a

GAO

United States General Accounting Office

Report to Congressional Requesters

April 2004 BISCUIT FIRE

Analysis of Fire 

Response, Resource 

Availability, and 

Personnel 

Certification 

Standards

GAO-04-426
www.gao.gov/cgi-bin/getrpt?GAO-04-426.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Barry T. Hill at 

(202) 512-3841 or hillbt@gao.gov. 

Highlights of GAO-04-426, a report to 

congressional requesters 

April 2004

BISCUIT FIRE

Analysis of Fire Response, Resource 

Availability, and Personnel Certification 

Standards 

National policies and procedures were in place and provided the framework 

to guide personnel in the local interagency dispatch center in Grants Pass, 

Oregon, who were responsible for acquiring resources to fight the Biscuit 

Fire. These policies and procedures provide for a multilevel dispatching 

system where, if sufficient firefighting personnel and equipment are not 

available locally, resource requests can be elevated to other dispatch centers 

at the regional and, if necessary, national level. To facilitate the swift 

suppression of new fires, local dispatch center personnel can contact 

neighboring centers directly, including those in adjacent regions, before 

elevating resource requests. When the first two fires were found on July 13, 

the Grants Pass dispatch center did not have sufficient firefighting resources 

available locally. Grants Pass personnel requested resources from the 

responsible regional center in Portland, as well as from a dispatch center in 

central Oregon, but no resources were immediately available in the region 

due to other higher priority fires that were threatening lives and property. 

Grants Pass personnel did not request resources from a neighboring 

interagency dispatch center in Fortuna, California, located in an adjoining 

dispatch region, because they believed the center had no available resources 

due to fire activity there. State officials working at the Fortuna dispatch 

center later said that a Fortuna-based helicopter fighting fires in Northern 

California near the first of the five Biscuit fires could have been made 

available to suppress this fire. However, Forest Service officials working 

with Fortuna personnel disagreed, saying that the helicopter had been 

needed to fight fires in California. Because no request was made, there was 

no discussion on that first day about whether the Biscuit Fire would have 

been the best use of the helicopter, and it is unclear, in any case, what the 

outcome of such a request would have been. 

Following the initial days of the Biscuit Fire, delays in obtaining needed 

personnel hampered efforts to fight the rapidly growing fire. Specifically, 

officials faced problems obtaining (1) highly experienced management 

teams to direct suppression strategies and crews to carry the strategies out, 

(2) supervisors to manage crews and equipment, and (3) support staff to 

monitor the training and experience of contracted crews. An unusually 

severe fire season, with many other higher priority fires, affected the 

availability of personnel needed to fight the Biscuit Fire. 

Finally, while some differences exist in certification standards for personnel 

between federal and state agencies responsible for fighting wildland fires, 

these differences did not appear to affect efforts to respond to the Biscuit 

Fire. 

 

In 2002, the United States 

experienced one of the worst 

wildland fire seasons in the past 50 

years—almost 7 million acres 

burned. These fires included the 

largest and costliest fire in Oregon 

in the past century—the Biscuit 

Fire. Following a lightning storm, 

five fires were discovered in the 

Siskiyou National Forest over a 3-

day period beginning July 13. 

These fires eventually burned 

together to form the Biscuit Fire, 

which burned nearly 500,000 acres 

in southern Oregon and Northern 

California and cost over $150 

million to extinguish. GAO 

evaluated (1) whether policies and 

procedures were in place for 

acquiring needed firefighting 

resources during the initial days of 

the Biscuit Fire, and the extent to 

which these policies and 

procedures were followed when 

the fire was first identified; (2) 

what resource management issues, 

if any, affected the ability of 

personnel to fight the fire; and (3) 

what differences, if any, existed in 

key certification standards for 

personnel among federal and state 

agencies and whether these 

differences affected efforts to 

respond to the fire. 

In commenting on a draft of this 

report, the Forest Service stated 

that the report appears to be 

accurate and the agency generally 

agrees with its contents. The 

Department of the Interior did not 

provide comments. 
Page i GAO-04-426 Biscuit Fire Response

Contents

Letter 1

Results in Brief 5

Background 8

National Policies and Procedures Were in Place to Guide the Process 

for Acquiring Firefighting Resources 12

Reduced Availability of Key Personnel Hampered the Ability to 

Effectively Fight the Biscuit Fire 21

Some Differences in Certification Standards Exist between State 

and Federal Firefighting Agencies, but No Effect Was Identified 28

Conclusions 30

Agency Comments and Our Evaluation 31

Appendixes

Appendix I: Scope and Methodology 32

Appendix II: Comments from the Forest Service 34

Appendix III: GAO Contact and Staff Acknowledgments 35

GAO Contact 35

Staff Acknowledgments 35

Table Table 1: The Five Types of Incidents 11

Figures Figure 1: Locations and Final Perimeter of the Five Fires That 

Became the Biscuit Fire 3

Figure 2: Biscuit 1 Burning on Steep Terrain on July 14, 2002 9

Figure 3: Example of an Extended Attack Firefighting 

Organization 10

Figure 4: Illustration of the Flow of Resource Requests between 

the Local Dispatch Centers Involved in the Initial Attack 

of the Biscuit Fire 14

Figure 5: Key Events on July 13 and 14, 2002, Related to the Biscuit 

Fire 16

Figure 6: New Fire Starts Identified in the Vicinity of the Biscuit 

Fire on July 13 and 14, 2002 18

Figure 7: Fire Size on Key Dates When Fire Management Teams 

Were Requested and Received 23
Contents

Page ii GAO-04-426 Biscuit Fire Response

Abbreviations

CDF California Department of Forestry and Fire Protection

NIFC National Interagency Fire Center

NWCG National Wildfire Coordinating Group

ODF Oregon Department of Forestry

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Page 1 GAO-04-426 Biscuit Fire Response

United States General Accounting Office

Washington, D.C. 20548

A

April 12, 2004 Letr

The Honorable Greg Walden 

Chairman, Subcommittee on Forests and Forest Health

Committee on Resources

House of Representatives

The Honorable Peter DeFazio

House of Representatives

The Honorable Scott McInnis

House of Representatives

In 2002, the United States experienced one of the worst wildland fire 

seasons in the past 50 years. In total, the federal government spent more 

than $1.6 billion to suppress fires that burned almost 7 million acres. These 

fires included the largest and costliest fire in Oregon in the past century—

the Biscuit Fire.1

 The fire season in 2002 began early, with major fires in 

Arizona, Colorado, and New Mexico draining many firefighting resources 

out of the Pacific Northwest during early summer. As a result, when 

lightning storms hit California and Oregon from July 12 to 15, there were 

limited resources available to fight the hundreds of ongoing fires, including 

five fires that eventually burned together to form the Biscuit Fire. While no 

lives were lost, the Biscuit Fire burned almost 500,000 acres, including 

much of the biologically diverse 180,000-acre Kalmiopsis Wilderness. The 

Biscuit Fire was not declared extinguished until December 31, 2002, more 

than 5 months after it began. In all, the Biscuit Fire destroyed 4 primary 

residences and 10 other structures, resulted in about 15,000 residents being 

put on evacuation notice, required thousands of firefighters and other 

resources, and cost over $150 million to fight. 

All five fires began in the Siskiyou National Forest in southwest Oregon 

over a 3-day period, beginning July 13, 2002. On the first day, two fires were 

found—one approximately 4 miles north of the California-Oregon border, 

named Biscuit 1, and another, the Carter Fire, 16 miles north of the state 

border within the Kalmiopsis Wilderness (see fig. 1). The Carter Fire was 

the first fire Siskiyou Forest officials took action to suppress, and it was 

contained within a few days. On July 14, the third fire—Biscuit 2—was 

1

Federal agencies select names for wildfires based upon nearby geographic features. For 

example, the Biscuit Fire started near Biscuit Creek in southern Oregon.
Page 2 GAO-04-426 Biscuit Fire Response

found near Biscuit 1, and on July 15, the last two fires—Florence and 

Sourdough—were found (see fig. 1). The Florence Fire was located almost 

30 miles north of Biscuit 1 and 2, and by early August it had burned 244,000 

acres, about one-half of the total acreage ultimately burned by the entire 

Biscuit Fire. The Sourdough Fire was located near Biscuit 1 and 2, and by 

July 22, the three had burned together to form one fire. By August 7, the 

Florence Fire had burned south and merged with the other fires to form 

what was later called the Biscuit Fire. 
Page 3 GAO-04-426 Biscuit Fire Response

Figure 1: Locations and Final Perimeter of the Five Fires That Became the Biscuit 

Fire 

Note: The names of the fires changed as they progressed. Initially, each of the fire starts was named 

individually. As these fires burned together, the names were modified. Ultimately, the fires merged to 

become one—the Biscuit Fire.

