United States Government Accountability Office

GAO Report to the Chairman, Subcommittee 

on Public Lands and Forests, 

Committee on Energy and Natural 

Resources, U.S. Senate 

WILDLAND FIRE 

SUPPRESSION 

Lack of Clear 

Guidance Raises 

Concerns about Cost 

Sharing between 

Federal and 

Nonfederal Entities 

May 2006 

 

GAO-06-570 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

May 2006

WILDLAND FIRE SUPPRESSION

Lack of Clear Guidance Raises Concerns 

about Cost Sharing between Federal and 

Nonfederal Entities 

Highlights of GAO-06-570, a report to the 

Chairman, Subcommittee on Public Lands 

and Forests, Committee on Energy and 

Natural Resources, U.S. Senate 

Wildland fires burn millions of 

acres each year, requiring 

substantial investments of 

firefighting assets. Since 2000,

federal suppression costs alone 

have averaged more than $1 billion 

annually. Wildland fires can burn or 

threaten both federal and 

nonfederal lands and resources, 

including homes in or near 

wildlands, an area commonly

called the wildland-urban interface. 

Cooperative agreements between 

federal and nonfederal firefighting

entities provide the framework for 

working together and sharing 

costs. GAO was asked to (1) review 

how federal and nonfederal entities

share the costs of suppressing 

wildland fires that burn or threaten

both of their lands and resources 

and (2) identify any concerns that

these entities may have with the

existing cost-sharing framework.

What GAO Recommends

GAO recommends that the

Secretaries of Agriculture and the 

Interior, working with relevant

state entities, provide more specific 

guidance on when to use particular 

cost-sharing methods and clarify 

the financial responsibilities for 

fires that burn or threaten to burn

across multiple jurisdictions. The

Forest Service and Interior

generally agreed with the findings

and recommendations. The 

National Association of State 

Foresters disagreed, stating that

the recommendations would not 

provide the flexibility needed to 

address the variability in local 

circumstances and state laws. 

Federal and nonfederal entities used a variety of methods to share the costs 

of fighting wildland fires affecting both of their lands and resources. 

Cooperative agreements between federal and nonfederal firefighting 

entities—which are developed and agreed to by the entities involved—

provide the framework for cost sharing and typically list several cost-sharing

methods available to the entities. The agreements GAO reviewed, however,

often lacked clear guidance for federal and nonfederal officials to use in 

deciding which method to apply to a specific fire. As a result, cost-sharing 

methods were applied inconsistently within and among states, even for fires 

with similar characteristics. For example, GAO found that in one state, the 

costs for suppressing a large fire that threatened homes were shared solely 

according to the proportion of acres burned within each entity’s area of fire 

protection responsibility. Yet, costs for a similar fire within the same state 

were shared differently. For this fire, the state agreed to pay for certain 

aircraft and fire engines used to protect the wildland-urban interface, while 

the remaining costs were shared on the basis of acres burned. In contrast to 

the two methods used in this state, officials in another state used yet a 

different cost-sharing method for two similar large fires that threatened 

homes, apportioning costs each day for personnel, aircraft, and equipment 

deployed on particular lands, such as the wildland-urban interface. The type

of cost-sharing method ultimately used is important because it can have 

significant financial consequences for the entities involved, potentially 

amounting to millions of dollars. 

Both federal and nonfederal agency officials raised a number of concerns 

about the current cost-sharing framework. First, some federal officials were 

concerned that because guidance is unclear about which cost-sharing 

methods are most appropriate in particular circumstances, it can be difficult 

to reach agreement with nonfederal officials on a method that all parties 

believe distributes suppression costs equitably. Second, some nonfederal 

officials expressed concerns that the emergence of alternative cost-sharing

methods is causing nonfederal entities to bear a greater share of fire 

suppression costs than in the past. In addition, both federal and nonfederal 

officials believed that the inconsistent application of these cost-sharing 

methods has led to inequities among states in the proportion of costs borne 

by federal and nonfederal entities. Finally, some federal officials also 

expressed concern that the current framework for sharing costs insulates 

state and local governments from the increasing costs of protecting the 

wildland-urban interface. Therefore, nonfederal entities may have a reduced 

incentive to take steps that could help mitigate fire risks, such as requiring 

homeowners to use fire-resistant materials and landscaping. On the basis of 

a review of previous federal reports and interviews with federal and 

nonfederal officials, GAO believes that these concerns may reflect a more 

fundamental issue—that federal and nonfederal entities have not clearly 

defined their financial responsibilities for wildland fire suppression, 

particularly those for protecting the wildland-urban interface. 

www.gao.gov/cgi-bin/getrpt?GAO-06-570.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robin M. 

Nazzaro at (202) 512-3841 or 

nazzaror@gao.gov. 
Contents 

Letter 1

Results in Brief 3

Background 4

Unclear Guidance and Inconsistent Application of Cost-Sharing 

Methods Can Have Significant Financial Consequences for 

Entities Involved 9 

Current Cost-Sharing Framework Raises Several Concerns 19 

Conclusions 27

Recommendations for Executive Action 28 

Agency Comments and Our Evaluation 28 

Appendix I Scope and Methodology 31 

Appendix II Characteristics of the Eight Fires That GAO 

Reviewed 34 

Appendix III Comments from the USDA Forest Service 35 

GAO Comments 37 

Appendix IV Comments from the Department of the Interior 38 

Appendix V Comments from the National Association of State 

Foresters 39 

GAO Comments 41 

Appendix VI GAO Contact and Staff Acknowledgments 43 

Table 

Table 1: Master Agreements for 12 Western States Varied in the 

Cost-Sharing Methods Specified 10 

Page i GAO-06-570 Wildland Fire Suppression Cost Sharing
Figures 

Figure 1: The Varied Cost-Sharing Methods Used for Eight Similar 

Fires We Reviewed 13 

Figure 2: Distribution of Costs under the Actual Cost-Sharing 

Method Used Compared with an Acres-Burned Method 17 

Abbreviations 

FEMA Federal Emergency Management Agency 

IMT incident management team 

NASF National Association of State Foresters 

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

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reproduce this material separately. 

Page ii GAO-06-570 Wildland Fire Suppression Cost Sharing
United States Government Accountability Office

Washington, DC 20548 

May 30, 2006

The Honorable Larry E. Craig 

Chairman, Subcommittee on Public Lands and Forests 

Committee on Energy and Natural Resources 

United States Senate 

Dear Mr. Chairman: 

Wildland fires burn millions of acres of land each year. Although wildland

fires triggered by lightning are a natural, inevitable, and necessary 

ecological process, past federal fire suppression policies have led to an 

accumulation of fuels and contributed to larger and more severe wildland

fires. In addition, as human development continues to expand in or near 

wildlands—an area commonly known as the wildland-urban interface—

wildland fires increasingly threaten not only federal lands and public 

resources, such as forests and watersheds, but also nonfederal lands and 

resources, including homes and other structures. 

Fighting wildland fires—which can burn across federal, state, and local 

jurisdictions—requires significant investments of firefighting personnel, 

aircraft, equipment, and supplies, resulting in substantial and increasing 

fire suppression expenditures. Since 2000, federal suppression

expenditures alone have averaged more than $1 billion annually. In 

addition, nonfederal entities, such as state and local governments, can 

spend hundreds of millions of dollars during severe fire years. Firefighting 

efforts are mobilized through an interagency incident management system, 

which depends on the close cooperation and coordination of federal, state, 

tribal, and local fire protection entities. At the federal level, five principal

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

Department of Agriculture and four agencies within the Department of the 

Interior.1

 Federal and nonfederal firefighting entities share their personnel, 

equipment, and supplies and work together to fight fires, regardless of 

which entity has jurisdiction over the burning lands. Agreements between 

cooperating entities, commonly referred to as master agreements, govern 

 1

The four agencies within the Department of the Interior responsible for wildland 

firefighting are the Bureau of Indian Affairs, Bureau of Land Management, Fish and Wildlife 

Service, and National Park Service. 

Page 1 GAO-06-570 Wildland Fire Suppression Cost Sharing
these cooperative fire protection efforts and include general provisions for 

sharing firefighting costs. According to federal officials, these provisions, 

and the guidance on available cost-sharing methods, have been changing 

over the years, in part, to address the continuing expansion of the 

wildland-urban interface and the resulting increase in nonfederal 

resources at risk from wildland fire.

In this context of both the increasing size and severity of wildland fires 

and the rising costs of suppressing fires and protecting federal and 

nonfederal lands and resources, you asked us to (1) review how federal 

and nonfederal entities share the costs of suppressing wildland fires that 

burn or threaten both of their lands and resources and (2) identify any 

concerns federal and nonfederal entities may have with the existing costsharing framework. To address these objectives, we reviewed federal 

statutes governing cooperative fire protection activities; federal and 

interagency wildland fire policies and procedures; master agreements 

between federal and nonfederal entities governing cooperative fire 

protection in 12 western states that frequently experience wildland fires;2

and federal, state, and nongovernmental entities’ reviews of recent large 

fires or other reports related to wildland fire suppression costs. We also 

interviewed national, regional, and local firefighting officials from the 

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

officials from Arizona, California, Colorado, and Utah. In addition, for two 

recent fires that burned or threatened both federal and nonfederal lands 

and resources in the 4 states, we reviewed the records listing the 

firefighting resources deployed, their costs, and the methods chosen to 

share these costs.3 We determined that these data were sufficiently reliable 

for the purposes of this report. Appendix I contains a more detailed 

description of our scope and methodology, and appendix II contains 

additional information on the fires we reviewed. We performed our work 

in accordance with generally accepted government auditing standards 

from May 2005 through May 2006. 

 2

These 12 states were Alaska, Arizona, California, Colorado, Idaho, Montana, Nevada, New 

Mexico, Oregon, Utah, Washington, and Wyoming. Although wildland fires can affect all 

states, we selected these western states because they have substantial federal lands and 

often experience wildland fires. 

