

We will hear a state air quality perspective. Mary Anderson, who is with the 

Idaho Department of Environmental Quality, can help us understand the practical 

challenges of managing wildfire smoke, and how her agency works to address air 

quality risks. 

Collin O’Mara, President of the National Wildlife Federation, brings an environmental perspective but also experience as the former head of the State of Delaware’s 

Department of Natural Resources and Environmental Control. 

And finally, we will hear from Oregon State Senator Herman Baertshiger, from 

southern Oregon, who has extensive experience in forestry and wildland firefighting. 

I’m looking forward to his perspective on what to do, and his perspective on the impacts of wildfires on his constituents. 

Let me welcome the panelists. I look forward to understanding the challenges and 

opportunities you face, and what we can do to ensure our Federal air regulations 

accommodate these strategies. 

Mr. FLORES. So thank you, Mr. Chairman, for yielding me a part 

of your time, and thank you for holding today’s important hearing. 

I am pleased to welcome my constituent, Mr. Tom Boggus, to today’s hearing. He is testifying on behalf of the National Association 

of State Foresters. Mr. Boggus is a native of Fort Stockton, Texas, 

and he joined the Texas A&M Forest Service in 1980. He was appointed as the director and State forester of the Texas A&M Forest 

4 

Service in February of 2010, and he has extensive familiarity with 

the issue we are going to be discussing today. 

I look forward to hearing from him, along with the rest of our 

expert witnesses, on how we can appropriately manage our forests 

to minimize wildfire impacts. 

Thank you, and I yield back. 

Welcome, Mr. Boggus. 

Mr. SHIMKUS. The gentleman yields back his time. 

The chair now recognizes the ranking member of the subcommittee, Mr. Tonko, for 5 minutes. 

OPENING STATEMENT OF HON. PAUL TONKO, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF NEW YORK 

Mr. TONKO. Thank you, Mr. Chair. And thank you to our witnesses for being here this afternoon. 

As some of you may remember, this subcommittee held a similar 

hearing last year on wildfires and air quality issues. Since that 

time, we confirmed that, in 2017, more than 66,000 wildfires 

burned approximately 10 million acres. 2018 is proving to be another difficult year. Right now, there are over 80 active fires covering over a million acres and threatening people’s health and safety and property, including the Mendocino Complex fire, the largest 

recorded fire in California’s history. 

Undeniably, these fires have become increasingly worse in recent 

years. Today, we will hear about the consequences of wildfires to 

both human health as well as forest health. Smoke, which includes 

particulate matter, is harming people, and the growing number and 

size of these fires are erasing the gains that have been made under 

the Clean Air Act in reducing fine particulate matter pollution. 

We will also hear about the best practices in forest management, 

including prescribed burns and other tools, that can mitigate some 

of the worst impacts of these fires and reduce the harm of smoke. 

While I do not follow this issue as closely as many of our western 

colleagues, my understanding is that historically the method for 

funding the United States Forest Service emergency fire response 

has been a major factor in limiting funding for more proactive forest management activities. 

In March, Congress passed the fiscal year 2018 omnibus appropriations bill, which included a fire funding fix that will take effect 

in fiscal year 2020. I acknowledge that more may need to be done 

to promote better forest management techniques, but we must see 

how this fix plays out before adopting new major provisions that 

undermine environmental laws in our national forests. 

As we discuss the devastation that can be caused by Mother Nature, we must also acknowledge our fellow Americans that are facing down Hurricane Florence. Whether it is hurricanes on the East 

Coast or fires out west, we are experiencing more frequent and 

costly natural disasters across our country. As with hurricanes, climate change creates conditions that make wildfires worse. 

Droughts, dryer soils, and higher temperatures, all associated with 

climate change, are resulting in a longer fire season and causing 

an increase in the severity and frequency of wildfires. 

A 2016 study published in the Proceedings of the National Academy of Sciences concluded that human-caused climate change is reVerDate Nov 24 2008 11:48 May 24, 2019 Jkt 037690 PO 00000 Frm 00008 Fmt 6633 Sfmt 6633 U:\MY DOCS\HEARINGS 115\HEARINGS\115-165 CHRIS
5 

sponsible for the doubling of the area burned by wildfires since 

1984. In 2017, the National Wildfire Federation, which is represented here today by NWF President Collin O’Mara, released a 

report entitled Megafires, which examined how climate change and 

other issues, including the funding issues at the United States Forest Service, are contributing to this growing problem. 

I appreciate our witnesses being here to discuss the consequences 

of wildfires, air quality being chief among them, as well as some 

of the potential mitigation options such as more proactive forest 

management. But we do ourselves a disservice if we continue to 

hold hearings only looking at the effects of these fires while ignoring the underlying causes, including climate change that will continue to exacerbate this problem. 

Thank you again, Mr. Chair, and I yield the remainder of my 

time to my good friend and colleague, Representative Matsui of 

California. 

Ms. MATSUI. Thank you, Ranking Member Tonko, for yielding. 

And I want to thank the witnesses for being here today. 

I appreciate the subcommittee is holding a hearing on this important issue. California has had a historic year for fire. The 

Mendocino Complex fire consumed over 410,000 acres, burning for 

more than a month, and becoming the largest in our State’s history. The Ferguson Fire took the lives of two brave firefighters and 

closed Yosemite National Park for 20 days. And the Carr Fire destroyed over 1,000 homes near Redding, north of my district. 

While my district was fortunate and did not directly endure a 

wildfire this summer, Sacramento residents still had to contend 

with the smothering impacts of wildfire smoke. We had a recordbreaking streak of 15 consecutive spare-the-air days when air quality was so poor that our air district encouraged people to stay inside and reduce pollution in any way possible. 

If we don’t take meaningful steps to reduce the risk and intensity 

of wildfires, then we will continue to face these overwhelming 

health, safety, and environmental challenges. That means we must 

adopt a sustainable approach to wildfire risk reduction. Management policies must recognize the impacts of climate change and the 

need to sustainably reduce the fuel load in our forests, ultimately 

moving their condition towards the pre-fire exclusion baseline. 

Thank you, and I look forward to hearing the testimony from our 

witnesses. 

I yield back. 

Mr. TONKO. And I yield back our remaining 8 seconds. There you 

go. 

Mr. SHIMKUS. The gentleman yields back his time. 

The chairman is running over here. The ranking member, I can 

see, is still on the floor. So we will begin with our witnesses and 

then interrupt as we can. 

We want to thank you all for being here today, taking the time 

to testify before the subcommittee. Today’s witnesses will have the 

opportunity to give opening statements followed by a round of 

questions from members. Our witness panel—and I have already 

announced the panel. So I would like now to turn to Mr. 

Baertschiger, Oregon State Senator. And I am sure Congressman 

6 

Walden from Oregon will get here for most of your opening statement. 

You are recognized for 5 minutes. 

STATEMENT OF HERMAN BAERTSCHIGER JR., SENATOR, OREGON STATE SENATE; MARY ANDERSON, MOBILE AND AREA 

SOURCE PROGRAM MANAGER, AIR QUALITY DIVISION, 

IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY; SONYA 

GERMANN, STATE FORESTER, MONTANA DEPARTMENT OF 

NATURAL RESOURCES AND CONSERVATION, FORESTRY DIVISION; COLLIN O’MARA, PRESIDENT, NATIONAL WILDLIFE 

FEDERATION; AND TOM BOGGUS, STATE FORESTER, DIRECTOR OF TEXAS A&M FOREST SERVICE 

STATEMENT OF HERMAN BAERTSCHIGER JR. 

Mr. BAERTSCHIGER. Thank you, Chairman Shimkus, Ranking 

Member Tonko, and members of the committee. Thank you for letting me have the opportunity to testify before you today about 

wildfires and their impact on my constituents and the people of Oregon. 

The lingering effects of smoke and large fires impact thousands 

of people in my State every year. Immediate suppression of 

wildland fires during peak fire season would alleviate the impacts 

to our communities. In exchange for a suppression model, we must 

be conscious of the fact that our forests still need management, and 

fire is one of those management tools. But this can be accomplished 

outside of fire season by controlled burning. Smoke from controlled 

burns is far less impactful to my constituents than these large fires 

during the summer months. 

Other management activities, including commodity production, 

logging, fuel reduction, are also effective in reducing the risk of severe fire. 

My name is Herman Baertschiger, and I am an Oregon State 

Senator representing southern Oregon. My background is in forestry and wildland firefighting. In more than four decades of firefighting in the west, I have never seen a catastrophic high-intensity wildfire benefit our forests. However, I have seen many examples of low-intensity fire benefit our forests. 

Fire has always been with us, and that is not going to change, 

likely. Large fires have affected the American people throughout 

our history. The fires of 1910 in Idaho, Montana, and Washington 

that burned 3 million acres changed how the U.S. Forest Service 

addressed fires. In Oregon, the Tillamook fires that occurred in the 

coast range four times between 1933 and 1951 forced Oregon also 

to address wildland fires. This approach is what, at times, is having us fighting large fires rather than suppressing small fires. 

The aggressive fire suppression model changed about 30 years 

ago with the U.S. Forest Service. It changed from a fire suppression to a fire management. The comparison of fire suppression 

against fire management is best shown in a comparison of firefighting divisions of Oregon Department of Forestry and the U.S. 

Forest Service. 

Oregon Department of Forestry has always employed an aggressive initial attack and suppression approach. The comparison of 

7 

lands managed shows a shocking disparity between the two styles 

of firefighting. The U.S. Forest Service protects about 17 million 

acres of Oregon forestlands. And so far in 2018, 300,000 of those 

acres have burned. Oregon Department of Forestry protects about 

16 million acres of forestlands in Oregon, and so far, only 70,000 

of those acres have burned. 

The two agencies protect about the same number of acres in Oregon but are having very different outcomes. 

Also, the human factor can’t be ignored. With over 300 million 

people in this country, we should expect more human-caused fire 

starts. Some people say that 9 out of 10 fires have a human element. 

Due to severe wildfires, the lack of forest management and the 

different approach to firefighting, our communities have suffered 

weeks from toxic smoke. This year’s citizens in southern Oregon 

endured 34 days of unhealthy air quality, and Travel Oregon estimated last year that $51 million was lost from smoke in tourism 

dollars. The Shakespeare festival in Ashland has lost over $2 million this year; Hell’s Gate excursion, $1.5 million. Smoke has led 

to cancellation and delays of school activities, church activities, and 

other events. 

To provide our citizens with relief from catastrophic wildfire, 

Congress should take action to promote active forest management 

and provide oversight and assure accountability over the U.S. Forest Service. 

Managing fire during peak fire season to treat fuels is no longer 

acceptable. We cannot manage our forests during peak fire season 

with fire at the expense of the health and welfare and the economic 

viability of our communities. We have got to do something else. 

I appreciate this opportunity to testify, and I welcome any questions that you may have. 

[The prepared statement of Mr. Baertschiger follows:] 

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TESTIMONY OF OREGON STATE SENATOR HERMAN BAERTSCHIGER, JR. 

BEFORE THE HOUSE COMMITTEE ON ENERGY AND COMMERCE 

SUBCOMMITTEE ON THE ENVIRONMENT 

September 13, 2018 

Chairman Shimkus, Chairman Walden, and Ranking Member Pallone, thank you for the 

opportunity to testify before you today about wildfires and their impact on the constituents of my 

district and all of Oregon. The lingering effects of smoke from large forest fires impact 

thousands of people every year. Congress Walden and I have toured the wildfires together and 

have seen and experienced the devastation these wildfires have on our communities. Immediate 

suppression of wildland fires during peak fire season would alleviate the impacts to our 

communities, their health and their economic viability. In exchange for a suppression model we 

must be conscious of the fact that our forests still need management and fire is one of those 

management tools. This can be accomplished outside of fire season by controlled burning, smoke 

from controlled burns is far less impactful to the communities than those of large fires during fire 

season. 

My name is Herman Baertschiger, Jr. and I am an Oregon State Senator representing 

Southern Oregon. My background is in forestry and wildland fircfighting. For 16 years I have 

been a wildland fire training instructor and I have been certified through the Oregon Department 

of Forestry as a National Type 3 Incident Commander and this year is my 41" fire season. In 

more than four decades of fighting fire from Washington to Montana, from California to 

Colorado, I have never seen a catastrophic wildfire benefit our forests. 

Fire has always been with us and that is not likely to change, what has changed is the way 

we react to fire. Large fires have afiected the American people for nearly two hundred years, in 

1825, when the Great Miramichi Fire in New Brunswick burned over 3 million acres and killed 
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160 people. In 1871 the Peshtigo Fire in Wisconsin burned 1.2 million acres and killed 1,182 

people. On the same day in 1871 in Illinois, Mrs. O'Leary's cow knocked over a lantern and 

started the Great Chicago Fire that killed htmdreds and burnt half the City of Chicago. The fires 

of 1910 in Idaho, Montana and Washington that burned 3 million acres changed how the US 

Forest Service addressed fires. In Oregon the Tillamook forest fires that occurred four times 

between 193 3 and 1951 forced Oregon to address wildfire also. Five of the last six years have 

seen enormous fires, in excess of the ten-year average. In 20 18 we are fighting fires in the same 

area that we fought them in the previous year. To say that climate changes is the cause of 

catastrophic wildfires is incorrect. Our approach and management of the fires and the smoke they 

produce is what has changed in the last twenty years. This approach is what has us fighting large 

tires, rather than suppressing small tires. 

After the Western fires of 1910, the US Forest service adopted a model of tire 

suppression. In the industry we have always referred to this with the term "out by 10", meaning 

that once a tire had started, it would receive whatever resources and attention needed to put it out 

by I 0 AM the following morning. This aggressive fire suppression changed about twenty years 

ago to a fire management model. Today the US Forest Service often manages fire along with 

their suppression efforts. 

The human factor can't be ignored when looking at the problem of wildland tires. In 

1910 the US population was 92 million. In 20 l 0, one hundred years later, it was 310 million. 

With a tripling of the population, we should expect more human caused tire starts. Recently the 

Oregon Department of Forestry estimated that the number of acres burned by human caused tires 

in the last ten years has doubled. With increases in tire starts, we should expect increases in lire 

severity, and increases in smoke effects from those fires. 

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The comparison of fire suppression against fire management is best shown in the 

comparison ofthe firefighting divisions of the Oregon Department of Forestry (ODF) and the US 

Forest Service (USPS). ODF has always employed an aggressive initial attack and suppression 

approach to wildfire. The USPS had a similar approach until about the mid-1980's. Now thirty 

years later, the comparison of lands managed, and acres burned shows a shocking disparity 

between the two styles of firefighting. The USFS protects 17 million acres(+/-) of Oregon forest 

lands. In 2018, 300,000 acres of those protected forests were burned. ODF protects 16 million 

acres(+/-) of Oregon forest lands. In 2018,70,000 acres of those protected forests were burned 

(these arc estimates as the 2018 Fire Season is not complete). 

These two agencies protect about the same number of acres of forest in Oregon but are 

having very different outcomes from their firefighting efforts. Another consideration is the 

impact on private landowners, in 2018 more than 3 3,000 acres of private land has burned by fires 

that started on federal lands. 

Impacts of wildfire and smoke to our communities 

Due to severe wildfires, the lack of active forest management and the U.S. Forest 

Service's current approach to firefighting, our communities have suffered from weeks of toxic 

wildfire smoke. As of Aug. 30, citizens in southern Oregon's Rogue Valley endured 24 days of 

"unhealthy" to "very unhealthy" air quality. This is the longest period of unhealthy air quality in 

the Rogue Valley since the Environmental Protection Agency began keeping air quality index 

records in 2000. 

Travel Oregon estimated the state lost about $51 million in tourism revenue from 

wildfires and smoke last year, and this year's wildfire season will likely bring greater losses. Last 

month's wildfires forced airlines at the Rogue Valley Airport to cancel multiple flights and put 

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delays on others. The smoke has created havoc and devastation for many businesses connected to 

Southern Oregon's vital Travel and Tourism Industry. The Oregon Shakespeare Festival in 

Ashland has already canceled more shows this year than it did in all of 2017. These are the first 

two years in a row that the festival has had to cancel multiple performances because of smoke. In 

2018 the festival has lost over $2 million dollars, with over 20 performances canceled. Britt 

Festivals has moved its orchestra rehearsals and some performances from its hillside, Britt 

Pavilion amphitheater in Jacksonville, to the North Medford High School auditorium, which 

downsized their attendance ti·om 2,200 attendees in auditorium to an 800-person capacity. The 

Rogue Valley Softball Association Fall Classic softball tournament was cancelled, marking the 

second consecutive year it's been called off. The wildfires and smoke have hanned our seasonal 

tourism businesses with many reporting 40% decreases in attendance, some as high as 80% 

lower attendance. Sections of the Rogue River have been closed at times, impacting those who 

are dependent on rafting and fishing. For July, Crater Lake was down on visitation by 22%, 

which represents over 50,000 people. Locally, the wildfire smoke led to cancellations or delays 

of school athletics, church activities and other events. 

These smoky summers continue to tax our public health resources and health care system. 

In past years. local emergency departments reported an increase of patients suffering from 

extremely sore throats, headaches, burning eyes and significant respiratory distress. 

Suggested Solutions. 

To provide our citizens relief from catastrophic wildfires and smoke, Congress should 

take action to promote active forest management and provide oversight and assure accountability 

over U.S. Forest Service wildfire management activities. 

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There is abundant science supporting the benefits of management activities- including 

logging, thinning and controlled burning- to improving the health and resiliency of our forests. 

According to the U.S. Forest Service's Fuels Treatment Effectiveness Database, 90 percent of 

fuels reduction projects were effective in reducing wildfire severity. 1 Researchers from the 

University of Montana found that comprehensive treatment prescriptions designed to restore 

sustainable ecological conditions can move 90 percent of treated acres into a low-hazard 

condition. 2 

Despite these benefits, federal agencies are failing to treat fire-prone forests at a pace and 

scale necessary to change the trend of larger and more severe fires. As much as 80 million acres 

of National Forests System lands are at a high, to very high, risk of catastrophic wildfire. And 

the Forest Service is only treating between I and 2 percent of high risk acres per year. That's 

why congressional action is needed to address the three primary barriers to active forest 

management on federal lands: 

The first barrier to active fiJrest management is the lack o([unding to prepare f(Jrest 

proiects and timber sales. The U.S. Forest Service often lacks the funding and personnel to 

develop and implement projects that reduce the risks of wildfires, insects and disease. Today 

more than half of the agency's budget is consumed by escalating wildfire suppression costs, 

which itself is due to the lack of management on our overgrown and fire-prone federal forests. 

The U.S. House of Representatives addressed this barrier by approving the Consolidated 

Appropriations Act of2018 ("Omnibus"), which provides a new disaster cap allocation for 

wildfire suppression beginning in 2020. This will end the practice of "tire borrowing" that has 

1 USFS, Adaptive Management Services Enterprise Team, Fuels Treatment Effectiveness Database 

( fs. fed. us/adaptivemanagemcnt) 2 C. Keegan, C. Fiedler, T. Morgan. Wildfire in Montana: Potential hazard reduction and economic effects of a 

strategic treatment program, Forest Products Journal, July/August 2004) 

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forced the Forest Service to temporarily redirect funds away from preventative forest health 

programs. I also applaud the U.S. House for increasing funding for the Forest Service's 

Hazardous Fuels line items in the omnibus spending bill, and for increasing funding for the 

agency's timber sale program in the House Interior Appropriations package for FY 2019. If 

enacted, the House level would represent a 20 percent increase in the timber program since FY 

2013. The House Report urges the Forest Service to offer a 4 Billion Board Foot sale program, a 

level that hasn't been reached in a quarter century. 

The second barrier to active forest management is the significant cost and time it takes 

for {ederal agencies to satisfY environmental analysis and compliance requirements. At a time 

when the Forest Service struggles to fund wildfire suppression activities, the agency spends more 

than $356 million annually just to satisfy National Environmental Policy Act (NEPA) analysis 

and compliance requirements on forest management projects3 It can take Forest Service 

personnel 18 months to four years to satisfy these requirements for a single forest project, and as 

a result they spend 40 percent of their time doing paperwork instead of managing forests. The 

U.S. House addressed this barrier by approving the Resilient Federal Forests Act (H.R. 2936), 

and by approving strong provisions in the Agriculture and Nutrition Act of20!8 (H.R. 2), known 

as the Farm Bill. Both measures provide our land management agencies with expanded 

categorical exclusions under NEPA to expedite treatments on forests that are at immediate risk of 

wildfire, insects and disease, and to protect municipal watersheds. Providing these NEP A 

efficiencies will help reduce the cost and time required to plan forest projects, and will provide 

and direct more resources toward improving the health of our forests. 

3 Feasibility Study of Activities Related to National Environmental Policy Act (NEPAl Compliance in the US Forest 

Service- Final Report, USDA Forest Service Competitive Sourcing Program Office Washington, DC. Available at 

https:/ lwww.peer.org/assets/docslfs/08 _ 14 _I_ nepa _feasibility _study. pdf 

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The third (actor is the obstruction and litigation that typically stalls much o(the ;vork 

that needs to be done on our [ederallands. Our federal land agencies are often paralyzed by the 

real and perceived threats of litigation and process obstruction. In U.S. Forest Service Region 1, 

for example, it is estimated litigation has encumbered up to 50 percent of planned timber harvest 

volume and treatment acres. Once again, the U.S. House addressed this barrier by approving 

ll.R. 2936 that prohibits litigant groups from receiving attorney fees when they sue to stop a 

project that is intended to reduce the threats of wildfire and insect infestations. It also requires 

that any court hearing a case regarding a Forest Service action must weigh the benefits of taking 

short-term action versus the potential long-term harm of inaction, SlJch as the threat of 

catastrophic wildfire. As an alternative to costly litigation. the legislation also proposes an 

innovative pilot project to test the use of arbitration to address challenges to certain forest 

management activities. Until environmental litigation is addressed, American taxpayers will 

continue to carry the increased burden of higher firefighting and land management costs, toxic 

smoke, and the continued loss of forests and the benelits they provide. 

Managing wildland fire during peak fire season to treat fuels as a way to manage our 

forests is no longer acceptable. We cannot manage our forests with fire at the expense of the 

welfare and economic viability of our communities. We have to do something else. 

Once again I appreciate the opportunity testify and welcome any questions you may have. 

7 
15 

Mr. SHIMKUS. The gentleman yields back his name. 

The chair now recognizes the chairman of the full committee, another Oregonian, Chairman Walden, for 5 minutes. 

OPENING STATEMENT OF HON. GREG WALDEN, A REPRESENTATIVE IN CONGRESS FROM THE STATE OF OREGON 

Mr. WALDEN. Thank you very much, Mr. Chairman. I apologize 

for being a little late. We had the WRDA bill on the floor where 

a number of our provisions, including Safe Drinking Water Act and 

some provisions for drought relief in the Klamath Basin were before the House, so I needed to speak on that before coming here. 

I want to thank you for holding this hearing, and I want to 

thank our witnesses for being here. 

Today’s hearing focuses on this topic that you have already heard 

from the Senator about, of great concern to Oregonians and those 

across the west who are experiencing terrible air quality. Hazardous, dangerous, unhealthy air quality smoke from these 

wildfires is literally choking people to death. 

In my home State of Oregon alone, we have already seen over 

700,000 acres destroyed by fire. These fires have left communities 

in my district blanketed with smoke and with the worst air quality 

in the world, period. Stop. Medford, Oregon, experienced the worst 

run of unhealthy air quality since the EPA began making such determinations in 2000. 

The leading offender is particulate matter. An article in the New 

England Journal of Medicine in March pointed out the robust evidence linking exposure to particulate matter to cardiopulmonary 

mortality and issues with asthma and COPD. I heard from a 

woman yesterday on a tele-town hall: COPD. She was just getting 

out of the hospital all as a result of this smoke. 

According to EPA research, premature deaths tied to wildfire air 

pollution were as high as 2,500 per year between 2008 and 2012. 

Other research out of Colorado State University suggests it could 

be as high as 25,000 people per year die prematurely because of 

this smoke. This is a life-and-death matter in the west. 

Making matters worse, it is hard to escape the smoke even in 

your own home. Curt in Eagle Point dropped off his air filter from 

his CPAP machine. I have got a picture of it up there. That filter 

is supposed to last for 2 weeks. That is, I believe, 2 days. You can 

see it up there and how dirty it got within 2 days inside his home 

during these fires. 

Or take this car cabin air filter. It was replaced after 2 months 

during the fire season. You can see up on the screen what a new 

one looks like. Two months, that is what it looked like in his car. 

Nearly three decades of poor management have left our Federal 

forests overstocked with trees and vegetation that fuel increasingly 

intense fires. Stepping up active forest management practices such 

as thinning, prescribed fire, and timber harvest, one of the best 

ways we could reduce the fuel loads and, therefore, the impact of 

the smoke from wildfires. 

Sadly, bureaucratic red tape, obstructionist litigation by special 

interest groups, it has all added up to make it very difficult to implement these science-based management techniques that we know 

work. And we are left to choke on the resulting wildfire smoke. 

16 

In 2017, the number of fires started on lands protected by the 

Oregon Department of Forestry and the U.S. Forest Service Land 

were split nearly 50/50. Forest managed lands, however, accounted 

for over 90 percent of the acres burned. So that is the Federal 

ground. This is partly due to forest management but also how fires 

are fought. 

As fires are managed rather than suppressed and back burned 

acreages increased, there is a clear impact on air quality and, 

therefore, on the air quality and health of our citizens. These agencies need to do more to take this into account when they make 

their decisions. 

As devastating as it is in the summer months, fire can also be 

a management tool. We know that. Prescribed fire, after mechanical thinning, can help reduce fuel loads and reduce emissions by 

up to 75 percent, if it is done at the right time and the right way. 

State smoke management plans set the process for these burns 

with an aim to protect public health, but also limit the work that 

gets done. According to Forest Service data, smoke management 

issues limited between 10 and 20 percent of their prescribed fire 

projects last year in Oregon. 

I look forward to hearing from our witnesses today about your 

perspectives on these issues and how we get the right balance. I 

also want to thank Senator Baertschiger for joining us from Oregon. He is the co-chair of the bipartisan fire caucus in Oregon, has 

nearly 40 years of experience in wildland fire and forest management both. So thanks for flying out to be here. 

And just to conclude, I would like to share a message I received 

from Jennifer. She is a mother in Medford, Oregon. Jennifer said: 

As a native Oregonian, living in southern Oregon my entire life, I 

write to express my extreme frustration with Oregon’s lack of forest management. This is now the third or fourth year that we are 

hostages in our own homes, that my children are robbed of being 

able to play outside. I absolutely hate that nothing is done to prevent this from happening. 

Well, we are here to help the concerns I hear from people like 

Jennifer and families across my district who have one simple message: Something needs to change. 

And in conclusion, I just got an email from a friend of mine in 

Medford, who is on the Shakespeare board, the Oregon 

Shakespearian Theater board in Ashland. And they said: I have exciting news. Our safety, health, and wellness manager sent this update. We are officially closing the smoke watch that started back 

on July 18 and returning to normal operations. 

I believe they had to cancel 25 outdoor plays at the Allen Elizabethan, and one for the Bowmer, for a total of 26 cancellations for 

performances. And so this is a real bad thing for the economy. It 

is bad for our health. 

Mr. Chairman, I appreciate your holding this hearing, and I 

thank the witnesses for being here. And I yield back. 

[The prepared statement of Chairman Walden follows:] 

PREPARED STATEMENT OF HON. GREG WALDEN

Today’s hearing focuses on a topic of great concern to Oregonians and those across 

the West who are experiencing terrible air quality and choking on smoke from 

17 

wildfires. In my home state of Oregon alone, we’ve already seen over 700 thousand 

acres destroyed and the fires are still burning. 

These fires have left communities in my district blanketed with smoke and with 

the worst air quality in the world. Medford, Oregon experienced the worst run of 

‘‘unhealthy’’ air quality since EPA began recording in 2000. 

A leading offender is particulate matter. An article in the New England Journal 

of Medicine in March pointed out the robust evidence linking exposure to particulate 

matter to cardiopulmonary mortality and issues with asthma and COPD. According 

to EPA research, premature deaths tied to wildfire air pollution were as high as 

2,500 per year between 2008 and 2012. Other research out of Colorado State University suggest it could be as high as 25,000 people a year. 

Making matters worse, it is hard to escape the smoke, even in your own home. 

Curt in Eagle Point, OR dropped off this air filter from his CPAP machine. He had 

to replace it after 2 days—it is supposed to last 2 weeks. 

Or take this car cabin air filter that was replaced after 2 months during fire season. A new one looks like this. You begin to realize what people are suffering 

through. 

Nearly three decades of poor management has left our Federal forests overstocked 

with trees and vegetation that fuel increasingly intense fire seasons. Stepping up 

active forest management practices, such as thinning, prescribed fire, and timber 

harvests, is one of the best ways to reduce the fuel and the impact of smoke from 

wildfires. 

Sadly, bureaucratic red tape, and obstructionist litigation by special interest 

groups has made it difficult to implement these science-based management techniques. And we’re left to choke on the resulting wildfire smoke. 

In 2017, the number of fire starts on lands protected by the Oregon Department 

of Forestry and those on U.S. Forest Service land were split nearly 50/50. The Forest managed lands, however, accounted for over 90 percent of the acres burned. This 

is partly due to forest management, but also how fires are fought. 

As fires are managed, rather than suppressed, and back burned acreages increase, 

there is a clear impact on air quality and our health. These agencies should do more 

to take that into account. 

As devastating as it is in the summer months, fire can also be a management tool. 

Prescribed fire after mechanical thinning, can help reduce fuel loads and reduce 

emissions by up to 75 percent. State Smoke Management Plans set the process for 

these burns with an aim to protect public health, but also limit the work that gets 

done. According to Forest Service data, smoke management issues limited between 

10 and 20 percent of their prescribed fire projects last year in Oregon. I look forward 

to hearing from our witnesses today on whether these plans properly balance the 

risk from prescribed fire with the risk of far more intense wildfire. 

I also want to thank Senator Herman Baertschiger for joining us from Oregon. 

Senator Baertschiger is co-chair of the bipartisan fire caucus in Oregon, and has 

nearly 40 years of experience in wildland fire and forest management. Thank you 

for your participation and sharing your knowledge with us today. 

Just to conclude, I’d like to share a message I received from Jennifer, a mother 

in Medford. Jennifer said, ‘‘As a native Oregonian living in Southern Oregon my entire life I am writing to express my extreme frustration with Oregon’s lack of forest 

management. This is now the third or fourth year that we are hostages in our own 

homes, that my children are robbed of being able to play outside. I absolutely hate 

that nothing is done to prevent this from happening.’’ 

We are here today to help address the concerns I hear from people like Jennifer 

and families across my district who have one simplemessage: something needs to 

change. 

Mr. SHIMKUS. The gentleman yields back his time. 

The chair now would like to recognize Ms. Mary Anderson, mobile and area source program manager, Air Quality Division, Idaho 

Department of Environmental Quality. 

You are recognized for 5 minutes. 

STATEMENT OF MARY ANDERSON 

Ms. ANDERSON. Thank you for the opportunity to provide some 

insight into how wildfires are impacting Idaho citizens. 

Wildfires are the single largest air pollution source in Idaho. In 

the past, Idaho would experience severe wildfire season with heavy 

18 

localized air quality impacts every 3 to 4 years. Now, we are seeing 

heavy regional air quality impacts every year from large, sometimes catastrophic wildfires in Idaho, central and northern California, Oregon, Washington, Nevada, and British Columbia. These 

catastrophic wildfires caused by fuels that have cumulated as a result of active fire suppression, drought, and climate change. 

In 2017, wildfire smoke caused widespread impacts starting in 

early August. And by the first week of September, smoke thoroughly blanketed all of Idaho, exposing many Idaho citizens to potentially serious health impacts. 

About 700,000 acres were burned in Idaho in 2017. Idaho is also 

surrounded by wildfires, meaning wind from any direction brought 

smoke into the State. Nearly 5.5 million acres burned in neighboring States and British Columbia in 2017. All of these fires had 

direct impacts on Idaho residents at one time or another throughout the wildfire season. We are seeing similar impacts this year. 

What I have described above is now the new norm. The public 

now experiences smoke impacts throughout the summer every 

year, with periods of very unhealthy to hazardous air quality conditions. To deal with the smoke impacts, the public wants information so they can make decisions to protect themselves and, in the 

case of schools, those they are responsible for. Telling them to remain indoors and limit exposure is no longer sufficient. In many 

cases, the air quality indoors is just as bad or worse than the air 

quality outside. 

Responding to wildfire smoke impacts requires significant resources from DEQ and other agencies throughout Idaho. To properly respond to wildfires and mitigate health impacts from smoke, 

the communities that are repeatedly hard hit from wildfire smoke 

must be made smoke ready before the smoke event occurs. This 

means working with communities to identify tools citizens can use 

to protect themselves from the smoke. 

An example of a smoke ready community action is identifying the 

sensitive population, such as elderly people with lung or heart 

issues, and purchasing a cache of room-sized HEPA filters prior to 

the wildfire season so they can be distributed at the start of the 

emergency. Establishing a smoke ready community must be done 

prior to the wildfire season in order to respond to the emergency 

in a timely manner. 

To be effective, smoke ready communities require funding similar 

in the way—similar to the way firewise programs are funded. 

Funding for both these programs would allow communities to prepare for wildfires from both the fire safety and public health aspect. 

We agree that prescribed fire is an important tool in reducing 

fuels that contribute to catastrophic wildfire, but prescribed fire 

also causes smoke that needs to be managed. When prescribed fire 

is being discussed as a way to mitigate wildfire impacts, it is important to remember that reasonable and effective smoke management principles and decisions must be used to truly lessen smoke 

impacts and not simply move smoke from one time of the year to 

another. 

To manage smoke impacts from prescribed burning, the Montana/Idaho Airshed Group was created. This group implements a 

19 

smoke management program for organizations that conduct largescale prescribed burning and the agencies that regulate this burning. 

Burn decisions in Idaho are very much driven and limited by the 

weather. Northern Idaho is very mountainous. Smoke from prescribed burning can sink into the valleys and impact communities. 

Using best smoke management practices requires good weather 

that will allow the smoke to rise up high into the atmosphere and 

disperse so as not to impact the public. The key to this airshed 

group is coordinating burn requests and approvals to looking at the 

regional picture, not just burns on an individual basis. 

The Airshed Group uses a meteorologist to provide a weather 

forecast specific to prescribed burning. A coordinator evaluates all 

burns that are proposed, other burning, and emission sources occurring in the area, current and forecasted air quality, to determine if and how much burning can be approved. This process helps 

to ensure that smoke does not accumulate in valleys and impact 

the public. 

DEQ works closely with the airshed group during the active burn 

season. We review the weather forecast, air quality data, and proposed burns, and provide recommendations to the airshed group on 

a daily basis. 

There is no short-term quick fix. We need to address all causes 

of wildfire and look at new innovative solutions and mitigation 

strategies to address the matter. The key to success will be working in partnership with all stakeholders, air quality agencies, State 

and Federal land managers, large and small private prescribed 

burners, the general public, environmental groups, and others who 

use burning as a tool. The only way to make progress is to have 

an open, honest, and trusting dialogue based on facts and science. 

Thank you. 

[The prepared statement of Ms. Anderson follows:] 

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TESTIMONY OF MARY ANDERSON 

MOBILE AND AREA SOURCE PROGRAM MANAGER, AIR QUALITY DIVISION 

IDAHO DEPARTMENT OF ENVIRONMENTAL QUALITY 

BEFORE THE HOUSE COMMITIEE ON ENERGY AND COMMERCE SUBCOMMITIEE ON ENVIRONMENT 

REGARDING AIR QUALITY IMPACTS OF WILDFIRES: MITIGATION AND MANAGEMENT STRATEGIES 

SEPTEMBER 13, 2018 

Good afternoon, Chairman Shimkus, Ranking Member Tonko, and members of the subcommittee. I am 

Mary Anderson, Air Quality Division program manager at the Idaho Department of Environmental 

Quality (DEQ). Thank you for the opportunity to testify today and provide some insight into how 

wildfires are impacting Idaho citizens. 

Wildfires are the single largest air pollution source in Idaho and the entire Pacific Northwest. Fine 

particulate matter (PM2.5) levels are decreasing nationally but increasing in the Pacific Northwest and 

Northern Rockies due to wildfire smoke. Since the mid-1980s, the total US area burned by wildfires has 

been increasing, with fires in the Pacific Northwest accounting for over 50% of the increased acreage. 

The length of the fire season has grown along with the number, size, and duration of wildfires. This 

situation is forecasted to stay the same or worsen in the future. Numerous catastrophic wildfires have 

become the norm during our summer months1 causing heavy regional air pollution events, These 

catastrophic wildfires are caused by fuels that have accumulated as a result of a century of active fire 

suppression, drought, and climate change. 

In the past, Idaho would experience a severe wildfire season with heavy localized air quality impacts 

every 3-4 years, with low air quality impacts in the intervening years. Now we are seeing heavy regional 

air quality impacts every year from large, sometimes catastrophic wildfires in Idaho, central to northern 

California, Oregon, Washington, Nevada, and British Columbia. 

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In 2017, wildfire smoke caused widespread impacts in early August, with air quality reaching the 

Unhealthy for Sensitive Groups category in nearly every area of Idaho. It is now fairly common to see 

widespread impacts in August. By the first week of September 2017, wildfire smoke thoroughly 

blanketed all of Idaho, exposing many Idaho citizens to potentially serious health impacts. The most 

severe air quality impacts were in northern and central Idaho, where Hazardous conditions were 

measured for four consecutive days in the Coeur d'Alene area of northern Idaho. 

About 700,000 acres were burned by wildfire in Idaho in 2017. Idaho was also surrounded by wildfires, 

meaning wind from any direction brought smoke into the state. Nearly 5.5 million acres burned in 

neighboring states and British Columbia in 2017. All these fires had direct impacts on Idaho residents at 

one time or another throughout the wildfire season. Idaho wildfires alone released an estimated 

111,000 tons of direct fine particulate pollution into the air (about 25 times the amount of fine 

particulate pollution emitted by all the cars and trucks in Idaho in a year). 

Preliminary information for the 2018 wildfire season indicates that it is as bad as or worse than 2017. 

Idaho became heavily impacted by smoke around July 10 and experienced smoke impacts on a daily 

basis until the first full week of September. The most heavily impacted regions have been northern 

Idaho, central idaho, southwest Idaho-including the densely populated Treasure Valley-and at times 

the rest of southern Idaho. This year, the majority of smoke came from fires outside of Idaho: 

Washington, Oregon, California, and southern British Columbia. The predominant weather patterns 

have allowed for consistent smoke brought into Idaho. We are seeing similar levels of air quality impacts 

as we did in 2017. 

What I've described above is now the new normal. The public now experiences smoke impacts 

throughout the summer every year, with periods of Very Unhealthy to Hazardous air quality conditions. 

To deal with the smoke impacts, the public wants information so they can make decisions to protect 
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themselves and, in the case of schools, those they are responsible for. The public wants information 

about how bad the air quality is, how long the smoke will last, and what precautions they should take. 

Telling them to remain indoors and limit exposure is no longer sufficient. In many cases, the air quality 

indoors is just as bad or worse than the air quality outside. 

Local governments and school districts have had to develop policies to respond to the wildfire smoke 

impacts brought by catastrophic wildfires. During the 2012 wildfire season, very few if any school 

districts had air quality policies that determined outside activity based on current or forecasted air 

quality. In 2018, the majority of school districts have these policies and are making daily decisions on 

whether to have outside recess, hold practices indoors, and cancel football games. 

To ensure a coordinated response to wildfire smoke, Idaho developed a Wildfire Smoke Response 

Protocol, similar to Oregon and Washington. This protocol identifies organizations, partners, and other 

governmental entities (city and county) that play important roles in the overall response to these 

wildfire smoke events. The protocol highlights general duties and responsibilities, provides examples of 

agency actions and assistance needed, and recommends public health actions based on level and 

duration of smoke exposure caused by wildfire smoke. Key participants are federal land managers (US 

Forest Service), the Environmental Protection Agency (EPA}, tribes, DEQ, the Idaho Department of 

Health and Welfare, and public health districts. We also work closely with county emergency managers, 

Red Cross, and school districts to ensure a consistent message is communicated. 

To meet the public's need for information, DEQ and cooperating agencies use many tools: 

o Idaho Smoke Blog 

o Social media (Twitter, Facebook, NextDoor} 

o Websites 

o News releases 

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o Videos explaining our smoke forecasts 

o Daily smoke and air quality forecast email blasts 

DEQ responds to local community requests and federal land manager requests to supply additional air 

quality monitoring in areas heavily impacted by wildfire smoke. Each year, DEQ deploys between one 

and four additional monitors throughout the state. This deployment requires significant coordination to 

identify and establish a suitable location for the monitor to operate. We have deployed four monitors so 

far in 2018. 

Responding to wildfire smoke impacts requires significant resources from DEQ and other agencies 

throughout Idaho. To properly respond to wildfires and help mitigate health impacts from smoke, the 

communities that are repeatedly hard hit by wildfire smoke must be made "smoke ready" before the 

smoke event occurs. This means working with the communities and counties to identify tools citizens 

can use to protect themselves from the smoke. An example of smoke ready community action is 

identifying the sensitive populations (elderly, people with lung or heart issues) and purchasing a cache 

of room-sized HEPA filters prior to the wildfire season. Establishing a smoke ready community must be 

done prior to the wildfire season in order to respond to the emergency in a timely manner. To be 

effective, smoke ready communities require funding, similar to the way Firewise programs are funded. 

Funding for both these programs would allow the communities to prepare for wildfires from both the 

fire safety and public health aspect. 

Many types of open burning occur in Idaho throughout the year. Prescribed burning-which includes 

burning for forest health, slash burning after a timber harvest, and rangeland burning-typically occurs 

in the spring and fall, outside the wildfire season. Prescribed burning is conducted by state and federal 

land managers and landowners. Agricultural burning also occurs during these times as does residential 

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backyard burning. During the winter, a high percentage of the population in rural Idaho uses wood to 

heat their homes, which creates additional smoke impacts. 

Prescribed fire is an important tool in reducing fuels that contribute to catastrophic wildfire, but 

prescribed fire also causes smoke that needs to be managed. When prescribed fire is being discussed as 

a way to mitigate wildfire impacts, it is important to remember that reasonable and effective smoke 

management principles and decisions must be used to truly lessen smoke impacts and not simply move 

smoke from one time of year to another. 

Smoke from prescribed fire has the potential to jeopardize attainment demonstration in some of our 

nonattainment areas (areas not meeting air quality standards) if not applied appropriately. Data can be 

flagged as "exceptional," thereby excluding it from attainment demonstrations, but only if adequate 

smoke management principles are adopted and applied. 

To manage prescribed burning smoke impacts, the Montana/Idaho Airshed Group was created to 

implement a prescribed fire smoke management program for organizations that conduct large-scale 

burning and the agencies that regulate this burning. The airshed group is an effective collaboration of 

state and federal agencies and most large private landowners to limit smoke impacts from prescribed 

fire while providing as much flexibility as possible. The airshed group is composed of three units: 

Montana, North Idaho, and South Idaho, formed in 1978, 1990, and 1999, respectively. 

As a group, the members sign a memorandum of understanding and commit to abide by the group's 

operating guide, which details policies and procedures. The group's members are committed to working 

together to manage air quality in a responsible manner so as not to impact public health. 

The key to the airshed group is coordinating burn requests and approvals to look at the regional picture, 

not just burns on an individual basis. The airshed group uses a meteorologist to provide a weather 

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forecast specifically for prescribed burning. A coordinator evaluates all burns that are proposed, other 

burning/emissions sources occurring in the area, and current and forecasted air quality to determine if 

and how much burning can be approved. This process helps to ensure that smoke does not accumulate 

in valleys and impact the public. 

DEQ works closely with the airshed group during the active burn season. We review the weather 

forecast, air quality data, and proposed burns and provide recommendations to the airshed group on a 

daily basis. 

Currently, the airshed group is staffed with two meteorologists from federal agencies who provide part 

of their time to the airshed group. One US Forest Service staff person reviews all proposed burns in 

Montana and Idaho, coordinates with both Idaho and Montana DEQs, and makes a burn 

recommendation for each proposed burn. Staff are barely able to keep up with the workload at the 

current rate. If prescribed burning is increased, one person will not be sufficient to manage the 

workload. 

Burn decisions in Idaho are very much driven, and limited, by the weather. Northern Idaho is very 

mountainous. Smoke from prescribed burning can sink into the valleys and impact those populations. 

Burn managers require specific weather conditions to ensure the burn accomplishes the intended goals. 

Using best smoke management practices also requires good weather that will allow the smoke to rise 

high into the atmosphere and disperse so as notto impact the public. 

Burning, whether wildfire or prescribed, is a large part of Idaho's air quality concerns. In order to 

respond to, and effectively manage, all the planned open burning, DEQ is developing a comprehensive 

smoke management program that addresses all types of burning in a consistent manner statewide. This 

smoke management program has two goals. The first is to protect public health, which is a key 

component of DEQ's mission. We protect public health by ensuring open burning does not cause an 

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exceedance of a National Ambient Air Quality Standard. The second goal is to provide flexibility to 

burners when it will not jeopardize public health. 

Idaho also participates in a smoke management group facilitated by EPA Region 10. This group consists 

of air quality regulatory agencies; health agencies; private, state, and federal land managers; 

researchers; and interested stakeholders and strives to improve all aspects of wildfire response and 

smoke management of prescribed burning and agricultural burning. 

According to a study funded by the Joint Fire Science Program, funding is one of the biggest hurdles for 

prescribed burning in Idaho. If funding is resolved, air quality could become the main hindrance. Air 

quality smoke management programs, and staffing, will need to adapt now to be ready to handle 

increased use if other issues are resolved. 

Conclusion 

There is no short-term, quick fix. We need to address all causes of wildfires and look at new, innovative 

solutions and mitigation strategies to address the matter. The key to success will be working in 

partnership with all stakeholders: state and federal land managers, large and small prescribed burners, 

the general public, environmental groups, and others who use burning as a tool. The only way to make 

progress is to have an open, honest, and trusting dialogue based on facts and science. 

7 
27 

Mr. SHIMKUS. And the chair thanks the gentlelady. 

The chair will now recognize the ranking member of the full committee, Congressman Pallone from New Jersey, for 5 minutes. 

OPENING STATEMENT OF FRANK PALLONE, JR. 

Mr. PALLONE. Thank you, Mr. Chairman, and thank you for letting me—I know—I was on the floor with our chairman. 

It has been a year now since this subcommittee last held a hearing on wildfires. And since that time, the same regions of the country are suffering due to the large number and size of forest fires, 

causing tremendous damage. And this is, once again, particularly 

destructive to Western States. 

We have all seen the devastating images of lives lost and homes 

destroyed. These extreme wildfires are also creating poor air quality in States far away from the fires. 

Last month, the National Weather Service found that smoke 

from western wildfires has spread as far as New England. And 

these wildfires are tragic, but they should not be a surprise. For 

years, scientists have warned that climate change was very likely 

going to contribute to the increased fire intensity and frequency 

that we are seeing now. That is exactly what we are seeing, and 

we are not going to improve the situation by only looking at forest 

management or timber harvesting practices. 

If this Congress wants to truly address the increase in extreme 

wildfires, we must act to slow the global warming that is driving 

changes in climate and weather patterns. 

Unfortunately, the Trump administration and congressional Republicans refuse to address climate change and have instead 

pushed policies that will exacerbate our climate problems. Here is 

my list of President Trump’s most significant climate actions. 

First, he pulled the U.S. out of the Paris Agreement, giving up 

our spot as a global leader and turning his back on our allies. Then 

he proposed to replace the commonsense Clean Power Plan with a 

dirty power scam that lets polluters off the hook. The EPA even admits this proposal will result in 1,400 more premature deaths every 

year. Third, President Trump proposed to relax standards for fuel 

efficiency in vehicles, hurting consumers and ensuring more climate changing substances are emitted into the air. And fourth, he 

doubled down on a loophole in the Clean Air Act that allows more 

efficient and polluting heavy duty trucks on our roadways. 

And then just this week, Trump relaxed controls on methane pollution from oil and gas operations and landfills. The President has 

also blocked all Federal agencies from considering or acknowledging the costs associated with climate change when making decisions, and he has proposed to cut funds for energy efficient programs and support for renewable energy. And finally, he continues 

to threaten to abuse emergency authorities to subsidize the oldest 

and least efficient coal plants in the country. 

President Trump and his administration are doing everything 

possible to increase emissions and block any attempt to slow the 

rate of climate change. The result is rising seas, extreme weather 

events, severe drought and, of course, extended and intense fire 

seasons. And these are costing lives, destroying property and infrastructure, and costing us billions in disaster assistance. 

28 

And as we sit here, the southeast is about to be hit by another 

powerful hurricane devastating more communities. A new report 

from the researchers of Stony Brook University and Lawrence 

Berkeley National Laboratory finds that hurricane Florence is 

about 50 miles wider as a result of climate change. That means 

that hurricane can result in 50 percent more rainfall. Yet Republicans refuse to address climate change. 

Even here today, the focus is not where it should be. How many 

more of these events do we need before Republicans join us in taking decisive action to combat climate change? When are Republicans going to stop actively pursuing policies that make the problem worse? 

If we are serious about stemming the terrible growth of the forest fire season as well as these other natural disasters, we need to 

abandon the disaster that is the Trump administration climate policy, and we need to do it immediately. 

And with that, Mr. Chairman, I yield back. And thank you for 

the time. 

Mr. SHIMKUS. The gentleman yields back his time. 

The chair now recognizes Ms. Sonya Germann, State Forester, 

Montana Department of Natural Resources and Conservation, Forestry Division, on behalf of the National Association of State Foresters. 

You are welcome and recognized for 5 minutes. 

STATEMENT OF SONYA GERMANN 

Ms. GERMANN. Thank you, Chairman Shimkus, Ranking Member 

Tonko, Full Committee Chair Walden, Ranking Member Pallone, 

and members of the subcommittee. It is a true honor to be before 

one of the Nation’s longest standing committees to discuss wildfire 

impacts to air quality and strategies we are undertaking to mitigate those impacts. 

My name is Sonya Germann, State Forester of Montana. And 

like Mr. Boggus, I am here testifying on behalf of the National Association of State Foresters. I am also a member of the Council of 

Western State Foresters, which represents 17 Western States and 

six U.S.-affiliated Pacific islands. I have spent my life in Montana 

in the past 12 years in forestry, with an emphasis on active forest 

management, and I am honored to share the Montana perspective 

with you here today. 

The 2018 fire year has been challenging, not only in severity and 

duration, but most importantly in the number of lives lost. There 

have been 14 fire-related fatalities, a devastating loss to families, 

the wildland firefighting community, and the greater public. Across 

the Nation and particularly in the west, wildfires are growing more 

intense and so large we are now calling them megafires. 

In Montana, our fire season is, on average, 40 days longer than 

it was 30 years ago. And as the chairman suggested, more than 7 

million acres has burned since January 1 on a national scale. And 

let me put that in perspective for you. 

In the past 16 years, we have surpassed the 7 million acre mark 

eight times and the 9 million acre mark five times. In the 10 years 

prior to that, we reached 7 million acres only once. 

29 

Although the 2018 fire year in Montana has thankfully been relatively moderate, our citizens and wildland firefighters are still 

reeling from 2017, which was our most severe season on record 

since 1910 with over 1.2 million acres burned, which is an area 

roughly the size of Delaware. 

With severe fire years comes intense smoke. And according to the 

Montana Department of Environmental Quality, the air quality 

standards for particulate matter have been exceeded 579 times for 

wildfire over the past 11 years, with 214 of those occurring in 2017. 

Fire is a natural part of our ecosystem. What is not natural are 

the unprecedented forest conditions we are facing. Nearly a century 

of fire exclusion has led to excessive fuel loading and changed forest types. These factors, in addition to insect epidemics, persistent 

drought, and climate change have resulted in a disproportionate 

amount of Montana’s fire-adapted forests being at significant risk 

of wildfire. Today, over 85 percent of Montana’s forests are elevated 

wildfire hazard potential. 

As land managers, we understand the connection between fuels, 

wildfires, severity, and smoke. Consequently, we make concerted 

efforts to work with key partners to reduce fuels that in turn reduce wildfire risk and smoke-related impacts. Treatments like prescribed fire mechanical fuels reduction will not prevent wildfires 

from occurring but can influence how a wildfire burns. Experience 

shows that actively managed forested stands often burn with less 

intensity and produce less smoke than stands with higher fuel 

loading. Additionally, active fuels reduction can create safer conditions for wildland firefighters and may also offer crews opportunities to keep those fires smaller. 

Along with our key partners, we endeavor to get more prescribed 

fire and mechanical fuels reduction work done on the ground. And 

as Ms. Anderson described, we are a part of the Montana/Idaho 

Airshed Group. This group assures coordinated compliance with 

regulatory agencies and strives to help us accomplish more prescribed burning while complying with air quality standards. 

In Montana, proof is in the air quality data. Over the past 11 

years, prescribed fire has exceeded air quality standards only four 

times compared to 579 for wildfire. This group has been recommended as a model for other States to follow. 

And lastly, with over 60 percent of forested land in Montana 

managed by Federal agencies, we strongly support authorities that 

facilitate fuels reduction projects and allow them to be completed 

more quickly through collaborative action. The Good Neighbor Authority and categorical exclusions for wildfire resilient projects represent two such authorities. 

We strongly appreciate and value Congress’ efforts to make authorities like these available to our Federal partners. 

In closing, my written testimony has been made available to you, 

and I look forward to answering any questions you may have. 

Again, thank you for the opportunity to testify before you today. 

[The prepared statement of Ms. Germann follows:] 

30 


36422.015

Testimony of Sonya Germann, Montana State Forester 

On Behalf of The National Association of State Foresters 

Submitted to the U.S. House Committee on Energy and Commerce, 

Subcommittee on the Environment 

For Hearing on 

Air Quality Impacts of Wild tires: Mitigation and Management Strategies. 

September 13, 2018 

Good morning, Chairman Shimkus, Ranking Member Tonka, and Members of the 

subcommittee. My name is Sonya Germann. I am the State Forester for the State of Montana, 

Department of Natural Resources and Conservation, Forestry Division. I appreciate the 

opportunity to speak with you today and submit written testimony as the Committee considers 

the significant impacts of wildfire smoke on citizens and communities across the country, as well 

as the preventive role prescribed fire and hazardous fuels reduction can have in mitigating smoke 

impacts from unplanned wildfires. 

The National Association of State Foresters (NASF) represents the directors of the state 

forestry agencies in all 50 states, eight territories, and the District of Columbia. State forestry 

agencies, like mine, deliver technical and financial assistance; protect lives, properly and natural 

resources from wildfire; and conserve forest health, water, and other ecosystem services on more 

than two-thirds of our nation's 766 million acres of forests. Through the State Fire Assistance 

(SF A) and Volunteer Fire Assistance (VFA) programs, state agencies equip prescribed fire 

managers and wild tire response resources who work on state and private lands, where over 80% 

of the nation's wildfires start. 

In addition, state forestry agencies work closely with our federal partners in managing 

complex multi-jurisdictionallandscapes. For example, with the authority granted by Congress in 
31 


36422.016

the 2014 Farm Bill, over 30 states, including in the state of Montana, have signed Good 

Neighbor Authority (GNA) agreements with the federal government. Under GNA, states may 

use their own contracting procedures to serve as the agent of the U.S. Forest Service (Forest 

Service) to conduct restoration activities on federal lands and adjacent non-federal lands. By 

partnering together in this way, the Forest Service and states like Montana can better leverage 

resources to accomplish more restoration work on the ground. 

While the duties of state agencies vary, each share common forest management and 

restoration missions and most have statutory responsibilities to provide wildland fire protection 

on public and private lands. As such, we are intimately aware of the increasing occurrence of 

wildland fire and associated smoke impacts across the country. 

Summary of National and Regional Fire Activity 

According to the National Interagency Fire Center, the 2018 fire year has proven 

challenging both in its severity and its duration. However, the severity and duration of the 2018 

fire year is more consistent with the past decade than it is an anomaly. Since 2002, with very 

few exceptions, tire seasons have tended to be more active, with larger acreages burned and 

more severe conditions than any other decade since we began keeping consistent and accurate 

records in 1960. 

