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44–854 PDF 2008

S. HRG. 110–540 

PREPAREDNESS FOR THE 2008 WILDFIRE SEASON 

HEARING 

BEFORE THE

COMMITTEE ON 

ENERGY AND NATURAL RESOURCES 

UNITED STATES SENATE 

ONE HUNDRED TENTH CONGRESS 

SECOND SESSION 

TO

CONSIDER THE PREPAREDNESS OF THE FEDERAL LAND MANAGEMENT 

AGENCIES FOR THE 2008 WILDFIRE SEASON 

JUNE 18, 2008 

( 

Printed for the use of the 

Committee on Energy and Natural Resources 
(II) 

COMMITTEE ON ENERGY AND NATURAL RESOURCES 

JEFF BINGAMAN, New Mexico, Chairman 

DANIEL K. AKAKA, Hawaii 

BYRON L. DORGAN, North Dakota 

RON WYDEN, Oregon 

TIM JOHNSON, South Dakota 

MARY L. LANDRIEU, Louisiana 

MARIA CANTWELL, Washington 

KEN SALAZAR, Colorado 

ROBERT MENENDEZ, New Jersey 

BLANCHE L. LINCOLN, Arkansas 

BERNARD SANDERS, Vermont 

JON TESTER, Montana 

PETE V. DOMENICI, New Mexico 

LARRY E. CRAIG, Idaho 

LISA MURKOWSKI, Alaska 

RICHARD BURR, North Carolina 

JIM DEMINT, South Carolina 

BOB CORKER, Tennessee 

JOHN BARRASSO, Wyoming 

JEFF SESSIONS, Alabama 

GORDON H. SMITH, Oregon 

JIM BUNNING, Kentucky 

MEL MARTINEZ, Florida 

ROBERT M. SIMON, Staff Director 

SAM E. FOWLER, Chief Counsel 

FRANK MACCHIAROLA, Republican Staff Director 

JUDITH K. PENSABENE, Republican Chief Counsel 
(III) 

C O N T E N T S 

STATEMENTS 

Page 

Bingaman, Hon. Jeff, U.S. Senator From New Mexico ........................................ 1 

Cason, James, Associate Deputy Secretary, Department of the Interior ............ 2 

Domenici, Hon. Pete V., U.S. Senator From New Mexico .................................... 4 

Judd, Casey, Business Manager, Federal Wildland Fire Service Association, 

Inkom, ID .............................................................................................................. 41 

Miley, Deborah, Executive Director, National Wildlife Suppression Association, Lyons, OR ..................................................................................................... 48 

Rey, Mark, Under Secretary, Natural Resources and Environment, Department of Agriculture .............................................................................................. 5 

Thatcher, Ron, President, Forest Service Council, National Federation of Federal Employees, International Association of Machinists and Aerospace 

Workers, Libby, MT ............................................................................................. 31 

Stanley, Christina M. .............................................................................................. 55 

APPENDIX 

Responses to additional questions .......................................................................... 57 

(1) 

PREPAREDNESS FOR THE 2008 

WILDFIRE SEASON 

WEDNESDAY, JUNE 18, 2008 

U.S. SENATE, COMMITTEE ON ENERGY AND NATURAL RESOURCES, Washington, DC. 

The committee met, pursuant to notice, at 2 p.m. in room SD– 

366, Dirksen Senate Office Building, Hon. Jeff Bingaman, chairman, presiding. 

OPENING STATEMENT OF HON. JEFF BINGAMAN, U.S. 

SENATOR FROM NEW MEXICO 

The CHAIRMAN. OK, why don’t we get started here, in the interest of time. I understand Senator Domenici is on his way and will 

be here shortly, but we want to just go ahead. 

At a time when much of the country is faced with devastating 

floods, other parts of the country are faced with the problems of 

wildfires, and the hearing today will focus on the preparedness of 

Federal agencies for the current wildfire season. 

So far, it’s been a very active season, many major wildfires from 

coast to coast, including the Trigo fire in my home State of New 

Mexico, which burned dozens of homes and, I believe, in excess of 

10,000—I think 13,000 acres was the last figure I saw. All indications are that the rest of the season will again strain budgets and 

firefighters and natural resources. 

During the last 8 years, we’ve experienced an average of more 

than four times as many days where agencies were at risk of running out of fire suppression resources than we did during the previous 10-year period. Last year, the agencies suffered the thirdhighest number of such days since 1990, leaving many wildfire 

managers with their requests for emergency firefighting resources 

unfulfilled. These numbers indicate that our preparedness has not 

kept pace with the dramatic increase in fire activity that we’ve experienced during these last 8 years. Nevertheless, in each of the 

last five budget proposals from the Administration, we’ve seen recommendations to cut the wildfire preparedness budget. In fact, in 

the President’s budget, had we gone at that level, we would be facing this summer with nearly a $100-million cut from in that budget, something which the Senate Appropriations Committee thankfully rejected. 

In recent years, the committee has considered many different aspects of wildfire management, including the pressing need for cost 

containment, the impacts of global warming on wildfire behavior, 

fuel reduction policies, and firefighter safety. This year, we also are 
2 

considering some of the serious human resource challenges that our 

firefighters and agencies are facing. Accordingly, we’ll hear from a 

number of organizations that represent wildfire fighters as part of 

our second panel. 

I’d also like to briefly comment on the continuing need for attention to the issue of global warming. Although we were not successful in having an extended debate on that issue when it was brought 

up a couple of weeks ago with the proposal for a cap-and-trade system, it is a topic which is certain to recur on our agenda. The incredible increase in fire activity we have seen clearly is associated 

with changes in our climate. As a result, we now spend billions of 

dollars more on wildfires than we did just 15 or 20 years ago, and 

we are losing more and more homes to fire, as well. 

So, it seems to me one of the most important things we need to 

do over the long term is to improve our wildfire preparedness, our 

control of fire suppression costs, and we need to reduce the strain 

on firefighters, communities, and the natural resources involved as 

part of dealing with climate issues. I look forward to a much more 

productive effort in the years ahead. 

So, with that, let me go ahead and call on our first panel, which 

is made up of The Honorable Mark Rey, the Under Secretary for 

Natural Resources and Environment in the Department of Agriculture, and James Cason, who is the Associate Deputy Secretary 

with the Department of Interior. 

You can proceed in whatever order you think is most appropriate, and then I’ll have some questions. 

Go right ahead. 

STATEMENT OF JAMES CASON, ASSOCIATE DEPUTY 

SECRETARY, DEPARTMENT OF THE INTERIOR 

Mr. CASON. Thank you, Mr. Chairman. Thank you for the opportunity to testify today on the wildland preparedness for the 2008 

fire season. 

Since the Department of Interior and the Department of Agriculture work closely together in fire management, the two departments are providing a joint statement. 

The Administration makes the protection of communities, the environment, and firefighters a priority, and included funding the full 

inflation-adjusted 10-year average for the wildland fire suppression 

in fiscal year 2008. 

Wildland firefighting activity has expanded and become more 

complex in recent years, contributing to the increased expenditures 

by the departments. As this committee has pointed out, these costs 

have escalated dramatically. The inflation-adjusted 10-year average 

for wildland fire suppression of the two departments, or $1.3 billion, is nearly three times the FY–2001 level of $472 million. 

Fire activity in 2007 was above normal by many standards. 

Across all jurisdictions, wildland fires total more than 85,000 incidents, burning over 9 million acres, including more than 16,000 

wildfires that burned 5.7 million acres on Federal lands. 

Last spring’s drought and high temperatures resulted in burning 

over 1.4 million acres in Florida and Georgia. The summer saw extreme fires in Utah, Nevada, and Idaho, with six of the year’s largest fires occurring in these States. Last year, the U.S. Forest Serv-
3 

ice spent nearly $1.4 billion on all fire suppression, while Department of the Interior spent approximately $470 million on all fire 

suppression. 

We are pleased that even in the face of a such a long and severe 

fire year, we achieved effective initial attack-and-suppression success on all fires. Working with our State, tribal, and local government partners, fewer homes were destroyed, approximately 2,900 

homes lost in 2007, compared to 4,500 homes lost in 2003, the most 

recent year that California endured a prolonged, extreme fire 

event. 

Most of the eastern, central, and northwestern U.S. is predicted 

to have a normal outlook for significant wildland fire potential in 

2008. Above-normal significant fire potential is expected across portions of southern California, the Southwest, Western Great Basin, 

the Rocky Mountains, Alaska, and Florida. 

For June-through-September period, significant fire potential is 

forecast to persist or increase in portions of California, the Southwest, Western Great Basin, and the Rocky Mountains. Significant 

fire potential will decrease across Florida, eastern New Mexico, 

western Texas, Alaska, and the southeastern portions of the Rocky 

Mountain area as the year progresses. 

The fire season has already produced incidents that are evidence 

of the potential for the 2008 fire season. As of May 31, 2008, over 

29,000 fires have burned in excess of 1.5 million acres. 

For the 2008 fire season, we will have available firefighting 

forces, firefighters, equipment, and aircraft comparable to those 

available in 2007. More than 18,000 firefighters will be available, 

including permanent and seasonal Federal and State employees, 

crews from tribal and local governments, contract crews, and emergency or temporary hires. This figure includes levels consistent 

with 2007 of highly trained firefighting crews, smoke-jumpers, 

Type-1 national interagency incident management teams—those 

are the most experienced and skilled teams available for complex 

fires or incidents—and Type 2 incident management teams available for geographic or national incidents. 

The National Interagency Coordination Center, located at the 

National Interagency Fire Center in Boise, Idaho, coordinates firefighting needs throughout the Nation. In the event of multiple, simultaneous fires, resources are prioritized, allocated, and, if necessary, reallocated by the National Multi-Agency Coordinating 

Group composed of representatives of major fire organizations 

headquartered at NIFC. If conditions become extreme, assistance 

from the Department of Defense is available under standing agreements, as well as firefighting forces from Canada, Mexico, Australia, and New Zealand, using established agreements and protocols. 

Recruitment, retention, and training of our firefighters are an 

important focus of the Department, one that is critical to our success. We are committed to the brave women and men across the 

country serving as wildland firefighters and wildland fire program 

managers. 

The two departments are working with the Office of Personnel 

Management to advance educational requirements for our professional firefighter managers in the series GS 401 within the time-
4 

frames that have been set. The departments believe that the 400 

series provides an advantage to its employees as a professional series that offers a broad range of natural resource leadership opportunities, as opposed to narrowly defined classification that may 

limit opportunities. 

Further, the positive educational requirements allow for better 

integration of fire management into the portfolio of skills necessary 

to achieve balanced knowledge of land and resource management. 

With that, Mr. Chairman, I’m going to turn the rest of the opening comments to Mark Rey, from the Forest Service. 

The CHAIRMAN. Let me just see if Senator Domenici wanted to 

make any statement, before you start, Mark, as an opening statement. 

STATEMENT OF HON. PETE V. DOMENICI, U.S. SENATOR FROM 

NEW MEXICO 

Senator DOMENICI. I would, Mr. Chairman, and I thank you very 

much for letting me do that. I apologize for being late. I thank both 

of you for being here. 

Under Secretary Rey, I also want to thank you for your focus on 

resolving the 401 firefighters classification issue, which I spoke to 

you about at Interior appropriations in April. 

Mr. Chairman, I was elected to the Senate, as we both know, in 

1972. In those 36 years, we have seen the total burned each year 

grow from an average of 2 to 3 million acres to an average of 8 to 

9 million acres per year. Over 154.8 million acres have burned 

since I was first elected to the Senate. But, what is stunning is 

that 58.5 million of those acres have burned in just the last 7 

years. Think of that. In 7 years, we have burned an area almost 

equal in size to the entire State of Oregon or slightly larger than 

the State of Utah. 

I would also note that the trend of acreage burned versus the 

number of acres managed by the Forest Service through timber 

sales and pre-commercial thinning is troubling. As the number of 

acres that have been treated has gone down, the number of burned 

acres has increased. From 1984 to 1993, the average burn rate was 

3.7 million acres per year, and the Forest Service treated nearly a 

million acres annually. From 1994 to 2003, the average burn rate 

was 4.9—let’s make it 5 million acres per year—while the Forest 

Service treated an average of only 550,000 acres. In the last 7 

years, 2000 to 2007, the average yearly burn has been 7.3 million 

acres, yet the Forest Service fuels-reduction work fell to an average 

of 470,000 acres annually. Seems to be falling further each year. 

In my mind, it’s one of those inconvenient truths that we have to 

face up to. We are spending more time managing less, burning 

more, and, as a result, we are having to cut funds to other important resource programs such as recreation, fisheries, and wildlife. 

At the same time, we are increasing the carbon dioxide and other 

pollutants that get pumped into the air by these fires. I would hope 

that Congress someday, hopefully soon, can get beyond the timber 

wars and focus on ways to reduce fire severity, increase utilization 

of forest products, and reduce the amount of money we’re forced to 

spend on fighting fires every year. 
5 

Mr. Chairman, thank you, again, for holding today’s hearing. If 

the hearing goes as planned, I have a closing statement that’s 

shorter, 1 and a half pages, that summarizes, from another aspect, 

what I’ve just said. 

Thank you very much. 

The CHAIRMAN. Thank you very much. 

Secretary Rey, why don’t you go right ahead. 

STATEMENT OF MARK REY, UNDER SECRETARY, NATURAL RESOURCES AND ENVIRONMENT, DEPARTMENT OF AGRICULTURE 

Mr. REY. Thank you. 

Secretary Cason left off with the educational requirements for 

the 401 series, and I want to submit for the record an update of 

where we’re at on that. I think we’re moving to an acceptable solution and won’t dwell on it further. 

[The information referred to follows:] 

USDA/USDOI GS-0401 UPDATE FIRE MANAGEMENT

Date: April 25, 2008. 

Update June 12, 2008. 

INTRODUCTION

This update addresses employees who currently occupy a GS-0401 Fire Management Specialist (FMS) position and employees in GS-0301, 0462 and 0455 fire technician positions who were scheduled to be converted to GS-0401 FMS positions over 

a five year transition period. These employees are required to meet the positive education and specialized experience requirements outlined in the Office of Personnel 

Management (OPM) Supplemental Qualification Standard for the Department of 

Agriculture—Forest Service and Department of Interior—Bureau of Indian Affairs, 

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

BACKGROUND

Following the deadly South Canyon Fire in 1994, an interagency team was formed 

to investigate the contributing factors to the fatalities. The subsequent 1995 Federal 

Wildland Fire Policy and Program Review, signed by both Secretaries of Agriculture 

and the Interior, directed Federal wildland fire agencies to establish fire management qualifications standards to improve safety and increase professionalism in fire 

management programs. After extensive effort, the Interagency Fire Program Qualifications Standards (IFPM) and Guide were completed. 

Standard positions descriptions were developed, classified and approved for coverage at the Departments for all 14 key positions that were identified as part of the 

IFPM Guide. The 5-year implementation plan was approved by the Secretaries of 

USDA and USDOI. 

The ‘‘Minimum Qualification Standards’’ (MQS) for IFPM contained four separate 

components: a positive education requirement as applicable; specialized experience; 

National Wildfire Coordinating Group (NWCG) position qualifications; and additional required training (if applicable). The OPM Supplemental Standards for GS0401 Fire Management Specialist requires a degree in biological sciences, agriculture, natural resources management or a related discipline, or courses equivalent 

to a major in biological sciences, agriculture, natural resources management, or at 

least 24 semester hours in biological sciences, wildland fire management, forestry 

or agriculture equivalent to a major field of study, plus appropriate experience or 

additional education that is comparable to that normally acquired through the successful completion of a full 4-year course of study in the biological sciences, agriculture or natural resources. Of the 14 key positions identified in the IFPM Guide, 

the positive education requirement addresses all positions identified as ‘‘professional’’ positions. This includes all positions classified at the GS-11 level and above 

and some GS-9 positions based on the complexity of the unit. This update addresses 

the requirements identified in the OPM Supplemental Standards for GS-0401 Fire 

Management Specialists series positions. 
6 

The fire management agencies have worked closely with academia for many years 

in an effort to develop curricula specific to fire management. Attachment #1 is a list 

of colleges and universities where the Forest Service currently has agreements in 

place or is developing them now. 

PROGRAM SCOPE

The Forest Service and Department of the Interior agencies have an estimated 

1000 positions affected by OPM educational requirements for GS-0401qualification. 

The number of Fire Management Specialists who occupy mid-to upper-level fire positions having a positive education requirement is estimated at 800. The Forest 

Service has identified an additional 200 professional positions at the District level 

that fall under a separate agency-specific timetable. 

On February 15, 2005, OPM issued new educational requirements in response to 

congressional direction. This change resulted in previously creditable NWCG courses 

no longer being creditable towards meeting the positive education requirements of 

the 0401 qualification standard. Courses are now creditable only if they appear on 

a transcript from an accredited institution. 

This decision affects employees in two different groups. First, there are employees 

who were placed in GS-0401 positions but do not meet the positive education requirement. The agencies have identified the employees and are working aggressively 

to ensure they meet the education requirement as quickly as feasible. OPM has 

granted the agencies until October 1, 2010 for employees to continue working in the 

wildland fire program while they meet the education requirement. The Department 

of the Interior estimates 37 employees and the Forest Service estimates 30 employees are in this category. 

FS Status as of June 2008: (To be updated quarterly) 

1. 30 Forest Service employees have been identified. 

2. HCM will notify these employees by July 11, 2008, of what they are lacking 

to meet the positive education requirements pending the receipt of documentation. ( HCM responsible staff) 

3. Employees will have signed agreements, IDPs and a plan of action in place 

by September 5, 2008. (Fire and Aviation Management responsible staff). 

The second groups of employees are those who hold positions slated to transition 

to GS-0401 FMS positions over the implementation period which has also been extended to October 1, 2010. At this time, the Forest Service and Department of the 

Interior estimate 236 employees in this status. The Forest Service estimates a maximum of 170 employees, and the Department of the Interior estimates 66 employees 

in this category. Therefore, we estimate the total number of employees affected by 

this standard change and are in the process of meeting educational requirements 

of the GS-0401 qualifications to be approximately 300 employees. 

FS Status as of June 2008: (To be updated quarterly) 

1. Forest Service is hiring a Contractor to review the education and 

coursework for the estimated 170 employees slated to transition to the GS-0401 

series by October 2010. 

2. Contractor targeted to be in place by July 14, 2008. 

3. Review estimated to be completed by September 30, 2008. 

Accomplishments and Actions: The following summarizes actions that were previously in place and recent additions. They apply to all employees currently seeking 

GS-0401 Fire Management Specialist series qualification including those erroneously placed in the series on or after February 15, 2005. The process is being communicated to managers and the field as indicated: 

• Agencies have sent out correspondence to make sure that affected employees in 

the GS-0401 Fire Management Specialists series are aware of the OPM 

changes. 

• Fire Managers have been briefed on the GS-0401 Fire Management Specialist 

changes. 

• Human Resources specialists have been made aware of the OPM changes. 

• Human Resources specialists have reevaluated employees who were erroneously 

placed in GS-0401 Fire Management Specialists positions. 

• Employees affected by the OPM policy are being notified and told how the 

change has affected their positive education. 

Short Term Accomplishments and Actions: These actions are planned to assist all 

employees in completing the positive education requirements for the GS-0401 Fire 

Management Specialist series. 
7 

Continue to ensure both management and affected employees clearly understand 

what constitutes creditable coursework. 

• Ensure supervisors and employees understand their respective roles. 

• Ensure that all agreements are in place between management and the employee 

(FS Due 08/01/08). 

• Continue to support employees attending universities or colleges through Individual Development Plans. 

• Continue to collaborate with universities and colleges that maintain fire management courses as part of their curriculum (For many of the programs already 

in place see attachment 1). 

• Encourage enrollment and completion of Technical Fire Management (TFM), a 

program that has provided 18 semester hours of qualifying courses since 1982. 

• Where agreements are in place, agencies will continue to provide tuition support for Technical Fire Management courses and possibly other applicable educational coursework as approved in employee development plans. 

• Ensure, by meeting with each individual, that all those employees erroneously 

qualified and placed after Feb 15, 2005, have a written plan of the actions needed to meet the GS-0401 requirements (FS Due 06/30/08). 

• If needed, Agency leads at the Geographic or National level will continue to 

identify additional institutions and formalize procedures for seeking retroactive 

approval and transcription of creditable NWCG courses. 

• For the Forest Service -where agreements are in place, agencies will pay for any 

past credits when they are creditable toward GS-0401 Fire Management Specialist standards through October 1, 2010. 

• Agency program leads at the Geographic and National level have and will continue to identify in-state tuition, distance learning and regional opportunities to 

limit costs when possible. 