3

The 12 master agreements reviewed, 4 states visited, and two wildland fires reviewed 

within each visited state are all nonprobability samples. Therefore, the results from these 

samples cannot be used to make inferences about all master agreements, states, or

wildland fires. 

Page 2 GAO-06-570 Wildland Fire Suppression Cost Sharing
Federal and nonfederal entities used a variety of methods to share the 

costs of fighting wildland fires affecting both of their lands and resources, 

but they applied these varied methods inconsistently to fires with similar 

characteristics. Master agreements between firefighting entities provide 

the framework for cost sharing and, typically, list several cost-sharing 

methods available to the entities. The agreements we reviewed, however, 

often lacked clear guidance for federal and nonfederal officials to use in 

deciding which method to apply to a specific fire. As a result, cost-sharing 

methods were applied inconsistently within and among states, even for 

fires with similar characteristics. For example, we found that in one state, 

the costs for suppressing a large fire that threatened homes were shared 

solely according to the proportion of acres burned within each entity’s 

area of fire protection responsibility. However, costs for a similar fire 

within the same state were shared differently. For this fire, the state paid 

for certain aircraft and fire engines used to protect the wildland-urban 

interface, while the remaining costs were shared on the basis of acres 

burned. In contrast to the two methods used in this state, officials in 

another state used yet a different cost-sharing method for two similar large 

fires that threatened homes, apportioning costs each day for personnel, 

aircraft, and equipment deployed on particular lands, such as the wildlandurban interface. The type of cost-sharing method ultimately used is 

important because it can have significant financial consequences for the 

entities involved, potentially amounting to millions of dollars. 

Results in Brief 

Federal and nonfederal agency officials we interviewed raised a number of 

concerns about the current cost-sharing framework. First, some federal 

officials were concerned that because guidance is unclear about which 

cost-sharing methods are most appropriate in particular circumstances, it 

can be difficult to reach agreement with nonfederal officials on a method

that all parties believe shares suppression costs equitably between 

affected federal and nonfederal entities, particularly for fires threatening 

the wildland-urban interface. For example, different cost-sharing methods 

were used for two fires we reviewed in one state, even though both fires 

required substantial suppression effort to protect the wildland-urban 

interface. Nonfederal officials agreed to pay a higher proportion of the 

suppression costs for one fire—primarily because most of the nonfederal

share of the fire’s costs were eligible for reimbursement by a Federal 

Emergency Management Agency (FEMA) grant program—but they would 

not agree to do so for the second fire. Second, nonfederal officials were 

concerned that the emergence of alternative cost-sharing methods is 

causing state and local entities to bear a greater share of suppression costs 

than in the past. Moreover, both federal and nonfederal officials were 

concerned that the inconsistent application of cost-sharing methods has 

Page 3 GAO-06-570 Wildland Fire Suppression Cost Sharing
created inequities among states in the proportion of suppression costs 

borne by federal and nonfederal entities. Finally, some federal officials 

also expressed concern that the current framework for sharing costs—

combined with the availability of funds from FEMA to reimburse 

nonfederal entities in certain cases—insulates state and local governments 

from the increasing costs of protecting the wildland-urban interface. 

Consequently, nonfederal entities may have a reduced incentive for 

requiring the use of fire-resistant building materials and landscaping, 

which can help mitigate fire risks in the wildland-urban interface and 

thereby help reduce the costs of protecting it. On the basis of our review 

of previous federal reports and interviews with federal and nonfederal 

officials, we believe that these concerns may reflect a more fundamental 

issue—that federal and nonfederal entities have not clearly defined their 

financial responsibilities for wildland fire suppression, particularly those 

for protecting the wildland-urban interface. 

To strengthen the framework for sharing wildland fire suppression costs, 

we are recommending that the Secretaries of Agriculture and the Interior, 

working in conjunction with relevant state entities, (1) provide more 

specific guidance as to when particular cost-sharing methods should be 

used and (2) clarify the financial responsibilities for suppressing fires that 

burn or threaten to burn across multiple jurisdictions. In commenting on a 

draft of this report, the Forest Service and Interior generally agreed with 

our findings and recommendations. The National Association of State 

Foresters (NASF) also provided comments on the report and generally did 

not agree with the recommendations. NASF stated that developing 

national guidance specifying appropriate cost-sharing methods and 

clarifying financial responsibility for fire suppression costs would not 

provide the flexibility needed by local federal and nonfederal officials to 

address the variability in local circumstances and state laws. We agree that 

a certain amount of flexibility is needed, however, without more explicit 

guidance to assist local federal and nonfederal officials responsible for 

developing cost-sharing agreements for individual fires, the 

inconsistencies in how suppression costs are shared within and among 

states are likely to continue, along with concerns about perceived 

inequities. Comments from the Forest Service, Interior, and NASF are 

reprinted in appendixes III, IV, and V, respectively. 

Wildland fires triggered by lightning are both natural and inevitable, and 

they play an important role on our nation’s lands. Many ecosystems have 

adapted to periodic wildland fires, which help control vegetation levels 

and stimulate seedling regeneration and growth. Past land management 

Background 

Page 4 GAO-06-570 Wildland Fire Suppression Cost Sharing
practices, including effective fire suppression, have disrupted the historic 

frequency of wildland fires. As a result, a decrease in the number of acres 

burned nationwide during much of the twentieth century has led to an

accumulation of dense vegetation that now fuels larger, more severe, and 

sometimes catastrophic wildland fires. 

In recent years, both the number of acres burned by wildland fires and the

costs to suppress fires have been increasing. From 1995 through 1999, 

wildland fires burned an average of 4.1 million acres each year; from 2000 

through 2004, the fires burned an average of 6.1 million acres each year—

an increase of almost 50 percent. During the same periods, the costs 

incurred by federal firefighting entities to suppress wildland fires more 

than doubled, from an average of $500 million annually to more than 

$1.3 billion annually.4

 Although efforts to fight these larger, more severe 

fires have accounted for much of the increase in suppression costs, the 

continuing development of homes and communities in areas at risk from 

wildland fires and the efforts to protect these structures also contribute to 

the increasing costs. Forest Service and university researchers estimate 

that about 44 million homes in the lower 48 states are located in areas that 

meet or intermingle with wildlands—commonly referred to as the 

wildland-urban interface.5

 When fire threatens the wildland-urban 

interface, firefighting entities often need to use substantial resources to 

fight the fire and protect homes, including firefighters, fire engines, and 

aircraft to drop retardant. Although firefighters are able to protect many 

homes threatened by wildland fires, these fires have burned an average of

about 850 homes each year in the United States since 1984. 

Because one firefighting entity alone cannot handle all wildland fires that 

may occur in its jurisdiction, federal and nonfederal entities work together 

to protect lands and resources and to fight fires. At the federal level, five 

principal agencies are involved in fire suppression—the Forest Service 

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

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

Service within the Department of the Interior. In addition, nonfederal 

entities—including state forestry entities and tribal, county, city, and rural 

 4

These dollars have been adjusted for inflation using the gross domestic product price 

index, with fiscal year 2005 as the base year. 

5

Susan Stewart et al., Mapping the Wildland Urban Interface and Projecting Its Growth to

2030: Summary Statistics, January 2005, 

http://www.silvis.forest.wisc.edu/Library/Stats/uswuistats.pdf (downloaded May 5, 2006). 

Page 5 GAO-06-570 Wildland Fire Suppression Cost Sharing
fire departments—play an important role in protecting resources and 

fighting fires. Federal and nonfederal entities enter into master agreements 

that govern their cooperative fire protection activities, including wildland 

fire suppression, and provide for sharing the costs of these efforts.6

 To 

share suppression costs for a specific fire, local representatives of federal

and nonfederal firefighting entities responsible for protecting lands and 

resources affected by the fire decide which costs will be shared and for 

what period. They document their decisions in a cost-sharing agreement 

for that fire. These local representatives can include federal officials from 

a national forest, a Bureau of Land Management district office, or a 

national park and nonfederal officials from the state or other entities. In 

developing the cost-sharing agreement for a specific fire, these officials 

are guided by the terms of the master agreement.

As wildland fire suppression costs have continued to rise, increasing 

attention has focused on how suppression costs for multijurisdictional 

fires are shared. According to federal officials, in the past these 

cooperating entities often shared suppression costs on the basis of the 

proportion of acres burned in each entity’s protection area. These officials 

explained that this method is relatively easy to apply and works well when

the lands affected by a wildland fire are similar. In 2000, federal officials 

updated interagency policy to include, among other things, additional 

information about alternative cost-sharing methods. According to a federal 

official, the interagency policy was updated, in part, in response to 

requests for additional guidance on cost sharing.7

 In addition to the acresburned method, the policy describes two alternative methods for sharing 

the costs of fire suppression efforts.8

 Under the first alternative—you 

order, you pay—each entity pays for the firefighting personnel, aircraft, 

 6

Cooperative fire protection agreements for the Forest Service are executed principally 

under the following five laws: The Granger-Thye Act of 1950, the Reciprocal Fire Protection

Act of 1955, the Cooperative Funds and Deposits Act of 1975, the Cooperative Funds Act of

1914, and the Cooperative Forestry Assistance Act of 1978, as amended. Cooperative fire

protection agreements involving Department of the Interior agencies are executed, among

other authorities, under the Reciprocal Fire Protection Act of 1955. 

7

National Wildfire Coordinating Group, Interagency Incident Business Management 

Handbook (Boise, Id.: 2004). 

8

According to the Interagency Incident Business Management Handbook, an acres-burned

method should be used when entities’ responsibilities, objectives, and suppression costs 

are similar. The handbook also lists a fourth method, which addresses sharing costs for a

fire controlled during initial fire suppression efforts. This fourth method did not apply to

our study because none of the fires we reviewed were controlled during the initial “attack” 

period. 