Quantifying a fire season's severity and comparing one year with another can prove 

challenging. One can do so using a variety of measures including the number of fires, acres 

burned, length of season, structures lost, incident management teams mobilized, or fire-related 

fatalities. For those in the firefighting community, the number of lircline and fire-related 

fatalities may be the most critical measure of a fire season's outcome. 

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36422.017

So far this year, almost nearing the wind-down stage of the Western fire year, there have 

been 14 firelighter or fire-related fatalities. This is a higher number than the 10 fatalities that 

occurred in 2017, the 12 fatalities that occurred in 2016, or the 13 fatalities that occurred in 2015. 

In 2013, when the Yarnell incident occurred in Arizona, firefighter fatalities reached an all-time 

high with 34 firefighters losing their lives that year. 

The number of acres burned provides a metric both useful to compare years and to 

quantify severity of a given year. It can also be a long-term indicator of fire conditions and 

trends on the landscape. As of September 7th, more than seven million acres have burned in 

2018. In the past 16 years, we've surpassed the seven million-acre mark eight times, and the 

nine million-acre mark t!ve times. So far, the peak year for acres burned by wildfire peaked in 

2015 at l 0.1 million acres. In the l 0 years prior to 2002 (!992- 200 l ), we reached 7 million 

acres on only one year, and had six years with less than 3 million acres burned. 

20I8 has been an active t!re season, with more than 30,000 people assigned to fire 

incidents during the peak in early August. At this point, 2018 has not yet been one of the 

"worst." However, with several months left during which California will experience critical fire 

conditions and fall fire seasons approaching in the east, Lake States, and elsewhere, more acres 

will burn before the fire year ends. Many California residents likely feel as though this fire 

season was one of the worst, as more than 1.4 million acres have burned throughout the state, 

2,356 homes have been lost to wildfires, and 14lives have been lost. 

According to 2018 statistics for the Northern Rockies Geographic Area alone (which 

includes Northern Idaho, all of Montana, and the western Dakotas), the Forest Service reported 

1,851 fires that burned 99,130 acres, YTD. However, the 2018 fire year is not yet behind us. 

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36422.018

We remain cautious and alert as there has not been substantial widespread moisture since July 

J'd, fuels are still dry, and we are having new fires every day. 

Our Nations Forests and Wildfire 

Fire is a natural phenomenon for nearly every forest ecosystem in this country. Fire has 

shaped the occurrence and distribution of difTercnt ecosystems for centuries, simultaneously 

impacting the human and plant and animal communities in and around those forests. Over the 

past century, a culture of fire exclusion unfortunately removed the natural role of fire from the 

public consciousness. When combined with a reduced level of forest management in many areas 

of the country, fire exclusion led to the build-up of forest fuels to unprecedented levels. Despite 

our attempts to manage away wildfire, many of our forests are more fire-prone than ever. 

What Federal, State and local fire managers and scientists have learned over the decades 

is that by managing hazardous fiJels, natural resource agencies can mitigate both the severity and 

impacts of wildfire. Experience has now shown us that wildfire suppression without proactive 

forest management is unlikely to result in the least amount of wildfire over time because forest 

fuels continue to build up to the point where wildfires eventually become unmanageable. 

Consequently, the challenge of land managers is to mitigate the risk to both human communities 

and ecosystem values both in the short and long-term by implementing a coordinated and 

science-based approach integrating fuels reduction, fire suppression, and community planning. 

Hazardous fuels reduction includes two commonly applied components; prescribed fire 

and mechanical thinning. Both can have a beneficial impact on smoke emissions from wildfires 

because they reduce combustible material. We believe that prescribed fire is an essential 

hazardous fuels reduction tool, that hazardous fuels reduction helps maintain the "investment" 

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36422.019

we make in working forests, and that we must manage forests and forest fuels in order to reduce 

the occurrence of catastrophic wildfire. 

Hazardous fuels reduction does not prevent wildfire from occurring but can influence 

how a fire burns. Experience shows that actively managed timber stands often burn with less 

intensity than those stands with higher fuel loading and often produce less smoke. Active 

hazardous fuels reduction can create safer conditions for wildland firefighters to conduct 

suppression activities and may also offer crews opportunities to keep fires smaller. 

Wildfire and Air Quality 

There exists ample research evidence documenting the air quality and public health 

impacts of forest fire smoke. Of primary concern is particulate matter (PM), produced from the 

combustion of woody material. Specifically, particulate matter smaller than 2.5 microns (PM 

2.5) is of concern for individuals exposed to wildfire smoke due to the ability of these small 

particles to penetrate deep into the lungs and respiratory system. PM 2.5 can cause both shortterm health effects such as eye, nose, throat and lung irritation, coughing, and shortness of 

breath; as well as long-term effects on respiration and the worsening of medical conditions such 

as asthma and heart disease. Air quality impacts from wildfire smoke often hit the hardest in 

sensitive populations (such as children, the elderly, and those with pre-existing conditions). In 

addition to human health, reduced air quality from wildfire smoke can impact tourism, 

recreation, education, and other aspects of community and economic life. 

Relatively recent research suggests that the air quality impacts generated from prescribed 

fire smoke differ from the smoke produced by unplanned wildfires; and those differences are 

important to recognize. Prescribed fires are timed to occur under conditions in which fire 

managers have an increased control over fire location, spread, intensity, and other parameters. In 

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36422.020

Montana, advanced weather forecasting and state-of-the-art smoke modeling, coupled with 

cooperative engagement between the natural resource agencies in the stale and the Montana 

Department of Environmental Quality's air quality program staff, allow fire managers to tailor 

ignition locations and times to meet specific smoke management objectives. White each state 

has differing laws and regulating burning, fire managers work within these parameters and laws 

with the intent of producing as little smoke as they can, with the intent being to produce as little 

smoke through prescribed burning to avoid much greater amounts of wildfire smoke in the 

future. 

The US Environmental Protection Agency (EPA) acknowledged, in its rulemaking over 

the past two years, the benefits of managing smoke production during prescribed fire activity in 

order to reduce air quality impacts. In both the updating oftbe National Ambient Air Quality 

Standard (NAAQS) for PM 2.5 (81 CFR 164, pg. 58010) and the updating of the Exceptional 

Events Rule (81 CFR 191, pg. 68216), the EPA clearly documents the role of wildfire as an 

emissions source and the relevance of prescribed fire use and fuels management to reduce the 

risk of catastrophic wildfire. It is becoming increasingly evident through both research and 

experience that without prescribed fire and the relatively small amount of managed smoke that 

comes with it, we are perpetuating the conditions that generate catastrophic fires and resulting air 

quality issues, while simultaneously putting people and their communities at risk. 

Let us not forget about the impact smoke exposure has on our wildland firefighters. Last 

Friday, September 7, 2018, the Joint Fire Science Program (JFSP) released a Final Report 

entitled "Wildland Fire Smoke Health Effects on Wildland Firefighters and the Public." The 

report examined smoke exposure concentration data for wildland firefighters to estimate the 

health risks specific to prescribed and wildland fire smoke. Findings suggest that wildland 

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36422.021

firefighters may be at more risk for smoke exposure and health-related impacts when working on 

wildland fires compared to prescribed tires. However, scientists cite the need to do more research 

to understand the true extent of health-related impacts to firefighters who work on both 

prescribed and wildland fires. This need speaks to the importance of maintaining JFSP funding. 

Current JFSP lines of work include fuel treatment effectiveness, post-fire recovery, smoke 

management and air quality, fire risk, and data and software integration frameworks for decision 

support. These lines of work are of importance to agencies who use the results of JFSP funded 

research both to inform our management and to help us inform and int1ucnce our citizens. 

Montana Perspective 

Although the 2018 fire year in Montana has been, thankfully, relatively moderate in 

comparison to other years, over time, fires have been growing larger and more intense 

throughout the state; and our average fire season is 40 days longer than it was 30 years ago 1

• 

According to the Northern Rockies Coordination Center (NRCC), the 2017 fire year was our 

largest on record since 191 0 with over 1.2 million acres burned statewide and two fire-related 

fatalities. Using data from NRCC, we can determine that from 1998-2007 an average of22,828 

acres burned per year in Montana. From 2008-2017 the average increased 15-fold with up to 

349,598 of wildland acres burning per year. Data also shows that Montana went fifteen 

consecutive years without a 100,000-acre fire year, from 1997-2010, but had two 1,000,000-acre 

years in the 20 I 0-2018 period. 

1 Freeborn, P. H., W. M. Jolly, and M.A. Cochrane (20 16), Impacts of changing fire weather conditions on 

reconstructed trends in U.S. wildland fire activity from J 979 to 2014, J. Geophys.Res. Biogeosci., 12 J, 

doi: J 0.1002/20 J 6JG003617. 

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36422.022

With larger and more severe fires comes more smoke. According to Montana Department 

of Environmental Quality (MT DEQ), the air quality standards for particulate matter have been 

exceeded 579 times over the past 11 years, with 214 of those occurring in 2017. During this year, 

particulate matter concentration increased 17-fold from the air quality standards maximum level. 

Similar to many forests within our region, forest conditions in Montana are at increased 

risk of wildfire. Large portions of the state's forests have succumbed to insect epidemics, 

historically fire-tolerant forests have been replaced by tree species less adapted to fire, and fuel 

loadings have increased across large portions of our forests, increasing the severity and intensity 

of wildfires. Due to changed conditions, a disproportionate amount of Montana's fire-adapted 

forests is at significant risk of wildfire. Today, over 85 percent of Montana's forests are outside 

of their historic vegetative condition and arc therefore at elevated wildfire hazard potential. 

Forest conditions and events resulting from those conditions affect all Montanans 

regardless of whose land they take place on. Insects outbreaks, wildfires, smoke, drought, and a 

changing climate do not recognize ownership boundaries. According to the Montana Wood 

Products Association, out of23 million acres of forested land, Montana has 19.8 million acres of 

productive, non-reserved timberland. 61 percent of this land is National F ores!; 25 percent is 

non-industrial private forest and tribal; 5 percent is industrial private forest, industry; 5 percent is 

state; and 4 percent is managed by the Bureau of Land Management. Although these various 

ownerships operate under unique missions, goals, and objectives, by working cooperatively to 

co-manage fire risk we can mitigate fire severity on Montana's forested landscape and reduce the 

smoke-related impacts to people and communities. This is especially important on federal lands 

which account for large areas of western states and on which fire management and fuels 

treatment have direct implications for adjacent state and private lands and/or communities. 

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In Montana, we have a long history of working together to resolve intractable land 

management issues facing our state. Montana has been engaging in regional and statewide efforts 

to renew our collective commitment on working together with other key stakeholders to reduce 

the risk of wildland fire and smoke-related impacts. 

A. Western Governors' Association 

Last summer, the Western Governors' Association (WGA), chaired by Montana 

Governor Steve Bullock, released the National Forest and Rangeland Management Initiative 

Special Report. This report represents a multi-state, bipartisan collaborative perspective on 

promoting health and resilience of forests and rangelands in the West and highlights mechanisms 

to bring states, federal land managers, private landowners, and stakeholders together to discuss 

issues and opportunities in forest and rangeland restoration and management emphasizing 

investments in all lands/cross-boundary management opportunities. Recognizing the impacts 

related to wildfire, the WGA offers specific recommendations to increase hazardous fuels 

reduction and support advancements in the usc of prescribed fire. 

Through the bipartisan spirit of the West, and by Governors working closely with 

Congressional members, recommendations contained in this report address critical issues to 

increasing restoration on acres at risk from wildfire. The Wildfire Suppression Funding and 

Forest Management Activities Act within the FY 2018 omnibus bill advanced many of these 

recommendations. The long-term "fire funding fix"; the GNA amendment to allow for road 

reconstruction, repair and restoration; and the establishment of categorical exclusions for wildfire 

resilience projects will facilitate more fuels reduction projects on and off federal lands and allow 

them to be started and completed more quickly. 

B. Forests in Focus 

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36422.024

In July of2014, Governor Bullock announced the Forests in Focus Initiative: A Forest 

Strategy for Montana, to increase the pace and scale of restoration on Montana's forests in order 

to reduce the risk of wildfire, address forest health issues, and to grow and sustain forest products 

industry within the state. included in the initiative was the dedication of a fund to accommodate 

cost-shared forest restoration and fuel reduction projects on tribal, state, and private forested 

lands. Additionally, nearly five million acres of National Forest System land were nominated as 

"priority landscapes" because those lands were at risk of forest health threats and/or catastrophic 

wildfires. This designation qualified eligible lands for important Farm Bill tools to accelerate 

forest restoration. Since its inception, Forests in Focus investments have supported the treatment 

of over 300,000 acres, production of nearly 200 million board feet of timber, and retention of 

jobs in the forest products industry sector. 

Like many other states throughout the region, Montana is investing in the use of GNA to 

increase the pace and scale of forest restoration across ownerships and in partnership with key 

forest stakeholders. This, along with increased investments in stewardship on private nonindustrial forest lands, supporting policies and tools that allow agencies to get more work done 

on the grotmd, and developing capacity for local governments to accomplish work in and around 

their communities, we endeavor to decrease wildland fire risk on a much broader scale than we 

are currently, thereby having a net-positive effect on wildfire smoke-related impacts to 

Montanans. 

C. Usc of Prescribed Fire in Montana 

In Montana, land managers use prescribed burning as a tool to mitigate the severity of 

wildland fires by reducing the build-up of flammable fuel in our forests. Prescribed burning also 

helps maintain biodiversity, and regenerates vegetation. According to the NRCC, thus far in 

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2018, the State of Montana, as well as its federal and local partners have implemented prescribed 

burns on 28,049 acres compared to the ten-year average of 37,352 acres. According to the 2015 

National Prescribed Fire Use Survey Report released by the Coalition of Prescribed Fire 

Councils, out of 17 western states, Montana burns less than average compared to nine other 

states within the region. Land managers within the state know we need to be doing more with 

prescribed fire. As the report's nationwide findings state, we find that our main challenges are 

weather, conditions of fuels during open burn windows, and capacity rather than air quality 

issues. However, we also acknowledge that, as we look for ways to increase the use of prescribed 

fire within the state, the public's acceptance of prescribed fire smoke will likely become an issue. 

However, air quality issues have not yet presented a major impediment to the use of 

prescribed fire in Montana according to many land managers. This may be in part to the 

development of a progressive model to regulate prescribed burning in a collaborative and 

cooperative manner. The Montana/Idaho Airshed Group (Group) is dedicated to the preservation 

of air quality in Montana and Idaho and was initially formed to reduce the impacts of smoke 

from prescribed burning on Montana and Idaho communities. The Group is run by and for major 

burners to coordinate burning activities and streamline engagement with MT DEQ and County 

public health officials. The Group's intent is to minimize or prevent smoke impacts while using 

fire to accomplish land management objectives. The Group is composed of state, federal, tribal 

and private member organizations. The Group jointly uses an Airshed Management System 

database to coordinate burning through the Smoke Management Unit. The Group tracks all 

planned burns and communicates this on behalf of the burners to regulators through one 

centralized position at the Smoke Management Unit. This allows for greater coordination among 

burners and air quality regulators by having one person communicating with the regulating 

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36422.026

agencies. If burning in Montana, members must have an annual air quality major outdoor 

burning permit issued by the MT DEQ. Additionally, members are required to comply with 

local air pollution control agency and/or a fire safety outdoor burning permit. In short, the Group 

assures coordinated compliance with regulatory agencies, and results in more prescribed burning 

taking place on the ground that complies with air quality standards. According to MT DEQ, over 

the past 11 years, there have been only 4 instances when prescribed fire exceeded air quality 

standards for particulate matter, compared to the 579 instances for wildfire. This success is 

largely due to the coordinating burning efforts of the Airshed Group. Lastly, in the Summer 2018 

Ecosystem Workfhrce Program Working Paper "Prescribed Fire Policy Baniers and 

Opportunities", authors recommended the Montana/Idaho Airshed Group as a model for other 

states to follow. 

Conclusion 

Thank you for the opportunity to appear before the Committee today on behalf of the 

National Association of State Foresters and the State of Montana. As State Foresters, we believe 

that, to avert a forest health and wildland fire crisis, we need to be doing significantly more 

hazardous fuels reduction throughout the country. We are working towards this goal and 

prescribed fire represents a critical tool necessary to accomplish it. Hazardous fuels reduction 

and prescribed fire treatments decrease fuel loading in the forests so that when wildfires 

inevitably occur, they burn with less intensity and reduced spread, burn for shorter periods of 

time, and produce fewer smoke impacts on firefighters, citizens, and communities. 

12 
42 

Mr. SHIMKUS. The chair thanks you. 

The chair now turns to Mr. Collin O’Mara, President and CEO 

of the National Wildlife Federation. 

You are recognized for 5 minutes. Welcome back. 

STATEMENT OF COLLIN O’MARA 

Mr. O’MARA. Thank you, Mr. Chairman, Mr. Tonko, Chairman 

Walden. You have my prepared testimony. 

I actually want to have kind of a real conversation today, because I really appreciate the topic and actually focus on the health 

consequences. But the external debate on this issue has become a 

little ridiculous, right? 

One side is saying it is all about logging and, frankly, just kind 

of cutting everything down. The other side is saying it is all about 

climate. We need to actively manage and we actually have to address the climate stressors that are causing this system. And this 

is a more complicated conversation. It doesn’t fit into the normal 

kind of right-left debate. 

You are going to have almost unanimous agreement on this 

panel on 80 percent of the recommendations. That doesn’t happen 

before this committee all that often, having been in the room with 

the chairman a handful of times. 

One of the missed opportunities in the fire funding fix this year, 

and I am so grateful because so many of you played a constructive 

role in it, was delaying the funding for 2 years, to not have it take 

effect until 2 years. We need that money in Oregon right now. We 

need that money in California right now. 

And I get it. But leadership, when they jumped in, they didn’t 

listen to some of you, and Congressman Simpson and others. It is 

billions of dollars of missed opportunity to do restoration work. 

And, look, the appropriation minibus is already moving. It is 

probably too far down the line. But there has to be a way to get 

a slug of money, because the Forest Service is basically out right 

now. They have hit the caps they would have hit at the end of the 

month. And if we don’t get these projects on the ground, we are 

going to continue to have more and more of this kind of restoration 

deficit, if you will, that we are trying to undo. Because we have basically starved ourselves for 40 years, right? At least the last 25. 

And you are talking about a lot of funding. There are great reports. There is a great one just put out by Oregon State looking at 

how to get more prescribed burns on the ground. 

Look, there are things we need to do, like making sure that the 

ambient air quality standards aren’t overly prohibitive and making 

sure that we are accounting for the impacts of prescribed burns in 

a way that is actually rational, and not discounting natural kind 

of anthropogenic emissions in a different way than we are treating 

manmade ones, especially if the manmade ones are going to save 

us 90 or 100 percent of emissions compared to the alternative. 

But most of the problem here is actually funding in collaboration. 

And Secretary Perdue put out a great report just a few weeks ago 

talking about shared stewardship, talking about how to use some 

of these tools that all of you put together in the last fire funding 

package and actually trying to get more projects on the ground. 

And there are things around good neighbor provisions that we abVerDate Nov 24 2008 11:48 May 24, 2019 Jkt 037690 PO 00000 Frm 00046 Fmt 6633 Sfmt 6633 U:\MY DOCS\HEARINGS 115\HEARINGS\115-165 CHRIS
43 

solutely have to fund. There are stewardship contracting provisions 

we have to fund. There are some mechanical issues that we could 

work through and actually use your help trying to make sure that 

the good neighbor provisions have the right accounting behind 

them so States are incentivized to do the work. 

There are some additional tools that folks like Congressman 

Westerman are working on, like Chairman Barrasso, and Senator 

Carper, some additional little tools on the management side. 

But this is one of those conversations, like, let’s not score points 

on it, right? Folks are hurting right now. I talked to my friend who 

is an air director up in Oregon right now. They are trying to rewrite their smoke plans right now. It is a good collaborative process. It is a few years too late. I would have liked to have seen it 

a few years ago. 

The leaders that you have on this panel actually have a lot of 

the solutions. And so I am like if you do the talking points, you 

can’t have this conversation without talking about climate. You got 

dryer soils. You got less snow pack. You have warmer temperatures. The fact that it is not a—I am going to steal your line, I 

apologize, that it is no longer a fire season, it is a fire year. 

This is a serious conversation. And I know there are a lot of 

other votes going on, but not a lot of folks are here right now. And 

so if there are folks that want to have this conversation in a real 

way—and it is not just the E&C. It affects Natural Resources. We 

obviously have jurisdictional issues all over the place. 

We got to fix the funding issue. That is the first thing. We have 

to figure out some of these collaborative measures and how we basically bolster the collaboratives in a big way, because the 

collaboratives are the way to get good products on the ground. 

There is huge opportunity there. And there are some commonsense 

things that could be fit into the farm bill. 

Advancing prescribed burns in a smart way, and there is some 

guidance—we don’t actually need to change the Clean Air Act, but 

there is some guidance coming out of EPA related to how they actually measure different types of emissions that have to be fixed. 

I think Administrator Wheeler could get this done. I think, frankly, 

Gina McCarthy would have agreed with him on some of these 

things. This is one of those areas, again, that it is not particularly 

partisan, and frankly, getting those products on the ground. 

Because right now, it is easier to try to respond after the fact 

than it is to actually do the prescribed burn on the front end. Because it is just a headache. The level of review that is necessary 

to do it is complicated. These folks do it better than most places. 

The folks in the southeast are probably doing it the best right now. 

But there are models there that we have to figure out how to actually get off the ground, because the scale of restoration that we 

need is massive. We are gone from doing a few million acres here. 

We need tens of millions of acres of your active management across 

the board. This is a big conversation we need to have. 

We can’t have this conversation without talking about acting on 

climate. I know it is a partisan issue. It shouldn’t be. We need to 

figure out ways to reduce emissions, because they are heating up 

these systems and making them worse. 

44 

There is a big oversight role for all of you too. I do worry about 

the fire funding fix when it kicks in. The extra money needs to go 

toward restoration. It needs to go toward active restoration, active 

management. It can’t just go to other programs. That is going to 

require some oversight, because the way the language is written, 

it doesn’t quite do that. 

And then finally, I would encourage, especially folks in the west, 

to try to figure out ways to get more members out to see the impacts. Because right now—I spend a lot of time in the west. I don’t 

think folks can fully appreciate the level of devastation in the 

southern California airshed, in these States. Breathing the soot for 

day after day, this is a big issue. And at a time when we are preparing for massive hurricanes, this is the time for serious people. 

And I would love to work with all of you, because as the great 

American poet Elvis Presley said, ‘‘a little less conversation, a little 

more action.’’ 

Thank you. 

[The prepared statement of Mr. O’Mara follows:] 

45 


36422.027

Testimony of Collin O'Mara 

President and CEO of the National Wildlife Federation 

Before the United States House of Representatives 

Committee on Energy and Commerce 

Subcommittee on Environment 

Hearing on Air Quality Impacts of Wildfires: Mitigation and Management Strategies 

September 13,2018 

Thank you to Chairman Walden, Ranking Member Pallone, Subcommittee Chairman Shimkus, 

Ranking Member Tonko, and the members of this subcommittee for convening this important 

hearing on a critical issue facing our communities, public health, and wildlife. 

My name is Collin O'Mara and I serve as the president and CEO of the National Wildlife 

Federation-America's largest conservation organization, comprised of 51 state and territorial 

affiliates and more than 6 million members who are committed to ensuring that wildlife thrive in 

our rapidly changing world. Prior to joining the Federation, I served as Secretary of Natural 

Resources and Environment lor the State of Delaware, where I oversaw forest management 

efforts on Delaware's State Parks and State Wildlife Refuges, as well as coordinated with our 

State Forester on projects to improve the health of our State Forests. 

Healthy forests underpin a healthy economy and help protect clean water, clean air, our climate, 

and essential ecosystems. Yet, the ability of our National Forests to do so has been jeopardized 

by inadequate restoration and management and escalating climate impacts, both of which 

exacerbate the threat and consequences of increasingly intense wildfires. 

Across our country, wildlife and human communities are living alongside the threat of wildfire. 

For high-risk communities that have not burned, residents fear evacuation orders and the 

ominous red glow fire casts on the horizon. For those that have experienced modern megafires, 

they are rebuilding or helping neighbors recover- even as the threat of future fires looms. 

Over the past three years, more than 25 million acres of U.S. forests have burned, including more 

than 10 million acres in both 20\5 and 2017. We are on pace to near 10 million acres burned 

again this year with more than 8.1 million acres burned this year-to-date. Right now, 84 wildfires 

are actively burning across 12 states from Alaska to Arizona, currently covering more than 1.4 

million acres, posing significant risks to people, property, and wildlife. We honor the brave 

firefighters and offer our deepest condolences for those who have lost friends and family. 

In our report issued last year, lo.4egatires: The Growing Risk to America's Forests, Communities, 

and Wildlife, the National Wildlife Federation demonstrated how these catastrophic fires are the 

leading edge of an emerging, tragic trend. Wildfires have been burning more intensely and 

frequently than in previous decades. These increasingly large, fast-spreading, intensely hot fires 

fueled by decades of fuel loading, fire suppression efforts, and climatic changes like 

decreased precipitation, warming temperatures, and increased pest problems have 

fundamentally altered the natural fire cycle and reduced the resilience of forest landscapes. 
46 


36422.028

Wildfire is a natural, and even healthy, phenomenon for forests and wildlife habitat, but this new 

normal is anything but for millions of Americans and the forests central to our wildlife heritage. 

Last year, we saw smoke so thick in places, like Missoula, Montana, and Los Angeles, 

California, that residents couldn't see across their front yards. Again today in Southern 

California, Eastern Oregon, and other states, children and the elderly are choking on smoke and 

need filters to simply breathe. These situations, particularly tragic for low-income families and 

those on fixed incomes, are becoming commonplace in our age of escalating megafires. The 

unhealthy levels of fine particulate matter (especially PM 2.5 and PM 10) and toxic fumes (such 

as heightened ozone levels caused by the reaction of oxides of nitrogen, volatile organic 

compounds, and carbon monoxide) exacerbate risks of asthma, pneumonia, and other respiratory 

and cardiac problems. In some cases, the increase in air pollution due to wildfires is 

undermirli!.lg vears of progress reducing air pollution from power plants, industrial facilities, and 

vehicles. Studies have shown that the annual carbon emissions released by U.S. wildfires can 

range from 160 million to 290 million tons, which is the equivalent of are equivalent to the 

emissions of34-63 million passenger vehicles or 2-4% of total U.S. carbon emissions. 

The National Wildlife Federation firmly believes that collaborative, science-based active 

restoration of our forests, including ecologically-sound controlled burns and mechanical 

treatments, is absolutely necessary to improve forest health. We believe providing sufficient 

funding, enhancing collaborative forest management, advancing ecologically-sound prescribed 

burns, acting on climate, and ensuring implementation oversight are all necessary components of 

a comprehensive strategy. Here arc our specific recommendations: 

Providing Sufficient Funding 

This March, Congress took a significant step forward to address the problem of wildfire by 

passing the fire funding fix. Unlike other disasters, such as hurricanes, wildfires have been 

ineligible for disaster assistance under the Stafford Act and thus the Forest Service has been 

forced to raid other accounts, such as forest restoration programs, to fund tire response activities. 

This ends up reducing the pace and scale of restoration efforts that could have otherwise reduced 

fire threats in future years. The fire funding fix adopted this spring eliminates this uncertainty by 

capping the amount of money that the Forest Service has to spend of fire response, before having 

access to emergency funding. This should free up significant resources for proactive forest 

restoration efforts in future years. 

We at the National Wildlife Federation were proud to champion this effort alongside Members of 

both parties. Unfortunately, the funding component of the final compromise does not take effect 

until Fiscal Year 2020, which provides no funding relief for this year's catastrophic fires. 

We urge Congress to fully fund and implement this common-sense strategy as soon as possible, 

while continuing to provide sufficient annual appropriations the federal land management 

agencies need to manage our forests and respond to wildfires. 
47 


36422.029

Enhancing Collaborative Forest Management 

A flexible, collaborative decision-making process is key to minimizing the threat of megafires. 

The U.S. Forest Service recently released a new plan, "Toward Shared Stewardship Across 

Landscapes: An Outcome-Based Investment Strategy," for managing forests more effectively to 

reduce fire risks. Built upon the new funding and management tools Congress provided the 

agency alongside the fire funding fix, the Shared Stewardship strategy represents an important 

start to improving collaborative, landscape-scale management of our National Forests. That said, 

we also see greater opportunities for USFS to integrate climate-smart adaptation practices into all 

restoration projects that improve forest resilience, improve wildlife habitat, and increase carbon 

sequestration volumes. 

Building upon the fire funding fix and additional tools provided by Congress to restore the 

resilience of our forests and reduce risks from future fires, the Farm Bill conference committee 

and the negotiators of the Interior Appropriations bill are currently considering additional 

proposals to improve collaborative forest management. 

If Members want to explore additional tools, it is clear the best path forward is the bipartisan 

approach that resulted in Congress recently passing the fire funding fix. Promising proposals 

with potential bipartisan support include: 

Reauthorizing the Collaborative Forest Landscape Restoration Program. 

Adding lodgepole pine restoration projects in Fire Regime IV to the Healthy Forest 

Restoration Act categorical exclusion for priority projects, and to the list of projects that 

can receive the expedited, focused analysis of the proposed action, no action, and a 

possible third alternative. 

Reauthorizing appropriations to treat insect and disease infestations. 

lncentivizing forest management projects under the Good Neighbor Authority by 

ensuring receipts from any timber sold through these projects can contribute to covering 

the costs incurred by non-federal project partners, and that any receipts in excess of costs 

are available for the Forest Service to spend on other Good Neighbor Authority or other 

forest restoration projects on National Forests in the same state. 

Expanding Good Neighbor Authority to include Tribes and counties with sufficient 

capacity to conduct work in accordance with adopted forest management plans. 

Passing the Timber Innovation Program, currently in the Senate Farm Bill, to create new 

markets for wood byproducts from forest restoration projects. 

Advancing Ecologically-Sound Prescribed Burns 

Though it may seem counter-intuitive, increasing prescribed burns is one of the most effective 

tools to improve forest health and reduce long-term adverse public health impacts, especially 
48 


36422.030

when combined with strategic efforts to reduce fuel loads in ways that do not harm biodiversity. 

While some debate has emerged about the health tradeoffs of engaging in strategic prescribed 

burns as a key management strategy to mitigate long-term fire risks, studies have consistently 

shown that prescribed burns emit 10 times to 100 times less particulate matter than wildfires. 

USFS and States take significant precautions to reduce the health impacts from prescribed burns, 

such as establishing hourly and daily PM 2.5 limits, as well as specific plans to support at-risk 

populations, but it should not be lost that the health impacts of uncontrolled wildfires are on 

average 90-99% worse than prescribed burns. 

We agree that funding, interagency collaboration, and insufficient capacity are the most 

significant barriers to increasing the utilization of prescribed burns-obstacles that the fire 

funding fix should help alleviate. 

We do not believe that changes are necessary to the Clean Air Act to allow for more prescribed 

burns, but we do believe that EPA guidance and state-level policies could be more supportive 

and disincentives could be removed. For example, there is a perverse incentive whereby 

emissions from prescribed burns ("anthropogenic ignition") are included in the calculations to 

determine whether a state is in attainment of the National Ambient Air Quality Standards, but 

wildfires ("natural ignition") are regularly excluded, despite typically emitting 90-99% more 

pollution. This is exactly backwards and unwittingly dis-incentivizes states from taking proactive 

measures to reduce risks of more-polluting megafires. Instead, EPA should account for all 

emissions and prioritize the granting of wildfire accounting exceptions to those states and 

communities who have ecologically-sound and landscape-scale fire programs. 

Further, the federal government could play a much more proactive role in bringing stakeholders 

together to advance best practices to accelerate the adoption of prescribed bums. The USFS 

Shared Stewardship Strategy takes important steps in this direction and we arc working with 

Secretary Perdue to implement its recommendations. In addition, states should be encouraged 

and incentivized to continue to improve their Smoke Management Plans and implement best 

practices that protect public health, such as f1exibility for communities that take measures to 

protect vulnerable populations, while encouraging greater collaboration and resourcing to ensure 

that prescribed burns occur at appropriate times and scales. 

Acting on Climate 

No conversation about improving forest health is complete without confronting the changing 

climatic conditions that are exacerbating megafires, especially less precipitation, drier soils and 

vegetation, and warmer temperatures. We urge Members to collaborate across party lines to 

advance bipartisan solutions that reduce greenhouse gas emissions through the accelerated 

adoption of land management practices that increase the carbon sequestration capacity of natural 

systems, like forests, grasslands and wetlands, as well as from fossil fuel sources through 

market-based mechanisms (e.g. price on carbon). 

Ensuring Implementation Oversight 
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Congress should prioritize making sure the Forest Service effectively utilizes the additional 

funding and management tools recently provided to USDA. The Committee should also ensure 

the agencies is applying the freed-up funding and policies in a climate-smart, wildlife-friendly 

manner that improves the resilience of forest habitats to disturbances and threats and 

simultaneously reduces overall adverse impacts to air quality. 

Conclusion 

We appreciate the Committee focusing on identifying solutions that would reduce these health 

consequences of escalating mcgafires. We encourage the Committee to pursue the numerous 

bipartisan, science-based solutions that are within reach. We believe that a comprehensive 

approach, including providing sufficient funding, enhancing collaborative forest management, 

advancing ecologically-sound prescribed burns, acting on climate, and ensuring implementation 

oversight, will benefit people and wildlife alike. Thank you for the opportunity to testify on this 

critical issue. 
50 

Mr. SHIMKUS. The gentleman’s time expired. 

Defending my colleagues here, I think this is actually a pretty 

good turnout. We do have a bill on the floor. We do have a Health 

Subcommittee hearing upstairs. So this is not bad, so—— 

Mr. WALDEN. Mr. Chairman, you might point out that this is a 

subcommittee too. When we are in full committee, all these seats 

are filled, as they were this morning. So just for the audience. 

Mr. SHIMKUS. I would agree. 

Reclaiming my time. The chair now recognizes Mr. Boggus, the 

State Forester and Director of Texas A&M Forest Service, on behalf of the National Association of State Foresters. 

You are recognized for 5 minutes. 

STATEMENT OF TOM BOGGUS 

Mr. BOGGUS. Thank you Chairman Shimkus and Ranking Member Tonko and Committee Chair Walden. I am glad all of you are 

here. And I am glad to be here to talk about this important issue 

today on air quality and wildfire. 

My name is Tom Boggus, and I am the State Forester and Director for the Texas A&M Forest Service. I am here to testify on behalf of the National Association of State Foresters, where I serve 

on the—member of the Wildland Fire Committee, as well as the 

past president of the Southern Group of State Foresters, which represents the 13 southeastern States. 

I have spent 38 years in forestry and fire, and I am honored to 

share some of that experience with the subcommittee today. 

The NASF and the regional associations like Southern Group 

represent the directors of the Nation State Forestry Agencies. We 

deliver technical and financial assistance, along with fire and resource protection, to more than two-thirds of our nation’s 766 million acres of forestland. We do this with critical partnerships and 

with investments from the Federal Government, including U.S. 

Forest Service State and Volunteer Fire Assistance Grants, which 

provide equipment and training to the firefighters who respond to 

State and private land where over 80 percent of our nation’s 

wildfires begin. 

This has been a heck of a year across the country. You have 

heard that. And Texas was no exception. We had over 8,000 

wildfires burning over half a million acres so far in 2018. The fire 

activity impacts responders at local, State, and national levels. 

The first impact is to communities. And what many people don’t 

understand and realize is that, in Texas, 75 percent of our wildfires 

occur within 1 mile of a community. Most of these fires, historically 

91 percent, are suppressed by the local responders. The other 9 

percent, when their capacity is exceeded, require local, State, and 

often national resources to control. 

Wildfires affect us all. I don’t care whether you are rural or 

urban, local or State or national. At the State and national level, 

demand to respond does not go away. And you just heard from my 

colleague here that in the wildfire community, we have quit using 

fire season and we started using fire year, because it is much more 

accurate. Because there is a wildfire season somewhere, and 

wildfires are happening somewhere across America at any time. 

51 

Fire has always been a natural part of the ecosystem in Texas, 

in the south, and, really, a lot of parts of the country. However, for 

many reasons, wildfires have become increasingly detrimental to 

the forests and communities around them, including the generation 

of catastrophic amounts of air pollutants. That is why we are here 

today. 

So what can we do to address the massive amounts of wildfire 

smoke? My State forester colleagues and I put a great deal of emphasis on proactive prescribed burning. During the times of year 

when fire risk is low, you have already seen it, where fire size and 

smoke emissions and community notification can be managed effectively as compared to an unplanned or an often catastrophic wildfire. 

In the southern part of the country, we have a long history of 

getting prescribed fire accomplished on the ground. We have 

formed a fire management committee in the States consisting of a 

fire director from each of the 13 States, and we work together on 

shared practices, best management practices. For example, we created the Southern Wildfire Risk Assessment Portal, or 

SouthWRAP. And it is especially important in an urbanizing State 

like Texas. 

We build and maintain strong partnerships with landowners and 

local governments in implementing partnerships with State environmental quality agencies, Federal land management agencies to 

get prescribed burning done and forest management done collaboratively. 

In Texas, unlike the west, 94 percent of our land is privately 

owned, and prescribed fire is primarily conducted by private landowners. Texas is a big and diverse State. And the reasons for conducting prescribed burning are just as diverse as our geography. 

We recently developed a State smoke management plan to provide best management practices for our landowners and these cooperators and certified burners. The plan provides resources for 

these professionals to utilize in order to minimize the smoke from 

their prescribed burns. 

Environmental regulations such as air quality are under the authority of the Texas Commission on Environmental Quality, the 

TCEQ. Now, that is a great conversation in the education process, 

but they are a great partner, and they understand and have said 

last week at a hearing in the State that we need more fire on the 

ground in Texas and more prescribed fire and not less. 

So once again, I want to thank you for this opportunity to testify 

and appear before you. I look forward to answering any questions. 

And if I can share more expertise that we have in Texas and the 

south related to wildfire, hazardous fuel reduction, and prescribed 

burning. 

Thank you, sir. 

[The prepared statement of Mr. Boggus follows:] 

52 


36422.032

Testimony of Tom Boggus, Texas State Forester 

On Behalf of The National Association of State Foresters 

Submitted to the U.S. House Committee on Energy and Commerce, 

Subcommittee on the Environment 

For Hearing on 

Air Quality Impacts of Wildfires: 

Mitigation and Management Strategies 

September 13, 2018 

Good morning, Chairman Shimkus, Ranking Member Tonko, and Members of the 

subcommittee. My name is Tom Boggus, State Forester and Director of the Texas A&M Forest 

Service, as well as an active member of the National Association of State Foresters' (NASF) 

Wildland Fire Committee and past President of the Southern Group of State Foresters (SGSF). 

appreciate the opportunity to speak with you today and submit written testimony as the 

Committee considers the significant impacts of wildfire smoke on citizens and communities 

across the country, as well as the preventive role prescribed fire and hazardous fuels reduction 

can have in mitigating smoke impacts. 

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

and the District of Columbia. While an independent organization, the SGSF represents 15 of 

those same State Foresters from across the South, Puerto Rico and the US Virgin Islands. State 

Foresters deliver technical and financial assistance, along with protection from wildfire and 

protection of forest health, water, and other ecosystem services for more than two-thirds of our 

nation's 766 million acres of forests. Through the State Fire Assistance (SFA) and Volunteer 

Fire Assistance (VFA) programs, state agencies equip prescribed fire managers and wildfire 
53 


36422.033

initial attack resources for state and private lands where over 80% of the nation's wildfires start. 

In addition, State Foresters have a critical role in maintaining healthy forests and minimizing 

wildfire risk through a variety of management techniques, including preemptive hazardous fuels 

reduction through tree thinning and prescribed fire. 

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. As such, we are intimately aware of the increasing 

occurrence of wildland fire and associated smoke impacts in nearly every state. State forestry 

agencies also work closely with our federal partners in managing complex multi-jurisdiction 

landscapes, both in wildfire response and in preemptive prescribed burning. As we often say 

"fire knows no borders", and thus aim to carry out management and planning across ownerships. 

Summary of Annual Fire Activity 

The current fire season that is still very active has been one of the most newsworthy in recent 

memory, with numerous incidents making national news. As of September 10, over 47,000 fires 

have burned more than 7 million acres across our country since the beginning of 2018 1

, with 

significant fire activity still expected before the year is out in California and parts of the 

southeast. Roughly 75% of those fires have been on state or private land, and thus under the 

response jurisdiction of State Foresters and local rural/volunteer fire departments. 

1 https:j /www. nifc.gov/firelnfo/nfn.htm 
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In Texas, we have seen 8,045 wildfires burn 518,074 acres so far in 2018- with 9,647 homes 

reported as saved from wildfires and 108 lost This fire activity directly impacts responders at 

the local, state and national level. The first impact is to the communities and local responders 

across our state- with 75% of Texas wildfires occurring within one mile of a community. While 

most of these fires (historically 91 %) are extinguished by local resources -the other 9% become 

the large, multiple-day incidents that account for roughly 2/3 (63%) of the acres burned in Texas 

-and require local, state and national resources to control. 

Wildfires affect us all rural & urban areas as well as at the local, state and national levels. 

At the state and national level- the demand to respond does not go away. The wildfire 

community has moved from using the term "fire season" to "fire year'', as wildfire is now a 

threat somewhere in our nation at all times of the year, and in places the local threat is yearround. Over the past 12 months, there has been virtually no area of the country immune from 

wildfire incidents and the associated smoke impacts. This year has been particularly noteworthy, 

in that fires and their impacts have not been localized to the forest-based communities most 

experienced with living with fire. Large cities, often far from the forests on fire, have 

experienced signitlcantly reduced air quality, impacting human health, community events, 

tourism, recreation, and much, much more. The issue of how to manage smoke from wildfires is 

an increasingly essential one to address. 

Our Nations Forests and Wildfire 
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36422.035

Fire is a natural phenomenon for nearly every forest ecosystem in this country. Fire has shaped 

the occurrence and distribution of different ecosystems for centuries, simultaneously impacting 

the human and natural communities that live in and around those forests. Over the past century, 

a culture of fire suppression has w1fortunately removed the natural role of fire from the public 

consciousness to varying degrees in different regions; however, when combined with a reduced 

level of forest management in many areas of the country this culture has also led to the build-up 

of hazardous fuels to historic levels. Our forests arc currently more fire-prone than ever. 

What Federal, State and local fire managers as well as scientists and researchers have learned 

over the past decades is the critical role of hazardous fuels management in mitigating wildfire 

impacts. Solely focusing on wildfire suppression and ignoring proactive forest management 

does not lead to the least amount of fire in the long run; the fuel continues to build up to the point 

where eventually wildfires become Wlmanageablc under initial attack. The task for wildfire 

managers is to manage the risk to communities and ecosystem values in both the short-term and 

long-term by implementing a coordinated and science-based program of fuels reduction, fire 

suppression, and community planning. Our forests will inevitably burn, the task is to figure out 

how this phenomenon can occur with the least impact, including from wildfire smoke, on 

communities. 

Wildfire and Air Quality 

The air quality impacts from forest tire smoke have long been scientifically documented. Of 

primary concern is patiiculate matter (PM), which is produced from the combustion of woody 

material. Specifically, particulate matter smaller than 2.5 microns (PM 2.5) is of concern for 
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36422.036

individuals exposed to wildtire smoke due to its ability to penetrate deep into the lungs and 

respiratory system. PM 2.5 can cause both short-term health effects such as eye, nose, throat and 

lung irritation, coughing and shortness of breath, as well as long-term effects on respiration and 

the worsening of medical conditions such as asthma and heart disease. Air quality impacts from 

wildfire often hit the hardest in sensitive populations (i.e. children, elderly and those with preexisting conditions). In addition to human health, reduced air quality from wildfire smoke can 

impact tourism, recreation, education, and a variety of other aspects of community life. 

The differing air quality impacts from prescribed tire compared to unplanned wildfire arc 

important to recognize. One of the keys to prescribed tire for hazardous fuels management is 

that it is done in seasons and under conditions where fire managers have the ability to control fire 

location, spread, intensity, and many other parameters. Weather forecasting and slate-of-the-art 

smoke modeling software allow for fire managers to tailor ignition locations and times to meet 

smoke management objectives. While each state has different laws and regulations around 

burning permits and number of allowable burn days, fire managers work within these parameters 

and laws to manage a minimal amount of smoke now in avoidance of the potential for a much 

greater amount in the future. 

The beneficial impact of managed prescribed fire on air quality emissions has been recognized 

by the US Environmental Protection Agency (EPA) in its rulemaking over the past years. In 

both the updating of the National Ambient Air Quality Standard (NAAQS) for PM 2.5 (81 CFR 

164, pg. 58010) and the updating of the Exceptional Events Rule (81 CFR 191, pg. 68216), the 

EPA clearly documents the role of wildfire as an emissions source and the relevance of 
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prescribed fire use and fuels management to reduce the risk of catastrophic wildfire. It is 

becoming increasingly evident through science and experience that without prescribed fire and 

the small amount of managed smoke that comes with it, we are perpetuating the conditions that 

generate catastrophic air quality issues and put communities and individuals at risk. 

Managing Prescribed Fire for Air Quality in the South 

The Southern part of the country has a long history of managing fire in its forests, and in 

coexisting with the smoke that necessarily comes along with fire, whether it be planned or 

unplanned ignitions. In 2017, the top eight states in terms of number of acres of prescribed fire 

carried out were in the South, including my state of Texas with almost 200,000 acres 2. Those 

eight southern states accounted for over 85% of the prescribed fire acres in the country in 2017. 

The reasons that southern states are able to successfully implement such a large program of 

prescribed fire work arc numerous and vary from state-to-state, but there a few regional 

commonalities that I would like to highlight. 

First is the expertise of our state fire and forest managers, and their diligence in planning. 

Within the South, we have formed a Fire Management Committee, consisting of the Fire 

Directors from each of our 13 States, who work together to share best practices and develop tools 

that support the whole region. One such tool is the Southern Wildfire Risk Assessment Portal 

(South WRAP) 3 • South WRAP is the primary mechanism for the SGSF to make wildfire risk 

2 Source: National Interagency Fire Center1 

https:/ /www. p redi ctivese rvi ces. nifc.gov /i ntelligence/20 17 _ statss u m m/fi res_ acres 17. pdf 

3 https:/ /www.southernwildfirerisk.com/ 
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36422.038

information available and create awareness about wildfire issues for the Southern states. It is an 

excellent tool for establishing the basis for "where" and the justification for "why" subsequent 

prescribed burning is necessary. 

This expertise of our state staff and pru1ners has also been used to generate educational materials 

to ensure that proper best management practices are followed by those conducting burns, 

minimizing smoke impacts and helping retain social license to burn. One such example is the 

Prescribed Fire Smoke Management Pocket Guide, created by the Coalition of Prescribed Fire 

Councils and the Southeast Regional Partnership for Planning and Sustainability (SERPPAS).4 

The Pocket Guide includes how-to videos on basic smoke management guidelines, fact sheets on 

specific smoke-related issues, and a comprehensive list of additional resources to help any 

prescribed burn manager complete their job effectively and efficiently from a smoke perspective. 

In Texas, state and federal agencies implement prescribed tire programs, but most prescribed fire 

is conducted by private landowners. Therefore, my agency is using concepts of the pocket guide 

to develop materials aimed at private landowners. Recently, we have worked to develop a Texas 

State Smoke Management Plan to provide best management practices to landowners and 

cooperators. The plan provides resources for prescribed burn managers to utilize in order to best 

manage the smoke from their prescribed burns. 

A second reason that the South has such a strong record of prescribed burning is that our state 

forestry agencies have built strong partnerships in many arenas which help facilitate prescribed 

4 http://smokeapp.serppas.org/ 
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burning work getting done on the ground. In many of our states we have employees in every 

county that work with local government and landowners to make them aware of any planned 

burning and keep community support for such necessary activities. Our states also work with 

many partners, NGOs, and federal agencies to accomplish the planning, treatment prioritization, 

and eventual work on the ground. In the spirit of the Cohesive Wildland Fire Management 

Strategy, our States and our partners across the region team up regularly to create and restore 

resilient landscapes with prescribed fire. The Cohesive Fire Strategy provides a framework to 

minimize the risks associated with wildland tire in the Southeast while increasing the region's 

tire-resiliency. 

Additionally, good communication and partnership with the State environmental regulatory 

agencies is essential to help them understand the need for prescribed fire, allowing some 

emissions under good weather conditions in order to avoid massive emissions down the road. 

One regional example of such efforts is regular "smoke summits" that have been organized with 

University extension specialists, staff from EPA Region 4, and air quality officials and fire chiefs 

from the eight southern states in that EPA region5 to discuss issues around smoke management 

and air quality. These are the only regional meetings of this type in the country. 

Finally, the land ownership matrix in the South, with our forests being primarily privately 

owned, allows for fewer process hurdles to getting work done. Each of our states, including 

Texas, has a process in place to permit and track prescribed burns throughout the year. This is 

important because over 94 percent of Texas is privately owned and the majority of prescribed 

5 EPA Region 4 includes Alabama, Florida, Georgia, Kentucky1 Mississippi, North Carolina, South Carolina, and 

Tennessee 
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36422.040

burning is done by private landowners. Texas is a diverse state from the forestlands in east Texas 

to the rangelands in central and west Texas. The reasons for conducting prescribed burning are 

just as diverse as the geography of Texas. Some fire managers utilize it to reduce fuel loading to 

protect communities, some usc it to improve rangeland, watershed quality, and wildlife habitat, 

and still others use it to manage forest or ecosystem health. This requires a collaborative 

approach to prescribed fire. Because of this, the statutory authority for prescribed burning was 

placed under the Texas Department of Agriculture. The Texas Department of Agriculture's 

Prescribed Burning Board (PBB) regulates the Certified Prescribed Burn Manager Program. The 

Board is comprised of representatives of state agencies, private landowners, and researchers. In 

Texas there are 64 certified burn managers and there are 11 prescribed fire councils. 

Environmental regulations such as air quality arc under the authority of the Texas Commission 

on Environmental Quality. 

In other parts of the country that have a majority of federal forest land, the NEPA planning and 

associated processes for burning projects can be cumbersome, or the staff and resources to carry 

out the burning can be lacking. Finding new and unique ways to accelerate the pace and scale of 

prescribed burning and active timber management on federal lands across the country is key to 

reducing wildfire risk and associated extreme smoke emissions, which is why making use of 

opportunities like Good Neighbor Authority (GNA) on federal lands is so important no matter 

what region of the country you are in. One of the essential ingredients for the substantial amount 

of prescribed burning on the South's primarily privately-owned forest landscape is a 

commitment by States and partners to hire and train the requisite staff to get the work done. Our 
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federal forests need to be similarly equipped for the pace and scale of active management that 

faces them. 

Conclusion 

Thank you again for the opportunity to appear before the Committee today on behalf of the 

National Association of State Foresters. Managing fire in Texas's forested landscapes is one of 

the most challenging facets of my job, as it for most of my colleagues in their respective states. 

As State Foresters, we believe we need to be doing significantly more hazardous fuels reduction 

all across this country and arc working towards this goal as individual members and as an 

association. I am proud of the work our state fire managers and partners are accomplishing on 

the ground. Such treatments allow us to put fire on the landscape at times and under conditions 

that minimize impacts, including smoke emissions. These treatments reduce fuel loading in the 

forests so that when wildfires inevitably occur, they burn with less intensity, reduced spread and 

fewer smoke impacts on communities and firefighters. 

My colleagues and I look forward to continuing our strong working relationships with the federal 

agencies, state and federal environmental quality agencies, and other partners, as well as working 

with Congress to facilitate more good work getting done on the ground. 
62 

Mr. SHIMKUS. Thank you very much. 

Seeing no other members of the panel, I would like to recognize 

myself 5 minutes to start the round of questions. 

And, Mr. O’Mara, I want to go with you just because of your 

opening statement. And I think you alluded to a missed opportunity in the minibus. I know you can fill the space, just briefly tell 

me, what was the missed opportunity? 

Mr. O’MARA. Yes. In the fire funding fix that was passed in 

March as part of a big budget deal, there was a provision that was 

snuck in at 3 a.m. that basically moved it from being 2018 fiscal 

year to 2020 fiscal year. There is no increased funding through the 

fire fix for the next fiscal year. So you are not going to have the 

additional money that you all passed for 14 more months. There is 

some supplemental money that folks here and Udall and Murkowski put in, but the actual tool isn’t available when we are having these horrible conditions. 

Mr. SHIMKUS. Great. Thank you very much. 

Let me go to Ms. Anderson and Ms. Germann. Compare and contrast for me the risk challenges and the environmental quality aspects of a forest fire and the resulting smoke and stuff versus auto 

emissions in coal-fired power plants. 

Ms. ANDERSON. So in Idaho, we don’t have any coal-fired power 

plants. The next biggest emitter are—we do have quite a bit of 

open burning. We have agricultural burning, backyard burning, a 

lot of auto emissions. We don’t have a lot of industry in Idaho. So 

by far, the wildfire emissions are the biggest air pollution source 

that we just can’t manage. We have to react to. 

Mr. SHIMKUS. Ms. Germann. 

Ms. GERMANN. Yes. Thank you. I lack the specifics on any type 

of coal emissions. But I can say anecdotally, certainly, wildfire 

smoke is, by far, the largest polluter within the State. 

Mr. SHIMKUS. Great. 

Let me go to Mr. Boggus. In your testimony, you say that, ‘‘Our 

forests are currently more fire prone than ever.’’ I think Mr. 

O’Mara may have alluded to that. Some of the opening statements 

would. 

Why do you believe that is the case? 

Mr. BOGGUS. We need more active management. And I think several people on the committee have alluded to that. And I think 

when you have a built up of fuel—and what we haven’t even really 

talked about is the land use changes that have happened. We have 

got more people living in and around our forests, but the fuel loads 

are increasing every year. 

Mr. SHIMKUS. And when you use that terminology for, the fuel 

load is increasing, what are you referring to? 

Mr. BOGGUS. There is more available to burn in the woods than 

there ever has been. 

Mr. SHIMKUS. So, Mr. O’Mara, I am not picking on him. He mentioned the threat of clear cutting. We are not talking about clear 

cutting large swaths of ground. We are talking about what? 

Mr. BOGGUS. No. We are talking about active management, forest management of the resource. 

Mr. SHIMKUS. Removing some of those fuels. 

63 

Mr. BOGGUS. Yes. That doesn’t mean harvesting, that doesn’t 

mean thinning. But that means keeping forests healthy. And I 

have great examples, and we won’t have time to get into them, but 

examples in Texas where a managed forest, even if you have severe 

drought or you have wildfires, the managed forests bear better and 

you don’t have the catastrophic damage that you do to wildlife 

habitat and the resources that you do with unmanaged forests. 

Mr. SHIMKUS. Let me go to Mr. Baertschiger—Senator, I am 

sorry—for that same question. 

Mr. BAERTSCHIGER. Well, from a fire science perspective, you always have to remember, you have to have drying of the fuels to a 

point where they can be ignited and sustain ignition, and you have 

to have ignition. You can have the driest and even huge fuel loadings, and if you don’t have ignition, you have no fire. 

And so when I talk about the human element, that is something 

that I have been tracking now for about 10 years of really looking 

at it. So we are having more and more of these fires that are 

caused by the human element. And when we get more and more 

fires, then we spread our resources and we can’t concentrate on 

putting one out because it is kind of like whack-a-mole. 

Mr. SHIMKUS. Of the fires we are experiencing, percentagewise, 

how much are natural caused and how many are caused by human 

intervention, a fire not left, or someone—we have had some intentional fires set. 

Mr. BAERTSCHIGER. Yes. When I referred to human cause, I am 

not talking about an arsonist. I am talking about it can be a power 

line failure, it can be a chain dragging from a vehicle down the 

road. It is something that has to do with a human, that we 

wouldn’t have that fire if we didn’t have that human element into 

it. And it is getting close to 9 out of 10 fires. 