Long Term Accomplishments and Actions: These actions are planned assist all 

employees with the migration‘ beyond the transition period from technical (GS-0301, 

0462 and 0455) to the professional GS-0401 Fire Management Specialists series: 

• National and Geographic program leads will continue to encourage more universities to develop Wildland Fire Science degree programs and integrate applied 

science to the field in the form of creditable internships with Federal and State 

agencies (FS Due 10/01/10). 

• Work with additional universities and colleges to enter into agreements to accept NWCG courses within their existing curriculum or expand their curriculum 

to accept NWCG courses toward a Wildland Fire Science or other Natural Resource Management degrees (FS Due 10/01/10). 

• National and Geographic program leads will continue to encourage universities 

to create more on-line or compressed courses that would be available to employees at isolated duty stations or in situations where they are less capable of attending formal classroom courses. 

• Data is continually being added at the local level to the Incident Qualifications 

and Certification System and monthly have been and will continue to be pulled 

to track accomplishments and identify trends. 

Note: Not all actions will be completed by the Forest Service and DOI. Some actions are Forest Service-specific and vice versa. 

ATTACHMENT #1 

The table lists universities and colleges where current agreements are in place for 

Natural Resources/Biological Science and/or some NWCG curriculum. However, this 

is not an exhaustive list. It is important to note that any course offered by any college or university is considered qualifying if it meets the academic requirements 

identified in the Fire Management Specialist Supplemental Standards. 
8 

He also talked about our commitment to retaining our firefighters where there are challenges, particularly in southern California, and I’d like to submit for the record a detailed report on 

that situation. 

[The information referred to follows:] 

FIRE AND AVIATION MANAGEMENT RECRUITMENT AND RETENTION ANALYSIS

USDA FOREST SERVICE

Introduction 

This report is in response to the following language in the Explanatory Statement 

accompanying the Consolidated Appropriations Act of 2008 (P.L. 110-161). 

The Appropriations Committees are aware that the Forest Service is facing challenges to recruit and retain wildland firefighters in Region 5, particularly on Southern California forests, due to the agency’s vastly different 

pay scales and personnel policies and the high cost of living in the region. 

The Forest Service should examine Federal firefighter pay and personnel 

policies and provide the House and Senate Committees on Appropriations 

with a proposal to increase recruitment and retention for Southern California forests no later than February 1, 2008. 

The Forest Service (FS) appreciates the patience of the Appropriations Committees in allowing Region 5 and the national headquarters to develop a thorough analysis of this complex set of issues. The dynamics studied in this proposal are controversial and will not be solved quickly or easily. For that reason, our proposal includes a series of long term suggestions to address the issues identified above. 

It is important to note two things about the national context surrounding this report. First, the efficacy of Forest Service initial attack response has not diminished. 

The success continues to stay around 98% for all initial attack incidents. The agency 

is committed to maintaining this high level of success. Second, recent increases in 

Fire Suppression expenditures have been well documented, as has the resulting impact on other agency programs. In response, Forest Service leadership has aggressively implemented cost containment measures, resulting in decreased Suppression 

costs in FY 2007. It is essential that the proposals related to Region 5 firefighter 
9 

* Figures 1–4 have been retained in committee files. 

recruitment and retention support both continued initial attack success and cost 

containment efforts. 

The issues highlighted by this report will continue to be closely monitored. 

Issues Examined 

The issues examined in the report are widely circulated and are frequently polarizing; therefore the methods used to complete the analysis relied on data from a variety of sources. Rates of attrition were from Region 5 records, Forest Service 

Human Capital records and the Office of Personnel Management. Pay data was 

from employees’ W-2’s both CAL FIRE and U.S. Forest Service. The reasons for 

leaving were provided from exit interviews in Region 5. 

Forest Service Human Capital Management staff reviewed pay act and authorities and determined there are actions available locally, regionally and nationally. 

The Regional Forester and other line officers have discretion in the application of 

these authorities. 

There is a perception, as noted by the Appropriations Committees and confirmed 

through informal employee sensing, the Forest Service faces recruitment and retention challenges in Southern California. While a detailed analysis shows the region 

has some retention challenges, it also suggests the problems are manageable. 

A 10-year analysis of permanent fire workforce in Region 5 reveals several important trends. 

1) The total number of permanent Fire and Aviation Management staff in the 

region nearly doubled between 1997 and 2007, from 1,257 to 2,290. An 82% increase indicates successful recruitment efforts, not the opposite. 

2) In 2007 the Region 5 Fire and Aviation Management staff experienced 370 

retirements, resignations and transfers. However, recruitment resulted in a net 

gain of 68 employees, or 3%. 

3) The overall Forest Service attrition rate in Southern California (9.4%) is 

actually lower than the national Federal attrition rate (13.4%).* 

These statistics indicate that recruitment is outpacing attrition in Region 5. Furthermore, attrition within Southern California is well within national averages. 

Based on these trends, it appears that recruitment and retention are within expected norms. However, there are areas within the statistics cited above which deserve closer examination, and which the proposals of this report will address. 

First, the largest component of separations within the Region 5 Fire and Aviation 

Management organization come at the GS-4 level, where the attrition rate is 46.6%. 

Attrition rates above the GS-4 level do not differ significantly from regional or national averages. 

Second, a higher percentage of separations are due to resignations (as opposed to 

retirement or transfers) than the regional or national average (Figure 2). Exit interviews indicate that 44% of those leaving the Forest Service went to CAL FIRE or 

local fire departments (Figure 3). 

Thirdly, these trends are most pronounced on the Angeles National Forest and 

the San Bernardino National Forest, which saw the most resignations of any Region 

5 forests. Of the resignations on these two forests in 2007, 45% were at the GS4 level, and 61% went to State, county or local fire departments. The attrition rates 

for the two forests were 12.2% and 9.3% in 2007, according to Region 5 data. 

Pay Scales, Cost of Living, and Personnel Policies 

Local perception, as noted by the Appropriations Committees, is Forest Service 

pay scales and personnel policies, coupled with the high cost of living in Southern 

California, make it difficult to attract and retain Fire and Aviation Management 

workforce in the region. Upon closer examination, the perception of the effects of 

pay scale and personnel policy discrepancies and high cost of living appears to be 

unsupported by the data. 

Pay Scales 

Comparison of Forest Service and CAL FIRE payment and hours worked data for 

2007 suggests that actual hourly rates of pay are comparable. It was difficult to determine the appropriate metric for comparison as the pay, staffing and personnel 

policies differed greatly. Wages as shown on W-2 forms were chosen as a measure. 

Cal Fire employees on average for the three (3) positions examined worked about 

62% more hours (4,457 v. 2,768) than their Forest Service counterparts. The comparison of pay and hours is not straight forward due to personnel policy differences, 

such as portal-to-portal pay and planned overtime that guarantee Cal Fire fire-
10 

fighters more total hours annually. Nonetheless, when accounting for all hours 

worked, overtime and hazard pay rates (see Figure 4): 

—Average pay of Firefighter II is $2.81/hour higher in FS than CAL FIRE 

—Average pay of Fire Engineer is $5.36/hour higher in FS than CAL FIRE 

—Average pay of Fire Captain is $7.08/hour higher in FS than CAL FIRE 

Although Forest Service hourly pay is equal or higher, staffing plans guarantee 

CAL FIRE employees more hours and consequently more pay annually. In addition, 

Cal Fire employees work a 72 hour, three day shift, benefit from 24 hour pay while 

on fire assignments, and have a more generous retirement plan. Federal wildland 

fire staffing is closely tied to the threat of wildland fire activity, which occurs within 

a defined season. To ensure initial attack success and public safety during the fire 

season at the most reasonable cost to taxpayers, the Forest Service uses variable 

staffing, seasonal aviation contracting and seasonal employees. 

The data in the table above (figure 4) was developed from actual 2007 W-2 data 

randomly selected from a sample of Forest Service employees in Southern California. It includes overtime and hazard pay. The Cal Fire data is actual 2007 compensation provided by their agency. Cal Fire employees do not receive hazard pay. 

The average hourly rate is computed by dividing the total compensation by the total 

hours worked. Unplanned overtime is highly variable for employees of both agencies. 

Forest Service employees at the GS-04 and 05 grades are Permanent Seasonal 

employees either 13/13 or 18/08 (guaranteed at least 13 pay periods or 18 pay period 

of employment out of a total of up to 26). Cal Fire employees are all full time employees. 

Cal Fire employees work a 72 hour schedule each week which is paid as 53 base 

hours and 19 planned overtime hours. Any time in excess of 212 in a 28 day period 

is paid as unplanned overtime. 

It should be noted the two agencies have very different work schedule expectations and pay rules therefore actual compensation was averaged to determine the 

unplanned overtime. 

Cost of Living 

Analysis performed by the Office of Personnel Management (OPM) indicates that 

Federal employees in Southern California do experience pay disparities compared to 

non-Federal workers. However, Los Angeles and San Diego are not the only localities where this is true, nor do they experience the most severe disparities. In fact, 

the pay disparity in Los Angeles is below the national average, and San Diego’s is 

comparable. Below is a table of 2007 pay disparities for comparison. 

Personnel Policies 

Comparing personnel policies of Federal wildland fire agencies with local and 

state fire agencies is complex. While it is natural for employees to compare their 

job descriptions, compensation, and benefits with those of similar workers in close 

proximity, there are also important distinctions and valid differences between them. 

Forest Service fire management personnel in Southern California and across the nation are Forestry Technicians. This title reflects their land management orientation. 

In the course of their work, they collaborate with state and local employees of fire 

departments. This is a subtle but key difference. Even though both Federal wildland 

firefighters and fire department firefighters focus on fire, the mission purposes of 

the agencies differ, and so too do the roles and responsibilities of their respective 
11 

personnel. Fire departments generally have an emergency responder role that includes traffic collisions, medical calls and other actions that are not wildland fires. 

That is to say, the Forest Service is a land management agency that employs 

wildland firefighters to accomplish land management objectives, while the mission 

of fire departments personnel focus on preserving life and property. Because of differing responsibilities, it is both impossible and inappropriate for the Forest Service 

to pay and staff the same way as these fire departments. For example the Forest 

Service does not allow fire fighters to enter structures to suppress these fires. 

The tendency of our employees, partners and the public to compare Forest Service 

fire management responsibilities to State and local fire departments points to a 

larger issue the Agency is facing regarding the need for a clear mission and definition of responsibilities for our firefighters in the wildland urban interface. Fires in 

recent years have become larger and more difficult to control due to a variety of factors, including climate change, historic fire suppression efforts resulting in increased 

density of hazard fuels, and expansion of residences in the wildland urban interface 

(WUI). This situation is acutely felt in Southern California where over 189,000 new 

homes have been built since 2003 in the Wildland/Urban interface. This growth 

poses a higher level of complexity on Wildland firefighting in fire adapted ecosystems. Therefore, the Agency must clearly express its emergency response role, 

and clarify distinctions between State and local fire department. 

Proposed Actions 

The analysis outlined above suggests that the perceptions around recruitment and 

retention in Southern California are hard to substantiate based on data. An analysis 

of available data confirms that while issues regarding perceptions around recruitment and retention in southern California may exist, they cannot be objectively substantiated. Absent such substantiation, recommendations that the Office of Personnel Management depart from standard Federal pay rates or the agency seek 

other special personnel authorities are unwarranted. Further, such actions may 

have the unintended consequence of negatively affecting recruitment and retention 

elsewhere in the nation. 

Accordingly, key actions to be undertaken immediately by the Forest Service will 

be internal and external communication around these findings: 

• Region 5’s Fire & Aviation Management recruitment rate is greater than its attrition rate. 

• The attrition rate in Southern California is below national averages. 

• On average, Forest Service hourly pay rates are actually greater than those for 

comparable CAL FIRE positions. 

• Federal workers in Southern California are paid less than their counterparts in 

the private sector, but other parts of the country experience similar or worse 

rates of disparity. 

In the course of this analysis, additional issues outside the scope of the requested 

report have become evident; clearly there are morale issues which need leadership’s 

attention and action. We refrained from making recommendations addressing these 

in the report as it is outside the scope of the committee’s request. Additionally, these 

morale issues will take more time to review, validate and resolve. Leadership will 

focus attention on this important area and will keep the committees apprised of the 

situation and the progress to resolve the issues. 

In addition to increased communication around key issues, the Forest Service will 

consider specific long-term actions. These recommendations will consider potential 

morale and budget impacts resulting from providing special benefits solely to firefighters in southern California. Changing public and agency perceptions and ensuring employee morale will require active management over years. The recommendations below may be tools in that process. 

• Review and strengthen commitment to Wildland fire mission with federal, State 

and local partners. 

• Strategically apply individual retention allowances and/or special pay authorities within the discretion of the Agency. 

• Encourage use of optional work schedules and tours of duty. 

• Improve employee housing and working facilities. 

• Improve communications connectivity, training, and access. 

• Determine cost and feasibility of special pay in identified high cost areas. 

• Renegotiate cooperative agreements to provide more equity for Forest Service 

employees. 

• Monitor issues identified and adjust as necessary. 
12 

* Document has been retained in committee files. 

Mr. REY. Then I’ll pick up where he left off and talk a little bit 

about our aviation assets as we talk about preparedness, and then 

talk about some of the cost control and fuels treatment initiatives 

we have underway. 

I have given, in the prepared statement, a detailed analysis of 

what our aviation assets will be for 2008. They will be comparable 

to the aviation assets that existed in 2007 and in previous years, 

with a heavier emphasis on exclusive-use aircraft as a cost-savings 

measure. 

Now, in terms of what we have done to reduce costs, the 

Wildland Fire Management Program is moving in a positive direction. We’ve committed to continued improvement to increase our effectiveness and maximize our efficiencies, and the agencies will 

continue to face challenges outside of our control of such outside 

variables as the expansion of the wildland-urban interface and climatic and ecological changes. These have made the protection of 

life, property, and natural resources from wildland fire more complex, demanding, and expensive. However, we have the ability to 

make managerial decisions before and during fire incidents, and 

are working assertively on risk-informed management, cost management, and operational efficiencies, utilizing research and technology and targeted program implementation to reduce these impacts. 

We have continued to strengthen and expand the implementation 

of adopted policy of risk-informed management, with the appropriate management response as its guide. We’ve continued to focus 

on hazardous fuels treatment in the wildland-urban interface and 

in fire-adapted ecosystems. We have accelerated the development 

and deployment of decision tools, such as the Wildland Fire Decision Support System. We’ve used the Stratified Cost Index to inform resource deployment options. We’re continuing to work on enhanced response and efficiency that comes with national shared resources and aviation resource cost management. We spent $100 

million less in 2007 than we did in 2006 in a more adverse fire 

year. We spent 200 million less than the midrange projection of 

what we thought 2007 would cost, given the climate and weather 

predictive models that we used. 

We’re in the process of finalizing a long-term interagency aviation strategy and we are now using routine after-action reviews to 

apply lessons learned from the large incidents that occur each year. 

Today, we released an independent study of controlled costs during the 2007 fire season done for us by the Brookings Institute.* 

The Brookings Institute Panel, which was a peer-review panel, reviewed the 27 incidents in 2007 that each exceeded $10 million 

during the 2007 fire season. The review panel found that there was 

a much greater awareness of cost containment throughout the fire 

community in 2007, and that there was a concerted effort to make 

cost management more than just another competing priority. 

The panel concluded that appropriate cost-containment initiatives were used in all 27 of the large fire incidents that they reviewed, and I’ll submit the entirety of that record, released today, 

for your hearing. 
13 

[The information referred to follows:] 

NEWS RELEASE

USDA FOREST SERVICE, PRESS OFFICE

INDEPENDENT STUDY FINDS FEDERAL AGENCIES CONTROLLED COSTS

DURING 2007 FIRE SEASON

WASHINGTON D.C., June 18, 2008,—An independent panel study, conducted by 

The Brookings Institution, found that the Forest Service and Department of the Interior exercised appropriate fiscal diligence during the 2007 wildfire season. The 

panel reviewed the 27 wildfire incidents that each exceeded $10 million in the 2007 

fire season, totaling $547 million in suppression costs and nearly 3 million burned 

acres. 

The review panel also found that there was a much greater awareness of cost containment throughout the fire community in 2007. The panel’s report compared the 

27 wildfires in 2007 with the 18 wildfires that exceeded $10 million during the 2006 

fire season. While both fire seasons were somewhat similar, in 2007 there was a 

‘‘concerted effort to make cost management more than just another competing priority,’’ according to the panel. This was reflected in the choice of fire suppression 

tactics, the selection of incident teams, and the use of resources—especially on 

longer term fires. 

The panel also offered recommendations on the following key issues: 

—Transforming Fire Management Plans from program reference documents 

into more strategic assessments of fire management planning and policies. 

—Creating stronger linkages from Fire Management Plans to Community Wildfire Protection Plans. 

—Ensuring that next generation decision support tools address complex fire 

management and longer term fire scenarios. 

—Pursuing flexible suppression strategies, especially on extended fires. 

—Revising the thresholds and selection criteria for regional and national reviews. 

According to USDA Under Secretary Mark Rey, the Department is implementing 

cost management strategies and will develop an action plan to address the panel’s 

recommendations. 

This independent study is chartered by the Secretary of Agriculture, per direction 

from congress, and has been successfully conducted since the fiscal year 2004. The 

complete 2007 report is available on the Forest Service Fire & Aviation Management Web site at: http://www.fs.fed.us/fire 

The Departments of the Interior and Agriculture have the best 

wildland firefighting organization in the world. I’m surprised that 

statement made through OMB clearance, since it’s a bit modest— 

immodest. But, you know, as Dizzy Dean said, ‘‘It ain’t braggin’ if 

ya done it,’’ and we have maintained an efficiency of—at initial attack, of extinguishing nearly 98 percent of the fires that we want 

to extinguish, and that’s the measure that we look at, not how 

many dollars we spend, not necessarily how many people or materiel we deploy, but, Are we still extinguishing that high level of ignitions when we’re in the midst of a fire season? That number, 

even with cost containment and cost savings, has remained the 

same. 

We’ve also continued to make the restoration of healthy forests 

and grasslands an environmental priority, and we’ve made great 

strides in accomplishing that goal. From 2001 through the end of 

May 2008, the Forest Service and the Department of the Interior 

land management agencies have treated over 26 million acres, an 

area larger than the State of Ohio. We are now treating, on an annual basis, four times the acres that were treated during the decade of the 1990s. 
14 

Now, that’s odds with the numbers that you just presented to us, 

Senator Domenici, and I’ll work your staff to reconcile them. But, 

I think the reason those numbers are at odds is that what you’re 

providing is acres burned. We agree with the increase in acres 

burned annually. But, I think, in the numbers you use, you excluded any fuels treatment done by prescribed burning, and limited 

your analysis to mechanicals fuels treatment and commercial timber sale activity. If you limit the analysis that way, the net number 

is declining, but if you look at all the fuels treatment activities that 

we do—prescribed burning, thinning, the development of fuel 

breaks, and, yes, the reduction of fuels through commercial timber 

sales—if you look at all four of those categories, the number is 

going up significantly, not down. 

With that, we’d be happy to answer any questions that the panel 

has. 

[The joint prepared statement of Mr. Rey and Mr. Cason follows:] 

JOINT PREPARED STATEMENT OF MARK REY, UNDER SECRETARY FOR NATURAL RE- SOURCES AND ENVIRONMENT, DEPARTMENT OF AGRICULTURE, AND JAMES CASON, ASSOCIATE DEPUTY SECRETARY, DEPARTMENT OF THE INTERIOR

INTRODUCTION

Mr. Chairman and members of the Committee, thank you for the opportunity to 

testify today on Wildland Fire Preparedness for the 2008 fire season. Since the Department of the Interior (DOI) and the Department of Agriculture (USDA) work 

closely together in fire management, the two Departments are providing a joint 

statement. 

The Departments take seriously and perform professionally and honorably our 

roles as land stewards and managing wildland fire. The Administration makes the 

protection of communities, the environment, and firefighters a priority and included 

funding the full inflation-adjusted 10-year average for wildland fire suppression in 

fiscal year 2008. 

Wildland firefighting activity has expanded and become more complex in recent 

years, contributing to increased expenditures by the Departments. As this Committee has pointed out, these costs have escalated dramatically: the inflation-adjusted 10-year average for wildland fire suppression of the two Departments, $1.3 

billion, is nearly three times the FY 2001 level of $472 million. 