Page 6 GAO-06-570 Wildland Fire Suppression Cost Sharing
and equipment it orders, regardless of where these resources are deployed

during a fire. Under the second alternative—cost apportionment—entities 

share total fire costs according to the assignment or actual use each day of 

firefighting personnel, aircraft, and equipment in federal or nonfederal 

protection areas. Indirect costs can then be shared in the same 

proportions as these direct costs.9

 According to the interagency policy, 

however, the cost-sharing terms of the master agreements take 

precedence.

To facilitate an effective response to wildland fires—including those 

affecting both federal and nonfederal jurisdictions—firefighting entities in

the United States use an interagency incident management system. This 

system provides an organizational structure that expands to meet a fire’s 

complexity and demands and allows entities to share firefighting 

personnel, aircraft, and equipment. When a fire is first detected, 

firefighting entities normally follow a principle of “closest available 

resource,” whereby, regardless of jurisdiction, the closest available 

firefighting personnel and equipment respond to the fire. The firefighter 

managing the suppression efforts is called the incident commander. 

Typically, when a fire is first detected, it is classified as a type 5—the least 

complex—or type 4 fire, depending on the fire and the number of 

firefighters needed to fight it. If additional firefighting assets are needed, 

the incident commander orders them through a three-tiered system of 

local, regional, and national dispatch centers. Federal, state, tribal, and 

local entities and private contractors supply the firefighting personnel, 

aircraft, equipment, and supplies, which are coordinated and dispatched 

through these centers. If the fire escapes initial suppression efforts, 

officials may request a type 3 incident commander and additional 

firefighting assets. The fire may grow in size or complexity into a type 2 or 

type 1 fire, the latter being the most complex. For such fires, officials may

request an incident management team that includes not only an incident 

commander but a cadre of personnel to handle command, planning, 

logistics, operations, and finance functions. Nationally, there are 17 type 1 

incident management teams available to manage the most complex fires. 

An additional 38 type 2 teams are available to manage large fires that are 

less complex. 

 9

Direct costs include the costs for firefighters, aircraft, and equipment deployed to fight the

fire. Indirect costs include the costs for fire managers, fire camps, and other support 

services. 

Page 7 GAO-06-570 Wildland Fire Suppression Cost Sharing
In 2000, in response to a decade of severe wildland fires, the Departments 

of Agriculture and the Interior developed a National Fire Plan. This plan 

comprises several strategic documents that together address how to 

respond to wildland fires, reduce the impacts of these fires on 

communities and the environment, and ensure sufficient firefighting 

resources for the future.10 The National Fire Plan encourages collaboration

and cooperation among a variety of stakeholders, including federal, state, 

and local firefighting and other government entities; nongovernmental 

entities; and property owners. The plan includes a 10-year comprehensive 

strategy and an associated implementation plan that outline a 

collaborative approach for reducing wildland fire risks to communities 

and the environment. The implementation plan includes steps addressing 

four key areas—improving fire prevention and suppression, reducing 

hazardous fuels, restoring fire-adapted ecosystems, and promoting 

community assistance—and identifies parties to help carry out these steps. 

For example, to help protect structures and communities, state and local 

entities are encouraged to develop and adopt local land-use plans and 

ordinances to help reduce the wildland fire risks to homes and other 

structures. To help meet National Fire Plan goals, Congress provided 

funding for programs to assist not only federal firefighting entities but also 

nonfederal entities and communities. For fiscal years 2001 through 2005, 

assistance to nonfederal entities and communities totaled $436 million 

($462 million adjusted for inflation). These funds—in the form of grants or 

other assistance administered by the Departments of Agriculture and the 

Interior—were used to train state and local firefighters and acquire 

firefighting equipment, carry out hazardous fuel treatments, conduct 

hazard assessments and assist communities in developing community 

wildland fire protection plans, and educate homeowners and others on 

preventive steps to help reduce their risk from wildland fires.

 10The various documents making up the National Fire Plan include (1) a September 2000

report from the Secretaries of Agriculture and the Interior to the President in response to

the wildland fires of 2000, (2) congressional direction accompanying substantial new 

appropriations in fiscal year 2001, and (3) several strategies to implement all or parts of the 

plan. For a description of these strategy documents, including the National Fire Plan, and 

their contents, goals, and relationships to one another, see GAO, Severe Wildland Fires:

Leadership and Accountability Needed to Reduce Risks to Communities and Resources,

GAO-02-259 (Washington, D.C.: Jan. 31, 2002).

Page 8 GAO-06-570 Wildland Fire Suppression Cost Sharing
Federal and nonfederal entities included in our review used a variety of 

methods to share the costs of fighting fires that burned or threatened both 

federal and nonfederal lands and resources. Although master agreements 

between federal and nonfederal entities provided the framework for cost 

sharing and, typically, listed several cost-sharing methods, the agreements 

often lacked clear guidance for officials to follow in deciding which costsharing method to apply to a specific fire. Consequently, for eight fires we 

reviewed in four states, we found varied cost-sharing methods used and an 

inconsistent application of these methods within and among states, 

although the fires had similar characteristics. The type of cost-sharing 

method chosen is important because it can have significant financial 

consequences for the federal and nonfederal entities involved. 

Master agreements provide the framework for federal and nonfederal 

entities to work together and share the costs of fighting wildland fires. The 

master agreements we reviewed for 12 western states all directed federal 

and nonfederal entities to develop a separate agreement, documenting 

how costs were to be shared for each fire that burned—or, in some cases, 

threatened to burn—across multiple jurisdictions. The master agreements 

also listed one or more methods that could be used for sharing costs (see 

table 1). The master agreement for Idaho was the only one of the 

agreements reviewed that did not cite any specific methods for sharing 

multijurisdictional fire suppression costs. Three other master 

agreements—for Alaska, Arizona, and New Mexico—provided that 

firefighting entities should distribute suppression costs exclusively or 

primarily on the basis of the percentage of acres burned in each entity’s 

jurisdiction, although two of the agreements permitted another method if 

all parties agreed to use it. The master agreements for the remaining 8

states listed a variety of methods that could be used to share suppression 

costs. Although, the specific methods varied from agreement to 

agreement, they included acres burned, cost apportionment, or variations 

of these or other methods. 

Unclear Guidance and 

Inconsistent 

Application of CostSharing Methods Can 

Have Significant 

Financial 

Consequences for 

Entities Involved 

Master Agreements 

Provided Cost-Sharing 

Framework, but Those We

Reviewed Lacked Clear 

Guidance 

Page 9 GAO-06-570 Wildland Fire Suppression Cost Sharing
Table 1: Master Agreements for 12 Western States Varied in the Cost-Sharing

Methods Specified

Cost-sharing method specified in master agreement 

State 

No specific 

method 

Acres burned was the 

primary or only 

method Multiple methods 

Alaska 9

Arizona 9

California 9

Colorado 9

Idaho 9

Montana 9

Nevada 9

New Mexico 9

Oregon 9

Utah 9

Washington 9

Wyoming 9

Source: GAO analysis of data provided by the Forest Service. 

The master agreements we reviewed provided a framework for cost 

sharing, but they did not provide clear guidance for federal and nonfederal

officials to follow in deciding which method to use for a specific fire. Only

one master agreement, the agreement for Alaska, clearly stated that an

acres-burned method should always be used. The agreement noted, 

however, that this method may distribute suppression costs 

disproportionately to the cost of protecting lands and resources in a 

particular jurisdiction. The acres-burned method spreads fire suppression 

costs evenly across the affected landscape, a distribution that may not 

recognize extra fire suppression costs incurred to protect lands and 

resources in one entity’s jurisdiction. Most of the master agreements we 

reviewed for the remaining 11 states listed multiple, alternative costsharing methods but did not provide clear guidance on when each method

should be used. For example, master agreements for several states defined 

three cost-sharing methods, including cost apportionment. These master 

agreements noted that the cost-apportionment method was “the most 

equitable method and should be used when a type 1 team is assigned” to 

manage a wildland fire, but they provided no further guidance about when 

the other methods should be used. Similarly, the master agreement for 

another state, Montana, suggested that an acres-burned method be used 

when entities’ responsibilities, objectives, and suppression costs are 

Page 10 GAO-06-570 Wildland Fire Suppression Cost Sharing
similar, but the agreement did not describe when the other three listed 

methods should be used. Finally, the joint master agreement for Oregon 

and Washington11 listed five possible cost-sharing methods. The agreement 

stated that some of the cost-sharing methods described were typically 

used on “smaller, less complex” fires and others were typically applied to

“larger, more complex” fires. It did not define, however, at what point a 

fire crosses the threshold from smaller and less complex to larger and 

more complex. 

Two other master agreements prescribed a primary cost-sharing method 

but allowed the use of alternative methods without explicitly stating under 

what circumstances an alternative method would be appropriate. The 

master agreements for these states—Arizona and New Mexico—stipulated 

that firefighting entities share suppression costs on an acres-burned basis 

unless federal and nonfederal officials jointly agreed to use an alternative 

method. But the agreements for these states did not clearly delineate the 

circumstances that would warrant use of such an alternative. The master 

agreement for New Mexico, for example, cited “extra suppression effort,” 

and the agreement for Arizona referred to “an unusually high amount” of 

suppression activity as prerequisites for distributing suppression costs on 

a basis other than acres burned. The agreements did not define what 

constitutes “extra suppression effort” or an “unusually high amount” of 

suppression activity. 

In addition to providing limited guidance on cost-sharing methods, the 

master agreements we reviewed also provided unclear guidance on 

whether estimated or actual costs should be shared between federal and

nonfederal entities. Although estimated costs can be more quickly 

determined than actual costs—often by the end of a fire—estimated costs 

can be incomplete or inaccurate. For example, federal and nonfederal 

officials with whom we spoke in California said that in their experience,

estimated costs could differ from actual costs by as much as 30 percent.