Mr. SHIMKUS. OK. Great. 

My time is close to be expiring. I will turn to the ranking member, Mr. Tonko, for 5 minutes. 

Mr. TONKO. Thank you, Mr. Chair. And again, welcome, to all of 

our witnesses. Thank you for your expert testimony. 

And, Mr. O’Mara, you made the observation that a great many 

of us agree about the severity of the problem and the need to move 

forward. And I am hoping that somehow we can be inspired to 

come up with solutions that incorporate the professionals that 

manage these resources in such an outstanding manner. 

I want to start with the big-picture question before we get into 

the specifics on forest management. How important is addressing 

climate change which we know contributes to conditions that exacerbate the number and severity of these fires for a long-term fire 

mitigation and our forest management strategy? 

Mr. O’MARA. Look, we have to address the underlying stressors 

of the system long term. Those aren’t improvements that will happen overnight. There are a lot of things we have to do in the near 

term. But if we want to have long-term kind of sustainable health, 

we have to bend the curve on the warming planet. 

Mr. TONKO. And in March, Congress passed the fiscal year 2018 

omnibus appropriations bill, which included changes to how we 

fund the United States Forest Service’s fire response beginning in 

2020. And you alluded to that funding. 

64 

Does everyone agree it is important to provide greater funding 

for more proactive forest management to reduce the risks of these 

large wildfires? 

Mr. O’MARA. Absolutely. I think the more that we can do, to my 

colleague’s point, thinking about private lands, State lands, Federal 

lands—these are the same landscapes. The ownership might be different, and I do think providing additional funding for certain tools 

like prescribed burns could be very effective. 

I actually don’t think that the fix itself is going to end up being 

sufficient long term, even just given the scale of the—we are talking another 10 million acres this year probably by the time we are 

done. We are escalating in a pretty concerning way. And I think 

you are going to need more money, frankly; not less. 

Mr. TONKO. So is that the additional work that we need to secure 

here, or is there something more than just the dollars that are required as we go forward with the fix? 

Mr. O’MARA. From my point of view, I think there are additional 

tools that we can provide. I think there are some very important 

tools that were provided as part of the funding fix in March. 

A few of the ones that just kind of come to mind, top of mind, 

is there is like the collaborative forest landscape program that is 

a very effective tool that is in the current draft of the farm bill, assuming that gets done. There are some things around funding disease and infestation. There are things around Good Neighbor Authority, like you mentioned, making sure that works for everybody, 

including tribes, including other partners, counties in some cases 

that are bigger. 

There are some innovation programs for trying to have markets 

for some of these products, because one of the worries I have is 

that if we don’t create robust markets and trade comes into this, 

because, a lot of the timber guys are struggling right now because 

the markets are closing, in China in particular. And so there is a 

bigger conversation with the economic consequences, making sure 

they have a place to put this material into good use. 

Mr. TONKO. Thank you. 

And based on the recommendations of NWF’s Megafires report, 

do you have other suggestions on how Congress and the administration can help reduce the threat of wildfires? 

Mr. O’MARA. I would encourage this committee to convene some 

of the stakeholders and the agency heads that are involved. Secretary Perdue and his team have done a really nice job, Acting Director Administrator Christiansen and Jim Hubbard. 

I think pulling together some folks at EPA and having conversations about how we encourage more prescribed burns and the way 

they are protective of public health, having some more clear guidance could be helpful. And then also highlighting the success of 

particularly the Montana-Idaho collaborative event, because I do 

think that is a model that could be replicated in other places. 

There is good collaborative in California as well that could be replicated. But we have to elevate these best practices in other places, 

because we are going to see the impacts get worse over time. 

Mr. TONKO. And a few people have mentioned forest provisions 

included in the House farm bill, H.R. 2, although there have been 

65 

criticisms that they go too far in undermining environmental laws, 

including NEPA and the Endangered Species Act. 

Do you have any thoughts on those provision? 

Mr. O’MARA. Yes. I am happy to provide additional detail, kind 

of point by point on them. I think there is a series of them that 

are very bipartisan. I think there are a few that probably go a little 

too far in some of the categorical exclusions. We probably should 

be using the ones that we have right now. I think the one that was 

passed before was the most important one from March. 

And I think the more that those conversations are being directed 

by the science, by the experts, the better. But I do think there is 

a suite of four or five of them that easily could move through this 

farm bill. And I would love to work with you offline to tell you exactly which ones those are. 

Mr. TONKO. Sure. I appreciate that. 

With that, Mr. Chair, I yield back. 

Mr. SHIMKUS. The gentleman yields back his time. 

The chair recognizes the chairman of the full committee, Mr. 

Walden. 

Mr. WALDEN. Thank you again, Mr. Chairman. Thanks to my colleagues for participating in this hearing and to all our witnesses 

for being here today. 

I want to talk about some of the issues that we have run into, 

some of the data that we have. According to the Georgia Institute 

of Technology, when they did a study on this, found that wildfires 

burning more than 11 million acres spew as much carbon monoxide 

into the air as all the cars and factories in the continental U.S. 

during those same months. I am sorry, that was California Forestry Association. You are probably familiar with these data points. 

And the Intergovernmental Panel on Climate Change, the IPC’s 

fourth assessment report on mitigation said in 2007, ‘‘In the long 

term, a sustainable forest management strategy aimed at maintaining or increasing forest stocks while producing an annual sustained yield of timber, fiber, energy from the forest will generate 

the largest sustained carbon mitigation benefits.’’ 

So, basically, healthy green forests sequester carbon. Dead, 

dying, old ones and ones that burn and re-burn actually emit carbon. 

So one of the provisions in the farm bill is something that we do 

on those other landscapes you referenced, Mr. O’Mara, and that is, 

after a fire, you harvest the burn dead trees where it makes sense 

and you replant a new green forest which will sequester carbon. 

Is that one of the provisions your organization opposes or supports? 

Mr. O’MARA. No, no. We have been supportive. 

Mr. WALDEN. Of the House farm bill provision? 

Mr. O’MARA. And we just want to make sure we are planting 

kind of smartly in terms of what is going to be sustainable in the 

long term. 

Mr. WALDEN. Sure. 

Mr. O’MARA. Oh, no. Absolutely. Yes. Absolutely. 

Mr. WALDEN. Yes. because it will be the types of trees for that 

area and the environment and all that. We got to be smart about 

it. 

66 

But what I hear, and, Senator, you may want to speak to this, 

because you both have been on the forest management side and 

had a career on the forest firefighting side, so you have seen both. 

Tell me what happens in these fires the second go-around after the 

trees on Federal ground have not been removed, the burned dead 

ones. What happens there when a fire breaks out the second time, 

which often is the case? 

Mr. BAERTSCHIGER. Well, on Forest Service lands, they are not 

going to replant after a fire. So when you have the first fire go 

through, the mortality rate of the live trees is pretty high. The second time or the third time it goes through, it takes out the rest of 

the trees. So there are no trees to cone out. Cone out means when 

a tree is starting to die, they will drop cones and reseed and start 

all over again. But after the second or third burn, there are no 

trees to do that. And so it changes the entire ecosystem of that forest. You will not have the same forest that you had. And that is 

what we are seeing in—and the dirt. Yes. Catastrophic high-density fire. 

Mr. WALDEN. This is the dirt which remains, which is called ash. 

Mr. BAERTSCHIGER. Yes. 

Mr. WALDEN. And on the second fire, doesn’t it make it even 

harder to maintain any kind of vegetation, frequently, because it 

burns the soils, it sterilizes the soil so deeply? 

Mr. BAERTSCHIGER. Our common terminology is it nukes the soil. 

Mr. WALDEN. Nukes the soil. How far down will it nuke the soil 

on a bad fire? 

Mr. BAERTSCHIGER. Just depends how hot it gets. And in southern Oregon, northern California where we have extremely high fuel 

loadings, in other words, tons per acre, we have a very hot, hot, hot 

fire. We can have 400-foot flames from some of those fires. 

Mr. WALDEN. Four hundred feet high? 

Mr. BAERTSCHIGER. Four hundred feet high, the flames. So depending on the severity, the hotter the fire, the deeper it is going 

to go into the soil. It can go pretty deep. 

Mr. WALDEN. Mr. O’Mara, I fully agree with you on the need to 

solve the fire borrowing issue. I have been an advocate of doing 

that from day one. It makes no sense. I am told there are statistics 

that—it costs four to five times as much to fight a fire as it does 

to do the kind of work you and I agree needs to be done on the 

forest. 

I had somebody in region 6 Forest Service at one point tell me 

70 percent of the Forest Service budget for these projects goes into 

planning, planning and appeals. And it seems like we have got a 

broken process, then, if all the money is going into the planning 

and not going to the ground. Do you agree? 

Mr. O’MARA. Yes. And I think there are two issues there. One 

is that I think there is some redundancy in the planning process. 

There are some things they could be streamlining. We are not bolstering the collaborative enough. If we have to go through a collaborate process, there should be a way of—— 

Mr. WALDEN. I was a cosponsor of that legislation to do landscape scale collaboratives that we are using in Oregon today. 

67 

And I think you said something too about we got to do bigger expanses on these collaboratives, right? Or on the treatment, because 

we are millions of acres behind. 

One of the other provisions in the farm bill would extend the categorical exclusions out to 6,000 acres. We have got millions we 

need to do. Three thousand is currently on the books, but only on 

certain forests in certain States have certain governors identified 

certain lands. 

So in southern Oregon where the Senator is from, our Governor 

didn’t designate any of those lands. But the provisions in the farm 

bill in the House would allow for a 6,000-acre CE where you could 

go in and begin this catchup work. And so I am hopeful we can get 

that into law. 

Our committee—while we want to believe we have complete jurisdiction over every issue on the books in the Congress, and I 

think we would be better off if we did, doesn’t fully have Forest 

Service jurisdiction, but this is our hook, because what is happening on Federal lands is dramatically, dangerously affecting the 

health of our citizens, and that is why linking to the air quality is 

so critical. 

Do you want to respond? 

Mr. O’MARA. Just one thing. Your point on the carbon emissions, 

in 20 to 30 percent of the global solution could come from repairing 

these kind of natural systems. 

Mr. WALDEN. Absolutely. 

Mr. O’MARA. It could be 10 to 15 percent of this country. When 

you are talking about the impacts just to the forests for the last 

few years, you are talking 36 million cars. Right? This is one of the 

most potentially bipartisan ways we restore our forests, we reduce 

emissions. It is a win for everybody. 

Mr. WALDEN. And you haven’t talked about the habitat, the 

water quality, et cetera, et cetera. My time is expired. The chairman has been very generous. Thank you, Mr. Chairman. 

Mr. SHIMKUS. The chairman is always generous to the chairman. 

So the chair now recognizes the gentleman from California, Dr. 

Ruiz, for 5 minutes. 

Mr. RUIZ. Thank you very much. And chairman, I agree with 

you, this is a definite public health concern. And there are two 

main points: One is that it is a public health concern, just recently 

in the fires in my district, I had to give a warning on social media 

to anybody who can smell smoke or see ash, especially vulnerable 

populations, the older, the young, and people with lung illnesses, 

that they should be inside in a closed air conditioned unit. 

The second main point that this tells us is that these fine particles, particle matter 2.5 microns and substance from a fire in 

California can travel clear across the country. So whether you are 

in a fire-prone State or not, it is an American issue and all of our 

public health can be in jeopardy. 

As we sit here today, there are 17 active wildfires burning across 

the State of California. The ongoing wildfire season has resulted in 

over 1.4 million acres burned, and the worst is likely yet to come 

due to climate change. As we know, that climate change can fuel 

the severity, frequency and the size of wildfires by increasing the 

duration of droughts, causing long stretches of low humidity and 

68 

high temperatures, and initiating early springtime melting, which 

leads to dryer lands in summer months. So we need to address and 

recognize climate change and do everything possible, or else we are 

not being as effective as we can. 

In August, the Cranston fire burned over 13,000 acres in my district outside of the community of Idyllwild. This fire exposed the 

residents of those mountain communities to numerous risks beyond 

just the flames themselves. While the fire burned, residents across 

southern California were subjected to increased air pollution as the 

smoke traveled across the region; these are kids with asthma; elders with COPD; people with pulmonary fibrosis, et cetera, were 

having more shortness of breath, visiting emergency departments, 

requiring more intensive care. 

The smoke and pollution from wildfires can affect populations far 

removed from these fires themselves. The fires in California can 

cause vast clouds of hazardous smoke that can affect the air quality for residents in Arizona, and Nevada and further east. 

So wildfires are regional disasters with national implications. 

And earlier this year, my Wildfire Prevention Act was signed into 

law, which extended the Hazard Mitigation Grant Program to any 

fire that receives a fire management assisting grant. Previously, 

this funding was only available to declared major disasters and not 

fire. Hazard Mitigation Grant Program funds may be used to fund 

projects that will help prevent and mitigate future fires. Some examples can include receding construction of barriers, hazardous 

fuel reduction or reinstalling ground cover. So Mr. O’Mara, can you 

speak to examples of mitigation projects that can be taken in the 

wake of wildfires that would be most helpful to preventing a repeat 

event? 

Mr. O’MARA. This is one of those great examples of an ounce of 

prevention would be worth a pound of cause. There are things you 

do on the landscape. You talked a lot about prescribed burns, you 

talked a lot about active management practices, they are ecologically sound, but there is also some common sense. We were 

building further and further into the wildland urban interface. 

Mr. RUIZ. Right. 

Mr. O’MARA. And you get folks that are building up into the 

hills. There is some common sense that we are putting people in 

harm’s way. And I do think there has to be some kind of accounting for that, and making sure we are not putting additional folks 

in harm’s way. It is unfortunate in some cases. These are beautiful 

places, but we allow people’s desire to live in the middle of the 

woods. 

Mr. RUIZ. What are some specific examples that households can 

do and that we can do as policymakers? 

Mr. O’MARA. Sure, there are things on building codes, making 

sure more fire resistant products and things like that, and some 

States have done that, or some local governments. There are things 

in siting that can be incredibly helpful. Making sure climate 

science is part of your planning process. There are a wide range of 

things that have people in less harm’s way. 

Mr. RUIZ. Ms. Germann, as a State forester, can you give examples of how you would use additional hazard mitigation funds to 

prevent future wildfire damage? 

69 

Ms. GERMANN. Yes, thank you. I can think of several. And I will 

speak specifically to working on private lands. Any funding that we 

get through State and private forestry, we are targeting lands 

within the wildland urban interface to work with landowners to reduce the fields in and around their home, and educate them on 

things like the home ignition zone. And we are finding that a lot 

of fires, homes also burn because of the expanse around the home, 

if they are not necessarily going to be planting fire resistant material, or shrubs, we try to work with people to educate them on the 

best type of landscaping that they can have. So it is going to take 

a couple of things, fuels reduction outside of that home and ignition 

zone and also work within and around homes. 

Mr. RUIZ. It is amazing to see the photos of the houses that were 

spared because of what they did around their house to mitigate the 

propagation of fires, it works, it definitely works. I yield back. 

Mr. SHIMKUS. The gentleman yields back. The chair now recognizes the vice chairman of the subcommittee, Congressman McKinley from West Virginia, 5 minutes. 

Mr. MCKINLEY. Thank you, Mr. Chairman. 

Unfortunately, the ranking member from New Jersey has left. I 

wanted to thank him for his opening statement, because it gave 

us—those that are here—a little snapshot of what life could be like 

after November, if he becomes the chairman, a diatribe of challenging President Trump for everything on climate change. It just 

shows that such a distraction is going to take place in this committee in the years ahead when we try to deal with all the matters 

that come before this committee. 

And perhaps it was just meant to be a distraction from the economic insurgence that has taken place across this country. And I 

appreciate you, Senator from Oregon, that you didn’t blame President Trump for one of those nine of ten fought fires being started. 

He got blamed for waters rising in the oceans, blaming Hurricane 

Florence. It is just inexcusable, but that is what we are going to 

see. So it is a little vignette of what we might be able to see in the 

future. 

My question—further with remarks would be, we had some discussion a couple years ago about the CO2 emissions out in the atmosphere. And I quoted O’Mara, I quoted from Al Gore’s book that 

the largest producer of the CO2s into the atmosphere is not from 

coal, it is coming from the deforestation of tropical rain forests. So 

the idea of what we are seeing in Oregon, California and elsewhere 

is we are contributing to this. That is why we need to address 

those problems and solutions so that we are not allowing this uncontrolled burn in our forests and allow that to take place. 

Now, I go to West Virginia and there we have the Mon, which 

is about 1 million acres. Like I say, Mr. O’Mara, with all due respect, it has been groups like yours and others that have prevented 

the logging in the Mon forest. It is a million acres, and they have 

only received about $1 million worth of harvest. Think about that: 

$1 per acre is all they are getting out of that forest. But yet, you 

go to the Allegheny Forest in Pennsylvania, and it is getting $12 

per acre. So we think about what the situation is we have in the 

Mon. I want to learn from what testimony has been given here, 

that we may be sitting on something that is a very aging force in 

70 

West Virginia in the Mon. And it is a tinderbox, because people are 

preventing us from logging and perfecting the situation that we 

have in West Virginia. 

So I am looking for some guidance as to how we might be able 

to approach this, because I am afraid we are going to start experiencing the same problem in West Virginia in the Mon that you all 

were experiencing out west because environmental groups do not 

want to have—I have got here, the West Virginia legislature was 

trying to do some in the State forest, but the environmental groups 

prevented that from happening. 

What advice can you give us for other areas? We have seen the 

devastation and we have seen the collection that the chairman has 

of soot from out west, how do we prevent that from happening in 

the east as well? What would you suggest, any of you? Don’t be 

shy. There is nothing we can learn? 

Ms. GERMANN. Is the question what would we—— 

Mr. MCKINLEY. What would you recommend? How should we go 

about this, because the National Forest, because of the environmental movement, is preventing us from thinning that and addressing the problem? We are only getting one-twelfth of the wood 

products out of the Mon that people are getting at other national 

forests. It is becoming a nursing home for wood. 

Ms. GERMANN. If I may, I think something that is happening 

right now, and I think you see it through the panel and Mr. 

O’Mara and my colleague, Mr. Boggus, we are talking about a lot 

of the same things. I think there is an opportunity that is happening right now is we are all interested as land managers, and 

as people who are interested in getting restoration and protecting 

water quality and air quality. We are wanting to focus on taking 

a cross-boundary approach. So we call it ‘‘All lands, all hands.’’ I 

think that is something we talk about across the Nation. But we 

have this opportunity right now to be doing more, but we have to 

be making sure that we are not only going to be doing more on private lands, we have to have the funding through our agencies for 

State and private forestry within our State. Other things like Good 

Neighbor Authority. So it is an excellent partnership between the 

Federal Government and the States. Working with collaboratives, 

working with local governments—— 

Mr. MCKINLEY. Again, those are great ideals, but it is not happening. So Mr. Boggus, what would you suggest? What do we have 

to do to try to encourage the Forest Service to eliminate these hazards so that we don’t experience this same problem? 

Mr. BOGGUS. Well, you have to keep the dialogue open. We are 

an early adapter, Texas is an early adapter for the Good Neighbor 

Authority, where you have these agreements—even before there 

was Good Neighbor Authority, we went into agreement with our 

State—our national forest folks in Texas, and to help them with 

prescribed burning. We had an agreement in 2007 and 2008 for 

that. Then we had the Good Neighbor Authority, which means the 

States can help the U.S. Forest Service get management done on 

their lands. And you all’s thank you for the fire fix as has been said 

before, but that is a great help to us, because a lot of times, the 

money we have and for reaching and technical assistance and the 

money that people don’t talk about is the State and private funding 

71 

that comes from you all; the borrowing came from State and private often, and so that is where we can reach out and do more on 

U.S. Forest Service lands, but also on technical assistance and 

helping the State and the private landowners across the State, 

which we heard was most of the land. Most of the forest land in 

this country is on—what you are talking about in the east and the 

south is on private lands. And those folks need technical assistance. 

So these programs like stewardship, Urban and Community Forestry and the Good Neighbor Authority help us put things not just 

in a plan, but put them on the ground and manage and make our 

forest healthier. 

Mr. MCKINLEY. Thank you very much. I yield back. 

Mr. SHIMKUS. The gentleman’s time has expired. The chair recognizes the gentlelady from Colorado, Ms. DeGette, for 5 minutes. 

Ms. DEGETTE. Thank you, Mr. Chairman. I know some of you 

were worried there weren’t a lot of members here, but you had 

members represent the entire Rocky Mountain west and west 

coast, so that is pretty darn good, because we are the ones dealing 

with these issues every day. 

I just want—I think Mr. O’Mara is correct, we don’t have any silver bullets for solving this problem. Being from Colorado, I see this 

firsthand, and believe you me, we couldn’t see the front range for 

most of August in Denver because of the smoke. 

Then I went to Oregon, and the same smoke was in Oregon, and 

then I went to Vancouver and it was still there for 1 month. This 

is not normal summer weather for us in the West. The thing we 

have to realize is there is no one solution. It would be super great 

if we could just go in and clear out all of this extra wood, and then 

we wouldn’t have as big of a fire risk. Number one, that is not the 

best management technique for a lot of these areas. But number 

two, for those of you not from the Rocky Mountain west and west, 

it is millions and millions of acres that we are talking about. There 

is no way, even if we had adequate funding, we could go in and 

clear out this wood. 

Secondly, in some of these areas, we really do need to have prescribed burns. We need to have forest management programs that 

are appropriate for those forests. And I am delighted to see our 

whole panel sitting here today agreeing with these concepts. 

So what can we do? There are a couple of things. Number one, 

several of you said we have to have adequate funding. And this is 

a bipartisan issue for those of us from the west where our colleagues don’t seem to understand how important funding is for forest management, no matter what those techniques are. 

The second thing is, we have to think about long-term planning. 

We are not going to be able to solve this air quality issue, or the 

other related issues, without the long-term planning. 

Mr. O’Mara, you talked about the dry soils, the water, and everything else from climate change, but there are other issues too. Let’s 

see if they have my picture, if the clerk has my picture to put up. 

This is a picture that I took in the Pike and San Isabel National 

forest last month. It is always really fun to go hiking with me, because I stopped and said take a look at this forest. See the trees 

on the ground? Those trees would not have been on the ground 10 

72 

years ago, that is Ponderosa pine, it was all killed by the pine beetle, and they died and they fell down on the forest floor. Then you 

can see the aspens now that have grown up because of the death 

of the pine forest. But then, if you look closely you can see the new 

baby Ponderosa pines growing up. 

So this is something the forest has tried to do to naturally recover from the pine beetle infestation. In Colorado, we think it is 

a miracle that all of these millions of acres that look like this have 

not burned. We have had some devastating fires the last few years, 

but we did not have devastating fires this year. I don’t know why, 

I think probably luck. But if you want to solve this problem—so 

these could all be burning. 

Now, we all said in Colorado, we need to be able to remove this 

dead Ponderosa pine, and we did in many areas. But it is millions 

of acres; it is wilderness areas; it is national forests; it is BLM 

land. So we have to think of ways where we are going to aggressively address climate change issues, because it is not just the carbon emissions that we are seeing and everything else, it is a whole 

ecosystem that is impacted. 

So I just really want to say, Mr. Chairman, I so appreciate you 

having this hearing. And I think that there are ways that we can 

aggressively work in a bipartisan way. But to think we can go 

down and clear out all the deadwood or just have a few controlled 

burns, that is not going to solve this problem over this entire massive and beautiful region. Thanks, and I yield back. 

Mr. SHIMKUS. The gentlelady yields back. The chair recognizes 

the gentleman from Texas, Mr. Flores, for 5 minutes. 

Mr. FLORES. Thank you, Mr. Chairman. This has been an enlightening panel today. Mr. Boggus, I have a couple of questions for 

you if we could. We have got something called Good Neighbor Authority, and we have had several people mention that, but nobody’s 

described it. Can you describe Good Neighbor Authority for us? 

Mr. BOGGUS. I guess the easiest answer is, it is a partnership, 

an agreement we go into with the U.S. Forest Service where they 

often have either lost the expertise or do not have the personnel 

available to help them with timber sales, with prescribed burning. 

And now you have added road building in the latest version into 

there to help with the management activities on the U.S. Forest 

Service lands, so we go in partnership with them and help them 

manage the Federal assets, the Federal force. 

Mr. FLORES. And how does this authority work for the State of 

Texas? You are the chief forestry officer in the State, how does that 

work for you? 

Mr. BOGGUS. It is a dialogue that has to go on, and it is something you learn as you go. Like I said, we were an early adaptor, 

we saw the benefits of this. In Texas, again, we are a private property State, the U.S. Forest Service is only 635,000 acres of forest 

land in Texas. But that is extremely important because the things 

that happen on that forest impact the private landowners around 

the forest. So with insects and disease, with fire and so forth and 

so, we work with them because we want to help make sure there 

are some other programs. Like we had the southern pine beetle 

prevention program; it is Federal funding through the U.S. Forest 

Service that we would help with those private landowners get their 

73 

property thinned and managed around, we kind of call it beetle 

proofing around the U.S. Forest Service land. We also now, with 

Good Neighbor Authority, we can work with the U.S. Forest Service partners and get those same—on the inside of the red paint, 

and get those protected as well and help do some thinning, and 

keep the forest healthy, that is the whole idea, we want to keep 

our forests healthy. 

Mr. FLORES. In your testimony, you mentioned that last year, 

Texas used prescribed fires on over 200,000 acres. And you also 

said that burning like this is pretty common across the south. 

Some States even do high amounts of prescribed burning. What are 

the challenges that exist with—well, let me rephrase the question. 

What are the challenges of dealing with prescribed burns versus 

the challenges of dealing with uncontrolled burns? 

Mr. BOGGUS. A wildfire is much more challenging and much 

more destructive. Now, a prescribed fire or controlled burn, says 

what it is, it is prescriptive, you have very set weather parameters, 

it is lower intensity. So you have less particulate matter, and so 

what it does is, it fireproofs communities, it fireproofs the area, so 

it keeps a catastrophic wildfire from happening. It prevents that 

fire. It is almost like saying fighting fire with fire, because you are 

making it where the fuel loading is less, you are keeping those 

four. It is a fire ecosystem in Texas so we are keeping those forests 

and those lands healthy, and keeping the fuel loading down. So if 

you were to have a wildfire break out, an uncontrolled, unplanned 

fire break in through there, it would be much less destructive. 

Mr. FLORES. And then you also do this adjacent to communities 

in order to protect those communities from the impact of the wildfire. What do you do to protect the community in the controlled 

burn process? 

Mr. BOGGUS. Well, obviously, the biggest thing we do, and I 

guess I will give an example, is our Jones State forest in Texas, 

which is almost in the city limits of Houston, so it is surrounded 

by subdivisions. So it is a very difficult place to burn. We have to 

plan, and part of these things is working with our environmental 

quality folks, and also working with the community around there, 

the landowners and homeowners around there, for them to understand if they do have issues, breathing issues, when we are going 

to it. So there is a lot of communication back and forth that those 

homeowners and landowners to say here is what is going to happen. If at first, if they are urbanized, urban dwellers, they are not 

used to seeing smoke. If you didn’t grow up in the country and 

burning your leaves and seeing smoke, it is disturbing. They think 

it is a wildfire. 

So we let them know what is—and we also show them are before 

and after and the benefits of that fire, the prescribed fire. And now, 

some of our biggest advocates are the ones that say, Yes, if you 

have anybody that is against prescribed fire, tell them to call me. 

So we have a lot of peers that will help and come to our defense, 

landowners and homeowners. 

So you have got to do a lot of outreach with the group, and you 

have got to do a lot of preparation and planning ahead of time. So 

the weather has to be right, conditions have to be right so that the 

74 

smoke cannot be an adverse condition for those homeowners and 

landowners around the fire. 

Mr. FLORES. And, of course, one of the ways that the prescribed 

burns are safer is you do it seasons when you are less likely to 

have it migrate into an uncontrolled burn. 

Mr. BOGGUS. Absolutely. 

Mr. FLORES. I am going to try to squeeze in one last question. 

A controlled burn has an environmental impact, a wildfire has a 

huge environmental impact. So because a controlled burn has an 

environmental impact, you have to work with the Texas CEQ on 

that. Describe that relationship. 

Mr. BOGGUS. That is an ongoing relationship, and that is one of 

the things we hope to get done, and just started 2 years ago, working with them to look at their rules. We would like to see prescribed fire treated differently than a wildfire, than smoke stacks, 

than car emissions. It ought to have some lesser because of the 

good it does and will help in the long-term prevent catastrophic 

particulate matter getting with a wildfire. So we would like to see 

the TCEQ treat prescribed burning and those that are done by 

trained, certified, prescribed fire managers, not just anybody, but 

that they would have a look at the smoke and emissions from a 

prescribed fire differently than they do—we are not there yet, but 

we are having those conversations. And like I said, last week, the 

chair of the TCEQ said, We need to have more prescribed fire on 

the ground in Texas, not less. So we are getting there. 

Mr. FLORES. Thank you. I have a couple of other questions, but 

I will ask you to respond supplementally to those. We will send 

those to you. I yield back. 

Mr. SHIMKUS. The gentleman’s time has expired. The chair recognizes the gentleman from Georgia, Mr. Carter, for 5 minutes. 

Mr. CARTER. Thank you, Mr. Chairman. And thank all of you for 

being here. This is certainly a serious problem, particularly in the 

State of Georgia. Georgia is the number one forestry State in the 

Nation. As you know we have over 22 million acres of privately 

owned land, and only about 1.7 million acres of government land. 

So we are a little bit different from, I think, the scenario that exists out west. 

However, we have had our share of fires. We had the West Mims 

fires, the Okefenokee swamp is in my district. It is truly one of the 

national treasures of our country. It is a beautiful, beautiful area 

that I have had an opportunity to visit on numerous occasions. 

We had a very serious fire there this past year, the West Mims 

fire. One of the adjacent property owners to that was telling me 

about this, and I met with him because he lost a lot of land as a 

result of the fire that started on the swamp, but spread to his private land. And I will start with you, Mr. Baertschiger, because I 

see that you worked as a fire training instructor, and a national 

type 3 incident commander. 

I just wanted to ask you, one of the things that was brought to 

my attention by the private landowner was that they didn’t utilize 

the air support. If they had been able to utilize it quicker, that they 

could have contained it possibly. Now in all fairness, a swamp fire 

is a little bit different than other kind of fires, because you have, 

from what I understand, and I know you all know it a lot better 

75 

than I do, but the Peat moss, and it is hard to put out, because 

the water has to rise up, and again, you understand it much better 

than I do. 

But he did make that point that if—and he attributes it to being 

a problem with the—whether it was low funding and they couldn’t 

afford to utilize the air support, the helicopters that were available. 

Is there something that you experienced before? 

Mr. BAERTSCHIGER. Well, there could be—I wasn’t there, I don’t 

know what the conditions were. And certain tools work good under 

certain conditions. If you have a wind blowing in excess of, say, 20 

miles per hour, aviation stuff really doesn’t help you much. And 

swamp is tough, because you can’t use dozers and other mechanical 

equipment because they don’t go through the swamp very well. So 

there are challenges with every fire. 

But the example you give is very good. Every forester in this 

country is exposed to catastrophic wildfire. And our history shows 

that going back to 1812, but the great Maine and New Brunswick 

fire, who would have thought that northern Maine and Brunswick 

would burn up, I think it was 3 million acres, and kill a lot of people. 

So, it is hard for me to comment on a fire that I don’t have any 

specifics, but not all the tools work all the time. In Oregon this 

year, landowners lost 33,000 acres of private timberlands from fires 

burning off of the Forest Service on to the private lands. 

Mr. CARTER. Let me ask you, I met with him as I mentioned before, and he owns a lot of forest land in the area in Georgia. And 

when I met with him, he said a lightning strike is what this originated from. And that generally, the Federal Government will just 

let it burn out and not even respond to it, is that—— 

Mr. BAERTSCHIGER. It just depends where it is, and, I believe you 

mentioned it was in a wilderness. 

Mr. CARTER. Yes, oh, yes, in the middle of the swamp, or at least 

it started, and now it spread on to the private lands. 

Mr. BAERTSCHIGER. In wilderness comes certain engagement 

rules, and I think some of that needs to be reviewed. 

Mr. CARTER. I appreciate that. Let me move to—I wanted to get 

to Ms. Germann. 

Ms. GERMANN. I am Germann. 

Mr. CARTER. Now you are in Montana, right? 

Ms. GERMANN. Yes. 

Mr. CARTER. OK. The practices in Montana, I suspect, are a little 

bit different than I described in the State of Georgia, particularly 

in the swamp, and I asked about that in my district. We are not 

all swamp in Georgia, but in my district we are. I am in south 

Georgia. But I wanted to ask you about the practice, the forestry 

practices that you have in Montana. Can you describe those very 

quickly? 

Ms. GERMANN. Sure. Absolutely. So we have, I will say that 60 

percent of the forested land within the State of Montana is managed by the Forest Service. And we have active forest management 

taking place on State, private and Federal lands. And anything else 

that you want to—— 

Mr. CARTER. I want to ask you specific about the State implementation plans, and I guess this is kind of a broad question, and 

76 

I am out of time, but nevertheless, these have to be approved by 

the EPA. Is that the way I understand it? 

Ms. GERMANN. Yes. And I don’t have expertise on the State implementation plans. I might ask that my colleague from Idaho—— 

Mr. CARTER. I was just wondering if there were any type of barriers that you are having, or any kind of constraints, and how soon 

did they approve those? How quickly do they approve? 

Mr. SHIMKUS. Quickly, please. 

Ms. ANDERSON. It normally takes an 18-month period for EPA to 

approve those. So any changes to, like Idaho rules we submit for 

EPA. It is a very long, drawn-out process. 

Mr. SHIMKUS. The gentleman’s time has expired. 

Mr. CARTER. Thank you very much. 

Mr. SHIMKUS. Chair recognizes the gentleman from California, 

Mr. Ca ́ rdenas, for 5 minutes. 

Mr. CA ́ RDENAS. Thank you very much for having this hearing. 

Hopefully we can see through the smoke of politics and get things 

a little more right, than not, in this great country. We don’t have 

some of the best response systems in the world? Aren’t we in the 

upper tier when it comes to being able to respond to fires and trying to protect life and property? I think everybody pretty much 

agrees with that. I am not saying we are the best, but we are definitely in the upper tier, right? We have got all that capacity and 

capability, thank God. 

One thing I would like to point out is the wildfires that have 

been ravaging through California are in excess of anything we have 

ever seen in the past. For example, 25 years ago, if you had a 

4,000-acre fire, that was considered big. Now we have these mega 

fires that are consuming over 100,000 acres per fire. And then all 

of a sudden, you have now where people talk about fire season. It 

is kind of like fire year now, there really isn’t a 3- or 4- or 5-month 

season. Now the situation is so bad, so dire, our forest and our 

vegetation has dried up so much that the—honest to God truth, as 

they say, protect yourself and hope and pray that there is not a 

fire, because there is no season anymore; it could erupt at any 

given time, and then when it does, we see these mega fires and 

some of them are raging as we speak. 

Another thing as well, I would like to point out this is a responsibility that we need to hopefully get right as policymakers, and as 

organizations, whether it is local or State or Federal. We need to 

make sure that we can work together to minimize the negative effects of these devastating fires. 

For example, according to the U.S. Forest Service alone, they 

have spent $2 billion last year just with the fires. That doesn’t include the economic loss, et cetera. That is just the Federal investment in that. I truly do believe that we can always do better if we 

take the opportunity to learn from the past, to learn about what 

is going on today, to learn about what it is that—how we are going 

to deal with this issue that many scientists are claiming that some 

of finest universities, Columbia University, et cetera, are saying 

that climate change is, in fact, contributing tremendously to some 

of the fires that are going on today. 

I hope we don’t argue about the simple fact that we do have a 

different environment now when it comes to the vegetation, when 

77 

it comes to the ability for Mother Nature to protect itself, and we, 

as human beings, have to make up the difference. Again, a 4,000- 

acre fire, not too long ago, was considered big, 100,000 acre fire is 

now becoming commonplace. 

So with that, I would like to also ask the chair and the ranking 

member coming from California in the future, we can try to glean 

through the wonderful experts, like the ones we have here today. 

Maybe we can get somebody from California up here because our 

disproportionality of being affected by fires as of late is just tremendous. 

Again, I don’t know if that is a complaint or what have you, I 

think it is an observation with five members from the California 

delegation on this subcommittee. Hopefully in the future, we can 

be a little more—— 

Mr. SHIMKUS. Would the gentleman yield? 

Mr. CA ́ RDENAS. Yes, absolutely. 

Mr. SHIMKUS. You do know the process by which the people are 

asked are both from the majority and the minority side. 

Mr. CA ́ RDENAS. And that is why I mentioned to both of you, the 

chair and the ranking member. 

Mr. SHIMKUS. Just wanted to make sure it was clarified. 

Mr. CA ́ RDENAS. But since you brought it up, maybe it is four to 

one, because we get one person and you get four. 

Mr. SHIMKUS. Will the gentleman yield? 

Mr. CA ́ RDENAS. I will yield. 

Mr. SHIMKUS. These negotiations are always done between the 

parties, and I see no objection. 

Mr. CA ́ RDENAS. OK, thank you. 

So again, that is why I say it is not so much a complaint, it is 

just an observation. And hopefully, we can get fortunate enough to 

have some folks who are dialed in directly within the California 

scene, especially since it is one of the most dire in the country now 

when it comes to our fires. 

Mr. O’Mara, what will the effect beyond California fire seasons, 

or as I just called it, fire years, actually if we continue to roll back 

clean air standards? 

Mr. O’MARA. You mean, the challenges that as the fires get 

worse, the displacing a lot of the air quality benefits that we have 

accumulated through cleaner power plants, cleaner cars, energy efficiency, all the work that you are doing at State level. 

I actually worked for the mayor of San Jose for 3 years and a 

lot of the work they have been doing—you could undo a lot of that 

progress unless we deal with the underlying issue: the public 

health consequences of uncontrolled fires. 

Mr. CA ́ RDENAS. Again, Mother Nature can—if we don’t help, can 

wipe things out, set us back decades, actually. 

What holistic steps can Congress, and State, and local governments take to do our part in reducing the devastating blazes across 

California and the U.S.? 

Mr. O’MARA. I think we talked a lot about funding today, making 

sure that we have the resources for the proactive work, through the 

proactive restoration work. I think there are things we can do to 

help individuals, make sure there is mitigation money and things 

like that. But also, making sure we are doing prescribed burns, 

78 

making sure we are doing good management. And frankly, you 

have some of the best people in the country in California. The challenge is they don’t have the resources they need to do the scale of 

restoration they need, given the scale of the impacts, and we have 

to help solve that problem. 

Mr. CA ́ RDENAS. Thank you, Mr. Chairman. 

Mr. SHIMKUS. The gentleman’s time has expired. 

The chair recognizes the gentleman from the South Carolina, Mr. 

Duncan, for 5 minutes. 

Mr. DUNCAN. Thank you, Mr. Chairman. Just like hurricanes 

aren’t limited to Florida or the Gulf of Mexico, wildfires are not 

limited to the west. In 2009, Horry County fire down in Myrtle 

Beach, same place being affected by Hurricane Florence, experienced 24 miles, 20,000 acres burned, 70 homes destroyed, 2,500 

people evacuated. In my district, we have Sumter National Forest, 

which is 370,442 acres. So national forests and forest fires are not 

limited to the west. 

My wife owns property in Montana. We have been out there 

since I graduated college in 1989. We have seen what the spotted 

owl controversy did to the timber industry in the west. I believe 

that was the beginning of the change of mitigation practices and 

how forests were managed all throughout the west, not just in 

Montana. Families that were supported by timber dollars lost their 

jobs. Ms. Germann from Montana can probably attest a number of 

saw mills are lost, a number of timber families have been displaced, and the lack of timber activity that you saw in the late 

1980s and 1990s; it went away, it went away. And at that point, 

we started managing our forests differently. 

So I traveled to Montana, I was out there this summer in August. I saw all the smoke. I experienced the smell. I saw that all 

the tourists that came into the Kalispell and Glacier National Airport to go to Glacier National Park, probably didn’t see the beautiful scenery of that national park due to the fires, and that was 

before the Lake McDonald fire. While we were there, had a lightning storm, four lightning strikes, caused four fires, one of them 

was a Lake McDonald fire. Burned all the way down the lake right 

there in Glacier National Park. Three of the other lightning strikes 

from the same storm didn’t burn near as much, because they actually hit on property that had been managed properly, and the fires 

were able to be contained a lot quicker than that in the national 

park, because we don’t do any sort of mitigation efforts in national 

parks. I am not advocating for that, but I think we ought to at 

least think outside the box when we are talking about managing 

fires. 

Last summer, not this past August, but a year ago, I was also 

in Montana, and the Gibraltar Ridge fire, which you are probably 

aware of up in Eureka, Montana, that was burning very close to 

our property. So I took it as an opportunity upon myself, and I 

challenge every Member of Congress and on this committee, to go 

to a fire camp and visit with the people that are fighting the fires 

in the fire camp like I did in Eureka, Montana, and then get in the 

truck with the forest manager, and go out to the fire line and see 

how these fires are fought. Because I went to the Gibraltar Ridge 

fire, and I spent 3 hours on the fire line to see the techniques that 

79 

were being used, mainly mitigation efforts to keep that fire from 

moving toward where people live, and that personal property to 

keep it from being destroyed. Other than that, it was just trying 

to contain the fire, keep more forest acreage from being burned. 

But they weren’t trying to put the fire out at all. 

In fact, in the wilderness study area, there is minimally invasive 

suppression techniques, missed techniques. So they weren’t doing 

anything up there, but maybe trying to contain it a little bit. Very 

difficult to get to, I get that. 

Having said all of that, we need to back up as a nation and start 

talking about how we manage our forests. That means more timber 

activity. This is the American taxpayers’ resources and it is growing, it is going to regrow. We have practiced timber sales forever. 

And one of the ways that we can mitigate the pine beetle is cut 

the timber. She said we don’t have a funding stream to do some 

of these clearing techniques. Guess what? It is called timber sales. 

They pay for themselves, actually provide revenue back to the government to provide revenue for these expenses. 

So let’s manage our forests, let’s sell some of the timber, and 

then let’s look at shading along rodads and near where residential 

areas are, let’s look at fire breaks. Let’s look at prescribed burning. 

I mentioned the Horry County fire earlier. The reason that fire 

was so bad and got out of control, and even the firefighters had to 

employ shelters to let the fire go over and to keep from losing their 

lives is because the northerners that moved down to South Carolina and occupied in Myrtle Beach, did not like the smoke from prescribed burning. And so prescribed burning didn’t happen. And because the prescribed burning did not happen, there was a lot of fuel 

there. Once that fire started, it burned out of control, because there 

was so much fuel for it. If we don’t manage these fires out west 

and even in South Carolina with prescribed burning and good management techniques, we are going to see, continue to see, out-ofcontrol wildfires that are very difficult to contain and we are going 

to pray for a snowfall to put these doggone things out, because that 

is what they pray for out west is that snow to get there. They see 

a thunderstorm come in August, that is kind of a double-edged 

sword. It is providing some moisture to help contain some of that 

fire, but it is also providing additional lightning strikes. 

I was talking to Brian Donner at the Kootenai National Forest 

Service, a forest ranger there. You may know Brian. He said while 

they were fighting one fire, a lightning storm came in, they saw 

lightning hit over on a hill. They saw the tree it hit. They knew 

right where to go, but before they could get there, because of the 

amount of fuel that was there, there was 5 or 10 acres already 

burning and that was very difficult to start containing at that point 

on the top of that mountain. Had they done prescribed burning and 

that fuel had gone away, that fire would have been contained a lot 

quicker. 

The last thing I will say, Mr. Chairman, because—— 

Mr. SHIMKUS. Your time has expired. 

Mr. DUNCAN [continuing]. She said in her statement—thank 

you—over the past century—and this was a good statement by the 

way, by Ms. Germann—over the past century a cultural fire exclusion unfortunately removed the natural role of fire from the public 

80 

consciousness, when combined with a reduced level of forest management in many areas of the country, fire exclusion led to the 

buildup of forest fuels to unprecedented levels. Despite our attempts to manage away wildfire, many of our forests are more fire 

prone than ever. And that is the truth. 

And with that, I yield back. 

Mr. SHIMKUS. The gentleman yields back his time. The chair now 

recognizes the gentleman from California, Mr. Peters for 5 minutes. 

Mr. PETERS. Thank you, Mr. Chairman. My constituents in San 

Diego are acutely aware of these issues. I do think it was progress 

to do the fire fix. I worked really hard on that to make sure that 

we weren’t spending prevention money fighting fires because it just 

makes it harder to do. You are never going to catch up. 

Mr. O’Mara, I have two questions for you, though. Specifically on 

the Clean Air Act in your testimony, you noted the strange thing 

where, in terms of calculating your compliance, whether you are in 

attainment of the National Ambient Air Quality Standards, you are 

penalized for prescribed burns, but not necessarily for natural 

burns that happened as a result of not taking care of things. You 

suggest that EPA can take care of this themselves. Is that not 

something Congress has to do? Tell me why EPA can change that? 

Mr. O’MARA. Yes, if you go back to the record—the Clean Air Act 

amendment to 1990, this anthropogenic versus natural kind of distinction isn’t as clear-cut as you might think. It has been an administrative practice, and the challenges that seems to build your 

prescribed burn and your State implementation plan and basically 

account for it, a wildfire you have to—it is excluded. You had to 

get an exemption, because it is kind of considered natural. The 

challenges—I was in Delaware at the time we were trying to prescribe burns, Delaware has so many challenges being downwind, 

pollution from coal plants out in the Midwest, there is nowhere to 

put it in a ship. You have to find a different place in some of those 

sources to offset. And so it becomes a big burden, so you end up 

not doing the very thing that would help protect you long-term because of the potential penalty. 

Mr. PETERS. So you think that that can be addressed at an administrative level? 

Mr. O’MARA. I believe so. 

Mr. PETERS. One other question for you, I like what you did, 

which was sort of threw out your notes, so I will throw out my 

notes a little bit and ask you if you were in charge of allocating 

money for fire, where would you put it first? What would be, you 

think the highest priority for new fire money? 

Mr. O’MARA. There are great collaborative plans that have been 

on the books for years that don’t have the resources to get on the 

ground. I think I would prioritize on the interface projects that 

have the potential of loss of human life. But I would pour money 

into mitigation, I would pour money into prescribed burns. I would 

pour money into the collaborative plans that already have buy-in 

among communities, because they are going to move faster through 

the process. But we need to move from a couple acres a year to tens 

of millions of acres a year. We don’t have the capacity at this point. 

The Forest Service has been, through sequester, their resources 

were taken down so far in addition to not having the money beVerDate Nov 24 2008 11:48 May 24, 2019 Jkt 037690 PO 00000 Frm 00084 Fmt 6633 Sfmt 6633 U:\MY DOCS\HEARINGS 115\HEARINGS\115-165 CHRIS
81 

cause of the fire borrowing issue. We have got to rebuild fire capacity in this country at both the Federal and State level. 

Mr. PETERS. The collaborative plans you are talking about are regional collaborative plans? 

Mr. O’MARA. The regional level, yes. 

Mr. PETERS. And what sort of management reforms would you 

like to see enacted, management reforms? I have to confess, I hear 

a lot of discussion back and forth. It sounds like disagreement, but 

never quite understand, kind of, what is it that we are fighting 

over? 

Mr. O’MARA. Look, I think there are places where you could have 

more efficient processes. There are things where maybe not having 

to go through the same level of review for individual parts of 

project if you actually do the analysis at the landscape level. We 

layered on so many parts of the process. 

Mr. PETERS. How do I write that down? How do I write that 

down from here? What does that mean? 

Mr. O’MARA. There are ways to do it. I mean, there is some language that Senator Cantwell was working on around Ponderosa 

pine, basically trying to say, Look, if it fits this kind of landscape 

project, we will have kind of one analysis, one environmental impact review as opposed to having them do every individual discrete 

component. 

So there are some things we can do at the landscape level. Some 

of that could be done administratively. And if the Forest Service 

has predictable resources to be able to do that kind of planning, but 

a lot of these forest plans are 20, 30, and 40 years old. It means 

we are updating project plans, we are not looking at the landscape 

level. We would love to work with you on that, because I think that 

could be bipartisan. I don’t think that would be a controversial 

issue. 

Mr. PETERS. Obviously, I am particularly interested in the urban 

forest interface. And I am concerned about the fact that it is not 

even October and we have already had fire season, we are not even 

into October. So we are getting ready for what we hear from our 

local firefighters is as bad a condition or worse than 2003 and 

2007, which were the fires that cost San Diego County a lot of 

property, and money, and damage. So we are very interested in 

taking you up on that and look forward to talking to you. 

Mr. Chairman, I yield back. 

Mr. WALDEN [presiding]. The gentleman yields back. The chair 

recognizes the gentleman from Ohio, Mr. Johnson. Thanks for joining us. You are recognized for 5 minutes. 

Mr. JOHNSON. Thank you, Mr. Chairman and thanks for holding 

this hearing today. 

While many of our witnesses are from western States, these 

issues are certainly relevant to where I live there in Ohio. I have 

a significant portion of the Wayne National Forest within my district which will, from time to time, carry out prescribed burns. The 

Wayne is a patchwork of public and private lands. So these burns 

are meant to protect human property and reduce potential damages from wildfire, but they can also encourage the growth of plant 

life, and help ensure oaks, for example, remain prevalent within 

the forest. 

82 

So while we have heard about the benefits of these practices, prescribed burns today, whether that is air quality, safety, et cetera, 

I would like to discuss the planning that is undertaken before a 

burn happens. It is crucial that many factors are considered before 

conducting a burn, such as temperature, humidity, atmosphere stability, wind direction and speed, as well as smoke dispersion. 

So a question for either Ms. Germann or Mr. Boggus, or both, 

along with other resource constraints and other issues, I am sure 

these factors that I just listed inhibit the ability to accomplish all 

that is needed to be accomplished over the course of a month or 

a year. So how do you balance the factors in planning with the 

need to efficiently manage healthy forests? 

Mr. BOGGUS. You mentioned it already that is planning, you 

have got to look out. We have a meteorologist on staff because of 

the very conditions you are talking about. And we have an urbanizing State. I know Montana has 1 million folks, we have 28 million; 

in Ohio, the same way, a very populated State. You have to take 

those into consideration. We have 94 percent privately owned. So 

we don’t have the luxury of—if a fire starts, we have got to get on 

it, and we suppress them all because there are human lives and 

property, and improved property at stake. And so you have got to 

plan that. And because of that, you have got to have folks that are 

dedicated to, we call them predictive services. So they are telling 

us days and weeks ahead what the weather is going to look like, 

when is it going to be right, 

And so you have these plans written way ahead of time. And you 

know this is the time, this is the window that this particular piece 

of land will burn. So then you have Good Neighbor Authority on 

Federal lands that you work with those, with our partners there. 

And so, we have got those agreements done well in advance. So you 

are not like, Oh, my gosh, it is a good day to burn, and you go out 

and burn. So the planning is crucial. 

Mr. JOHNSON. Sure. Ms. Germann, do you have anything to add? 

Ms. GERMANN. Certainly. I think one of the challenges we were 

talking about before this hearing is the social license that you have 

with this. And something that we constantly face, our Federal partners, we as State agencies face when we are planning prescribed 

burning, the communication piece, so educating the public, getting 

them to understand the benefits of that. 

In the State of Montana, we burn, on average, about 30,000 or 

40,000 acres of forested land per year, prescribed burning. We need 

to do about 10 times that, from an ecological perspective, to really 

have an impact on fuels reduction. And one of the things that we 

find the most challenging is getting the public buy in. So I think 

in addition to all the planning is the communication piece of that 

that we need to constantly be doing better. 

Mr. JOHNSON. Gotcha. Well, along those same lines, how do you 

choose what section of forest to address next, particularly if you 

can’t treat every section that needs to be treated? You said you are 

doing 10, or you are doing 45,000, you need to do 10 times that 

many. How do you decide which 45,000 acre lot to do. 

Ms. GERMANN. So there is a number of different filters. And I 

want to clarify that in the State of Montana, we don’t just put prescribed burning on the ground, we have to do active mechanical 

83 

fields reduction before we do that, because our fields are at such 

unprecedented levels. We use a number of different things statewide, and I will talk about our forest action plan that we are going 

to be undertaking. What we did do in the State of Montana is our 

governor did identify 5 million acres of priority treatment, and that 

was on Forest Service land, under the authority of the 2014 farm 

bill. 

So we match that along with high severity areas, identified by 

community wildfire protection plans. We use collaborative groups 

to really help identify where we need to be focusing our treatment. 

A lot of that is driven by forest pests, insects and disease occurrence, fuel loading, wildfire hazard. We have a lot of that data, and 

that is where we typically plan our priority treatments. 

Mr. JOHNSON. Thank you, Mr. Chairman. I yield back. 

Mr. WALDEN. The gentleman yields back. The chair recognizes 

the gentleman from California, Mr. McNerney, for 5 minutes. 

Mr. MCNERNEY. Well, I thank the chairman and ranking member. It feels kind of strange, this morning we were talking about 

hurricanes, and now we are talking about wildfires. But both of 

those have some connection to climate impact, so this has to be a 

holistic discussion. 

Now, it seems to me the difficulty is managing forests to prevent 

and minimize damage, but also protecting health and safety. On 

the other hand, is it necessary, or will it be necessary at all to prevent—to manage development, so that we don’t put people and 

property at risk at these high risk areas. So my question was sort 

of a general one for whoever wants to answer: How should we be 

thinking more holistically about forest fires and management? 

Mr. BAERTSCHIGER. I would like to respond to that. In your 

State, which I have been down many times fighting fire, has that 

Mediterranean climate, and your fuels cure much earlier in the 

season, and they stayed cured much longer, and then you have the 

Santa Ana wind event in the southern California. So dispensable 

space around houses and evacuation routes need to be a lot more 

thought through because fire in your State burns very quickly. As 

a firefighter, we say in Oregon, sometimes you can’t run fast 

enough. In California, you can’t drive fast enough. So I think that 

is something you need to take into consideration as you build your 

communities and expand them into what we call the urban interface, that those conditions are really taken into consideration, defensible space and evacuation routes. 

Mr. MCNERNEY. Well, I would like to direct this toward Ms. 

Germann. How are you working with communities to manage 

building in these high risk areas? 

Ms. GERMANN. In Montana and some research just came out 

from one of our groups out of Bozeman that showed that a tremendous amount of money is being spent in urban interface in suppressing fires. And I will say, in Montana, we are in the infancy 

of talking about this from a land use planning perspective. But 

what we do is DNRC, we are really trying to interface with the 

local government to help them organize around the tenets of the cohesive strategy. Talk to them about fire-adapted communities, the 

stuff that we are experts at, at forest management, really helping 

local governments do that treatment in and around homes; and 

84 

educate people on the risk of living in the wild land, but urban 

interface. But from a planning perspective, it is really pretty much 

in its infancy in the State of Montana. 

Mr. MCNERNEY. So do you feel the local communities are responsive to your advice and input? 

Ms. GERMANN. Certainly, absolutely. We pride ourselves in really 

excellent relationships with local governments. We have a local 

government forest adviser who is engaging with county commissioners and volunteer Fire Departments on engaging with the Forest Service, which is the predominant landowner, forest landowner 

around the communities about suppression efforts, about forest 

fuels reduction, and certainly, we help deliver a lot of that education to private landowners within our communities. 

Mr. MCNERNEY. Mr. O’Mara, is there a lack of funding that we 

can address at the Federal level to improve how we as a nation 

handle wildfire management? 

Mr. O’MARA. Yes. I think it is amazing what the Congress did 

in the last session, fixing the fire borrowing practice; it is still an 

underinvestment. I can say all Americans are Libertarians until 

they need help. We have to figure out a way to monetize some of 

these costs. They are putting people in harm’s way, they are putting firefighters in harm’s way. It is the same thing in flood insurance, it is the same thing. We are basically paying people to be in 

more risky areas. I think we are billions of dollars short in terms 

of the amount of money that is used toward active restoration annually, that is the kind of level of funding that we are going to 

need, because Chairman McKinley and I have gone back and forth 

on many issues. He is exactly right. I want to say when he is not 

here. Because we are not talking the east coast forest enough. The 

east coast forests and the Great Lakes forests have equal threats, 

they are just a couple of years behind in terms of the temperature 

patterns. 