Since no one agency alone can handle all wildfires that may occur in its 

jurisdiction, especially when large fires like the Biscuit Fire occur, the 

United States uses an interagency incident management system that 

depends upon the close cooperation and coordination of federal, state, 

tribal, and local fire protection agencies. At the federal level, there are five 

0 10 20

Scale in miles

Six Rivers National Forest

Siskiyou National Forest

Geographic location of Biscuit Fire in Oregon and California

13

14

15

Saturday

Sunday

Monday

Fires started by lightning

(numbered on map):

Date found in July 2002

1 Biscuit 1

1 2

3

3

4

4

5

5

Carter

Biscuit 2

Florence

Sourdough

California

Oregon

Perimeter of

Biscuit Fire

Source: GAO analysis of Forest Service data.
Page 4 GAO-04-426 Biscuit Fire Response

agencies involved in firefighting efforts—the Forest Service, within the 

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

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

Service, all within the Department of the Interior. The Forest Service is the 

predominant firefighting agency among these in terms of the amount of 

resources devoted to firefighting. In addition to the federal agencies, state, 

tribal, and local firefighting agencies also play an important role in fighting 

wildland fires and share firefighting personnel, equipment, and supplies to 

facilitate cost-effective firefighting. Private companies are increasingly 

providing contracted crews and equipment to supplement those of federal, 

state, and local agencies. 

To coordinate the firefighting efforts of these agencies, the National 

Wildfire Coordinating Group (NWCG) was established. This group adopted 

an interagency incident management system and firefighting standards for 

responding to wildland fires. This system provides an organizational 

structure that includes command, planning, logistics, operations, and 

finance functions to meet the complexity and demands of wildland fires. 

Needed personnel, aircraft, equipment, and supplies for wildland fires are 

ordered through a system of local, regional, and national dispatch centers. 

These dispatch centers are staffed or funded by federal or state agencies, 

or a combination of those agencies. Federal, state, local, or tribal agencies 

or private contractors supply the firefighting resources dispatched at these 

centers. If resources in the local dispatch area close to a wildland fire are 

insufficient, dispatch center personnel forward the requests to the 

responsible regional dispatch center2

 that locates and sends additional 

firefighting resources from within the region. If necessary, the regional 

dispatch center can forward the request to the National Interagency 

Coordination Center in Boise, Idaho, which locates and assigns the closest 

available resources to the fire. This center is staffed jointly by Bureau of 

Land Management and Forest Service personnel. This incident 

management system was used to respond to the Biscuit Fire.

Concerns about the response to the Biscuit Fire surfaced as the fire rapidly 

grew and began to threaten lives, homes, and businesses. These concerns 

included whether firefighting resources were available across the border in 

California, which could have been used during the critical early days of the 

fires, and whether better management of firefighting resources could have 

2

There are 11 regional dispatch centers nationwide, called geographic area coordination 

centers, each of which serve a specific geographic portion of the United States. 
Page 5 GAO-04-426 Biscuit Fire Response

improved suppression efforts. In this context, we reviewed (1) whether 

policies and procedures were in place for acquiring needed firefighting 

resources during the initial days of the Biscuit Fire, and the extent to which 

these policies and procedures were followed when the fire was first 

identified; (2) what resource management issues, if any, affected the ability 

of firefighting personnel to effectively fight the Biscuit Fire; and (3) what 

differences, if any, existed in key personnel certification standards at 

federal and state agencies involved in fighting wildland fires—particularly 

in Oregon—and whether any such differences affected efforts to respond 

to the Biscuit Fire. 

To address these questions, we reviewed firefighting policies and 

procedures that included interagency standards for fire and fire-aviation 

operations, interagency personnel certification standards, the national 

mobilization guide, and the local mobilization guide and mutual aid 

agreement for the dispatch center in Grants Pass, Oregon,3

 which was 

responsible for acquiring resources to respond to the Biscuit Fire. We 

interviewed headquarters, regional, and local firefighting officials from the 

Forest Service and Department of the Interior agencies, as well as state 

officials from California, Oregon, and five other Western states. We 

reviewed Biscuit Fire records, including daily fire reports, resource orders, 

and transcripts of key radio transmissions during the initial days of the 

Biscuit Fire. We conducted our work in accordance with generally 

accepted government auditing standards.

Results in Brief National policies and procedures were in place and provided the 

framework to guide personnel in the local dispatch center in Grants Pass, 

Oregon, responsible for acquiring firefighting resources for the Biscuit Fire. 

Guided by these policies and procedures, dispatch centers use a threetiered dispatching system—local, regional, and national—to locate and 

send resources to wildland fires. If sufficient resources are not available 

locally, a dispatch center requests additional resources from its regional 

dispatch center. If sufficient resources are not available within the region, 

3

In the case of the Biscuit Fire, the local dispatch center was the Grants Pass Interagency 

Fire Center in Grants Pass, Oregon. The Siskiyou National Forest has contracted with the 

Oregon Department of Forestry (ODF) to operate this center. ODF personnel staff the 

center, but the operating costs are shared between ODF and the Forest Service. The regional 

dispatch center responsible for the Biscuit Fire was the Northwest Interagency 

Coordination Center in Portland, Oregon. 
Page 6 GAO-04-426 Biscuit Fire Response

the request is then elevated to the national level. However, to facilitate the 

swift suppression of new fires—called the initial attack phase of a fire—

these policies also permit dispatch centers to contact neighboring centers 

directly for resources, including those in adjacent regions, before elevating 

resource requests to a higher level. For the Biscuit Fire, the Grants Pass 

dispatch center did not have sufficient resources available and took steps 

to locate resources to fight what began as five separate fires in the Siskiyou 

National Forest, found over a 3-day period beginning July 13, 2002. Grants 

Pass dispatchers contacted their regional dispatch center in Portland about 

the availability of resources, including helicopters, on the first day of the 

Biscuit Fire. There were no resources immediately available due to other 

higher priority fires burning in the region. In making these inquiries, Grants 

Pass personnel did not request resources from the Fortuna dispatch 

center,4 a neighboring center located in the adjoining dispatch region in 

Northern California. Grants Pass personnel believed that Fortuna had no 

available resources, based on daily fire situation reports, because Northern 

California was also fighting numerous fires. Concerns were later expressed 

by state and local officials in California that a helicopter, under the control 

of the Fortuna dispatch center, was fighting fires in Northern California 

near one of the five fires in the Siskiyou National Forest—Biscuit 1—and 

could have been made available to fight it. However, Forest Service and 

California state officials working in the Fortuna dispatch center expressed 

differing viewpoints on whether they could have provided the helicopter 

for the Biscuit Fire, had Grants Pass requested it. State officials at the 

dispatch center said that the helicopter could have been sent to Oregon. 

However, Forest Service dispatchers disagreed, stating that the helicopter 

was needed to fight fires in Northern California. Because no request was 

made, there was no discussion on that first day about whether the Biscuit 

Fire would have been the best use of the helicopter, and it is unclear, in any 

case, what the outcome of such a request would have been. 

Following the initial efforts to suppress the Biscuit Fire, fire officials faced 

delays obtaining (1) highly experienced management teams to direct fire 

suppression strategies, along with sufficient crews to carry out fire plans; 

(2) supervisors to manage crews and equipment; and (3) support staff to 

monitor the training and experience of contracted crews. These delays 

4

The Fortuna Interagency Emergency Command Center, which we will refer to as the 

Fortuna dispatch center, is an interagency center staffed by Forest Service and California 

Department of Forestry and Fire Protection (CDF) personnel. The center serves Six Rivers 

National Forest, Redwood National Park, the CDF Humboldt-Del Norte Unit, and the Hoopa 

Indian Reservation. 
Page 7 GAO-04-426 Biscuit Fire Response

were primarily due to the severe fire season—there were many higher 

priority fires within and outside the region. By the time the most highly 

experienced type of management team had arrived at the fire, the fire had 

grown from a few hundred acres to almost 200,000 acres. Difficulties in 

filling supervisory positions for managing firefighting crews hindered the 

effectiveness of firefighting efforts. Insufficient personnel to supervise 

crews and equipment resulted in the inability to use crews to carry out 

planned actions, and as a result, fire suppression progress was delayed. 