Such discrepancies can occur because not all costs are available and

entered into the accounting system at the time of a fire. In addition, some 

costs entered into the accounting system at the time of a fire, such as 

federal personnel costs, are in fact estimated costs. According to federal 

 11Instead of having a separate master agreement for each state, federal and state officials in

Oregon and Washington developed a joint master agreement for fire protection in both

states. 

Page 11 GAO-06-570 Wildland Fire Suppression Cost Sharing
officials, actual cost data may take from several weeks to several months 

to become available. 

For several of the fires we reviewed, total actual fire costs were much 

higher than the costs estimated immediately after the fire. For one fire we 

reviewed in Colorado, for example, total estimated fire costs increased 

from $5.4 million at the end of the fire to $7 million as of February 2006—

an increase of 29 percent. Federal and state officials have been using 

actual costs to finalize federal and nonfederal entities’ shares. In another 

example, for a fire we reviewed in Arizona, total costs increased from an 

estimated $17.3 million at the end of the fire to $19.4 million as of February 

2006—an increase of more than 12 percent. In this case, nonfederal 

entities’ share of costs was agreed to on the basis of estimated costs. As a 

result, federal entities will bear the total increase. 

Cost-Sharing Methods 

Were Inconsistently

Applied for the Eight Fires 

We Reviewed 

Federal and nonfederal entities used varied cost-sharing methods for the 

eight fires we reviewed, although the fires had similar characteristics. As 

shown in figure 1, the cost-sharing methods used sometimes varied within 

a state or from state to state. 

Page 12 GAO-06-570 Wildland Fire Suppression Cost Sharing
Figure 1: The Varied Cost-Sharing Methods Used for Eight Similar Fires We Reviewed

a

A complex consists of two or more individual fires located in the same general area and managed by

a single incident commander. 

The costs for the two fires that we reviewed in Utah were shared using 

two different methods, although both fires had similar characteristics. For 

the Blue Springs Fire, federal and nonfederal officials agreed that aircraft 

and engine costs of protecting an area in the wildland-urban interface 

Page 13 GAO-06-570 Wildland Fire Suppression Cost Sharing
during a 2-day period would be assigned to the state and that the 

remaining costs would be shared on the basis of acres burned. Federal and 

state officials explained that, because the Blue Springs Fire qualified for 

assistance from FEMA, state officials agreed to bear a larger portion of the 

total fire suppression costs.12 In contrast, state officials were reluctant to 

share costs in the same manner on the Sunrise Complex of fires. Although 

these fires also threatened the wildland-urban interface, they did not meet

the eligibility requirements for FEMA reimbursement of nonfederal costs.

Consequently, federal and nonfederal officials agreed to share costs for 

the Sunrise Complex on the basis of acres burned. 

The costs for the two fires we reviewed in Arizona were also treated 

differently from each other. For the Cave Creek Complex, federal and 

state officials agreed to share suppression costs using an acres-burned 

method for the southern portion of the fire, which encompassed federal,

state, and city lands and required substantial efforts to protect the 

wildland-urban interface. The federal government paid the full costs for 

the northern portion of the fire, which burned almost exclusively on

federal land although some efforts had also been taken on federal lands to

protect an area of wildland-urban interface northeast of the fire. Forest 

Service regional officials who conducted a postfire review expressed 

concern about the method chosen for the Cave Creek Complex because 

they believed that it did not equitably share the fire suppression costs 

among the affected entities, especially the costs of protecting the wildlandurban interface. The Arizona state forester explained, in contrast, that he 

and local forest officials agreed to use an acres-burned method because 

they did not believe that an unusually high amount of suppression effort 

had gone toward protecting nonfederal lands and resources. 

Unlike the Cave Creek Complex, federal and nonfederal officials were 

unable to reach any agreement on how to share costs for the Florida Fire 

in Arizona. Officials from the affected national forest had proposed a cost-

 12Under its Fire Management Assistance Grant Program, FEMA provides financial 

assistance to nonfederal entities for the mitigation, management, and control of any fire on 

public or private forest land or grassland that would constitute a major disaster. Under this

program, nonfederal entities can be reimbursed for 75 percent of the allowable fire 

suppression costs. FEMA evaluates the threat posed by a fire or fire complex according to

the following criteria: (1) threat to lives and improved property, including threats to critical 

facilities/infrastructure, and critical watershed areas; (2) availability of state and local 

firefighting resources; (3) high fire danger conditions, as indicated by nationally accepted

indexes such as the national fire danger ratings system; and (4) potential major economic 

impact. 

Page 14 GAO-06-570 Wildland Fire Suppression Cost Sharing
sharing agreement, whereby the state would pay the costs of firefighting 

personnel, equipment, and aircraft used to protect the wildland-urban 

interface, and all other fire suppression costs would be paid by the federal 

government. The state forester, however, did not agree with this proposal. 

He explained that he believed that the Forest Service, not the state, was 

responsible for protecting areas of the wildland-urban interface threatened 

by the Florida Fire and that he was not authorized to agree to the terms of 

the proposed agreement.

13 Federal and state officials were not able to 

reach agreement, and, according to federal officials, no further discussions 

were planned. 

Methods used to share suppression costs for fires with similar 

characteristics also varied among states. For example, costs for the fires 

we reviewed in California and Colorado were shared using methods 

different from those used for similar fires we reviewed in Arizona and 

Utah. In California, federal and nonfederal officials agreed to share the 

costs of two fires using the cost-apportionment method—that is, costs 

were apportioned on the basis of where firefighting personnel and 

equipment were deployed. Officials said that they had often used this 

method since the mid-1980s because they believed that the benefit it 

provides in more equitable cost sharing among affected firefighting 

entities outweighs the additional time required to apportion the costs. In

contrast, federal and state officials in Colorado shared suppression costs 

for both of the fires we reviewed in that state using guidance they had

developed and officially adopted in 2005, called “fire cost share 

principles.”14 Under these principles, aviation costs for fires burning in the 

wildland-urban interface are shared equally for 72 hours,15 and other fire 

suppression costs, such as firefighting personnel and equipment, are 

shared on the basis of acres burned. State officials said that they 

developed the principles because they did not want firefighting officials to

be reluctant to order needed resources due to concerns about which entity

would pay for them. They added that using the principles is less labor-

 13Specifically, the state forester said that under Arizona law, the state had no responsibility 

to protect the private lands and resources in the wildland-urban interface threatened by the 

Florida Fire because the fire did not threaten state lands, and the private properties that 

the fire threatened were not covered by cooperative fire agreements with the state. 

14These principles were adopted in 2005, but the basic framework contained in the

principles was also used for the McGruder Fire in 2004. For the McGruder Fire, however,

equal sharing of aviation costs was not limited to 72 hours. 

15The 72-hour count generally begins after a fire escapes initial suppression efforts, or 

initial attack. 

Page 15 GAO-06-570 Wildland Fire Suppression Cost Sharing
intensive than cost apportionment and better distributes the cost of 

expensive aviation assets than an acres-burned method alone. In addition, 

for the Mason Gulch Fire, Colorado officials agreed to pay for some fire 

engines that were used to protect homes in the wildland-urban interface 

during one operational period. 

The Cost-Sharing Method 

Used Can Lead to 

Significantly Different 

Financial Outcomes 

Having clear guidance as to when particular cost-sharing methods should 

be used is important because the type of method ultimately agreed upon

for any particular fire can have significant financial consequences for the 

firefighting entities involved. To illustrate the effect of the method chosen, 

we compared the distribution of federal and nonfederal costs for the five 

fires we reviewed in which the actual cost-sharing method used was not 

acres burned with what the distribution would have been if the method 

used had been acres burned (see fig. 2). 

Page 16 GAO-06-570 Wildland Fire Suppression Cost Sharing
Figure 2: Distribution of Costs under the Actual Cost-Sharing Method Used Compared with an Acres-Burned Method 

Dollars in millions

0

2

4

6

8

10

12

14

Actual

method

Actual

method

Acres

burned

Acres

burned

Actual

method

Actual

method

Actual

method

Acres

burned

Acres

burned

Acres

burned

Coloradob Californiaa Utahb

Nonfederal costs

Federal costs

Source: GAO analysis of data from the Forest Service; Department of the Interior; and Utah Division of Forestry, Fire and State Lands.

Deep Fire Pine Fire Mason Gulch

Fire

McGruder Fire Blue Springs

Fire

Note: For each illustrated fire, we estimated costs under an acres-burned method by multiplying the 

total costs for each fire by the percentage of affected acres under nonfederal and federal protection, 

respectively. Dollars were not adjusted for inflation. 

a

Data for these California fires, which occurred in 2004, reflect total actual suppression costs. 

b

Data for these Colorado and Utah fires—which, according to the fire officials involved, were the best 

available as of March 2006—reflect a combination of actual suppression costs and estimated costs, 

when actual costs were not available. Because final actual shares of the costs had not been 

determined for the Mason Gulch Fire at the time of our review, we worked with federal officials to 

estimate the federal and nonfederal shares on the basis of the fire’s actual cost-sharing agreement. 

The federal and nonfederal shares of total costs calculated at final settlement by firefighting entities 

involved in the Mason Gulch Fire may differ from these estimates.