Mr. MCNERNEY. Well, I think one of the big controversies or 

areas of disagreement is whether we should use suppression or 

management. From the science that I have seen, the fires can be 

managed better, and it gives the forest a better chance to recuperate and create natural fire breaks and natural water sheds and 

so on. So I wouldn’t rush to one or the other. But I would lean toward management, in my opinion. Thank you, I yield back. 

Mr. WALDEN. The gentleman yields back, I want to thank our 

panelists for being here, we will send Mr. McKinley a video of your 

comments where you agree with him. I don’t know how that is 

going to play out. But we do appreciate it. Our work is better informed by your participation, I know some of you, including the 

Senator, have traveled great distances, and we thank you for doing 

that. 

Seeing there are no further members to ask questions for the 

first panel, I would like to thank all of our witnesses for being here 

today. Before we conclude I would like to ask unanimous consent 

to submit the following documents for the record: Two academic reports entitled Prescribed Fire in North American Forest and Woodlands, and Prescribed Fire Policy, Barriers, and Opportunities; and 

document from the National Academy of Sciences, called, The Impact of Anthropogenic Climate Change on Wildfire Across the 

85 

Western U.S. Forests; an article from GeoHealth, Future Fire Impacts on Smoke Concentrations, Visibility and Health in the Contiguous United States; Washington Post editorial board, We Won’t 

Stop California’s Wildfires if We Don’t Talk About Climate Change; 

New York Times article, Trump Inaccurately Claims California is 

Wasting Waters as Fires Burn; the Scientific American article 

Fuels by Climate Change Wildfires Erode Air Quality Gains; and 

a document from the National Wildlife Federation, Mega Fires. 

And in pursuant to committee rules, I remind members they 

have 10 business days to submit additional questions for the 

record. I ask that our witnesses respond to those questions within 

10 business days upon receipt of those questions. And so again, 

thank you all for participating in this very important hearing, and 

without objection, this subcommittee is adjourned. 

[The information appears at the conclusion of the hearing.] 

[Whereupon, at 3:15 p.m., the subcommittee was adjourned.] 

[Material submitted for inclusion in the record follows:] 

86 


36422.042

ONLINE SPECiAL Prescribed burning-----------------------1 Prescribed fire in North American forests 

and woodlands: history, current practice, 

and challenges 

Kevin C Ryan1*, Eric E Knapp2

, and J Morgan Varner3 

Whether ignited by lightning or by Native Americans, fire once shaped many North Amerkan ecosystems. 

Euro-American settlement and 2oth-century fire suppression practices drastically altered historic fire regimes, 

leading to excessive fuel accumulation and uncharacteristically severe wildfires in some areas and diminished 

flammability resulting from shifts to more fire-sensitive forest species in others. Prescribed fire is a valuable tool 

for fuel management and ecosystem restoration, but the practice is fraught with controversy and uncertainty. 

Here, we summarize fire use in the forests and woodlands of North America and the current state of the practice, 

and explore challenges associated with the use of prescribed fire. Although new scientific knowledge has reduced 

barriers to prescribed burning1 societal aversion to risk often trumps known 1 long-term e-cological benefits. 

Broader implementation of prescribed burning and strategic management of wildfires in fire-dependent ecosystems will require improved integration of science, policy1 and management, and greater societal acceptance 

through education and public involvement in land-management issues. 

Front Ecol Emdmn 2013; 11 (Online Issue 1): cl5-e24, doi:10.1890/120329 

Wildland fire has imp;:~ctcd most 

Amerie<.lS, evidence of its 

biota, S\)i!s, fossils, cultural artifacts 

Betancourt Dc!comt and De !court 

Ryan et aL Many terrestrial 

long evolutionary history with fire 

fire 10 maintain 

and function 

Keeley 2009). 

ill. fire spread 

intensity across landscapes are dependent on tht' 

physical ami chemical characteristics of these with 

fuel moisture and fuelbcd continuity two the 

most important factors. An abundance (high surface arca~to~volume ratio), fuels that are continuous 

or interconnected is fire to spread. ColJ~ or 

moisture-limited ecosystems are often fuel~limited 

because combustible biomass accumulates slowly and the 

continuity of the fuclbed. takes longer to redevelop fol~ 

lowing a flrc. Wet forests develop fuclbcd continuity 

more quickly but also be effectively fuel-limited 

because the fine are rarely dry to bum. 

Intermediate to these extremes are H range 

that produce abundanr fine fuel and are dry 

and from lightnin~ or humans. 

accumulaticltt and prevalence of ignition 

sources varies by region and ecosystem across North 

America (Knapp et al. 2009). Within regions, fire potential also varies year to under the influence of global 

circulation as the El N ifio-Southern 

Oscillation 

Ryan etal. 

southwestern mountain ranges experience frequent light~ 

ning storms; when lightning strikes dry fuels, for example, 

in the prior ro ~urn mer monsoon rains (Figure 1; 

Flagstaff, and Ocala, Florida), numerous fires 

result and Betancourt 1990; Stambaugh et al. 

2011 ). conflagrations commonly occur during La 

N ifia episodes, when mom;oonal rains arc delayed or 

Forest and weak. These areas recover fuel continuity quickly and arc 

characrcrized by high fire frequency. In contrast, soaking 

www.frontieninecology.org 
87 


36422.043

Prescribed fire in North American forests 

that lack wetting rains - arc a mujor source of summer 

fires in the western mountains, pmticular!y Juring 

is also the dominant source of large, 

landscapc,-scale fires in the boreal forests of Alaska and 

northem Canada (Krczek-H:mes et al. 2011), ln many 

areas of Norrh Ameriw, relatively recent settlement of 

1.\WW.frontiersloe.::o!ogy.org 

rural woodlands is shifting the 

sus lightning ignitions (Peters 

KC Ryan et al. 

of human ver~ 

II Humans and fire prior to Euro-American 

settlement 

Humans migrated to the Western Hemisphere at least 

14 000 years hefore rresent (Goebel et al. 2008) and used 

fire for heat, light, fotld and hunting (cf 

Nowacki et al. 2012; Ryan hut the degree to 

which human~causcd fires were agents of land-cover 

change is unknown because of the spatial and temporal 

limitations of paleological data, Questions therefore 

remain ahout the extent to which prc~Columbian fires 

were of natural or human origin (Boyd 1999; Vale 2002 ). 

In areas of high lighrning density, such as in the moun~ 

rains of the US Southeast and Southwest, fire frequency 

was most likely limited by the recovery rate of fine fuels. 

In Pacific Coast forests and in the temperate deciduous 

forest biorne of eastern North Arnericn, the rarity 

season lightning suggests that humans were a major 

©The Ecologro::al SoCiety of Amenca 
88 


36422.044

KC Ryan eta/. 

tion source (McCkdn and Elzinga 1994; Drown and 

Hebda 2002; Kay 2007; Abrams and Nmvacki 2008); 

while lightning fires occur in these it is difficult 

to cxpl<1in the of burning without 

human ignitions 2002; Guyette and Spctich 

2001; Spctich 

:agcmcnt or travel (Pyne 1982; Anderson 

and Nowacki 2008), Although tan,dscapc-se<ttc 

ended with nomadic hunting 

usc of fire to promote varim_;~ materials remains an 

integral component of traditional ecological knowledge in 

American Indian cuitures (Anderson 2005). 

An estimated 21 million people inhabited 

North America at the European serrlement 

(Dcncvan 1992). Eurasinn diseases transmitted by these 

early settlers decimated native populations. Many regions 

show a marked reduction in fire frequency at the same 

time as this decline (Spetich et al. 2011; 

Power ct al. also coincides with the 

\-VCt Little 

1111 Humans and fire after Euro-American settlement 

Fire factored into the creation of ::;ev~ 

lan<J-ntar~;,gcmul1t agencies (cg US Forest 

Service [!9051, US Park Sccvicc [1916], and the 

US Bureau oflanJ Management [1946]) and similar for~ 

est conservation agencie~ at the state level 1982}. 

\Vithout cxceprion, pt)licies 

ganda on the henc·fits 

were designed to control 

Prescribed fire in Norrh American forests 

northem boreal forests. 

cocchi<l1atinn of fire suppression and t-he decrease 

in burning by Native Americans dramatically altered the 

fire regime across much of North America. The eastern 

US experienced a steep decline in fire occurrence 

(Nowacki and Abrams 2008). In the western US, the 

total area burned declined sharply for some decades, 

reaching its minimum during the 1970s (Agee 

Leenhouts Since then, the trend has been 

activity (Wcsterling et aL 2006; Littell 

despite extensive efforts. In 

burned area from 1959 to the 

except in the western 

provinces (Krezek-Hanes et 2011 ). Regardless Llf 

regional differences, the land area being burned today 

across much of North America is far less than what was 

burned historically. Leenhouts (1998) estimated that in 

the contenninou::; US, burning in the hue 20th century 

was 7--12 times less rrevalent than in pre~industrial 

times. In California, Stephens ct al. (2007) estimated that 

18 tirnes less ~rca was burned annually between 1950 and 

1999 than had burned to that time. A compilation 

forests indicated an average 

modem burn rate aprroximately five times less than the 

historical burn rate (Bergeron et al. 2004 ). Similar statis~ 

tics for Mexico and Central America arc not as well 

developed; here, fires continue to burn across large areas 

in some years, and ecosystems vary between experiencing 

less than and rnorc than historic levels of fire (Rodriguez~ 

Trejo and FulC 2003; Mmtfnez Dominguez and 

Rodriguez~ Trejo 2008). 

II Ecological consequences of fire exclusion 

Excluding ftrc from previously fire-frequent ecosystems 

results in major changes in 

and function across a 

1994; Keane et al. 

conoequcn,ces of fire regimes 

include a in or of ecosystem services, and 

vastly altered fuels and pl1tcnt!al future fire behavior. 

Without the disturbance of periodic fire, tree density 

2) and homogenizes 

Hutchinson et 2008; Nowacki and 

'The influx of fire-sensitive species alters 

Clmununity compt)sition, stand and ecosystem 

(Keane et al. 2002; and Abrams 

McShea et al. 2007; Alexander and Arthur 2010; 

Maynard and Brewer 2012). Canopy infil1ing by shade~ 

tolerant, fin>sensitive trees and accumulated litter in 

unbumed forest floors can lead to reduced cover and 

diversity (Hiers eta/. 2007; Engbcr et al. 201 i). Plant 

lhat. benefit from disturbance and exposed bare 

typically decHnc (Harvey et aL 1980i Gilliam and 

Platt 1999; Knapp et al. 2007). The effects of fire t.'xclu· 

sion aho affect amm:1l communities. Loss of herbaceous 

species in long~unburned forests has been associated with 

www.frontiersinecology.org 
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Prescribed fire in North American forests 

to 

(Means 2006 ). 

In drier portions of wcstem North America, greater sur· 

face fuel in combination with the influx of 

conifer seedlings saplings contributes to higher fire 

intensity and severity, and an increased prnbahility of crown 

fires (Agee and Skinner 2005). In contmst, fire exclusion in 

fire-prone landscapes of eastern North America 

larly oak, southem pine, and oak-pine associated with the invasion of fire-sensitive species with less 

flammable litter, more shaded and moister microclimatic 

conditions, and reduc.cd fire activity. The r.esult is a positive 

feedback termed "mc:mphication" by Nowacki and 

with lower potential for buming reinforc~ 

invading shadc~tolcrant, fire-sen~ 

II Restoring fire as a landscape process 

In North America, recognition of the 

of prcscrihcd burning was slow in 

graphically. Fuel accumulation and loss of game 

habitat occurred especially quickly in south~ 

ern pine forests anJ woodlands and ecologists in the 

southeastern US promoted the usc of fire in land m<m<Jgcment from early on (eg Stoddard 1931; Chapman 1932). 

In spire of their convincing arguments, fire in the southeastern US (and elsewhere) was still frequently viewed as 

incompatible with timber production due to the potential 

for injury to mature trees and the inevitable loss of tree 

www.frontie(sinecolot.:Y·Org 

KC Ryan et al. 

seedlings. Since then, research in numerous 

has helped public recognition interole in "fire-dependent" plant commuHowever, contemporary fires fueled by hiomass 

that accumulated in rhe absence of fire now pose a greater 

risk of damage to private infrastructure, 

and Numerous documented the 

prescribed burning to mitigate extreme wildfire aml uncharacteristically severe fire effects 

(Agee and Skinner 2005; Finney et al. 2005; Prichard et 

al. 2010; Cochrane et al. 2012) 1 further reinforcing the 

importance of fire management (Ryan and Opperman 

2013). Nevertheless, the tension between risks and 

recognized benefits remains. 

The extent to which fire has been incorporated into 

management protocols varies across regions. In the US, 

approximately one million ha are burned annually as a 

result t)f prescribed fire (NIFC 2013a). Between 1998 and 

2008, US federal agencies also actively managed :an aver~ 

age ~)f 327 lightning-caused wildfires for the purpose of 

restoration, and these burned an additional 75 000 ha 

(NIFC 2013b). US federal fire managers still 

to nllmv some to burn to pro~ 

vide resource but policy change, 

hectares treated in way arc no longer counted separately from total wildfire hectares. a small percentage nf wildfires in to burn or 

some 

basis (Weber and Tiwlor 

scribed burning for ecosystem restoration 

uncommon Cl~1ylor 1998). While statistics for MC'xico 

and Central America indicate a preponderance of 

human~caused fires, most are either escaped agricultural 

and burns or intentional hums thnt lack clear 

objectives (Rodrfguez~Trejo and FulC 2003; 

© 11-w Ecobgic,tl Sonety of AmenGl 
90 


36422.046

KCRyanctal. 

lncreas<.'J forest density <.md accurnuhnion of litter, duff, 

and wnod debris has 

form!y 

Prescribi!J fire in North American forests 

restorarinn anJ management 

mentation by mechanical means. In 

excess fuds, around the base of 

(Figure]), may 
91 


36422.047

Prcscnbed fire in North American forests 

protect (Varner et al. 2005; Hood 

Variations in fire susccpl!o;tmy 

result of differing 

time of burning can lead to 

Martin 1990; Howe 1994 ). 

ics show little or no influence of timing relative 

that also typically 

the 

www.fronticrsineco!ogy.org 

KCRyanetal. 

a suite of environmental laws, including the National 

Environmental the Clean Air Act, the Clean 

Water Act, and the Species Act, and the 

resulting analysis and review processes 1 hat accompany 

land management often lead to conOicts. Fm 

while the Clean Air Act had the beneficial effect 

term 

but not the long~tcrm risks inaction. 

the lmv creates a disincentive to treat lands inhabited endangered 

(eg displacement1 

Shott·tcrm risks to a 

direct mortality) should 

©The Ecoh1gical Society of Anwnca 
92 


36422.048

KC Ryan ct aL 

cause nest sites 

for decades or centuries 

Similar cont1icts between short- long-tenn risks have 

been described fm the effects of fire on 

in the hardwood forests of central 

et al. 2009), where heat and smoke may be 

in the short term but will potentially have pos~ 

canopy openness, and 

Prescribed ftre in North American forests 

(cg Wade and Brcnm'r 

l)ther southeastcm states (Sun 

Further testament to the importance of 

in the Southeast arc the lon.g-stanc!ing 

go the immediate effects are often 

tie noticed and landscape 

burns the COC>'CCIUN,CC' 

short-tcnn 

term risks 
93 


36422.049

Prescribed fire in North American forests 

of escape is greater 

moisture conditions approximate historical burning con~ 

Jitions. Prescriptions are therefore often cor1servarive, 

fuel moisture, relative humidity, anll 

minimize the chance of fire escape. 

ruonu:mueiy, such c6nditions are uncommon, 

in narrow bum windows of only a few days per 

\\'estern landscapes and 

Infrequent conditions 

and air quality permits, which ore 

to burning. Thus, f::Jctors 

rationales often decisions 

where treatments occur. 

II Conclusions 

Anthropogenic and lightning fires shaped North 

American landscapes for millennia, so that many ecosystems are dependent on periodic fire ro maintain impor~ 

tant {At-warns 1992; McClain anll Elzinga 

1994; and Delwurt 1997; Pausas <Jnd Keeley 

2009; Nowacki ct al. TI1ere is, however, still much 

to be learned, with respect to how fire 

(ie the and severity of fire) 

stand-level fire relationships 

scales. Most 

conservation, Experience indicates that neither 

faire fire management nor full suppression 'vill 

accomplish these goals. With current limits to prescribed 

burning, many managers have turned to mechanical surrog<ltes (cg thinning and pile burning). Allowing lightning-ignitell wildfires to burn for resource benefits where 

consistcnr with local management offers 

for large, relatively road!ess et 

al. 2006; et ai. 2009) but may bC' impractical in 

areas. 

J-hnnam been, <:~nd will continue to be, a dominant force in shaping the- landscape (Dcnevan 1992; 

Nowacki et al. 2012; Ryan and Opperman 2013). 

www.fronti,;rsinerolo~:y.org 

KCRyannal. 

Prescribed burning and managed wildfire have been, and 

should continue to be, major tools for affecting that 

process. The challenge for all natural resource management centers around not only conserving the species but 

also preserving and/or restoring biophysical processes. 

Given the current lack of public awareness <mll social 

acceptance (McCaffrey et al. 2013L subdivided anll fragmented landscapes {Gudc et al. 2013; Peters ct al. 2013), 

anll limited funding, expansion of prescribed fire programs will entail a redoubled effort to integrate fire and 

ecological sciences into management and policy. 

R Acknowledgements 

We wish to thank our colleagues for conversations over 

the years that helped shape our thinking ahout the role of 

fire in the past, present, anJ future. Comments 

R Keane substantially improved the manuscript. 
94 


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KCRyanet al. PrcscribcJ ftrc in North American forests 
95 


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Pr~scribc:d fire: in North American forests 

www.frontiersincco!ogy.org @The Ecological Sudety of Amcnn1 
96 


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97 


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About the authors 

Courtney Schultz is the Director of the CSU Public Lands Policy Group and Associate Professor in 

the Department of Forest and Rangeland Stewardship, Colorado State University. 

Heidi llulwr-Stenrns is Associate Director of the Ecosystem Workforce Program, Institute for a 

Sustainable Environment, University of Oregon. 

Sarah McCaffrey is a Research Social Scientist with the U.S. Forest Service Rocky Mountain 

Research Station. 

Doug/us Quirke is a Research Associate at the University of Oregon School of Law's Environmental & 

Natural Resources Law Center. 

Gwen Ricco is a Research Associate with tho Public Lands Policy Group, Colorado State University. 

Cassandra Moseley is Director of the Ecosystem Workforce Program, Institute for a Sustainable 

Environment, and Associate Vice President for Research, University of Oregon. 

Acknowledgements 

This study was made possible with funding from tho joint Fire Science Program (#16-1-02-8). Many 

thanks to all of our interviewees for participating in this research. Layout and design by Autumn 

Ellison, Ecosystem Workforce Program, University of Oregon. 

All photos public domain from U.S. Forest Service and USDA Flickr sites, 

Ecosystem \Vorkforce Program 

Institute for a Sustainable Environment 

5247 University of Oregon 

Eugene, OR 97403-5247-1472 

ewp@uoregon.edu 

ewp.uoregon.edu 

0 I UNIVERSITY OF OREGON 

Public Lands Policy Group 

Department of Forest and Rangeland Stewardship 

Colorado State University 

Fort Collins, CO 80523-1472 

courtney.schultz@colostate.edu 

siles.warnercnr.colostate.edu/courtneyschultz/ 

The University of Oregon is an equal-opportunity, affirmative-action institution committed to cultural diversity and compliance with !ho Americans witfl 

Disabilities Act This publication will bo m~ch ava1!ab!c in accessible formats upon roquest. IG\201 B Univers1ty of Oregon, 
98 


36422.054

Prescribed Fire Policy Barriers and Opportunities: A Diversity of Challenges and Strategies Acmss the West 1 

o are a project investigat· 

ing policies that managers' ability 

to conduct prescribed fire on US Forest 

Service and Bureau of Land Management (BLM) 

lands in the 11 Western states. The goals for this 

phase of our work were to understaml the extent 

to which various policies are limiting prescribed 

fire programs, strategies to maintain and increase 

proscribed fire activities, and opportunities for 

improving policies or policy implementation. To 

understand the of challenges faced and 

st ratogies in use across \'Vest, we conducted a 

legal analysis of the laws and policies that affect 

prosr:ribed fire on Forest Service and 

BLM lands online at 

edu/publicatiens/working) and apprc1X1Ifiiltery 

intorvio"vs with land air regulators, state 

agency partners, and NGO partners. 

Interviewees in most states said air quality was not 

the primary variable limiting their application of 

prescribed fire. The exceptions were in Oregon and 

\\fnshington, whore interviewees said that state~level smoke managtnnent programs rostrkt their abil* 

ity to burn. Rospondon\s in California also said air 

quality can be a major consideration: however, they 

emphasized that there are many other factors that 

are currtmtly lixnHing their programs that IH~cd to 

be addressed, and they did not suggest a need for 

changes to stale regulatory approaches at this lime. 

No respondent suggested tho noed for changes to 

the Clean Air Act. Some additional details include 

the following: 

• In the Intfnmountain \Nest, ptwple said air 

quality is a consideration and constraint for all 

burners, but that available funding and capacity, other land management considerations, and 

internal agBncy dynamics wel'e the fac~ 

tors limiling their use 

• Air quality is a more significant consideration in 

areas near large population centers where there 

are many source.s of in the air.shcd, 

areas with poor air (e.g. the Wasatch and 

San Joaquin sensitive populations. 

• In Oregon and Washington, there are relatively 

stricter state standards for regulating air quality, 

and burners said air quality regulation is one 

of the major barriers to burning. Both states arc 

in the procoss of revising their smoke management programs, and revised programs will 

continue to limit smoke from prescribed to 

standards stricter than those of the federal Clean 

t\ir Act. 

• Challenges au tho horizon include managing air 

for large, multi-day burns and during 

ignitions that are managed for resource 

benefit. 
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2 Prescribed Fire Policy Barriers and Opportunities; A Diversity of ChalJcngcs and Strategies Across the West 

Lack of capacity and funding, and challenges sharing resources across agencies were the most sig~ 

nHicant barriers to accomplishing more prescribed 

fire that we uncovered in our interviews. Addi~ 

tiona! details include the following: 

• Capacity to burn is limited when burn windows 

coincide with wildfire season. 

• Capacity to burn can be limited outside of wildfire season due to loss of seasonal staff, trainings, and other demands on staff time, 

• People cite significant problems sharing resources across units and agencies~ due to a lack of flexibility associated with budgetary requirements 

and challenges using agreement mechanisms 

efficiently and effectively. 

Interviewees said there are limited incentives to 

burn, making leadership and personal investment 

in burning central to success. 

• Con1mitted leaders, according to our interviewees, often find creative strategies to overcome 

the multiple challenges associated with burning. 

Successful programs depend on a personal investinent fronlline officers and fire Inanagement 

officers in conducting prescribed fire, 

• The current structure of performance measures 

within the Forest Service could provide stronger 

incentives to conduct prescribed fire. 

• Interviewees across all states also believed risk 

aversion was an important factor in willingness 

to burn. At the local level this tended to retlect 

concerns about personal liability in case of an 

escaped fire. A\ the higher level it tended to reflect political considerations. 

Interviewees also cited other challenges, including short burn windows, planning limitations, 

and other landscape conditions and conservation 

priorities {e.g. sage grouse conservation, the pres~ 

ence of cheat grass, steep topography) that significantly limit burning in many places, With regard 

to planning, some suggested streamlined planning 

requirements and better coordination across agencies, while others noted the need for fire personnel 

to be present on planning teams to ensure project 

design supports prescribed fire. In some locations 

burn windows are short and infrequent; when 

coupled with capacity limitations, pec>ple said it is 

often difficult to accomplish burning during their 

available windows. 

There is no "silver bullet" to increasing prescribed 

fire, and finding opportunities requires: collaborative, place-specific problem solving; active coordination across air regulators and land nlanagers; 

and coordination among burners to share resources, communicate effectively with the public, and 

manage competition in airsheds. Examples of collaborative bodies and strategies that interviewees 

pointed to include: 

• California's Fire MOU Partnership, which is a 

voluntary group that involves regulators, CALFIRE, federal land managers, and NGO partners. 

The group is focused on improving understanding of barriers to prescribed fire and opportunities. Working groups within this partnership 

are examining why burning does not occur on 

available burn days, and whether this is due to 

weather, lack of capacity, poor planning, or other 

variables. 

• The Montana-Idaho Airshed Group, which is 

run by and for major burners (federal and state 

land managers, and large private landowners) 

to coordinate burning activities and streamline 

cornmunication with the state air quality regulatory bodies, The group tracks all planned burns 

and communicates on behalf of the burners to 

regulators, 

• Dedicated air quality liaisons and smoke coordinators, who are federal agency employees 

that work directly and often daily with state air 

quality regulators. The first such position was in 

1\rizona and was jointly funded by the Arizona 

DEQ and the Forest Service; the Forest Service 

has these positions in place in many states, The 

Department of Interior also has similar positions 

in some states, but there are opportunities to expand this practice for both agencies. 
100 


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Prescribed Fire Policy Barriers and Opportunitie&: A Diversity of Challenges and Strategies Across the West 3 

• PooplA on the ground have some strategies to 

share resources through agreements and use of 

the Good Neighbor and "Wyden" Authorities: 

however, people said that finding easier ways to 

share resources and charge to common funding 

codos are high priorities for change. 

Our interviews did not yield clear indications 

that policy change is needed at the federal level 

at this time, as most interviewees said there were 

opportunities to increase !he use of prescribed 

fire that would not require changes to federal law. 

Realizing these opportunities will require creative problem-solving, and a commensurate input 

of staff time, funding and capacity, and leadership 

initiative. Two areas where policy change may be 

warranted arc 1) in smoke managAment programs 

in Oregon and Washington, where such revisions 

are underway, and 2) potentially to facilitate easier 

approaches to interagency resource sharing. In ad~ 

clition, changes to incentive structures within the 

Forest Service may be warranted, and it is worth 

exploring possible internal practices that could alhwiate current capacity limitations. Some suggestions drawn from our interviews include: 

• Ensuring air quality liaisons are in place for 

all states and exploring whether additional 

state-level groups, modeled after practices in 

California and Montana/Idaho, are needed to 

coordinate among burners a11d with air quality 

regulators. 

• Improving intornal incentiv(~S to burn through 

redesign of somo performance measures or the 

creation of special initiatives with funding that 

units and r::ollabnrative partners could cmnpeto 

for. 

• Identifying more efficient and effective avenues 

for resource sharlng. Suggestions inclndo: centralizing contracts and agreen1onts staff, or find~ 

ing other ways to ensure they arc knowledgeable 

about all options and give consistent advice; ere~ 

ating other agreement mechanisms that are less 

cumbersome than current options; and finding 

ways to charge more easily to .single budget lines 

when using resources frorn multiple agencies. 

As our work continues, we will explore whether any of these recommendations may require 

policy changes. 

• Ensuring capacity is available through improved 

strategic planning, use of dedicated proscribed 

fire crews, greater flexibility to use fire personnel 

across units, and rnore effeclive use of partner 

capacity. 

• llnproving measurement of smoke generation 

and dispersion in order to identify additional 

opportunities to burn and promote transparency 

in decision making. Investments could be directed to necessary equipment and meteorologist 

positions. 

This report contains additional, spt:-)ci11c details on 

the strategies in place and suggestions from participants in this phase of our research. Our future 

work will build on this analysis with case studies 

in locations that are currently finding ways to build 

their prescribed fire programs and will include ongoing dialogue with practitioners, partners, agency 

leadership, and policymakers. 
101 


36422.057

4 Prescribed Fire Poliry Barriers and Opporlunilies: A Diversity of Clwllengos and Strategies r1cmss the West 

e are conducting a project investigating policies that limit managers' ability 

to conduct prescribed fire on US Forest 

Service and Bureau of Land Management lands in 

tho 11 Western states. Our primary objectives are 

to: 1) Identify current perceived policy barriers to 

implementing prescribed tlre and how these vary 

across the West, and 2) Characterize actionable opportunities and mechanisms for overcomi.ng barri~ 

ers. Ultimately, our aim is to identify which policies 

present the greatest priorities and opportunities for 

change, and what the mechanisms are for realizing 

those opportunities. This report details our findings from our initial phases ofresearch on this project, including a legal analysis and approximately GO 

interviews with key informants (e.g. land managers, 

air regulators, and state agency partners). 

Prescribed fire1 is an essential n1anagement tool for 

restoring and maintaining the resilience of fire-dependent ecosystems; however, land managers are 

unable to apply prescribed fire at the necessary lev¥ 

els to achieve land management objectives (North et 

a!. 2012, Ryan eta!. 2013, USDA and USDI 2014). In 

past surveys, managers have indicated. that air quality regulation is the most significant barrier to undertaking proscribed fire (Cleaves eta!. 2000). Other 

policies that reportedly act as barriers include the 

Endangered Species Act (ESA) and environmental 

planning laws, such as the National Environmental 

Policy Act (NEPAl and National Forest Management 

Act (NFMA) (Cleaves eta!. 2000; Quinn-Davidson 

& Varner 2012). Recent papers on the challenges in 

US fire management generally have emphasized the 

need for policy change to support prescribed fire, 

and some have suggested there may be a need to 

reduce regulatory restrict ions on smoke to allow 

for more application of prescribed fire to promote 

fire-adapted ecosystems and communities (North et 

a!. 2015; Schoennagel et al. 2017). As a result, thoro 

is a widely accepted understanding that the current policy environment significantly constrains 

decision-making around prescribed fire (USDA & 

USDI 2014). 
102 


36422.058

Pn:::wlihed Fire Policy Barriers ond Opportunities: A Diversity of Challenges and Stmtegi()S Across the Wnst 5 

The term "policy" encompasses a variety of actions 

taken (or not taken) by government, and changing 

policy is a complex To where 

policy may necessary and 

is to distingulsh between 

thai 1) fixer! in congressional 2) a result 

of state or federal agency policy interpretations 

(o,g, regulations and agency 3) a result of 

agency culture or habit, and a result of individual 

""'"''w;;-u;u>-'11!4 at the tleld level, whore decisions 

factors such as the social onvironmrmt in which decision~makers act and their 

individual of risk~aversion {Moseley and 

Charnley Each typo of policy-related chal1r.ngt; presents different opportunities, risks, and 

for change, Amending federal environthrough tho US Congress is dif!!cult 

achieve; issues for congressional action must be 

agenda and often require substanof members of Congress \o champion 

legislative Regulatory changes can be 

undertaken by the executive branch, hut they also 

takt.:; many years to achieve through rule~ making 

processes under the i\dmin]stratbm Procedures 

J\ct and can be amended by subsequent administrations, Substantial to 

ally aro relatively less 

norms and behaviors requires susto communication, loadershi p, and 

incentive slructmes (Fernandez & Rainey 2006), It 

is also important to note that policy changes may 

have limited efficacy and unexpected effects, These 

considerations should inform discussions of policy 

change RS an avenue for increasing the application 

of prescribed lire on fedora! lands, 
103 


36422.059

Prescribed Fire Policy Barriers and Opportunities: A Diversity of C'hallcnges and Stmtegies Across the 

This project was funded 

Program in 2016 with the of identifying 

the origin and range of interpretation of perceived 

policy barriers, characterizing the opportunities 

and mochanisms that are available to overcome 

barriers at various scales, and educating stakehold· 

ers about the most ready opportunities for change. 

The involves four primary tasks: 1} a legal 

of laws that affect tbe use of prescribed 

fire (available online at http://ewp.uoregon.edu/ 

publications/working); 2} interviews across the 11 

\Vestern states to identify the divHrsity 

es and challonges associated with 

pr•osc:ntled fire; 3) a spatial analysis of 

accmnpnsnn1er1ts and their correlation with air 

4) case studies of locations that are acto accomplish more prescribed 

our findings from tasks 1 

We began with an analysis of tho major 

that constrain fire, including a 

state-level air quality regulation 

federal Clean Air Act. For the state-lnvel 

investigatlon, ·we initially identified rnfonmces to 

proscribed fire, smoke management, and visibil~ 

ity or regional haze in state implementation plans 

(SIPs), which are required by tbe Clean Air Act. We 

revie·wcd state laws pertaining to prescribed fire 

and additional state lm.vs, policies, or plans relevant 

fire on federal lands. Subsequent innr:actiti'"'"'"' generally revealed more 

regarding the implementation of 

and polic:ies on tho ground, and brought to 

light additional laws and policies having an effect 

on implementation of prescribed fire. We revicewed 

these as nnces::;ary to completo our legal analysis. 

In Fall of 2017, we began inlflrviews across the 11 

western states. 2 Our goal was to obtain a broad un~ 

derstauding of policy barriers to fire 

across the \Vest, and to idrmtifv across 

the states and for. improving practice. 

VVe 'vero not con1prehonsive case sturl.~ 

ies of overy state in this analysis. Our approach ·was 

to interv icw a lead person for the BLM and Forest 

Service in each state. At the state or regional level 

for these agencies, we identified people who were 

fuuls program leads or direc!ors/assislanl directors 

of fire and aviation managemnnt We also spoke to 

air quality or smoke management liaisons within 

these agencies whnn our pritnary point of contact 

recommended "\VB do so. In states where the For~ 

est Service has no regional office, we spoke to a 

fire management staff person at tho national forest 

level. We also reached out to state forestry agencies to identify a contact for each state and to state 

departments of environmental to hear the 

perspective of air quality In the states 

where they exist we also spoke to chairs of prescribed fire councils. In the end, we targeted at a 

minimum one Forest Service, one BLM, one state 

regulatory, and one prefor all 11 states. Our 

lotA.l number of interviews was 56, with son10 stateto-state variation, due either to unvvillingness to 

participate or recommendations for additional, koy 

people to interview. Interview focused 

on: 1) progress towards 

goals for the management agone ius; Z)rcgnlalory processes for regulatory agencies; 3) barri· 

ers to improving prescribed fire accomplishments, 

4) strategies and suggestions for increasing use of 

prescribed fire, and 5) the role of partners and com-
104 


36422.060

Prescribed Firv Policy Barriers and Opportunities; A Diversity of Challenges and Strategies Across the West 7 

Because the literature had identified air quality regulation as a major barrier to prescribed fire and an 

arena for potential policy change, we investigated 

this topic in detail in both our legal analysis and interviews. In this section, we provide an overview of 

interviewees' perspective on air quality regulation 

as it interacts with prescribed fire programs (the legal analysis oflaws that affect the nse of prescribed 

fire is available online at hllp://ewp.uoregon.cdu/ 

publications/working). Policy in this area is complex. necessitating some background, provided in 

the next section, on how regulation works under 

the Clean Air Act in order to interpret our findings. 

Subsequent sections report on findings from both 

our legal and intlnview analyses. 

Federal Clean Air Act regulation of prescribed fire 

emissions primarily addresses two categories of po~ 

lential consequences of such emissions: 

• The potential for prescribed fires emissions to 

violate National Ambient Air Qualitv Standards 

(NAAOsl: and 

• The potential for prescribed fires emissions to 

negatively affect visihilitv and rogional haze. 

States have smoke management programs to main~ 

tain compliance with requirements related to both 

regional haze and NAAQs. The eleven states encompassed by this project generally regulate emissions 

from prescribed fires for both of these potential 

effects, with specific details of programs varying 

from state to state. Srnoke management programs 

are typically incorporated into state regulatory law, 

and the elements of a state's smoke management 

program that are legally binding under the Clean 

Air Act also are referenced in the State Implementation Plan (SIP). 

NAAQs: The federal Clean Air Act requires the 

federal Environmental Protection Agency (EPA) to 

establish National Ambient Air Quality Standards 

(NAAQS), and "states have the primary responsibility for achieving and maintaining" these standanls.' EPA has established standards for carbon 

monoxide, lead, nitrogen dioxide, ozone, particle 

pollution, and sulfur dioxide. States then must outline their strategies for achieving and maintaining 

the standards for each of these pollutants in their 

SIPs. Areas within states are designated as in "attainment," "non attainment," or an "unclassifiable" 

status based on available information. The major 

pollutants of concern from fires are particulate matter-both coarse (l'M10) and fine (PM25)-and ozone 

precursors (NWCG, 2001, as cited in Engel, 2013), 

SIPs: State implementation plans (SIPs) are required 

under the Clean Air 1\ct, are legally binding, and 

incorporate a range of tools to address air pollution, 

including statutes, regulations, directives, manuals, 

and county and municipal ordinances. The Clean 

Air Act and its implementing regulations (promulgated hy tho federal EPA) establish minimum standards for SIPs, with differing "requirements and 

procedures ... triggered depending on the degree 

of attainment or nonattainment of the NAAQS." 

Visibility & Regional Haze:• The Clean Air Act's 

visibility protection requirements date to 1977 

amendments to the Act aimed at remedying existing and preventing future "'impairment of visibility" in ''Class I Areas," which are primarily desiguated wilderness areas over 5,QOO acres in size 

and national parks over 6,000 acres in size. There 

are 108 Class I areas in the eleven-state region en~ 

compassed by this project, which amounts to 59% 

of all Class I areas nationwide. Congress amended 

the Clean Air Act in 1990 to address impairment of 

visibility in Class I areas by ~<regional haze", or "vis~ 

ibility impairment that is produced by a multitude 

of sources and activities that are located across a 

broad geographic area .... "5 Current regional haze 

regulations require comprehensive SIP revisions 

to strengthen existing regional haze SIPs by july 

31, 2021. Revised regional haze SIPs must focus 

on "attain[ing]natural visibility conditions by the 

year 2064,"6 and must include "a long-term strategy 

that addresses regional haze visibility in1pairment 

for each mandatory Class I Federal area within the 

State and for each mandatory Class I Federal area 

located outside the State that may be affBcted by 

emissions from tho State."7 
105 


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8 Prescribed Fire Policy Baaiers and Opportunities: A Diversity of Challenges nnd Stratr.gif-'S Across the VIlest 

Exceptional Events Rule: \VhBn exceptional events, 

such as a wildland fire, occur, a state can petition 

EPA to exclude the monitored emissions of that 

event frmn assessments of slate compliance with 

SIPs. In recent years. EPA has signaled increased 

support for prescribed fires in its revised regulations regarding exceptional events, EP1\ has stated 

that it "do[es] not expect the total acreage subject 

to prescribed flres on wildlands to decrease in the 

future because prescribed fire is needed for ecosystern health and to reduce tho risk of catastrophic 

wildfires."' Although managers are not allowed to 

plan a prescribed fire that will violate a state's SIP 

[e.g. cause an exceedance of NAAQs), the rule allows emissions from qualifying prescribed fires to 

be excluded from compliance determinations when 

smoke from prescribed fires leads to unanticipated 

exceedances, as long as smoke management is employed and the fire is part of a qnalifying prescribed 

flre program included in a land or resource manageInent plan.n 

state is unique in its regulatory structure 

and interagency partnerships for overseeing air 

quality impa<:ts from prescribed burning (see Table 

1, page 14 for an overview of legal requirements by 

state). Most states have a Department of Environmental Quality (DEQ) or equivalent office that handles air quality permitting for prescribed burning. 

Exceptions include: California, where tho California Air Resources Board oversees 30+ air pollution 

districts or control boards that handle permitting 

for specific areas; Nevada, where two county offlees handle permits for their county, while the NV 

Department of Environmental Protection handles 

permits for the rest of the state: Oregon, where the 

Oregon Depart men\ of Forestry handles permitting 

as a conduit between the Oregon DEQ and burners; 

and Washington, where tho Department of Natural 

Resources handles permitting for federal public 

lands. 
106 


36422.062

Prcsr:ribed Fire Poli<.y Ban1ers and Oppo<lunitiDs: A Diversity of Challenges and Strategies Across the West 9 

All states have unique permitting processes that 

depend on their smoke management plans, regu~ 

latory structure, and local considerations. Some 

states, like New Mexico and Wyoming, have a 

permit-by-rule system, whereby burners must register burns and notify DEQs about burning activities, hut do not receive a permit. In Colorado and 

Washington, air quality agencies write permits for 

each burn plan, usually with daily acreage limits 

that vary depending on ventilation conditions. In 

other states, such as Montana and Idaho, the DEQ 

writes a single permit for the entire year for each 

"major burner," a category that includes each land 

management agency. During much of the burn season, daily coordination calls are held between DEQ 

and with major burners to minimize conflicts and 

potential smoke impacts. In Arizona, burners register their hurns and smoke management prescriptions with the DEQ annually and then must seek 

a daily permit, based on daily conditions and considerations. Pennittingin California proceeds similarly, with annual registration of planned burns in 

the Prescribed Fire Information Reporting System 

and then a daily coordination call to communicate 

whether burning is allowable on a particular day 

and for coordinating and approving planned burns 

wHhin 24 hours of iguition. States generally require 

24-hour-prior notification of plans to burn and postburn reporting 

to 

Although air quality is a consideration and constraint for all burners, many intervieweest particu .. 

larly in the Intermountain West, said air quality 

is not the primary barrier they face to increasing their prescribed fire accomplishments. As wo 

discuss in more detail in Section II of this paper, 

in most of the states in the Intermountain West, 

people said that available capacity (resources and 

personnel), other land management considerations, 

or internal agency dynamics were the primary factors limiting their use of prescribed fire. People 

acknowledged that while there are times when air 

quality is a limiting factor, there are often many 

other days they can burn. Some staff indicated that 

if they were burning as much as the>y should be to 

min1ic natural ecological processes, then air quality would become a major consideration; however, 

people said their programs were nowhere near this 

ambitions, becanse of other reasons like risk tolerance, funding, capacity, and competing priorities. 

When we asked why air quality gets highlighted as 

a barrier. interviewees indicated that an air quality 

pennit is an easy variable for managers to focus on, 

because it is a structured process and often the last 

piece of the puzzle to put into place in planning 

a burn. To illustrate, we include here a sample of 

comments from different land managers: 

• "We have worked really hard to communicate 

and build relationships with our air quality 

folks in Arizona and New Mexico. I think there 

are a lot of other things that come into play hefore air quality does, to keep us from implementing prescribed burns." 

• "There's a misconception out there a lot of times 

that l hear, that the air quality regulator is the 

barrier that's restricting us from being able to 

accomplish our burns that we are required to 

do. I find that is an easy go-to, but the data that 

we have does not reflect that." 

• "The law doesn't necessarily impede prescribed 

burning so much as some of the more practical 

realities on the ground. You don't have enough 

money, you don't have enough people, there's too 

much fire danger." 

• "I think the biggest thing is buru window availability. The smoke side of it ... it does have an 

effect, but I think it's minor." 

• "Air quality is soi11ething we have to consider, 

but it's also just a matter of, 'Do we have the 

people to burn where we want to burn? Do we 

have the buru windows? Is there political tolerance?' I've heard from a numhor of peopln that 

they feel like air quality gets almost scapegoated 

as an easy excuse sometimes. I'll say ... it does 

get scapegoated, because it has a structure that 

you have to follow." 

"Air quality plays a role in all these things, bnt 

in my experience people like to complain about 

it. But, I haven't seen it deemed a major barrier. 

Once people have all their ducks in a row and 

are ready to go, air quality is generally not the 

issue." 
107 


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10 Prescribed Fire Policy Barriers and Opportunities: A Diversity of Challenges and Stmtcgics Across the West 

• "I think a Jot of people kind of hang their hat on 

lair quality permitting] being our major implementation barrier, but when you start to look 

at the numbers, I don't think it's tho major one. 

It's definitely a component that restricts ... kind 

of narrows our windows when we can use prescribed fire ... extra hoops that we have to jump 

through. And it's not univcrsalli.o .. it's different 

from state to state]." 

Air quality is a more significant consideration 

in areas with large populations centers, poor air 

quality, and sensitive populations. Being close to 

Class I airsheds or population centers, where there 

are many sources of emissions that compromise air 

quality, presents both land management agencies 

with more air-quality related considerations. For 

example, one person explained that air quality was 

a challenge on Colorado's Front Range, given population centers and the presence of a Class I airshed 

(Rocky Mountain National Park). As another person 

noted, "When you go to a national park... the one 

lime in your life you might visit an individual park, 

you can have a very poor experience because of 

fire , ... It's really hard to convince somebody this 

is a wonderful, natural experience.'1 Inversions in 

places like Missoula or the Wasatch Valley of Utah 

were cited as a limiting factor, as was air quality 

in highly populated and polluted areas of California, such as the San Joaquin Valley. In Oregon and 

Washington, in addition to relatively higher levels of regulation, which we discuss below, some 

said towns with high levels of tourism and smokesensitive populations can be less tolerant, leading 

land managers and air quality regulators to be rnore 

careful about smoke intrusions'" than the NAAQS 

would require. Another person pointed to communities throughout Arizona with people who have 

moved their specifically because they are sensitive 

to smoke and air pollution. However, outside oft he 

West Coast states, people did not indicate these considerations wore primary variables limiting their 

burning programs. 

In Oregon and Washington, there are relatively 

stricter state standards for regulating air quality; 

in these states, burners said air quality regulation 

is one of the major barriers to burning. Both states 

limit smoke intrusions into communities~ oven in 

cases whore these would not cause an exceedance 

of a NAAQS. For example, a prescribed fire might 

result in a temporarily unhealthy level of smoke 

that the stale regulator deems intolerable even when 

it might not trigger an exceedance if the NAAQS is 

based on a 24-hour standard. One person explained, 

"Washington really has been strict. They don't want 

any intrusion of any smoke into any communities 

at any time." Prescribed burns are generally pro· 

hibited on weekends (Friday-Sunday) between June 

15 and October 1 in Washington (though there are 

provisions allowing for exceptions to this prohibition). Another person explained that smoke management plans and permitting in Washington also 

create barriers to burning, saying "when it comes to 

air quality regulation, the biggest barrier is the way 

the smoke management plans and the permitting 

[are] implemented [which] is really [about] protection against short term intrusions of smoke or nuisance smoke." They wont on to explain that even 

if federal standards are not violated, it can lead to 

complaints from the public, discussions of fines 

from the state, and increased local regulation. An 

interviewee said in Oregon they would like to see 

ongoing consideration of sub-24-hour intrusions but 

less formal regulation to a standard that exceeds 

that of EPA. A number of people said that inversions and intrusions tend to happen at night, even 

during times of good daytime dispersion, limiting 

the ability to burn. People indicated that the tolerance of individual regulators in Oregon for writing 

intrusion reports and dealing with public backlash 

leads to variability in what is allowed across the 

state. VVhen discussing tradeoffs between human 

lwalth and then need for fire, it was in these two 

states that burners consistently said there was a 

need to improve smoke managernent plans, noting 

that some of these changes were in the works. Both 

Oregon and Washington are revising their smoke 

management plans, which will require demonstration to EPA that changes to regulation will not lead 

to a greater chance of an exceedance of a NAAQS. 

In California, multiple sources of pollotion and 

high population levels can lead to air quality 

conditions that restrict burning. One person explained, when discussing communication with 
108 


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Prcscribr.d Fire Policy Barriers ond Opportunities: A Dhnxsity of Challenges and Strategi()S Across the ""Vest 11 

Air Pollution Control Districts, "Some of these air 

districts have taken ... more restrictive policies than 

the law requires. Some of those air districts might 

loosen up those policies. But, in California, if you 

are burning in an area where your smoke is going 

to wind up in the Central Valley, it's always going 

lobe difficult, because you're dealing \.vith so much 

comp1::1tition for your air. The farming industry, 

manufacturing, cars, diesel trucks , , , everybody 

wants \o pollute ... We're the easiest tap to turn 

off." Another person said, "We do face challenges 

on air quality, but we've sort of, , , submitted to 

those challenges, if you will , , , We're competing 

with folks who aro burning wood smoke in their old 

wood ftreplaces. A couple million people doing that 

day," Despite this, people did not highlight a 

for regulatory change, but rather the need for 

more communication and creativity to help identify 

opportunities within the current legal framework, 

One person said, "The air regulations are going to 

be an impediment. , , , hut I feel like there's a little 

bit of change happening , .. Particularly after a 

year of really large, catastrophic wildfires, and the 

[fact that the] science shows that prescribed fire 

under almost all conditions, , producc[sl significantly less smoke per acreage , . , . I feel like the 

air regulators are really working \'\rith us, but we 

are going to continuo lo comply "vith tho statutes, 

as they exist." One person suggested changes to air 

quality regulations may be needed in the future, 

but everyone said lhat, before focusing on changes 

to regulations designed to protect human health, 

there were other priorities to address to increase 

use of proscribed llre, including bettor monitoring 

and planning to find ways to burn without triggoring the NAAQS, addressing capacity issues, and 

planning more strategically to capitalize on burn 

days when they are available (see the Section If for 

more information on these topics), 
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12 Prescribed Fire Policy Barriers and Opportunities; A Diversity of Challenges and Slrate[Jie8 Across the West 

I.and managers and air quality regulators 

cussed the importance of air quality regulation for 

protecting human health. Many regulators emphasized their professional duty to protect sensitive 

populations from air quality risks; in states with 

smoke management liaisons, who work for tho land 

management agencies and interface with tho DEQs, 

those individuals often also expressed significant 

concerns about the public health impacts of prescribed fire. People said a fundamental challenge 

is detennining what is an acceptable level of risk 

to public health from prescribed fire. Due regulator said, "One hour of the wrong smoke level can 

trigger an asthma attack [and! put someone in the 

hospital .... That's my main concern .. , are those 

vulnerable populations who can't really afford to 

protect themselves,'' Land managers also often acknowledged that air quality can be a life or death 

matter for individuals, and that the NAAQS may 

not be protective anough for sensitive populations, 

Another person front a land management agency 

explained, "One of the first things that I always talk 

to, when I talk to [staff frustrated with air quality 

regulation]-the first thing I explain to them is if 

wo waited for an exceedanco on burns, there '"'~auld 

be people that would probably die." Interviewees 

said allowing prescribed fire requires trust that 

land managers are doing their best to limit smoke 

impacts and that prescribed !lre will prevent wildfires in the future. One person noted,"! think the 

law has tried to facilitate prescribed burning, but 

not really give a blank check." Several people emphasized the need for air quality regulation and 

said that land managers, with their professional 

training and incentives oriented towards land 

manogmnent objectives, could not bo relied upon 

to manage for smoke without input from air quality regulators, who are focused on and trained to 

address human health considerations. 

Larger-scale, landscape burning is particularly 

challenging to achieve and to permit from a regulatory perspective. Some people explained that it 

is dif!lcult to find multiple days in a mw with tho 

right weather conditions, adequate capacity, and 

air quality/dispersion conditions to facilitate large 

burns. From an air quality permitting perspective, 

it can be both uncertain and risky to permit large 

burns that may go on for weeks, In smne places near 

towns, where smoke settles into populated areas at 

night, some people suggested landscape burning 

is difficult to justify and achieve, given the risks. 

In California, in particular, this issue may require 

attention. One person explained, "So we've all been 

saying, in all of our venues where we come together 

with air regulators, we need longer windows, and 

we need more opportunity to burn on marginal 

days. We've got to expand the permission space. 

And we don't U1ean that to hurt anyone, to cause 
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Prescribr:d Fire Policy Barriers and Opportunities: A /Jivnrsity of Challenges and Strategir:s Across the West 13 

them to go to a hospital, or because wo don't care, or 

anything like that; it's just that there's an emissions 

trade off every time we don't burn that we need to 

call out as very much a real thing. It's not speculative anymore. Ccllifornia is so flammable these days 

that we're trying to push this conversation ... are 

the [burn] windows long enough? No, they're not," 

The argument that communities have to face 

smoke now (i.e, through prescribed fire) or later 

(Le, through wildland fire) was not convincing to 

many on the ground. Regulators emphasized that 

this argument hinges on the assumption, which 

may not always be true, that proscribed fire now 

will limit wildland fire later. Others noted that 

people in general prefer to put off risks into the future, particularly when those risks may novor come 

to pass. Some noted that a key difference between 

wildfire and prescribed fire is that prescribed fire 

is intentionally lit. and, therefore, the government 

has a responsibility to minimize harm in a way that 

fundamentally differs from a wildland fire event. 

Ultimately such dichotomies are too simplistic to 

accommodate the deliberative dialogue about prescribed fire so many emphasized as being critical 

among the public. land managers, and air quality 

regulators. However, several people emphasized 

that smoke from prescribed fire, which can be done 

under controlled conditions with good ventilation, 

is far preferable to smoke from wildland fire. The 

challenge is ensuring that all involved parties believe tho risks of prescribed fire, which may need to 

be done every few years, are worth taking in order 

to lower the risks associated with future fire. 

Some have suggested that prescribed fire be treated 

as an exceptional event like wildland fire and not 

he regulated; this is not a feasible recommenda~ 

tion, according to our interviewees. Although a few 

interviewees indicated that the new exceptional 

events rule creates more space to petition for a prescribed fire that causes exceedances of NAAQS to 

he considered an exceptional event, intcrvieweos 

also noted that the signillcance of the rule change 

was limited because it does not allow prescribed 

fire to be exempted from regulation. It is not permissible under the Clean Air Act for federal land 

n1auagers to intentionally plan and cause for exceedances. As one person said, "The problem with 

tho exceptional events rule is you've gotta have an 

exceptional event You can't plan to have an exceptional event." Changing this would require an 

amendment to tho Clean Air Act. People who spoke 

to this question said this is not desirable, offering 

multiple reasons: 1) air quality regulation to stay 

helow NAAQS exceedances is not the biggest barrier to prescribed fire, 2) it would introduce considerable risk to a major environmental law to open 

it up to amendment. 3) it is unreasonable to think 

that land managers acting alone will steward air 

resources with adequate care, finding the ideal balance of burning to reduce risk while protecting human health. and 4) it is politically not viable to look 

for legislation where a federal laud rnanagmnent 

agency wants an exemption from environmental 

law in a way that would compromise human health. 

One person said, "I think politically that would be 

suicide ... public opinion would bang us. [They'd 

think] the government is trying to kill us." 