The Departments have adopted substantive management reforms to mitigate this 

cost trend. The Departments and our partners have spent significant effort and resources over the past several years to coordinate capability, improve inter-governmental communication, and employ management controls to ensure effective response. At the same time we have increased attention to cost containment and these 

efforts are having an effect on suppression costs. For example, USDA saw a decrease of over $100 million on suppression expenditures in 2007 compared with 2006 

even though the size of wildfires and acres burned were greater. Likewise, Interior 

has instituted management controls in 2008 to better manage overall suppression 

expenditures. Together, the Departments are committed to continue progress enhancing fiscal accountability, adopting best management practices, and improving 

efficient program delivery. 

THE 2007 FIRE SEASON

Fire activity in 2007 was above normal by many standards. Across all jurisdictions, wildland fires totaled more than 85,000 incidents burning over 9 million 

acres, including more than 16,000 wildfires that burned 5.7 million acres of Federal 

lands. Last spring’s drought and high temperatures resulted in the burning of over 

1.4 million acres in Florida and Georgia. The summer saw extreme fires in Utah, 

Nevada and Idaho with six of the year’s largest fires occurring in these States. 

Last year, the U.S. Forest Service spent nearly $1.4 billion on all fire suppression 

while DOI spent approximately $470 million on all fire suppression. We are pleased 

that even in the face of such a long and severe fire year we achieved effective initial 

attack and suppression success on all fires. We will strive to maintain that level of 

performance. Although the 2007 fire season had 13 fires over 100,000 acres, and 33 

days in Preparedness Level 5—the highest level of fire activity during which several 
15 

geographic areas are experiencing simultaneous major incidents and events in highly populated areas in Northern and Southern California, less money was spent by 

the Forest Service on suppression than in 2006. Working with our state, tribal, and 

local government partners, fewer homes were destroyed—approximately 2,900 

homes lost in 2007 compared with over 4,500 homes lost in 2003, the most recent 

year that California endured a prolonged, extreme fire event. In the face of increasing fire management challenges around the country and southern California 

wildfires last fall, the Departments demonstrated superior performance. 

The dedicated focus on hazardous fuels treatments and other forest restoration actions are making a difference in the wildland urban interface and a commitment 

to cost containment strategies are producing results. 

2008 WILDLAND FIRE SEASON OUTLOOK

Most of the eastern, central and northwestern U.S. is predicted to have a normal 

outlook for significant wildland fire potential in 2008. Above normal significant fire 

potential is expected across portions of southern California, the Southwest, Western 

Great Basin, Rocky Mountains, Alaska and Florida in June. For the June through 

September period, significant fire potential is forecast to persist or increase in portions of California, the Southwest, Western Great Basin, and Rocky Mountains. Significant fire potential will decrease across Florida, eastern New Mexico, western 

Texas, Alaska, and southeastern portions of the Rocky Mountain area. The primary 

factors influencing fire potential this outlook period are: 

• The amount of precipitation many areas receive in the early summer periods 

is an important factor in the severity of the fire season. Even with a rather wet 

period during the latter half of May, most of the West has been drier than normal this spring. 

• Drought conditions continue over portions of the West and Southeast. However, 

improvement is expected in the Southeast and to a lesser degree over Texas and 

New Mexico. 

• Abundant fine fuels across portions of the Southwest, southern California 

deserts and Front Range of the Rockies may lead to an above normal fire season 

in these areas. 

• Fire potential should begin to wane over the Southwest and Florida in July due 

to the onset of the Southwest monsoon and increasing humidity and showers 

in the Southeast. Late spring snows could result in reduced fire potential in the 

Northern Rockies. 

The fire season has already produced incidents that are evidence of the potential 

of the 2008 fire season. As of May 31, 2008, over 29,000 fires have burned in excess 

of 1.5 million acres. About half of the incidents occurred in the southeast and they 

burned two-thirds of the acres. Large fires in Texas and Florida, which continue to 

experience long-term drought conditions, made up much of the spring acres burned. 

WILDLAND FIRE PREPAREDNESS

To prepare for conditions anticipated in the 2008 fire season, the Departments are 

working to improve the efficiency and effectiveness of our firefighting resources. Fire 

managers assign local, regional, and national firefighting personnel and equipment 

based on anticipated fire starts, actual fire occurrence, fire spread, and severity with 

the help of information from the National Interagency Fire Center Predictive Services group. 

Firefighting Forces 

For the 2008 fire season, we will have available firefighting forces—firefighters, 

equipment, and aircraft—comparable to those available in 2007. More than 18,000 

firefighters will be available, including permanent and seasonal Federal and State 

employees, crews from Tribal and local governments, contract crews, and emergency/temporary hires. This figure includes levels consistent with 2007 of highlytrained firefighting crews, smokejumpers, Type 1 national interagency incident 

management teams (the most experienced and skilled teams) available for complex 

fires or incidents, and Type 2 incident management teams available for geographical 

or national incidents. 

The Forest Service hosts four interagency National Incident Management Organization (NIMO) teams staffed for 2008. They will operate with four seven-member 

full-time Type I Incident Management Teams ready to respond to wildland fire incidents. Already this year we are utilizing these teams in an interagency fashion in 

North Carolina on the Evans Road fire. These teams will not only assist in wildland 

fire incidents this season but implement the NIMO Implementation Plan, which 
16 

calls for improvements in wildland fire program management in the areas of training, fuels management, cost containment, and leadership development, among others. 

The National Interagency Coordination Center, located at the National Interagency Fire Center in Boise, coordinates firefighting needs throughout the nation. 

In the event of multiple, simultaneous fires, resources are prioritized, allocated, and, 

if necessary, re-allocated by the National Multi-Agency Coordinating group, composed of representatives of major fire organizations headquartered at NIFC. 

Prioritization ensures firefighting forces are positioned where they are needed most. 

Fire managers dispatch and track personnel, equipment, aircraft, vehicles, and supplies and are all managed through an integrated national system. If conditions become extreme, assistance from the Department of Defense is available under standing agreements, as well as firefighting forces from Canada, Mexico, Australia, and 

New Zealand, using established agreements and protocols. 

Recruitment, retention and training of our firefighters are an important focus of 

the Departments—one that is critical to our success. We are committed to the brave 

women and men across the country serving as wildland firefighters and wildland 

fire program managers. The two Departments are working with the Office of Personnel Management to achieve educational requirements for our professional fire 

managers, GS 401, within the time frame they have set. The Departments have a 

plan in place to outreach to employees affected by this policy and will make every 

effort possible to assist all affected employees who wish to meet these educational 

requirements. The Departments believe that the 400 series provides an advantage 

to its employees as a professional series that offers a broad range of natural resource leadership opportunities as opposed to a narrowly defined classification that 

may limit opportunities. Further, the positive education requirement allows for better integration fire management into the portfolio of skills necessary to achieve balanced knowledge of land and resource management. 

The agencies are dedicated to active recruitment and retention of fire fighters as 

well. The Forest Service recently completed an analysis for California and found 

that the recruitment rate is greater than its attrition rate. In fact, the total number 

of permanent Fire and Aviation Management staff in the region nearly doubled between 1997 and 2007, from 1,257 to 2,290. An 82% increase indicates successful recruitment efforts, not the opposite. Also, on average, Forest Service hourly pay rates 

are actually greater than those for comparable State positions. We acknowledge 

some National Forests areas in California have retention challenges, but we believe 

these situations are manageable. The Forest Service is currently assessing options 

to address this situation carefully in California and will implement approaches that 

are appropriate for the region shortly after June 30, 2008. The agencies have begun 

to assess this issue nationally and expect progress on a strategy for ensuring a 

strong firefighting force into the future. 

Aviation 

The wildland firefighting agencies continue to employ a mix of fixed and rotor 

wing aircraft. Key components of the Forest Service 2008 aviation assets include approximately 20 civilian large air tankers on Federal contracts, along with up to 35 

Type 1 heavy helicopters and 34 Type 2 medium helicopters on national exclusiveuse contracts; 53 Type 3 helicopters on local or regional exclusive-use contracts, and 

8 Modular Airborne Fire Fighting System units that will be available for deployment. 

Additionally, there are nearly 300 call-when-needed Type 1, 2 and 3 helicopters 

available for fire management support as conditions and activity dictate. Likewise, 

Interior the lead contractor for Single Engine Air Tankers, will maintain a mix of 

aviation resources in 2008 similar to that used in 2007, including call-when-needed 

and exclusive-use SEATS along with two water scooper air tankers, 34 Type 3 helicopters, and 11 Type 2 helicopters, as well as a mix of other classes of aircraft. 

WILDLAND FIRE MANAGEMENT PROGRAM

The wildland fire management program in the two Departments is strong and 

moving in a positive direction. We are committed to continued improvement to increase our effectiveness and maximize our efficiency. The agencies will continue to 

face challenges outside of our control such as the expansion of the wildland-urban 

interface, and climatic and ecological changes. These have made the protection of 

life, property and natural resources from wildland fire more complex, demanding 

and expensive. However, we have the ability to make managerial decisions before 

and during fire incidents, and are working assertively on risk-informed management, cost management and operational efficiencies, utilization of research and tech-
17 

nology, and targeted program implementation in order to reduce these impacts. 

More specifically, these actions include: 

• Continuing, under the guidance of the Wildland Fire Leadership Council, to 

strengthen and expand the implementation of adopted policy of risk-informed 

management with Appropriate Management Response as its guide; 

• A focus on hazardous fuels treatments in wildland urban interface areas and 

in fire-adapted ecosystems that present the greatest opportunity for forest restoration and to reduce the risk of severe fires in the future; 

• Accelerated development and deployment of decision tools such as the Wildland 

Fire Decision Support System (WFDSS) to support risk-informed incident management; 

• Use of the Stratified Cost Index to inform resource deployment options; 

• Continuing to work on enhanced response and efficiency that comes from national shared resources and aviation resource cost management; 

• Execution of management controls—for the Forest Service, the establishment of 

the Inter-Deputy Group, the Chief Principle Representative, the Line Officer 

certification process for incident management, and the enhancement of fiscal 

monitoring and oversight; 

• Developing an Interagency Aviation Strategy intended to provide a national 

strategy for the future procurement and management of aviation resources; 

• After action reviews to apply lessons learned and best practices to policy and 

operations. 

The Departments have the best wildland firefighting organization in the world 

and together with our state, local, and tribal government partners work to maintain 

our operational excellence and continually improve the fire management program. 

ADDRESSING WILDLAND FIRE RISK TO COMMUNITIES AND THE ENVIRONMENT

This Administration made the restoration of healthy forests and grassland an environmental priority and has made great strides in accomplishing that goal. The Administration has focused its effort and dedicated its budget resources to improve 

hazardous fuels reduction on the nation’s landscape. The Departments have aggressively treated hazardous fuels to help reduce the risk of catastrophic fire to forests, 

and rangelands. In this effort, we put the National Fire Plan (NFP), the Healthy 

Forests Initiative (HFI), and the Healthy Forest Restoration Act tools to work, as 

well as other land management activities to keep progress going. However, dangerous fuels conditions still exist in many areas in the United States and the Departments will continue their emphasis on reducing hazardous fuels on priority 

lands. The FY 2009 President’s Budget provides $500 million in funding for hazardous fuels reduction, a level that is more than four times greater than in 2000, 

and over $927 million to the implementation of the President’s Healthy Forest Initiative. 

The Administration has been and remains committed to restoring healthy conditions to our forests and rangelands, and protecting communities from wildfire. The 

effectiveness of these treatments in reducing wildfire severity and protecting property has been demonstrated time and time again. Several fires from last season, the 

Angora Fire in South Lake Tahoe, fires around the San Bernardino National Forest, 

and the complex fires in Florida and in Georgia around the Okefenokee National 

Wildlife Refuge illustrate this well. Specific accomplishments in this area are: 

• From 2001 through the end of May 2008 the Forest Service and Department 

of the Interior land management agencies have treated over 26 million acres, 

an area larger than the State of Ohio, for fuels reduction on Federal lands, including about 21 million acres treated through hazardous fuels reduction programs and over 5 million acres of landscape restoration accomplished through 

other land management activities. 

• In 2007, despite a substantial national wildfire suppression workload, the Forest Service and DOI reduced fuels and improved ecosystem health on more than 

4.7 million acres of land nationally, of which over 3 million acres were treated 

through hazardous fuels reduction programs and 1.7 million acres of land restoration accomplished through other land management activities. Of the total, 

2.5 million acres of treatments were performed in the WUI. As of the end of 

May we have together already accomplished over 1.5 million acres of hazardous 

fuels reduction and landscape restoration treatments in FY 2008. 

• U.S. Forest Service and DOI, in cooperation with our non-Federal partners, continue to increase the community protection emphasis of the hazardous fuels program. Community Wildfire Protection Plans (CWPPs) assist localities to reduce 
18 

risk and set priorities. Over 1,500 CWPPs covering more than 4,700 communities have been completed nationally. 

• Collaborative Stewardship Contracting has expanded. These contracts facilitate 

projects that shift the focus of Federal forests and rangeland management towards a desired future resource condition of healthier forests and a means for 

agencies to contribute to the development of sustainable rural communities by 

adding local income and employment. To date, 428 Stewardship Contracts and 

agreements to work across almost 224,000 acres have been completed. 

• In 2007, to more adequately demonstrate the benefits of fuels reduction treatments on fire risk, the Departments continued to measure changes in the Condition Class of Federal lands and we are currently working on metrics for forest 

health changes that will help demonstrate the outcomes of projects that remove 

fuels. 

• Since the advent of the National Fire Plan in 2000, federal and non-governmental entities have collaborated operationally and strategically to improve fire 

prevention and suppression, reduce hazardous fuels, restore fire-adapted ecosystems, and promote community assistance. The 10-year Implementation Plan, 

with its performance measures and implementation tasks will guide the agencies to build on this success with our partners. 

CONCLUSION

This concludes our statement, we would be happy to answer any questions that 

you may have. 

The CHAIRMAN. Thank you very much. 

Let me start with a couple of questions. 

Mr. Cason, you referred to the fact that the inflation-adjusted 10- 

year average for wildfire—wildland fire suppression for the two departments is three times what it was in fiscal year 2001. One issue 

I just wanted to raise again—and I’ve raised it now for several 

years—is when you look at the number of acres burned by wildfires 

in the country, it’s been going up, and it’s been going up now for 

well over a decade, with very few exceptions. We would get a much 

better read on what resources we’re going to need to fight wildfires 

if we had a shorter period that we looked at for averaging and estimating costs. Instead of continuing to look at a 10-year period, look 

at an average for the last 5 years, for example. Now, that would 

mean you’d have to ask for more money. That would mean Congress would have to appropriate more money. But, it would give us 

a more realistic estimate of the resource we need for this important 

activity. Would you agree with that, or not? 

Mr. CASON. Senator, I guess, from my view, I don’t know the variability over time of the experience that we’ve had. I know it’s been 

growing; and in the last 5 years, it’s been more severe. So, if we 

used a 5-year period, and that was actually indicative of the future, 

that’s probably true. Whether or not we return to a lower experience rate, I don’t know whether that’s going to happen. My crystal 

ball isn’t good enough. So, I don’t really have a good basis to say, 

yes, we should do a 5-year average versus a 10-year average, or 

that we’ve just had unusual exposures here in the more recent 5 

years. Certainly, with the prevalence of pervasive drought across 

the country, and with fuel loads the way they are, it’s possible we’ll 

continue to have pretty significant fire seasons. But, I really don’t 

know whether we should go to 5 or 10—— 

The CHAIRMAN. We don’t have any estimates from any of the 

folks who crunch numbers within your Department, or anywhere in 

the Federal Government, that looks ahead 5 years and says, ‘‘This 

is what we expect by way of incidence of fires?’’ 
19 

Mr. CASON. Mr. Chairman, I haven’t seen any estimates that are 

like that. In my experience with other types of analysis, I think a 

lot of that gets driven by the assumptions that you use, as opposed 

to empirical data. So, I’m not aware that anybody’s done that calculation. 

Mr. REY. We probably have the capability of doing that, but I 

think we’re almost a year away from making the issue moot, because, once we get past 1999, we’re dealing with 10 fairly heavy 

fire years. I think the one—— 

The CHAIRMAN. But fairly heavy compared to the previous 10, 

but not, perhaps, compared to the next 10. 

Mr. REY. You know, the rate of increase over the last decade has 

not been that significant. 2000 wasn’t that much higher than 2007. 

The one problem with a 5-year average is that if you get a really 

rainy year, let’s say, then the—it’s going to drop significantly, and 

you have fewer years to average that unusual drop against. So, it 

could work against you in some respects if you get a cycle where 

you get a lot of rain. 2005, for instance— 

The CHAIRMAN. But, if it worked against you, the only downside 

is, you’d have gotten more money than you needed. 

Mr. REY. Or less, if that really good year, where the costs were 

very low, wasn’t—— 

The CHAIRMAN. Was averaged in. 

Mr. REY [continuing]. Averaged against a longer number of bad 

years. 

The CHAIRMAN. Let me ask one other line of questions here. I 

gather that there are agency figures for 2007 that indicate that 

about 38 percent of the requests that were received from fire managers for fire crews went unfulfilled, 33 percent of the requests for 

overhead support went unfulfilled, and 37 percent of the requests 

for helicopters went unfulfilled. 

Mr. REY. Those are fairly typical numbers that occur when we’re 

in preparedness level 5, when we have extreme fires burning in 

more—in three or more regions. You don’t build a fire organization 

to pay for assets the full season that reflect what you need during 

the worst few days of that season; you build it on something that’s 

closer to the average, and then you rely on the people at the Boise 

Interagency Fire Center to make priorities against the severity, location, and importance of the fires that are igniting. So, it is not 

uncommon to have that level of order unfillment, if that’s a word, 

during preparedness level 5. 

Now, conversely, when we had the large southern California 

siege in the fall of 2007, we were at preparedness level 1 and 2, 

because southern California was the only region that was burning, 

and we had no significant unfulfilled orders during that period of 

time. But, if you wanted to get down to a less-than-10-percent 

unfulfilled orders year-round on every day that we’re at preparedness level 5, two things would happen. One, you’d have to about 

double the amount of money you’re spending to hire people, planes, 

and engines; and, two, for any day of the fire season when you’re 

not at preparedness level 5, those people would sitting around 

twiddling their thumbs, because they wouldn’t have anything to do. 
20 

The CHAIRMAN. Let me just point out—my understanding is that 

when it says that 38 percent of fire managers’ requests went 

unfulfilled during the year—— 

Mr. REY. That’s not a true statement. 

The CHAIRMAN. That’s not your understanding? 

Mr. REY. No. It—they went fulfilled during the period of time 

that we were at preparedness level 5. 

The CHAIRMAN. So, that’s just for that period where you—— 

Mr. REY. That’s correct. 

The CHAIRMAN. Those are only a few days during the year. 

Mr. REY. Yes, a relatively few days. You don’t build, you know, 

to the most severe situation as you’re trying to figure out what the 

right level of preparedness investments are; otherwise, you’d have 

people sitting around a good part of the year. 

The CHAIRMAN. My time’s up. 

Senator Domenici. 

Senator DOMENICI. Thank you, Mr. Chairman. 

I’m pleased to note the presence of Senator Craig. I don’t hold 

myself out to be anywhere near as prepared on this subject as he 

is, having worked on it for a long time. 

But, as I leave the Senate, I want to leave a few of my thoughts 

on the record. Perhaps you might follow up and tell me if I should 

strike them because I’m nuts. 

The CHAIRMAN. I’ll cheer you. Go on. 

[Laughter.] 

Senator DOMENICI. But, look, I want to say to both of you, what 

I have to say has nothing to do with your management skills or you 

working hard—and you do—nor does it have anything to do with 

whether you have enough fire equipment, whether you have become a better manager of the tools and equipment and manpower 

to extinguish fires and protect property. All of those things are 

easy. You are much better prepared. You’ve just finished talking 

about it. All you have to do is go to a couple of fires, and you see 

what you’ve got. I mean, it’s considerably different, on the plus 

side, than it was 10 years ago. Certainly I don’t remember it when 

I was a young boy living in New Mexico, going to Hamus Mountain 

and the mountains around there, maybe five times a year, just to 

walk in the open spaces, because we were a family, believe it or 

not, of Italian immigrants that found a luxury of a mushroom that 

grew in the mountains of Tijeras, the Tijeras Mountains and others 

up there, grew just exactly like in northern Italy, where they came 

from. They had an Italian name. We never knew its English name, 

they were called ‘‘cocore,’’ and they were very big, white mushrooms that you could either eat fresh or dry, and they were a great 

luxury. So, I got to see what the forests looked like. I’m now 76. 

I got to see them when I was 12 and 13 and 14. 