We found that the distribution of costs between federal and nonfederal 

entities differed, sometimes substantially, depending on the cost-sharing 

method used. Of the five fires included in our review, the largest 

differences occurred for the two fires in California. Officials shared the 

costs for each of these fires using a cost-apportionment method. For the 

Deep Fire, federal entities paid $6.2 million, and nonfederal entities paid 

$2.2 million. Had the costs been shared on the basis of acres burned, 

federal entities would have paid an additional $1.7 million, and nonfederal

Page 17 GAO-06-570 Wildland Fire Suppression Cost Sharing
entities would have paid that much less because most of the acres burned 

were on federal lands. According to federal and state officials, the 

nonfederal entities bore a larger share of the cost than they would have 

under an acres-burned method because (1) substantial aircraft, fire 

engines, and personnel were used to protect nonfederal lands and 

resources, primarily in the wildland-urban interface, and (2) the costs for 

protecting these nonfederal lands and resources were assigned to the 

nonfederal entities. In contrast, for the other California fire we reviewed, 

the Pine Fire, federal firefighting entities would have paid about $2 million 

less, and nonfederal entities would have paid that much more under an 

acres-burned method. Under the cost-apportionment method, federal 

entities paid $5.2 million, and nonfederal entities paid $8.1 million. 

According to a federal official who worked on apportioning costs for that 

fire, the higher costs that the federal entities paid under cost 

apportionment were largely due to extensive firefighting efforts on federal 

land to ensure that the fire was extinguished. 

In Colorado and Utah, which for three fires used cost-sharing methods 

other than cost apportionment and acres burned, the differences in federal 

and state entities’ shares between the methods used and the acres-burned 

method were less pronounced. This is likely because the cost-sharing 

methods used still relied heavily on acres burned. In each case, federal

entities’ shares would have been more and nonfederal shares less had an 

acres-burned method been used, due to the efforts to protect the wildlandurban interface. For example, the federal share of costs for the Blue 

Springs Fire in Utah would have been about $400,000 more and the 

nonfederal share that much less if an acres-burned method had been used 

for the whole fire. In Colorado, we estimated that the federal share of 

costs for the Mason Gulch Fire would have been about $200,000 more and 

the nonfederal share that much less under an acres-burned method. For 

the McGruder Fire, where the number of federal and nonfederal acres 

burned were nearly identical and the total fire cost of about $800,000 was 

much less than the cost of other fires we reviewed, the change in the

distribution of costs between the method used and acres burned—about 

$30,000—was much less than for the other fires. 

For two other fires we reviewed in which federal and nonfederal entities 

had agreed to use the acres-burned method, nonfederal entities might have 

borne a greater proportion of the costs had a different cost-sharing 

method been used. For these two fires, in Arizona and Utah, federal and

state officials we interviewed had identified many aviation and ground 

firefighting assets that went toward protecting nonfederal lands and 

resources. Although we were unable to fully estimate a distribution of 

Page 18 GAO-06-570 Wildland Fire Suppression Cost Sharing
costs using an alternative method due to limitations in the data available, 

our analysis suggested, and many of the officials we interviewed 

acknowledged, that the nonfederal entities would have borne a larger 

share of the costs. 

Federal and nonfederal agency officials we interviewed raised a number of 

concerns about the current cost-sharing framework. First, some federal 

officials said that because master agreements and other policies do not 

provide clear guidance about which cost-sharing methods to use, it has 

sometimes been difficult to obtain a cost-sharing agreement that they 

believe shares suppression costs equitably. Second, nonfederal officials 

were concerned that the emergence of alternative cost-sharing methods 

has caused nonfederal entities to bear a greater share of fire suppression 

costs than in the past. Finally, some federal officials expressed concern 

that the current framework for sharing costs insulates state and local 

governments from the cost of protecting the wildland-urban interface, 

thereby reducing their incentive to take steps that could help mitigate fire 

risks and reduce suppression costs in the wildland-urban interface. On the 

basis of our review of previous federal reports and interviews with federal

and nonfederal officials, we believe these concerns may reflect a more 

fundamental issue—that federal and nonfederal entities have not clearly 

defined their financial responsibilities for wildland fire suppression, 

particularly for the wildland-urban interface. 

Some federal officials said that the lack of clear guidance can make it 

difficult to agree to use a cost-sharing method that they believe equitably 

distributes suppression costs between federal and nonfederal entities, 

particularly for fires that threaten the wildland-urban interface. For 

example, different cost-sharing methods were used for the two fires we 

reviewed in Utah, even though both fires required substantial suppression 

efforts to protect the wildland-urban interface. For the Blue Springs Fire, 

nonfederal officials agreed to pay a higher proportion of the suppression 

costs than they would have paid had an acres-burned method been used,

because they recognized the substantial effort undertaken to protect the 

wildland-urban interface and because most of the state’s costs for that fire 

were eligible for FEMA reimbursement. For the Sunrise Complex, the 

federal official who negotiated the cost-sharing agreement said that using 

a method other than acres burned might have better recognized and 

distributed the costs of the suppression effort necessary to protect the 

wildland-urban interface. Nonfederal officials, however, said they were not 

willing to pay a higher proportion of costs for the Sunrise Complex 

Current Cost-Sharing 

Framework Raises 

Several Concerns 

Lack of Clear Guidance 

Can Lead to Difficulties in 

Sharing Costs 

Page 19 GAO-06-570 Wildland Fire Suppression Cost Sharing
because for that fire, the state was ineligible for financial assistance from 

FEMA. The federal official said that because of the state officials’ 

unwillingness to use a method other than acres burned, and because of the 

lack of clear guidance about which cost-sharing method should be used, 

he agreed to use an acres-burned method and did not seek a cost-sharing 

agreement that would have assigned more of the Sunrise Complex’s costs 

to the nonfederal entities. Some federal officials in Arizona expressed 

similar views, saying that the lack of clear guidance on sharing costs can 

make it difficult to reach agreement with nonfederal officials. For 

example, federal and state officials in Arizona did not agree on whether to 

share costs for the Florida Fire in that state. 

Officials from NASF and the Utah Division of Forestry, Fire and State 

Lands raised a related issue—that existing guidance does not specify how 

costs should be shared when one entity’s management goals alter fire 

suppression strategies and increase costs. For example, these officials said

that federal agencies may restrict the use of mechanized equipment in 

wilderness areas or in sensitive wildlife habitat and increase the use of 

aircraft instead. The officials did not believe that nonfederal entities 

should have to pay for the resulting higher costs. Utah officials said that 

although they have been able to reach cost-sharing agreements they 

believe are appropriate in such cases, guidance should be improved to 

recognize these situations. 

Officials from the Forest Service’s and the Department of the Interior’s 

national offices agreed that interagency policies for cost sharing could be

clarified to indicate under what circumstances particular cost-sharing 

methods are most appropriate. They said that the acres-burned method, 

for example, is likely not the most equitable method to share costs in cases

where fires threaten the wildland-urban interface. But they also said that it

would be difficult to develop universal guidance requiring a particular 

cost-sharing method for fires with certain characteristics. They explained

that the organization, responsibilities, and funding of state and local 

firefighting entities vary from state to state, and flexibility is therefore 

needed. The National Fire and Aviation Executive Board was developing a 

template for both master and cost-sharing agreements.16 As of May 2006, 

 16The National Fire and Aviation Executive Board is made up of the fire directors from the

five federal land management agencies and a representative from NASF. The board reports

to the Wildland Fire Leadership Council, which is a group established to support the 

implementation and coordination of the National Fire Plan and the federal wildland fire 

management policy. 

Page 20 GAO-06-570 Wildland Fire Suppression Cost Sharing
this template had not been finalized, but our review of a draft version 

indicated that the template might not provide additional clarity about 

when each cost-sharing method should be used.17

Nonfederal Officials Were 

Concerned about 

Increased Costs and Equity 

among States 

While federal officials expressed the need for further guidance on how to 

share costs, nonfederal officials were concerned that the emergence of 

alternative cost-sharing methods was leading state and local entities to 

bear a greater share of suppression costs than in the past, and they 

questioned whether such an increase was appropriate. Nonfederal officials 

also said that wildland fire suppression costs already posed budgetary 

challenges for state and local entities and that using alternative costsharing methods more often could exacerbate the situation. State officials 

said that if a state’s suppression costs in a given year exceed the funds 

budgeted, they must seek additional state funds, which can be difficult. 

Moreover, they said, in many states, protecting structures is primarily a 

local responsibility, and many local entities are unable to pay the costs of 

fighting a large fire that threatens the wildland-urban interface.18 Although 

clarifying guidance about which cost-sharing methods are most 

appropriate for particular circumstances could cause nonfederal entities 

to bear more wildland fire suppression costs, over the long term, such 

clarification would also allow each entity to better determine its budgetary 

needs and take steps to meet them. 

In addition to their concerns about increased costs, nonfederal as well as 

federal officials were concerned that the federal government was treating 

nonfederal entities in different states differently, thereby creating 

inequities. Federal and nonfederal officials said that because some states 

use particular cost-sharing methods more often than other states, the 

proportion of costs borne by federal and nonfederal entities likely varies 

from state to state, resulting in nonfederal entities’ paying a higher 

proportion of costs in some states and a lower proportion in other states. 

For example, nonfederal officials in Utah said that even though they 

agreed to pay certain aircraft and fire engine costs to protect the wildland-

 17The draft template was very similar to the joint master agreement for Oregon and 

Washington. The template described several cost-sharing methods that can be used, but it 

did not specify that certain methods be used for certain types of fires.

18Some states have provisions whereby wildland fires exceeding the logistic and financial 

capabilities of local entities can be managed and paid for by the state, but officials said that

state funds to do so are also limited. 

Page 21 GAO-06-570 Wildland Fire Suppression Cost Sharing
urban interface on the Blue Springs Fire, they were uncertain if this 

method was equitable, particularly if nonfederal entities were not paying 

for similar costs in other states. Clarifying which cost-sharing methods 

should be used in particular situations could increase nonfederal officials’

assurance that the federal government is treating them equitably relative

to other states. 