There is potential for conflict around how smoke 

from managed natural ignitions is handled; some 

of these issues may require attention going for .. 

ward. One regulator noted, "So if they get a natural start ... they are going to be putting fire on the 

ground to keep that fire going as long as they can 

to avoid having to comply with our requirements 

because we did not see this coming. They're using 

that as a way to avoid our requirements for smoke 

management." This person explained that avoiding 

direct communication will only force regulators to 

act to protect public health. As a separate issue, 

some discussed that managers can count wildland 

fire acres burned as accomplishments towards fuels targets; however, in one state, we were told that 

those acres can only be counted towards targets on 

days when air quality regulators also would permit 

hurning. On this topic, one person said, "[Regulators] realize they can't force a suppression, Then 

you get this policy jockeying around ... you know, 

[air quality is] not favorable today, so it's not considered a resource benefit , .. hut tomorrow [it] might 

be. It doesn't change on the ground generally, so it 

is bizarre." Some of these details may require additional attention to find positive paths forward. 
111 


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14 Prcsctihcd Fire Policy Barriers and Opportunities: A DiveTsity of Challenges and Strategies Across the West 

Table 1 State•by·State Overview of Air Quality Regulatory Process and Interagency 

Relationships to Support Burning 

Regulatory overview: 

Responsible agencies 

and applicable law 

r -Ar~~ De;rtment of--

1 

Environmental Quality (ADEO) 

Arizona Administrative Code 

I"' 

.~ , <C I 

I I 

I I 

~- ~hlo;~ia Air Resources Board 

t and California's 35 air districts 

l Smoke Management 

I Guidelines for Agricultural and 

~ Prescribed Burning (codified in I ·E Califomla Code of Regulatlocs) 

~~ 

I 

.g 

Colorado Air Quality Control 

I Commission 

1 Colorado Department of Public 

Health and Environment or an 

authorized local agency 

f! Colorado Code of Regulations 

-

~ Colorado Smoke Management 

Program Manual 

Prescribed fire planning and approval 11 

Land managers must make best efforts to register all planned bum projects before December 31 

each year, but no later than January 31 

ADEO required to hold meeting after January 31 and before April1 between ADEO and land man~ 

agers to evaluate program and cooperatively establish "annual emission goal" ("planned quantifiable 

value of emissions reduction from prescribed fires and fuels management activities'') 

Land managers must submit burn plans to ADEQ at least 14 days before burn date 

Daily burn request must be submitted to ADEQ by 2 P.M. on business day preceding burn 

ADEQ approval of request required before ignition, with constructive approval where explicit ap~ 

proval is not received from ADEO by 1 0 P.M. on the day request was submitted (burner must make 

effort to confirm that request was received by ADEQ) 

Smoke management programs for air districts with "prescribed burning in wildlands or urban interfaces" must include annual or seasonal registration of all planned burn projects; burns are registered 

online in Prescribed Fire Information Reporting System (PIFRS) 

Each of California's 35 air districts must have a smoke management program that includes a daily 

burn authorization system 

Air districts' burn authorization systems issue "48~hour forecasts, 72~hour outlooks, and 96·hour 

trends" for burns 

Air district burn authorization systems must include procedures "for authorizing .. , proscribed burns 

24 hours prior to ignition~ 

By 3 PM each day, California Air Resources Board must normally announce whether following day is 

a "permissive burn day'' or a "no-bum day" for each of California's 15 air basins 

Significant users of prescribed fire must submit planning documents to Colorado Air Oualhy Control 

Commission for each area in which the user intends to use prescribed fire addressing the use and 

role of prescribed fire and resulting air quality impacts 

Air Pollution Control Division of Colorado's Department of Pub!ic Health and Environment must 

review planning documents and present comments and recommendations to the Commission 

Commission must hold a public hearing and complete review within 45 calendar days of receipt unless significant user of prescribed fire agrees to longer review period 

APCD may take up to 30 days to review permit application 

"Nottfication of Ignition'' must be submitted 2 to 48 hours before ignition 

Fire Activity'' report due by 10:00 AM on business day following each proposed igni-
112 


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Pmscribed Fire Policy Barriers and Opportunities.· A Diversity of Challenges and Strategies Across the West 15 

Regulatory overview: 

Responsible agencies 

and law 

Group with Missoula-based 

"Smoke Management Unit'' that 

coordinates/administers 

Idaho and Montana DEOs and 

local regulatory authorities also 

have roles 

Montana/Idaho Airshed Group 

MOU committtn_g to agreedupon smoke management 

program and operating guide 

Idaho and Montana DEO 

regulations 

Nevada Division of 

Environmental Protectbn 

(NDEP) for all of state except 

Clark County and Washoe 

County, which administer 

program in their jurisdictions 

Management 

"Burns that will require more than one consecutive day of ignition to complete require additional 

coordination" 

''Special notification and direct approval from both DEOs" required for ''Extended-duration Landscape-scale Prescribed BurnsN ("ignited and managed over weeks of time to mimic tho natural 

progression of fire on the landscape within parameters identified in the bum plan" and "monitored, 

additionally ignited, or partially extinguished until season-ending precipitation puts them out completely") 

Smoke dispersion forecasts posted to Airshed Group web page by approximately 10:00 am Man 

through Fri 

Burns proposed via Airshed Management System by noon day before proposed bum (noon Fri for 

Sat/Sun/Man burns) after reviewing dispersion forecast 

Idaho and Montana DEOs and local air agencies "may review the forecast and burn proposals by 

2:30 pm ... and relay any issues or concerns" 

Restrictions/burn recommendation posted by 4 pm 

"Local regulatory authorities .. may impose additional burn restrictions after the, , , burn recommendations have bean posted" 

Permit application must be submitted at !cast 30 days prior to planned ignition date for fires emitting 

more than 10 tons of PM1 0 

Permit application must be submitted at least two weeks prior to planned ignition date for projects 

emitting between 1 .0 and 1 0 tons of PM1 0 

Land managers must notify the Division as soon as practicable, but no later than 2 pm of the business d<:~.y preceding the burn 

Division must issue final decision on the burn (approval, approval with conditions, or disapproval) by 

5 pm on the business d<:~y prior to ignition or burn is deemed approved 

Notification to relevant regulatory authorities is required prior to ignition for projects that emit more 

than 1 0 tons of PM1 0 and are within 15 miles of the state border, BlA trust lands managed under 

of a tribal air quality agency, or the borders of Washoe or Clark counties 

Different requirements for burn projects with < 1 ton PM-1 0 emissions per day (SMP-1) and burn 

projects with one or more ton PM~1 0 emissions per day (SMP-11) 

SMP-1: 

• Notification of populations w/i one mile betwo.cn 2 and 30 days prior to ignition 

• Registration by 1 0 am one business day prior to planned ignition 

SMP-11: 

• Registration by two weeks prior to planned ignition 

• Public notification between 2 and -30 days prior to ignition for burns within 15 miles of a population 

or w/ wind blowing toward a population 

• Notification to Dept between 7 days prior to ignition and 1 0 am one business day prior to planned 

ignition 

Notification for both 
113 


36422.069

16 Prescribed Fire Policy Barriers and Opportunities: A Diversity of Challengos and Strategies Across the West 

Regulatory overview: 

Responsible agencies 

and applicable law 

Oregon Department of Forestry 

Oregon Department of 

Environmental Quality 

Oregon Administrative Rules 

§_ Operational Guidance for the 

~ Oregon 

Smoke Management Program 

Utah Department of 

Environmental Quality Division 

of Air Quality 

Utah Administrative Code 

Washington Department of 

Natural Resources 

Washington Department of 

Ecology 

l Smoke Management Plan 

.S: codified in Washington 

~ Administrative Code 

~ 

Wyoming Smoke Management 

~ Standards and Regulations 

'E (codified as Chapter 10 of 

g. Wyoming Administrative Rules) 

;: 

Prescribed fire planning and approvaP1 

Land managers must register burns with the State Forester at least seven days before the first day of 

ignition (requirement may be waived if federal policies met) 

Land managers may request special forecast and instructions at !east two days in advance for multiday burns and burns with > 2,000 tons of fuel loading 

Smoke Management Forecast Unit issues daily forecasts and instructions no later than 3:15 p.m. 

during periods of substantial prescribed burning (forecasts and instructions are fur the day following 

issuance) 

Land managers must provide location, method of burning, and fuel loading tonnages to Smoke Management forecast unit by the day of the burn 

Land managers must obtain current smoke management 'forecast and instructions prior to ignition 

and must conduct burn in compliance with instructions 

ugo-no go 

Director of Utah Department of Environmental Quality's Division of Air Quality must provide opportunity for an annual meeting with land managers to evaluate and adopt annual emission goal, 

which must be developed in cooperation with states, federal !and management agencies and private 

entities to control prescribed fire emissions increases to the maximum feasible extent; goa! is established prior to the beginning of fire seas-on, either at the beginning of the calendar year or before the 

year begins 

Land managers must provide director with "!ong~term projections of future prescribed fire activity" 

and "list of areas treated usin9 non~buming alternatives to fire during the previous calendar year'' by 

March 15; land managers planning prescribed fire that will burn more than 50 acres annually must 

also submit a "burn schedule" at this time 

Land managers must submit pre~burn information to director for approval at least 2 weeks 

beginning of the "burn window" 

prescribed fires to the director by 1 0 AM at 

Multiple day burns require landowner to give burn plan information to DNR for review three 

before the burn, with DNR notification of any additional requirements two months before the burn 

!f DNR determines that the burn has potential to affect communities, landowner must notify public of 

the burn at leas! one week before they plan to burn 

Approval process for ''large prescribod fires" (those with potential to create significant smoke impacts beyond tho immediate firo area) 

Land managers responsible for gathering and entering pre-bum site data into smoke management 

reporting system 

Land managers screen, pre-authorize/pro-approve and prioritize 

pre-approvals to Smoke Management Section via Forest Service/DNR 

Smoke Management Section approves or disapproves each burn 

Burners/land managers "whose total planned burn projects in a year are 

greater than 100 tons of PM1 0 emissions" must submit written 

Department of Environmental Quality's Air Quality Division "by January 31 every third yearn; reports 

must "include documentation of ... !ong~term bum estimates for the nerl three years, including the 

location, burn area or pile volume, vegetation type, and type of burn f-or each planned bum project 

Bums projected to generate ~ 2 tons/PM1 0 per day (classified as "SMP-11") must be registered with 

Air Duality Division at least 2 weeks prior to ignition 

Public notification required at least 2 days prior to ignition 

notification to Air Duality Division 1 hour prior to ignition for SMP-l burns and by 10 A.M. on business day prior to ignition for SMP-11 burns 

authorities" prior to ignition 
114 


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Prescribed Fir!! PolirT Barriers and Opportunities: A Divr;rsity of Challenges and Stratr.gics Across the West 17 

Interviewees across all states said internal agency 

variables, such as funding, incentives, and capac .. 

ity, tended to pose larger barriers than air quality concerns. In this section we discuss the factors 

outside of air quality that prevent land management 

agencies from reaching their prescribed fire goals. 

People said inadequate funding and capacity to accomplish more prescribed fire were the 

key barriers to accomplishing more burning. Many 

people madH statements like, "My higgest barrier 

right now is funding," or "We just didn't have the 

resources." In particular, people said they lacked 

the funding needed to hire qualified staff to prepare 

for, plan, and conduct the burns. As one person 

summarized, "!\takes a lot of work to go from planning and doing the NEPA to implementation. We're 

pretty limited as far as the number of personnel 

we have." One person arlded that they often focus 

their limited budgets on mechanical thinning and 

explained, "Mechanical work is expensive. So, if 

we're spending our nwney on mechanicat then we 

don't have money to do the final treatments of doing 

burning on landscape. And, so, the constant pnsh 

for new mechanical acres then causes a backlog in 

prescribed fires." Forest Service interviewees across 

regions felt that the size of the fire suppression 

budget as proportion of overall agency budgets restricts the amount of burning that can occnr. BLM 

interviewees stated that to plan at landscape scales, 

units would require more stable funding. Burners 

with tho BLM in states without sage grouse populations said their ability to burn had been limited 

particularly in recent years, because the agency at 

the national level had reallocated budgets to states 

with sage grouse. People said decreased state funding for DEQs also limits regulators' their ability to 

observe on burns or interact with land managers, 

which, as we note below, is important to finding 

opportunities to increasing burning. 
115 


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18 Prescribed Fire Policy Barriers and Opportunities: A Diversity of Challenges and Strategies Acmss the West 

Lack of sufficient qualified staff to conduct burns 

was a key capacity limitation. 

o Capacity to burn is limited when burn windows 

coincide with wildfire season. Across agencies 

and states. individuals consistently said when 

wildfires are burning, their qualiiled person~ 

nelleave local units to work on wildland fires. 

Sometimes when the nation is at a preparedness 

level four or five, people said it is too difficult 

to request fire personnel to work on prescribed 

fire. One person explained, "One of our big strategic issues is of course when we need to burn 

in the summer, everybody's fighting wildfire ... 

We just don't have people around to burn. I got 

certified as a helicopter manager because when 

I needed to burn in the summer, everybody was 

gone, doing suppression, and iLl could manage 

the helicopter, we could burn." One interviewee 

said that they sometimes can get burning done 

with severity resources (i.e. people relocated to 

an area in preparation for wildland firefighting), 

but this is challenging because those personnel 

might be called onto a fire at any moment. People said the fact that wildfire seasons arc getting 

longer has exacerbated this problem. 

o Capacity to burn can be limited outside of wildfire season due to loss of seasonal staff, trainings, and other demands on staff time, Often 

land managers want to burn in the off-season 

when they no longer have seasonal employees 

to implement burns. One person explained, 

"just as burn season is gearing up, we lose most 

of our workforce. If that didn't happen, I think 

we would be in a very different position to do 

landscape-scale burning." In another state someone said, "One of the biggest restrictions is just 

funding in general. And then, because a lot of 

our firefighters are more of our operational staff, 

or more on a seasonal basis, a lot of times they'd 

be committed to other projects ... committed to 

some seeding [elsewhere/ or committed to doing 

some fencing. And so, then ... when the burn 

window does open up, we don't have the capacity to complete the objectives, because we dou't 

have the bodies." A few interviewees said that 

trainings and leave during the holiday season 

also limit the availability of personnel during 

key burn windows, especially in the Southwest. 

o Some pointed to the challenge of hiring and 

training qualified burners and "fire adapted" 

line officers. People said the professionalization of fire personnel has limited the nnmber of 

people who are available to staff burns. Some 

interviewees felt that there is a significant challenge in hiring personnel and having the right 

person in the right position in order to implement prescribed burn programs. One ELM inter~ 

viewee said, "It's very challenging to hire fuel 

spccialist(s) at the GS9 level . . . [The] field offices are competing with the Forest Service and 

with [the state forestry agency] for the same personnel. [Those] agencies are often hiring at higher grades .... My first challenge is personnelhaving the right person and the right position, 

in order to implement these prescribed fires." A 

Forest Service interviewee pointed out that there 

was a need, not just for people qualified to conduct a burn, but for line officers who understood 

fire, explaining a need for "actively finding and 

developing fire adapted line officers. And, that 

doesn't mean that they had a lot of fire experience, but that they have a lot of fire knowledge 

and have people that they can work with and 

trust to build that knowledge and continue to 

be able to do fire." One state forestry interviewee 

shared that their agency "does not hire foresters 

nor do we have a training program for foresters 

to be equipped to conduct prescribed burning on 

the landscape," In multiple states, we heard that 

if the state land board or forestry division does 

not support prescribed fire, this can limit federal 

burners' ability to burn, because it becomes more 

difficult to share resources, coordinate communication, or work across jurisdictions. 

People problems sharing resources across 

units due to lack of flexibility associated with 

budget requirements and limitations on travel. 

Oml person told us t hal in the past year they had 

observed that seasonal fire personnel on a particular forest were inactive, but were not being shared 

with other forests. When we asked why they said, 

"I don't know if it's a cultural thing, I don't know 

if there is actual legal barriers, or the budgets, 
116 


36422.072

Prt:,'>'CTibcil Fire Polir:y Borriers and Opportunities: A Divcrsit_v of Chalfengcs and S'tratogiAs Across the West 19 

or whatever it is, There has to be some n1asorL I 

know when I talked with people in the past, it's 

ultimately they have people that they need to give 

paychecks to, There is a fear of if they start movaround like that, they will lose their budgets, 

lose their people, They'lllose the ability to 

pay salaries!' Another person indicated that when 

burn windows fall at the end of the !\seal year, this 

can be challenging because of the avail a hility of accessing funding as the !\seal year ends and begins, 

Limitations on travel also have affected the ability 

to find capacity, according to several interviewees. 

People said entering into agreements to share re .. 

sources is a persistent challenge, and that there is a 

need for more knowledge offnnding mechanisms, 

streamlined legal advice ahout their nse, and more 

staff capacity to administer agreements, Many noteel that they have to combine the resources of multiple units or agencies to conduct burns, and UlC)St 

highlighted the challenges associated wilh 

One person explained this in detail saying, "We often reach out to our neighboring 

agencies for assistance with resourcos and staffing. 

And that's all facilitated through agreements that 

we have, both with our state and other federal partners, and that process of getting those agreements 

in is often cumbersome, Some of the [authori1 think are not clearly undorstood, 

[are] differences of opinion between indi;,,i;:!;,;,,;;i! 

grants and agreement specialists, or different !Lti''l" 

yers, but there isn't even agree1nent from one :n:;i~i!•.::n 

to another [about] how things are being interl''''''t;:;.;:L 

Or when lhe VVashingtou office, when thei.:r 

puts together agreements, thBy may do sommill:dr.Li~! 

that our staff hnro says we can't do. And so, tfn:•lrf.(:; 

a lot of inconsistency or different interpre1::;i:km:qi 

of how law is applied to these agreements'''"""'' 

authorities thal facilitate these agreements 

see tbat as another big regulatory barrier that ,,,,.;,,., 

for us to be able to move forward and furth ;·:: ut:' 

lizo proscribed fire as a management tooL" Tc: g.l:i.;:!r:"· 

resources, often people have in place 1nany! iF·;::n· 

ments with partner agencies. For instance, a E 

Service Regional Off\ce might have two agree; ,;,o; n!;; 

with a corresponding National Park Service 'i' ni.t···· 

often one for outgoing and one for incoming ;j;;r;.ri.;•;, 

each only lasting five years and requiring tn:;;::kLo\~, 

and reporting. 

A consistent theme was the need to find ways to facilitate more nimble resoun:e sharing, particularly 

among federal agencies. One person commented, 

"We try to partner, whether it's with the Forest Service, Fish and Wildlife, [National Park Service], [or 

Bureau of Indian Affairs], and we're trying to increase the size oft he burn-do cross boundary type 

work. There's no good way to move money bctwGon 

the federal for this, I\ would really help, 

because a lot at least in [this state], the Forest Service is the ones with hot shot crews and the 

belicopters, We want to do larger landscape type 

burns, and want to use tbeir helicopter, They're 

more than happy to work with ns on that, but it 

is a nightmare to try and pay for that helicopter 

, , We have to be ahle to move money between 

the agencies, just like in a wildfire, we all charge 

to the same code, Why doesn't that happen on a 

proscribed fire'! It's a huge hindrance," Staff frequently said things such as, "Tbero has to be a way 

that we can exchange money between the agencies 

to get! hese larger landscape burns done," Another 

person said finding a way to use something akin to 

the funding system in plac<l during wildland fire to 

order and pay for resources from otber federal agencies would be "the single biggest breakthrough" she 

could imagine that v.rould help the federal agencies 

get more llre on the ground. 
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20 Prescribed Fire Policy Barriers and Opportunities: A Diversity of Challenges and Strategies Across the West 

Interviewees said there are limited incentives to 

burn, making leadership a critical component of 

successful programs. Federal agency employees 

in particular said burn programs rely on the com· 

mitment of agency leadership and fire management 

officers (FMOs). As one person explained, "I really 

don't think there's a lot of incentive within the organization to do prescribed fire. I think the incentive 

con1es from the agency administrator and burn boss 

passion for doing what's right on the landscape." 

Interviewt~es said when line officers and FMOs exhibit initiative and passion for burning, they often find creative ways to rnaintain and build their 

programs. One interviewee also reflected that local 

line officers or fire personnel can create a culture 

supportive of prescribed burning on their units, 

As they described their forest staff, this person explained, "They have a great deal of enthusiasm and 

understanding about why this work is important, 

and how they can use prescribed fires in the future 

to make good use of wildfire opportunities. There's 

a lot of focus on being strategic with the use of pre· 

scribed fire, and then also with the use of wildfire, 

and there's a huge amount of support from the regional leadership all tbe way down to get there. I 

think the leadership plays a huge role in that." 

People said agency history, culture, and professional expertise can all influence prescribed fire 

programs, Besides the need for clear and active 

support of senior leadership for prescribed fire, 

people noted that having a culture or history of 

focusing on suppression can affect an agency's 

activities, Ono BLM employee explained that the 

agency has rnorc experionce, history, and personnel 

trained for suppression, creating sorne bias towards 

suppression and less expertise in prescribed fire. A 

Forest Service employee noted, "A key part is it's a 

cultural thing. I think [from] a lot of places [where] 

we gel our fire folks. they come from the suppression background, so suppression is what they know 

.... They may not be completely comfortable with 

prescribed fire." 

The structure of agency performance measures 

creates weak incentives to use prescribed fire. 

Setting fuels targets (i.e. acres on which fuel loads 

have been reduced by a certain amount) can ere· 

ale incentives for land management agencies to 

increase prescribed fire usc, However, rnechanical 

treatments (i.e. removal offuel through mechanical 

thinning) can be a more predictable way to meet 

fuels targets with less associated risk, both to the 

public and to agency staff who need to implement 

projects and meet targets. As one person said, "[M] 

echanical treatments typically have wide open windows ... [they] can happen 10 months, 11 months of 

the year, versus prescribed fire on a specific piece 

of ground. You n1ay only have a few days here and 

there ... to put that [prescribed fire] project on the 

ground." Others noted that the timber target (i.e. 

volume of board feot sold) is more challenging to 

meet than fuels targets, and that timber targets have 

gone up for the Forest Service in recent vears. Me~ 

chanica! thinning can help managers achieve both 

targets, while prescribed fire only contributes to the 

fncls target. Several Forest Service personnel noted 

that it is not difficult to meet fuels targets, particularly because they can count wildland fire acres 

that burn for resource benefit towards their targets, 

leading to relatively more emphasis on meeting 

timber targets (however, this bas changed as of FY 

18; regions and forests now only count prescribed 

fire and non-fire treatments towards their targets, 

although acres treated through natural ignitions 

that burn for resource benefit are still counted at 

the national level). A BLM employee raised another 

dynamic around increasing prescribed burning, explaining, "I don't want them pushing getting prescribed fire work done to meet our target, because 

once we start doing that, then we can end up putting fire on the ground when we shouldn't be." 

lntHrviewees across all states also believed risk 

aversion was an important factor in willingness to 

burn. At the local level this tended to re!lect concerns about personal liability in case of an escaped 

fire. At tbe bigber level it tendeo to reflect political considerations. One interviewee explained: "Il 

gets to that risk aversion component with our line 

officers or even our burn bosses. And I would say 

with the burn bosses ... it probably gets more back 

into those liability questions, tort claims, and the 

potential consequences if there's an escape that's 

created some risk aversion with our implcmenters 

for sure. I think at the agency arlministrator level, 

it's probably more the social/political components 

that create or contribute toward lhat risk aversion." 
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Prescribed Po!icv Barriers and Opporf11nilies: Jl Diversity of Challenges and Strategies .t'\crass the West 21 

• At the local level, interviewees felt that the 

liability and career risk associated with prescribed fire is a deterrent from being more 

proactive with fire, Some burners, especially 

with the Forest Service, said they wore not al· 

ways sure the would support them in 

case of un others felt confident 

that they have legal protection from the 

as long as they acted within the scope of 

dnties and parameters of their burn plans, 

Some said they woro encouraged to holcl privatH 

insurance; others said this was not necessary. 

Another challenge may rest with the different 

liability laws across states; as onB interviewee 

stated "Anytime you do prescribed fire, differ· 

ent states have different liability laws, Some are 

, Some arc limited liability or simple 

uu:~u:4ui1ce . , .. there's gross negligence, simple 

and strict liability," Several people 

noted that because the incentives to burn are 

few and hurdles to burning are Inany, if a line 

officer or FMO is n1ore risk-averse, prescribed 

fire activities will be minimal on that unit. 

• Among high-level decision makers, political risk 

aversion and other agency practices can pose 

major harriers to putting lire on the landscape, 

If an elected official does not support prescribed 

fire, this can significantly limit burning, even on 

federal lands, One interviewee in Washington 

said, "[The] personalily ofthe person that's talking to tho burner, the parson signing the ponnit, 

all tho way up to the Commissioner of Public 

Lands, who's an elected official , , , if the elected 

ofllcial is extremely risk-avorse, that pretty much 

shuts down burning. If [that person] is very pro· 

active about forest health, we can bave a little 

hit of risk, and maybe an intrusion and learn 

fron1 it." In Colorado, one person explained that 

lhcre have been limitations on their prescribed 

fire programs statewide duo to moratoriums on 

burning after the escaped Lower Nnrth Fork 

prescribed l1re and during times when fires are 

active on the Front Range, oven whun burning 

conditions may be excellent in other parts of the 

state, Duo to several escaped burns in tho early 

2000s, the BLM put in place a system of checks 

and balances that make it a more lengthy and 

difficult process to implement prescribed burns. 

According to BLM interviewee, this process 

still exists and is in need of updating in light of 

improved training and practice. 
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22 Prescribed Fire Policy Barriers and Opportunities: A DivN.~ity of Clwllenges and Strategies Across the West 

ground 

Limited burn windows, coupled with the chal· 

lenges of getting adequate capacity during those 

windows, are a significant barrier in some places. 

Even when the conditions meet the prescription, 

burn windows often coincide with other considerations: a high visibility fire elsewhere, a weekend 

with a local festival, or a time when personnel are 

not available. In Arizona, one interviewee said that 

drought conditions meant that fuels were often too 

dry to burn (i.e. locations were not within prescrip· 

lions for prescribed fire). In high elevation areas, we 

heard that burn ·windows are short, because fuels 

can be under snow or too moist, and often carne at 

the height of wildland fire season, making it dif· 

ficult to get capacity to burn. 

Other landscape conditions, like fuel types and 

topography, can create challenges for increased 

prescribed burning. Discussing fuel loads, one interviewee said, "It took a long time to get into this 

problem, and it's probably going to take quite a long 

time to get out of it. I mean, we·'ve been suppressing 

wildfire for over 100 ycars, and it's led to a larger 

fuel buildup." Many BLM interviewees discussed 

invasive cheatgrass as a prorninent barrier, as the 

presence of cheatgrass makes use of prescribed fire 

particularly challenging, providing additional incentive to rely on 1nechanical treatments. A Forest 

Service employee also described the issue, saying, 

"Cheatgrass, of course [it's a] huge limit to prescribed fire .. , We're actually buying mechanical 

equipment b8cause we know we can't pul fire on 

the ground." Some places said their steep topography made burning difficult, while others said topography that facilitates inversions into populated 

areas makes it difficult to manage potential smoke 

impacts. 

Species conservation requirements in some locaw 

lions can conflict with application of prescribed 

fire. BLM interviewees all agreed that a major factor impeding the agency's ability to implement prescribed burn programs are the restrictions put into 

place to protect sage grouse. Another example is 

spotted owl habitat protection in western Oregon, 

which impacts burning ability, and is further exacerbated by fragmented land ownership patterns, 

creating, as one interviewee described, "layer(s) of 

Swiss cheese on the [land management] map. And 

[then] you're just trying to burn all the little pieces 

in-betwecn that happen to be mid-slope or down 

in the creek, [which is] not ideaL" These variables 

around threatened and endangered species habitat 

also can interact with other considerations. As one 

person said, "I think [it's] all the different regulations on the landscape from threatened and endangered species lo just . . trying to find that perfect 

time where you're in prescription, the weather's 

right because you're in prescription, you're in the 

right place at the right lime 1 so the owls and the 

bugs are happy and the salamanders are happy , , . 

.And then also I think third on the list is the smoke 

management approvaL" 

A few of interviewees indicated that getting 

through the NEPA process creates a barrier to ac· 

complishing more prescribed fire, Some suggested 

that the federal agencies find greater opportunities 

to undertake project planning and NEPA analysis 

jointly. One person explained, "!think we should 

be looking at being able to share, do NEPA jointly 

and have the Forest Service take the lead and actually work on a landscape scale that includes all 

federal ownerships. And then we can maybe move 

through that process faster, and actually get more 

fire on the landscape on those fringe areas where 

we could do joint projects." A couple people expressed a desire for less NEPA requirements, One 

person said it was not the law that was the problem, 

as much as the details of decisions made through 

the NEPA process by interdisciplinary teams without a fire ecologist on staff; in these cases, their 

plans did not adequately anticipate or support prescribed fire. 
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Prescribed Fire Policy lJartinrs and Opportunities: A Diversity of Challenges and Strategies .Across the West 23 

Most interviewees said that they were focused on 

opportunities to grow prescribed fire programs 

through addressing capacity and resource limitations. People in most states said air quality regulation was not their biggest challenge and pointed to 

the importance of tho strategies they have in place 

that allow them to work well with air quality regulators, The Bxception ·was in Oregon and \IVashing~ 

ton where people said additional work is needed 

to find agreement on air quality regulations and 

space to increase burning with state agencies. In 

this section we discuss the strategies interviewees 

said the~/ were using to maintain and increusc their 

uso of prescribed fire (see also Table 2, page 29). 

Increased collaboration among all interested parlies can be crucial to finding creative solutions to 

accomplish more prcs(:ribed fire, For instance, a 

creative is in place now in California, 

called tho MOU Partnership, which is a voluntary group that involves regulators, C.t\LFIRE~ 

federal land managers, and NGO partners. The 

group is focused on improving understanding of 

barriers to proscribed fire and opportunities. Working groups within this partnership arc examining 

why burning does not occur on available hurn days, 

and whether this is due to weather, lack of capacity, poor planning. or other variables. An agency 

staff member in another state explained the need 

for increased agency collaboration, saying, "it 

wouldn't hurt for us to have a little more collaboration with other agencies as far as trying to get fire 

on the ground .. , . We probably don't work witb 

other agencies as much as wo probably should , .. 

. We could probably work a little bit together to do 

more landscape typn projects instead of we do our 

and the [other land management agency] 

tbeir projects." These types of partnership 

also allow groups to find creative opportunities for 

resource sharing. Such efforts to foster more prescribed burning have benefits beyond prescribed 

fire, One Forost Service interviewee explained this, 

stating, "hnr:ause it's the working relationships dnrthe prescribed fire season that jumps over into 

suppression season, and you already know each 

other, and snpprBssion goes easily because of havthose relationships in fire and fuel management 
121 


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24 Prescribed Fire Policy Barriers ond Opportunities: A Diversity of Challenges and Strategies Across the West 

Coordination among burners and between air 

quality regulators and land managers is essential 

to managing competition in airsheds and capital· 

izing on opportunities for burners with difficult 

burn windows and prescriptions. One example is 

tho Montana-Idaho Airshed Group, which is run by 

and for major burners (federal and stale land managers, and large private landowners) to coordinate 

burning activities and streainline communication 

with DEQ, The group has a system, something that 

people in several other states said they wanted, for 

inputting and tracking all burn requests online 

(provided by 1\ir Sciences, Inc.). To avoid triggering air quality concerns, the group's coordinator, 

staffed as a rotating position among the burners, 

approves all burn requests, and commtmicates on 

behalf of the burners to DEQ, so that individual 

burn bosses do not have to. One person explained, 

"!think that smoke management is a genuine challenge. I think thai we can work with what we have, 

which has been built by burners and has been iterated by burners over the last 30 years to be as unobtrusive a snwke management approval process) 

as we can figure out how to build [our programs]," 

Burners and regulators alike in Montana pointed 

to the fact that regulation in the state leaves some 

flexibility, which is valuable for finding creative 

solutions and promoting comrnunication. As we 

discuss more below, other states also have air quality liaisons or meetings throughout the year to coordinate among burners, 

Dedicated positions and processes, particularly to 

navigate the intersection between prescribed fire 

and air quality, to bridge across land management 

agencies, and with air regulatory agencies, are es~ 

sential. Interviewees said that open communication 

and trust are essential to understanding each other's concerns and finding opportunities to improve 

practice. As one person said, "I find that for our 

federal partners and for me, working with private 

landowners, having a strong relationship with our 

air quality districts, like a personal relationship, 

has been so important to getting projects done." The 

Montana/Idaho Airshed Group plays this bridging 

role. In most states today, the Forest Service has a 

dedicated liaison that works directly with air quality managers to find opportunities to burn and track 

multiple planm1d burns in airsheds, The first such 

position was in Arizona, where for years it was cofunded by the DEQ and Forest Service, which now 

funds the position entirely from the National Forest 

System budget; people credited this model for being 

essential to supporting effective burn programs. On 

the matter oftrust, one regulator said, "When you're 

talking about the consequences of a decision being 

health consequences, if you don't trust that person or think that person might not be forthcoming 

with the amount of information that you may need 

to make a good decision, then we have to default 

back to a more conservalive decision." This person 

explained that FMOs who proactively communicate 

within their agency and with county and regulatory partners often get their burns approved with 

more success than those who do not embrace communication. 

People also emphasized the importance of relationships among land management agencies, at 

both the state and federal levels, One person gave 

the following example: "Those working under the 

FMO are very integrated and [on a] first-name-basis 

with their [state agency] counterparts on the fire 

side. And there's a good rapport and cooperation 

between the supervisor and the unit chief .... In 

the areas where we've had the biggest challenge, 

[that] is where either one or both of those relationships are not as strong. So I think where there's 

a wUl there's a way, and when there's not a will, 

there's not an incentive to find a way. And it very 

much does come down to those, in many cases, 

those relationships." In several states, people said 

partnerships among agencies allow them to find 

greater opportunities to burn, often by finding opportunities to share resources. 

Communication, trust, and creative public out~ 

reach also are essential among agencies and the 

broader public. One person noted the importance of 

having interagency communication strategies and 

using multiple partners to communicate about fire 

with the public, both to build a united voice and 

use partners that have established trust with different stakeholder groups. Another person explained, 

"These [agencies] entities are basically working 

with ... limited resources and 110% workload usu-
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Prescribed Fire Polic.v Barriers and Opportunities: A Diversity of Challenges and Strategies Across the West 25 

ally. So coordinating between tbc agencies, if it's 

not mandated typically falls of£ the plate ... that's 

I think where a lot of the issues end up happening 

.. that [lack of] communication ... that translates 

into really mixed messages to the public. If people 

aren't saying what the issues are, or why we're using prescribed fire, it creates a lot of communication 

barriers." 

People have in place some options to share resources, although these are limited and vary in 

their use by state. Interviewees stated that there 

are ways around agreement issues such as "if you 

just need an engine for a day or two, most folks are 

morn than willing to say, 'Yeah, I'll send my engine 

over, you send yours over, we'll just kind of do a 

handshake;"' however, people said this was more 

challenging for high-cost items. In Arizona, the 

land management agencies are using a Joint Powers Master Agreement to support resource sharing 

within the state for prescribed fire. Other regional 

and state offices said they are working with units to 

coordinate agreements to create efficiencies. Other 

people said they were utilizing the Good Neighbor Authority or "Wyden Authority" to share resources with the states and indicated those wore 

useful policy tools." In Utah, tho state established 

tho Watershed Restoration Initiative (WRI) in the 

Conservation and Development Division. VVith a focus on wildlife habitat, WRI brings together funds 

and proposals from state and federal agencies as 

well as non-prolll organizations to fund priority 

habitat restoration projects. Interviewees indicated that this facilitates proscribed flre projects and 

other fuels treatments by leveraging funding from 

multiple entities that has the flexibility to be used 

across diverse land ownerships and funding years. 

The program is one thing that helps provide "my 

fuel managers a lot more room to be strategic and 

to jutnp on when a window opens." 

Improved monitoring data and smoke modeling 

effOrts within the land management agencies can 

provide information that will support increased 

burning. As one person explained about their DEQ 

partners, "They've recognized that some of [their 

air quality requirements] really don't align with 

meeting the goals of protecting public health. We've 

got some of our meteorologists that work both for 

the BLM and for the Forest Service ... we're deploying them when we do prescribed fire. And we're doing much more intensive monitoring of atmosphere 

conditions. And we're starting to question some of 

the models that have been used in tho past to help 

deterrnine what the ventilation index is on any 

given day, and therefore, how much we can burn." 

In both California and Utah, as well, people told us 

that air quality regulators and land managers are 

working together to identify opportunities to burn 

more at higher elevations, even when air quality 

in populated areas is poor. Doing so will require 

improved monitoring and modeling of smoke and 

could present opportunities for additional burning. 

In a few places, people said that individual regulators within a state sometimes would allow for different levels of burning; improved data from land 

managers and transparency in decision-making 

from air quality regulators both would be useful 

for making decisions more consistent and evidencebased. In some states, interviewees noted that their 

current or anticipated hiring of a dedicated meteorologist position in the state supports their increasing reliance on meteorology to inform smoke management in the state. 

Several interviewees said that the land management agencies could incorporate air quality and 

human health considerations more effectively into 

their ethos. One person, said, for example "I still 

think land rnanagement in the Forest Service is still 

really lacking air quality as a resource as something this is part of our responsibility. It's vastly improved ... [but] it's still lacking .... I think ... until we 

do that, it looks to the regulators much like we're 

not taking this very seriously, as if air quality is not 

a part of the decision-making system." A suggestion was that air quality considerations and cmnmunications training bo 1nore om bedded within 

the cadre of personnel conducting prescribed llre . 

.Some suggested the need for dedicated prescribed 

fire teams for capacity reasons, and a couple people suggested that those teams could be especially 

trained in communicating around smoke impacts 

to improve practice. 
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26 Prescribed Fire Policy Bauicrs and Opportunities: A Diversity of Glwl!tm1-5es and Stmtogif's Ac.ro:.;s llu: Wvst 

Our interviews did not yield clear indications that 

policy change is needed at the federal level at this 

time, as most interviewees said there were op~ 

portunities to increase the use of preseribed fire 

that would nol require changes to law. However, 

realizing these opportunities will require creative 

problem-solving, and a conunensurate input of 

staff limo, funding and capacity, and leadership 

initiative. Two areas where policy change may be 

warranted are in smoke management programs in 

Oregon and \Vashington, where such revisions are 

underway, and potentially to facilitate easier 

proaches to interagency resource sharing. In 

dition, changes to incentive structures within the 

Forest Service may be warranted, and it is worth 

exploring possible internal practices that could alleviate current capacity li.n1itations. \'Ve offer our 

targeted suggestions basr:d on this phase of our research below, 

Coordination among burners and between air 

quality regulators and land managers is critical 

to maintaining and increasing the amount of pre~ 

scribed burning that occurs. Our interviews incHcalc that thoro is no "silver bullet" to increasing 

tho application of prescribed fire, and that problemsolving requires local solutions that can only be 

identified through interagency coordination and 

problmn examination. VVe recommend other states 

consider whether they would benefit from a statewide airshed group or partnerships following the 

models of Montana/Idaho Airshed Group and the 

California Fire MOU Partnership, or whether their 

existing partnerships and forums already serve this 

role. Other suggestions include the following: 

• Ensure liaisons or smoke coordinator 

positions are in and stuffed in all regions, 

with additional state-level positlons as needed. 

• Support state-level groups that promote communication among burners to manage competition within airshcds; these groups benefit from 

online v!atforms for tracking burn requests and 

related information. 

• Improve measurernont of smoke generation and 

dispersion to allow partners to find additional 

space to burn while navigating air quality concerns; targeted investment in necessary mea~ 

surement techniques, equipment, and trained 

staff/meteorologists would be valuable. 
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Pwsr.ribed Fire Policy Barriers and Opportunities: A Diversity of Challenges and Strategies Across the "1lest 27 

The Forest Service, and the BLM to a lesser extent, 

would benefit from improved internal incentives 

to encourage more burning. Opportunities may 

include: 

• Ensuring that leaders prioritize proscribed fire at 

all levels oft he agency. One example come;· from 

Utah, where several forest supervisors havo, ac~ 

cording to one interviewee, "set a million acre 

challenge in the next five years to help move 

the [prescribed fire] program;" the challenge is 

endorsed by the Governor in order to "help move 

tho culture into more action on the ground." 

• Examining targets to identify additional pathways to incentivize prescribed burning. For instance, there may be opportunities to provide 

targets at the national and regional levels that 

can only be met through prescribed fire, as compared to current fuels targets that can be met 

through wildland fire acres-burned or mechani· 

cal removal of fuels. 

• Creating rewards or additional incentives for 

places that have the interest and a plan in place 

to increase burning. Options include dedicating funding to prescribed fire, which could bo 

allocated by Regions or by Congress; recipients 

could be the agencies or collaborative efforts 

among community partners working together 

with federal land managers. 

• Providing training to key fire management per~ 

sonnel and line officers about navigating personal liability concerns so that they are comfortable 

responding to positive incentives to burn more. 

In a time of limited capacity and declining federal 

budgets, the federal agencies need more efficient 

avenues for sharing resources. Recommendations 

include: 

• Providing cont:istenl guidance on agreement 

mechanisms and associated requirements and 

developing additional personnel with tho expertise to enter into and manage resource shar~ 

ing agreements effectively. One option may be 

to reorganize contracts and agreements staff so 

that expertise is more centralized and advice- is 

more consistent 

• Identifying a mechanism for sharing resources 

and dollars for prescribed fire activities that limits requirernents for agreements. One possibility is to identify whether the Forest Service or 

BLM could have a budget line or authorities that 

would allow them to order resources front multiple agencies more eftkiently, with less need for 

interagency agreements. As all resources are the 

property of the federal government, many people 

said they wanted to see easier ways to share resources, while still maintaining accountability. 

To overcome persistent «;apacity challenges, per~ 

sonnel must be available at critical times to con~ 

duct prescribed fires. We have three suggestions 

for consideration: 

• Dedicated prescribed fire crews could be created, either within or across agencies, and uti~ 

lized more extensively. These crews would not 

be available for wildland firefighting, except 

perhaps in special circumstances, and would be 

trained in the unique smoke managOinent and 

outreach skills that are needed in conjunction 

with an activo prescribed fire program. 

• Fire personnel could be organi"ed such that 

they are more easily nwved from one forest to 

the next, depending on the need for to conduct 

priority burns. We suggest actively seeking ways 

to utilize fire personnel more nimbly throughout 

the year. For instance, one Forest Service region 

is exploring how to put i udividuals with prescribed burns qualifications into the Resource 

Ordering and Status System (ROSS)13 to facilitate available personnel staff being shared across 

forests. 

• Agencies could find ways to support greater involvement of non-federal personnel (The Nature 

Conservancy, local fire departments. etc.) on prescribed burns. 

There are opportunities to improve planning to 

support increased application of prescribed fire, 

We suggest requiring that teams planning fuels reduction and forest restoration projects ensure they 

have members from both resource management and 

fire management. When this does not occur, proj-
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28 Prescribed Fire Policy Barriers and Opportunities: i\ Diversity of Challenges and Strategies Across the West 

ects often fail to incorporato plans and proscriptions for prescribed fire effectively. Regional and 

state prograrn leads also should consider where 

there are 

ning to 

personnel arc in plnco to on vdndows in aroa.c> that aro high priority for fuels reduction. 

Changes to air quality law and associated regulalions at the federal love! are not a priority, according to our interviewees~ at this tinm. Most people 

said this was not their biggest barrier, and everyone 

suggested there was room for irnprovernent related 

to internal agency dynamics, incentives, 

and capacity is In most states, 

factors should bo addressed before 

on air regulation; the exceptions 

wore Oregon and where more collaboration and comnlunicnUon is needed at thH state 

level to inentify opportunities to accomplisb more 

firo and relatively more conservative air 

"'"''"'""·wv processes. People also said more 

strict PM2.5 standards will likely pose additional 

wanm''"' compared to the curront state of practhM this issue will need ongoing attention. 

Among the major challenges moving forward will 

be finding opportunities to increase !he spatial 

scale of burning. Landscape-level burning will 

generally require: 

• Creator resource sharing both between agencies 

and other partnering organizations; 

• Bettor of private landowners, which 

that the states adconcerns private burners; and. 

• ldeniifying ways, given the noocl for such burns 

to last multiple days, to create flexibility wii h 

regard to air quality regulation. 
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Prcscrihed Fim Policy Barriers and Opportunities: A Diversity of Challenges and Strategies Across tho West 29 

Table 2 State-by-State Summary of Primary Challenges and Opportunities 

Primary reported barriers and 

challenges 

n-:-Many air-quality sensitive populations 

I • Limited personnel capacity; resources on 

1 wildland fire 

~ • Utilizing agreement/funding mechanisms 

I § • BLM funding redirected to states with sage 

.~ I grouse 1 <i: • Non-attainment for PM 2.5 around Phoenix 

and Tucson 

•Intermixed landscape across private/federal/ 

state lands 

• Non~attainment areas for PM2.5 and ozone 

in places with high population (e.g, San 

I 

Joaquin Valley) 

• Competition in airsheds in terms of 

emissions from woodstoves, farm industry, 

manufacturing, cars, etc. 

• Qualified personnel ore limited and often 

not available due to trainings, vacations, or 

being pulled to wildland fire in other parts 

of state (year-round fire season) 

"Qualified personnel sometimes not 

available to fill BLM positions 

• Intermixed landscape across private/ 

federal/state lands 

• Lack of capacity during short burn 

windows (resources often out on wildland 

fire) 

• Short burn windows (fuels often under 

snow or too moist) 

Facilitators and opportunities 

• 4FR!' 4 is a motivator for increased 

Rx firo in the state 

• Agreements and partnerships 

across agencies and organizations 

to move resources and increase 

capacity. This includes the communities-at~risk agreement between 

BLM and State to administer private 

land projects 

• Extensive interagency communication has identified greater opportunities to burn 

• Strong communication across air 

quality and land managers 

• !nnovat!vo public outreach strategies 

• CAL FIRE increasing commitment 

to Rx fire, and partnering with USFS 

and the Nature Conservancy (TN C) 

to do more 

• Findings opportunities to better 

utilize burn days, address policy 

issues, and identify opportunities 

through MOU16 partnership 

• Creating more local and strategic 

air quality decisfons based on better 

monitoring, data, and communication 

• Potential improve Forest Service 

strategic planning to identify and 

support more opportunities 

• Committed FMOslburn bosses who 

capita!fze on available opportunitios to burn and communicate with 

regulators to maintain productive 

relationships 

•Interagency resource sharing 

• Group of stakeholders forming to 

meet annually with Air Pollution 

Control Division 

Interagency relationships for burning 

and air quality oversight 

• Joint Powers Master Agreement allows 

exchange of resources across boundaries 

outlines joint procedures/policies 

• Working groups for individual counties 

• Arizona Conservation Partnership brings 

agencies together to identify priority areas 

based on their goals and objectives 

• USFS air quality liaison with DEQ In AZ 

• Rx fire 1s council active to support burning 

• Online PlFRS (Prescribed Fire Incident 

Reporting System) to track multiple burn 

requests and facilitate permitting 

•Interagency, daily smoke coordination call 

to consider effects and feasibility of multiple 

planned burns 

• MOU between federal land managers, 

environmental organizations, Cal Fire, Rx 

fire councils, committed to common goal of 

increasing Rx fire and identifying problems 

and solutions 

• Air and Land Managers group, which meets 

twice a year to problem solve 1 

• CA and NV Smoke and Air Council 1 

•Interagency Air and Smoke Committee I dedica~ed to technical matters like monitoring 

strategtcs j 

• Three Rx fire councils active to support burn- j 

• The Air Pollution Control Division meets bien~ 

nia!ly with burners 

• CO Fire Prevention and Control reviews burn 

plans; all agencies operate under master 

agreement to share resources 

• Colorado State Forest Service are employees of Colorado state University and cannot 

conduct Rx burns; they burn piles as DNR 

employees 

• Rx fire council active to support burning 

• Annual meetings with major burners and 

regulators occurring In last two years 
127 


36422.083

30 Prescribed Fire Policy Barriers and Opportunities: A Diversity of Challenges and Strategies Across the West 

Primary reported barriers and 

challenges 

l

r Short burn windows due to weather 

conditions and complex topography 

(valleys .m. ore prone to smoke in~rusions) 

• When burning can occur, there 1s 

competition in some airsheds among 

Faeilitators and opportunities 

• Strong interagency communication 

• Burning goals based on available 

resources 

•Improved understanding of burn 

policies and how to conduct Rx fire 

I 

multiple burners • Dedicated meteorologist position i: • Lack of funding and resources to conduct • Opportunities lie in building a more 

:2; burning. robust SMP17 including more com-

, • Non-attainment areas are already at risk of munication with the public. 

I 

violating air quality standards • Potentia! opportunities to increase 

I . • BLM funding redirected to states with sage staff for burn paperwork adminisPublic communication about Rx burning education, and improve interagency 

Interagency relationships for burning 

and air quality oversight 

• Montana/Idaho Airshed Group coordinates 

burn planning across both states among 

federal, state, and private burners working 

under a MOU; group leads coordinate and 

communicate with DEO on behalf of burners 

during ventilation hotline period 

• Annual burners meeting 

grouse tration, increase resources in fie!d 

has historically bee~ limited communicat_io_n ____________________ -1 

USFS' focus on moetmg timber targets • The MT/ID Airshed group facilitates • Montana/Idaho Airshed Group coordinates 

, results in more mechanical thinning than Rx communication across major and burn planning across both states among 

I

' b. urns, especially when fuels acre ta:gets non-major burners federal, state, and private burners working 

tu until FY 18 could be met through wildland • Some burners work closely with the under a MOU; group leads coordinate and 

j fwe events airs hod group to make their needs communicate with DEO on behalf of burners 

[. 

,g, • Utilizing agreement/funding mechanisms known, which helps them get ap- during ventilation hot!ine period 

...:;;: • Non-attainment for PM 1 0 around Missoula proval during tight vvindows • Annual burners meeting 

• Public frustration about Rx fire when their • Flexible regulatory structure at the • State has agreements with BLM and FWS, 

t use of wood stoves or other activities may state level which enables them to help federal agencies 

[ be co~~trained during some seasons -----------~~---------~-duct pile burning ---------

• Limited funding and human resources, 

often due to being pulled to fire 

suppression 

~Short burn windows for broadcast burns 

• Sage grouse and cheatgrass 

considerations for BLM 

• Rx fire st!H somewhat sensitive in state due 

to Little Valley escaped Rx fire in 2016 

where homes were lost State forestry, 

which conducted the burn, hasn't done any 

burning since that fire 

strong sense that a great deal more Rx 

fire is needed 

• MOU between BLM and NDEP 

• USFS-BLM fire resource sharing 

agreement in place 

• Opportunities include increased 

outreach to the public and providing more burn trainings to increase 

capacity and skills of agency 

employees 

• 8LM and NV Division of Environmental 

Protection (NDEP) have an agreement for Rx 

burning that must be re-done every five years. 

BLM agrees to work with the state and follow 

the permitting process, and BLM agrees to 

provide NDEP the amount of pollution the 

agency produces and allows NDEP to come 

to their burns 

• The USFS in R4, specifically NV, to address 

personnel capacity issues, has an agreement 

with BLM in which USFS sets aside money in 

an account, and if they need to use the BLM, 

BLM can charge to that account and be available on a fire 

• !n process of fanning an Rx flre council 
128 


36422.084

Prescribed Fire Policy Barders and Opportunities: A Diversity of Challr:mgos and Strategies Across the West 31 

Primary reported barriers and Interagency relationships for burning 

challenges Facilitators and opportunities and air quality oversight 

• Pub!i_c opposition to smoke in so~-e ---:in. terag;-;;;y resourc~-;h-;;;~~---·An~-ual interag.en~y planning ;:;,eeting -~ 

local!ons • Returning Heroes Wildland F1re~ • USFS air quality haison with DEO in NM 

0 , • Intermixed landscape across private/ f1ghter Program • BLM and State Land Office partner in E NM '* federal/state lands • Future potential to review and up~ on cross~boundary burns 

] ~ • Limited personnel capacity; resources on date air quality regulatory process~ • Southwest Coordination Group (all federal 

wildland fire es; will be key to address processes burners) l • BLM funding redirected to states with sage for management of natural ignitions • Oil and gas partnerships in place with BLM 

to facilitate communication to shut off the oil 

lines around burns 

grol1se 

• Utilizing agreement/funding mechanisms 

• Short and unpredictable burn windows due 

to weather 

• Concern about potential far smoke 

intrusions18 into Smoke Sensitive Receptor 

Areas (SSRAs). 

• Non-attainment areas due to wood smoke 

are already at risk of violating air quality 

standards 

~, • Endangered and threatened species 

- protections limit Rx fire 

• Lower public smoke tolerance after recent 

wildfires 

• Lack of dedicated funding for burning; 

USFS prioritizing wildfires and BLM 

prioritizing sage grouse 

• Improved communication between 

DEQ and OregQn Department of 

Forestry 

• Partnerships with NGOs to burn 

(e.g. TNC, Rx Fire Council) 

• Opportunities with SMP revision to 

improve techniques, increase public 

outroach, revise terminology 

• Opportunities for greater investment (people and funding) in certain 

regions could increase Rx fire 

• Opportunities to bring forestry and 

public health experts together to 

create and revise relevant policy 

• Rx fire council active to support burning 

• BLM and Region 6 USFS partner together to 

develop supplemental interagency guidance 

for Rx burning 

• Formal and informal partnerships between 

burners augment limited agency staff for 

burns events and can facilitate sharing of 

training, technical assistance, personnel, 

equipment, and communication 

• R}( fire council active to support burning 

I • Historically, li~ited dialogue statewide 

about Rx burnmg and public health 

_;_ _ tradeoffs ---------·--·-----·---·-·--------·-------! ~Single clearing index across entire state • Flexible funding mechanisms •Interagency smoke coordinator working for 

(500 or above wi1hin 50 miles of sensitive through Watershed Restoration federal !.and management agencies and state 1· 

areas) is limiting as it doesn't allow Initiative (WRI) facilitate Rx burns forestry 

elevation at and geographic differences. • Interagency smoke coordinator • Watershed Restoration Initiative (WRI) of 

Some exceptions being allowed at 450 or increases communication Utah's Conservation and Development Dlviabove • FS working to address limited staff sian. Bnngs funds and proposals together 

-Challenges of burning cheat grass with Rx quais by improving the abi!- from state and federal agencies and nondiscourages Rx fire ity to share resources in the state profits. Multi-agency teams rank, select, and 

~Lack of staff with needed Rx fire (putting Rx personnel into Resource allocate funding to projects that all parties 

Ordering and Status System consider high priority qualifications 

~ • ~~~::~i~~p~:~~~ma~~sfu:~~~;;~~~c~xb!~~n 

to meet targets 

~Limited burn windows due to winter 

~ DEQ perception that agencies are writing 

burn plans that are overly complex 

• Perceived public aversion to smoke 

• Significantly less Rx burning being done 

than at the inception of the National Fire 

but there appears to be little interest 

in doing more b~rn1ng in the state 

(ROSS)) • MOU between a!\ burning partners conduct-

• Forest Supervisors set million-acre ing Rx burns according to the best manage ... 

challenge in next five years to move ment practice guidelines of the SMP, Includes 

the program, with support from the state, federal, and tribes as part of UT 

Governor Regional Haze SIP. The MOU group meets 

• Interagency committee working to ~~~esa~~ ~;:;~~ear to evaluate the effectiveconsider how clearing index limits 

can be adjusted to create more local 

and strategic air quality decisions 
129 


36422.085

32 Prescribed Fire Policy Barriers and Opportunities: A Diversity of Challenges and Strategies Across the West 

Primary reported barriers and Interagency relationships for burning 

challenges , ______ F_a_ci_li_ta_t_or_s_a_n_d_o_:_p_:_p_o_rt_u_ni_ti_e_s __ a_nd_a_ir_q,_u_a_Hty oversig_ht _____ , 

'l:l_·;-~k-~f capacity ---- •Interagency communication im- • BLM and Region 6 USFS partner together to 

,: • ~~~~t~ou~: windows due to weather ~ ~:~::~ ::~~~:n~d~~:~~~:~;~ot to 1o~v~~o~u~~Fn~emental interagency guidance 

I

; • Burn approvals on the day of the burn identify opportunities for Rx fire "Rx fire council active to support burning 

come too late to mobilize resources to burn •Interagency and partner resource 

I · • Topogr~phy (valleys) a~d concentrate.d sharing to burn 

I 

populations in areas Wlth smoko sensttive "Community outroach through local 

~ populations impacts burning fire departments, Rx Fire Council 

.5. • S~ate contains f~ve ~!ass 1 federal areas • Rx fire trainings build capacity 

i • Visibility protection 1n SMP restricts ~Opportunities with SMP revision: 

~ weekend burning more burn days/changing bum 

• Lack of consistency in regulatory thresholds, earlier burn approval, 

understandings between agencies and improved communication 

local and state !eve! entities 

•Technical glitches with burn requests 

online 

• Limited public acceptance of smoke and 

fire 

• Unpredictable weather and inversions 

• Non-attainment zones for PM 2.5 around 

Sheridan and Ozone around the Upper 

Green River 

grouse~re!ated restrictions for BLM 

• Strong interagency resource sharing of eq1,.1ipment to help increase 

capacity 

• Opportunities may !io in finding 

options in sage grouse habitat, and 

in creating a web-based program to 

document burns 

• DEO holds an annual smoke management 

meetmg to discuss b-urn requirements and 

provide an overview of the burn program 

• BLM has agreements with USFS and USPNS to share equipment on Rx burns 

• Land management agencies partner with 

NGOs to conduct Rx burns: Rocky Mountain 

Elk Foundation, Mule Deer Foundation, Trout 

Wildlife and Natura! 
130 


36422.086

Prescrihcd Fire Policy flarriers ond Opportunitir.s: A Divr:rsity of C'haflengr.s ond Stratogir.s Across tho West 33 

Endnotes 

1 Prescribed fire, or planned fire used to meet management 

objectives JS a t(lrm synonymous with prescribed burns, and 

planned or controlled burns or fires. ln our work we focused on 

planned in our questions, although some interviewees 

also perspectives about management of unplanned 

1gni!ions. 