I’ve got to tell you, I go up there and take a look, and I’m not 

interested in walking in those forests anymore, because they’re not 

the same forests they were when I was a kid. They are ugly. They 

are full of underbrush. They are full of trees. Instead of stately 

pine trees scattered that let you walk leisurely through the forests, 

pointing out to the little kids where the mushrooms are, you can’t 

even see now. 
21 

What I’m saying is, I have noticed, during my tenure as a Senator, that the forests look like nobody has bothered to try to manage them so that they would be accessible and usable and functional on a day-to-day basis, as they were some time ago. 

Now, as experts, you might have something to add to it, that 

they were better back yonder in some other respect. But, I’m just 

expressing what I said—what I saw. I said this one other time during this 36 years after a couple of visits, and I don’t see any 

change. In fact, it’s worse. 

The other thing I see that discourages me greatly is, when you 

have a fire, especially if it’s a fire where there were big trees and 

modest-sized trees, like the one up at Los Alamos, it burns down, 

and then you see all these trees that were burned down for blocks 

upon blocks, using a block as a description of time. The first year 

after the burn, you say, ‘‘Oh, they’re up, they still look that way.’’ 

The second year after the burns, ‘‘Oh, gee, they still look the same.’’ 

Third, fourth, fifth, and now you’re in the sixth year or seventh 

year, and nobody’s touched them, and nobody’s touched the forest. 

If you go up there and try to clean up or do something, it’s just 

anathema, so nothing’s done. You find infested forests, you see 

them, and they look just the same for 3, 4, 5 years, because nobody 

does anything about them; and if they do, they just leave it like 

it is. 

Now, to me, we can come here once or twice a year and talk 

about how many billions we are spending on forest-fire fighting, 

and I’m not very impressed, other than to say I guess, if we’re 

going to have fires, we’ve got convince the people that we’re going 

to have equipment and manpower to put them out. But, I wonder 

what’s wrong with the idea of managing the forests better so that 

you’re not spending so much money on putting our fires out and 

spending more on trying to manage the forests, or is there something about managing the forests, by way of cleanup and cutting 

down old, burned-out trees, and forest underbrush? Perhaps it’s not 

that you don’t want to do it; perhaps you can’t do it with current 

environmental rules. But I will stand on what I have said and ask 

you two experts, ‘‘Why is it so?’’ unless you want to say, ‘‘You’re 

wrong.’’ I think I’m right, but if I’m wrong, then we’re finished. 

But, if I’m right, why is it so? 

Mr. REY. I think what you observed is what our experts believe 

to be the case, that these stands, over 100 years of time of fire suppression, have grown much denser than they were historically, and 

that that density of foliage is providing the fuel that contributes to 

much more intense fires. 

Senator DOMENICI. You bet. 

Mr. REY. The problem is that you don’t cure a problem that’s 100 

years in the making in a year or 2 years or 3 years time. It’s going 

to take us a significant amount of time to get those stands cleared 

out. There are a lot of them that are cleared out now. Last year, 

we were able to put out a lot more fires, because they burned into 

thinned areas, than we did the year before that; and the year before that, we did more than 2005. But, that’s not going to reach all 

of those acres right at the same time. 

We are spending record-levels amount of money to do this work. 

I would say, on the question of thinning for fuels treatment work, 
22 

we have a pretty broad consensus nationally that that needs to be 

done. That’s not to say there still aren’t people suing us, trying to 

slow it down. They are, and they have. There are impediments that 

way. But, you know, I could give you lots of survey data to demonstrate why I think that national consensus exists, but let me just 

give you one sort of anecdotal story. 

After you all passed the Healthy Forest Restoration Act, spring 

of 2004, I was sitting in my office at 7 o’clock one night, and Dana 

Perino, who’s now the White House press secretary, was then 

CEQ’s press secretary, called me, said, ‘‘You won’t believe what I 

just saw on TV.’’ 

I said, ‘‘Well, I don’t have the TV on, so you’ll have to tell me.’’ 

She said, ‘‘I was waiting to see how the networks handled a story 

we were working on today, and channel surfing, and the clicker hit 

the game show ‘Jeopardy.’ I was going to click past it, but, before 

I could click past it, Alex Trebek, the ‘Jeopardy’ host, said ’The 

final Jeopardy answer is a November 2003 Federal Government report said this natural disaster could have been avoided by better 

trimming of trees.’’’ 

She said, ‘‘My God, I couldn’t believe it. We’ve become a ‘Jeopardy’ question.’’ 

So, she said, ‘‘Then I couldn’t turn it off. I had to wait and see 

if any of the three contestants would get the right answer.’’ 

She—‘‘You won’t believe what happened next.’’ 

I said, ‘‘What happened next?’’ 

She said, ‘‘They turned over their boards,’’ because you have to 

scrawl the question for final jeopardy, and all three of the contestants had some variation of the phrase, ‘‘What are catastrophic 

wildfires?’’ 

Now, unfortunately for those three contestants, the correct question was, ‘‘What was the Northeast power blackout of August 

2003,’’ because, as you remember, a tree fell across the high tension 

line and started a chain reaction that blacked out the Northeast. 

But, you know, we cost those poor souls thousands of dollars in 

prize winnings, but we had their attention. I think there is a consensus that is moving us forward. 

All I can offer you, though, is, it’s going to be a problem that’s 

going to take a decade to fix, not a year. We’re about 5 years into 

that decade. 

Senator DOMENICI. Thank you very much. 

The CHAIRMAN. Senator Salazar. 

Senator SALAZAR. Thank you, Chairman Bingaman. Thank you 

very much, Senator Domenici. 

Under Secretary Rey, the question that you and I have had an 

ongoing dialog here for a very long time has to do with bark beetles 

in Colorado, and now a disease, really, that has spread to many 

other places, wherever we have our national forests. I was wondering if you could spend a few minutes just describing to us what 

the bark beetle problem is like as you forecast into this year, and 

how the bark beetle issue might contribute to the forest fire danger 

that we’re facing. 

Mr. REY. In Colorado, we’re seeing almost pandemic levels of infestation in lodgepole pine. That actually is not unnatural, as opposed to the situation we were just describing in Ponderosa pine, 
23 

which are lower-elevation systems. Lodgepole pines, which are at 

the highest elevations, typically cycle, you know, in a 100-year 

cycle, and it’s usually the bark beetle that knocks them back, and 

then the trees grow back after a fire, and that’s why you’ve got, in 

place at 10,000 feet or thereabouts, above, a fairly homogeneousage class of forest. You had it in Colorado, you had it in Yellowstone when Yellowstone burned up in 1988. 

The difference between when this cycled the last time, about 100 

or so years ago, and now is, we’ve built a lot of infrastructure at 

that elevation in your State. So, our primary objective is going to 

be to treat the areas around communities and around homes so 

that we can protect that infrastructure. 

It is not likely that we’re going to stop what is, in this case, a 

more natural event from occurring, as unpleasant as it is for people 

who live in that environment now to countenance the fact that 

those trees are going to cycle through on a—what has been, you 

know, historically, about a natural 100-year cycle. We’re going to 

ramp—— 

Senator SALAZAR. Is there—— 

Mr. REY [continuing]. Up our—— 

Senator SALAZAR. Is there more, Under Secretary Rey, that you 

think we might be doing for people in my State and for me when 

I drive up I–70, up into Keystone area, Vail area, and you see now, 

I think, what is over 1 and a half million, close to 2 million, acres 

of acreage that has now been infested by the bark beetle? It’s going 

to cause huge economic consequences to those communities, but 

also creates an unprecedented fire danger to those communities. 

In my view, it seems like everybody is throwing up their hands 

and saying, ‘‘Hey, it’s just there, and we have to live through it. 

There’s not much we can do.’’ Yet, it seems to me that if we were 

able to implement the stewardship contract concepts that we’ve 

talked about in the past, and able to do the hazardous fuels mitigation and treatment programs that we’ve talked about in the past, 

then we might be able to at least do something about it. 

I guess my question to you is, What more do you think that we 

ought to be doing to deal with that reality? 

Mr. REY. I think the—some of the ideas that we’ve talked about 

in the past—in terms of stronger partnership authorities to work 

with tribes and State and local governments, ideas that the Administration sent forward in the Healthy Forest Partnership Act in the 

last Congress, some of the ideas that Senator Bingaman, Domenici, 

and Craig have been working with in the proposal that they’ve gotten out, some changes to the stewardship contracting authority 

that don’t require us to set aside so that the government is indemnified from liability, if we fall behind in NEPA development so that 

we don’t have to, basically, do all the work for a 10-year contract 

before we let the contract—those will all help. 

Nobody at the Forest Service is throwing up their hands. What 

we’re doing is trying to look across the landscape in Colorado and 

make some fairly clear priorities on what we need to treat first in 

order to protect homes and communities, and then work our way 

out from there to see what we can treat once we get that initial 

priority done. We could use some—— 

Senator SALAZAR. Let me—— 
24 

Mr. REY [continuing]. Additional tools, and we’ve talked about 

them, and you’re proposed some of them. It would be great if we 

could work with your staffs to produce a proposal yet this year. 

Senator SALAZAR. Let me just say to you, Under Secretary Rey 

and to Chairman Bingaman, that I hope it is something that we 

can do. We have legislation from the Colorado delegation. I know 

Senator Bingaman does, as well. Maybe this is one of those 

issues—it certainly is not a Republican, Democratic, or political 

issue, this is just the reality of a huge infestation that we have to 

deal with on the ground. 

One last question for you, and that is, Region 2 and funding for 

Region 2 and the Forest Service; we never get our fair share. I 

think, again, the Administration’s proposal showed a $25-million 

cut in Region 2 allocations over what we had the year before in the 

proposed budget from the President. We’re going to fight that back 

and hope that we’re able to get the right allocation of money given 

to the Region 2 area, because, as we look at the fire dangers that 

are being faced in region in that 4-State area, it’s going to be very 

significant in the summer months ahead. 

Mr. REY. We’ll work with you on that. Our request for Region 2 

is in excess of our last request last year. You all did a very fine 

job at securing additional funding for Region 2 during the budget 

cycle, and we’ll work with you during this cycle, as well. 

Senator SALAZAR. Thank you. 

The CHAIRMAN. Senator Craig. 

Senator CRAIG. Mr. Chairman, thank you very much. 

Senator Salazar, with the help of the U.S. Forest Service and 

their scientists and a whole other group of folks, we prepared a set 

of amendments for the climate change bill that obviously is dead 

on arrival, so it won’t happen. But, what you’re asking, and what 

I think we can do, and will do in the future, is bulletproof, in part, 

categorical exclusions so we can do some of these things. Because, 

you know, the great untold story of my State and your State, when 

we took away the authority of the Forest Service and gave it to the 

courts to manage our land, was that what is green in a climax environment turns brown and dies. If somebody’s not there to take 

it away and create a new dynamic in the forest, Mother Nature 

comes along and burns it. That’s what’s going to happen in your 

country if we don’t get categorical exclusions so you can go in and 

clean up those watersheds and protect them and replant them and 

assist Mother Nature in the cycle. We’re just sitting by watching 

right now, and fending her off a little bit along the way as she 

comes close to a human structure, and we’re spending hundreds, 

millions, if not billions of dollars to do it. 

So, now the Forest Service, and BLM, Interior are rushing to 

help citizens fireproof their, I call, mega-mansions. When we fireproof them, they stand. We’ve got phenomenal record out there, 

and we—I’ve watched it across Idaho’s landscape this year, of these 

large homes that were effectively dealt with. I’m one that would 

say we ought to put a clause in insurance—fire insurance contracts 

that says your premium is tripled if you don’t go out and cut a few 

trees around your house and prescribe your house management to 

the terms of good fireproofing. Maybe we’ll get there. Private sector 

probably will. 
25 

Senator SALAZAR. Will the Senator yield for a question? 

Senator CRAIG. I’d be happy to. 

Senator SALAZAR. Senator Craig, I do agree with you that there’s 

a lot more that we ought to be doing in our forest lands, including 

some changes in the law that would allow us to address these 

kinds of infestations and these problems. There is also a problem 

beyond legislation, I think, frankly, that has to do with resources, 

because I know—— 

Senator CRAIG. Sure. 

Senator SALAZAR [continuing]. Forest Service has approved, in 

my State, hundreds of thousands of acres for hazardous fuels reduction. The money is not there—— 

Senator CRAIG. Yes. 

Senator SALAZAR [continuing]. Frankly, for us to go and get the 

job done. I think it is both a resource issue, as well as statutory 

issue that we have to deal with. 

Senator CRAIG. I don’t disagree with that at all. 

Both to Mark Rey and to Jim Cason, thank you for being with 

us today. 

I’d ask unanimous consent, Mr. Chairman, that my full statement be a part of the record. 

I would agree with you, the dynamics of reality are changing, 

and we may be 5 years into a 10-year cycle. But, there’s a reality 

out there that nobody wants to talk about. It’s the dirty little secret 

of large fires today at a time when everybody’s hyper over climate 

change. That acreage—that 9.4 that burned last year, 2 million of 

it in my State—was the equivalent of taking 12 million automobiles off the road as it relates to carbon into the atmosphere. 

Oh, my goodness. But, there isn’t an environmentalist out there 

wringing their hands about that today in the great debate over climate change. Now, if you’d take 12 million cars off the road, that 

is nearly equal to the transportation fleet in the State of California. 

We know what it would do the airsheds of California, let alone 

emissions into the environment, but that’s where we are today. 

But, nobody wants to talk about it. 

You’ve got to talk about it. It’s got to be real. It’s got to be practical. We need our forest to be young, vital, healthy, sequestering 

carbon in a way that they historically did, and will again if we 

allow that to happen. 

Mark, let me thank you for working with us. I guess we’ve 

worked with both sides as related to the 401-series issue. You 

know, we were getting to a point, Mr. Chairman, where we were 

going to say that this great fire team out there, that both Jim and 

Mark talk about, is the best in the country. We were always made 

to say they all had to have a master’s degree to fight fire. I mean, 

oh, stupid us for playing that game. Do they need advanced knowledge and talent? You bet they do. Are our fires different? Yes, they 

are. Do we need to not only study the past, but look at the future 

as it relates to putting humans inside one of those fire scenarios? 

You bet we do. But, they don’t need master’s degrees; they need experience, or they need to be with experienced people. I hope we’ve 

got that settled or we’ve resolved it for a year, and that we don’t 

get back to the business of saying, ‘‘Now, you’ve got to go get a 

master’s degree in firefighting before you can fight fires for the 
26 

BLM or Department of the Interior or the U.S. Forest Service.’’ So, 

thank you for working with us on that. 

Aviation fleet, Mark, you’ve talked about that. Air tankers. No 

DC–10s? Can’t we borrow Arnold’s big airplane? 

Mr. REY. We have an RFP out for supertankers, and we expect 

that we’ll get a bid from the company that’s—now has two DC–10s, 

and we expect a bid from a competing company, in Senator Wyden’s State, that’s using a 747. What—— 

Senator CRAIG. Are they effective? 

Mr. REY. They’re effective under certain scenarios. They are not 

as maneuverable into tight canyons as our current tanker fleet is. 

But, on open range fires they’ll drop about—in the case of the DC– 

10, about 10,000 gallons of water or retardant, as compared to a 

P–3 Orion, which will drop about 3,000. A 747 can actually drop 

about 20,000 gallons of water or retardant. So, on certain fire scenarios, they’re—they probably are going to be effective. They also 

have a wider range—service range than a P–3 or a P–2V or a C– 

130, because they’re faster, they’ll get to a site faster. 

What we’re going to evaluate in the responses we get to the 

RFPs are what—not only what their effectiveness is, but what their 

cost efficiency is. Is it competitive on a dollar-per-gallon basis of delivered retardant or water, or are their rates so high that that’s 

probably not an attractive asset for the government to use? 

Senator CRAIG. OK. 

Mr. Chairman, I have taken plenty of time; I’ll come back for a 

brief second round if it’s available. Thank you. 

The CHAIRMAN. OK. Senator Wyden. 

Senator WYDEN. Mr. Chairman, thank you. Thank you, Mr. 

Chairman, for holding this important hearing. 

I also want to thank you for inviting Deborah Miley, who’s the 

executive director of the National Wildfire Suppression Association. 

She’s from Lyons, Oregon, and we’re very glad that you would have 

Ms. Miley here. 

I’m going to get into questions relating to wildfires in just a second, but, Secretary Rey, I think you know it wouldn’t be a hearing 

on forestry unless we addressed the issue that is on the mind of 

all the people in rural Oregon and the rural West right now, and 

that’s the county payments legislation. It is emergency legislation 

for folks that I represent; and along with a number of colleagues 

up here on the panel, we were collectively able to get into emergency supplemental appropriation a 1-year extension of this legislation. We were pleased about it, and the House of Representatives 

is now working on their legislation. Suffice it to say, many in the 

House want to know whether the President will state that he will 

not veto the entire supplemental appropriations bill if it includes 

the county payments legislation, in that this is very much a factor 

in the House’s thinking now about whether it would be included. 

So, could you give us some insight into the President’s thinking 

on this? Because I know you’ve been involved in various discussions back and forth, and I want to be sensitive to internal communications within the Administration. But, at the same time, this is 

hugely important in the rural West, and the fact is, some sense 

that the Administration would not veto the emergency supplemental because it includes the county payments funding could ac-
27 

tually be the key to getting it into the House and getting that help 

out to the rural West. 

Mr. REY. All right, then. You know, we have not issued a statement of policy from the Administration on the supplemental yet. 

So, what I would tell you would be largely speculative. But, let me 

just say two things. 

One, we remain committed to reauthorizing the legislation, and 

have continued to work, most recently on the House side, to see if 

mutually acceptable offsets could be found. I know a lot of people 

in Oregon and elsewhere are beginning to say, ‘‘Well, are they really committed to it?’’ Well, we’ve put it in our last three budget proposals, we’ve changed the offsets each time to try to respond to objections to the offsets, and we’ve continued to work with you for 

that purpose in both the House and the Senate. So, that’s not, by 

my way of thinking, passive activity; it’s active support for the 

proposition that the Administration first articulated in 2005, a year 

before the bill—the 2000 bill expired, that we believed an additional extension was justified, with mutually agreeable offsets. 

As to what’s sitting in the supplemental now, you know, I’m not 

here today to be able to give you a statement of Administration policy. On the other hand, I can reflect on the history last year, and 

we signed a bill with a 1-year extension. 

Senator WYDEN. OK. Tell your colleagues at the White House 

that if you all could amplify on that, and do it very quickly, I think 

it might well be what puts it over the top in the House, because 

I know they’re trying to get a sense of what the Administration will 

do. I appreciate what you’ve said today, and I hope you’ll be able 

to go further in the hours ahead. 

One question for you on this round, Mr. Cason, if I might. Fuel 

prices are just going through the stratosphere, and there have been 

a number of articles and others written about how this is going to 

impact firefighting. My sense, it’s going to hurt the effort this summer unless action is taken and contracts for firefighting airplanes 

and helicopters are negotiated annually. I’d like to know what you 

all are planning to do to address the rising price of fuel so it 

doesn’t jeopardize firefighting abilities, particularly those airplane 

and helicopter contracts, this summer. 

Mr. CASON. Senator, I think Mark might want to follow my comments, since he does more on the aviation stuff. But, it’s my understanding, on key contracts that involve aviation resources, that we 

have escalators built into most of those contracts that will accommodate significant rises in fuel prices. 

Early in the fire season, it’s not a material issue, from the standpoint that we still have significant reserves left to fight fires because we’re still early in the fire season. At the end of the fire season, if it’s a really busy fire season like the last two or three have 

been, we may end up in a situation that we go through what’s become a fairly typical process of borrowing additional money to complete the fire season and then look for some mechanism to adjust. 

So, it may have an impact at the end of the season for us. 

Senator WYDEN. My time is expired, Mr. Chairman. I get the 

sense that it is hurting firefighting efforts right now. I will put in 

the record a recent article from the Wall Street Journal that talks 

about how a number of the country’s rural fire departments are 
28 

now cutting back as a result of increased fuel costs. So, I would 

hope that you’d go back and take a look at what’s happening now, 

and not just wait until the end of the firefighting season. 

With the unanimous consent, Mr. Chairman, I’d ask that this 

Wall Street Journal article that documents how local firefighting 

departments are already scrapping their plans locally to have 

maintenance programs and trying to use volunteers, as a result of 

increasing fuel costs, are being hurt. 

The CHAIRMAN. All right, we’ll include that. 

[The information referred to follows:] 

THE WALL STREET JOURNAL 

U.S. NEWS 

FIGHTING FIRES WITH FRUGALITY

DEPARTMENTS SEEK CUTS TO BALANCE RISING FUEL COSTS

By A.J. Miranda 

Many of the nation’s fire departments are cutting back on training and maintenance to balance out increasing fuel costs, especially in rural areas where fire trucks 

must travel long distances to homes or accidents. 