Cost-Sharing Framework 

May Reduce Incentives to 

Mitigate Fire Risks in the 

Wildland-Urban Interface 

In addition to the concerns raised about obtaining equitable cost-sharing 

agreements and about the increased costs to nonfederal entities, federal 

officials said that the current cost-sharing framework insulates state and 

local governments from the cost of protecting the wildland-urban 

interface. A variety of protective measures are available to help protect 

structures from wildland fire, although they are not consistently used in 

areas at risk. Some federal and nonfederal officials noted that the current 

framework for sharing costs—combined with the availability of funds 

from FEMA for some emergency fire suppression costs—may reduce the 

incentive for state and local governments to require that such measures be 

taken. 

Firefighting officials and researchers have identified a variety of measures 

that can mitigate the risk to structures from wildland fire. As we have 

previously reported, key among these measures are (1) reducing 

vegetation and flammable objects within an area of 30 to 100 feet around a 

Measures Are Available to 

Mitigate Fire Risks in the 

Wildland-Urban Interface, but 

They Are Not Consistently 

Used 

structure, often called creating a defensible space, and (2) using fireresistant roofing materials and covering attic vents with mesh screens.19 In 

addition, fire-resistant windows and building materials can help prevent 

structures from igniting. Other measures, such as designing communities 

to ensure an adequate water supply for fighting fires and access for 

emergency vehicles, can assist fire suppression efforts and further reduce 

the risk to structures. Taken together, these measures can help reduce the

likelihood that a wildland fire will damage a structure. 

Increasing the use of protective measures to mitigate the risk to structures 

from wildland fire is a key goal of the National Fire Plan. This plan—

developed by federal wildland fire agencies and state governors—

encourages, but does not mandate, state or local governments to adopt 

 19GAO, Technology Assessment: Protecting Structures and Improving Communications 

during Wildland Fires, GAO-05-380 (Washington, D.C.: Apr. 26, 2005). 

Page 22 GAO-06-570 Wildland Fire Suppression Cost Sharing
laws requiring homeowners and homebuilders to take measures to help 

protect structures from wildland fires. Because these measures rely on the 

actions of individual homeowners or on laws and land-use planning 

affecting private lands, achieving this goal is primarily a state and local

government responsibility. The National Association of Counties supports 

this goal. 

Federal and nonfederal officials told us that the use of measures to help 

protect structures from wildland fires has become more common, but that 

such measures are not consistently used in areas at risk. The increased use 

of these measures in recent years is due in part to continuing federal and

nonfederal efforts to educate homeowners in the wildland-urban interface 

and to state and local governments’ adopting laws requiring that such 

measures be used. Education efforts, such as the Firewise Communities 

program,20 seek to increase the voluntary use of such measures by working 

with community leaders and individual homeowners. As wildland fires 

have become more severe and the number of damaged homes has grown, 

more state and local governments have adopted laws requiring 

homeowners or homebuilders to use measures to reduce the risk to 

structures from wildland fires. Nevertheless, federal and nonfederal fire 

officials told us that protective measures are not used consistently in many

areas at risk from wildland fire. Some homeowners and homebuilders, for 

example, resist using fire-resistant landscaping and roofing because they 

are concerned about aesthetics, time, or cost. As a result, federal and 

nonfederal officials said, it can be politically difficult for state and local

governments to adopt—and enforce—laws requiring such measures, and

many at-risk areas have not done so. In 2004, the Western Governors’ 

Association reported that greater use of protective measures was urgent, 

but the progress made was unknown.21

 20The Firewise Communities program is the primary national effort to educate homeowners

about wildland fire risks. The program is jointly sponsored by the International Association 

of Fire Chiefs, National Emergency Management Association, National Association of State 

Fire Marshals, NASF, National Fire Protection Association, FEMA, U.S. Fire 

Administration, Forest Service, Bureau of Indian Affairs, Bureau of Land Management, Fish 

and Wildlife Service, and National Park Service. Numerous state and local fire and forestry 

officials also participate in this program. See http://www.firewise.org/ for more 

information. 

21Western Governors’ Association, “Letter to the Secretary of Agriculture and Secretary of 

the Interior,” December 16, 2004, 

http://www.westgov.org/wga/initiatives/fire/tempe-report04.pdf (downloaded May 8, 2006). 

Page 23 GAO-06-570 Wildland Fire Suppression Cost Sharing
The states and communities we visited exhibited various degrees of 

progress in adopting laws requiring protective measures. Since 1965, for 

example, California has required homeowners in the wildland-urban 

interface to maintain 30 feet of defensible space around their homes, a 

requirement that was increased to 100 feet in 2005. This law applies to 

existing homes as well as to new construction and specifically allows local 

jurisdictions to adopt stricter standards. In areas at particularly high risk 

from wildland fires, California regulations also require new structures to 

be constructed with fire-resistant roofing materials and vents. The other 

states we visited do not have such statewide requirements, but they are

taking a variety of steps to require or encourage protective measures. 

Utah, for example, passed a law in 2004 requiring its counties to adopt 

standards for landscaping and building materials if they want to be eligible

to receive state funds to assist with fire suppression costs. According to 

state officials, exactly what will be required under these standards was 

still being determined, but once final, the standards will apply only to new 

construction, not existing structures. Similarly, Arizona did not have any 

statewide requirements, although it adopted a law in 2004 explicitly 

granting local governments the authority to establish codes to mitigate 

wildland fire risk in the wildland-urban interface. Finally, in Colorado, 

laws requiring protective measures have been adopted primarily at the 

local, not state, level. Although some counties, such as Larimer County, 

required owners of new structures in the wildland-urban interface to use 

measures to help mitigate fire risk, others—including the three counties 

affected by the wildfires we reviewed—were educating homeowners 

about measures they can use to reduce their risk, without requiring that

such measures be used. 

Although measures are available to help protect structures in the wildlandurban interface from wildland fires, federal officials expressed concern—

and some nonfederal officials acknowledged—that the use of cost-sharing 

methods that assign more costs to federal entities, and the availability of

federal emergency assistance, insulate state and local governments from 

the cost of providing wildland fire protection. These federal officials 

pointed out that wildland fires threatening structures often require added 

suppression effort, such as an increased number of aircraft and fire 

engines or firefighters to remove vegetation around individual structures. 

Under some cost-sharing methods, such as acres burned, federal entities 

often end up paying a large proportion of the costs for these efforts. Some 

federal and nonfederal officials also noted that the availability of FEMA 

assistance to nonfederal entities—which can amount to 75 percent of 

allowable fire suppression costs for eligible fires—further insulates state 

and local governments from the cost of protecting the wildland-urban 

Cost-Sharing Framework and 

Federal Assistance May Reduce 

the Incentive to Require the 

Use of Protective Measures 

Page 24 GAO-06-570 Wildland Fire Suppression Cost Sharing
interface. Of the eight fires included in our review, nonfederal officials 

were seeking reimbursement for the allowable costs of the five fires that 

FEMA determined met eligibility requirements. 

Federal officials suggested that to the extent that state and local 

governments are insulated from the cost of protecting the wildland-urban 

interface, these governments may have a reduced incentive to adopt laws 

requiring homeowners and homebuilders to use protective measures that 

could help mitigate fire risks. Homeowner and homebuilder resistance 

make it politically difficult to adopt and enforce such laws. Both federal 

and nonfederal officials noted, however, that greater use of fire-resistant 

building materials and landscaping could help reduce the cost of 

protecting the wildland-urban interface. Some officials also said that by 

requiring homeowners and homebuilders to take such measures, more of 

the cost of protecting the wildland-urban interface would then be borne by 

those who chose to live there. The Colorado State Forest Service, for 

example, has reported that the expansion of the wildland-urban interface 

has increased wildland fire suppression costs, but that these costs have 

not been equitably divided because all taxpayers—not just those who live 

in areas threatened by wildland fire—fund the cost of suppression.22

Officials’ Concerns May 

Reflect Ambiguity over 

Financial Responsibilities 

On the basis of our review of previous federal reports and interviews with 

federal and nonfederal officials, we believe that the concerns we identified 

may reflect a more fundamental issue—that federal and nonfederal 

firefighting entities have not clearly defined their financial responsibilities 

for wildland fire suppression, particularly those for protecting the 

wildland-urban interface. Federal officials said that the continuing 

expansion of the wildland-urban interface and rising fire suppression costs 

for protecting these areas have increased the importance of resolving 

these issues. First, federal wildland fire management policy states that 

protecting structures is the responsibility of state, tribal, and local entities; 

but the policy also says that, under a formal fire protection agreement 

specifying the financial responsibilities of each entity, federal agencies can 

assist nonfederal entities in protecting the exterior of structures 

 22Colorado State Forest Service, State of Colorado Wildfire Hazard Mitigation Plan, 

Colorado Multi-Hazards Mitigation Plan (Denver, Colo.: July 2002). 

Page 25 GAO-06-570 Wildland Fire Suppression Cost Sharing
threatened by wildland fire.23 Forest Service guidance defines actions to 

protect the exterior of structures to include removing fuels in the vicinity

of structures and spraying water or retardant on structures or surrounding

vegetation. Federal and nonfederal officials agreed that federal agencies 

can assist with such actions, but they did not agree on which entities are 

responsible for bearing the costs of these actions. Federal officials told us

that the purpose of this policy is to allow federal agencies to use their 

personnel and equipment to help protect homes but not to bear the 

financial responsibility of providing that protection. Nonfederal officials, 

however, said that these actions are intended to keep a wildland fire from 

reaching structures, and financial responsibility should therefore be 

shared between both federal and nonfederal entities. 