2 The 11 western states 

Washmgton 01nd Wyoming, 

3 This mformation is drawn frofTl D. Braddock & Alec C, Zacaroli, 

Meet1ng Ambient Air Standards· Development of the State 

Implementation Plans, .n Tho Clean A1r Act Handbook, pp. 49-

87 (julie R. Dom1ke & Alec C. Zacaroli eds. 2016). 

Clean Air Act Handbook, 

C. Zacaro!i eds. 2016). 

5 81 Fed. Reg. 26,942, 26,946 (2016). 

6 40 CFR § 51,308(d)(1)(•)(B). 

7 40 CFR § 51.30B(d)(3). 

8 81 Fed. Reg. 26,959 (2016). 

9 40 CFR §§ 50.\(j),(k) & (m) thcocgh (c), 50.14, and 51,930. 

11 Quoted matenal ir1 th1s column is drawn from the applicable law 

indicated for the state in column 1. 

12 The "Good U.S.C § 2113a) allows 

the U.S. secretanes and lntenor to enter into 

agreements or contracts with states 

state ager'!Cies can perform 

and watershed restoration serv1ces" 

other resources on public or private land" 

and for "the r!'lduct1on of nsk from natural d1sastnr where public 

safety is threatened." 

13 https://lamit.nwcg.gov/appLcations/ROSS. 

14 "Four Forest Restmalmn ln,t~alive (www.ls.usda.gov/4fr;), 

15 Rx f1re: pres en bed f1re. 

16 MOU: Memorandum of Understanding. 

17 SMP: Smoke management plan. 

18 Smoke mtrus1on: "smoke from prescribed fire entenng a 

des1gnated area at unacceptable levels" (NWCG, 2012). 

Bibliography 

Cleaves, D.A., Martinez, J., and Haines, T.K. 2000. "Influences of 

prescnbed burn1ng activ1ty and costs in the Nattonal Forest 

System." General Techmcal Report SRS~37. Washington. DC: 

USDA Forest Service. 

Domike, J. and Zacaroli, A. C. 2016. The Clean Air Handbook. 

American Section of Environment, Energy, and 

Resources. 

Engel K.H. 2013. 'Perverse incentives: the case of wildfire smoke 

regulat10n." Ecology Law Ouarter!y 40, 623-672. 

S., and Ramey, H.G. 2006. "Managing successful 

change m the public sector." Public 

Adcn•ccW••t<oc Review 66: 168~176. 

Moseley C., and Charnley S. 2014. ·'Understanding rn1cro~ 

processes of mstitut1onalizatmn: stewardship contractmg and 

nat1onal forest management." Policy Sc1ences 47: 69-98. 

Group]. 2012. ·'Glossary 

National Wildf1re 

NIFC [National Interagency Fire Center]. 2015. "Fire Information 

StatiStiCs." Avatlablc at: https:J/www.nlfc.gov/ftre/nlo/ftrelnfo_ 

stattstics.html. Last accessed Nov. 5, 2015. 

North, M., Collin, B.M., and S. 2012. HUsing ftre to 

1ncrease the scale, benefits, and Maintenance of fuels 

treatments." Journal of Forestry 110:392-401. 

Quinn~Davidson, L., and Varner, J.M. 2012. "!mpodiments to 

prescribed f1re across landscape and manager: an 

lnternat1nnal Journal of 

Ryan, K,C., Knapp. E.E., and Varner, J.M. 2013. "Prescribed f1re 

in North Amer1can forests and woodlands: history, current 

snd challenges." Frontiers m Ecology and the 

11 (onli'1e issue 1): e15-e24. 

Schoennagel, Balck, J.K., Brenkery-Smilh, H., Dennison, 

PE. Harvey, and others. 2017. "Adapt to more wildfire 

1n western North American forests as eLm ate changes." 

Proceedings of the National Academy of Sciences 114: 4582-

4590. 

USDA and USD! [US Department o-! Agnculture and US 

Department of Interior}. 2014. 2014 Quadrennial F1re Rev1ew. 

Washington, DC: USDA and USDL 
131 


36422.087
132 


36422.088

Impact of anthropogenic climate change on wildfire 

across western US forests John T. Abatzoglou3 '

1 and A. Park Williamsb 

•ocpcmment of Geograpfly, University of !delflo, Moscow, ID 838'1'1; ilfld t>l<lmont~Doherty Eartfl Observatory, Columbia University, Palisades, NY 10964 

Ed1ted by Monica G, Turner, University of Wisconsin-Madison, Madison, WI, and approved July 2.8, 2016 (received for review May 5, 2016) 

Increased forest fire activity across the western continental United 

States (US) in recent decades has likely been enabled by a number of 

factor5, including tMe legacy of fire suppression and human settlement natural climate variability, and human-caused climate change. 

We use modeled climate projections to estimate the contribution 

of anthropogenic climate change to observed increases in eight fuel 

aridity metrics and forest fire area across the western United States. 

Anthropogenic increases in temperature and vapor pressure deficit 

significantly enhanced fuel aridity across western US forests over the 

past several decades and, during 200Q-201S, contributed to 75% 

more forested area experiencing high {>1 n") fire-season fuel aridity 

and an average of nine additional days per year of high fire potential. 

Anthropogenic climate change accounted for ..... ss% of observed increases in fuel aridity from 1979 to 2015 across westem US forests, 

highlighting both anthropogenic dimate change and natural climate 

variability as important contributors to increased wildfire potential in 

recent decades. We estimate that human-caused dimate change contributed to an additional 4.2 million ha of forest fire area during 1984-

2015, nearly doubling the forest fire area expected in its absence. 

Natural climate variability will continue to alternate between modulating and compounding anthropogenic increases in fuel aridity, but anthropogenic dim ate change has emerged as a driver of increased forest 

fire activity and should continue to do so while fuels are not limiting. 

wildfire I climate change I attnbut1on I forests 

Widespread increases in fir~ activity, including area burned 

( 1, 2), number of large fues (3 ), and fire-season length 

(4, ."i), have been documented across the western United States 

(US) and in other temperate and high-latitude ecosystems over 

the half century (6, 7). Increased fire across western 

US has coincided with climatic more conducive to wildfire 8). The strong interannual correlation 

between forest fire and firc-S(.'ason fuel aridity. as well as 

observed increases in vapor pressure deficit (VPD) (9), fire danger 

(10), and climatic water deficit (CWD) ( ll) over the past 

decades, present a compelling argument !hal clim<~tc 

change has contributed to the recent increases in fire activity. Previous studies have implicated anthropogenic climate change (ACC) 

a'i a contributor to observed and projected increases in fire activity 

globally and in the western United States (12-19), yet no studies 

have quantified the degree which ACC has contributed to obscn.:cd increases in fire in western 1JS forests. 

Changes in fire activity due to climate, and ACC therein, arc 

modulated by the co-occurrence of changes in !and management 

and human activity that inlluencc fuels, ignition, and suppression, 

The legacy of twentieth century fire suppression across western 

continental US forests contributed to increased fuel loads and fire 

potential in many locations (20, 21 ), potentially increasing the 

of area burned to climate variability and change in recent Climate influences wildfire potentia! primarily 

by modulating <~hundance in fuel-limited environments, and 

by modulating fuel midity in llammability-limitcd environments 

( l, 23, We constrain our attention to climate processes that 

promote aridity that encompass fire behavior charactcris~ 

tics of landscape ignitability, flammability, and fire spread via fuel 

desiccation in primarily flammability-limited western US forests by 

f'NAS I October 18,2016 I vol 113 I no il2 

considering eight fuel aridity metrics that have well-established 

direct interannual relationships with burned area in this region 

from monthly data for 

(i) reference potential evapotranspiration (ETo ), 

(ii) YPD, (iii) CWD, and (tv) Palmer drought severity index 

(PDSI). The other four metrics arc daily fire danger indices cal~ 

cutated for 1979-2015: (v) fire weather index (FWI) from the 

Canadian forest fire danger rating system, (vi) energy release 

component (ERC) from the US national fire danger rating w~tem, 

(vii) McArthur forest fire danger index (FFDI), and (viii) KeetchByram drought index (KBDI). These mctrics arc further dcscribcd 

in the Muterial'i and Methods and Supponing lnfonnation. Fuel 

aridity has been a dominant driver of regional and subregional 

interannual variabihty in forest fire area across the western US in 

recent decades (2, 8, 22, 25). This study capitalizes on these relationships and specifically seeks to determine the portions of the 

observed increase in fuel aridity and area burned across western 

US forests attributable to anthropogenic climate change. 

The interannual variability of all eight fuel aridity me tries averaged over the forested lands of the western US correlated significafltly (R2 = 0.57--0.76, P < 0.0001; Table Sl) with the logarithm of 

annual western US forest area burned for 1984-2015, derived from 

the Monitoring Trends in Burn Severity product for 1984-2014 and 

the Moderate Resolution Imaging Spcctroradiomctcr (MODIS) 

for 2015 (Supporling lnfomwtion). The record of standardized fuel 

aridity averaged across the eight metrics (hereafter, all-metric 

mean) accounts for 76% of the variance in the burned-area record, 

with signific.:tnt increases in both records for 1984-2015 (Fig. 1). 

Correlation between fuel aridity and forest fire area remains 

highly significant (R2 = al!~metric mean) after the 

linear-least .squares trends each time series for 

supporting the mechanistic relationship between fuel aridity 

lheauthorsdeclarenownf:>etoflnterelt. 

Thi1 article l<<l PNAS D1re~t Submts«on 

Se~Commentaryonpage 11649 

'Towhomcorrespondenteshouldbeaddrosscd.Emarl.jabatzoglou®uidahoedu 

wwwpna~.org/cg•/do•/10 1073/pnas1607171113 
133 


36422.089

AbatloglouarldWdl<ams PNAS I october18,2016 I vol.113 I no. 42 I 11771 
134 


36422.090

A 

B 

~1. r--

!2 

.!2-1 

"0 

c 

~ 0. Ithe contribution of ACC on western US forest fire area for the 

three decades (Fig. 5 and Fig. SS). ACCdrivcn increases in 

aridity are estimated to have added -4.2 minion ha (95% 

confidence: 2.7--6.5 million ha) of western US forest fire area 

during 1984-2015, similar to the combined areas of Massachusclls 

and Connecticut, accounting for nearly half of the total modeled 

burned area derived from the all-metric mean fuel aridity. Repeating this calculation for individual fuel aridity mctrics 

ACC contributions of 1.9-4.9 million ha, but most 

fuel aridity mctrics had weaker correlations with burned area 

and thus may be less appropriate proxies for attributing burned 

area. The effect of the ACC forcing on fuel aridity increased 

during this period. contributing ~5.0 (95% confidet1ce; 

times more burned area in 2000-2015 than in 1984-1999 (Fig 

During 2000-2015. the ACC-forccd burned area 

the burned area expected in the absence of 

A more conservative method that uses the 

detrcndcd records of burned area and fuel 

11771 www.pnasorg/cgrldol/101073/pnasl&Ol171113 

reduction in the proportion of total burned 

SS). 

assumes that anthropogenic increases 

in fuel aridity arc to the wildfire extent that would have 

arisen from natural climate variability during 1984--2015. Because 

the influence of fuel aridity on burned area is exponential, the 

influence or a ACC forcing is in an already arid fire 

season such as (Fig. SA and Fig. Anthropogenic in· 

creases in fuel aridity arc expected to continue to have their most 

prominent impacts when superimposed on naturally occurring 

extreme climate anomalies. Although numerous studies have 

projected changes in burned area over the twenty-first century due 

to ACC, we arc unaware of other studies that have attempted to 

quantify the contribution of ACC to recent forested burned area 

over the western United States. The ncar doubling of forested 

burned area we attribute to ACC exceeds changes in burned area 

by some modeling efforts to occur by the mid-twentycentury (29, 30), but is proportionally consistent with midtwenty-first century increases in burned area projected by other 

modeling efforts (17, 

Beyond anthropogenic several additional 

factors have caused increases in fuel and forest fire area 

since the t 97(k The lack of fuel aridity during 1948-1978 

and persistence of positive trends during 1979·-2015 even after 

removing the ACC signa! implicates natural multidecada! climate 

variability as an important factor that buffered anthropogenic 

A --Observations 

200 --NoACC co c 

"' "' "' Q) :Jl E150 

wo 

~~ !l) ..c100 

""' Q) c ~ Q) t;::-

B 

1990 2000 

year 

2010 

Fig. 4. 1n fire-weather >~ason length and number of high f1re 

USforest{A) fire-weatherse<~~on 

when daily fire danger indices 

exceeded the 95tl1 percentile penod· 19B1-2010 using observational records that exclude the ACC s1gnal. Red lmes show the observed 

and black lines show the rewrd that excludes the ACC signal. Bold 

acros~ fuel aridity metrics 

AbaUoglou<lndWtlltams 
135 


36422.091

inAbdt7oglouandWdhams PNAS ! October18,2016 vol.ll3 no.A2 ' 11773 
136 


36422.092

Methods 

metrrcs 

to 1948 us1ng monthly relative to a common 1981-

2010 period from the dataset developed by the Parameterized Regressmn 

on Independent Slopes Model (51) for temperature, predpitation, 

and vapor pressure, and by mterpolating NCEP-NCAR reanalysis 

forw1nd speed and surface solar We aggregated data to annu· 

alized t1me series of mean May-Sep da1ly FWI, KBD!, ERC and FFDI; Mar-Sep 

VPO and ETo; Jun-Aug PDS!; and Jan~ Dec CWO We also calculated the 

artdtty metrics stnctly from ERA,!NTERIM and NCEP-NCAR reanalysis products for 1979-2015 covering the satell!te era (Supporting Information) 

Daysperyearofhighfirepoterrtialarequantifiedbydaityfiredangerindices 

FWI, FFDI, and KBD!) that exceed the 95th percentile threshold deimed 

1981-2010 from observations after removtng the ACC signal Observational studies haveshoW!lthatfire gro>Nthpreferentlallyoccursdunnghigh 

ftredang!'rperiods(52,53).Wealsocalculatetheftreweatherseasonlength 

for the four daily ftre danger ind1cesfollowing prev1ousstudies (10) 

The ACC Signal IS obtained from en~emble members taken from 27 CM!PS 

1'resolutionfor185o--

trme senes for each of the 12 mo for 1850-2099. We averaged each month's 

low-pass-frltered time senes across the 27 GCMs and addltively adjusted so that 

all smoothed records pass through zero in 1901. The resultant ACC srgnal 

the CMIPS modeled anthropogenic impact smce 1901 for each 

grid cell, and month (Supporting Information) 

We bilincarly mterpolated the 1" CMIPS multtmodel mean 50-y low-pass 

t1mesen~stothe 1/24"spatlal resolution oftheobser11ationsandsubtracted 

the ACC signal from the observed daily and monthly time series. We consider 

the remaining rewrds a her subtraction of th~ ACC s1gnal to indicate dimate 

recordsthat<~refree of anthropogenic trends (26) 

Annual variations in fuel andity metncs are presented as standardized 

metncs is quant:fted as the difference between metncs 

observations and those calculated With observations that excluded the ACC signal Area-wetghted standardized anomalies and the 

extent of western US forested land that experienced high (>1 cr) 

AnnualizedburnedareaasweH 

data from ref 50 and the 

We use the regression relationship between the annual western US forest 

ftreareaandtheall-metncmeanfuel 1 to estimate the 

due to imperfect 

correlation and temporal are propagated as estimated 

conf:dence bounds on the anthropogenic forcing of forest fire area. This 

approach was repeated using a more conservattve defimt:on of theregress:on relatlonsh!p,whereweremovedthe!:nearleastsquarestrendfor 

1984-2015 from both the area burned and fuel aridity time senes before 

regression to reduce the poss:bi!ity of spurious correlation due to common 

but unrelated trends (Fig. 55). Statistical significance of all linear trends and 

correlatlo!lsreportedmthisstudyareassessed 

and Kefldall's tau statistics. Trends are 

y1eld P < 0 05 

ACKNOWLEDGMENTS. We thank J. Manktn, B. Osborn, and two reviewers 

for helpful comments on the m<Jnuscript and coauthors of ref. 26 for help 

develop:ng the empirical attribUtion framework AP W. was fu'lded by Columbia University's Center for Climate and life and by the lamont-Doherty 

Earth Observatory (Lamont contnbution 8048)_ .J.T A. was supported by 

funding from Nattona! Aeronautics and Space Admimstration Terrestrtai 

Ecology Program under Award NNX14AJ14G, and the Nattonal Science 

Foundation Hazards Science, Engineering and Educatwn for Su~tain.ab:!ity 

(SEES) Program under Award 1520873 

1. Littell !5, McKenm.• D. Peterson DL, We>terlmg Al ()009) Cl<mate and wi1d!1re area 13 

)4(6)•1121-1141 

10. JoliyWM, el al (2015) Climate induced varidt1om in g~obal wtldfwcdangerfrom 1979 

GowmanLM (2009)1mpl< 

tatmr" ofCh8t'lgmg d'mate for globa' wild'and fJfC lrll J Wdd/imd f~re 18(~)·4!U 507 

11774 ! wwwpnasorgkg,/dm/101073!pnas1607171113 

14 YoonJ, Kr<lv•tzB,Ra«hP()OlS)FJ<tremcfirewa>oninCn':fomia Agfimp<eintothe 

future'8uiiAmMeteoro/Soc96'iS 59 

Kolden 

AbaUoglou and Williams 
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25 Wr,;~am> AP. et al (2015) (or•e.atmns between '""'ponants of the wMcr bi!:an(e and ,, 

AbatzoglowandWdl,ams f>NAS Octobert8.2Cl1£ ! vol 113 no 42 11775 
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36422.094

GeoHealth 

RESEARCH ARTICLE l 0. l 029/201 13GH000144 

Key Points; 

Weprovidethefirstesttmatesof 

'>totesusmgcprognosticla11dfire 

model 

Thenumberofdeathsattnbutableto 

tota1PM, 5 willdecrease,butthe 

numberattnbutabletofire·related 

PM 1,willdoublebylate21stcentury 

Supportinqtnformation; 

· SupportmglnformationSl 

Correspondence to: 

B. ford, 

bilnnc@atmos.colostate.edu 

GeoHea/th,2.hnwl/dOI.org/10.1029/ 

2016GH000144 

Rece,ved 2.4APR 2018 

Accepted 27 JUN 2018 

Accepted art1cleonlme6JUL 2018 

<N018TheAuthors 

Th•slsanopenatcessartideunderthe 

termsoftheCreat1veCommons 

Attnbut1on-NonCommerc!al NoDenvs 

FORD ET AL. 

ADVAN!;IN.G 

EARTH AND 

SPACE SCIENCE 

Future Fire Impacts on Smoke Concentrations, Visibility, 

and Health in the Contiguous United States 

B. Ford1 {~it, M. Val Martin2 lt\!), s. E. Zelasky ~), E. V. Fischer1 &j'~\ S.C. Anenberg \~~. 

C. L. Hea!d5

'

6 €,~\ and J. R. Pierce 1 f~*~ 

1

0epartment of Atmospheric Science, Colorado State University, Fort Collins, CO, USA, 2leverhulme Centre for Climate 

Change Mitigation, Department of Animal and Plant Sciences, University of Sheffield, Sheffield, UK, 3

Department of 

Environmental Sciences and Engineering, University of North Carolina at Chapel Hdl, Chapel Hill, NC. USA, 4Department of 

Environmental and Occupational Health, The George Washington UnJVersity, Washington. DC, USA, 5Department of Civil 

and Enwonmental Engineering, Mass<~chusett~ Institute of Technology, Cambridge, MA, USA, 0

Departmcnt of Earth, 

Atmosphenc and Planetary Sciences, Massachusetts lnstit\Jte of Technology, Cambridge, MA, USA 

Abstract Fine particulate matter (PM2 5 ) from U.S. anthropogenic sources is decreasing. However, 

previous studies have predicted that PM2_5 emissions from wildfires will increase in the midcentury to next 

century, potentially offsetting improvements gained by continued reductions in anthropogenic emissions. 

Therefore, some regions could experience worse air quality, degraded visibility, and increases in 

population-level exposure. We use global climate mode! simulations to estimate the impacts of changing fire 

emissions on air quality, visibWty, and premature deaths in the middle and late 21st century. We find that 

PM25 concentrations will decrease overall in the contiguous United States (CONUS) due to decreasing 

anthropogenic emissions {total PM25 decreases by 3o/o in Representative Concentration Pathway [RCP] 8.5 

and 34% in RCP4.5 by 2100), but increasing fire-related PM25 {fire-related PM2.s increases by 55% in RCP4.5 

and 190o/o in RCP8.5 by 21 00} offsets these benefits and causes increases in total PM2 5 in some regions. 

We predict that the average visibility will improve across the CONUS, but fire-related PM25 will reduce 

visibility on the worst days in western and southeastern U.S. regions. We estimate that the number of deaths 

attributable to total PM2.

5 will decrease in both the RCP4.5 and RCPB.S scenarios (from 6% to 4-5%), but 

the absolute number of premature deaths attributable to fire-related PM2.5 will double compared to early 

21st century. We provide the first estimates of future smoke health and visibility impacts using a 

prognostic land-fire model. Our results suggest the importance of using realistic fire emissions in future air 

quality projections. 

1. Introduction 

Exposure to particulate matter (PM2.

5, particles with an aerodynamic diameter smaller than 2.5 flm) is associated with many neg<ltive health impacts {Crouse et al., 2012; Krewski et a!., 200g; C. Arden Pope, )007; C 

Arden Pope 3rd & Dockery, 2006), visibility degradation, and ecosystem impacts. There are many different 

sources of PM25, both from human and natural sources. Because of the known detrimental effects of air 

po!!ution, the United States has sought to improve air quality through regulation of anthropogenic emissions. 

This has led to PM2 5 improvements in most regions of the United States (e.g., Hand et aL, 2013; Malm et al., 

2017; U.S. Environmental Protection Agency (EPA), 2012). These PM25 improvements are predicted to 

increase in the future with a further decrease in anthropogenic emissions (e.g., Lam et aL, 2011; 

Leibensperger et al., 2012; Val Martin et a!., 2015). 

Wildfires are a large source of PM25 in the United States, and studies have shown that the number of large 

wildfires has been increasing in the western United States due to warmer temperatures, earlier spring snowmelt, and longer fire seasons (e.g., Westerling, 2016; Wester!ing eta!., 2006). Several studies have suggested 

that this trend will continue throughout the 21st century and that smoke could become the dominant source 

of PM2.s in the western United States during the fire season (e.g., (Uu et aL 2016; Yue eta!., 2013), However, 

estimating future fire emissions and their impact on air quality is challenging. Fire trends are influenced not 

only by the changing climate but also by land use changes, land management choices, and human interactions (in terms of both ignition and suppression; e.g., Balch et aL, 2017; Fusco et al., 2016; Prestemon et al., 

2013). Most studies that have estimated future fires {risk or area burned) have relied on statistical regressions 

of current-day meteorological values (such as precipitation, relative humidity, and temperature) and fire 
139 


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GeoHealth 10.1 029/2018GH000144 

indices (Uu et al., 2016; Prestemon et al., 2016; Spracklen et al., 2009; We sterling & Bryant, 2008; Yue et al., 

2014), or parameterizations built off these statistical regressions (Liu eta!., 2016; Yue et al., 2013, 2014) 

showed that these methods are ab!e to explain 25- 65% of the variance in area burned, but the efficacy is 

regionally dependent. When applied to future predictions, these studies suggest increases in fire emissions, 

specifically in the western United States, leading to increases in surface fire-related PM concentrations 

(Spracklen eta!., 2009; Yue et al., 2013), visibility degradation (Spracklen eta!., 2009), and smoke-exposure 

events (Uu et al., 2016). Va! Martin et al. (2015) previously used Community Earth System Model (CESM} to 

simulate future PM concentrations in the United States with regard to changing emissions, land use, and 

climate. For fire emissions, they used the spatial distributions from the Representative Concentration 

Pathway (RCP) scenarios and then homogeneously scaled the monthly emissions in the western United 

States and Canada to match the total fire emissions from Yue et a!. (2013). 

More recently, process-based fire modules embedded in global land models have been used to estimate 

future fires and emissions (e.g., Knorr et al., 2017; Pierce et a!., 2017). These fire modules use information 

on both climatic and socio-economic drivers (e.g., soil moisture, temperature, gross domestic product, and 

population density) to estimate area burned and fire emissions (Knorr et al., 2014; Li et aL, 2013; Pierce 

et al., 2017). In contrast to statistical models, processed-based fire models can better represent feedbacks 

between emissions and climate and land use (Li et al., 2012, 2013, 2017). Additionally, they do not have to 

assume that the st<Jtistical relationships determined from current day observations will stay the same in 

the future under different climate scenarios nor do we need to either assume a statistical relationship holds 

for al! regions or create a statistical relationship for each region, Fir>ally, using the process-based Are module 

within a global model allows us to account for changes in lire emissions outside the study domain (contiguous United States) that can also impact air quality within our study domain. In this study, we use simulated 

concentrations of PM25 generated by the CESM for early 21st century ("2000," the average of 2001~2010), 

mid century ("2050," average of 2041 ~2050), and late 21st century (''21 00," average of 2091~2099) described 

in Pierce eta!. (2017) to estimate changes in PM2.s concentrations, population-level exposure, health effects, 

and visibility in the United States_ 

2. Methods and Tools 

2.1. Model Simulations of Fire Emissions and Atmospheric Concentrations 

We use the CESM to simulate surface-level PM 2 5 concentrations. A description and evaluation of the model is 

given in Tilmes eta!. (2015). The model is run at 0.9° x 1.25° horizontal resolution for three periods: early 21st 

century (2000~2010), midcentury (2040--2050), and late century (2090-·2099). Results are shown as 10-year 

averages (with the first year excluded for model spin-up). Ten-year time periods were run to represent climatological averages and account for interannual variability. The simulations were conducted in two separate 

steps: (1) simulating fire emissions using a land model and then (2) simulating air quality impacts using an 

,1tmasphcric model. 

First, emissions for landscape, agricultural, and peat f1res were interactively simulated using the Community 

Land Mode! (CLM) v4.5 (Oleson eta!., 2013), which accounts for changes in land cover, vegetation, climate 

change, and population (Pierce et al., 2017). These runs were conducted globally at 0.9° x 1.25° resolution 

for 1850 to 2100. Future fire simulations (2006-2100} were driven by monthly meteorological fields from 

archived CESMl simulations with the RCP4.5 and RCP8.5 scenarios and population projections from the 

Shared Socioeconomic Pathways (SSPs; Jones & O'Neil!, 2016); the transition period (1850-2005) was forced 

with assimilated atmospheric data from the Climatic Research Unit of the National Centers for Environmental 

Prediction (CRUNCEP) and population data from the History Database of the Global Environment (HYDE). The 

transient run started from an 1850 equilibrium (spin-up) state of CLM4.5 with the fire module. Description of 

the original fire module and comparison with fire emission inventories are given in U et a!. (2012), and 

updates to the module and further validation are in U eta!. (2013) and Li eta!. {2017). Li eta!. {2013) and 

Li eta!. (2017) found that CESM with the updated fire module is able to simulate the spatial distribution of 

fires, total area burned, fire seasonality, fire interannual variability and trends, and fire carbon emissions reasonably wet! compared to observations, 

Second, the Community Atmospheric Model v4 fully coupled with an interactive gas-aerosol scheme 

(CAM-Chem) was used to simulate air quality impacts {Lamarque et a!., 2012) using the fire emissions from 
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FORD ET AL. 

GeoHealth 10.1 029/2018GH000144 

the CLM. Meteorology in our present-day CAM-Chem simulations is free-running and not assimilated for present day. Hence, specific daily meteorological conditions in the present-day simulations do not correspond to 

observed conditions, Population projections are taken from the SSPs (Jones & O'Neill, 2016) and are 

described in detail in section 2.2. Biogenic emissions were determined using the Model of Emissions of 

Gases and Aerosols from Nature (MEGAN v2.1; Guenther eta!., 2012). For estimating future anthropogenic 

emissions, we used the RCP scenarios 4.5 and 8.5 (van Vuuren et al., 2011 ). The RCPs are four different future 

climate scenarios that describe trajectories for greenhouse gas concentrations. They are referred to by the 

associated amount of radiative forcing that would occur by 2100 compared to preindustrial times (i.e., 

RCP4.5 corresponds to a t4.5 W/m2 forcing). The RCPB.S scenario assumes continued increases in green~ 

house gas concentrations throughout the 21st century due to high populations, slow income growth, high 

energy demand with moderate technological changes to reduce emissions, and the absence of climate 

change policies. In RCPB.S, methane and carbon dioxide emissions wll! increase throughout the century. 

The RCP4.S pathway has a gradual reduction in greenhouse gas emission rates after 20SO such that radiative 

forcing is stabilized shortly after 2100. It assumes a shift to lower emission energy sources, enactment of 

climate policies, less croplands, and more forests. ln RCP4.S, carbon dioxide emissions will increase to 

midcentury and then decline; methane emissions will have a slight decline throughout the century, Both 

scenarios suggest a decrease in SO; and NOx emissions (although a greater decline in NO~ emissions with 

the RCP4.S scenario). 

Fire emissions were provided to CAM~Chem from the CLM4.5 fire simulations described above. We note that 

due to internal variability in climate dynamics, an ensemble of CESM simulations could potentially provide a 

range of potential future smoke PM2 s concentrations {Kay et al., 2014). While we were only able to perform a 

single set of simulations due to the computational complexity of the CESM simulations, future work should 

consider an ensemble of simulations to better capture the potential range in the projections offuture smoke 

concentrations. A full description of the model set-up, experimental design, and model evaluation can be 

found in Pierce eta!. (2017), 

Several different atmospheric simulations were conducted for each of the three different time periods to 

determine the contribution of different sources and emission regions to atmospheric concentrations in the 

contiguous United States (CONUS, the United States without Hawaii and Alaska; Table 51). Our baseline 

simulations included aU emission sources, while our Fireoff simulation turned off all fire emissions, and our 

TransportFireOff turned off fire emissions only in Canada, Alaska, Hawaii, and Mexico {this does not include 

transported smoke from fire emissions on other continents). By comparing these two sensitivity tests with 

the baseline simulation, we can determine the contribution of all wildfire smoke and the contribution of 

transported smoke to total PM? 5 concentrations. 

We calculate the surface-level PM2 5 concentration from the model output with the following equation as in 

Val Martinet al. {2015): 

(1) 

PM2 5 is the combination of sulfate, ammonium nitrate, secondary organic aerosols {SO As), fine dust {first two 

size bins), tine sea salt (SSLT First two size binsL black cMbon {BC), and organic carbon (OC), BC and OC are the 

sums of the hydrophobic and hydrophilic components, and we use 1.8 as the OM:OC ratio following Hand 

eta!. (2012). SOA is the sum of species formed from toluene, monoterpenes, isoprene, benzene, and xylene. 

2.2. Population Projections 

Also, included in the CLM simulations are population projections from the SSPs (Jones & O'Neill, 2016). 

Following van Vuuren et al. (2011), we use SSP3 with RCP8.S and SSP1 with RCP4.S. SSP3 is a "fragmented 

world" scenario where a focus on national security and borders has hindered international development 

{O'Neil! et al., 7017). Population growth is high in developing countries and !ow in industrialized countries, 

and migration is low. This leads to a decline in the U.S. population by 2100 (but increased global population). 

SSP1 is the "sustainabi!ity" pathway, where there is rapid technological development, lower energy demand 

(particularly with less fossil fuel dependency), increased awareness of environmental degradation, and 

medium-to-high economic growth. Higher education levels lead to an overall tower global population, but 

fast urbanization and migration increase population density in urban areas around the CONUS (O'Neill 
141 


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GeoHealth 

2050 SSP1 ~'.Population 

45'N 

2000 Population Density 40~N 

[peoplelkm'l 

45'N 

40'N 

35'N 

30'N 

25'N L_=ccW~A!':-:---~ 

1 0.1 029/2018GH000144 

2100 SSP1 <1Populatlon 

Figure 1. Figure shows the current CONUS population density (avcrage2006"-2010) and the changes m population dl:'nsityprojected in 2050 (average of2040-2050) 

and 2100 {average of 2090- 2100) by the SSP1 and SSP3 projections. 

FORD ET Al. 

et at, 2017). The predicted changes in population density for each scenario are shown in Figure 1. These 

population projection scenarios are included in the simulations discussed in section 2.1 because 

demographic changes can alter fire activity due to suppression and can influence where fires occur (Balch 

eta!., 2017; Knorr et aL, 2014, 2016). We also use these population projections to estimate future smoke 

exposure, health effects, and determine popu!ation+weighted average concentrations. 

2.3. Visibility Calculations 

We used the first IMPROVE equation (equation (2)) developed by Maim et al. (1994) to calculate potential 

changes in visibility. We chose to present results in the main text using the first equation rather than the 

revised equation (Pitchford et al., 2007) for better comparison with Val Martin et al. (2015). The revised equation also separates the organic mass into large and fine mode fractions using the total mass (if the total concentration is above 20 ,ug/m3

, all of it is assumed to be in the large mode. If the concentration is below 

20 ~tglm', then it is separated into small and large modes, whKh have different mass extinction efficiencies). 

Using this cutoff value based on total mass to distinguish between large and small modes created some 

counterintuitive results when examining our sensitivity simulation results on days with high concentrations. 

However, we did calculate these changes in visibility using the revised IMPROVE equation and found generally similar results (see section 55). 

bext""3xf (RH)'</Immonium Sulfate! 1 3xf {RH)x(Ammonium Nitrate]-:- 4x;Organlc Mass] 

+ 10 x [Elemental Carbon: + 1 x ~Fine Soil; + 0.6 x (Coarse Mass! - Rayleigh scattering (2) 

With the IMPROVE equation, light extinction (b"xtl at each IMPROVE site is calculated by multiplying the mass 

concentrations (in M91m3

) of different aerosol components by typical component-specific mass extinction 

efficiencies. For sulfate and nitrate, the dry extinction efficiency is also multiplied by a water grovvth factor 
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GeoHealth 1 0.1 029/2018GH000144 

that is a function of relative humidity (f(RH)), Rayleigh scattering is assumed to be 10/Mm at every site, and 

gas absorption is assumed to be 0. For our results, we use the CESM ground-level daily-average relative 

humidity and daily-average PM species concentrations. 

We also convert this to a haze index {HI) fa !lowing equation (3) (U.S. EPA, 2003) and visual range (VRJ following 

equation (4) (Pitchford & Maim, 1994) as in Val Martin et at. (2015). 

HI---= 10<dn(b,xt/10) (3) 

where bext is in inverse megameters. 

VR K/bc·xt (4) 

where K is the Koschmieder coefficient and is assumed to be 3,91 in Pitchford and Ma!m (1994). 

2.4. Health Impact 

We calculate the all-cause mortality associated with changes in the annual-average concentrations in PM25 . 

We rely on the following concentration response function as used in Anenberg et at (2010, 2014): 

!\Mortality= Pop (1 exp·-il•IIX)Y0 lSI 

In this equation, the change in mortality is determined by the population (Pop) and baseline mortality (Y0 ) 

and the concentration response function. The health response (here, mortality) is related to the change in 

annual-mean PM2 _5 concentration (!.'~.)() using a concentration-response factor or beta coefficient (/J) determined from relative risk (RR) estimates in epidemiological studies. The fJ can be determined from the RR estimate following equation (6), which is commonly used (i.e., An en berg et al.,2010, 2014; Fann et aL, 2017) and 

assumes a linear relationship between the ambient concentration and the log of the RR. While some studies 

have suggested that a linear relationship would overpredict outcomes at high concentrations (Burnett eta!., 

2014; Nasari et al., 2016; Pope eta!., 2015), this linearity has been demonstrated over the range of PM2.s values 

relevant to this study (Krewski et al., 2009). 

p -- In (RR)j.A.X (6) 

When calculating the !1X for equation (5), studies often subtract the threshold value (concentration below 

which there is no effect) or use the original epidemiological studies lowest observed concentration. For this 

study, we use several different fl coefficients commonly used in health impact assessments in order to determine a range of estimates for all-cause mortality. To note, there are uncertainties not only in fJ but also in the 

application of the threshold/lowest-observed-concentration value, and shape of the concentration response 

function that will all impact our final estimates of the number of attnbutab!e premature deaths. We do investigate the impact of the threshold value for our estimates, but for a more-detailed exploration and sensitivity 

analyses of these uncertamties on the estimates, see Johnston et al. (2012), Kodros et al, (2018), or Ford and 

Heald (2016). 

In this study, we use (J coefficients from Krewski eta!. (2009), Crouse et at. (2012), and Laden et aL (2006). The 

RRs, confidence intervals (Cis), and threshold/lowest-observed-concentration values from these studies are 

given in Table 1, To note, all of these studies are of the health effects associated with total PM2_5 mass. 

Therefore, by using these (J coefficients for determining the burden contribution due only to smoke, we 

are assuming (as has been done in other studies) that all sources and aerosol types have equal toxicity, which 

may not be accurate. Recent review studies specific to wildfire smoke exposure (e.g., Uu et al., 2016; Reid 

et al., 2016) have highlighted both similar health effects to total PM2 5 exposure studies (positive associations 

with respiratory morbidity) and some distinctions (no clear association with cardiovascular morbidity). 

However, while there have been many studies looking at the effects of acute exposure to wildfire smoke, 

there are no studies that have quantified the relationship between aU-cause mortality and long-term exposure to smoke PM25, which is what we are determining here, Therefore, previous studies (e.g., Johnston 

et al., 2012) have also retied on using RR values from studies of total PM ~ when estimating the number of 

premature deaths attnbutable to long-term exposure to smoke PM25• 
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GeoHealth 10.1 029/2018GH000144 

Table 1 

Epidemiology Studies Used for Our Calculations of Attributable Premature Deaths With Their RRs, Cis, and Threshold/Lowest Observed Concentration V?lues 

Swdy reference 

Krewski et aL(2009) 

Crouse et al. (2012) 

Laden et al. (2006) 

FORD ET AL. 

Relative risk forM.::: 10 ~gtm 3 

1.06 

1.10 

1.16 

Confidence interval 

1.04-1.08 

1.05-1.15 

1.07-1.26 

Lowest observed/threshold concentration 

For our final results, we use the Krewski et a!. {2009) RR because It is widely used and derived from a large 

cohort population in the United States (American Cancer Society Cancer Prevention Study II). We pair the 

Krewski et al, (2009) RR with the lowest observable concentration from Crouse et al. (2012) because subsequent research since Krewski et at (2009) has shown mortality effects of PM2 5 exist at PM25 concentrations 

below the minimum observed value of Krewski et aL (2009) of 5.8 11g/m3 (Crouse eta!., 2012; Pinault eta!., 

2016). Other studies have assumed a threshold of 0 pg/m3 (i.e., Fann et al., 2017). We also examine the sen· 

sitfvity to other choices in fJ coefficients and threshold values, and we present those results as well. 

Population is taken from the SSPl and SSP3 projections and is on a O.SO spatial resolution grid, For baseline 

mortality, we use the SSP population death rate estimates for aU-cause mortality. These are given for five~year 

time periods for each country. We use the nationally averaged death rate for the U.S. rate for each year in our 

simulation period, and we regrid the PM;..s concentrations to the same 0.5° resolution as the population to 

estimate exposure concentrations. There is a decrease in the morta!lty rates for SSP1 and an increase for SSP3. 

Fina!ly, to attribute the number of premature deaths to each source (non fire, CONUS fire, and AKIHI/Mexico/ 

Canadian transported smoke), we multiply the total number of premature deaths determined from the total 

PM2 5 by the fraction of PM25 from each source (determined from our sensitivity simulations). This method, as 

opposed to using the results from the sensitivity simulations with zeroed out emissions, avoids underestimating the contribution of sources that would occur given the dependence on the threshold value and the nonlinearity of the concentration response function (Kodros et a!., 201 B). 

3. Results 

3.1. Projections of Future Smoke Emissions in North America 

From the CLM, the present~day area burned for the CONUS (or Temperature North America, TENA) is 6.2 Mha/ 

year (for 1995~2005); this is greater than the Global Fire Emissions Database version 4 (GFE04) estimate of 

1.8 Mha/year (Giglio et al., 2013); however, this GFED4 estimate does not include small fires, which are important in the United States. The GFED4s estimate, which does include small fires, estimates an average of 

2.7 Mha/year for 2001~2010 with a range of -1.5-4 Mha/year {Randerson eta!., 2012). The land model simulations described in section 2.1 showed an increase in area burned in the middle and late 21st century relative 

to the start of the century. As the burn area increases, biomass burning (BB) emissions also increase (v-.rhereas 

carbon emissions from other sources are projected to decrease). The total annual average emissions of BB 13C 

and OC for the CONUS as determined from the CLM simulations are given in Table 2. Our early 21st century 

(2000} CONUS BB emissions of BC (0.058 Tg/year} are in the range of the GFED (0,01 1 Tg/year), Fire INventory 

National Center for Atmospheric Research (FINN; 0.024 Tg/year), and National Emissions Inventory (0, 102 Tg/ 

year) inventories as given in Larkin et al. (2014). Our CONUS OC 138 emissions (0,84 Tg/year} are a!so between 

the Streets eta!. (2004) estimate of 0.954 Tg/year (for 1996), the U.S. EPA (2006) estimate of 0.658 Tg/year {for 

2000), and FINNvl estimate of 0.405 Tg/year (Wiedinmyer et al., 2011 ). Results from the CLM interactive fire 

Table 2 

Decadai-Avemge Black Carbon and Organic Carbon Emissions in the Contiguous United States Due to Biomass Burning 

CONUS biomass burning emissions 

2000-2010 

Baseline 

0.058 

0.84 

2040-2050 

RCP4.5 

0,13 

1.9 

RCP8.5 

0.087 

1.3 

2090-2100 

RCP4.S 

0.12 

1.9 

RCP8.5 

0.14 

2.1 
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36422.100

2000 OC+BC BB Emissions 

[g/m2

/yr] 

GeoHealth 10.1 029/2018GH000144 

2050 L10C+BC Emissions RCP4.5 2100 6-0C+BC Emissions RCP4.5 

SO'N ~:;;,;;rc:c:;:::·--:~:,;.:::--···--;;:'1 

45"N 

40"N 

35'N 

30"N 

25"N C-----~--'-

2050 ~OC+BC Emissions RCP8.5 2100 :\OC+BC Emissions RCPS.S 

50'N r:c:=c·:c::·:·:: :•c--:::------·--:"'1 

45'N 

40"N 

30"N 

25"N 

Figure 2. Early 21st century (2000), decada! averilge OC and BC BB emissions for the CONUS, and the changl's for 20<10-2050 and 2090-2100 projected with the 

RCP4.5 and RCP8.5 scenarios 

FORD ET AL. 

simulations shown in Table 2 suggest that emissions should double by mid century in the RCP45 (increase by 

~so% in RCP85) and almost triple by 2100 in RCP8.5. As noted in Val Martinet a!. (2015), the standard RCP4.5, 

which does not include prognostic future tire emissions from CLM (as done here) or a statistical fire prediction 

model (e.g., Yue eta!., 2013),suggests an increase of about 60% in flre OC emissions over the western United 

States by 2050 whi!e the RCP8.5 suggests a 0.3% decrease in these emissions. These assume that fire emission 

changes are because the standard RCP scenarios consider land use changes (afforestation in RCP4.5 and 

deforestation with a transition to more croplands in RCPB.S), but not any climate effects {Lamarque et al., 

201 O; Val Martinet al., 2015). Using a statistical fire model that did include climate changes on fires (and relied 

on output from 15 climate models using theA1 B scenario), Yue et al. (2013) predicted a 150··170% increase in 

OC and 13C fire emissions in the western United States by 2050. Thus, by adding in an increase in fire emissions following Yue et al. {2013), Val Martinet al. (201S) had similar increases in emissions in the western 

United States as shown here (-1 00% in RCP4.5 and -50% ln RCP8.5 increase by 2050). 

However, we find significant spatial differences in where the changes in 8B emissions occur compared to 

these previous studies. In Figure 2, we show the early 21st century (average 2000--2010) 8C and OC 88 

emissions over the CONUS and the changes for 2050 (annual average for 2040-20SO) and 2100 (average 

2090-2099) for the RCP4.5 and RCP8.5 scenarios determined from the land model simulations. The largest 

projected changes are in the southeastern United States and along the Canadian border (Figure 2). These 

increases in 813 emissions in the eastern United States are an important distinction of this current work, as 

previous studies such as Yue et al. (2013) and consequently Val Martin eta!. (2015} did not consider any significant increases in area burned or fire emissions over the eastern United States and only focused on the 

western United States. Yue et al. (2013) predicted a 150~ 170% increase in fire-related OC and 8C emissions 

m the western United States by midcentury using the A 1 B scenario. Here we frnd a 60% (RCP8.5) or 130% 

(RCP4.5) increase for the whole United States in midcentury; however, the majority of the increase in 

8C + OC emissions is for the eastern United States (85% RCP8.5, 220% RCP4.5) and not the western United 

States (40% RCP8.5, 45% RCP4.5). Like Yue et al. (2013), our simulations show that the western United States 

has peak fire emissions in August throughout the century. AdditionaHy, the northeastern United States has 
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GeoHealth 10.1 029/2018GH000144 

a similar fire season compared to the western United States, whereas the southeastern United States has 

peak fire emissions earlier in May. For aH regions, the e~nnua! fire emissions increase due to both increases 

in emissions during the peak fire season and a lengthening of the fire season, with the largest changes in 

both the peak emissions and lengther>ing occurring in the southeastern United States, 

In the CLM simulations (Pierce et al., 2017), both climate and population changes drive the fire emissions. In 

both the RCP4.S and RCP8.5 scenarios, the relevant climate changes (i.e,, temperature, precipitation, and soil 

moisture) throughout the United State~ are overall conducive to increasing fire emissions in the future 

(Stocker et aL, 2013; Val Martinet aL, 2015, Figure 51), and climate is the main driver of our simulated changes 

in fire emissions in the CONUS (Pierce eta!., 2017, Figure 52). The RCP4.5 scenario projects strong afforestation up to 2050 over the southeastern United States due to mitigation strategies for carbon emission reductions (shown in Val Martinet al., 2015); this rate begins to stabilize <J:fter 2050, and there is less fuel recovery by 

2100. While climate is the primary driver of fire changes in the United States, population changes also impact 

fires, particularly the suppression and ignition of fires. The SSPl (used with RCP4.5) projects an increase in 

population over the CONUS {Figure 1), which leads to increased suppression of fires in the eastern United 

States in the CLM, offsetting some of the increases in fires that might be projected if only changes in climate 

are considered (Val Martin et al., 2.015). The RCP8.5 scenario projects deforestation in much of the eastern 

United States and a transition to more croplands leading to less fuel available to burn. Correspondingly, 

the RCP8.5 scenario does suggest a slight increase In agricultural burning in the southeast (although 

landscape fires overall dominate the area burned). Additionally, the SSP3 (used with RCP8.5) projects little 

population change by 2050 and then widespread decreases by 21 DO {Figure 1). This leads to less suppression 

of fires, which coupled with the changes in climate, increases fire emissions significantly between the midcentury and late century. 

Because our model simulations suggest that BB in the eastern United States could significantly increase, and 

as population and PM2,

5 concentrations are generally higher in the eastern United States compared to the 

western United States (with the exception of California), this could have important implications for smoke 

exposure and the resulting health effects. 

3.2. Projections of Future PM and Fire PM in the United States 

Changes in emissions w!l! also alter PM25 concentrations levels in the CONUS. By 2050, total PM2.s concentra· 

tions are projected to decrease primarily due to expected reductions in anthropogenic emissions in both the 

RCP4.5 and RCP8.5 scenarios (Figure 3). The reductions shown here are most notable in the eastern United 

States, particularly in the Ohio River Valley, consistent with recently observed downward trends in this region 

(e.g., Maim et al., 2017; U.S. EPA, 2012), In our RCP4.5 scenario simulations, PM25 concentrations will continue 

to decrease by 21 00; however, in the RCP8.5 scenario, several areas in the western United States, northeastern United States, and southeastern United States are projected to have higher concentrations compared to 

the early 21st century (2000). Our results shown here in Figure 3 differ from Lam eta!. (2011), which showed 

that PM2.

5 should decrease drastically by 2050. However, they did not account for changing fire emissions. 

In Figure 4, we show the decadal average of the annual changes in fire-related PM2 5 projected in our simulations (summertime [June-July-August] average is shown in Figure 56). These results indicate that smoke concentrations are the cause for the higher PM;:.s in our future simulations and that without an increased 

contribution from smoke, many regions would be projected to have even !ower PM2.s concentrations than 

shown in Figure 3. Both our RCP4.5 and RCP8.5 scenarios suggest that PM2.s due to fire emissions wm increase 

in the future. There are three main regions that wi!l be Impacted: (1) the Pacific Northwest (and northern 

California), (2) the southeastern United States, and (3) the north-centra! and northeastern United States along 

the Canadian border. In the early 21st century, fire emission accounts for more than 50% of the annual PM2.s 

only in the Pacific Northwest (Figure 56). By 2100 in both our RCP4.5 and RCP8.5 scenarios, fire emissions are 

projected to account for more than 50% of the annual PM25 across most of the CONUS, and in areas of the 

three previously mentioned regions, fire emissions are projectQd to be responsible for 75% or more of the 

annual average PM2 s concentrations in the RCP8.5 scenario (Figure 57). 

Figure 5 shows the average PM25 concentrations divided by species over the CONUS from our simulations. 

Inorganic: species (sulfate and nitrate ammonium) are predicted to decrease, while SOA and OA concentrations wH! increase. SOA is predicted to increase with increasing biogenic emissions as shown in Val Martin 
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[~g/m ] 

45"N 

40'N 

35'N 

30'N 

25'N 

Figure 3, Total surface PMLs concentr21tlons in the CONUS 

concentratiom by mid century and late century from the 

50'N 

45'N 

40'N 

35'N 

30'N 

25'N 

40'N 

[~gim'] 

25'N 

2050 ciPM,, RCP8.5 2100 .~PM,., RCP8.5 

[~g/m'] 

21st century, and the projected change (compared to early 21st century) in surface PM25 

using the RCP4.5 and RCP8.5 scenarios. 

2050 Fire PM,., RCP4.5 2100 Fire PM2.s RCP4.5 

2050 Fire PM,., RCP8.5 

Figure 4, Simu!21ted decadal average PM2.5 concentrations due to fire emissions from the land model in 2000 and as projected in 2050 and 2100 in the ACP4.S and 

RCP8.5 simulations {with the land model tire emissions}. 

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eta!. (2015), while the OA increase is primarily due to fire emissions, as 

BB is the largest emission source of OC in the United States, Although 

Val Martin et aL (2015) used different fire emissions (scaled RCP4.5 

and RCP8.5 scenMio fire emissions to match Yue et al., 2013), they also 

showed that OA concentrations would double by 2050 due to fire 

emissions in both the RCP4.5 and RCPB.S scenarios. BC is predicted to 

decrease as mobile and industrial emissions are significant but decreasing sources, and BB is not currently the major source of BC in the United 

States, Yue eta!, (2013) found that wildfire emissions increased western 

U.S. summertime OC by 46-70% and BC by 20-27% at midcentury 

compared to the present day. Here we find that if we do not consider 

changes in anthropogenic emissions, wildfire emissions would lead 

to a 16% (28%) increase in summertime BC averaged for the 

CONUS and a 51% (86%) increase in OA in the RCP8.5 (4.5) scenario 

by midcentury. 

Figure 5, Average {decadill means) PM2 5 concentrations over the CONUS S('parated by species for early 21st century. midcentury, and late century from the 

RCP4.5 and RCP8.5 scenarios 

Because of the large concentration increases along the border in the 

Northeast as shown in Figures 3 and 4 (where there are large population centers) projected in the RCP8.5 scenario, we also wanted to determine how much of this increase could be due to smoke transported 

from North American regions outside CONUS. Figure 6 shows the 

results from our TransportFireOff simulation (where fire emissions in 

Canada, Alaska, and Hawaii were turned off), which suggests that not only will concentrations increase due 

to local frres but also fire emissions in Canada could cause a 1-5 )lg/m3 increase in PM2.

5 in the RCP8.5 

scenario (absolute concentrations are shown in Figure 58). This is approximately 50% of the smoke PM2 5 

in the northern United States, which suggests that smoke from Alaskan or Canadian fires could be responsible for 25% of the annual PM1 5 burden in the northern United States by 21 00 compared to 5% in the early 

21st century. 

For the CONUS-wide decadal average, the fire~re!ated contribution to PM2 s concentrations is projected to 

go from -25% to over 50o/o by 2100 in both the RCP4.5 and RCP8.5 scenarios (Figure 7; regional results are 

shown in Figure S9). In the RCP8.5 scenario, smoke will almost completely offset the projected reductions in 

nonfire PM,:, from the early 21st century. To note, this is for the (decada!) annual averages. During the fire 

season, the concentrations (and thus, the exposure concentration levels} wm be even higher. In the 

southeast, midsouth, northeast, and west regions the summertime (June, July, and August} average in 

our simulations (see Figure 51 O) is above the World Health Organization {WHO) guideline of 10 !191m3 

and the EPA national ambient air quality standard limit of 12 fl9/m3 (these standards/guidelines are for 

annual averages). 

SOoN 2000% Fire PM due to Transport 2050% Fire PM due to Transport 2100% Fire PM due to Transport 

45°N 

40°N 

35°N 

30°N 

25 75 

Figure 6. Percent of smoke PM2 s due to transport (fires outside the CONUS) for 2000 and in 2050 and 2100with the! RCPS.S scenario. 

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3.3. Projections of Visibility Changes in the United States 

The Regional Haze Program was established with the goal of reducing 

visibility Impairment in National Parks, forests, and historic sites around 

the United States. According to our simulations, visibility will increase in 

many of these designated areas in the eastern United States due 

to decreases in anthropogenic emissions. However, in the western 

United States where concentrations are predicted to increase due to 

wildland lire smoke, visibility could worsen by 2100. Additionally, wildfires are not a continuous emission source; their timing and location are 

sporadic, and they can produce large emission spikes on day to week 

timesca!es. Therefore, white the impact on the annual timescale may 

be relatively sma!!, the contribution to a single day could be quite large, 

The Region a! Haze Rule requires states to set goals to improve visibility 

and reach natural conditions on both the dearest (average of bottom 

20% over 5-year period) and haziest (average of bottom 20% over 

5-year period) days by 2064. 

conducted for RCP8.5 scenano}. 

In these RCPS.S simulations (for RCP4.5 results, see Figure 53, and for 

results with revised equation, see Figure 54), we see that the 20% best 

days are projected in our simulations to have improved visibi!!ty by 

2050 and 2100 {Figure 8). However, when we look at the 20% worst 

days, our simulation results suggest that smoke from fires would lead 

to visibility degradation in many regions of western United States 

and the southeastern United States in 2050, which would then worsen 

FORD ET AL 

by 2100 {Figure 8). Particular areas of vulnerability include parks in the western United States (e.g., Glacier 

National Park, Lassen Volcanic National Park), southeastern United States (e.g,, Great Smoky Mountains 

National Park), and in the northeastern United States (e.g., Acadia National Park). If we compare to results 

from our FireOff simulation, we see that this is due to fires. Without fires, our projections suggest that visibility 

would continue to improve by 2050 and 2100. Visibility projections from our RCP4,5 simulations suggest simi~ 

lar spatial changes (visibility degradation on the worst days in the west and southeastern United States), but 

with different magnitudes. These results differ from the projections shown in Val Martin et al. (201 5), which 

showed that visibility would improve on the worst and best d<1ys by 2050 in both the RCP45 and RCP8.5 

scenarios. As we are using the same anthropogenic emissions as Val Martinet al. (2015), these differences 

are due to the CLM~predlcted fire emissions, which have a different magnitude and spatial distribution of 

changes during the 21st century. As mentioned in section 3.1, Val Martinet a!. (2015) only considered f1re 

emission changes in the western United States, whereas the simulations used in this study suggest much 

larger changes in the eastern United States, 

In Figure 9 (Figure 54 for revised equation), we show the cumulative probability distributions of the HI at four 

different national park locations in the United States that will potentially experience more visibl!ity degradation due to fires: Acadia National Park in ME (ACADl), Glacier National Park 1n MT (GLACl}, Great Smoky 

Mountains National Park in Tennessee Mountains (GRSM1), and Lassen Volcanic National Park in northern 

CA (LAV01). In general, our simulations suggest that visibility should improve in the future on the average 

day and on the cleanest days. At the northeastern (ACAD1} and southeastern (GRSM l} sites, fire-related 

PM has little impact on visibility in the early 21st century (little difference between the fire and no fire results). 