Such trade-offs are among those made by locargovernments as they try to control 

costs and adhere to taxpayer-funded budgets while operating fleets of fuel-guzzling 

buses, police cars, fire trucks and ambulances, many of which run on diesel fuel. 

Growing global demand has driven the price of diesel up 67% since the first week 

of June 2007, 2 outpacing the rise in gasoline prices. A year ago, diesel sold for 40 

cents a gallon less than gaso line; now, diesel costs 70 cents more a gallon, according 

to the federal Department of Energy. 

Diesel, which yields about 30% more miles a gallon than gasoline, is still a cheaper option overall. But local governments that weren’t counting on such a steep jump 

in their fuel bill have little budget flexibility to adapt. Trimming costs is especially 

difficult when cutbacks could compromise public safety. 

‘‘When people dial 9-1-1, they expect a response in a reasonable amount of time, 

and we have a need to deliver on that response,’’ said Lee Feldman, city manager 

of Palm Bay, Fla. 

In Oregon’s Marion County, where diesel prices are inching toward $5 a gallon, 

rural fire departments are budgeting an average 25% increase in fuel spending for 

the new fiscal year beginning July 1. 

Fire trucks get, on average, about five miles a gallon. But no extra money is coming from the county. The fire and rescue department has to make up the money by 

cutting costs in other areas. 

The fire department in rural Jefferson, Ore., scrapped plans to hire a station 

maintenance worker this year, instead spreading the work among its 50 volunteer 

firefighters. It no longer dispatches a fire engine automatically to accidents on the 

nearby Interstate 5 highway—a round trip of about 15 miles, said chief Don 

Bemrose. Instead, a duty officer is first dispatched to survey the accident and see 

what is needed. 

Many fire departments are now sending medics and other staff in pickup trucks 

or SUVs to answer calls for medical assistance. 

In rural Montezuma, Ga., a two-hour drive from Atlanta, the fire department is 

conserving fuel by staging smaller fires for advanced firefighter training. The smaller fires can be extinguished with water from hydrants instead of the two or three 

fire engines that used to be needed, said chief David Trussell. 

There is only so much a fire department can do without cutting essential life and 

property-saving services. Ultimately, Mr. Trussell said, a fire department’s duties 

are based largely around driving. 

‘‘There’s just no way to say ‘Well, we can’t afford to respond to,your house today— 

we can’t afford to buy a tank of gas,’’ he said. 

In California’s oil-and agriculture-driven Central Valley, the cost of diesel has 

pushed the Bakersfield fire department $140,000 over its $1 million fuel and maintenance budget, said chief Ron Fraze. The department has deferred some maintenance and renovation work at stations, and cut overtime hours to compensate. ‘‘You 

end up doing more with less,’’ Mr. Fraze said. 
29 

Rather than risk further cutbacks on services or supplies, the tiny Arkansas town 

of Lonsdale, population 118, launched a fund-raising campaign to pay its fuel bill. 

Lonsdale Volunteer Fire Department, which protects roughly 3,000 rural residents 

in a 40-square-mile fire district, has seen its fuel bill rise to triple the $300 a month 

it has budgeted. 

Raising the optional $50 annual fee that funds the department wasn’t an option, 

since many of the area’s residents are retired seniors living on a fixed income, said 

Steven Snellback, a firefighter and Lonsdale’s volunteer mayor. Instead, the department raised more than $10,000 with a June 7 spaghetti dinner. 

Every little bit helps; the Ponderosa Volunteer Fire Department, 20 miles north 

of Houston, traditionally never let a fire engine’s fuel tank dip below three-quarters, 

to ensure the truck didn’t run out of fuel on an emergency call. Now the standard 

is half a tank. That makes for fewer trips to the filling station, said Fred Windisch, 

Ponderosa’s chief. 

The CHAIRMAN. Senator Barrasso, did you have questions of this 

first panel? 

Senator BARRASSO. Yes, I did, Mr. Chairman. 

The CHAIRMAN. Go right ahead. 

Senator BARRASSO. Thank you very much, Mr. Chairman. 

Welcome, to members of the panel. 

I know, Mr. Rey, for sure, you know what we’re dealing with in 

Wyoming, in terms of pine-beetle outbreaks across the State, and 

the impacts. I heard Senator Salazar’s discussion with you a little 

earlier. You know, in Wyoming we believe we need more on-theground solutions. We need to protect our firefighters and our ecosystem by preventing wildfires from burning out of control. I’m just 

very concerned about the amount of flammable material that is out 

there as a result of what’s happening with the bark beetle. 

You know, I’ve introduced Good Neighbor legislation so the State 

and the Forest Service can work together on forest health projects. 

I introduced the bill back in December, and I’m hoping that we can 

get some consideration of the bill in this Congress. 

If I could visit with you about the beetle-kill timber and what effect that has on fire patterns, in terms of the serious nature of the 

fire and the likelihood of fire to spread faster. Is it more likely, 

with that amount beetle-kill in the area, that the fires will grow 

in size quicker, make it more expensive and more difficult? 

Mr. REY. Yes, that’s generally true. Before you arrived, Senator 

Salazar and I were talking about the higher-elevation lodgepole 

pine systems that naturally cycle on about a 100-year cycle. The 

beetle is the equivalent of the natural force that fire plays at a 

lower elevation. So, you know, the reason you have homogeneousage-class stand is that about 100 years ago the beetle went through 

there and wiped them out then, and they burned up, and then 

they’ve regenerated to another homogeneous-age stand. The difference between now and 100 years ago is, we’ve built a lot of infrastructure in those areas, that we’re going to have to protect. But, 

the amount of beetle-kill will inevitably lead to a more intense fire. 

Senator BARRASSO. So, for people who are in Wyoming and want 

to see if we can—what we can do to help mitigate the risk, what 

things would you suggest? Are there different effective management options that we should be looking at? 

Mr. REY. One thing that we haven’t done yet, that we are doing 

in Colorado, is contracting with the State forestry agency, where 

they’re doing treatments on non-Federal lands to treat Federal— 

adjacent Federal lands, as well, and we reimburse them for the 
30 

cost of that treatment. But, I think the strategy in both Colorado 

and now, as the epidemic spreads up north into Wyoming, will be 

to look at where we have homes in communities, do the treatments 

necessary to protect those first, to create defensible space around 

them, and then work our way further out into the forests, to protect watersheds or other sensitive areas that we’d just as soon not 

see burn up. But, you know, I think one of the cautions is, we’re 

not going to treat 100 percent of the acres, given the size of the 

epidemic. It’s going to be a case where we prioritize the treatments 

to protect the infrastructure that’s been installed in these areas. 

Senator BARRASSO. Do you see a role for salvage sales in these 

areas, as well? 

Mr. REY. That’s unmet potential that has some possibilities. 

Lodgepole typically lasts longer after it’s been killed by beetles 

than Ponderosa pine does, and the logs that could be produced by 

salvage sales could go into the home log market. But, there what 

we’re going to have to do is attract some additional manufacturing 

infrastructure to use the amount of material we have. 

Then, in addition, we’re going to have to reach a better social 

consensus on salvage logging. Before you arrived, I opined that I 

thought we had reached considerable consensus nationally on the 

importance of fuels reduction in thinning pre-fire. I, unfortunately, 

am sorry to report that I don’t think that same level of consensus 

has been reached on salvage harvests after a fire. There is still a 

very vibrant public and, to some extent, scientific debate underway 

about whether it’s a good idea to salvage or whether we ought to 

just let nature take its course. We are, today, getting challenged 

and appealed far more frequently on salvage sales than we are on 

thinning projects, on a proportional basis. 

Senator BARRASSO. Thank you. 

Thank you, Mr. Chairman. 

The CHAIRMAN. Senator Craig, did you have additional questions 

of this panel? 

Senator CRAIG. One brief one, Mr. Chairman. 

First of all, to comment to the Senator from Wyoming. There’s 

large groups out there that have invested large sums of money in 

the word ‘‘salvage.’’ It’s so effectively demonized that we have to 

prove you can go back in and do it right, and then maybe we’ll get 

back to that. There’s some value there. 

Under title 2 and 3 of the Secure Rural Schools and Self-Determination Act—and Ron already has had that dialog with you as to 

the Administration’s position—but, under that, the Resource Advisory Committees are allowed to recommend projects, that we know 

of, and they’ve done so very effectively over the years in the lifetime of that bill. Hazardous fuel reductions are part of one of the 

types of projects recommended under this authority. If it’s reauthorized—and we stand to believe that maybe we can go beyond 

just the 1 year, because we’re into the tax extension package, and 

there it’s reauthorized, and we might—might be able to carry that 

through, this year. If that happens and it is reauthorized, can the 

September 30 deadline for allocating the funds or projects be extended? Will the Office of Management and Budget have funds left 

over if there is not an extension granted, to give the RACs time to 

review and authorize good projects on our forests? 
31 

Mr. REY. If the act is extended, either for 1 year or multiple 

years, I believe we’ll have the administrative flexibility to give the 

Resource Advisory Committees additional time to do their project 

selection. 

Senator CRAIG. OK. Thank you all. 

Let me ask unanimous consent that my full statement be a part 

of the record, Mr. Chairman. 

The CHAIRMAN. We’ll be glad to put that—— 

Senator CRAIG. We have other questions we’ll let them address 

for the record. 

Thank you. 

The CHAIRMAN. Very good. 

Thank you both very much. 

Why don’t we move to our second panel. On the second panel is 

Ron Thatcher, who is the president of the Forest Service Council 

with the National Federation of Federal Employees of the International Association of Machinists and Aerospace Workers, from 

Libby, Montana; Casey Judd, who is the business manager of the 

Federal Wildland Fire Service Association, in Inkom, Idaho; and 

Deborah Miley, who is the executive director for the National Wildfire Suppression Association, in Lyons, Oregon. 

[Pause.] 

The CHAIRMAN. OK, thank you all for being here. Why don’t we 

take about 5 minutes for each of you to summarize the main points 

you think we need to understand from your testimony. We’ll include your full testimony in the record as if presented orally. 

So, go right ahead. Mr. Thatcher, why don’t we start with you. 

STATEMENT OF RON THATCHER, PRESIDENT, FOREST SERVICE COUNCIL, NATIONAL FEDERATION OF FEDERAL EMPLOYEES, INTERNATIONAL ASSOCIATION OF MACHINISTS 

AND AEROSPACE WORKERS, LIBBY, MT 

Mr. THATCHER. Thank you, Chairman Bingaman and distinguished member, Senator Craig, for the opportunity to submit this 

testimony. 

My name is Ron Thatcher. I serve as the president of the National Federation of Federal Employees, Forest Service Council. In 

this capacity, I’m honored to represent approximately 20,000 dedicated Forest Service employees. Among those employees, many are 

Federal firefighters. 

I’ll briefly address current staffing levels and a policy problem 

that is contributing to rising attrition rates, which could and will 

have an effect on our preparedness for the FY–08 fire season. 

Regarding retention and staffing levels, the specifics of my testimony on this topic deal with the situation we find ourselves in, in 

California, where much of the national firefighting capacity resides. 

However, we also believe that these problems are not confined to 

just California. 

Focusing on California, on May 6, 2008, Under Secretary Rey 

provided Senator Diane Feinstein with a summary table showing 

that only 363 of the 4,432 positions planned for the 2008 fire season were vacant. A breakout by grade level was apparently not provided. This breakout shows that the most striking shortfall is at 

the GS–06 level, where 208 of the 532 positions, or 39 percent of 
32 

the work force at that grade level, were vacant. This data also revealed a vacancy rate of 14 percent, or 81 positions, at the GS–07 

level. 

Staffing levels tell some, but not all, of the story. Staffing levels 

can be maintained, even with excessive attrition, by hiring large 

numbers of entry-level employees. In such a case, there is a substantial pressure to rush these employees into higher-graded positions to meet the staffing needs. This results in a large number of 

minimally qualified employees in module positions which can also 

decrease our preparedness and our safety. 

This pipeline issue of GS–06s and GS–07s is extremely important. With higher-level employees retiring or resigning, there is an 

increased need for experienced firefighters to continue up this ladder. Experienced crew members become experienced squad bosses, 

who become experienced operational section chiefs, who become experienced incident commanders. This takes a significant amount of 

time, and continually filling the lower ranks with new recruits isn’t 

going to accomplish this task. Without experience throughout the 

organization, effective firefighting and safety is going to be compromised. 

There are a number of factors affecting these attrition rates. In 

the brief time I have remaining, I’d like to focus on a current problem that increases our attrition and presents a clear and present 

danger to safety on our fire lines. 

Fortunately, this problem can be easily resolved. Experienced 

leadership is crucial to our fire organization. Wildland firefighting 

is physically demanding and dangerous. This is unavoidable. A recent OPM policy change is pushing our most experienced field generals in the war on fire out of positions of leadership. In the aftermath of South Canyon, in 1994, in which 14 brave firefighters met 

their deaths, an initiative began to ‘‘professionalize’’ the fire management positions of the U.S.—of the GS—U.S. Forest Service and 

Department of Interior. The agencies made a decision to utilize the 

GS 401 series for the professionalization of our firefighters, which 

requires a degree in biological science. 

The development of a consistent standard, the Interagency Fire 

Program Management standard, or IFPM, was completed in 2004. 

This standard was put in place to improve safety and effectiveness 

on the fire line. In-house fire incident-management courses were 

then credible. These courses were specifically tailored by the 

world’s experts in incident command and wildfire suppression, to 

meet the unique needs of our wildland firefighting work force. 

Fire leaders come up through the ranks and are trained inhouse. Many lack college degrees. Under this gutted standard, a 

college degree or equivalent is now required. Hundreds are now unqualified for the jobs they’ve been successfully performing for years. 

Many have specialized qualifications and have had 20 years of experience to get to that level. These are our field generals. They provide the critical leadership. Too many will be forced out by this unnecessary standard. 

In closing, let me ask two simple questions that cut to the heart 

of this matter. Who would you want leading your son or your 

daughter into harm’s way? Who would you want in charge of the 

operation to save your house from an advancing wildfire? I know 
33 

who I’d want. I’d want the person best qualified, in terms of fire 

experience and competency. Reinstating the standard of our inhouse training program is the best way to ensure that’s exactly 

who we’d get. If OPM will not do so administratively, we urge Congress to do so legislatively. 

Thank you, again, for this opportunity. 

[The prepared statement of Mr. Thatcher follows:] 

PREPARED STATEMENT OF RON THATCHER, PRESIDENT, FOREST SERVICE COUNCIL, NATIONAL FEDERATION OF FEDERAL EMPLOYEES, INTERNATIONAL ASSOCIATION OF

MACHINISTS AND AEROSPACE WORKERS, LIBBY, MT 

Thank you, Chairman Bingaman, Ranking Member Domenici, and distinguished 

Committee members, for the opportunity to submit the following testimony. 

My name is Ron Thatcher. I serve as the President of the National Federation 

of Federal Employees’ Forest Service Council. In this capacity, I am honored to represent approximately 20,000 dedicated public servants committed to the professional 

and ethical management of the 192-million-acre National Forest System. I will briefly address current staffing levels and discuss in some detail an easily-remedied policy problem that is contributing to rising attrition rates. 

RETENTION AND STAFFING LEVELS

The specifics of my testimony on this topic will deal with the situation in California. However, this is not just a regional issue. First, much of the national firefighting capacity resides in Region 5. A shortfall in California resources is a shortfall in national resources as well. Second, we believe that problems in staffing upper 

level Incident Command and General Staff positions are not confined to California. 

Increasingly, we are forced to rely on retirees and state personnel to fill these positions on Incident Teams. California may be the most striking example, but we will 

soon have to pay attention to the erosion of our capability on a national scale. 

Obviously, we do not have access to nearly as much information or staff resources 

as do Chief Kimbell or Undersecretary Rey. However, the information we have been 

able to obtain raises troubling questions about fire suppression preparedness now 

and in the future. I will not be able to make sweeping conclusions with the bits and 

pieces of data we have available. I do hope to raise some issues that will suggest 

specific lines of inquiry for the Committee to consider pursuing. 

On May 6, 2008, Undersecretary Rey provided the Honorable Dianne Feinstein 

with a summary table showing that only 363 of the 4,432 positions planned for the 

2008 fire season were vacant. A more complete picture of staffing levels is provided 

by the breakout by grade level (see Appendix 1), a part of the complete table which 

was apparently not provided. The most striking shortfall is at the GS-06 level, 

where 208 of 532 positions (39%) were vacant. How does this shortfall affect preparedness? 

The great majority of GS-06 firefighters staff Engines as Assistant Fire Engine 

Operators (AFEOs). It appears this shortfall is not likely to be corrected in the short 

term: during the March 2008 hiring round, the number of vacancies in this critical 

position actually increased in spite of nearly two dozen hires. 

At full staffing level, a Type 3 Engine is staffed with seven employees at defined 

positions. Rotational staffing provides 7-day coverage. Without this full complement, 

the Engine must be downgraded to a 5-day Engine. Is the fact that roughly half 

of the Forest Service’s Engines are 5-day Engines a result of the 39% firefighter vacancy rate at the GS-06 level? This would seem to be a likely explanation. 

Understaffing can lead to over-reaching, with negative effects on safety. This is 

illustrated by a March 27, 2008 letter from Regional Forester Randy Moore to Region 5 personnel, in which it is stated that ‘‘supervisors may be informally assigning 

employees to positions above their current grade level.’’ Obviously, it is a safety 

issue when employees are placed in positions for which they do not meet qualifications. The Regional Forester took steps to prevent this practice and advised field 

supervisors that ‘‘[i]f there are vacant positions and no qualified individuals to fill 

them, other options need to be considered. For example, engine modules may need 

to provide a 5-day work week, covering with a GS-07 and GS-08 in lieu of the GS06.’’ 

The complete data also reveal a vacancy rate of 14% (81 positions) at the GS-07 

level. Although less severe than the 39% shortfall in GS-06 personnel, this is still 

a significant figure that will be difficult to bring to a full staffing level this fire season. During the March hiring round, a net of only 14 GS-07 Fire Engine Operators 
34 

(FEO) positions were filled. Further, GS-07 FEO positions are typically filled from 

the pool of GS-06 AFEO employees, so any reduction in the vacancy rate of the 

former would increase the vacancy rate of the latter. 

Staffing levels tell some, but not all, of the story. Staffing levels can be maintained even with excessive attrition by hiring large numbers of entry-level employees. In such a case, there is substantial pressure to rush these employees into higher-graded positions to meet the staffing needs of the module. This results in a large 

number of minimally qualified employees in module positions, which can also decrease preparedness. 

For example, an Engine is not available for dispatch outside its area unless one 

crew member is red card qualified as an Engine Boss, ENGB. A GS-08 Supervisory 

Fire Engine Operator (SFEO) must be a certified ENGB to occupy their position. 

A fully qualified GS-07 FEO is also ENGB-certified, in which case s/he may rotate 

with the SFEO and the Engine may be dispatched outside its area. However, a 

newly placed GS-07 FEO may only be certified as an ENGB trainee (ENGB-t). An 

Engine under his/her command may not be dispatched outside its area. The outcome 

is reduced capacity. The Engine may be staffed as a 7-day Engine, but one whose 

range is limited, or it may be downgraded to provide only 5-day coverage. 

At least in some areas, this scenario is being played out as an increasing number 

of employees at the middle and upper levels leave federal service for Cal Fire and 

municipal fire departments. For example, nine of eleven Los Angeles River District 

Engines are staffed with ENGB-t FEOs. 

This pipeline issue is extremely important. With higher level employees retiring 

or resigning, there is an increased need for experienced firefighters to continue on 

up the ladder. Experienced crew members become experienced squad bosses who become experienced Operation Section Chiefs who become experienced Incident Commanders. 

This takes a significant amount of time and continually filling the lower ranks 

with new recruits isn’t going to accomplish this task. Without experience throughout 

the organization, effective firefighting and safety is going to be comprised. Meaningful analysis of this aspect will require more than a snapshot in time of staffing levels. 

There are a number of factors affecting attrition rates. In the brief time I have 

here today, I’d like to focus on one that not only increases attrition but also presents 

a clear and present danger to safety on the fire lines. This is a problem that cries 

out for a timely solution. Fortunately, a simple remedy is available to solve it. 

‘‘PROFESSIONALIZING’’ FIRE MANAGEMENT

Experienced leadership is crucial to the fire organization. Because of a recent policy change, our most experienced field generals in the war on fire are being pushed 

out of positions of leadership. By its very nature, wildland firefighting is physically 

demanding and dangerous. This is unavoidable. But we can avoid implementing 

policies that make it less safe and less effective. 

To explain, the Forest Service and Department of Interior (DOI) agencies are in 

the midst of an initiative to ‘‘professionalize’’ their fire management positions. To 

understand this initiative and how it has strayed off course, I need to give some 

history. 