Insufficient support personnel meant that thousands of contracted 

personnel could not be adequately monitored to determine if they met 

applicable training and experience requirements. As a result, some 

insufficiently trained or inexperienced contractor crews were not always 

able to carry out planned operations, resulting in the need to postpone or 

alter some tactical firefighting operations.

Finally, while some differences exist in certification standards for 

personnel between federal land management agencies and state agencies 

responsible for fighting wildland fires, these differences did not appear to 

have affected efforts to respond to the Biscuit Fire. In 1993, the National 

Wildfire Coordinating Group—an interagency group comprising federal 

and state representatives—established minimum training and experience 

standards for personnel assigned to fight interagency wildland fires outside 

their home region. Federal land management agencies, as well as 

firefighting agencies in five of the seven states we contacted in and around 

the Northwest Region, have adopted these standards as the minimum 

requirements for all of their fire personnel. The state firefighting agency in 

Oregon—the Oregon Department of Forestry—uses these standards for 

firefighting personnel assigned to fight interagency fires outside their home 

region, although the state maintains its own certification standards for 

personnel assigned to state fires or interagency fires within the Northwest 

Region. Finally, the California state firefighting agency—the California 

Department of Forestry and Fire Protection—has maintained its own 

requirements and certification system for fire personnel, but state officials 

said that these standards meet or exceed those established by the National 

Wildfire Coordinating Group. We did not find any evidence of problems at 

the Biscuit Fire that stemmed from these differing standards, based on our 

review of relevant documents and interviews with knowledgeable officials. 

We provided a draft of this report to the Secretaries of Agriculture and of 

the Interior for review and comment. The Forest Service commented that 

the report appears to be accurate and the agency generally agrees with its 
Page 8 GAO-04-426 Biscuit Fire Response

contents. The Forest Service’s comment letter is presented in appendix II. 

The Department of the Interior did not provide comments. 

Background A severe drought in many Western states set the stage for an early and 

intense fire season. By mid-June, several major fires were burning, 

including the Rodeo-Chediski Fire in Arizona and the Hayman Fire in 

Colorado. These fires siphoned both aerial and ground firefighting 

resources from the Pacific Northwest, including helicopters, air tankers, 

agency and contract fire engines, smoke jumpers, highly trained agency 

crews (called “hot shot” crews), and contract firefighting crews. By June 

21, the National Interagency Fire Center (NIFC) in Boise, Idaho, was 

reporting a preparedness level of 5, the highest level, indicating that the 

nation had the potential to exhaust all agency firefighting resources. When 

lightning storms passed through California and Oregon on July 12 and 13, 

igniting hundreds of fires, including the Biscuit Fire, more than 30 large 

fires were already burning across the nation and firefighting resources 

available for initial attack were limited. 

The Biscuit Fire began as five separate fires in the Siskiyou National 

Forest5

 in southwest Oregon. The Siskiyou Forest, encompassing more 

than 1 million acres, contains diverse topography, including the Siskiyou 

Mountains, the Klamath Mountains, the Coast Ranges, and the 180,000-acre 

Kalmiopsis Wilderness. Steep terrain, together with many roadless areas, 

presented accessibility and logistical challenges for managers directing fire 

suppression efforts at the Biscuit Fire. To complicate the situation, the fires 

were also located almost 30 miles apart. As the fires rapidly grew during 

late July and early August, the southern fire burned south and crossed the 

state border into the Six Rivers National Forest in Northern California. 

While the Biscuit Fire burned primarily federal forestland, by early August, 

it threatened a number of communities in Oregon and California. Figure 2 

shows Biscuit 1 burning on a steep hill on July 14, 2002. 

5

The Siskiyou National Forest and the Rogue River National Forest are separate forests but 

are administered jointly. However, because the Biscuit Fire burned only in the Siskiyou 

Forest, we will only refer to the Siskiyou National Forest.
Page 9 GAO-04-426 Biscuit Fire Response

Figure 2: Biscuit 1 Burning on Steep Terrain on July 14, 2002

To understand the response to the Biscuit Fire, it is important to 

understand the phases of fire suppression efforts and the nature of 

interagency wildland firefighting. On a large wildland fire, such as the 

Biscuit Fire, fire suppression efforts generally fall into two phases. The 

initial attack phase is defined as efforts to control a fire during the first 

operational period, usually within 24 hours. Local fire managers direct 

these initial firefighting efforts. In fiscal year 2002, firefighters were 

successful in suppressing about 99 percent of wildland fires in federal, 

state, and local jurisdictions during the initial attack phase. If a fire has not 

been contained or will not be contained during this period or additional 

firefighting resources are ordered, firefighting efforts move into the 

extended attack phase.6

 In this phase, key fire management officials 

6

Fire managers may order more experienced leadership immediately based on the initial 

assessment if it appears that the fire will become a more complex incident. 

Source: Forest Service.
Page 10 GAO-04-426 Biscuit Fire Response

prepare a Wildland Fire Situation Analysis that describes the situation and 

objectives, and compares multiple strategic wildland fire management 

alternatives. Additional management and firefighting resources may be 

requested. Figure 3 shows an example of a firefighting organization 

involved in an extended attack, although the specific positions filled 

depend on the complexity of the fire. 

Figure 3: Example of an Extended Attack Firefighting Organization

The Forest Service and its interagency firefighting partners employ an 

incident management system that is designed to provide the appropriate 

management and leadership team capabilities for firefighting efforts. The 

complexity of the fire determines the type of leadership team and 

Firing boss Firing boss Firing boss Firing boss

Planning

Helicopter

manager

Squad bosses

Bulldozer

boss

Crew

boss

Engine

boss

Operations Logistics Finance/

administration

Incident commander

Firefighters

Source: GAO analysis of National Wildfire Coordinating Group data.
Page 11 GAO-04-426 Biscuit Fire Response

firefighting resources assigned. There are five types of incidents—type 1 

being the most complex (see table 1). For example, to manage a type 5 

incident, the incident commander may be a local district employee with 

adequate experience to direct initial attack efforts on a small fire with two 

to six firefighters. In contrast, for a type 1 incident, such as the Biscuit Fire, 

the incident commander is just one member of a highly qualified 

management team. While both type 1 and type 2 incident management 

teams have a standard composition of 28 members, type 1 team members 

receive additional training and experience in handling the most complex 

incidents. 

Table 1: The Five Types of Incidents

Source: GAO analysis of National Interagency Fire Center and National Academy of Public Administration data.

Incident management teams manage a variety of firefighting resources. 

These include highly trained “hot shot” crews, agency and contracted 

crews, air tankers, helicopters, fire engines, and bulldozers. Federal 

agencies, such as the Forest Service, provide a large number of the 

personnel that work on fires. These federal agencies rely on a “militia” 

strategy to fight wildland fires whereby personnel within each agency are 

trained to serve in fire suppression or support roles, when needed and 

requested, in addition to performing their normal day-to-day work 

responsibilities. However, many factors, including past downsizing within 

the federal government, have reduced the pool of employees qualified to 

work on fires. Increasingly, private contractors provide crews and 

firefighting equipment, including engines and helicopters. 