At the western sites, and particularly at the northern California site (LA VOl), fire~related PM has a larger 

impact on visibility, especially on the days with the worst visibility. For a!! sites, fire-related PM2.s wi!! play a 

larger part in visibility degradation in 2050 and 2100 {in the RCPS.S scenario) and more days wit! be impacted 

by fire-related PM compared to the early 21st century. !n Figure 9, we also have the 2,064 HI targets marked 

for each state. Our simutation results suggest that for the four sites shown here, that smoke will make it difficult to reach the haziest day targets. Without smoke, all of the sites would be able to reach both the haziest 

day and dearest day targets (by 21 00); with smoke, only ACADl will reach the dearest day goal. However, 

these simulation results may not be completely representative of the necessary rate of progress needed to 

reach the goals as we have not analyzed how we!! our simulations match the real baseline conditions (determined from 2000 to 2004) at each site. 

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RCP8.5 2050-2000 No Fires RCP8,5 2100-2000 No Fires 

[deciviews] 

Figure 8, Change in the haze index calculated for the average of the (top row) 20% best and (bottom row) 20% worst days by 2050 and 2100 in the RCPB.S scenario 

determmed from our baseline simulation {''f1res") and our F1reOff simulation ("no fires"). Sites in Figure 9 are labeled as follows: Acadia National Park In ME (ACADl}, 

Great Smoky Moun tams National PMk in TN (GRSMl), and lassen Volcanic Nat1onal Park m northern CA {LAV01). 

FORD ET AL. 

:[ ~ i 

I ~ . 

J 

Figure 9, Cumulative probability distributions of the haze index (equation (3)/ and visibility range (equation (4)) at Acadia 

National Park in ME (ACAD1), Great Smoky Mountains National Park 1n TN (GRSMl), and Lassen Volcanic National ParK in 

northern CA (LAV01) for our different RCPB.S model ~imu!ations and time periods. The solid black lines show the 2064 HI 

targets for the dearest (average of bottom 20%) and haztest (average of top 20%) days at each site. Location of sites is 

noted in Figure 8 

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2050 2050 2100 2100 

2000 RCP4.5 RCPB.S RCP4.5 RCP8.5 

2050 2050 2100 2100 

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2000 RCP4.5 RCP8.5 RCP4.5 RCPB.S 

2050 2050 2100 2100 

Figure 10. Decadal average of the annual population-weighted PM2.'> concentrations for different regions of the CONUS 

(as defined 1n Val Martinet at 2015) separated by source {nonfire, fire, and transported smoke from fires) for early 21st 

century (2000), midcentury (2050), and late century (2100) from the RCP4.5 and RCPB.S scenarios (simulations to determine 

transported smoke were only conducted for the early 21st century and RCPB.S projeCtion scenarios). 

3.4. Projections of Popul<~tion-Level PM Exposure in the United States 

While emissions and concentrations are expected to change, population is also expected to change in the 

future. This population change will impact the population-level exposure and the expected health effects. 

Thus, it is important to determine not only the average concentration but also the average exposure concentration experienced by populations in different regions. 

In Figure 10, we calculate the population-weighted aver£Jge concentrations for the different regions of the 

United States (same regions as in Val Martinet a!., 2015}. Both the RCP8.5 and RCP4.5 scenarios predict a 

decrease in the decadal average of the annual population-weighted PM15 by 2050, suggesting that 

population-level exposure will improve for all regions of the United States. This is due both to decreasing 

urban emissions and population changes. However, in several regions (such as the Great Plains and 

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Table 3 

Number (1000s) and Percent (in Parentheses) of Premature Deaths Attributable to Total PM:u Exposure per Year Determined From Using Different RRs and Threshold/ 

Lowest Observed Values for the Different Time Periods and RCP Scenarios 

Table4 

2000 2050 2100 

RCP4.5 RCP8.5 RCP4.5 RCPB.S 

147 (4.8%) 145{3,9%) 107 (3.6%) 121 (3.9%) 

114(3.7%) 105(2H%) 75(2.5%) 88 {2.9%) 

50(1,6%) 31 (0.84%) 17 (0.57%} 30{0.99%) 

185(6.0%) 171 (4.6%) 121 (4.1%) 142(4.7%) 

28{0.91%) 6 {0.17%) 5 (0.17%) 16(0.53%} 

Southwest), increases in frre PM:t s will offset a signiAcant amount of the improvements in exposure levels 

associated with decreases in anthropogenic emissions. Additionally, in every region, our simulations 

suggest that smoke will become a dominant source of the annual average PM25 exposure, even in regions 

that are not typically associated with wildfires, such as the Northeast and Midsouth. In these two regions, 

much of this increase is due to transport of smoke from other regions. 

In our RCP8.5 scenario simulations, population·level exposure concentrations in most regions is projected to 

increase or stay consistent in 2100 compared to 2050 due to increasing fire emissions offsetting decreasing 

non fire emissions. For the Great Plains and Northeast, transported smoke from Canada is a significant part of 

this projected increase (we did not do transport sensitivity simulations for the RCP4.5 scenario). 

3.5. Projections of the Health Impact of PM2 .5 and Fire PM2 .5 in the CONUS 

From the PM2 5 concentrations and population estimates, we determine the burden on premature deaths 

attributable to PM2.s exposure following the method outlined in section 23. In Table 3, we show results 

acquired using different RRs and threshold values from the studies described in the methods (Table 1). 

Laden et aL (2006) calculated a higher RR, but <Jlso had a higher lowest observed level, such that using this 

value as the threshold value causes concentrations for much of the United States to fall below this value 

and not contribute to the number of premature deaths attributable to PM2,

5. The highest estimates come 

from using the Crouse et al. {2013) RR and threshold value. The range of estimates shown here highlights 

the importance of the assumptions that are used in determining the health impact. Including results using 

these different assumptions can make our results more comparable to other studies that use different 

baseline assumptions. 

To determine the source-specific contribution from fires, we multiplied the total premature deaths by the 

fraction of PM2 5 from each source in each grid. Results are shown in Table 4 (which provides the range of 

estimates using the dtfferent RRs dnd threshold values). Both our RCP4.5 and RCPB.S scenario simulations 

suggest that the number of premature deaths attributable to fire-related PM2.s wil! increase in 2050. In our 

simulations with the RCP4.5 scenario, it is projected that the number of attributable deaths will decrease 

Number (JOOOs) and Percent (in Parentheses} of Premature Deaths Attributable to Fire PM;u Exposure Determined From Using Different RRs and Threshold/Lowest 

Observed Values for the Different Time Periods and RCP Scenarios 

Study for RR; threshold value used 

Krewski et al., 2009; X0 "' 0.0 ~tgim 3 

Krewski et al., 2009; Xo"' 1.91lg/m3<l 

Krewski et al., 2009; Xo = 5.8 ftQ/m3 

Crouse et al., 2012; Xo"' 1.9 ~tg/m 3 

Laden et al., 2006; Xo == 10.0 ,_.g/m3 

2000 

Baseline 

21 {0.89%) 

17(0.70%) 

10 (0.4%) 

28(1.2%) 

7(0.31%) 

"'study and threshold value used for results shown in Figure 11. 

FORD ET AL. 

RCP4.5 

53(1.7%) 

42(1.4%) 

20(0.66%) 

67(2.2%) 

15(0.49%} 

2050 

RCP8.5 

43(1.4%) 

32(1.0%) 

11 (0.34%) 

51 (1.7%) 

3 (0.09%) 

RCP4.5 

45 (1.5%) 

32(1.1%) 

9(0.31%) 

52(1.8%) 

4(0.13%) 

2100 

RCP8.5 

59(2.4%) 

44(1.8%) 

18 (0.700;0) 

71 (2.9%) 

11 (0.41%) 

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2000 RCP4,5 RCPB.SRCP4.5 RCPB.S 2050 2050 2100 2100 

Figure 11. (a) Number and (b) percent of prem<Jture deaths attributable to PM1 s per year in ?000, 2050, and 2100 fol!owmg the RCP4.5 and RCP8.5 scenarios and separated by source (nonflre, fire, and tnmsported smoke}. The bl<~ck lines show 

the estimate range for the total attributable deaths from the RR Cis. 

by 2100 (but still be higher than in the early 21st century), while the number of premature deaths attributable 

to fire-related PM25 is projected to continue to rise by 2100 In our RCP8.5 scenario simulation. 

We summarize these results in Figure 11, which shows the calculated annual number (Figure 11a) and percentage {Figure llb) of premature deaths attributable to PM25 exposure in the CONUS using modelsimulated PM2.

5 concentrations, the SSP population projections, the projected U.S. mortality rates from the 

SSPs, the concentration-response function (equations (S) and (6)), the Krewski et al. (2009} RR listed in 

Table 1, and the threshold value from Crouse et aL {2013) listed in Table 1 (regional estimates are given in 

the Figures S 11 and S 12). Our results using these baseline assumptions suggest that approximately 5% of 

the total deaths in the CONUS are attributable to PM2 5 in the early 21st century (range of2-*% with different 

assumptions), which is in the range estimated by several previous studies (roughly 2-llo/o in Fann eta!., 2012; 

Ford & Heald, 2016; Lim et al., 2012; Punger & West, 2013; and Sun et aL, 2015). Estimates from our model 

simulations suggest that the overall number of premature deaths attributable to PM2.5 should decrease in 

the United States in both the RCP4.5 and RCP8.5 scenarios. However, the U.S. population also changes 

throughout the century as welt as the baseline mortality rates. In the SSP1 scenario (used with RCP4.5), population increases, while in the SSP3 scenario (used with RCP8.5), population declines; thus, the percent of premature deaths attributable to PM2 5 is projected to remain at 3-4(Vo of the total deaths. We also find (using the 

baseline assumptions) that 0.70% of total deaths (12.5% of the premature deaths attributable to total PM2.

5) 

are due to fire-related PM2 5 in the early 21st century. The percent of deaths attributable to tire-related PM2.

5 

increases by the end of the 21st century to 1.1% and 1.8% for our respective RCP4.5 and RCP8.5 cases, While 

the overall trends in mortality number and percent are similar m both panels of Figure 11, the qualitative differences between the two panels arc due to changing population and baseline mortality rates in the future. 

4. Discussion of Uncertainties 

We have presented here estimates of future {2050 and 2100) air quality, health effects, and visibility in the 

CONUS determmed from CESM simulations using emissions from a prognostic tire modeL These are predictions and the veracity of the results will be limited by the model and the assumptions we made to calculate 

visibility and the health effects. These mode! simulations are uncertain due to the nature of the study which 

relies on RCP emission scenarios and SSPs. We are only using a single model and single simulations for each 

scenario. Compared to other models, CAM is more sensitive to C02 forcings and therefore produces stronger 

climate changes (Meehl eta!., 2013). However, climate studies have shown that projections of decadal-mean 

temperatures at the end of the 21st century for specific global regions can vary greatly between simulations 

of even a single model due to internal variability in large-scale oceanic and atmospheric dynamics (e.g., Oeser 

eta!., 2012), Hence, we expect that an ensemble of CESM simulations would provide a range of potential 

future smoke PM1.s concentrations and associated visibility and health effects. However, due to the computational complexity of the CAM-Chem simulations at the simulated resolution, we were only able to perform 

one set of simulations. Future work should consider ensembles of simulations. 

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Additionally, the model is limited by the processes that it is able to represent. While this study does use 

wildfire emission est1mates that were calculated with a land model (unlike many previous studies), the land 

model was not run dynamically/online in the CESM simulation of atmospheric concentrations. Therefore, 

there are potential land-atmosphere interactions that are not represented. Additionally, while the model 

was run at a relatively fine global resolution for a global chemistry-climate model, the grid spacing 

{~100 km) does not capture some important variability in concentrations relevant to the United States. At 

this resolution, model simulations tend to smooth out concentrations over broad regions and therefore cannot predict the high exposure concentrations often associated with dense smoke plumes or urban centers. 

Not only are there large uncertainties in the PM2 5 concentrations, but we are also limited in calculating the 

health burden by using the simple formulation give in equation (2). While this method is often used to provide estimates of the attributable premature deaths, studies can use different RR values, threshold values, and 

different formulations, or apply it to different resolutions of exposure estimates (i.e., grid level or country 

level), that can all lead to large uncertainties in the final numbers. A few examples were given in Table 1, 

but there is a large range in the RRs found in different epidemiology studies (see Ford & Heald, 2016). 

Additionally, we are assummg that the association between mortality and PM2 ~ remains constant over the 

study time period, irrespective of change in composition (we assume all PM2.s has the same toxicity), health 

care access, population activity, or other factors that might modify the relationship over time. The SSP1 and 

SSP3 population and mortality estimates are also model predictions that rely on many assumptions. 

While there are the uncertainties described above, our results do suggest that wildfire smoke will account for 

a large amount of the premature deaths associated with PM exposure in the future and could offset many of 

the health gains from reducing anthropogenic emissions, especially by the year 2100. Future work should 

include ensembles of simulations and combinations of coupled land-fire-atmospheric models with statistical 

fire projections to quantitatively map the range of uncertainties in future projections. 

5. Conclusion 

This study used CESM simulations of the early 21st century, midcentury, and late century surface PM2.5 to 

determine the potential impact of fires on visibility, exposure, and mortality in the CONUS. Unlike 

previous studies, these simulations used burn area determined from a land and fire model, which includes 

not only climate changes but also socioeconomic drivers. We looked at two scenarios for the future: the 

RCP4.5 scenario with SSP1 and the RCP8.5 scenario with SSP3 to provide the first estimates of future smoke 

visibility and health impacts from model simulations using emissions determined from a prognostic 

fire model. 

Here we show, as other studies (e.g., Spracklen et al., 2009; Yue et al., 2013) have shown, that wildfire emissions will likely increase in the United States in the middle and late 21st century, while U.S. anthropogenic 

emissions will continue to decrease. However, unlike previous studies that focused on the western United 

States, our simulations suggest that there will also be significant increases in fire emissions in the southeastern United States. Our unique result could also be due to including population changes and assumptions 

about afforestation and deforestation in our simulations as discussed in section 3.1. Additionally, these 

previous studies mainly relied on parameterizations determined from statistical regressions of current day 

conditions while we are using a land fire mode!, which could explain these discrepancies. Therefore, while 

we are only presenting one set of simulations, these differing results do suggest that more work needs to 

be done us1ng models that better account for feedbacks between climate, land use, and emissions to understand how the statistical relationships between these variables might change under different scenarios to 

alter fire regimes. 

In many regions, the decrease in anthropogenic emissions will lead to a decrease in PM2.s concentrations, visibility, population-level exposure, and associated premature deaths, However, in some regions of the United 

States, the potential improvements will be partially offset by increases in wi!dflre emissions. Results from the 

CLM suggest that BC and OC emissions from fires will double with the largest changes in the western United 

States, along the Canadian border, and in the southeastern United States. By 2100, both the RCP4.5 and 

RCP8.S scenanos suggest that fire-related PM will account for more than SO% of the annual average PM 2 s 

concentration in the CONUS. This wi!J be due to both local flres and transported smoke. Smoke 

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transported from outside the CONUS (AKJH!/Mex!co/Canada} could account for >50% of the fire-related PM 

in the Great Plains and Northeast regions in the RCP8.5 scenario. 

Most of our results are for the decada! average, but wildfire smoke tends to be seasonal with large daily variability. Therefore, when looking at visibility, we saw that while the average visibility wiJ! improve, the visibility 

on the worst days could get even worse, particularly in the western United States, southeastern United States, 

and northeastern United States. We project that wild tire smoke wil! be the main cause of visibility degradation on the worst days in these regions. 

Previous studies have quantitatively determined relationships between PM2.

5 exposure and premature 

deaths. Using these relationships, we calculated the burden for the early 21st century and future scenarios. 

We found that approximately 138,000 deaths (5.1% of total deaths) are attributable to total PM;ts in the early 

21st century with 17,000 (0.7%} of these deaths attributable to fire-related PM2.

5 . The number of total deaths 

attributable to PM2 5 is projected to decrease in both scenarios over the next century, but the number attributable to ~re-related PM will increase to 42,000 (1.4%, RCP4.5) or 32,000 (1.0%, RCP8.5) by 2050 and 32,000 

(1.1%, RCP4.5) or 44,000 (1,8%, RCPB.S) by 2100. 

Fires are potentially less controllable than urban and anthropogenic emission sources, and although there has 

been increased efforts to better manage fuels and forests in the United States to reduce wildfire risk, the number and intensity of wildfires has continued to increase. This is in large part due to the fact that fire frequency 

and mtensity are strongly !inked to the climate. While it is difficult to confidently determine how much the 

health burden could be reduced under a future climate with an RCP4.S scenario compared to an RCP8,5 scenario (and decoupled from the changes in population) from our limited set of simulations, mitigation of climate change that could lead to a less warm and dry future climate should reduce the potential tire risks. In 

our simulations, we also saw that population changes had an impact on our exposure and mortality estimates, 

and more people are currently moving into the wildland-urban interface in the western United States, leading 

to a greater risk of wildfire smoke exposure. Additionally, both the RCP4.5 and RCPB.S scenarios suggested 

that while the overall PM25 health burden would decrease, the fraction attributable to smoke exposure could 

increase in the future. Therefore, to continue to reduce the health burden associated with PM2.

5 in the CONUS, 

more emphasis will need to be put on reducing fire-related PM exposure through public health campaigns 

(installing filters, creating clean air shelters, etc) in conjunction with climate mitigation efforts. 

References 

17 
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GeoHealth 1 0.1029/201 BGH000144 

Hand, J. L, Schichtel. B II,, P•tchford, M., Maim, W. C., & Frank, N. H.1201 ::').Seasonal compomwn of remote and urban line particulate m~tter 

FORD ET Al. 18 
156 


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FORD ET AL. 

GeoHealth 10.1029/2018GH000144 

v~n Vuuren, 0. P., Edmond>, .1., Ka1numa, M., f{iah!, K., fhomson, A., Hibbard, K., et al. {2011). The RepresentatiVe Concenrrat10n PathwJys: An 

overvlew.Chmatu:Chonge, 109(1 2),5 3\. https//dOJ.Org/10.1007/s10584·011·0148·<: 

).atmoserw.2013.06.003 

19 
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we wuu tswp Lan1unua s wuuures 11 we aon r mH<-aoout cnmate cnange- l nc wasn1ng ... rage 1 or j 

The Washington Post 

The Post1

s View Opinion 

We won't stop California's ~wildfires if we don't talk about 

climate change 

By Editorial Board 

AugustS 

CALIFORNIA, THE nation;s .most populous state and the ·world's fifth-largest economy, is on 

fire. In a state already knovm for .monster conflagrations, the past month has been unusually 

destructive. The Mendocino Complex fire north of San Francisco is now officially the largest in 

California's histoi}', having burned an area aboutthe size of Los Angeles, and it is just one of the 

major blazes the state has had to face since last October. 

President Trump tried to lay the blame on "bad environmental laws" and wasted water, claims 

that expe1ts quicldy debunked. The 14,000 tlrefighters on the ground do not lack for water; they 

are battling blazes next to big lakes and other major bodies of water. The state's big rivers have 

not been "diverted into the Pacific," as Mr. Trump claimed; theyflowinto the ocean as they 

always have, though with large amounts sent to cities and farmland for human usc. 

Should even more of that water be taken to keep wild plants and soil moist, and therefore more 

resistant to fire? That wouldn't work. "Even if you built a massive statewide sprinkler system 

and drained all of our natural water bodies to operate it, it wouldn't keep up ""ith evaporation 

from warmer temperatures from climate change," University of California at Merced professor 

LeRoy Westerling explained to NPR. 

As much as the president might prefer to point fingers elsewhere, it is impossible to talk about 

California's blazes without considering the role of climate change. Four of lhe five largest 

conflagrations the state has had to battle have come since 2012, according to the Los Angeles 

Times, and that is probably no mere coincidence. Drought~. storms and heat waves have 

occurred throughout history, of course, and it is hard to attribute any single event to climate 

c.hange. But scientists have concluded that climate change has increased the freql!ency of 

extreme weather and will continue to do so. 

In California, a half-decade-long drought was~followed by swamping winter rains in 2016 and 

2017, which encouraged rapid plant growth. Then, intense heat last summer dried out the land. 

That resulted in massive fires .last October. Come July, triple-digit heat once again fueled huge 

blazes, as arid land senred as an ideal tinderbox. The state may offer an alarming taste of the 

troubles to come. 

https://www.washingtonpost.com/opinions/we-wont-stop-califomias-wildfrres-if-we-dont-t... 9/13/2018 
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We won't stop Califomia's wildfires if we don't talk about climate change- The Washing ... Page 2 of3 

Even after major periods of rain, uninterrupted high heat can produce arid conditions quiddy, 

and arid conditions lead to big fires. A 2016 study published in the Proceedings of tbe National 

Academy of Sciences concluded that human-caused climate change is responsible for about half 

the additional drying that researchers have found since the 1970s, resulting in a doubling of the 

area forest fires have consumed since 1984. Climate change may also increase lightning strikes, 

which are a major source of "Wildfires, and generate the high winds that can drive big blazes. 

Meanwhile, earlier springtime melting means that the land has more time to dry out over the 

warmer months. Global warming will incre<tsingly prime the environment for spect,1cular 

disasters. 

Addressing global warming and hiring more firefighters are obvious responses; the federal 

government should also prepare to spend more money in disaster relief. Yet, pumping cash into 

ever-more firefighting is in part howforestfires got so bad in the West. So much of the U.S. 

Forest Service's budget has gone to firefighting that too little has been left !or care and 

restoration. Lawmakers should examine the many ways they can help prevent another summer 

like "this one - or worse. 

Read more: 

Peter Gleick: Trump's nonsense tweets on water and wildfires are dangerous 

David Arkusb and David Michaels: Climate change isn't just cooking the planet. It's 

cooking our workforce. 

The Post's View: There's still hope on global warming- if the world gets to work 

Robett J. Samuelson: Trump ignores the messy reality of global warming- and 

makes it a1l about him 

The Post's View: The practically cost-free way to slow global warming that Trump 

won't adopt 

01)e t\lru;~ington $lCJ51: 

The story must be told. 

Your subscription supports journalism that matters. 

httns ://www. washinvtonoost.corn/ anini ons/we-wont -stoo-califomias-wildfires-if-we-dont-t... 9113!10 18 
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9/13!2018 Trurnp Inaccurately Clatms Cal1fornia Is Wasttng Water as Ftres Burn The New YorK Ttmes 

~be ~c\u tforl\: ~itncs 

Trump Inaccurately Claims California Is Wasting 

Water as Fires Burn 

By Lisa Friedman 

Aug. 6, 2018 

In his first remarks on the vast California wildfires that have killed at least seven people and 

forced thousands to flee, President Trump blamed the blazes on the state's environmental policies 

and inaccurately claimed that water that could be used to fight the fires was "foolishly being 

diverted into the Pacific Ocean." 

State officials and firefighting experts dismissed the president's comments, which he posted on 

Twitter. "We have plenty of water to fight these wildfires, but let's be clear: It's our changing 

climate that is leading to more severe and destructive fires," said Daniel Berlant, assistant deputy 

director of Cal Fire, the state's fire agency. 

He and others said that Mr. Trump appeared to be referring to a perennial and unrelated water 

dispute in California between farmers and environmentalists. Farmers have long argued for more 

water to be allocated to irrigating crops, while environmentalists counter that the state's rivers 

would suffer and fish stocks would die. 

[For the latest updates on the Mendocino Complex Fire, read this story.] 

The president first addressed the fires late Sunday, writing on Twitter, "California wildfires are 

being magnified & made so much worse by the bad environmental laws which aren't allowing 

massive amount of readily available water to be properly utilized." He also referred to a debate in 

forest management about the effectiveness of removing trees and vegetation as a fire control 

method. 

On Monday, Mr. Trump expanded on his comments in another tweet, for a second time referring 

to water being diverted into the ocean. 

The remarks came hours after the White House declared the wildfires a "major disaster" and 

ordered that federal funding be made available to help recovery efforts. 

You have 3 free articles remaining. 

Subscribe to The Times 

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9/13/2018 Trump Inaccurately Cla1ms California Is Wasting Water as F1res Burn- The New York T1mes 

Is there a water shortage? 

California does not lack water to fight the Carr Fire and others burning across the state, officials 

said. 

Mr. Berlant of Cal Fire declined to speculate on the meaning of Mr. Trump's statement that water 

was not being "properly utilized." 

Asked about that line and the president's claim that water was being diverted into the Pacific, a 

spokesman for Gov. Jerry Brown, Evan Westrup, said in an email, "Your guess is as good as 

mine." 

The White House did not respond to requests for clarification on Mr. Trump's statement. 

William Stewart, a forestry specialist at the University of California, Berkeley, said he believed 

Mr. Trump was referring to the battle over allocating water to irrigation versus providing river 

habitat for fish. 

That debate has no bearing on the availability of water for firefighting. Helicopters lower buckets 

into lakes and ponds to collect water that is then used to douse wildfires, and there is no shortage 

of water to do so, Cal Fire officials said. 

California water regulators are preparing to negotiate how much water from the Sacramento-San 

Joaquin River Delta should flow to California's farms and how much should flow down the river 

and to the ocean to ensure fish have enough fresh water to spawn and hatch. The issue has long 

pitted environmentalists against the state's farming communities. 

During the 2016 presidential campaign, Mr. Trump took on the farmers' grievances in language 

similar to his tweets this week. 

"You have a water problem that is so insane, it is so ridiculous, where they're taking the water 

and shoving it out to sea," he said during a May 2016 campaign rally in Fresno. "They have farms 

up here, and they don't get water." 

Recently, California Republicans encouraged the Trump administration to weigh in on the issue, 

inviting Interior Secretary Ryan Zinke to the Central Valley to discuss water rights in the state's 

agricultural heartland. 

"It's a pretty big story, but it's got nothing to do with the fires," Mr. Stewart said. 

Does removing trees control fires? 

https:f!www.nytimes.com/2018/08/06/c!imate/trump-california-fire-tweets.htmt 214 
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9/13/2018 Trump Inaccurately Claims Californ:a Is Wast1ng Water as Fires Burn- The New York Times 

Mr. Trump raised another issue when he wrote that officials "must also tree clear to stop fire 

spreading!' Scientists and forest experts said the president was referring to a valid and 

continuing debate. 

The timber industry has argued that "thinning" forests- removing certain trees to improve the 

health of the remaining ones and diminish the plants and underbrush that fuel fires- reduces the 

risk of wildfires. Republicans in Congress have sought to loosen environmental restrictions to 

allow more thinning. Democrats and environmentalists argue the practice will open the door to 

expanded commercial logging and threaten wildlife. 

California already has policies in place to address wildfire risk. 

LeRoy Wester ling, a management professor at the University of California, Merced, who studies 

wildfires, said that Mr. Trump's statement about fire-control efforts hit on an important issue, but 

that he wrongly placed the blame on California. Professor Wester ling noted that while federal 

funding for lowering wildfire risk has been tied up in budget negotiations, California has allocated 

$256 million this year. 

That money is coming from a source the Trump administration finds troublesome: revenues from 

California's program to reduce planet-warming greenhouse gases. Under its market-based 

approach for curbing carbon emissions, California sets a ceiling for the total amount of carbon 

that can be emitted. Companies are then required to obtain permits to release carbon into the 

atmosphere. 

The Trump administration opposes federal efforts to address climate change. 

California is "spending millions and millions of dollars on this while the federal government is 

sitting on its hands," Professor Westerling said. "And all that money is being raised because we're 

putting a price on carbon." 

What about climate change? 

Scientists noted that Mr. Trump's statement didn't address the role climate change has played in 

creating a hotter and drier fire season. The president in the past has dismissed climate change as 

a hoax and his top cabinet officials have questioned the established science that rising global 

temperatures are caused by human activity. 

Michael F. Wehner, a senior staff scientist at Lawrence Berkeley National Laboratory, said it was 

not possible to quantify precisely the likelihood that climate change is having an impact on forest 

fires, as can now be done with other extreme-weather events such as heat waves. 

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9/13/2018 Trump Inaccurately Cla1ms Califorma Js Wastmg Water as Fires Burn- The New York T1mes 

And, he said, it's not easy to weigh how much of the problem can be laid at the feet of forestmanagement practices. However, climate change is making summers longer and drier, which 

expands the wildfire season. 

"To dismiss the role of climate change on these fires is simply incorrect," he said. 

California fire officials on Monday said the Carr Fire in Shasta County had ravaged more than 

160,000 acres while the Mendocino Complex fires grew overnight and had charred more than 

273,000 acres across Mendocino, Lake and Colusa counties. 

The White House's disaster declaration ordered federal funding be made available to help 

recovery efforts. "Assistance can include grants for temporary housing and home repairs, lowcost loans to cover uninsured property loses and other programs to help individuals and business 

owners recover from the effects of the disaster," a White House statement said. 

A version of this article appears in print on Aug. 7, 2018, on Page A13 of the New York edition with the headline: Trump Inaccurately Claims California !s Diverting 

WaterFromF1res 

https:!lwww.nytimes.com/2018/08/06/c!imateltrump~catifornia-fire~tweets.lltml 414 
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9113/2018 Fueled by Climate Change, Wildfires Erode A1r Qual!ty Gams- Sc1ent1f1c Amencan 

SHARE LATEST 

PUBLIC HEALTH 

Fueled by Climate Change, Wildfires Erode Air Quality 

Gains 

~ueh fire.'i are causing spikes in fine particles that threaten human health 

By Scott Waldman, E&E News on July 17,2018 

https.//www.sclentiflcamerican.com/articte/fueled-by-climate-change-wildfires-erode-air-qua!ity-gains/ 1/11 
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9/13!2018 Fueled by Climate Change, Wt!dftres Erode Atr Quality Gams- ScJenttftc Amencan 

Ventura, Callfornia during Thomas Fire in December, 2017, Credit: AI Seib Getty Images 

ADVERTfSB.MENT 

Fourteen years ago, University of Washington researcher Daniel Jaffe installed an air 

pollution monitor on a mountainside outside Eugene, Ore. 

His intention was to measure pollution levels, with a particular focus on tracking 

emissions from China that drift into the United States in the spring. But in recent 

years, the monitor has unexpectedly produced a second and more urgent data set: 

tracking fine particle pollution from \\ildfires in the western United States. 

"We spend more of our time not worrying about what's corning across the ocean but 

worrying about what's coming here," he said. 

https /!v.;ww.sctentiflcamencan.comtarttcle/fue!ed-by-dimate-change-wildftres-erode-air-quality-gains/ 2/11 
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9/13/2018 Fueled by C!1mate Change, Wlldf1res Erode Atr Quality Gams- Scientific Amencan 

Climate change is not just increasing the likelihood of wildfires in some areas of the 

country; it's also erasing decades of air pollution gains in those same regions, 

according to a study published yesterday in the Proceedings of the National Academy 

of Sciences. It shows that wildfires are causing a spike in air pollution across the 

West. 

https·/fwvvw.sclentificamerlcan.com/articleffueled-by-climate-change-witdfires-erode-air-quality-gains/ 3/11 
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9/13/2018 Fueled by Climate Change, W1ldf1res Erode A1r Quahty Gams- ScientifiC Amencan 

A man walks along Ventura Ave. in Ventura, Ca!lforni.'l during the Thomas Flre in December, 2017. 

Credit: ,:,:o:::.:L:':c'.::::L~::.:L.::,:··.:"·'" 

Global warming creates conditions that feed wildfires, It has led to earlier snowmelts 

in the West, increased temperatures in summer and spring and drier conditions, 

research shows. That bas sparked more frequent wildfires that last longer. And that 

increase in wildfires has increased fine particle air pollution, according to the study. 

In the United States, fine particulate matter (PM2.5) is generated by coal-burning 

power plants, automobiles and the manufacturing sector, arnong other sources. 

PM2.5 refers to tine particulates that are no more than 2.5 microns in diameter, or 

one-thirtieth the width of a human hair. 

EPA's N a tiona! Ambient Air Quality Standards have been successful at lowering 

human-caused PM2.5 standards across the country for years, researchers found. A 

2017 study found that reducing fine particle pollution even slightly could save 12,000 

lives annually, pa1ticularly among vulnerable populations such as the elderly and 

people with asthma. 

https·f/wwvv.scientificamerican.com/article/fueled-by-climate-change-wildfires-erode-air-quality-gains/ 4/11 
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9/13/2018 Fueled by Climate Change. Wildfires Erode Air Quality Gams- Scientific Amencan 

"These findings suggest that lowering the annual NAAQS may produce important 

public health benefits overall, especially among self-identified racial minorities and 

people with low income," that study said. 

The new research shows that natural factors, exacerbated by human-caused climate 

change, may have more of a role in declining air quality than previously realized. 

Wildfires in Montana last year caused a spike in PM2.5, Jaffe said. Monitors picked 

up the highest levels of air pollution ever recorded in the United States during August 

and September in Montana. And climate change is likely to drive similar events in the 

future, mostly in the summer and in Western states plagued by more frequent fires, 

he said. 

In some areas of the United States, fine particles from wildfires are driving a second 

round of pollution events. Weather patterns in the winter can see cold air mass 

entrapped under warm air, which snares fine particles and raises air pollution levels. 

Both Utah and Fairbanks, Alaska, typically record high levels of air pollution in the 

winter, but wildfires are driving a second spike in PM2.5levels in the summer. 

https //www.scientiflcamerican.com/article/fueled-by-climate-change-wildfires-erode-air-quality-gains/ 5/11 
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9/13/2018 Fueled by Climate Change, Wildfires Erode Air Quality Ga1ns- ScientrflcAmencan 

PM2.5 is detrimental to human health. It affects the lungs as well as the hea1t, 

according to EPA. It can aggravate asthma, decrease lung function, and lead to 

premature death in people with lung and heart disease. 

Clean Air Act regulations have targeted PM2.5. Controls on coal-burning power 

plants and other sources of pollution have yielded significant reductions of pollution 

for years. Nationally, the amount of fine particle pollution has dropped 42 percent 

since 2016. However, researchers found that emissions have increased in parts of the 

country where 1\ildfires are concentrated. 

Scientists examined data from rural monitoring sites. They found increases in PM2.5 

in all or parts of Montana, Idaho, Oregon, California, Nevada, Utah and Wyoming. 

Tfley found an increase for total carbon, whicfl indicates wildfire emissions, in the 

Northwest. By contrast, the rest of the country saw decreasing total carbon, 

researchers found. 

"If you've been out in the West at all in the last few years, we've just seen more and 

more fires and bigger fires, so that was why we went looking for it," Jaffe said. "I 

https //www.scientiflcamencan.com/artic!e/fueled~by*clirnate-change-wildfires-erode-air-quality-gains/ 6/11 
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9!13/2018 Fueled by C!1mate Change, Wildfires Erode Air Quality Gains- ScJentlflc Amencan 

guess what surprised us was the geographic extent over which we could really pull out 

a statistically significant increase." 

The results show that fine particle pollution from wildfires may be worse than 

researchers have realized, Jaffe said. What's more, they come as EPA has proposed a 

new science transparency rule that would restrict the use of key air pollution studies 

in crafting regulations. Critics have noted that the proposed transparency rule would 

exclude future consideration of a landmark 1993 Harvard University air pollution 

study-the "Six Cities" paper-that has been used to back air regulations for decades. 

Jaffe said snowpack has a direct effect on the wildfire season, especially if the snow 

extended into late June and early July and kept the soil wet. In addition, insects such 

as the pine bark beetle haw damaged millions of trees, prO\-iding fuel for bigger fires 

that last longer, he said. Still, he cautioned that climate change is a threat multiplier 

for wildfire season but that forest management issues have also played a significant 

role in driving wildfires. 

"We want to be careful not to put it all on climate change, but climate change is 

clearly a contributing factor, and particularly in the size of these fires," he said. "A fire 

that used to become a small fire has now become a massive conflagration." 

https /fww.N.scientiflcamerican.com/artide/fueled-by~climate-change-wildfires-erode-air-quality-gains/ 7/11 
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9/13/2018 Fueled by Climate Change, Wildfires Erode Air Quality Ga1ns- Scientific Amencan 

With fine particle pollution from ·wildfires increasing, it may need even more 

consideration by future regulators, said Gannet Hallar, an atmospheric scientist at 

the University of Utah who was not involved in the study. She said it shows that the 

highest-polluting wildfire events are intensifYing. 

"The really important point of this paper is that these events, although episodic, are 

increasing in their intensity," she said. 

Reprinted from C/imatewire wilh permission from E&E News. E&E provides daily 

coverage of essential energy and environn1ental news at _W1!!,~~.~.0.?.!!g_~~!.:'!.·?::.~t 

ABOUT THE AUTHOR(S) 

Scott Waldman 

Recent Articles 

l\s C!lmate Scientists Speak Out Sexist Attacks Are on the 

Coming Soon: Acting EPA Administrator's First Moves on Science 

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E&E News 

Recent Articles 

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Want a Carbon Tax? Wait Until Next Year, Advocates Say 

This Federal Lab Works to Make Cars More Efficient, as Trump Pumps the Brakes 

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9/13/2018 Fueled by C!tmate Change, Wildfires Erode Atr Quality Gams ~ Sctenttfic Amencan 

LATEST NEWS 

POLICY & ETHICS 

Don't Condemn People who Don't Evacuate for 

Hurrieane ~1orence 

McKinnon 

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Space Station Commander: It's "Absolutely a Shame" 

Suggest Astronauts Caused Leak 

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North Carolina's Natural Hurricane Defenses Are 

Disappearing 

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7 Ways to Let Go of Guilt 

5 hours ago -· Savvy Psychologist Ellen Hendriksen 

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9/13/2018 Fueled by Climate Change, W!ldfires Erode Air Quality Gams w SctentifJc American 

NATURAL DISASTERS 

Health Oftlcials Rush to Protect Seniors, the Most 

Vulnerable Group, from Hurricane Florence 

Szabo, JoNe1 Alecc1a, STAT 

MEDICAL & BIOTECH 

Study Cracks Open the Secrets of Genetie Mutations 

That Boost Breast and Ovarian Cancer Risk 

STAT 

NEWSLETTER 

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9/13/2018 Fueled by Climate Change, W1!dfires Erode Air Quality Gams • Sc1entlfic American 

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MEGAFIRES 

THE GROWING RISK TO AMERICA'S 

FORESTS, COMMUNITIES, AND WILDLIFE 

Copyright© 2017 National Wildlife Federation 

Lead Authors: Shannon Heyck-Wi!liams, Lauren Anderson, and Bruce A. Stein. 

We appreciate the work and dedication to conservation of all National Wildlife Federation staff and 

our affiliate partners, who help make efforts like this possible. In particular, we would like to thank the 

following for their contributions to this report: Chris Adamo, Mitch Friedman, Patty Glick, Mike Leahy; 

Jim Lyon, Jim Murphy, Collin O'Mara, Josh Saks, and Tiffany Woods. 

Suggested citation: Heyck-Williams, S., L. Anderson, and BA Stein. 2017. Megafires: The Growing Risk to 

America's Forests, Communities, and Wildlife. Washington, DC: National Wildlife Federation. 

Cover image: Blackha!l fire, Wyoming, 2000. Photo: Kerri Greer 

The National Wildlife Federation is the education partner for Years of Living Dangerously, an Emmywinning climate change film series. You can learn more about wildfires and dimate change science with 

our lesson plans, videos, and resources on wwwclimatecbssroom.org. 

Megajlres is available online at: \NW\VJ1wf.orgjmegafires-report 

National Wildlife Federation 

1200 G Street, NW, Suite 900 

Washington, D.C. 20005 

www.nwf.org 
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36422.132

BLE OF CONTEN S 

PRESIDENT'S LETTER 

MEGAFIRES A GROWING THREAT .. 

MORE, BIGGER, AND HOTTER FIRES. 

HOW CLIMATE CHANGE INCREASES THE RISK OF MEGAFIRES. 

FROM FIRES TO FLOODS. 

BEETLE INFESTATIONS CAN AMPLIFY FIRE RISK .. 

MORE HAZE FOLLOWS MEGAFIRES 

A GROWING THREAT IN THE SOUTHEAST. 

RE-ESTABLISHING NATURAL FIRE REGIMES .. 

ADDRESSING THE MASSIVE FOREST RESTORATION BACKLOG 

FIXING THE FEDERAL FIRE BUDGET 

RECOMMENDATIONS. 

REFERENCES 

2 

..3 

5 

7 

8 

9 

. .. 10 

11 

13 

15 

16 

18 
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PRESIDENT'S LETTER 

As I write this, explosive wildfires are raging across nearly 200,000 

acres in northern California, devastating communities and pushing the 

total area burned in 2017 to more than 8.5 million acres nationally. 

Although wildfires are a natural and essential feature of many forest 

ecosystems, there has been a dramatic increase in recent decades of 

unusually large and severe "mega fires." There are multiple reasons for this increase in extreme wildfires. Changing 

climatic conditions-including earlier onset of spring, earlier snow melt, hotter summer temperatures, and prolonged 

drought-are reducing moisture levels in soil and forest vegetation. The spread of pest species like bark beetle, often 

facilitated by a changing climate, is weakening the resilience of many natural ecosystems. And seriously overgrown 

forests, resulting from years of fire suppression and coupled with insufficient resources and bureaucratic obstacles for 

proactive forest management and restoration, have created conditions that are ripe for explosive mcgafires. 

Fighting wildfires is now devouring more than half of the U.S. Forest Service budget, depriving the agency of critical 

resources for restoration and improved forest management that would reduce ongoing fire risks. In recent years 

the agency has been spending more than $1 billion annually to fight wildfircs,1 and in 2015, one of the worst years 

for wildfires on record, the U.S. government as a whole spent more than $2.6 bi!lion2-a record that we arc poised 

to match this yea:r: Despite increasing fire activity and escalating costs, Forest Service wildfire budgets are based on 

historical averages rather than future projections. As a result, as fire season progresses and budgeted wildfire funds 

are exhausted, money is shifted ("borrowed") from other activities, including recreation, wildlife management, and 

forest restoration. But in contrast to hurricanes, tornadoes, and major floods, disaster funds arc not available to cover 

the exceptional costs involved in fighting these catastrophic megafires. 

The social, economic, and ecological costs of these mcgafires has been devastating. Communities have lost thousands 

of buildings, suffered tens of billions of dollars in damages, and, tragically, people h;,we died. Waterways and other 

habitats have been degraded, imperiling fish and wildlife. Tens of millions of tons of climate-altering carbon dioxide 

have been released. Unfortunately, current wildfire policy is woefully insufficient to address this urgent crisis. 

Our nation needs bipartisan Congressional leadership to fix the forest fire funding crisis and ensure adequate 

funding for restoring forests and appropriately fighting wildfires. We must accelerate the pace of forest restoration 

by promoting outcome-dlivcn, collaborative processes, by expanding the use of prescribed fire, and by improving 

environmental review of beneficial restoration projects. We must boost the resilience of our forests and communities, 

discouruge development in fire-prone areas, and prioritize fire risk reduction in the wildland-urban interface. And, 

Congress must confront the underlying causes of climate change that are exacerbating the wildfire crisis by ensuring 

sufficient funding for climate research and reducing cl!mate-altcring pollution. 

The time for bipartisan action is now. 

Collin O'Mara 

President and CEO 

National Wildlife Federation 
178 


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MEGAFIRES: A GROWING THREAT 

ildfirc, like actors in a Greek drama, has 

Gvo opposing faces: one of destruction 

and another of rejuvenation. Scenes 

of smoldering forests and burnt-out homes vividly 

illustrate the destructive force of uncontrolled 

wildfires, Paradoxically, many U.S. fm·ests <:~re not only 

adaptt'd to burn periodically, but actually depend on 

fire for their rejuvenation, maintenance, and health. 

Consequently, forest and wildfire management is and 

always has been an extraordinarily complex and high 

stakes issue, which rapid climate change is making even 

more challenging. In particular, the increase in large, 

intensely hot "megafires'' not only poses increased risks 

to local communities and economies, but has the ability 

to permanently transform the eco!:>)'stems and habitats 

through which they burn, with profound implications 

for wildlife. 

The current crisis in wildfire and forest management 

has its roots in three interacting dynamics: the legacy of 

past forest management Jnd fire suppression; dramntic 

increases in housing development in the fire-prone 

wlldland-urban interface; and rapidly changing climatic 

conditions. Reducing risks from megafires will require 

that we address each of these underlying problems, 

including: scaling up efforts to tackle the massive 

backlog in forest restoration; encouraging more 

responsible and fire-wise development in wildland 

areas; and confronting climate change both by reducing 

greenhouse gases and by incorporating climate 

considerations in forest management and restoration, 

What is most urgently needed, howevec is to fix the 

broken feder<:~l budget process for fighting wildfires, 
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36422.135

MORE, BIGGER, AND HOTTER FIRES 

or several years California and other parts of 

the West have been in a severe and sustained 

drought, and the La Nii'ia weather of last 

winter was anticipated to reduce the risk of severe 

wildfire in the region by bringing more rain and snow 

Intense summer heatwaves, however, countered muny 

of the expected benefits, and the explosive growth of 

annual grasses stimulated by winter rains may have 

even added to the fire risk These conditions set the 

stage for the deadly wildfires now scorching nearly 

200,000 acres across California and devastating many 

local communities. Indeed, 2017 is on track to be one of 

the most active years for US. wildfires on record, with a 

total of 8.5 million acres burned, and more than 21,000 

firefighters assigned to wildfires in 10 western states.3 

Over 1.2 million acres have burned in Montana alone:1 

The Lolo Peak fire has burned over 50,000 acres, 

covering much of the surrounding areas in Montana 

and Idaho with smoke. The Lodgepole Complex and 

Rice Ridge fires have also scorched hundreds of 

thousands of acres in Montana. In California, a state of 

emergency was declared for Los Angeles County as the 

La Tuna fire blanketed an area near Burbank, requiring 

over 1,000 firefighters to protect the heavily populated 

area." In Oregon, the Eagle Creek wildfire has burned 

nearly 50,000 acres across the iconic Columbia River 

Gorge. 6 In Washington State, the Diamond Creek fire 

has charred over 125,000 acres.7 

These fires not only affected large areas of wildlife 

habitat, but have had direct implications for 

wildlife managers and their efforts to restore key 

wildlife populations. In Washington State, for 

instance, biologists raced to rescue a population of 

endangered pygmy rabbits as the Sutherland Canyon 

fire threatened to overtake their captive breeding 

enclosure. 11 Thick smoke and the threat of new fires 

in Montana forced federal wildlife managers to 

postpone the annual roundup at the National 

Bison Range.q Western wildfires in 2017 have also 

had serious impacts on people and communities, 

blanketing cities in ash, and in many areas making the 

air dangerous to breathe. 
180 


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With massive fires continuing to cover the West, 

experts are observing some disturbing trends. There 

is strong evidence that regional warming and drying 

in the western United States is linked to increased fire 

frequency and size, as well as to longer fire seasons. w 

The U.S. Forest Servlce, for example, has concluded that 

fire seasons are now on average 78 days longer than in 

1970. 0 The area of forest burned annually in the Pacific 

Northwest has increased by nearly 5,000 percent since 

the early 1970s, while the area burned in the Southwest 

has increased by nearly 1,200 percent. 11·

13 

It is not only the frequency and size of fires that are 

changing, but also their intensity and severity. Indeed, 

more, bigger, and hotter wildfires are becoming the 

new normal. Extreme fire behavior-characterized by 

rapid fire spread, intense burning, prolific crowning, 

strong convection columns, and unpredictable 

shifts-not only can have serious ecological effects, 

but increasingly puts wildland firefighters at risk 

Decades of fire suppression has in many places 

prevented smaller, less-intense surface fires that help 

to naturally thin forests. As a result, many forests have 

grown so dense that once ignited, flames quickly climb 

understory "ladder fuels" and set the tree canopies 

ablaze. Crown fires can burn so hot they have the ability 

to create their own weather, spreading the fire ever 

further and hindering control efforts. Complicating 

matters more, there has been an increase in the number 

of human-caused wildfire ignitions, due in part to the 

dramatic expansion of housing into the wildland-urban 

interface. Nearly 45 million housing units are now in 

naturally fire-prone wildland areas,~'~ and one study 

estimates that human-caused ignition is responsible for 

04 percent of all U.S. wildfires.15 

Rather than leaving a tapestry of burned and unburned 

areas, which facilitates forest regeneration and 

provides a diversity of habitats for wi!dHfE<, ultra-hot 

megafires can destroy complete forest stands and burn 

across entire landscapes. If hot enough, extreme fires 

can even sterilize the soil by killing subsurface seed 

banks that normally aid in post-fire recovery. Indeed, 

forests in some places may never recover from these 

fires and instead be permanently transformed into 

shrub!and or grasslands. 16 For example, in 2011 the Las 

Conchas fire in New Mexico burned more than 156,000 

acres of forest and scrubland, one of the largest fires 

in the state's history. The fire burned so intensely 

that only bure dirt and tree stumps were left in many 

places, and some burned areas will probably never 

revert to forest 17• w 

An increase in the frequency of wildfire events can 

also lead to the long-term conversion of forests and 

other wildlife habitats by enabling the expansion 

of non-native invasive species. 19 Many invasive 

plants are able to rapidly colonize disturbed areas, 

often outcompeting native species. For example, in 

northern Nevada and elsewhere in the Great Basin, 

burned sagebrush ecosystems, on which sage grouse 

and migrating mule deer depend, often convert to 

grasslands dominated by invasive cheatgrass, which 

has little wildlife value. Unfortunately, cheatgrass also 

provides the type of fine fuel that promotes even more 

frequent wildfires in these areas, leading to permanent 

conversion from native sagebrush steppe habitat to 

invasive grassland.2° This conversion is not only a 

major contributor to the decline of sage grouse, but 

also effects the many other wildlife that depend on this 

habitat type, including short-horned lizard, sharptailed grouse, pygmy rabbit, and Brewer's sparrow. 

Some wildlife may be able to adapt or even thrive in 

fire-altered or transformed habitats, or migrate to 

areas better supporting their needs. Others, though, 

will be negatively impacted either as an immediate 

effect of a large fire, or in the aftermath when food 

resources, water, or shelter are hard to come by, or 

their hnbitats are permanently lost. 21 
181 


36422.137

Wildfires in centml Idaho, 2013, Photo: NASA 

HOW CLIMATE CHANGE INCREASES 

THE RISK OF MEGAFIRES 

limate change increases the risk of 

more frequent and severe fire in several 

ways, Earlier spring sno11vmelt, higher 

temperatures in spring, summer, and fall, and increases 

in evapotranspiration, all contribute to drying of 

vegetation, and extend the geographic area and time 

periods in which forests become combustibleY 

These changing climatic conditions have resulted in 

wildflre seasons becoming longer, particularly in the 

western United States. In parts of California, fire 

season is now 50 days longer than in 1979/~ while 

Alaska moved its official fire season, defined as the 

date permits are required for burning residential 

yard and other refuse, from May to April. 24 With fires 

burning both earlier and latet; some places may even 

start experiencing what has been called "year-round 

fire season." 

Higher temperatures and extreme drought can 

trigger tree stress and mortality, which can 

0 million trees died during 

e recent prolonged drought. And 

induced stress can exacerbate 

outbreak<; of forest pests, such 

as bark beetles, which can also 

increase the susceptibility of forests to wildfire. ~ 

Drought conditions can also contribute to super-hot 

fires that produce more lasting damage, where high 

temperatures penetrate deeper into soils and prevent 

seeds from germinating once the fire is over. 

Although there are multiple reasons for the overall 

increase in wildfire activity, researchers have concluded 

thut over the past few decades climate change has 
182 


36422.138

caused more than half the increase in fuel a tidily, and 

is responsible for a doubling in the cumulative forest 

area burned. 26 Looking to the future, researchers projeti: 

that climate change will increase the potential for very 

large fires, both through increasingly frequent conditions 

conducive to these fires (Le., changes in temperature, 

precipitation, and relative humidity} and through 

lengthening of the seasonal window when fuels and 

weather support these fires.n.zs 

Not only does climate change increase 

the risk of extreme fires, but mega fires 

in turn contribute to the underlying 

cause of climate change through the 

release of large quantities of carbon into 

the atmosphere. ln Washington State, for instance, wildfires 

were the second largest source of carbon dioxide emissions 

in 2015, behind only the transportation sector:29 Although 

wildfires always release carhon, the amount released 

through most low intensity fires typically is offset in 

subsequent years by vegetation regrowth and recovery in 

the burnt area.ln contrast, the massive amounts of carbon 

released by mega fires, coupled with declines in the capacity 

of the landscape to recover, may in some instances lead to a 

shift from carbon "sink" to carbon "source," lO 

Researchers have concluded that 

the past few decades climate 

has more half 

the increase in fuel aridity, and 

responsible far in the 
183 


36422.139

FROM FIRES TO FLOODS 

ecause severe fires can burn away much 

of the vegetation that holds soil in place and 

retains run-off, when the rainy season 

returns there is often an increased risk oft1ooding 

below the burned area. For example, the 2010 

Schultz fire burned just over 15,000 forested acres 

above Flagstatl Arizona and caused the evacuation 

of hundreds of homes. Monsoon rains following the 

fire caused heavy flooding that resulted in extensive 

property damage in Flagstaff and took the life of a 

young girl. Overall, estimates of the total impact of the 

Schultz fire place the cost between $133 million and 

$147 million. These costs are a heavy burden on rural 

communities, and to reduce the risk of future fire 

and flood disasters, the Flagstaff community passed 

a $10 million bond to finance vvi!dfirc control 

treatments throughout local watersheds, including 

on federal lands. ll 

damage 

Runoff from burned ureas can also 

result in soil and ash polluting streams 

and rivers. The ash can increase the pH 

level in water, and sediment can clog 

the gills of fish as well as destroy and 

degrade fish habitat. Studies in Arizonu 

show that the state fish, the Apache 

trout, can suffer severe population 

dcdines following major wildfires. 12 

life of a young girr 
184 


36422.140

Mountain pme beetle infestatiOn, Colorado. Photo: Hustvedt 

BEETLE INFESTATIONS CAN AMPLIFY FIRE RISK 

ire is not the only major, climate-amplified 

disturbance affecting U.S. forests. Bark 

beetles are naturally occurring forest insects 

that have reached unprecedented epidemic levels over 

the past two decades. Mountain pine beetle infestations 

in particular have caused significant tree mortality 

across millions of acres in the Rocky Mountains. These 

heetle outbreaks have been correlated with climatic 

changes, and especially warmer winter temperatures 

that allow more beetles to successfully overwinter:'·' 

Various species of bark beetles are 

also causing significant forest damage 

elsewhere in the U.S., including Alaska 

and the Southeast, and appear 

to be expanding their range due to 

warming conditions. Southern bark 

beetles, for instance, historically have heen restricted 

to pitch pine forests of the South, constrained by cold 

winters further north. That has now changed, and since 

2002 the beetles have damaged more than 30,000 acres 

afforest in New Jersey, and recently have been detected 

in forests as far north as Massachusetts:'·' 

In addition to the effect of rising winter and summer 

temperatures on beetle reproduction, drought 

conditions create water stress in forest trees and can 

make them more susceptible to bark beetle infestations. 

As large swaths of forest succumb to beetle infestations, 

beetle-killed trees can increase the risk of wildfires, 

particularly early in an outbreak when dead or dying 

needles are still on the trees.·(' Colorado, for example, 

has recently experienced the largest bark beetle 

outbreak in its recorded history, which left hundreds of 

thousands of trees dead and vulnerable to wilc\fire. 16 

In 2016, the Beaver Creek fire burned over 38,000 

acres and cost an estimated $30 million to contain.:n 

The fire was made more difficult to manage as it burned 

through beetle infested timber and dead trees. 