This initiative was born in the aftermath of the South Canyon tragedy of 1994, 

in which 14 brave firefighters met their deaths. The Interagency Management Review Team (IMRT) was chartered to perform a comprehensive review of federal 

wildland fire policy. The June 26, 1995 IMRT Final Report states, ‘‘A lack of qualified supervisory and management personnel could result in poor decisions, directly 

jeopardizing the safety of employees. Filling vacant positions with personnel not 

qualified to make crucial strategic and tactical decisions could directly jeopardize 

employees.’’ Regarding qualifications of fire managers, it recommended that ‘‘fire 

management positions include competency and performance based criteria related 

to the nature and complexity of their wildland fire responsibilities.’’ Following up 

on these recommendations, the Wildland Firefighter Safety Awareness Study (also 

know as the ‘‘Tri-Data Study,’’ Phase III completed in March, 1998), articulated the 

goal that ‘‘fire experience and competency should be considered as critical selection 

factors for fire leadership and fire management positions.’’ 

The development of a consistent standard, the Interagency Fire Program Management Standard (IFPM), was completed in 2004. I’d ask that you remember this 9- 

year lag when you hear promises about how the current crisis in the implementation of this standard will be handled over the next two years. 

The IFPM standard established minimum qualifications standards for key fire 

management positions. Wildfire (‘‘red card’’) qualifications were established for all 
35 

positions. In addition, some positions were slated for conversion to a professional Office of Personnel Management (OPM) classification series. It is for these ‘‘professional’’ positions that problems have arisen. 

Here, I have to digress for a moment to describe where our fire leaders come from. 

Many do not have college degrees. Fire management is a highly specialized profession. You don’t learn to fight fire in a classroom; you learn it on the fire lines working under more experienced firefighters. On an incident, rapid and correct decisions 

with incomplete information in a highly chaotic environment can mean the difference between life and death. An experienced leader has a collection of mental 

‘‘slides’’ which guide this decision-making process. And it is from the fire lines, not 

from academia, that folks come by this hard-won experience. 

In addition, fire personnel take specialized courses to advance to positions of leadership. Courses administered by the National Wildfire Coordinating Group (NWCG), 

an interagency wildfire organization, have been specifically tailored by the world’s 

experts in incident command and wildfire suppression to meet the unique needs of 

the wildland fire workforce. Courses such as Fire Management Leadership, Advanced Incident Management, and Fire Behavior Interpretation are directly related 

to improving safety and effectiveness on incidents. 

Now, to return to the OPM ‘‘professionalization’’ of fire management: initially, the 

Forest Service and DOI requested that OPM establish a new occupational series for 

fire program management. They did not. Instead, a supplemental qualification 

standard was approved: GS-0401 Fire Management Specialist. The basic, garden-variety GS-0401 included a minimum education requirement of a college degree, in a 

variety of fields related to natural resources or general biological sciences, or courses 

equivalent to a major field of study plus appropriate experience or additional education. This series did not work. So, the Fire Management Specialist supplemental 

standard was developed, under which a number of NWCG courses counted toward 

the education requirement. 

This compromise—a supplemental standard instead of a specific series for fire 

program management—was not a perfect solution. For example, we were asked by 

two dispatcher managers with degrees in psychology and one with a degree in business management, neither of which qualified them under the GS-0401, how their 

degrees were less relevant to running a Dispatch Center than qualifying degrees 

such as plant physiology or agronomy. We have no good answer for them, other than 

they are collateral damage of a policy in which a square peg is being shoved in a 

round hole. However, for most employees, the supplemental standard provided a 

workable path for getting qualified—even though many were annoyed at having to 

re-qualify for the same jobs they had been successfully performing for years. Use 

of in-house NWCG courses was cost-effective and allowed coursework to be scheduled during low fire activity periods. NWCG coursework was the most practical way 

many employees, especially those stationed in remote locations, could obtain education credits that were both relevant to their duties and needed under the new 

Standard and also fulfill their incident response responsibilities during times of 

local and national emergencies. 

The current deadline for conversion of all 800 targeted upper-level fire management positions to the GS-0401 series is October 1, 2010. An additional 200 Forest 

Service positions at the District level are scheduled for conversion in 2013. Upon 

conversion, incumbents who do not meet the new qualifications will be removed 

from these positions. 

THE INADVERTENT GUTTING OF THE FIRE MANAGEMENT STANDARD

In 2005 OPM implemented a policy intended to keep credits earned from ‘‘diploma 

mills’’ from counting toward meeting education qualifications for federal positions. 

This is an admirable goal. Unfortunately, it had the unintended consequence of removing the standing of NWCG courses as well. Specifically, the policy states that 

only courses from accredited institutions now have standing. Since NWCG is not an 

accredited institution recognized by the Department of Education, NWCG course 

certificates no longer count. 

This change effectively gutted the GS-0401 Fire Management Specialist supplemental qualification standard. Fire managers in upper-level positions scheduled for 

conversion have a substantial portfolio of previously creditable NWCG courses. So 

do those in mid-level positions, experienced leaders who are the best candidates for 

the next generation of upper-level fire managers. Now, these courses, directly applicable to safety and effectiveness on the fire line, no longer count toward the education requirement, whereas courses in unrelated natural resource and general biological sciences do. 
36 

The issue goes beyond the 300 of 800 incumbents in these GS-0401 positions (and 

the addition 200 employees scheduled for conversion in 2013) who are not qualified 

under the gutted GS-401 standard. This is not a problem looming; it is a clear and 

present danger. Although effects will accelerate as the deadline approaches, capacity 

is already being eroded as vacant positions are filled. With the stripping of academic 

standing of their portfolio of NWCG courses, many of our best fire leaders are excluded from competing for these positions. Employee safety is already being compromised with each position filled under these accidentally imposed criteria (see Appendix 2 for accounts from field managers). As noted by a field manager, it takes 

15-20 years to become a Division Supervisor or Type 3 Incident Commander and 27 

years to become a Type 2 or Type 1 Incident Commander. It is leaders like these 

who are being pushed out of fire leadership positions. 

It is worth pausing to note that the stated intent of the reforms implemented by 

the IFPM standard was to improve safety and effectiveness on the fire lines. It was 

not to better integrate fire management into natural resources. Yet, that seems to 

be the unstated agenda behind use of the GS-0401, a natural resources series. We 

agree with the goal of improving the natural resources expertise of fire personnel. 

However, it is questionable whether this approach will yield a workforce with appropriate natural resources expertise. A large number of irrelevant and marginally relevant fields of study are qualifying under this series, such as agriculture, agronomy, 

biochemistry, etc. Just as a degree in manure management doesn’t make a better 

fire manager, it also doesn’t make a better land manager. Further, experience is important in land management as well as fire. Specific knowledge about the specific 

land being managed is gained through experience. 

More importantly, we strongly feel that safety must be the first priority. Under 

the gutted standard, safety has taken a back seat to academic natural resources credentials. This is not acceptable. 

Recall the goal that ‘‘fire experience and competency should be considered as critical selection factors for fire leadership and fire management positions.’’ The gutted 

standard seriously undercuts this goal. It is worth quoting once again a key finding 

of the June 26, 1995 IMRT Final Report: ‘‘Filling vacant positions with personnel 

not qualified to make crucial strategic and tactical decisions could directly jeopardize employees.’’ Here is what field managers say is happening already (for more 

accounts, see Appendix 2): * The forest is having difficulty getting applicants for 401 

positions. We are trying to fill a 401 position right now. The applicants who are 

making it onto the referral list lack on the ground fire experience (for the most part) 

while many applicants that do have the on the ground fire experience do not meet 

the 401 requirement. 

• My Forest is having trouble filling 401 positions, and only with personnel with 

marginal field qualifications. 

• We are having trouble finding candidates that meet both requirements. The 

folks that meet the experience and qualification requirements don’t meet the 

education requirements... Conversely the folks that have applied that meet the 

education requirements do not have the field skills for the positions. This goes 

for the Regional level as well. 

• What I have been seeing recently is the people that have been hired since we 

went to the 401 series for FMO’s and Fuel Specialist are mostly people who 

have graduated from a college in the past 10 years and do not yet meet the 

NWCG qualifications for the jobs they are getting. Why? Because they are not 

experienced firefighters! With 10 years or less in an agency they have not had 

the opportunity for that broad based fire experience. So how are we as federal 

agencies handling this? We fast track them through the NWCG qualification 

(quals) process. For quals that would normally take 10-15 years of experience 

they are getting with only 5 years of experience. 

APPROPRIATE REGULATORY ADJUSTMENTS HAVE NOT BEEN MADE

Of course, NWCG is not a ‘‘diploma mill.’’ NWCG courses were developed and are 

taught by the world’s experts in incident command and wildfire suppression to meet 

the unique needs of the wildland fire workforce. One would expect this to be readily 

recognized and appropriate administrative action taken. However, OPM has steadfastly refused to restore the standing of NWCG-sponsored courses previously approved for the supplemental standard. Indeed, they have refused to even address 

the question of whether NWCG is a diploma mill. 

OPM’s position seems to be that waivers to policy can never be granted because 

the policy must always be followed. One of two premises must underlie this position: 

(1) application of the policy will never lead to significantly harmful outcomes, or (2) 

it is not OPM’s responsibility to address harmful outcomes. We believe the former 
37 

premise is false and the latter is irresponsible, especially in the present case in 

which matters of life and death are involved. We believe any request should be reviewed on its merits and actions be based upon an objective analysis of the particulars. This should not create an overwhelming workload, certainly not as compared 

with that thrust upon the field by the rigid application of policy even when it has 

clearly missed its target. Indeed, if waiver requests with merit multiply beyond reason, one might be moved to question the soundness of the policy. Perhaps this is 

the fear. 

The only response so far has been to delay the conversions for one year. Originally 

scheduled for 2009, conversion to the GS-0401 has been pushed back to 2010. The 

Forest Service/DOI plan is to ‘‘encourage universities to develop Wildland Fire 

Science degree programs,’’ ‘‘identify additional institutions and formalize procedures 

for seeking retroactive approval and transcription of creditable NWCG courses,’’ and 

provide ‘‘tuition support.’’ 

This plan is not realistic. Establishment of the previously approved portfolio of 

NWCG as accredited courses in academic institutions will be a time-consuming endeavor. Development of agreements and procedures for obtaining retroactive credits 

is even more problematic. OPM regulations prevent accredited institutions from 

granting ‘‘rubber-stamp’’ credits. Credit could only be granted for NWCG courses in 

cases where equivalent courses or curricula were already present at the accrediting 

institution. At best, years of effort may yield a patchwork of agreements providing 

incomplete coverage. 

Even if it could be achieved, this ‘‘solution’’ would not be desirable. It would be 

more expensive than coursework provided at existing in-house training centers, depleting scarce training budgets and discouraging career advancement of tomorrow’s 

leaders who must pay tuition out of their own pockets. In addition, quality would 

suffer, as instructors will in general lack the current, hands-on knowledge of inhouse fire experts. 

Past performance gives us no reason to expect the Forest Service to be able to 

implement this plan in time to stop the bleeding: 

• The OPM ‘‘diploma mill’’ policy change was enacted on February 15, 2005. Field 

management was not notified until May 31, 2007, over two years later. Thus, 

field employees continued to earn NWCG credits to meet the new qualifications 

of their positions (or of positions to which they aspire) only to discover, after 

the fact, that these courses were not qualifying. One 25-year fire manager qualified as a Type 3 Incident Commander noted, ‘‘I moved my entire family to a 

new state based on an offer that I had from the USFS saying that I was qualified only to learn 2 years later that they may have been just joking.’’ 

• Over a year later, employees have still not been notified of their current qualification status. They are unable to obtain career counseling to determine how 

to meet the new requirements of the gutted standard. Under these circumstances, many are understandably waiting for clarification before proceeding with further coursework. As noted by one employee, ‘‘When the OPM 

ruling was announced last year I was removed from [401] rosters and have been 

in a state of career limbo ever since. I still haven’t been informed what curriculum I should apply myself to re-qualify in the 401 series. In the Forest Service there is no ability to attain career counseling because Human Resources are 

centralized in Albuquerque, NM and therefore there are no local personnel officers to assist me. I currently have no plan to follow.’’ 

• The problems cited above are largely attributable to the recent downsizing and 

centralization of Human Capital Management (HCM), motivated by a competitive sourcing quota. The HCM organization is extremely compromised. The 

agency has difficulty even providing basic services, such as hiring seasonal and 

temporary firefighters and getting employees paid on time. It is extremely 

doubtful the capacity exists within HCM to help implement and administer this 

piecemeal solution. 

As noted, erosion of capacity is already occurring. Employees with families to support don’t wait until drop-dead deadlines; they look for other opportunities. Vacant 

positions are being filled without access to many of our most experienced fire leaders. These trends will only accelerate as we approach the deadline. Further, morale 

and trust after this treatment are very low. Field employees feel as though they 

have been ill-advised for over two years and then hung out to dry for another year. 

They are stressed out and distracted by this long-running drama. This is bad for 

safety in and of itself, and yet those making life and death decisions have been in 

this state for over a year. 
38 

CONCLUSION

Prior to the government-wide OPM policy change to address ‘‘diploma mills,’’ OPM 

had approved a supplemental Qualification Standard, GS-0401 Fire Management 

Specialist, for which in-house courses administered by NWCG counted toward the 

education requirement. Clearly, this specific approval demonstrates that OPM does 

not consider NWCG to be a ‘‘diploma mill.’’ This bureaucratic fiasco is a clear and 

present danger to safety on the fire lines—one that cries out for a timely solution. 

It is also a contributing factor to increased attrition rates and one which can be 

readily addressed. We urge enactment of legislation to restore the standing of these 

courses, and suggest the following language: 

• For the purposes of meeting education requirements of the GS-0401 Fire Management Specialist supplemental qualification standard, courses approved and 

provided by the National Wildfire Coordinating Group shall be considered to 

meet all applicable accreditation requirements. 

In closing, let me ask two simple questions that cut to the heart of this matter. 

Who would you want leading your son or daughter into harm’s way? Who would you 

want in charge of the operation to save your house from an advancing wildfire? I 

know who I’d want. I’d want the person best qualified in terms of fire experience 

and competency. Re-instating the standing of our in-house training program is the 

best way to ensure that’s who we’d get. 

APPENDIX 1.—REGION 5 STAFFING LEVELS
39 

APPENDIX 2.—EMPLOYEE COMMENT EXCERPTS ON FILLING VACANT POSITIONS

Comments were collected during a three-day period in March, 2008. It is noteworthy that we received well over a hundred comments, the vast majority from top 

fire managers in the field, during this 3-day window. We do not represent these 

managers and it is unusual that they would turn to the union in such numbers. We 

do, however, represent the employees who follow them into harm’s way. And we do 

share their interest in a safe and effective firefighting organization. More comments 

in their entirety are posted at http://www.nffe-fsc.org/Documents/IFPM/Web/ 

LoglWeb.htm. We strongly encourage review of these comments for a more complete understanding of perspectives from those on the front lines who have firsthand knowledge regarding the impacts of this problem. 

These are excerpts pertaining to the filling of vacant positions that is already 

going on. In some cases, excerpts reference dual announcements using the 401 and 

462 series. The 462 is a technical series without a minimum education requirement. 

For the jobs discussed here, these positions will be converted to 401 positions on 

October 1, 2010. Any employees hired into a targeted 462 position must therefore 

obtain the necessary education credits before this time or be removed from the position. Obviously, as we approach the 2010 deadline, the option of ‘‘floating’’ jobs 401/ 

462 becomes less tenable. 

• Region 1, Fire Management Officer (FMO): I have hired a Center Manager (401) 

since 2/15/2005. Candidates that met education requirements (Forestry Degrees) 

had little or no experience (met very few competencies) for the position. The 

only individual who met the competencies did not meet the 401 education requirements. The competencies were much more important to the candidate’s 

ability to lead and supervise a Dispatch Center than a degree was. When I 

made the selection I understood that the NWCG courses would apply that 

would help meet 401 requirements. The individual hired is an excellent center 

manager. He is over 50 years old. By the time the agency has committed time 

and dollars to meet his 401 education requirements, he will be near retirement. 

The dollars spent to pursue his 401 training are not available to younger employees to pursue specific, identified needs to prepare them as our future leaders. 

• Region 1, FMO: The forest is having difficulty getting applicants for 401 positions. We are trying to fill a 401 position right now. The applicants who are 

making it onto the referral list lack on the ground fire experience (for the most 

part) while many applicants that do have the on the ground fire experience do 

not meet the 401 requirement. 

• Region 1, Assistant FMO (AFMO): My Forest just filled a 401 FMO position 

with only four applicants and only one met the 401 requirements so they hired 

him. There should be a much larger applicant pool for such a key position. 

• Region1, AFMO: My Forest is having trouble filling vacancies, in fact in some 

cases they are flying the job in both the 462 and 401 series to gain more applicants (even though these positions are supposed to convert to 401 here shortly). 

From what I have been involved with there has been approximately 6-10 highly 

qualified candidates for every 1 401 candidate. 

• Region 1, FMO: Even under the old 401 series rules it made no sense to require 

that the center manager positions be filled in the 401 series. We have trouble 

getting a decent pool of applicants as it is for center manager positions, requiring them to meet 401 series standards will cripple our ability to fill these positions with highly qualified individuals. This may well turn out to be the real 

safety issue with IFPM. By requiring all positions at the GS11 level and above 

to be classified in the 401 series, we will be filling top leadership positions with 

less than the most experienced leaders. 

• Region 1, FMO: The Center Manager position is the only 401 position we have 

had to fill. Candidates that met education requirements (Forestry Degrees) had 

little or no experience (met very few competencies) for the position. 

• Region 2, FMO: We were in the middle of filling a District FMO job last year, 

had verbally offered the position to somebody, and that day the announcement 

came out that S courses (NWCG) no longer count, and we had to go and find 

another individual that currently met a 401 qualification, RATHER than being 

able to hire the preferred applicant... We need qualified leaders in these positions, not just paper certified individuals. We’re losing the flexibility of identifying and promoting leaders from fire professionals when we can’t count the 

thousands of dollars per individual the US Govt and taxpayers have invested 

(in NWCG or other fire courses) in these fire professionals as part of their education. This is completely irresponsible... 
40 

• Region 2, Assistant Dispatch Center Manager: Casper Dispatch in Wyoming 

had to advertise their 401 position 4 times! They finally had to create a GS11 Tech [who will have to fulfill education requirements before conversion 

date]... We will lose our Center Manger in 10/2009 [now 2010] because that person does not qualify for 401 under the current regs. None of the other personnel 

(four) can move into his position. We have a brand new seasonal working in dispatch this year that has a college degree. That person would legally qualify for 

the job....but has no understanding of upper management processes within Dispatch. Is this going to help? We have Dispatchers who have worked in the system, understand it and need to move up. Those are the kind of people you want 

running a Dispatch Center, not fresh out of college kids without experience, 

without knowledge or ROSS or the National Mobilization system. Dispatch is 

becoming more complex by the day....ROSS, IQCS, IQS, Best Value, VIPR, 

WIMS, Fire Use, WFIP, Urban Interface, etc., etc., etc. 

• Region 3, FMO: We have had three FMO jobs flown as 401. [Two Districts] flew 

their positions numerous times before they got enough applicants to have a viable cert. For one job I was on the hiring panel and one candidate (there were 

only 3 on the cert) was determined he did not actually have enough credits to 

qualify for the 401 so he was dropped. One District has also had a GS-9-401 

Fuels AFMO vacant since I got to the Forest in May 2006. Because this position 

was flown 401 it disqualified the interested applicants on the Forest and had 

no outside interest thus they have been unable to fill the position and are now 

advertising it as a 462 series. We just lost our Dispatch center manager to another Forest because we flew his position (this was an upgrade) as 401 believing 

that he qualified and after HCM got through with his credits he no longer 

meets 401 quals. Thus he applied for another Forest that flew their manager 

position as 401/462. Now we are flying our position as a GS-401/462-10/11. We 

also have many employees on this forest who we have been sending to training 

to get qualified for 401 who are good employees that are ready to move into 

AFMO and FMO jobs but don’t qualify for 401 jobs. One individual who is currently an AFMO was determined to not have enough credits now with the new 

rules and he had to get through another class in order to apply for FMO jobs. 

This is having a negative impact on morale and budgets because money we 

spent on getting people to an NWCG course that counted for credits are no 

longer viable and we are now having to send these employees to college courses 

basically tripling our training costs for our employees who want to be in positions that are 401 and extending the amount of time they have to wait to compete for promotions. 