Second, the presence of structures adjacent to federal lands can 

substantially alter fire suppression strategies and raise costs. A previous 

federal report and federal officials have questioned which entities are 

financially responsible for suppression actions taken on federal lands but 

intended primarily or exclusively to protect adjacent wildland-urban 

interface. Fire managers typically use existing roads and geographic 

features, such as rivers and ridgelines, as firebreaks to help contain 

wildland fires. If, however, homes and other structures are located 

between a fire and such natural firebreaks, firefighters may have to 

construct other firebreaks and rely more than they otherwise would on 

aircraft to drop fire retardant to protect the structures, thereby increasing

suppression costs. For example, for the Sunrise Complex fires in Utah, 

federal and nonfederal officials agreed that if structures had not been 

present, they could have used easily accessible roads to contain the fire 

and would not have used as many aircraft. Nonfederal officials in several 

states, however, questioned the appropriateness of assigning to nonfederal 

entities the costs for suppression actions taken on federal lands. These 

officials, as well as NASF officials, also said that accumulated fuels on 

federal lands is resulting in more severe wildland fires and contributing to 

 23Department of the Interior, Department of Agriculture, Department of Energy, 

Department of Defense, Department of Commerce, Environmental Protection Agency, 

Federal Emergency Management Agency, and the National Association of State Foresters,

Review and Update of the 1995 Federal Wildland Fire Management Policy (Washington,

D.C.: January 2001). 

Page 26 GAO-06-570 Wildland Fire Suppression Cost Sharing
the increased cost of fire suppression.

24 They also said that federal 

agencies are responsible for keeping wildland fires from burning off 

federal land and should, therefore, bear the costs of doing so. Federal 

officials in the states we visited recognized this responsibility, but some 

also said that with the growing awareness that wildland fires are inevitable 

in many parts of the country, policy should recognize that wildland fires 

will occur and are likely to burn across jurisdictional boundaries. In their 

view, those who own property in areas at risk of wildland fires share a 

portion of the financial responsibility for protecting it. Previous federal 

agency reports have also recognized this issue and have called for 

clarifying financial responsibility for such actions.

25

Wildland fires are an enduring part of the landscape, and they will 

continue to affect both federal and nonfederal lands and resources. 

Federal, state, and local firefighting entities have taken great strides to 

develop a cooperative fire protection system so that these entities can 

effectively work together to respond to these fires. Nevertheless, where 

federal and nonfederal lands and resources are adjacent or intermingled, 

particularly in the wildland-urban interface, different views prevail about

which entity is responsible for the costs of protecting these lands and 

resources. Without explicit delineation of each entity’s firefighting 

financial responsibilities, federal and nonfederal entities’ concerns about 

how these costs are shared are likely to continue. In addition, lack of 

clarity about respective financial responsibilities can also make it more 

difficult for both federal and nonfederal entities to accurately forecast and 

plan for future budget needs. As the wildland-urban interface continues to

become a more prominent feature of the fire suppression landscape, 

contributing to rising suppression costs, the need for clarity is becoming 

more acute. Improved guidance that clearly delineates federal and 

Conclusions 

 24GAO has previously reported on fuel conditions on federal lands. See GAO, Wildland Fire 

Management: Update on Federal Agency Efforts to Develop a Cohesive Strategy to 

Address Wildland Fire Threats, GAO-06-671R (Washington, D.C.: May 1, 2006); Wildland 

Fire Management: Important Progress Has Been Made, but Challenges Remain to 

Completing a Cohesive Strategy, GAO-05-147 (Washington, D.C.: Jan. 14, 2005); and

Western National Forests: A Cohesive Strategy Is Needed to Address Catastrophic 

Wildfire Threats, GAO/RCED-99-65 (Washington, D.C.: Apr. 2, 1999). 

25Department of Agriculture, Secretary of Agriculture Independent Cost-Control Review 

Panel: FY 2004 Large Cost Wildfires Report (Washington, D.C.: Mar. 23, 2005); and

Department of Agriculture and Department of the Interior, Consolidation of the 2003 

National and Regional Large Incident Strategic Assessment and Oversight Review Key

Findings (Washington, D.C.: Sept. 22, 2003). 

Page 27 GAO-06-570 Wildland Fire Suppression Cost Sharing
nonfederal entities’ financial responsibilities for suppressing wildland fires 

could assist all entities in better planning for, and during, a fire season. 

To strengthen the framework for sharing wildland fire suppression costs, 

we recommend that the Secretaries of Agriculture and the Interior, 

working in conjunction with relevant state entities, take the following two 

actions: 

• provide more specific guidance as to when particular cost-sharing 

methods should be used and 

• clarify the financial responsibilities for suppressing fires that burn, or 

threaten to burn, across multiple jurisdictions. 

We received written comments on a draft of this report from the Forest 

Service and Interior. Both agencies generally concurred with our findings 

and recommendations. The Forest Service stated that it will clarify the 

guidance to the field regarding the most appropriate cost-share method to 

use in a given situation, which will serve as a place to begin negotiations

with its partners. We recommended, however, that the Secretaries of 

Agriculture and the Interior work in conjunction with relevant state 

entities to develop more specific guidance. If the Forest Service 

independently clarifies guidance without engaging state entities that also

will be affected by any changes, there is no assurance that these state 

entities will agree to the changes in cost-sharing methods. Interior stated, 

however, that it would work closely with the Forest Service and state

agencies to clarify such guidance to the field. 

The Forest Service also stated that its financial responsibilities are clearly 

defined in policy. Several federal officials with whom we spoke during our 

study disagreed, however, stating that these policies do not clearly 

delineate federal entities’ financial responsibility for fire protection, 

especially in regards to the wildland-urban interface. Although Forest 

Service policy states that structural fire suppression is the responsibility of 

tribal, state, or local governments and the Forest Service’s primary 

responsibility and objective for structure protection is to suppress 

wildland fire before it reaches structures, it does not clearly define what 

this would constitute. Officials told us that such actions could include 

efforts on Forest Service lands to keep fire from crossing jurisdictional 

boundaries or suppression actions in closer proximity to a structure, such 

as removing vegetation or other flammable objects. Without a clear 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

Page 28 GAO-06-570 Wildland Fire Suppression Cost Sharing
definition of each entity’s protection and related financial responsibilities, 

it will be difficult to determine how to appropriately share the costs of the 

efforts. The Forest Service also provided additional comments that we 

have incorporated in this report where appropriate. The Forest Service’s 

and Interior’s letters are reprinted in appendixes III and IV, respectively, 

along with our evaluation of specific Forest Service comments in appendix 

III. 

In addition to these federal agencies, we also sought comments from 

NASF because of our report’s potential financial implications for states 

and other nonfederal entities. NASF provided both oral comments and a 

written response to our report. NASF did not agree with our 

recommendations, stating that developing national guidance specifying 

appropriate cost-sharing methods and clarifying financial responsibility for 

fire suppression costs would not provide the flexibility needed by local 

federal and nonfederal officials to address the variability in local 

circumstances and state laws. We agree that a certain amount of flexibility 

is needed. However, without more specific guidance to assist federal and

nonfederal officials when developing cost-sharing agreements for 

particular fires, inconsistencies in the methods used—as well as perceived

inequities in how costs are shared between federal and nonfederal entities,

as expressed by many officials with whom we spoke—are likely to 

continue. A copy of NASF’s letter and our evaluation of its specific 

comments are included in appendix V. 

As agreed with your office, unless you publicly announce the contents of

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

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

congressional committees, the Secretaries of Agriculture and the Interior, 

the Chief of the Forest Service, the Director of the Bureau of Land 

Management, and other interested parties. We will also 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. 

Page 29 GAO-06-570 Wildland Fire Suppression Cost Sharing
If you or your staff have questions about this report, please contact me at

(202) 512-3841 or nazzaror@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are listed in appendix VI. 

Sincerely yours, 

Robin M. Nazzaro 

Director, Natural Resources 

 and Environment 

Page 30 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To determine the general framework for how federal and nonfederal 

entities share suppression costs when fires burn or threaten both their 

lands and resources, we reviewed federal laws and interagency policies 

governing cost sharing for cooperative fire protection efforts. To identify 

similarities and differences in the cost-sharing framework and available 

methods from state to state, we obtained and reviewed master agreements

between federal and nonfederal entities for 12 western states.1

 Although 

wildland fires can affect all states, we focused our review on these 

western states, which have substantial federal lands and often experience 

wildland fires. 

To identify how cost-sharing methods are applied in different states, we 

selected a nonprobability sample of four states—Arizona, California, 

Colorado, and Utah—that used a variety of different methods to share 

wildland fire suppression costs between federal and nonfederal entities. In

each of the four states, we selected a nonprobability sample of two fires 

that occurred in 2004 or 2005 and were managed by either the Forest 

Service or the Bureau of Land Management.2

 The eight fires all burned or 

threatened to burn both federal and nonfederal lands, burned or 

threatened both natural resources and wildland-urban interface areas, and 

were of sufficient size and complexity to require type 1 or type 2 incident 

management teams for a portion of the fire. For each of the eight fires, we 

reviewed available records on firefighting personnel, aircraft, and 

equipment used for fire suppression efforts; reviewed fire cost data; 

reviewed the cost-sharing agreement that federal and nonfederal officials 

negotiated, if any; interviewed federal and nonfederal officials to identify 

the process used to select the cost-sharing method; and obtained agency 

estimates of total suppression costs that were based on data collected by

federal agencies for each fire. Using this information and working with 

federal and nonfederal officials, we estimated the federal and nonfederal 

shares of the suppression costs. To determine the effect of the costsharing method selected on the relative proportion of costs borne by 

federal and nonfederal entities—for the five fires that used a cost-sharing 

method other than acres burned—we compared the estimated federal and 

nonfederal shares of costs resulting from the cost-sharing agreement to 

our estimate of what the federal and nonfederal shares of costs would 

 1

These states were Alaska, Arizona, California, Colorado, Idaho, Montana, Nevada, New 

Mexico, Oregon, Utah, Washington, and Wyoming. 

2

Of the federal firefighting agencies, the Forest Service and the Bureau of Land 

Management spend the most funds each year on wildland fire suppression. 