The combination of beetle kill and fire can have 

serious effects on native wildlife. As an example, the 

2016 Hayden Pass fire ln Colorado's Sangre de Cristo 

range burned through an area badly affected by bark 

beetles. This area contains streams that are the only 

knov.rn refuge for a unique and isolated population of 

cutthroat trout, which was only discovered by 

biologists in 1996. Fall monsoon rains after the 

fire washed significunt amounts of debris, ash, and 

sediment into the trout's habitat. Surveys following 

the fire and rains did not !ocate any remaining trout in 

Hayden Creek, and this unique trout might have been 

extirpated but for emergency rescue efforts following 

the fire that brought 158 of the fish into captivity for 

breeding and reintroduction.-w 
185 


36422.141

MORE HAZE FOLLOWS MEGAFIRES 

estern high country and wilderness It is not only remote and wild places 

are increasingly seeing the impacts of out West being impacted. Orban 

haze pollution from mega fires, obscuring areas are also being affected by 

the views westerners and visitors alike cherish. New these fires. In 2014, the Carpenter 

rese<~rch indicates that more frequent drought and 1 fire burned the landmark peak of 

wildfire are leading to increased haze in western states Mount Charleston 35 miles northwest 

as the fires produce a combination of small dust, soot, of Las Vegas. Smoke from the fire 

ash, smoke particles, and other air pollutants?" Small triggered a health advisory from the Clark 

particles are public health concerns <:IS they com lodge County Department of Air Quality that lasted 

deep within the lungs and cause respiratory and cardiac days and impacted the entire Las Vegas are.J.. 41 

distress and illness, and even premature death. li) 
186 


36422.142

A GROWING THREAT IN THE SOUTHEAST 

xtreme fires are not restricted to the 

arid West: the Southeast is also 

experiencing an increasing number of 

large ;:md intense blazes. Many southeastern forests, 

especially softwood pines, are fire-adapted and 

depend on relatively frequent, low intensity burns 

for their milintenance. 

A changing climate and 

associated periodic drought 

conditions, however, are 

contributing to much larger; more intense wildfires 

th<.~t can affect not just drier pinelands, but burn 

typically moist hardwood forests as welL Although 

the southeast is in general characterized by warm, 

humid climates, severe drought conditions, such as 

occurred in 2007 and 2016, are creating conditions 

ripe for major fires. Last yem~ some of the biggest fires 

in the Southeast were in Georgia and North Caro!ina, 42 

but the fire that caught the most national attention 

occurrC'd in Tennessee. This explosive fire started in 

Great Smoky Mountains National Park as a result of 

human activities, and quickly spread to the gateway 

towns of Gatlinburg and Pigeon Forge, Tennessee. 

The Gatlinburg fire burned 1,700 structures, caused 

14,000 to evacuate, and resulted in the death ofl4 

people, the deadliest the state has ever experienced.41 

Forecasting the long-term impacts of climate change 

in the Southeast is challenging because of variability 

in precipitation patterns across the region. It is dear, 

however, that summer and winter temperatures in the 

region are rising. This will increase evapotranspiration 

and make drought conditions more likely during 

periods of low precipitation, with consequent increase 

in wildfire risk.H 

Prescribed burns are an important and widely used 

mrmagement tool in the region, and are essential for 

maintaining and restoring the biologically rich longleaf 

pine forests, as well as for rebuilding populations 

of popular game species like bobwhite quail. To be 

effective and safe, these controlled burns must be 

carried out under particular weather conditions. 

Projected climate shifts are likely to shrink the 

availabiHty of those conditions and significantly 

constrain the capacity for wildlife and nutural resource 

managers to employ this essential tool for forest 

restoration and management. 
187 


36422.143

RE-ESTABLISHING NATURAL FIRE REGIMES 

hile fire is a natural process in most 

U.S. forests, there is wide variation in 

the natural fire regimes that characterize 

different forest types. Fire regime refers to a 

combination of factors, such as the frequency, intensity, 

size, pattern, season, and severity of burnsY As an 

example, many low-elevation ponderosa pine forests 

historically had a fairly frequent fire return interval 

(every 10~30 years), with low-severity surface fires 

that resulted in relatively open forest conditions.·16 

In contrast, northern Rockies lodgepole pine forests 

historically had long fire return cycles {often greater 

than 100 years), with high-severity, stand-replacing 

crown fires (as occurred, for example, in the 1988 

Yellowstone fires). Understanding natural fire regimes 

is key to evaluating forest restoration needs, since 

they provide a benchmark for determining the degree 

to which current forest conditions deviate from their 
188 


36422.144

"historical range of variability." Altered fire regimes, 

often due to long-term fire suppression, are a principle 

cause of elevated fire risk in many places, and 

re-establishing an area's natural fire regime can 

therefore be an important goal for forest management 

and restoration. 

Beginning in the early 1900s, Federal and State 

agencies began carrying out aggressive fire suppression 

polides in efforts to reduce the loss of economically 

valuable timber and to protect communities. The role 

of fire in maintaining healthy ecosystems was not well 

understood at the time, and just as with the unbounded 

predator control taking place during that same period, 

these management policies produced unintended and 

far-reaching ecological consequences. Lack of fire in 

many fire-dependent forests led to the build-up of 

flammable materials and significantly affected forest 

successional patterns and processes. Changes 

were particularly dramatic in areas where fires 

historical!y were relatively frequent and of low 

intensity. Increasingly overgrown conditions and high 

fuel loads elevated fire risk in many areas, leaving them 

ripe for the ignition and spread of high intensity and 

severe burns. 

Over the past forty years there has been an enormous 

amount of research on the fundamental role of fire in 

forest systems, resulting in an increased awareness and 

appreci;;~tion of fire as an essential natural process. This 

has been accompanied by major advances in efforts to 

re-establish natural fire regimes by putting fire back 

into these systems, as well as development of other 

ecological restor<1tion techniques designed to enhance 

forest health and resilience. 

Over the past forty years there 

enormous of 

research an the fundamental role 

in forest systems, 

essential 
189 


36422.145

ADDRESSING THE MASSIVE FOREST 

RESTORATION BACKLOG 

he scale of forest restoration needs is 

enormous. The US Forest Service estimates 

that between 65 and 82 mJlllon acres are 

in need of restoration just on lands within their 193 

million acre national forest and grasslnnd system<47 

There is, however, no "one size fits all" approach for 

forest restoration given the wide range of forest types, 

natura! fire regimes, and current watershed conditions. 

Rather, restoration and hazardous fuels reduction 

efforts must be firmly grounded in an understanding 

of the dynamics of particular forest types, take into 

account the local and regional ecological context, as 

well as the needs and concerns oflocal communities, 

industry, and other stakeholders. 

Reintroducing fire into systems through the use of 

prescribed or controlled burns is one of the most 

important restoration approaches, and there is a need 

to dramatically expand the appropriate application 

of this management tool. There are places, however, 

where fuel loads are simply too high or conditions too 

dangerous for prescribed burns to be safely used. In 

these instances hazardous fuel loads can be reduced 

through a variety of mechanical thinning techniques. 

Ecologically appropriate thinning usually emphasizes 

removal of small diameter trees and dense understory 

vegetation. Salvage logging, which focuses on post-fire 

harvesting oflarger-diametcr standing trees, 

is far more controversial. Although providing 

economic benefit, it should only be considered on a 
190 


36422.146

site~specific basis since the practice can have significant 

ecological impacts, and its effects on reducing (or 

even increasing) fire risk is actively debated.~ 49 Other 

forest restoration approaches include controlling 

invasive species, restoring streams, replacing 

undersized culverts, enhancing wildlife hahitat, and 

decommissioning old forest roads. 

In carrying out restoration and hazardous fuels 

reductions, it is also important to ensure that 

broader ecological and wildlife needs are taken into 

consideration. For example, many wildlife species 

depend on snags (standing dead trees) and downed 

woody deblis for different stages in their life cycles. 

Some species, such as the declining black-backed 

woodpecker, are almost entirely dependent on 

post-fire snags. 5° 

In an era of rapid climate change, forest restorJtion 

efforts increasingly will need to take future climatic 

conditions into account, rather than base management 

decisions on historical climatic conditions. An 

emphasis on climate adapt.LJ.tion and resilience in 

forest management will he especially important 

given the long life span of most tree species.5L 32 

PosHire recovery efforts, in particulai~ will need to 

carefully consider the species composition and genetic 

variability in plant materials used in restoration 

efforts in order to anticipate and prepare for changing 

temperature and predpit:ttion patterns and resulting 

shifts in habitat suitability. 

Given the enormous scale of restoration needs, it is 

also important to carefully target areas most in need of 

restoration and hazardous fuels reduction."'' In general, 

fuel reduction treatments will be most appropriate 

close to and around wildland communities, rather 

than in remote backcountry and wilderness areas. Not 

only is the wildland-urban interface where people and 

property are at highest risl< from \"Jildfire, but given 

the preponderance of human-caused ignitions, areas of 

high human activity are also some of the places most 

likely for fires to start. 5 4 

In recent years there has been considerable progress 

in addressing the massive forest restoration need, 

and the Forest Service currently is treating about five 

million acres a year, aided by a number of promising 

partnership programs. 5

5 The Collaborative Forest 

Landscape Restoration Program, for example, has 

worked with partners to reduce wildfire risk on 1.45 

ml!lion acres and improve wildlife habitat on 1.3 

million acres. 56 This innovative program was created 

to encourage partnerships between the federal 

government and diverse local interests, including 

sawmill owners, conservationists, businesses, and 

sportsmen. By creating opportunities for dialogue 

and collaboration among groups that often have 

been adversaries, the program is designed to promote 

more science-based planning and restoration, and 

fewer court challenges. These creative collaborations 

have helped increase Forest Service timber volume by 

20 percent since 2008. Other policies, such as Good 

Neighbor Authority and Stewardship Contracting, 

have also been put in place to create additional 

incentives for forest management and restoration, 

and provide significant benefits to communities and 

wildlife. While more work is needed, we can look to 

these collaborative models for ways to address the 

many issues facing our forests, 

Restoring and enhancing the health of our forests 

has multiple societal benefits beyond traditional uses, 

such as providing timber and livestock forage. These 

include fueling our growing outdoor economy, 

providing abundant and clean watei~ enhancing 

wildlife populations, and sequestering and storing 

carbon. Healthy forests are essential for the outdoor 

recreation industry, which currently contributes 

$887 billion to our national economy annually, is 

responsible for 7.6 million direct jobs, and generates 

$124.5 billion in federal, state, and local tax revenueY 

Forests are hugely important for producing the 

water that people depend on, and some 180 million 

people in over 68,000 communities rely on national 

forest lands to capture and filter their drinking 

water."n Forests also provide habitat for a vast array 

of wildlife, yet nearly one-in-five forest~dependent 

animal species is imperiled or vulnerable.~" Forests 

are also a major factor in sequestering and storing 

carbon that would otherwise enter the atmosphere 

and contribute to climate change. Indeed, U.S. 

forests account for more than 90 percent of the 

country's carbon sink,r,n 
191 


36422.147

FIXING THE FEDERAL FIRE BUDGET 

espitc the enormous benefits that healthy 

forests provide, federal efforts to enhance 

their health and resilience are being 

impeded by antiquated approaches to funding the 

accelerating costs of fighting wildfires. Addressing 

the OlilSsive restoration backlog starts with fixing the 

broken federal fire budgeting process. 

Traditionally, federal budgets for fighting wildfire have 

been based on rolling ten year historical averages. 

While this budgeting approach may have worked in 

prior eras, given the dramatic increase in the number 

and size ofwi!dtlres, and the rapidly escalating costs 

of fighting these fires, this retrospective approach is 

clearly inadequate for today's needs. Today, fighting 

wildfire consumes more than 50 percent of the Forest 

Service's budget, and this number could grow to 67 

percent over the next decade, in large part due to a 

changing climate and ensuing drought conditions.61 

Annually, the United States spends more than $1 billion 

to fight wildfires/'2 and in 2015, one of the worst years 

for wildfires on record, the U.S. government spent more 

than $2.6 billion.(>.l Large catastrophic megafires eat up 

a disproportionate amount of federal resources, with 

just one to two percent off! res consuming 30 percent 

or more of agency firefighting budgets each year:61 

These costs are only expected to rise as the climate 

continues to change, and as more homes are built in 

fire-prone wildland areas. 

Unfortunately, the current fire funding system 

is not only inadequate for fighting fires, it is also 

compromising the ability of agencies to proactively 

reduce fire risks. Because of the retrospective 

budgeting process for fire control and suppression 

funds, during active fire years (which are now the 

norm) as fire season progresses and available wildfire 

funds are exhausted, money is shifted {euphemistically 

termed "borrowed") from accounts funding other 

important agency activities. This fire borrowing 

severely affects the government's ability to carry out 

the programs for which those funds were originally 

intended, including recreation, wildlife management, 

and forest restoration. A permanent fix is needed to 

address this growing problem. 

Part of that fix must include a recognition that 

the number, size, and cost of wildfires on federal 

lands is increasing and should be budgeted for 

appropriately. Additionally, instead of expecting 

agencies to cover the exceptional costs of fighting 

truly catastrophic fires from their limited annual 

appropriations, these expenses should be eligible to 

be covered by specially appropriated disaster funds, 

similar to how hurricanes, tornadoes, and major flood 

events have long been treated. 
192 


36422.148

RECOMMENDATIONS 

he US. must address the growing threat of 

megafires through a comprehensive 

wildfire funding fix, through dramatically 

scaling up the pace of forest restoration, through 

incorporating climate adaptation practices into forest 

restoration and management, and through achieving 

significant reductions in climate-altering carbon 

pollution. By restoring and better managing U.S. 

forests, it is possible to reduce fire risks to 

communities, increase populations of cherished 

wildlife species, and protect our climate by enhancing: 

lhe carbon sequestration and storage potential of our 

forests. These steps will help ensure that America's 

forests will be sustainable and resilient in the face of 

a rapidly changing and uncertain future, and will be 

capable of continuing to provide important economic, 

ecological, and societal benefits. 

ENSURE ADEQUATE 

AND DEPENDABLE 

WILDFIRE FUNDING 

• Provide sufficient funding for federal agencies to 

respond to wildfires, recognizing the growing average 

annual cost of firefighting; 

• Allow the Forest Service to access a disaster 

funding account for catastrophic and extraordinarily 

costly fire.<>; 

• End the transfer of funds from conservation, forest 

managen]('nt, and other non-fire programs to cover 

growing fire suppression costs; and 
193 


36422.149

• Increuse fcdeml funding to implement proactive 

restoration and fire risk reduction, such as prescribed 

burns (when appropriate), on public and private 

forested lands. 

ACCELERATE RESTORATION 

PROJECTS AND IMPROVE 

FOREST MANAGEMENT 

• Prioritize restoration projects that achieve outcomes 

related to improved forest resilience, increased 

wildlife populations, and watershed health; 

• Cany out significantly more prescribed and managed 

burns in fire-adapted forests; 

• Improve environmental review processes for largescale landscapes and for project-level sites in the 

short-term that help achieve and facilitate forest 

restoration and healthy forest management; and 

• Expand on successful nationwide policies such 

as Good Neighhor Authority and Stewardship 

Contracting, which provide models for how 

stakeholders can work collaboratively towards 

mutually beneficial forest management goals 

and bring additional non-federal resources to 

restoration projects. 

PREPARE FOR CHANGING 

CLIMATIC CONDITIONS AND 

FOR MORE FREQUENT AND 

SEVERE WILDFIRES 

• Integrate climate adaptation principles into forest 

management and restoration efforts to ensure they 

are designed for future, rather than past, climatic 

conditions and promote sustainability and resilience 

of forest resources; 

• Encourage wildland communities to incentivize 

new housing in areas of lower fire risk, promote or 

mandate the use fire-resistant building materials, and 

adopt other fire-wise approaches for reducing 

wildfire risk; and 

• Prioritize hazardous fuel reduction investments 

in the wildland-urban interface where they will 

have the greatest effect on reducing the impacts and 

costs of wildfires. 

REDUCE CLIMATE-ALTERING 

CARBON POLLUTION 

• Manage forests on federal lands in ways that promote 

continued capture and storage of carbon, and foster 

financial incentives and markets to encourage carbon 

sequestration on private forest lands; 

• Implement common sense safeguards-like 

greenhouse gas limits for power plants, vehicles, 

and oil and gas facilities-that are needed to protect 

public health and wildlife from climate impacts; 

• Enact measures at state and local levels of 

government to curb carbon pollution and expand use 

of clean, renewable energ:y; and 

• Ensure that federal agencies have sufficient resources 

to pursue important climate change research and 

monitoring, anJ to spur the development and 

adoption of dean energy technologies. 
194 


36422.150

REFERENCES --------------
195 


36422.151
196 


36422.152

Post-j1re wildflower display_ Photo: Damian Gijda/ 
197 


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National Wildlife Federation 

1200 G Street, NW, Suite 900 

Washington, D.C. 20005 

www.nwf.org 
198 


36422.154

GREG WALDEN, OREGON 

CHAIRMAN 

ONE HUNDRED FIFTEENTH CONGRESS 

FRANK PALLONE, JR., i'IEW JERSEY 

RANKING MEMBER 

QCongress of tbt ltnittb ~ta:tts 

1!1oust of l\tpttstntatibrs 

COMMITTEE ON ENERGY AND COMMERCE 

2125 RAYBURN House 0Ff'ICE BuiLDING 

WASHINGTON, DC 20515-6115 Majority {lll2}225~2921 

Mfrtol'ity !20212.25-3641 

October 9, 20 I 8 

The Honorable Herman E. Baertschiger, Jr. 

Senator 

Oregon State Senate 

900 Court Street, N.E. 

Salem, OR 97301 

Dear Senator Baertschiger: 

Thank you for appearing before the Subcommittee on Environment on September 13, 20 I 8, 

to testify at the hearing entitled "Air Quality Impacts of Wildfires: Mitigation and Management 

Strategies." 

Pwsuant to the Rules of the Committee on Energy and Commerce, the hearing record 

remains open for ten business days to pennit Members to submit additional questions for the record, 

which are attached. To facilitate the printing of the hearing record, please respond to these 

questions with a transmittal letter by the close of business on Tuesday, October 23,2018. Your 

responses should be mailed to Kelly Collins, Legislative Clerk, Committee on Energy and 

Commerce, 2125 Rayburn House Office Building, Washington, DC 20515 and e-mailed in Word 

format to ke)ly,collins@mail.house.gov. 

Thank you again for your time and effort preparing and delivering testimony before the 

Subcommittee. 

cc: The Honorable Paul Tonko, Ranking Member, Subcommittee on Environment 

Attachment 
199 


36422.155

Responses by Oregon State Senator Herman E. Baertschiger, Jr. 

To: The Honorable John Shimkus 

1. What is necessary to increase the pace and scale of prescribed 

burning and other active forest management activities? More specifically what 

needs to happen at the Federal level vs State and local levels? 

To increase the pace and scale of active forest management activities, 

uninterrupted investment by the Congress is necessary. Continuity and 

consistency with long-term support is crucial to the success of any effort related 

to active forest management. The solution to Western forest management is very 

long-term. It should be at least a 100 year plan to make an impact. long term 

goals are difficult for most people to conceive, but is the reality in forest 

management. Forest management is dynamic {an ever changing environment} 

where one must adjust strategies, goals and tactics to meet the ever changing 

events. A consistent set of principles and directives that are adequately funded 

for the very long-term is needed to have successful active forest management. 

Coordination between Federal, State and local agencies must include 

common and coordinated objectives and goals. This coordination is also required 

to increase the pace and scale of active forest management. Most states have a 

fire suppression model for state protected lands. The Federal government for at 

least the last 20 years has operated under a fire management model. This 

Suppression versus Management model is unsustainable. Managing fire during 

peak fire season is unacceptable because of the adverse effects to the health and 

welfare of the people. To have successful fire and forest management there 

should be coordinated strategies and goals, betwe-en the Federal and State 
200 


36422.156

governments, especially during peak fire season. Their fire policies should be 

parallel and efforts should be consistent relating to same goals and outcomes by 

both State and Federal agencies. 

2. Can you provide your perspective on whether more coordination 

among federal and state authorities needed to make meaningful difference in 

reducing the risks of catastrophic wildfires? 

Managing fire during peak fire season is unacceptable because of the 

adverse effects to the health and welfare of the people. To have successful fire 

and forest management there should be coordinated strategies and goals, 

between the Federal and State governments, especially during peak fire season. 

From a prevention and awareness perspective, identifying defensible space 

around communities and creating adequate escape routes that the public can be 

made aware of is a risk management tool that can be used to minimize the effects 

of catastrophic wildfires in rural communities. Fuel reduction around 

communities in fire prone areas can be employed to create and improve 

defensible space. Identification and enhanced public knowledge of escape routes 

in fire prone communities is an awareness tool. Much in the way that tsunami 

prone areas have signs and placards giving direction and creating awareness, a 

similar approach in fire prone areas could be used. 
201 


36422.157

3. Should air quality considerations play a greater role in informing 

decisions related to wildfire suppression and forestry management planning, 

and if so, how so? 

Air Quality considerations must play a greater role in decisions related to 

wildfire suppression and forestry management planning. Attempting to manage 

fire rather than suppress it during peak fire season is unacceptable because of air 

quality considerations. Managing fire during peak fire season is unacceptable 

because of the adverse effects to the health and welfare of the people. Forestry 

management planning, including harvest, thinning and controlled burning, can be 

managed correctly outside of peak fire season while still preserving air quality. 

Harvest and thinning do not create significant air quality impacts. Controlled 

burning can be managed outside of peak fire season and the impacts of smoke 

can be minimized. Air Quality impacts during some of the most recent fire seasons 

has often exceeded hazardous levels. Therefore, a full suppression policy should 

be followed during peak fire season and an aggressive control burning policy for 

the off season to minimize the impacts of smoke, and the health risks it presents 

to the public. 
202 


36422.158

GREG WALDEN, OREGON 

CHAIRMAN 

Ms. Mary Anderson 

ONE HUNDRED FIFTEENTH CONGRESS 

FRANK PALLONE, JR., NEW JERSEY 

RANKING MEMBER 

C!Congrcifg of tl)c llnttcb ~tatcg 

~ou~e of 1\tprt.Utntatibe1i 

COMMITTEE ON ENERGY AND COMMERCE 

2125 RAVauRN HouSE OFFICE Bun.DfNG 

WASHINGTON, DC 20515-6115 MajOrity {2CJ2J225-Z927 

MinoiiiV {207122&...:3841 

October 9, 2018 

Mobile and Area Source Program Manager 

Air Quality Division 

Idaho Department of Environmental Quality 

1410 North Hilton 

Boise, ID 83 706 

Dear Ms. Anderson: 

Thank you for appearing before the Subcommittee on Environment on September 13, 2018, 

to testify at the hearing entitled "Air Quality Impacts of Wildfires: Mitigation and Management 

Strategies." 

Pursuant to the Rules of the Committee on Energy and Commerce, the hearing record 

remains open for ten business days to permit Members to submit additional questions for the record, 

which are attached. To facilitate the printing of the hearing record, please respond to these 

questions with a transmittal letter by the close of business on Tuesday, October 23,2018. Your 

responses should be mailed to Kelly Collins, Legislative Clerk, Committee on Energy and 

Commerce, 2125 Rayburn House Office Building, Washington, DC 20515 and e-mailed in Word 

fonnat to kelly.colljns@mail house goy, 

Thank you again for your time and effort preparing and delivering testimony before the 

Subcommittee. 

y, (!) # 

~ an 

Subcommittee on Environment 

cc: The Honorable Paul Tonko, Ranking Member, Subcommittee on Environment 

Attachment 
203 


36422.159

STATE OF IDAHO 

DEPARTMENT OF 

ENVIRONMENTAL QUALITY 

14iO Nor1h Hilton· Boise, Idaho 83706 • (208) 373-0502 

www,deq.idaho.gov 

October 23, 2018 

Ms. Kelly Collins 

Legislative Clerk 

Committee on Energy and Commerce 

2125 Rayburn House Office Building 

Washington, DC 20515 

C.L "Butch" Otter, Governor 

John H. Tippets, Dtrector 

RE: Responses to Questions for the Record on "Air Quality Impacts of Wildfires: Mitigation 

and Management Strategies." 

Dear Ms. Collins: 

lbank you for the opportunity to testify at the hearing entitled "Air Quality Impacts of Wildfires: 

Mitigation and Management Strategies" on Thursday, September 13,2018. Per your request, 

please find attached my responses to your additional questions for the record. 

If you would like further clarification regarding any of the answers provided, please don't 

hesitate to contact me. 

Mobile and Area Source Program Manager 

Attachment (I) 
204 


36422.160

Responses to Questions for the Record for 

Mary Anderson, Idaho Department of Environmental Quality 

Hearing: Air Quality Impacts of Wildfires: Mitigation and Management Strategies 

The Honorable John Shimkus 

1. What is necessary to increase the pace and scale of prescribed burning and other active forest 

management activities? More specifically what needs to happen at the Federal level vs State 

and local levels? 

Answer: From an air quality regulatory agency perspective, more collaboration and coordination is 

needed before more prescribed burning can be achieved. State and federal land managers need to 

coordinate closely with Idaho DEQ and other private burners. In order for the prescribed burning 

program to be successful, there also needs to be a collaboration and communication with the public. 

This coordination and collaboration needs to happen long before the prescribed burn is scheduled to 

occur. The following steps need to be accomplished prior to increasing the use of prescribed burning: 

Establish airshed groups- These groups will be based on defined geographic area and include all 

burners as well as other stakeholders such as the public. These groups will help prioritize burns 

and educate the public on the need for prescribed burning. 

Develop a comprehensive smoke management plan- Because many types of burning occur in 

Idaho, a plan that addresses all open burning is needed to ensure public health is protected. 

Coordination across state lines- Similar to the MT/ID Airshed group, burners and air quality 

agencies need to coordinate burn decisions across state lines. 

Increase in staffing -As I stated in my testimony, the current staffing level can barely keep up 

with the current level of burning. Additional staffing would be needed to ensure the public 

health is protected while maximizing the opportunities to burn. 

Evaluate all possible solutions- Prescribed burning cannot be seen as the only solution to the 

wildfire problem, other forest management techniques to remove wildland fuels must become 

part of the solution. 

Use smoke management principles -It is important to remember that reasonable and effective 

smoke management principles and decisions must be used when conducting prescribed burning 

to truly lessen smoke impacts and not simply move smoke from one time of year to another. 

The addition of more smoke into some of Idaho's airsheds through increasing the use of 

prescribed fire during October through December will put some communities in jeopardy of 

exceeding the national ambient air quality standards for PM,.5as well as adversely impacting the 

public's health. Data can be flagged as "exceptional," thereby excluding it from attainment 

demonstrations, but only if adequate smoke management principles are adopted and applied. 

1 
205 


36422.161

Reducing emissions -lncentivizing the use of alternatives to open burning of wildland fuels as 

well as the replacement of old inefficient wood stoves are both needed concurrently to reduce 

the amount of emissions competing for the airshed. 

2. Can you provide your perspective on whether more coordination among federal and state 

authorities is needed to make a meaningful difference in reducing the risks of catastrophic 

wildfires? 

Answer: From my perspective there is always room for more coordination. Managing lands involves 

many agencies at both the state and federal level. The decisions made by these agencies also impact the 

public that live near these lands. With multiple agencies and stakeholders, collaboration is also needed 

to truly make a difference. More coordination will only be effective if all participants value each other's 

missions and mandates and are committed to finding common goals and balanced solutions. 

3. Should air quality considerations play a greater role in Informing decisions related to wildfire 

suppression and forestry management planning, and if so, how so? 

Answer: Yes, air quality should play a greater role in informing decisions related to wildfire suppression 

and forestry management planning. One of the guiding principles of the 1995 Federal Fire Policy 

(reaffirmed in 2001 and 2009) is that "Fire management plans and activities incorporate public health 

and environmental quality considerations." When responding to wildfire, air quality should be one of 

the risk factors evaluated when determining the appropriate response, whether it is direct attack, 

conducting a back burn, or establishing point protection. When air quality deteriorates to the unhealthy, 

very unhealthy, and hazardous conditions, air quality should become a more important component of 

the decision making process. The same focus of wildfire suppression to commit resources for the 

protection of structures should be afforded the protection to public health whenever possible. 

The Honorable Richard Hudson 

1. In North Carolina we recently saw one of the worst wildfires our state has seen, claiming over 

55,000 acres. Not only do these blazes destroy our homes and lands, but they also impact our 

health. What type of risk communication strategy should states like mine who normally don't 

experience major wildfires put out to inform the public of the risks associated with wildfires? 

Answer: The key to responding to wildfire impacts is preparing ahead. Identifying key stakeholders and 

developing outreach material on the fly during the event is not effective. I recommend working during 

the winter months to develop a communication strategy with the stakeholders in your state. Idaho 

relies heavily on the Wildfire Smoke A Guide for Public Health Officials to make recommendations to the 

public (https://www3.epa.gov/airnow/wildfire may2016.pdf). We also work closely with our 

neighboring states when developing smoke forecasts and communicating health recommendations for 

the public. To improve coordination and collaboration during wildfire response, DEQ and several 

partners developed a wildfire smoke response protocol to help mitigate impacts on public health by 

guiding air quality information distribution and health related messaging and outreach responses 

2 
206 


36422.162

through the appropriate agency. Idaho highly recommends developing a communication strategy with 

your state's health partners. 

2. From a health perspective, what are the impacts of wildfires? More specifically, how does 

smoke impact sensitive populations such as the elderly, children, or individuals who suffer 

from respiratory challenges? 

Answer: When it comes to smoke impacts, the sensitive populations include children (especially children 

age 7 and younger), pregnant women, older adults (over 65 years of age), individuals with pre-existing 

lung and cardiovascular conditions, and smokers. Symptoms from smoke inhalation can include 

shortness of breath, chest pain or tightness, headaches, coughing, irritated sinuses, stinging eyes, sore 

throat, and fatigue. 

a. How do you work with public health officials to alert communities about the health 

impacts of wildfire smoke? What steps can individuals and communities take to 

minimize the health impacts of wildfire smoke? 

Answer: Idaho DEQ coordinates closely with the Idaho Department of Health and Welfare (IDHW) as 

well as the local Health Districts during a wildfire smoke event. In collaboration with many stakeholders, 

we developed a Wildfire Smoke Response Protocol that identifies key stakeholders and contact 

information, agency expertise, triggers for agency actions, and recommended actions. DEQ and Tribal 

Air quality agencies provide current and forecasted air quality while the IDHW and Health Districts 

communicate health related information and recommendations to the public. The US Forest Service is 

also part of this collaboration and provides insight into current wildfire behavior to the group. We follow 

the information presented in the Wildfire Smoke A Guide for Public Health Officials to make 

recommendations to the public (https://www3.epa.gov/airnow/wildfire may2016.pdf). Individuals and 

communities can take the following steps to minimize health impacts: 

Stay indoors 

o Keep windows closed and run a filtered air conditioner with the fresh air intake closed 

o Use room high-efficiency particulate air (HEPA) cleaners that DO NOT produce excess 

ozone. 

o Create a clean room at home 

Reduce activity 

Stay well-hydrated by drinking plenty of water 

Follow your doctor's advice about medication and your respiratory management plan if you 

have asthma or another lung disease. This is best done prior to wildfire smoke impacting the 

community. Plan ahead. 

Switch to eyeglasses if you wear contacts 

Do not add to indoor pollution- avoid frying or broiling when cooking, do not vacuum or smoke 

Do not add to outdoor pollution- do not burn wood, limit using gas lawn mowers and driving 

3 
207 


36422.163

GREG WALDEN, OREGON 

CHAIRMAN 

Ms. Sonya Gennann 

State Forester 

Forestry Division 

ONE HUNDRED FIFTEENTH CONGRESS 

FRANK PALLONE, JR., NEW JERSEY 

RANKING MEMBER 

Cltongtess of tbe mntteb i;tates ~oust of l\rprtlirntatibrli 

COMMITTEE ON ENERGY AND COMMERCE 

2125 RAYBURN HousE OFFICE Bun.oiNG 

WASHINGTON, DC 20515-6115 Maforltv 1202l22!i-29Z7 

Minority (202)22fi-3fi41 

October 9, 2018 

Montana Department of Natural Resources and Conservation 

2705 Spurgin Road 

Missoula, MT 59804 

Dear Ms. Gennann: 

Thank you for appearing before the Subcommittee on Envirmunent on September 13, 2018, 

to testify at the hearing entitled "Air Quality Irnpacta of Wildfires: Mitigation and Management 

Strategies." 

Pursuant to the Rules of the Committee on Energy and Commerce, the hearing record 

remains open for ten business days to permit Members to submit additional questions for the record, 

which are attached. To facilitate the printing of the hearing record, please respond to these 

questions with a transmittal letter by the close of business on Tuesday, October 23,2018. Your 

responses should be mailed to Kelly Collins, Legislative Clerk, Committee on Energy and 

Commerce, 2125 Rayburn House Office Building, Washington, DC 20515 and e-mailed in Word 

fonnat to ke1ly col!ins@mail.house.gov. 

Thank you again for your time and effort preparing and delivering testimony before the 

Subcommittee. 

cc: The Honoreble Paul Tonko, Ranking Member, Subcommittee on Environment 

Attachment 
208 


36422.164

October 23,2018 

Responses to Questions for the Record for Sonya Germann, Montana State Forester 

Hearing: Air Quality Impacts of Wildfires: Mitigation and Mapagement Strategies 

(Sept 13, 2018) 

Questions from The Honorable John Shimkus 

I. What is necessary to increase the pace and scale of prescribed burning and other active forest 

management activities? More specifically what needs to happen at the Federal level vs State 

and local levels? 

The USDA Forest Service State & Private Forestry programs support essential investments in the health 

and management of our nation's forests. Any increase in federal appropriations to those programs will be 

critical in helping reduce hazardous fuel loads on private lands in and around the Wildland Urban 

Interface, reducing the risk of wildfire for communities. Additionally, the Landscape Scale Restoration 

(LSR) program is a key priority for State Foresters, allowing land managers to address national priorities 

identified in state Forest Action Plans. Codifying this program and funding it appropriately would allow 

state forestry agencies to tackle the nation's most pressing forest priorities in the most cost-effective, 

collaborative, and coordinated ways. 

Increasing the implementation of authorities granted by Congress, such as the Good Neighbor Authority 

and categorical exclusions for wildfire resilience projects, will ensure that high priority areas are actively 

managed. The recent passage of the wildfire funding solution that will end the detrimental practice of fire 

borrowing will assist the Forest Service in utilizing these available tools. Montana, like other states, 

appreciates Congress' support for increasing the pace and scale of forest restoration and for the authorities 

that facilitate strong cooperation between the state and federal agencies. We would urge Congress to 

consider additional actions, such as the recommendations cited in the Western Governors' Association 

National Forest and Rangeland Management Initiative to carryout hazardous fuels reduction and support 

advancements in the use of prescribed fire. This initiative represents a multi-state, bipartisan 

collaborative perspective on promoting health and resilience afforests and rangelands in the West and 

highlights mechanisms to bring states, federal land managers, private landowners, and stakeholders 

together to discuss issues and opportunities in forest and rangeland restoration and management 

emphasizing investments in all lands/cross-boundary management opportunities. 

Additionally, we would urge Congress to continue increasing its support of collaborative efforts on 

federal forest land management. In Montana, these groups have done the hard work of reaching 

agreement on intractable land management issues, and their continued engagement is critical to the 

success of increasing the pace and scale of forest management within the state. 

2. Can you provide your perspective on whether more coordination among federal and state 

authorities is needed to make a meaningful difference in reducing the risks of catastrophic 

wildfires? 

Increased coordination is critical to successful forest management across shared boundaries. 

Thankfully this concept is widely recognized by federal and state land management agencies as a 

method to success in making meaningful differences across the landscape. Right now there is a 

unique opportunity for an all-hands, all-lands approach where federal, state, and local governments 
209 


36422.165

as well as collaborative groups are all involved in the planning process as well as being on the front 

lines. Additionally, authorities such as the Good Neighbor Authority support opportunities to 

increase cross-boundary coordination between states and federal partners in order to accomplish 

more restoration work. 

The recent initiative from the USDA Forest Service, "Toward Shared Stewardship Across 

Landscapes: An Outcome Based Investment Strategy," also calls for increasing coordination. This 

strategy highlights the Forest Service's vision of bringing the States together with the Agency and 

other partners to identifY priority areas for increasing active forest management. Since the 

establishment of the Wildland Fire Leadership Council in 2002, there has been an ongoing effort by 

federal, state, local governments, and collaborative groups to increase coordination around the 

efforts to reduce the risk of catastrophic fire. The National Cohesive Strategy is an example of this 

improved coordination that continues today. 

3. Should air quality considerations play a greater role in informing decisions related to wildfire 

suppression and forestry management planning, and if so, bow so? 

Air Quality considerations could serve a greater role in informing decisions related to wildfire 

suppression and forestry management planning. We cannot prevent wildfrre, but we can influence 

the way that wildfire burns. We can also work to lessen the hazardous fuel loads on the ground 

through mechanical thinning and prescribed fire, which will mitigate the amount of smoke 

communities experience as a result of wildfire. The data shows that in Montana, over an 11-year 

period, air quality standards were surpassed 579 times due to wildfire, while air quality standards 

were surpassed only 4 times due to prescribed fire. In both the updating of the National Ambient Air 

Quality Standard (NAAQS) for PM 2.5 (81 CFR 164, pg. 58010) and the updating of the 

Exceptional Events Rule (81 CFR 191, pg. 68216), the Environmental Protection Agency (EPA) 

clearly documents the role of wildfire as an emissions source and the relevance of prescribed fire 

use and fuels management to reduce the risk of catastrophic wildfire. It is becoming increasingly 

evident through both research and experience that without prescribed fire and the relatively small 

amount of managed smoke that comes with it, we are perpetuating the conditions that generate 

catastrophic fires and resulting air quality issues, while simultaneously putting people and their 

communities at risk. NASF, my fellow State Foresters and I, are ready to work with members of the 

House Energy and Commerce Committee and staff, to examine possible legislative solutions to 

allow for more implementation of prescribed bums and mechanical thinning. 
210 


36422.166

GREG WALDEN, OREGON 

CHAIRMAN 

Mr. Collin O'Mara 

President and CEO 

ONE HUNDRED FIFTEENTH CONGRESS 

FRANK PALLONE, JR., NEW JERSEY 

RANKING MEMB£R 

cteongre~~ of tbr llnftrb ~tate~ 

~ouse of l\epresentatibes 

COMMITTEE ON ENERGY AND COMMERCE 

2125 RAYBURN House OFFICE BuiLDING 

WASHINGTON, DC 20515-6115 Majnrltv!202!225-2927 

Minorlty!202)226--.~1 

October 9, 2018 

National Wildlife Federation 

1200 G Street; Suite 900 

Washington, DC 20005 

Dear Mr. O'Mara: 

Thank you for appearing before the Subcommittee on Environment on September 13, 2018, 

to testify at the hearing entitled "Air Quality Impacts of Wildfires: Mitigation and Management 

Strategies." 

Pursuant to the Rules of the Committee on Energy and Commerce, the hearing record 

remains opan for ten business days to pennit Members to submit additional questions for the record, 

which are attached. To facilitate the printing of the hearing record, please respond to these 

questions with a transmittal letter by the close of business on Tuesday, October 23,2018. Your 

responses should be mailed to Kelly Collins, Legislative Clerk, Committee on Energy and 

Commerce, 2125 Rayburn House Office Building, Washington, DC 20515 and e-mailed in Word 

format to kelly.collins@mail.house,gov. 

Thank you again for your time and effort preparing and delivering testimony before the 

Subcommittee. 

an 

Subcommittee on Environment 

cc: The Honorable Paul Tonko, Ranking Member, Subcommittee on Environment 

Attachment 
211 


36422.167

Response from Collin O'Mara to the House Committee on Energy and Commerce 

Subcommittee on Environment 

Hearing entitled "Air Quality Impacts of Wildfires: Mitigation and Management Strategies" 

September 13, 2018 

Thank you again for the opportunity to testify, and for the additional questions you have posed. 

My answers are contained below. 

1. What is necessary to increase the pace and scale of prescribed burning and other active 

forest management activities? More specifically what needs to happen at the Federal 

level vs State and local levels? 

Funding, collaboration, and focus. Earlier this year Congress passed the Fire Fix that will 

ensure that, starting in fiscal year 2020, the Forest Service will no longer have to extinguish 

all resources from its forest management accounts to cover the increasing costs of fighting 

the larger, more numerous, and more intense forest fires being fueled by climate change. 

This was an extremely important step that Congress took and we thank all of the Members 

of this Committee who supported it and worked to enact it. 

That said, we are extremely frustrated that the Fire Fix will not take effect until FY20, when 

it should have begun in the second half of FY18. Given the severity of fires we experienced 

in FY18 and what we're expecting for FY19, we urge this Committee to work with other 

committees of jurisdiction to begin the fire funding fix this year (FY19). rather than waiting 

for yet another year to begin restoration at-scale, while local communities suffer even more 

devastating health and economic impacts. 

Further, the fire funding fix in and of itself is not enough. After years of starving the Forest 

Service budget combined with its own restoration budget cannibalization to fight fires, we 

urge Congress to follow through by making sure the Forest Service has sufficient funding 

on an annual basis to restore our National Forests to health and resilience, through forwardthinking restoration projects, prescribed burns, and other efforts. Such funding should at 

least be commensurate with the new wildfire disaster funds to be allocated for fighting 

wildfires, so we are reducing the long-term restoration deficit. Further, in out years, 

Congress should ensure that the Forest Service is spending the resources freed up by the fire 

funding fix on the restoration, reforestation, and proactive management. 

More collaboration by the Forest Service with more partners will also increase the pace and 

scale of forest restoration projects. The more buy-in and local, regional, and national support 

the Forest Service has for its work, the more likely those projects are to move forward 

without controversy or pushback. The Forest Service's Shared Stewardship strategy released 

earlier this year sets it on the right course toward increased coordination with the full range 

of national forest stakeholders and the public. This strategy seeks to address fire at scale, 

and emphasizes and prioritized greater coordination with states in particular, and with other 

stakeholders. Congress should support the agency in implementing the shared strategy and 

provide funding as well as oversight to make sure the Forest Service stays on track and 

delivers forest restoration results. 
212 


36422.168

A focus on restoration results will also be needed to increase the number of prescribed bums 

and other forest restoration projects. The Forest Service has plenty of policy and 

programmatic tools to restore the national forests, and now it has more funding available for 

this purpose thanks to Congressional action earlier this year. Some additional policy tools or 

flexibility from Congress might help around the edges but are not a priority right now, when 

the Forest Service has barely begun to implement the tools Congress recently provided this 

spring as part ofthe fire funding fix. Instead, the agency must make sure all of its forest 

restoration tools and authorities, and the restoration projects it is implementing on-theground through them, are actually focused on improving the resilience of forest ecosystems 

and on improving wildlife habitat and delivering results. The restoration work these 

authorities were set up to achieve is far too important, and the scale of restoration needed far 

too great, to allow any projects under these programs to focus on anything but restoring the 

health and resilience of our national forests. Yet there is a tendency for the Forest Service to 

prioritize generating receipts from the sale of commercially viable timber to cover costs 

over delivering restoration results. A commercial timber program is a legitimate and 

important use of the national forests, but seeking receipts through forest restoration 

programs and projects serves as a distracting and corrupting influence on those programs. 

Receipts from the sale of timber must be a byproduct of restoration projects, not an 

objective. The Forest Service therefore needs to measure the success of its forest restoration 

program in terms of community fire risk reduction, forest resilience, wildlife habitat, carbon 

storage, water quality, and other measurable results on the ground. Congress can help by 

providing oversight to make sure objective forest restoration results are being delivered 

irrespective of receipts generated. For example, Congress should make sure the restoration 

authorities it has provided the agency such as the Collaborative Forest Landscape 

Restoration Program, Stewardship Contracting, and Good Neighbor Authority are fulfilling 

their restoration purposes and not authorizing commercial timber sales except as necessary 

to achieve a specific restoration result. 

2. Can you provide your perspective on whether more coordination among federal and 

state authorities is needed to make a meaningful difference in reducing the risks of 

catastrophic wildfires? 

More-earlier and more strategic-coordination among federal and state authorities will lead 

to a meaningful difference in reducing the risk of catastrophic wildfires. The key will be to 

make sure the coordination is centered on the restoration of forest resilience, for example 

through presc.ribed bums, the removal of flammable understory, or the retention of mature fire 

resistant trees. Some steps the Forest Service could take to improve coordination with states 

include providing more oversight of the Good Neighbor Authority program to make sure 

projects under this authority are prioritizing restoration over receipts, and adopting policies or 

regulations making sure Stewardship Contracts are only signed for legitimate forest 

restoration projects. 

3. Should air quality considerations play a greater role in informing decisions 

related to wildfire suppression and forestry management planning, and if so, 

how so? 

Air quality considerations need to play a greater role in informing forest restoration projects. As 

I mentioned in my testimony, prescribed burns emit I 0 times to I 00 times less particulate matter 

than typical wildfires--and prescribed bums are one of the most important forest restoration and 

fire risk reduction strategies. The USFS and States already take precautions to reduce the health 

impacts from prescribed bums, such as establishing hourly and daily PM 2.5 limits, as well as 

specific plans to support at-risk populations. These plans should continue to be improved to 
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minimize further any potential health impacts from prescribed burns, but potential impacts 

should always be compared to the health consequences of inaction, which are often orders of 

magnitude greater as residents across the Northwest have experienced. 

There are administrative actions that EPA can take to remove some of the disincentives for 

prescribed burns through both changes to implementation guidance and policy. The most 

important change is to eliminate the perverse incentive whereby emissions from prescribed 

burns ("anthropogenic ignition") are included in the calculations to determine whether a state is 

in attainment of the National Ambient Air Quality Standards, but wildfires ("natural ignition") 

are regularly excluded, despite typically emitting 90-99% more pollution. In other words, states 

that proactively utilize prescribed burns to reduce risks of megafires often need to find further 

reductions elsewhere in their state economy to offset the emissions from the prescribed burns; 

whereas a state that does not take such preventative action is not held accountable for the 

emissions from a megafire that could have been mitigated. Instead, we believe that EPA should 

account for all emissions and prioritize the granting of wildfire accounting exceptions to those 

states and communities who have ecologically-sound and landscape-scale fire programs and in 

doing so encouraging states to prioritize forest restoration, including prescribed burns, as a 

means of reducing overall emissions and adverse impacts to public health. We would glad to 

work with the Committee on this effort. 
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GREG WALDEN, OREGON 

CHAIRMAN 

Mr. Tom Boggus 

ONE HUNDRED FIFTEENTH CONGRESS 

FRANK PALLONE, JR., NEW JERSEY 

RANKING MEMBER 

€ongre55 ot tbe Wntteb ii>tates 

Jl,Jouge of l\epn.uentatibes 

COMMITIEE ON ENERGY AND COMMERCE 

2125 RAYBURN House OFRcE BuiLDING 

WASHINGTON, DC 20515--6115 Msjcrirv f2G:2) 22&-2927 

MJnoritv !202)225--l&n 

October9, 2018 

State Forester and Director 

Texas A&M Forest Service 

200 Technology Way; Suite 1281 

College Station, TX 77845 

Dear Mr. Boggus: 

Thank you for appearing before the Subcommittee on Environment on September 13, 2018, 

to testify at the hearing entitled "Air Quality Impacts of Wildfires: Mitigation and Management 

Strategies." 

Pursuant to the Rules of the Committee on Energy and Commerce, the hearing record 

remains open fur ten business days to permit Members to submit additional questions for the record, 

which are attached. To facilitate the printing of the hearing record, please respond to these 

questions with a transmittal letter by the close of business on Tuesday, October23, 2018. Your 

responses should be mailed to Kelly Collins, Legislative Clerk, Committee on Energy and 

Commerce, 2125 Rayburn House Office Building, Washington, DC 20515 and e-mailed In Word 

furmat to kel!y.collins@mail.house.gov. 

Thank you again for your time and effort preparing and delivering testimony before the 

Subcommittee. 

cere!~, \0 ~ 

hairman 

hnShi~ 

cc: The Honorable Paul Tonko, Ranking Member, Subcommittee on Environment 

Attachment 
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October 23, 2018 

Responses to Questions for the Record for Tom Boggus, Texas State Forester 

Hearing: Air Quality Impacts of Wildfires: Mitigation and Management Strategies 

(Sept 13, 2018) 

Questions from The Honorable John Shimkus 

1. What is necessary to increase the pace and scale of prescribed burning and other active forest 

management activities? More specifically what needs to happen at the Federal level vs State 

and local levels? 

Increasing both prescribed burning and active forest management are critical to improving forest 

health and supporting economic prosperity and safety in rural communities across the country. At 

the state and local levels, it is imperative that we help communities and citizens understand the dire 

risks from catastrophic wildfire, and the tie between prescribed burning and active management to 

reducing that risk. Maintaining the social license to burn and harvest has always been a key to our 

successful forest management in Texas and many other parts of the South, but it is becoming 

increasing challenging as our country is urbanizing. Increasing awareness within the regulatory 

community is also importarit, helping state environmental authorities understand the benefit to 

allowing some prescribed fire smoke in lieu of an egregious amount of wildfire smoke and 

potentially catastrophic tree and property losses sometime down the road. 

At the federal level, public land management agencies need more tools and resources to facilitate 

and streamline active forest management. Our federal forests are in dire need of restoration and fire 

risk reduction, and it is very much in the public interest to find ways to support getting that work 

done. The Good Neighbor Authority is particularly helpful, as it allows state agencies to carry out 

work on federal lands. Texas was an early adopter of this authority and continues to find ways to 

help our federal partners restore the health of our federal forests. Federal programs that support 

technical assistance to private landowners through the state forestry agencies are also critical to 

keeping our forests actively managed and healthy. In particular, the Forest Stewardship Program 

(FSP) of the USDA Forest Service is the gateway through which private landowners are encouraged 

and educated on how to burn and manage their acres to keep them healthy. Supporting FSP and 

other critical State and Private Forestry programs is essential to keeping up the pace of active 

management and prescribed burning. 

2. Can you provide your perspective on whether more coordination among federal and state 

authorities is needed to make a meaningful difference in reducing the risks of catastrophic 

wildfires? 

Increasing coordination between public agencies and authorities is crucial, whether that be at the 

state, federal or local level, to address wildfire suppression and mitigation challenges. The recently 

released report from the USDA Forest Service "Toward Shared Stewardship Across Landscapes: An 

Outcome Based Investment Strategy" presents an unprecedented opportunity to foster that 

collaboration among fire and forest managers. The forested landscape in our country is a patchwork 

of ownerships (private, state, federal, tribal, etc), and fire, insects, disease and other challenges know 

no boundaries. To make a meaningful difference in addressing any of these challenges we need to 

work together, draw from each other's strengths, and coordinate our resources to be most efficient 

with the tools we have. 
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3. Should air quality considerations play a greater role in informing decisions related to wildfire 

suppression and forestry management planning, and if so, how so? 

The air quality impacts of fire on communities are becoming increasingly apparent as fires get larger 

and more people move closer to forested areas. These and other changes necessitate an intentional 

assessment of air quality impacts alongside any plans for forest management, prescribed fire, or 

wildfire suppression. Health and human impact data is increasingly showing that the serious risks to 

humans from wildfire are not confined to the flames on the ground, but that smoke impacts dozens 

or even hundreds of miles way could be the greatest human threat from fire. 

As such, this should be a wake-up call to do more prescribed burning under manageable conditions 

as well as forest thinning and active management to reduce hazardous fuels. If we have the ability 

to do preventive work in our forests to reduce air quality impacts on communities from wildfire, 

then our management decisions need to be informed by that opportunity. At the federal level, 

National Environmental Policy Act (NEPA) analyses should include assessments of the benefits of 

proposed forestry projects on potential wildfire air quality emissions which would be of detriment to 

the environment and human communities, and that information considered by line officers in their 

decision making. 

Questions from The Honorable Bill Flores. 

1. Your testimony mentions both prescribed burning and tree thinning as important tools 

available to make our forests healthier and less fire prone. 

a. As a forester, could you explain how cutting trees makes the remaining forests 

healthier? 

b. How successful has tree thinning been in Texas and the rest of the country? Should we 

be doing more? 

In any forest, there is a finite amount of resources (water, nutrients, etc) to be shared among the 

trees and associated vegetation. The trees are in competition for these resources. When some of 

the trees are removed, this allows the remaining trees to access more water and nutrients, grow 

larger, and get healthier. Healthier trees are more resistant to insects and disease and the forest 

more resilient to wildfire. As land managers, we aim to manage each forest stand at a density that 

allows the trees to be as healthy as possible. When the density gets too high, we cut the smaller 

trees (i.e. -forest thinning) or use prescribed burning to thin out the smaller trees and brush to 

reduce the stand density to an ideal level for forest health. 

Additionally, reducing hazardous fuels through either prescribed burning or forest thinning makes 

the remaining forest more resilient to wildfire. Without the ground fuels and small trees that act 

as "ladder fuels" that would otherwise transport fire into the upper canopy and damage or destroy 

the trees, wildfires in thinned managed stands take on a healthier more historically appropriate 

role. These fires stay closer to the ground, produce less smoke and air quality pollutants, are 

easier to contain, and have many ecological and wildlife benefits. This is all made possible by 

proper tree cutting and/or prescribed fire. 

We need to be doing more tree thinning all across this country, especially on federallaitds where 

we see millions of acres in need of restoration. There is a need for more resources at all levels to 

support federal land managers, state agencies, private landowners, and other stakeholders to 

conduct these thinning operations that benefit all of society. A critical component to getting 

enough thinning done on the landscape is having forest products markets for biomass and the 
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small diameter trees that are thinned out. Often times this is the limiting factor in how much 

good work can be done on the ground - if there are no markets then sound management will be 

limited. We need to be doing more to support domestic markets for small diameter thinned wood. 

In Texas, we partner with the USDA Forest Service to deliver the Forest Inventory & Analysis 

program. This program collects tree and forest data from all across Texas to provide meaningful 

information about forest health and timber availability. Because ofFIA, we were able to 

demonstrate that Texas has enough trees to sustainably supply a brand-new oriented strand board 

(OSB - similar to plywood) mill in Corrigan, TX, as well as a brand-new sawmill in Lufkin, 

TX. These two mills will provide hundreds of jobs and will create new markets for Texas forest 

owners. 

As stated in my written and oral testimony, Texas was an early adopter of the Good Neighbor 

Authority and continues to work with our federal partners to restore healthy forests on our Texas 

National Forests and Grasslands through both prescribed fire and forest thinning. 

Questions from The Honorable Richard Hudson 

1. In your testimony you say that "our forests are currently more fire-prone than ever." Why is 

this the case? How did we get to the point where our forests are at such high risk of fire? Are 

there any regulations inhibiting the ability to lower our forests risks-of fire? 

As I stated in my written testimony, our nation's forests are indeed currently more fire-prone than 

ever. Fire is a natural phenomenon for nearly every forest ecosystem in this country. It has shaped 

the occurrence and distribution of different ecosystems for centuries, simultaneously impacting the 

human and natural communities that live in and around those forests. However, over the past 

century, a culture of fire suppression has unfortunately removed the natural role of fire from the 

public consciousness to varying degrees in different regions. When combined with a reduced level 

of forest management in many areas of the country this culture has also led to the build-up of 

hazardous fuels and unhealthy forests to historic levels. 

Of these two factors, the level of forest management is more easily addressed through policy and 

regulation. As discussed at the hearing, prescribed fire and active forest management are both key 

tools to lowering fire risk. National Environmental Policy Act (NEPA) processes and regulations 

have taken on an increasingly cumbersome role for federal land managers in the past three decades, 

straying far from the original intent of the law and delaying good and necessary forest management 

work that would also reduce fire risk. 

Air quality regulations relative to prescribed burning can also play a role in inhibiting prescribed 

fire that would otherwise reduce wildfire risk. At both the federal level through the EPA, as well as 

at the state level, regulations need to be flexible enough to recognize that allowing smoke now in 

lieu of a lot of smoke later is a good policy outcome.