Type

Source of incident 

commander/team Description

5 Local Up to 10 firefighters

4 Local Up to 50 firefighters

3 Local Up to 100 firefighters

2 Regional Operations personnel normally do not exceed 

200 at any one time

1 National Operations personnel often exceed 500 at any 

one time
Page 12 GAO-04-426 Biscuit Fire Response

National Policies and 

Procedures Were in 

Place to Guide the 

Process for Acquiring 

Firefighting Resources 

National policies and procedures7 were in place and provided the 

framework to guide personnel in the local dispatch center in Grants Pass, 

Oregon, who were responsible for acquiring firefighting resources for the 

Biscuit Fire. Guided by these policies and procedures, dispatch centers use 

a three-tiered dispatching system—local, regional, and national—to locate 

and send resources to wildland fires. During the initial attack phase of a 

fire, these policies also permit dispatch centers to contact neighboring 

dispatch centers directly for resources, including resources in adjacent 

regions, before elevating resource requests to a higher level. For the Biscuit 

Fire, the Grants Pass dispatch center did not have sufficient resources 

available and took steps to locate needed resources to fight what began as 

five separate fires in the Siskiyou National Forest. Grants Pass dispatchers 

contacted their regional dispatch center in Portland about the availability 

of resources, including helicopters, on the first day of the Biscuit Fire. In 

making resource inquiries, Grants Pass personnel did not request resources 

from the Fortuna dispatch center, a neighboring center located in the 

adjoining dispatch region in Northern California. Grants Pass personnel 

believed that Fortuna had no available resources, based on daily fire 

situation reports, because Northern California was also fighting numerous 

fires. Concerns were later expressed by state and local officials in 

California that a helicopter, under the control of the Fortuna dispatch 

center, was fighting fires in Northern California, just across the border from 

the first of the five Biscuit fires, and could have been provided to fight it. 

Forest Service and state dispatchers working in the Fortuna dispatch 

center expressed differing viewpoints on whether they could have provided 

a helicopter for the Biscuit Fire, had Grants Pass requested it. 

National Policies and 

Procedures Provide the 

Framework for Acquiring 

Firefighting Resources 

The National Interagency Mobilization Guide includes policies and 

procedures to help ensure the timely and cost effective mobilization of 

firefighting resources. Federal, state, tribal, and local firefighting agencies 

share their firefighting personnel, equipment, and supplies, following a 

standardized process to coordinate responses to fires and mobilize 

resources. When local dispatch center personnel are notified of a fire, they 

send available firefighting resources based on a preplanned response. If 

fire managers need additional resources, they send a request to the local 

dispatch center identifying the type and amount of resources needed. If the 

dispatch center personnel cannot fill a request locally, they can forward the 

7

National Interagency Mobilization Guide (Feb. 1, 2002).
Page 13 GAO-04-426 Biscuit Fire Response

request to the responsible regional dispatch center. If the regional center 

cannot fill the request with resources from within the region, the request is 

sent to the National Interagency Coordination Center in Boise, Idaho, the 

primary support center for coordinating and mobilizing wildland 

firefighting resources nationally. When requests exceed available 

resources, the fires are prioritized, with those threatening lives and 

property receiving higher priority for resources. To facilitate the swift 

suppression of new fires—called the “initial attack” phase of a fire—local 

dispatch center personnel can first contact neighboring dispatch centers 

directly, including those in adjacent regions, before elevating resource 

requests to the regional or national level. For resource sharing between 

neighboring dispatch centers in adjoining regions, a formalized agreement, 

such as a mutual aid agreement and local operating plan, is needed.

Existing policies and procedures encourage the sharing of resources 

between local dispatch centers. The national guidance states that local 

dispatch centers should use mutual aid agreements whenever possible to 

obtain resources directly from neighboring units. In the case of the Biscuit 

Fire, a regional mutual aid agreement between the state of California and 

federal agencies in California, Nevada, and Oregon establishes the 

protocols for interagency coordination and cooperation for wildland fire 

protection in California, which includes the areas along the Nevada and 

Oregon borders.8

 Local, state, and federal agencies jointly develop local 

operating plans that identify the specific resources that can be shared 

under the mutual aid agreement and the provisions for cost sharing. One of 

these plans allows the Grants Pass dispatch center in Oregon and the 

Fortuna dispatch center, located in the neighboring region in Northern 

California, to request resources directly from each other. (See fig. 4.) The 

Grants Pass dispatch center operates under a contract between the 

Siskiyou National Forest and the Oregon Department of Forestry (ODF). 

ODF operates and staffs the center, and the Forest Service reimburses the 

department for a portion of the center’s operating costs, according to a 

Siskiyou official. The Fortuna dispatch center is operated by the Six Rivers 

National Forest and the California Department of Forestry and Fire 

Protection (CDF) and is staffed by personnel from both agencies. 

8

This mutual aid agreement, the Cooperative Fire Protection Agreement, involved the 

Bureau of Land Management, California and Nevada; National Park Service, Pacific West 

Region; Forest Service, Regions 4, 5, and 6; and California Department of Forestry and Fire 

Protection.
Page 14 GAO-04-426 Biscuit Fire Response

Figure 4: Illustration of the Flow of Resource Requests between the Local Dispatch Centers Involved in the Initial Attack of the 

Biscuit Fire 

Portland

Grants Pass

Boise, Idaho

Redding

Northern California 

Region

Northwest Region

Washington

Oregon

Fortuna

California

Source: GAO analysis of National Interagency Fire Center data.

Regional coordination center

National Interagency Coordination Center

Local dispatch center

Illustration of the flow of a resource request to a dispatch 

center in a neighboring region through the regional and 

national coordination centers

Illustration of the flow of a resource request made directly 

to a dispatch center in a neighboring region using a 

mutual aid agreement
Page 15 GAO-04-426 Biscuit Fire Response

Grants Pass Dispatch 

Center Personnel Sought a 

Variety of Firefighting 

Resources for the Initial 

Attack of the Biscuit Fire

When the first two fires were found on the afternoon of July 13, 2002, the 

Grants Pass dispatch center did not have the firefighting resources needed 

locally to fight the fires. Many resources, including the helicopter normally 

stationed at Grants Pass, had been sent to other higher priority fires that 

were threatening lives and property. The fires, located in the Siskiyou 

National Forest, were initially small—two trees and 1 acre. Biscuit 1 was a 

few miles north of the California-Oregon border, and the Carter Fire was 

about 12 miles north of Biscuit 1. Figure 5 provides information about the 

initial attack on the fires.
Page 16 GAO-04-426 Biscuit Fire Response

Figure 5: Key Events on July 13 and 14, 2002, Related to the Biscuit Fire 

Note: For the Oregon air reconnaissance, ODF personnel used a Siskiyou National Forest 

reconnaissance aircraft.
Page 17 GAO-04-426 Biscuit Fire Response

Biscuit 1 was the first fire found. At 3:17 p.m. on July 13, a Siskiyou Forest 

Service aircraft being used by ODF personnel to perform reconnaissance 

spotted Biscuit 1. The aerial observer reported the fire to Grants Pass 

dispatch. At 3:53 p.m., air reconnaissance spotted the Carter Fire 12 miles 

north of Biscuit 1.

Soon after Grants Pass and Siskiyou officials became aware of the first fire, 

firefighting personnel in California also spotted the fires. At 3:51 p.m., a 

CDF reconnaissance airplane, assisting the Six Rivers National Forest, 

spotted smoke columns to the north while circling a fire in Northern 

California. The airplane was directing the activity of a CDF helicopter and 

crew of six firefighters assigned to a fire in the Six Rivers National Forest in 

Northern California, just south of the California-Oregon border. At the 

request of a Six Rivers National Forest official, the CDF airplane flew north 

to investigate the smoke in Oregon. Reconnaissance personnel reported 

Biscuit 1 and the Carter Fire to the Six Rivers official and to the Fortuna 

dispatch center—an interagency center staffed by CDF and Six Rivers 

National Forest personnel. Since the helicopter and crew were close to 

finishing up their assignment in California, the CDF reconnaissance 

personnel suggested to Fortuna dispatch that the helicopter and crew 

could next take action on the fire in Oregon. The Forest Service dispatcher 

at Fortuna informed the reconnaissance airplane to continue patrolling 

while, in accordance with normal dispatching protocol, Fortuna notified 

the Grants Pass dispatch center about the fire. Grants Pass told Fortuna 

that it already had reconnaissance aircraft in the area. Because of the lack 

of communications between the CDF and Oregon aircraft, the Fortuna 

dispatch center advised the CDF airplane to leave the area to ensure air 

safety. At 4:15 p.m., CDF air reconnaissance reported another three 

lightning-caused fires in Northern California, and at 4:36 p.m., the CDF 

helicopter and crew were sent to fight these fires. Figure 6 shows the new 

fires found in southern Oregon and Northern California on July 13 and 14. 
Page 18 GAO-04-426 Biscuit Fire Response

Figure 6: New Fire Starts Identified in the Vicinity of the Biscuit Fire on July 13

and 14, 2002

Area of Biscuit Fire

Grants Pass

Gold Beach

Gasquet

Fires found on 7/13/02

Fires found on 7/14/02

Crescent City

Brookings

Fire starts

Geographic location

of Biscuit Fire in

Oregon and California

Source: GAO analysis of Forest Service data.