Page 31 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix I: Scope and Methodology 

have been if an acres-burned method had been used. We used estimates of 

suppression costs for some of the fires because the entities had not yet 

determined the actual total cost for all eight fires we reviewed. To 

determine the reliability of the data used, we reviewed previous audits of 

the federal financial systems used for the accounting of fire costs; 

interviewed federal officials knowledgeable about these systems to 

identify how data are entered into the system and what steps are taken to 

help ensure accuracy; and, working with federal and nonfederal officials, 

reviewed data on the specific firefighting assets used and the related costs 

for the eight fires. Because we were primarily interested in the relative

proportions of fire costs borne by federal and nonfederal entities using 

different cost-sharing methods, we determined that these data were 

sufficiently reliable for the purposes of this study. The 12 master 

agreements reviewed, the four states visited, and the two fires we 

reviewed within each state are all nonprobability samples. The results of 

these samples, therefore, cannot be used to make inferences about all 

master agreements, states, or wildland fires. 

To identify concerns that federal and nonfederal entities may have about 

the existing cost-sharing framework, we reviewed previous reports on 

wildland fire suppression, including large fire cost reviews conducted by 

the Departments of Agriculture or the Interior, a series of reports by the 

National Academy of Public Administration, and reports by state entities. 

We interviewed federal officials from the Department of the Interior’s and 

Forest Service’s national offices and the National Interagency Fire Center 

in Boise, Idaho; Forest Service officials from the four regional offices and

other Forest Service officials involved with the fires we reviewed; and 

Bureau of Land Management officials from the two state offices and 

several district offices involved with the fires we reviewed. We also 

interviewed additional federal officials in other regions and states to 

obtain a broader perspective on any concerns with the cost-sharing 

framework. Nonfederal officials that we interviewed included state—and,

in some cases, local—officials from the four states we visited, as well as 

officials from Montana, Oregon, and Washington. We also reviewed 

reports by or interviewed officials from the National Association of State 

Foresters (NASF), the Western Governors’ Association, and the National 

Association of Counties. To better understand the concern officials raised 

about the cost-sharing framework and incentives to increase the use of 

protective measures, we reviewed federal policies and reports on 

protecting the wildland-urban interface, including the National Fire Plan 

and the federal wildland fire management policy; federal laws and 

regulations governing Federal Emergency Management Agency (FEMA) 

Page 32 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix I: Scope and Methodology 

assistance; and reports by GAO,3 the American Planning Association,4 and 

state audit entities. 

We performed our work in accordance with generally accepted 

government auditing standards from May 2005 through May 2006. 

 3

GAO, Technology Assessment: Protecting Structures and Improving Communications 

during Wildland Fires, GAO-05-380 (Washington, D.C.: Apr. 26, 2005). 

4

James Schwab et al., Planning for Wildfires (Washington, D.C.: American Planning 

Association, 2005). 

Page 33 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix II: Characteristics of the Eight Appendix II: Characteristics of the Eight Fires That GAO Reviewed 

Fires That GAO Reviewed 

Number of acres burned (percentage of total) 

State/Fire Date IMT typea Federal Nonfederal

Total acres

burned Total cost

Arizona

Cave Creek 

Complex 

June-July 2005 1 231,171 (94%) 15,543 (6%) 246,714 $19,413,000

Florida Fire July 2005 1 22,549 (97) 634 (3) 23,183 6,217,000

California

Deep Fire August 2004 1 2,928 (93) 220 (7) 3,148 8,412,000

Pine Fire July 2004 1 4,180 (24) 13,238 (76) 17,418 13,311,000

Colorado

Mason Gulch 

Fire

July 2005 1 9,124 (80) 2,233 (20) 11,357 7,054,000

McGruder Fire July 2004 2 1,404 (50) 1,402 (50) 2,806 805,000

Utah

Blue Springs 

Fire

June-July 2005 2 10,331 (84) 1,955 (16) 12,286 3,497,000

Sunrise 

Complex 

July 2005 2 18,186 (85) 3,272 (15) 21,458 2,043,000

Source: GAO analysis of data from the Forest Service and the Department of the Interior. 

a

Incident management teams (IMT) are assigned to manage wildland fire suppression efforts on the 

basis of fire size and complexity. Type 1 IMTs typically handle the most complex fires. The IMTs

listed in the table represent the IMT type on each fire during its peak size and complexity. 

Page 34 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix III: Comments from the USDA Appendix III: Comments from the USDA Forest Service 

Forest Service 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix. 

See comment 1. 

See comment 2. 

Page 35 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix III: Comments from the USDA 

Forest Service 

Page 36 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix III: Comments from the USDA 

Forest Service 

The following are GAO’s comments on the USDA Forest Service’s letter 

dated April 18, 2006. 

1. We modified the language of our report to clarify that the cost-sharing 

method chosen can have significant financial consequences for the 

entities responsible for providing fire protection to the lands involved.

Although we agree that fires affecting the wildland-urban interface 

may be costly, regardless of the method used, it is precisely these high 

costs that make it critical for federal and nonfederal entities to agree 

on appropriate cost-sharing methods. 

GAO Comments 

2. We modified the language of our report to clarify that for the two fires 

discussed, nonfederal entities would likely have borne a greater 

proportion of the costs if another cost-sharing method had been used 

that better recognized the many aviation and ground firefighting assets 

that went toward protecting nonfederal lands and resources. We are 

not implying that costs should be shifted to the state or nonfederal 

entities without any basis. Rather, federal and nonfederal partners 

need to agree on cost-sharing methods that appropriately distribute 

wildland fire suppression costs on the basis of the federal and

nonfederal lands and resources requiring fire protection and the extent 

of firefighting assets used to protect each. 

Page 37 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix IV: Comments from the Department Appendix IV of the Interior : Comments from the 

Department of the Interior 

Page 38 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix V: Comments from the National Appendix V Association of State Foresters : Comments from the National 

Association of State Foresters 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of this appendix. 

See comment 1. 

Page 39 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix V: Comments from the National 

Association of State Foresters 

See comment 2. 

Page 40 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix V: Comments from the National 

Association of State Foresters 

The following are GAO’s comments on NASF’s letter dated May 5, 2006. 

1. NASF stated that it believes that the national template currently being

developed for master cooperative agreements will provide appropriate 

guidance for cost-sharing agreements. As NASF noted, the draft 

template lists several options for sharing suppression costs but does 

not provide definitive guidance as to when each cost-sharing method 

should be used. NASF stated that it does not believe that further 

efforts to define the specific circumstances that would warrant the 

selection of one cost-sharing method over another would be either 

productive or helpful. We continue to believe that more specific 

guidance—which could consider local characteristics and 

conditions—would assist local federal and nonfederal officials in 

negotiating cost-sharing agreements for individual fires. Without such 

guidance, inconsistencies in how costs are shared are likely to

continue, along with perceived inequities within and among states. 

GAO Comments 

2. NASF strongly believes that it is not the responsibility of the 

Secretaries of Agriculture and the Interior to clarify the financial 

responsibilities for suppressing fires that burn or threaten to burn 

across multiple jurisdictions. We agree with NASF that the Secretaries 

alone cannot clarify these responsibilities, and for that reason, we 

recommended that the Secretaries do so in conjunction with relevant 

state entities. Further, NASF stated that it is neither feasible nor 

appropriate to attempt to define at the national level the financial 

responsibilities for these fires. Ultimately, however, one or more 

entities will end up paying for the costs of fighting a particular fire, 

whether by explicit agreement beforehand or by negotiation afterward. 

To avert decision making after the fact, we maintain that federal and 

nonfederal entities—which have developed an effective cooperative 

firefighting relationship—need to further clarify their respective 

financial responsibilities in guidance articulated in advance of the fire 

season. 

In addition to written comments, NASF also commented orally about two 

other issues discussed in our report. First, NASF officials expressed 

concern about our example illustrating the influence of FEMA assistance 

on the selection of a cost-sharing method for a particular fire. They said 

that, in their experience, the availability of FEMA assistance does not 

influence a state’s willingness to use certain cost-sharing methods, some 

of which may lead states to pay higher costs. Although we did not attempt 

to determine how often the availability of FEMA assistance affected a

state’s choice of cost-sharing method, we believe that our example 

illustrates how, without specific guidance, costs for similar fires have been 

Page 41 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix V: Comments from the National 

Association of State Foresters 

shared in different ways. In its written comments, Interior also raised a 

related concern about federal assistance such as FEMA’s. Interior 

commented that it has already seen the issue arise several times this year, 

when states have requested, then canceled, federal firefighting resources 

seemingly on the sole basis of whether federal reimbursement was 

available. Second, with regard to state and local governments’ incentives 

for protecting the wildland-urban interface, NASF officials said that 

reducing the potential loss of life and property provides sufficient 

incentive for state and local governments to adopt laws requiring the use 

of protective measures against wildland fire. As we noted here and in a

previous report, however, many jurisdictions at risk from wildland fire 

have not yet adopted such laws. We have incorporated other NASF 

comments into our report as appropriate. 

Page 42 GAO-06-570 Wildland Fire Suppression Cost Sharing
Appendix VI: 

A

GAO Contact and Staff 

cknowledgments 

Page 43 GAO-06-570 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

Robin M. Nazzaro (202) 512-3841 or nazzaror@gao.gov 

In addition to the contact named above, David P. Bixler, Assistant 

Director; Ellen W. Chu; Jonathan Dent; Janet Frisch; Timothy Guinane; 

Kevin Jackson; Richard Johnson; Chester Joy; Winchee Lin; Tom 

Moscovitch; and Jena Sinkfield made key contributions to this report. 

Wildland Fire Suppression Cost Sharing

GAO Contact 

Staff 

Acknowledgments 

(360586) 
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