• Region 4, FMO: Most all of the vacancies in Region 4 that have come out as 

only 401, have not been filled due to no or few applicants that meet the education AND the Quals. Most have had to be flown as 462/401 in order to get 

a decent applicant pool. 

• Region 4, AFMO: My Forest is having trouble filling 401 positions, and only 

with personnel with marginal field qualifications. I know some who have quitartificial ceiling, being supervised by college grads with very little fire experience 

• Region 5, AFMO: From what I understand, when they flew the FFMO job last 

spring as a straight GS-401 no one applied so they had to go with a GS-401/ 

462 with the highest grade being met when the occupant meet the GS-401 requirements. [Note: the window on this option closes as the conversion date approaches.] 

• Region 5: A recent outreach effort to fill the upcoming Forest FMO position 

(401) yielded no interest! The Forest Fuels Officer will take an early retirement 

rather than spend the last years of his career pursuing ‘‘educational requirements’’... I am personally aware of several individuals who have made the decision to drop out of the program because of the unrealistic demands and timeframes placed on them. This is a huge hit to the agency. Near and long-term 

effects to the agency will be untenable. 

• Region 5, FMO: Three of our top employees have been adversely affected by the 

OPM ruling that their NWCG courses may not be counted towards their conversion to the 401 job series... A GS-12 462 Deputy Forest Fire Management Officer does not qualify for the GS-13 Forest Fire Management Officer position I 

will be vacating in five weeks. Not a single 401 candidate applied for this position recently, which leaves the forest without leadership that [this Deputy 

FMO] could provide if he was converted. The OPM decision also adversely affects two GS-11 fire staff, from occupying key leadership positions as of October 

1, 2009. 
41 

• Region 6: We have an DFMO position open at this time and of the local candidates only one has enough credits to meet the 401 standards. 

• Region 6: My Forest is having trouble filling 401 positions. I currently have one 

vacancy in my organization that I am advertising as a 401 position. Considering 

the recent qualification changes for a GS-09 position, most of our experience in 

the organization is in the 0462 series and they can not compete under these 

new qualifications. 

• Region 8, FMO: We are having trouble finding candidates that meet both requirements. The folks that meet the experience and qualification requirements 

don’t meet the education requirements... Conversely the folks that have applied 

that meet the education requirements do not have the field skills for the positions. This goes for the Regional level as well. 

• Region 9, FMO: What I have been seeing recently is the people that have been 

hired since we went to the 401 series for FMO’s and Fuel Specialist are mostly 

people who have graduated from a college in the past 10 years and do not yet 

meet the NWCG qualifications for the jobs they are getting. Why? Because they 

are not experienced firefighters! With 10 years or less in an agency they have 

not had the opportunity for that broad based fire experience. So how are we as 

federal agencies handling this? We fast track them through the NWCG qualification (quals) process. For quals that would normally take 10-15 years of experience they are getting with only 5 years of experience. Not nearly enough to 

make decisions under the duress of fire operations. What will this mean to the 

FS and other agencies? Our new fire managers meet the 401 college course requirements but they don’t have the experience to be in the FMO positions. 

• Region 9, FMO: We have been trying to fill a Zone Fire Management Officer 

position at the GS-11 level. The position was filled prior to with a well qualified 

technician that had an excellent fire background and I believe a business degree. The problems I’m seeing is excellent candidates with good fire backgrounds are not meeting the certs due to education or worse yet a person with 

a 4 year degree qualifies for the education job and has 5 years to meet the 

qualifications. These higher up positions provide oversight safety for our ground 

personnel and without a background in fire qualifications (in other words having the qualifications to draw from -learning by experiences), we are risking the 

safety of our personnel by getting less qualified applicants from a standpoint 

of fire management. In the new fire leadership courses (L-380 and L-381), we 

are instructed that fire fighters base their decisions on past experiences not 

from what they learned in a 4 year degree. 

The CHAIRMAN. Thank you very much. 

Mr. Judd. 

STATEMENT OF CASEY JUDD, BUSINESS MANAGER, FEDERAL 

WILDLAND FIRE SERVICE ASSOCIATION, INKOM, ID 

Mr. JUDD. Thank you, Mr. Chairman and Senator Craig, my Senator. Appreciate the opportunity and the honor to convey and articulate the voice of our Nation’s Federal wildland firefighters regarding the preparedness of our Federal land management agencies to meet the current wildfire season. 

The voices of these brave men and women include those who occupy all fire positions from all five land management agencies. 

They are those who cut the lines, staff the engines, jump out of 

perfectly good airplanes, and manage the fire incidents. 

For many years, the FWFSA has done everything in its power to 

reach out to the previous and current agency leadership in an attempt to convey the concerns of firefighters and offer to work with 

the agencies to make their fire programs the place to make a 

wildland firefighting career. Each step of the way, we have been ignored. 

Today, you will hear two very different assessments of agency 

preparedness. Agency representatives continue to suggest they are 

adequately prepared, and reference the many non-Federal firefighting resources available to them, without referencing the higher 
42 

costs often associated with such resources. We do not believe this 

accurately portrays the preparedness of the Federal land management agency fire programs. They continuously suggest that resources can assigned based on anticipated starts and other criteria, 

yet unable-to-fill lists for resources continue to get longer and 

longer. 

Although the preparedness of all agencies is at issue in this hearing, we will primarily refer to the Forest Service, as it is the largest employer of wildland firefighters and the agency we believe to 

be the most dysfunctional with respect to the management of its 

fire program. 

Firefighters believe that agency policy, more than any other factor, is at the core of declining preparedness levels and what we perceive as the systematic dismantling of the agency fire programs. As 

a result of agency policy, America’s taxpayers are needlessly paying 

more for fire suppression, and continue to feed an agency incapable 

of fiscal efficiency with respect to its fire program. The agency’s refusal to address longstanding pay and benefit issues encumbering 

our firefighters, and the archaic organizational structure that manages the fire program as it was 30 to 40 years ago, have failed to 

prepare the agency for the complexities of wildfires in the 21st century. Despite decades of discussion and volumes of documentation 

supporting such reforms, firefighters from the Federal land management agencies continue to be stifled by inequitable pay and benefits, as compared to other non-Federal firefighters they stand side 

by side with on any given Federal wildfire incident. 

Although nearly everyone in this room today, inclusive of agency 

representatives, refer to these brave men and women as wildland 

firefighters, the agency continues to refuse to support any effort to 

remove these employees from outdated classification standards and 

develop a new wildland firefighter classification series that more 

accurately reflects the variety of duties they now perform, even 

though the House passed such legislation during the last session 

of Congress. The consequence of the failure of the agencies to address such issues facing their firefighters has been the recent and 

continuing migration of many Federal wildland firefighters to other 

non-Federal fire agencies for better pay and benefits. 

This has resulted in a stunning number of vacancies, in all 

grades, that the agencies have simply ignored until recently, when 

Congress started to ask serious questions about firefighter retention. 

Given the number of vacancies in many different fire positions, 

the ability to be properly prepared for the fire season, as envisioned 

by the National Fire Plan and as expected by Congress and the 

American public, is further compromised by the organizational 

structure of the fire program. 

The agency fire program is managed as it was decades ago. 

Those developing and implementing fire policy are line officers, 

such as the leadership in the Washington office, regional foresters, 

forest supervisors, and district rangers, who have virtually no wildfire experience or expertise. 

Further, these are the same Forest Service employees who continue to systematically divert hundreds of millions of dollars in appropriated fire preparedness and hazard fuels-reduction dollars 
43 

away from the field to pay for non-fire projects. As a result, a number of Federal fire preparedness resources in the field, inclusive of 

temporary firefighters, is compromised and inadequate. 

The combination of Federal firefighter vacancies and fiscal mismanagement of the fire program by non-fire line officers requires 

the agency to often fill in the gaps of missing Federal resources 

with a significantly more expensive non-Federal resources, placing 

an even greater financial burden on the American taxpayer. 

Simply stated, the agencies cannot be adequately prepared if, (1) 

they must appear before Congress each year seeking a supplemental appropriation of a half a billion dollars, (2) they must augment the staggering losses from within their own Federal ranks 

with significantly more expensive non-Federal resources, which 

leads to increased suppression costs, and (3) they continue to systematically divert fire preparedness and hazardous fuels reduction 

dollars away from the field to pay for non-fire projects. 

How do we fix this? The utilization of the 10-year average to establish budget levels for fires must be reviewed. Because of the fact 

that agency policy has led to unnecessary and artificial increases 

in suppression expenditures in recent years, it would make sense 

to allow those with the fire experience and expertise to develop 

budget requirements, without political influence, to establish a new 

baseline of funding for fire suppression and preparedness. 

Sadly, it is clear the agencies have no desire to reform fiscally 

inefficient fire programs in order to be better prepared for wildfires 

in the future. Congress must decide if it wants these agencies to 

continue fielding fire programs. If it does, Congress must mandate 

that the agency fire programs and associated funding be managed 

by those with fire experience and expertise with the authority and 

autonomy to manage the fire program as a fire department. 

Further, Congress must make changes to archaic pay and personnel policies to retain the highly qualified firefighters the agencies are now losing. Properly classifying employees as wildland firefighters, providing fundamental compensation processes, such as 

portal-to-portal pay, found in nearly all paid professional fire organizations, and basic benefits for temporary firefighters, such as eligibility to FEGLI and health coverage, would make great strides in 

eliminating the mass exodus of Federal wildland firefighters we are 

seeing, and restore the value of the investment our taxpayers have 

made in our Federal wildland firefighting forces. We urge you to 

listen to and consider the voices of these heroes. 

Thank you, again, and I’ll be delighted to answer any questions 

you may have. 

[The prepared statement of Mr. Judd follows:] 

PREPARED STATEMENT OF CASEY JUDD, BUSINESS MANAGER, FEDERAL WILDLAND

FIRE SERVICE ASSOCIATION, INKOM, ID 

INTRODUCTION

Mr. Chairman and Members of the Committee, it is an honor and privilege to appear before you today on behalf of the brave men and women across this country 

who serve as wildland firefighters and wildland fire program managers. These brave 

men and women make up our Nation’s federal wildland firefighting forces, and I intend to offer you their voice and their perspectives on the current preparedness of 

the federal land management agency fire programs, as we face yet another potentially catastrophic wildfire season. I also intend to offer their recommendations on 
44 

a corrective course of action needed to improve the overall efficiency, cost effectiveness, accountability, and safety needed to provide wildland fire management in the 

21st Century. 

The Federal Wildland Fire Service Association (FWFSA) is an employee association whose membership is primarily made up of federal wildland firefighters from 

all five federal land management agencies. As an association, our diverse membership includes those occupying all fire positions from entry-level firefighter to fire 

chief, along with dispatch, prevention, and support personnel. It is that diversity 

that continues to provide the FWFSA with a wealth of reliable data and information 

from the field. The FWFSA in turn provides ‘‘real world’’ information to Congress 

to illustrate and define the serious issues facing the fire programs of the land management agencies, and how these issues directly affect community and firefighter 

safety, as well as wrongly increase the financial burden being placed upon the 

American taxpayer to fund an often misguided program. 

FIRE PREPAREDNESS

During this hearing, the committee will no doubt hear two significantly different 

perspectives on the readiness and preparedness of the land management agency fire 

programs to meet the current wildfire season. The committee will hear from Agency 

representatives who, for at least the past two years have suggested to this and other 

committees that they (the agencies) are adequately prepared for the season. They 

(the agencies) undoubtedly will use terms such as ‘‘increased management efficiencies’’ and ‘‘the ability to move resources to areas of need’’ to describe their 

version of preparedness, and how they feel it is possible to do more with less. These 

terms, as well as their implementation, need great attention and oversight by this 

committee. 

The committee will also hear testimony representing the voice of the Nation’s federal wildland firefighters. The FWFSA will suggest that the federal land management agencies and their fire programs are not as prepared for the wildfire season 

as the agencies would like us to blindly believe. As an employee association, the 

FWFSA will present several significant issues that must be addressed if proper fire 

preparedness is to be realized. 

Preparedness levels can be somewhat subjective depending on what criterion is 

being used. The FWFSA believes it is prudent to utilize the guidance and expectations of Congress, and who through thorough consultation with the land management agencies and their constituents, approved the National Fire Plan (NFP) as the 

baseline for measuring current levels of preparedness. As I understand it, it was the 

intent of Congress to fund the ‘‘Most Efficient Level’’ (MEL) of resources at 90-100% 

to provide improvements to community and resource protection, as well as reduce 

large fire costs. Today, regardless of data being provided by the agencies, the current MEL level has dropped below 2000 levels in most areas. 

As the NFP suggests and common sense would dictate, having sufficient preparedness resources in place prior to the wildfire season would lead to reduced fire suppression costs. Fire preparedness dollars are designed to pay for a variety of resources including temporary firefighters, which in any given season can make up 

nearly 46% of the fire season staffing. 

To compliment having adequate preparedness resources in place, it is imperative 

that, as a result of the wildfire season being year round in many parts of the country, hazardous fuels reduction must be accomplished. These two elements: proper 

preparedness resources and hazardous fuels reduction, are key to reducing wildfire 

suppression costs. 

SO WHY ARE SUPPRESSION COSTS CONTINUING TO SKYROCKET?

This and other committees have been consistently told by the Agencies and ‘‘experts’’ that suppression costs are continuing to rise because of 1) climate/drought 

and 2) the increasing costs of protecting the Wildland Urban Interface. We, the 

FWFSA, take serious note with these assumptions. While these two elements are 

indeed factors, proper preparedness mitigates to a great degree the influence these 

two elements have on the overall costs of suppression. The question has been posed 

by both Congress and OMB: If it stands to reason that proper preparedness lead 

to reduced suppression costs, why after increased preparedness funding under the 

National Fire Plan, have suppression costs continued to rise? A simple answer— 

Smoke and Mirrors. 

As previously mentioned, the answer from the Agency(s) is that while they cling 

to their (unrepeatable data) suggestion that initial attack (IA) success is still 96- 

98%, climate & Wildland Urban Interface have caused the other 2-4% of fires to cost 
45 

record sums. With all due respect, the Nation’s federal wildland firefighters adamantly disagree with this assessment. 

FIREFIGHTER POSITION

In 2003 the FWFSA warned the Forest Service leadership that changes to the retirement package enjoyed by employees of the California Department of Forestry & 

Fire Protection (now called CAL FIRE) would result in a mass-exodus of CAL FIRE 

firefighters taking advantage of the more gratuitous 3% @ 50 benefits by the year 

2007 & 2008. The FWFSA further warned the Forest Service that as a result of the 

vacancies at CAL FIRE, it (CAL FIRE) would naturally look to federal land management agency wildland firefighters to fill their ranks. It was at that time that the 

FWFSA made every conceivable effort to reach out to the agencies, primarily the 

Forest Service, to work with it to find ways to address long standing pay & benefit 

issues so that when 2007 & 2008 came, the losses would be minimal. The FWFSA 

was summarily ignored by the leadership of the agencies. 

Throughout this decade, hundreds of millions of dollars in fire preparedness and 

fuels reduction dollars have been systematically diverted by non-fire ‘‘line officers’’ 

of the agencies (again primarily the Forest Service) to pay for a variety of non-fire 

programs, positions & projects. These line officers include leadership of the Washington Office (WO), Regional Foresters, Forest Supervisors, and to a lesser extent, 

District Rangers. 

The impact of this diversion was not felt until 2006 as up to that time forests 

were able to ‘‘deficit spend’’ in order to secure the needed preparedness resources 

despite these huge sums of money being diverted away from fire. However in 2006 

the word came down that there would be no further deficit spending. Incredibly fire 

management officers were expected to maintain the same IA rate without the ability 

to pay for adequate preparedness resources. Several years ago, Congress directed 

the executive branch agencies to cut the costs associated with ‘‘cost pools’’, and show 

actual costs and where the Congressionally intended and appropriated dollars were 

actually being spent. As a result, the Forest Service for example, changed terminology and began using ‘‘Indirect Shared Costs’’ to rename where dollars were being 

redirected and spent. The decision above to no longer allow ‘‘deficit spending’’ 

(Antideficiency Act, 31 U.S.C. sect. 1517) must be addressed as both fire preparedness and fire suppression funding is being misused, and directly contribute to ‘‘the 

increasing costs of fire suppression’’ as agency officials say ‘‘we are prepared’’ (Reference: GAO, Comptroller General Decision, B-310108). 

In February 2006, Agency (USDA) representatives appeared before this committee 

and once again assured the Committee that adequate preparedness resources would 

be in place. Firefighters knew this wasn’t going to be the case. The continuation of 

diverting preparedness dollars resulted in less preparedness resources in the field. 

The diversion of fuels reduction dollars reduced the number of treated acres. The 

result was what firefighters expected: reduced preparedness resources allowed many 

small fires to grow in size, intensity and ultimately cost as either Incident Commanders waited for federal resources that had to now come from much greater distances or, in the typical alternative, the Agency reverted to its over-reliance on significantly higher-priced non-federal resources to fill in the gaps of the missing federal resources. Either way suppression costs increased needlessly. The result was 

a record year for suppression costs. 

Rather than admitting the diversion of funds played a role in less resources being 

in place and thus ultimately increasing the costs of fires needlessly, the Agency simply reverted to its theory of climate and wildland urban interface as the causes of 

increased suppression costs. 

In 2007 we suggested to Congress that a repeat of 2006 was inevitable. We further predicted as we correctly did in 2006 that the Agency would return to Congress 

in the fall, complain that it had been a terrible season and seek a supplemental appropriation of another half billion dollars. That is exactly what happened. The problem was exacerbated by the expected exodus of CAL FIRE firefighters retiring and 

by the vacancies they left to be filled by federal firefighters. In 2007, the migration 

of federal wildland firefighters began to CAL FIRE and other fire agencies offering 

better pay, benefits, and working conditions The Agency, as it did in 2003 when first 

warned of the issue, did nothing to retain their employees despite having a number 

of authorities to do so under the Workforce Flexibility Act of 2004. To compound 

the problem for the federal sector, the Governor of California opened up hiring to 

the outside for mid-level positions at CAL FIRE. This generated an entirely new 

round of hiring and federal losses. These losses, and the Agency’s inability to retain 

highly tenured and quality firefighters, are currently being investigated by Senator 

Feinstein of California. 
46 

As we enter the 2008 season, the Forest Service fire program, primarily focused 

in the western United States, and especially in California is imploding. Despite assurances from the Agency that all funded positions would be staffed by the start 

of the season, as of June 6, 2008, 32% of California’s Forest Service Engines are 

unavailable. That doesn’t include hotshot crews that are being disbanded because 

of staffing and other resources not being staffed. Despite the USDA suggesting on 

May 6th in a letter to Senator Feinstein that California had 363 vacancies, the fact 

was that there were, and still are, more than 500 vacancies. 

Further, while the Agency referenced a round of hiring in July, firefighters know 

very well that with the continuing HR problems and training requirements, anyone 

who does get a job offer likely won’t actually come on board until later in the season, 

or after they meet minimal qualifications. Thus the July hiring idea will have little 

impact on this season’s staffing. Furthermore, the problem hasn’t been recruiting 

firefighters, it has been keeping them once they are trained at taxpayer expense. 

The staffing problems are not exclusive to California. Across the country Forest 

Service engines and other crews are not staffed and left uncovered. More importantly, while Congress and the American taxpayers expect these engines to be available 24/7, because of the losses of firefighters and the failure of the Agency to get 

fire preparedness dollars to the field where they belong, many engines are running 

only 5 days a week or even 3 days a week allowing firefighters to wonder if the 

Agency leadership has found a way to ‘‘schedule’’ wildfires. 

PROGNOSIS FOR 2008 & BEYOND

Unless Congress takes immediate action to break the vicious cycle described herein, the infrastructure of our Nation’s federal wildland firefighting forces will continue to be less than adequate to meet the complexities of wildfires in the 21st century. Allowing the land management agencies to continue to manage their fire programs as they do today will continue to needlessly result in skyrocketing suppression costs borne by the American taxpayer. Throwing more money at the problem, 

i.e. emergency supplemental appropriations without demanding proper fiscal management of the funds already appropriated to the Agencies for suppression, preparedness and hazardous fuels reduction will not result in a stronger, more effective 

and fiscally efficient fire program. 

SIMPLE BASIC SOLUTIONS TO LONG STANDING PROBLEMS

If Congress intends for the federal land management agencies to field and manage 

fire programs, it (Congress) must insist that the organizational structure of said 

programs be changed so that they are managed in a manner that will meet head 

on the challenges and complexities of wildfires in the 21st century. The fire programs can no longer be managed as they were 30-40 years ago. While recognizing 

that any such fire program is a part of a land management agency, the fire programs must be managed like a fire department. This means, above all, that the program must be managed by those with fire experience and expertise. This includes 

those who are responsible for developing and implementing fire policy along with 

the responsibility for handling and managing fire funds. 