Biscuit 2

Biscuit 1

Kalmiopsis Wilderness

California

Oregon Carter
Page 19 GAO-04-426 Biscuit Fire Response

At the request of Siskiyou National Forest officials, Grants Pass dispatch 

personnel began to try to locate needed firefighting resources. At 4:30 p.m., 

Grants Pass dispatch personnel requested a helicopter (with a bucket for 

water drops) from the dispatch center in Portland, Oregon. Shortly after 5 

p.m., Siskiyou officials asked the Grants Pass dispatch center to check on 

the availability of smoke jumpers, rappellers, helicopters, and air tankers. 

Dispatchers checked with the regional dispatch center in Portland and 

were told that no helicopters or air tankers were available. Dispatchers 

contacted the Central Oregon dispatch center and were told that no smoke 

jumpers or rappellers were available for the Biscuit Fire for 48 to 72 hours 

because of higher priority fires elsewhere. Grants Pass personnel relayed 

this information to Siskiyou officials. 

By the next morning, July 14, the fires had grown. Shortly after 10:10 a.m., 

Siskiyou Forest officials directing firefighting efforts departed on a 

reconnaissance flight. They flew over the Carter Fire and decided to staff 

this fire as soon as possible because of its proximity to a trail that would 

allow access to the fire and because there were natural safety zones for 

firefighters. A type 2 crew began to hike to the Carter Fire later that 

afternoon. Siskiyou officials next flew over Biscuit 1 and found it was 

about 7 acres. They also spotted a third fire, named Biscuit 2, which was 

about 20 acres and located about one-half mile from Biscuit 1. Siskiyou 

Forest officials believed that the Biscuit 1 and 2 fires would burn together 

in the afternoon and had a high probability of getting significantly larger. 

Due to safety concerns, limited accessibility, wind and fire behavior, and 

insufficient firefighting resources, forest officials decided not to staff 

Biscuit 1 and Biscuit 2 at that time. Siskiyou officials requested that Grants 

Pass dispatch personnel order additional firefighting resources, including a 

type 2 incident management team, air tankers, and other equipment for the 

fires. However, due to higher priority fires elsewhere, many of these 

resource orders could not be filled by the regional dispatch center in 

Portland for several days or longer, and the request for air tankers was 

never filled. 

Shortly before noon, a CDF helicopter and crew were on duty in Northern 

California performing reconnaissance and responding to reported fires. A 

Six Rivers Forest official helping to direct the helicopter crew’s activities 

requested that the crew check the fire in Northern California they had 

worked the previous day to ensure it was out. She also requested that the 

crew, on the way, fly by a campground near the Biscuit 1 and Biscuit 2 fires 

to ensure no campers were there. None were seen. The helicopter then 

landed near the site of the fire they had worked the previous day in 
Page 20 GAO-04-426 Biscuit Fire Response

Northern California, and the crew hiked to the fire to ensure it was 

extinguished. At 2:17 p.m., the CDF helicopter reported the fire was cold, 

and the helicopter was assigned to another incident in California.

At 6:40 p.m., in response to the July 13 request for a helicopter, a regional 

dispatch official in Portland working with officials in the Northern 

California regional dispatch center in Redding, the Fortuna dispatch center, 

and the Grants Pass dispatch center arranged for a CDF helicopter with a 

water bucket to respond to the Biscuit fires, as allowed under the 

provisions of the mutual aid agreement. The helicopter had been working 

on fires in Northern California. However, a few minutes later, as the 

helicopter was en route to Oregon, Siskiyou officials canceled the request 

because at that point the fires had spread to more than 300 acres, and 

officials stated that the helicopter would have been of limited use on a fire 

that size. Officials explained that without ground resources available to 

fight the fire, water drops alone are usually of limited value.

On July 15, the last two fires that would make up the Biscuit Fire—

Sourdough and Florence—were discovered. The Sourdough Fire was 

found near Biscuit 1 and Biscuit 2. The Florence Fire was located almost 30 

miles north of these fires. Siskiyou officials requested the Grants Pass 

dispatch center to order numerous resources on July 15, including 

helicopters, engines, and crews. Most of these requests were not able to be 

filled for several days or longer. By July 16, the Northwest’s Multi-Agency 

Coordination Group in Portland, Oregon, which is responsible for 

prioritizing fires and allocating firefighting resources in the region, ranked 

the Biscuit Fires as priority 12 out of 18 large fires in the region. The 

Florence Fire went on to burn almost 250,000 acres before merging with 

the other fires on August 7.

Concerns were later expressed by state and local officials in California that 

a CDF helicopter, fighting fires in Six Rivers National Forest on July 13, just 

across the state border from Biscuit 1, could have been provided earlier to 

assist on the Biscuit Fire. Grants Pass personnel explained that they did not 

request assistance from the Fortuna dispatch center on July 13 because, 

based on the daily fire situation reports, they believed no resources would 

be available due to the fires in Northern California. California was also 

fighting numerous fires ignited by the same lightning storm that passed 

through Oregon. When we asked the Fortuna dispatch center about this 

issue, the Forest Service and state of California dispatchers working there 

expressed differing viewpoints on whether they could have provided a 

helicopter on the first day of the Biscuit Fire if such a request had been 
Page 21 GAO-04-426 Biscuit Fire Response

made. A CDF dispatcher working at the Fortuna dispatch center said that if 

the Grants Pass dispatcher had requested the helicopter at that time to 

launch an initial attack on the Biscuit Fire, he believed he would have 

provided it to them. However, a Forest Service official also working at 

Fortuna to dispatch firefighting resources had a differing opinion, saying 

that even if Fortuna had sent the helicopter to Oregon, he believes that it 

likely would have been diverted back to California to suppress other higher 

priority fires in Fortuna’s direct protection area. Because Grants Pass 

dispatch did not request assistance from Fortuna on the first day of the 

Biscuit Fire, there was no discussion at that time about whether this would 

have been the best use of the helicopter. In the final analysis, it is unclear 

what the outcome of such a request would have been. 

Reduced Availability of 

Key Personnel 

Hampered the Ability 

to Effectively Fight the 

Biscuit Fire

Following the initial attack of the Biscuit Fire, delays in obtaining needed 

personnel hampered efforts to effectively fight the Biscuit Fire in three key 

ways. First, neither a management team with adequate experience to 

strategically plan and manage firefighting efforts nor sufficient highly 

trained crews to carry out the plans were initially available for the Biscuit 

Fire due to their need on higher priority fires. By the time a highly 

experienced management team became available and was assigned to the 

Biscuit Fire in late July, the fire had increased from a few hundred acres to 

almost 200,000 acres. Second, key supervisors needed to direct the tactical 

efforts of firefighting crews and equipment were unavailable at critical 

points in July and August as the fire was growing in size and intensity. As a 

result, the ability to implement aggressive fire suppression tactics was 

compromised due to concerns about the safety of fire crews. Finally, some 

fire support positions, such as contracting technical representatives, also 

were unavailable to play a key role in monitoring contracted crews. 

Delayed Availability of a Top 

Management Team Affected 

Initial Firefighting Efforts 

Siskiyou Forest officials directing the firefighting effort had difficulty 

obtaining both a highly trained incident management team with the 

necessary level of experience to plan and direct firefighting efforts on the 

Biscuit Fire, as well as needed crews to carry out such plans. Within one 

day after the initial fires were discovered, Siskiyou district fire managers 

determined that the fire would likely grow larger and require a more 

experienced incident management team to direct the firefighting effort 

than was currently available at the forest. They requested a type 2 team and 

numerous type 1 crews and other firefighting resources during the initial 

days. However, because of the high level of fire activity both in the Pacific 
Page 22 GAO-04-426 Biscuit Fire Response

Northwest, as well as in other Western states, higher priority fires meant 

that no type 2 incident management teams or highly experienced crews 

were immediately available for assignment to the Biscuit Fire. Siskiyou 

officials’ request for a team was not filled for 7 days, by which time the 

acres burned had grown from about 700 to more than 5,000. 

When a type 2 management team assumed command of the Biscuit Fire on 

July 21, they quickly realized that the fire had grown beyond the scope of a 

type 2 team and that a more experienced type 1 team was needed to handle 

the increasingly complex situation. A type 1 team was ordered on July 22, 

but the Northwest’s Multi-Agency Coordination Group in Portland 

prioritized the Biscuit Fire, on this day, as priority 6 of 15 fires burning in 

the region. This was largely because the Biscuit fires were not threatening 

lives and property. As a result, most requests for management, crews, and 

equipment for the Biscuit Fire went unfilled. 

In the case of the management team, rather than assigning the type 1 team 

requested, two other type 2 management teams were assigned in late July 

to assist in managing firefighting efforts on the southern fire,9

 including the 

portion that had crossed into California. As these teams tried to direct the 

firefighting efforts of crews and equipment, the fires—especially the 

Florence Fire in the north—grew rapidly. Winds and low humidity 

contributed to the fires’ intensity. Between July 27 and August 1, the size of 

the Florence Fire grew from 18,000 acres to 164,000 acres, and the size of 

the southern fire—the Sour Biscuit Fire—grew from 7,000 acres to 38,000 

acres. Finally, on July 31, 9 days after first requested, two type 1 

management teams arrived and assumed command of fighting the Biscuit 

Fire. Type 1 firefighting crews and many other resources continued to be 

listed as critical resource needs throughout August. Figure 7 shows the 

dates management teams were requested or assumed command, the 

personnel and equipment assigned to the fire, and the growth of the fires. 

9

The southern fire resulted from the merging of the Biscuit 1, Biscuit 2, and Sourdough 

Fires. The southern fire was named the Sour Biscuit Fire.
Page 23 GAO-04-426 Biscuit Fire Response

Figure 7: Fire Size on Key Dates When Fire Management Teams Were Requested and Received

Note: The fire size information was not available for July 14.

The first type 2 incident commander assigned to the Biscuit Fire said that 

not having a type 1 management team and other needed resources slowed 

the progress of the firefighting effort. He said that while he understood the 

Portland group’s decision not to assign a type 1 team at that time, it 

nonetheless was difficult to effectively fight fires located almost 30 miles 

apart with the limited resources available. The available management and 

other resources were split between the fires. He added that the type 2 

team’s firefighting strategies were the same as those of a type 1 team—

initially to improve access to the site of the fires. However, without needed 

resources, tactics had to be modified, and progress was slower. His 

operations section chief said that the complexity of the fire, coupled with

Fire progression as of July 15 Fire progression as of July 22 Fire progression as of July 31

Size (acres)

Management

team

Crews

Helicopters

Bulldozers

Type 2 requested July 14 Type 2 assumes command July 21;

Type 1 requested July 22

Type 1 assumes command July 31

Total

personnel

5,470 186,585

3 19 58

0 4 21

Engines 0 13 95

2 3 40

82

750

663 2,146

Brookings

Cave

Junction

California

Oregon Brookings

Cave

Junction

California

Oregon Brookings

Cave

Junction

California

Oregon

Indicates area of each fire

Source: GAO analysis of Forest Service data.
Page 24 GAO-04-426 Biscuit Fire Response

the lack of a type 1 management team, type 1 crews,10 and equipment, 

meant that firefighters could not attack the fire directly and had to use 

more indirect methods, such as using bulldozers to build a firebreak, in an 

effort to slow the spread of the fire. The incident commander and 

operations section chief said that generally, when a fire is a high priority 

and qualifies for a type 1 management team, it is also more likely to be 

assigned other needed firefighting resources. In the case of the Biscuit Fire, 

a type 1 team and additional type 1 crews and other resources might have 

improved the chances of stopping the fire before it burned southeast to an 

area called Oak Flat, according to the incident commander. However, 

Forest Service headquarters officials said that in a severe fire season such 

as 2002, difficult decisions have to be made about where to assign limited 

resources. Fires are prioritized, and those presenting the greatest threat to 

life and property receive firefighting resources first.

Reduced Availability of 

Supervisors Slowed Biscuit 

Fire Suppression Efforts

Even as top management teams and increasing numbers of crews and 

equipment were assigned to the Biscuit Fire, some critical supervisory 

positions were not filled as quickly as needed or remained unfilled at the 

end of the fire. In all, over 200 requests for supervisory positions were 

never filled. The primary cause for reduced availability of supervisory 

personnel was the demand for these staff to work more than 30 other large 

fires throughout the nation, including other fires in Oregon. Fire managers 

and a Forest Service review11 of the Biscuit Fire stated that delays in 

obtaining needed supervisors affected their ability to implement aggressive 

fire suppression tactics or use equipment until sufficient supervision 

became available. Federal officials, however, did take some action to 

mitigate these problems, including obtaining personnel from Australia and 

New Zealand to fill certain supervisory positions. Officials emphasized that 

the difficulties in obtaining personnel to serve as supervisors was not a 

problem unique to the Biscuit Fire and that such issues have affected 

numerous fires in recent years. 

Biscuit Fire managers identified a number of key supervisory positions that 

went unfilled for a period of time in July or August when the fire was 

rapidly growing and that were critical for effective fire suppression efforts. 

These included government managers of contracted helicopters and 

10A crew normally consists of 20 persons.

11Final Draft Biscuit Fire Review, USDA Forest Service, PNW Region (Jan. 31, 2003).
Page 25 GAO-04-426 Biscuit Fire Response

bulldozers (known as helicopter managers and dozer bosses); government 

supervisors directing tactical operations for a division or segment of crews 

(known as strike team leaders); and government supervisors (known as 

division supervisors) directing the activities of strike team leaders.

Although it was not possible to measure the specific effect on fire 

suppression efforts, such as the number of additional acres burned, from 

unfilled supervisory positions, Biscuit Fire managers provided a number of 

examples to illustrate the difficulty they faced in carrying out plans without 

sufficient supervisors for aircraft or for equipment and firefighting 

personnel. For example, an incident commander and an incident business 

advisor working at the fire said that some bulldozers sat idle for a few days 

and could not be used on fire suppression efforts because of the lack of a 

dozer boss to manage and direct the equipments’ use. Interagency 

requirements state that one dozer boss is required to safely manage the 

operations of each dozer. However, dozers and dozer bosses are ordered 

separately and may arrive at a fire at different times. If a dozer arrives first, 

it may sit idle until a dozer boss is available to supervise its operation. 

According to an interagency Fire and Aviation Safety Team Review,12 it was 

appropriate to not use all available resources, including dozers, if safety 

would have been compromised because of insufficient supervision. 

In the case of helicopters, fire officials told us that for one or two days 

several helicopters may have sat idle due to insufficient helicopter 

managers. However, fire records indicate, and agency officials agreed, that 

the major reason helicopters did not fly was due to poor visibility as a 

result of weather or smoke. To minimize the impact of helicopter manager 

shortages, fire officials used a waiver system so that, under certain 

circumstances, one helicopter manager could manage two type 1 or type 2 

helicopters rather than only one, as permitted by interagency policy.13

Using this waiver process, six waivers were granted for helicopter 

managers working at the Biscuit Fire. In addition, National Interagency 

12Final Report: Fire & Aviation Safety Team Review of Northwest Geographic Area (July 

19 through Aug. 1, 2002).

13According to the Interagency Helicopter Operations Guide (January 2002), two type 1 or 

type 2 helicopters may be designated as “limited use” and managed by one qualified 

helicopter manager when (1) a second qualified helicopter manager is on order, and there 

are active efforts to fill the position; (2) both helicopters are physically side-by-side at the 

same helibase; (3) a helibase manager is assigned; (4) aerial supervision is provided; and (5) 

approval has been granted by the appropriate agency aviation manager.
Page 26 GAO-04-426 Biscuit Fire Response

Fire Center officials requested and received numerous supervisors from 

Australia and New Zealand, including eight helicopter managers. 

The inability to fill government strike team leader positions also resulted in 

delays in fire suppression actions, according to a Biscuit Fire operations 

manager. In one effort to mitigate this shortage, three qualified staff were 

transferred from a hot shot crew to work as strike team leaders supervising 

contracted crews, according to the division supervisor. The supervisor 

said, however, this move lowered the firefighting effectiveness of the hot 

shot crew. In another case, a shortage of division supervisors resulted in 

the inability to provide adequate supervision in two of the four fire zones 

for about one week, according to an operations section chief. The lack of 

needed supervision resulted in the inability to use crews to carry out 

planned actions, and as a result, fire suppression progress was delayed. 

Our findings on the reduced availability of personnel to fill critical staff 

positions were confirmed by an internal Forest Service review of the 

Biscuit Fire as well as Forest Service reviews of other wildland firefighting 

efforts. The Forest Service review of the Biscuit Fire concluded that 

opportunities to halt the spread of the fire had to be abandoned because of 

limited resources, and as a result, the fire grew larger and threatened more 

communities on both the western and eastern perimeters. The Forest 

Service’s January 2000 report, An Agency Strategy for Fire Management, 

highlighted the shortage of federal staff for both fire suppression and fire 

support positions. Also, during July 2002, the Northwest Multi-Agency 

Coordination Group in Portland, Oregon, reviewed ongoing fires in the 

Pacific Northwest, including the Biscuit Fire, and the effects of the reduced 

availability of personnel to fill critical supervisory positions for fire 

suppression. The group noted that some crews and equipment had been 

suspended from fire suppression efforts because of a lack of appropriate 

supervision. 

Shortage of Personnel to 

Effectively Monitor 

Contractors Working on the 

Biscuit Fire

Contracted resources played a key role in the Biscuit Fire—at its peak over 

1,600 contracted firefighters and over 400 pieces of contracted equipment 

and helicopters were assigned to the fire. Interagency fire managers 

acknowledged, however, that there was little, if any, monitoring of private 

contractors to ensure that contracted crews assigned to the Biscuit Fire 

met established training and experience requirements. Instead, fire 

managers generally relied on contractors to certify that their crews met 

these requirements, as stated in their contract. Despite contractors’ 

assurances that their crew met all requirements, Biscuit Fire officials told 
Page 27 GAO-04-426 Biscuit Fire Response

us that some insufficiently trained or inexperienced contracted crews 

negatively impacted firefighting efforts because these crews were not 

always able to carry out planned operations. In contrast, contracted 

engines and other equipment had fewer problems.

Fire managers participating on the Biscuit Fire said that poorly trained and 

inexperienced contracted crews presented significant operational 

concerns. They cited examples of contracted crews that were unable to 

carry out planned firefighting operations. Managers said that they 

postponed or changed some tactical firefighting operations because it was 

not safe using these crews in more aggressive fire operations. Crews that 

could not be used as planned were assigned minimal firefighting 

responsibilities, such as “mop up” activities at a considerable distance from 

intensive fire activity. Although the limitations on how the crews could 

safely be used likely affected progress of firefighting, the actual effect 

cannot be measured. 

Communication to and between crews also adversely impacted the use of 

contracted crews on the Biscuit Fire. There were instances where crew and 

squad bosses for contracted crews were unable to communicate in English 

with government supervisors, as required in the interagency crew 

agreement. The lack of fluency in English caused safety concerns and 

resulted in crews being assigned to far less technical tasks than planned. 

Fire managers told us that, even when assigned minimal fire tasks, some 

private crews required above normal supervision, which in turn resulted in 

supervisors having less time available to plan and implement higher 

priority fire suppression tasks. 

Under a cooperative arrangement between the federal government and the 

states of Oregon and Washington, ODF has oversight responsibility for 

private crew contractors in the Northwest. Typically, the monitoring of 

crew qualifications should take place before the start of the fire season. An 

ODF official, however, said that insufficient funding and personnel have 

resulted in few, if any, evaluations of crews’ qualifications prior to the start 

of the fire season. Alternatively, interagency support personnel, such as 

contracting officers or their technical representatives, can perform 

contract crew qualification assessments. We found that during the Biscuit 

Fire, however, these key support positions were identified as a critical, but 

unfilled, resource need. According to federal firefighting managers, about 

90 individuals have been trained as technical representatives to work with 

firefighting management teams, but at any given time during recent fire 

seasons, only about 10 percent of these trained technical representatives 
Page 28 GAO-04-426 Biscuit Fire Response

were available to serve on incident management teams. The ODF official 

having oversight responsibility for contracted crews in the Northwest 

concluded that because of these shortages and the significant numbers of 

contracted crews, it is likely that there was minimal monitoring of contract 

crews at the fire. Finally, we noted that these shortcomings in the 

monitoring of contracted crews were not limited to the Biscuit Fire. The 

importance of monitoring crew training and experience was also cited in an 

interagency fire and aviation safety report issued in 2002.14 The review 

stated that deficiencies in the physical fitness and job skills of crews raised 

concerns about the validity of qualifications of some contracted resources. 

Some Differences in 

Certification Standards 

Exist between State 

and Federal 

Firefighting Agencies, 

but No Effect Was 

Identified

There are some differences in certification standards for personnel 

between state and federal wildland firefighting agencies, but these 

differences did not appear to have affected efforts to respond to the Biscuit 

Fire. 

In 1993, the National Wildfire Coordinating Group (NWCG)—an 

interagency group comprising federal and state representatives—

established minimum training and experience standards15 for personnel 

assigned to fight interagency wildland fires outside their home region. 

These standards, which were updated in 2000, have been adopted by five 

federal land management agencies, including the Forest Service.16 Five of 

the seven states that we contacted in and around the Northwest Region 

have also adopted these standards as the minimum requirements for all 

their firefighting personnel.17 The Oregon Department of Forestry (ODF) 

meets these standards for personnel on interagency wildland fires outside 

the Northwest Region. For fires under state management and for 

14Final Report: Fire & Aviation Safety Team Review of Northwest Geographic Area (July 

19 through Aug. 1, 2002). 

15This system is the Wildland and Prescribed Fire Qualifications System, commonly referred 

to as 310-1. 

16The Forest Service has supplemented NWCG (310-1) standards with additional 

requirements that apply only to Forest Service personnel.

17We spoke with wildland firefighting officials in California, Idaho, Montana, Nevada, 

Oregon, Utah, and Washington.
Page 29 GAO-04-426 Biscuit Fire Response

interagency fires within the region,18 ODF has maintained its own 

certification standards. These standards are nearly identical to the 1993 

version of NWCG standards.19 In 2000, NWCG added some course and 

experience requirements. ODF officials are currently working to 

incorporate many, but not all, of these changes into state standards. For 

example, ODF requirements for many positions rated type 2 or below will 

meet NWCG standards. For type 1 positions, including incident 

commander, some of the most advanced courses will not be required. An 

ODF official explained that he believed, for state-managed fires, these 

additional courses were not necessary. The California Department of 

Forestry and Fire Protection (CDF) has maintained its own firefighting 

certification system for its firefighting personnel. CDF shares many of the 

same standards as those established by NWCG, including the combination 

of coursework and experience requirements for firefighting certification,20

but requires state-specific courses for some positions. Under an agreement 

with federal land management agencies, California state personnel 

assigned to interagency fires in supervisory roles within the state are 

required to be certified to a level equivalent to NWCG standards.21 For 

national mobilization, NWCG requires that participating agencies certify 

that their personnel meet the established interagency qualification 

standards. In the case of California, CDF officials stated that state 

certification requirements meet or exceed the standards established by 

NWCG. In addition, National Interagency Fire Center officials said they 

have no concerns about the adequacy of the standards used by CDF. 

18A 1998 agreement between Oregon, Washington, and federal land management agencies 

recognizes each agency’s standards as reasonable, prudent, and acceptable for firefighting 

on lands under private, state, or federal protection.

19Although Oregon standards differ from those set by NWCG, approximately 70 percent of 

the state’s roughly 600 permanent firefighting personnel are certified in one or more 

interagency incident command positions, according to an ODF official. In addition, another 

roughly 300 seasonal employees are brought in each year that, by their job duties, must be 

interagency certified.

20California’s Office of Emergency Services coordinates the sharing of local emergency 

personnel, including wildland firefighters, through the state’s municipal aid program. The 

standards used are based on NWCG standards, and these personnel are shared with 

interagency efforts.

21A May 2002 agreement between California and federal land management agencies specifies 

that supervisory personnel responding to interagency fires in the state and some adjacent 

areas shall meet either NWCG training requirements or those of the California Incident 

Command Certification System, which is based on NWCG standards. The agreement also 

provides recommended qualifications for engine crews. 
Page 30 GAO-04-426 Biscuit Fire Response

There was no apparent impact on the response to the Biscuit Fire as a 

result of different agency firefighting certification standards. As with other 

interagency fires, personnel that were dispatched to fight on interagency 

fires outside their home region were required to meet these standards. 

Within the Northwest Region, ODF maintains its own standards for state 

fires and interagency fires, although only NWCG-qualified personnel were 

dispatched to the Biscuit Fire, according to an ODF official. While CDF 

utilizes an independent set of requirements, NIFC officials said they had no 

concerns about the adequacy of the certification system used by CDF. In 

addition, for the portion of the Biscuit Fire that was located in California, 

CDF supervisory personnel assigned to the fire were required by agreement 

to be certified to a level equivalent with NWCG standards. Finally, our 

review of relevant documents and discussions with knowledgeable federal, 

state, and local officials did not identify any evidence that the differences 

between these systems created difficulties during the response to the 

Biscuit Fire. 

Conclusions The cornerstone of wildland fire policy is interagency cooperation and 

coordination among federal, state, tribal, and local firefighting agencies. 

Central to that cooperation and coordination is a system that includes 

managers and personnel from many different agencies and that crosses 

jurisdictional boundaries. Such a system is facilitated by good 

communication between personnel at all levels to help ensure clarity of 

firefighting goals, strategies, and tactics. Communication is also important 

for those working in various dispatch centers to obtain firefighting 

resources. These personnel must communicate in a timely—sometimes 

immediate—fashion to other dispatch centers the resources they need to 

fight new or ongoing fires in their area. In the case of the Biscuit Fire, 

Grants Pass dispatch personnel did communicate resource needs to their 

regional dispatch center in Portland, but no resources were immediately 

available due to other higher priority fires in the region. However, 

personnel did not communicate the need for initial attack resources to a 

neighboring dispatch center in Fortuna, California, although this was an 

option available to Grants Pass personnel. Whether this would have 

resulted in any resources being provided for the initial attack of the Biscuit 

Fire is unclear because personnel in the Fortuna dispatch center disagree 

on whether any resources could have been spared, given that fires were 

also burning in Northern California at the time. Since no request was made, 

the priority of the Biscuit Fire relative to other ongoing fires within the 

Fortuna dispatch center’s direct protection area was not discussed on the 
Page 31 GAO-04-426 Biscuit Fire Response

first day of the Biscuit Fire, and the outcome of such a request, had it been 

made, remains unclear.

Agency Comments and 

Our Evaluation

We provided a draft of this report to the Secretaries of Agriculture and of 

the Interior for review and comment. The Forest Service commented that 

the report appears to be accurate and the agency generally agrees with its 

contents. The Forest Service’s comments are presented in appendix II. The 

Department of the Interior did not provide comments.

As arranged with your offices, unless you publicly announce the contents 

earlier, we plan no further distribution of this report until 30 days after the 

date of this letter. At that time, we will send copies of this report to other 

interested congressional committees. We will also send copies to the 

Secretary of Agriculture; the Secretary of the Interior; the Chief of the 

Forest Service; the Directors of the Bureau of Land Management, the 

National Park Service, the Fish and Wildlife Service, and the Bureau of 

Indian Affairs; and other interested parties. We will make copies available 

to others upon request. In addition, this report will be available at no 

charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions about his report, please contact me 

at (202) 512-3841. Key contributors to this report are listed in appendix III.

Barry T. Hill

Director, Natural Resources and Environment
Page 32 GAO-04-426 Biscuit Fire Response

Appendix I

Scope and Methodology ApApenednxidexiIs

To determine whether policies and procedures were in place for acquiring 

needed firefighting resources during the initial days of the Biscuit Fire, and 

the extent to which these policies and procedures were followed when the 

fire was first identified, we reviewed national policies and procedures that 

included the National Interagency Standards for Fire and Fire Aviation 

Operations and the National Interagency Mobilization Guide. We reviewed 

the interagency mobilization guides in 9 of the 11 regions.1

 We also 

reviewed the local mobilization guide covering the Grants Pass dispatch 

center and the mobilization guides for three other local dispatch centers.2

 

We reviewed the mutual aid agreements governing resource sharing for the 

Siskiyou National Forest. We spoke with officials at the National 

Interagency Fire Center (NIFC) in Boise, Idaho; Forest Service 

headquarters in Washington, D.C.; Forest Service Regions 5 and 6 regional 

offices; Bureau of Land Management, Oregon State Office and the Medford 

District Office; the Siskiyou and Six Rivers National Forests; the Oregon 

Department of Forestry (ODF); and the California Department of Forestry 

and Fire Protection (CDF). We visited three dispatch centers in Oregon 

(the Grants Pass Interagency Fire Center, the Medford Interagency Fire 

Center, and the Northwest Interagency Coordination Center in Portland) 

and one in California (the Fortuna Interagency Emergency Command 

Center) to discuss dispatch center operations. We also reviewed Biscuit 

Fire records stored at Siskiyou National Forest headquarters in Medford, 

Oregon, and records kept at Fortuna, including resource orders and 

transcripts of key radio transmissions during the initial days of the Biscuit 

Fire. The Forest Service provided the data used to generate the fire 

progression maps. We took steps to assess the reliability of the mapping 

data and determined that it was sufficiently accurate for our purposes.

To determine what resource management issues, if any, affected the ability 

of firefighting personnel to effectively fight the Biscuit Fire, we reviewed a 

variety of information, including resource orders and daily incident reports 

showing firefighting resources requested and obtained, incident action 

plans showing firefighting strategies and tactics, close-out reports 

discussing firefighting progress and problems, and Forest Service reviews 

of the Biscuit Fire. We interviewed a number of federal and state personnel 

knowledgeable about the Biscuit Fire, including officials from the Siskiyou 

1

These were the Northwest, Northern California, Southern California, Western Great Basin, 

Eastern Great Basin, Southwest, Northern Rockies, Rocky Mountain, and Eastern regions.

2

These dispatch centers were the Central Washington Interagency Communications Center, 

the Casper Interagency Dispatch Center, and the North Dakota Interagency Dispatch Center.
Appendix I

Scope and Methodology

Page 33 GAO-04-426 Biscuit Fire Response

and Six Rivers National Forests, ODF, and CDF, and the management teams 

and other key support staff that were assigned to the Biscuit Fire. We 

discussed resource management issues, their effect on the fighting of the 

Biscuit Fire, and the reasons for these issues or problems. We also 

reviewed assessments of other wildland fires to determine if the issues 

identified were limited to the Biscuit Fire or were more widespread. 

To determine what differences, if any, existed in key personnel certification 

standards at federal and state agencies involved in fighting wildland fires—

particularly in Oregon—we reviewed the interagency qualification 

standards established by NWCG. We also contacted officials from Oregon 

and California, where the Biscuit Fire burned, and five other states—Idaho, 

Montana, Nevada, Utah, and Washington—to discuss the certification 

standards they use, and whether they differ from those established by 

NWCG. In addition, we reviewed state firefighting standards for ODF and 

CDF and compared them with those established by NWCG. To determine 

what effect any differences may have had on the response to the Biscuit 

Fire, we spoke with federal officials with NIFC, the Forest Service, the 

Bureau of Land Management, and the National Park Service; officials with 

the National Association of State Foresters; and state and local officials in 

Oregon and California, including officials from ODF, CDF, and the 

California Office of Emergency Services. 

We conducted our work from April 2003 through February 2004 in 

accordance with generally accepted government auditing standards.
Page 34 GAO-04-426 Biscuit Fire Response

Appendix II

Comments from the Forest Service ApendxiI
Page 35 GAO-04-426 Biscuit Fire Response

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contact Barry T. Hill, (202) 512-3841 or hillbt@gao.gov

Staff 

Acknowledgments

Andrea W. Brown, John Delicath, Cliff Fowler (retired), Janet Frisch, Molly 

Laster, Paul E. Staley, Stanley G. Stenersen, Amy Webbink, and Arvin Wu 

made key contributions to this report.

(360319)
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