A common analogy of the current organizational structure of the land management agency fire programs is that it is tantamount to a major metropolitan city fire 

department being managed by that city’s Parks & Recreation Department. As ridiculous as that sounds, that is the reality of land management agency fire programs 

today. 

Turning fire program management over to those with fire experience and expertise will eliminate the diversion of preparedness & fuels reduction funds ensuring 

adequate resources are in place. This will lead to reduced suppression costs as envisioned by the National Fire Plan. Further, policies more in line with current fire 

department protocol would be realized which is essential given the frequency that 

federal wildland firefighters interact with those from other non-federal fire agencies. 

Secondly, solutions must be implemented immediately to stem the tide of losses 

of federal wildland firefighters to other agencies. The issues facing our firefighters 

with respect to pay & benefits are not new. They have been well documented for 

decades and all reports point to the removal of firefighters from beneath archaic pay 

& personnel policies as the solution to this problem. Unfortunately the Agencies 

have done nothing to correct these problems. 

As a result, our Nation’s federal wildland firefighters have turned to Congress for 

help in strengthening the land management agency fire programs; making those 

programs the place to make a wildland firefighting career while saving the American taxpayer staggering sums of money. 
47 

The FWFSA has repeatedly suggested to the Agency leadership that two actions 

would have immediate positive benefits in stemming the tide of losses. The first is 

to properly recognize these brave men and women as wildland firefighters through 

proper job classification. 

Nearly every member of Congress, the President of the United States and even 

the Forest Service Chief and USDA Undersecretary refer to these employees as 

‘‘wildland firefighters.’’ Yet the agencies have turned a deaf ear towards the firefighters in removing them from outdated classifications such as ‘‘Forestry Technicians’’ and Range Technicians.’’ 

The Congressional Budget Office has determined that there would be no financial 

impact to the federal budget if the Office of Personnel Management (OPM) were to 

create a new wildland firefighter series (reference HR 5697, 109th Congress). In fact 

creating such a series would eliminate the current debacle associated with the 401 

classification as it affects our firefighters. 

There simply is no compelling reason not to classify these men and women as 

wildland firefighters. The Forest Service Fire & Aviation Management Director recently acknowledged what our firefighters have known for years—wildland firefighting is a year round job in the 21st century. The job descriptions and classifications of these employees should more accurately reflect the variety of fire related 

duties these employees now perform. Properly recognizing these brave men & 

women for who they are and what they do would be a tremendously cost effective 

morale boost and give them the sense that someone actually does care about them. 

Finally, the compensation concept of ‘‘portal to portal’’ pay has been a subject of 

contention between federal wildland firefighters and their employers for decades. 

Despite the fact that the vast majority of paid professional firefighters in the United 

States, inclusive of Department of Defense federal firefighters are compensated in 

this way, the land management agencies have steadfastly refused to do so. It is likely a result of the fact that the fire program is managed by those with no fire background and thus ill-equipped to understand what is needed to field a top notch firefighting force. 

Ironically the payment of ‘‘portal to portal’’ to non-federal firefighters (primarily 

those in the West from municipal fire agencies) is also a major factor in skyrocketing fire suppression costs. One only needs to look at major costly fires in the 

West and see that the majority of suppression costs are for non-federal resources. 

However the refusal of land management agencies to compensate their own 

wildland firefighters with portal to portal pay is perhaps the most egregious issue 

when one conducts exit polls of those federal firefighters leaving the federal system. 

It is unconscionable for the Federal Government to criticize the rising costs of 

wildfire suppression while continuing to pay non-federal firefighters portal to portal 

pay while taking their own, inherently less expensive firefighters ‘‘off the clock’’ on 

the same incident. 

Currently, federal wildland firefighters who are on assignments that exceed 24 

hrs are taken off the clock for anywhere from 8-14 hours of that 24 hour period 

while their municipal counterparts are paid their already higher salary for a full 

24 hours. These assignments can be up to two weeks or longer and result in federal 

wildland firefighters being away from home and family yet they are not compensated even though they cannot utilize their time as they would normally do. 

The concept of portal to portal as it relates to federal wildland firefighters would 

be to simply compensate said firefighters for all hours on an assignment exceeding 

24 hours in duration. 

While the Agencies have suggested that such compensation is ‘‘cost prohibitive’’ 

such an argument defies logic given that those same agencies compensate cooperators with portal to portal pay at much higher rates. In fact, it is our assumption 

that compensating federal wildland firefighters with portal to portal pay would not 

only cost a fraction of what is currently funded for wildfire suppression but it would 

lead to better retention and thus reduce the need to over rely on the higher-priced 

non-federal resources thereby saving taxpayers significant sums. It should be interesting to note that despite their opposition to portal to portal pay, the Forest Service 

approved the use of ‘‘24 hour pay plans’’ on several Southern California forests this 

past fall. These plans paid firefighters 8 hours of base pay and 16 hours of overtime 

less 3-half hour meal periods. 

Furthermore these plans were utilized for crews who were simply pre-positioned 

and not on an active assignment. Thus we believe the precedent has been set for 

portal to portal pay. Furthermore, the greatest irony involving portal to portal pay 

is that if preparedness funds were not diverted as previously referenced and sufficient federal fire preparedness resources were actually in the field, the number of 

incidents (24 hrs+) in which portal to portal would be compensable would be significantly reduced. There mere knowledge that they would be eligible to be paid in a 
48 

similar manner as their non-federal counterparts on any given emergency incident 

would lead to better retention. 

These changes, along with providing temporary wildland firefighters basic health 

benefits and eligibility to the Federal Employee Group Life Insurance (FEGLI) 

would eliminate any retention problem; ensure adequate preparedness resources are 

in place each season; reduce the costs of suppression; eliminate the annual request 

for emergency supplemental appropriations; strengthen the infrastructure of our 

Nation’s federal wildland firefighting forces and ultimately save the American taxpayer hundreds of millions of dollars. 

The federal land management agencies have steadfastly refused to support or implement any plans/policies that would serve to solve the myriad problems facing 

their fire programs. If the agencies are unwilling to make the necessary changes, 

we urge Congress to make them for them or, in the alternative, take fire away from 

the land management agencies and create a stand-alone federal wildland fire service 

managed by firefighters for firefighters. 

Until these changes are made, our Nation’s federal land management agencies 

will be ill-prepared to face this and subsequent fire seasons and will remain unable 

to provide the American public with the strongest, yet most cost-efficient and effective wildland firefighting force in the world. 

The CHAIRMAN. Thank you very much. 

Ms. Miley, go right ahead. 

STATEMENT OF DEBORAH MILEY, EXECUTIVE DIRECTOR, 

NATIONAL WILDLIFE SUPPRESSION ASSOCIATION, LYONS, OR 

Ms. MILEY. Mr. Chairman and members of the committee, I want 

to thank you for the opportunity to present testimony today regarding wildland fire preparedness. 

My name is Deborah Miley, and I’m the executive director of the 

National Wildfire Suppression Association. Prior to my current position, I was a fire contractor for 12 years. 

NWSA currently represents 200 professional private wildfire contractors in 17 States, and we also have 68 certified training instructors. NWSA’s members provide professionally trained emergency resources to the Federal, State, and local agencies responding to the wildfires, assisting with fuels reduction, and other national disasters, such as Hurricane Katrina. 

Up to 40 percent of the fire resources across the U.S. are provided by private wildland fire services. Our goal is to complement, 

rather than to compete with, the existing agency resources when 

fire activities exceed agency capacity. Approximately 75 percent of 

our contract companies are located in rural areas and recruit local 

rural citizens to fill their employee needs. We’re currently an integral part of the fire service that provides resources, such as 20-person crews, engines, tenders, dozers, and timber-fallers, along with 

totally operational fire camps, which include showers, laundry, lavatory, housing units, and catering operations that feed and house 

all emergency personnel. The savings to the agencies is that we are 

paid only for our time on the line; typically, a 12- to 16-hour shift. 

The contractor bears all of the costs of training, equipment, liability, and insurance. What the agencies get is a highly effective, experienced resource that is available only when they need them. 

NWSA advocates the use of the multiyear best-value contract 

when contracting for private resources. These best-value contracts 

help to reduce the cost to the agency by issuing multiyear contracts 

that do not require staff resources needed for managing annual 

contracts; ensure resource quality by considering not only cost, but 
49 

past performance, company history, equipment condition, dispatch 

location, and their training. 

For the upcoming fire season, we estimate that we have roughly 

10,000 trained firefighters and another additional 5,000 in support 

staff available and ready to provide a variety of resources. These 

figures do not include the aerial firefighting industry, nor do they 

include rural fire districts. This is comparable to the number of 

firefighter resources that we made available last year, and these 

figures can vary and are based on the projected needs of the agencies. 

The NWSA, like the agencies and members of the committee, 

continue to focus on issues such as cost containment, the quality 

of training, and safety of our firefighters. 

With regards to cost containment, NWSA provides a professional 

cost-effective resource that complements the agency’s fire program. 

Two reports commissioned by the Forest Service, one in 2003, done 

by Fire Program Solutions, and one in 2007, by Geoffrey Donovan, 

shows that private resources can be cost-effective, and that the best 

solution is an optimal mix of agency and private resources to 

achieve the most effective efforts in fire suppression while addressing cost containment. 

On safety, we’re partnering with several agencies and others in 

2008 to start a new contractor certification program. We’re going 

to continue to offer ongoing education and safety training and compliance to our members. 

With regards to training, we currently certify only qualified instructors, most of whom are retired agency personnel with years of 

fire experience. We have a monitoring program for our instructors 

and an annual update workshop for them. 

The NWSA also has a data base storage system that tracks the 

training for all of our NWSA instructors to help eliminate falsified 

records and incident qualification cards by allowing only certified 

instructors to enter training into the system. 

In conclusion, NWSA believes the private fire services are ready 

for the 2008 fire season. NWSA will continue to partner with the 

agencies to promote best-value contracting for the private fire services. NWSA will continue to work to promote professionalism in all 

areas of safety and training within the private fire service. NWSA 

will continue to provide a cost-effective integrated resource to complement the agencies’ efforts in fire suppression and emergency 

services. 

Thank you. 

[The prepared statement of Ms. Miley follows:] 

PREPARED STATEMENT OF DEBORAH MILEY, EXECUTIVE DIRECTOR, NATIONAL

WILDLIFE SUPPRESSION ASSOCIATION, LYONS, OR 

Good afternoon, Chairman Bingaman, Ranking Member Domenici and members 

of the Committee and thank you for the opportunity to present testimony today regarding wildland fire preparedness. My name is Deborah Miley and I am the Executive Director for the National Wildfire Suppression Association. Prior to my current 

position I was a fire contractor for twelve years. 

The National Wildfire Suppression Association (NWSA) represents over 200 professional private wildfire contract companies in 17 states. NWSA’s members provide 

professionally trained emergency resources to federal, state and local agencies responding to wildfires and other national disasters such as Hurricane Katrina, that 

threaten our national natural resources, private property, and personal safety. 
50 

Up to 40% of the fire resources across the United States are provided by private 

wildland fire services and are utilized when all the agency resources are depleted 

or when a catastrophic disaster strikes such as the wildfires in Southern California 

last year. Our goal is to complement rather than compete with the existing agency 

resources when fire activity exceeds agency organizational capacity. 

Approximately 75% of our contract companies are located in rural areas and recruit and rigorously train local residents including displaced workers and college 

students to fill their ranks. 

When lives are on the line, the agencies must have confidence in any resource 

that is a part of the fire community. Since 1991, the mission of NWSA is to insure 

that its members earn that confidence. 

In order to accomplish this the NWSA provides training certification, advocacy 

and support to help its member companies field experienced, highly trained, safety 

focused resources that meet or exceed all federal standards. 

We are currently integrated in the fire services in that private sector provides resources on the ground including 20 person crews, engines, tenders, dozers and timber fallers. In addition the private sector provides totally operational camps including showers, laundry, lavatory, housing units Private Sector fire catering operations 

that feed and house all firefighters and emergency response personnel. 

HISTORY OF THE DEVELOPMENT OF PRIVATE SECTOR FIRE SERVICES

The relationship between the federal, state and private wildland fire contract industry began in the late 70’s and early 80’s—this was an era of shrinking agency 

budgets and an ever growing incident of large fires. To respond effectively, agencies 

needed professional, trained resources that were available on a call-as-needed basis 

to complement their dwindling ranks of full time firefighters. Thus was born the industry of private contractors, who could rapidly dispatch those resources. An added 

saving to the agency is that private resources are paid only for the time on the fire. 

The contractor bears all costs of training, equipment, liability and insurance. What 

the agencies get is highly effective, experienced resources when they need them and 

only when they need them. 

In the late 1980’s the first contract crew agreement was written in the Pacific 

Northwest by the Oregon Department of Forestry. As the federal agencies had a 

larger need for those resources, the first Interagency Crew Agreement was developed in the Pacific Northwest which was followed by the Interagency Engine/Tender 

Agreement. Prior to the implementation of those agreements everyone was hired on 

an Emergency Equipment Rental Agreement (EERA). 

NWSA SUPPORTS THE BEST VALUE CONCEPT OF CONTRACTING

NWSA continues to advocate the use of the Multi-Year Best Value Contracting 

program when contracting for private resources. We believe that this contracting vehicle will help ensure a high level of professionalism in the industry while helping 

the agencies assure that they get the most professionally trained, cost effective resources. 

These Best Value contracts provide best value for the government and the tax 

payer: 

—Reducing the cost to the agency by issuing multi-year contracts that do not 

require the staff resources needed for managing annual contracts or Emergency Equipment Rental Agreements. 

—Ensure resource quality by considering not only cost but past performance, 

company history, equipment condition, dispatch location and training. 

—Help promote professionally trained, safety focused resources. 

Best Value Contracting also helps stabilize the industry and help encourage the 

private sector to continue to invest in their businesses. This is a positive factor for 

the economy, especially in the rural communities. 

RESOURCES AVAILABLE FROM PRIVATE SECTOR

For the upcoming fire season we estimate that we have roughly 10,000 trained 

firefighters, and another additional 5000 in support staff for caterers, showers and 

other support resources available and ready to provide resources of all types including showers, catering units, laundry, engines, tenders, 20-man crews, and other specialized equipment. These figures do not include the aerial firefighting industry. 

This is comparable to the number of firefighter resources that were made available 

last year. These figures can vary and are based on the projected needs of the agencies. 
51 

Last year, we were dispatched to 19 different states including Tennessee, Florida, 

Georgia, Minnesota, Colorado, California, Oregon, Washington, Idaho, Utah, Wyoming, Arizona, Nevada, Montana, Kentucky, and New Mexico, Virginia and North 

Carolina. 

We will be ready to answer the call when the agency resources are depleted and 

they request additional resources to complement their efforts. 

INDUSTRY CONCERNS: COST CONTAINMENT, TRAINING, SAFETY, EROSION OF

FIRE EXPERIENCE

The National Wildfire Suppression Association, like the agencies and members of 

the committee continues to focus on ensuring cost effectiveness of our resources, the 

quality of our training, which we believe to be the best anywhere. Our focus on firefighter safety is intense and has resulted in a very low incidence of injury and fatality. We are concerned, however, about the loss of agency personnel with fire experience—a situation which creates safety issues on the line for everyone, including our 

members’ personnel. 

Some of the Solutions we have implemented to address these issues are: 

Cost Containment 

NWSA provides a professional cost effective resource that complements the agencies fire program. A report commissioned by the Forest Service in 2003 done by Fire 

Program Solutions LLC shows the costs for the using private sector for fire suppression was a cost effective addition to be used by agencies requiring additional help. 

In addition a report done by Geoffrey Donovan, USFS, in the Winter of 2007, shows 

that many variables determine the cost effectiveness of private resources, and that 

they can be just as cost competitive and that there needs to be an optimal mix of 

agency and private resources to achieve the most effective efforts in fire suppression 

while addressing cost containment. In short, Private fire resources are and have 

been an integral part of the fire community in Wildland fire suppression, and do 

provide a cost effective resource that can be utilized on an as needed basis to complement the agency fire program. 

NWSA believes that continuing to support the implementation of true Multi-Year 

Best Value Contracts is the best solution to ensuring cost effectiveness in contracting. 

Instituting a Contractor Certification Program 

NWSA is partnering with a variety of agencies over the next year to offer a new 

Contractor Certification Program for our members. This program will better equip 

members with resources on Workers Compensation requirements, Safety & Health 

Standards, U.S. Department of Labor and U.S. Department of Transportation regulations in addition to a class on Business Ethics, and information on Drug & Alcohol 

Supervisory Training. 

Instructor Monitoring Program insures top quality instruction for firefighters 

Currently NWSA has 68 Certified Instructors. They are certified by our NWSA 

Training Coordinator according to National Wildfire Coordinating Group (NWCG) 

standards. Most of our NWSA instructors are retired ex-agency personnel with 

years of fire experience. NWSA instituted an Instructor Monitoring program and we 

have hired an independent 3rd party to perform this function. 

We adhere to the currency requirements for instructors per the National Wildfire 

Coordinating Group standards. NWSA conducts an annual training session for our 

instructors where they are updated on course content changes, suggested training 

processes, and association requirements. All NWSA instructors are required to 

record their training in the NWSA Database Storage System. 

In addition all instructors must adhere to a Code of Ethics. NWSA has terminated 

certification for 4 instructors who have not adhered to our requirements. When an 

instructor’s certification is terminated, they are no longer able to use the NWSA 

Database system and we notify the appropriate agencies. 

NWSA Database Storage System helps eliminate falsification of records and IQ cards 

NWSA has developed a Web based database storage system that tracks all training done by NWSA Certified Instructors. This program helps eliminate falsified 

records and Incident Qualification (IQ) cards by allowing only certified instructors 

to enter training into the system, which includes the firefighter’s picture and the 

instructor’s electronic signature. It produces training certificates and Incident Qualification Cards that meet all agency requirements. The documents can be verified by 

agency personnel on a fire accessing the system and looking at training and comparing the IQ Card in the system if necessary. The company owner can also track 
52 

event information for its employees in the system, which determines qualification 

of position. There are many levels of security and authorization built into the system. 

Records Verification Process standardizes contractor record keeping processes 

This year in 2008 in the Pacific Northwest Region we started a process of records 

verification where we have hired an independent 3rd party that visits the contractors’ establishments and looks at the records on all overhead and 10% sampling of 

the crews. We make recommendations on file process and submit a letter to the 

company owner on issues that need to be addressed and provide follow up to ensure 

it has been remedy. 

Code of Ethics creates standard of business operations for member companies to protect and preserve industry reputation 

All NWSA members must sign and follow a Code of Ethics and there is a process 

in which we can terminate membership of a member if that is violated and not remedied. NWSA has terminated 2 members as a result of violations. When a member 

is terminated we notify all appropriate parties, and that member no longer has access to the NWSA Database. 

IN CONCLUSION

The National Wildfire Suppression Association (NWSA) believes that the private 

fire services will be ready for the 2008 fire season. 

NWSA will continue to partner with the agencies to promote Best Value Contracting for private fire services. 

NWSA will continue to work to promote professionalism in all areas of safety and 

training within the private fire services. 

NWSA will continue to provide cost effective integrated resources to complement 

the agency efforts in fire suppression and emergency services. 

The CHAIRMAN. Thank you very much. Thank you all for your 

testimony. 

Let me ask a few questions. I’m sure Senator Craig has some, 

as well. 

Mr. Thatcher, you described a circumstance where agency managers are in a position of having to hire less-experienced firefighters because some of the more experienced applicants have not 

met these new educational requirements, as I understand it. 

Mr. THATCHER. Let me clarify that. What’s happening is, we’re 

seeing an excessive amount of attrition with our existing GS–06s 

and –07s. What’s happening is, they are being pilfered, if you will, 

to private firefighting agencies in California, which is leaving us 

with a shortage of the experienced people that have been working 

their way through the system to get these grade levels, and now, 

when they leave, it leaves a void, to where we need to rapidly fill 

behind them so we can staff these engine modules. We’re beginning 

to see some pretty serious implications from having to do that. 

The CHAIRMAN. This high attrition rate is a result of what Mr. 

Judd was complaining about, too, the inadequate pay, the inadequate benefits. Is that the main factor? 

Mr. THATCHER. I won’t speak for Mr. Judd. I’ll let him do that 

on his own. But, some of the folks that we have done exit interviews—which would be an excellent thing for the committee to request, is to see why are our folks migrating away from our agency 

and going to other agencies—but, we do feel that that is one of the 

reasons why. 

The CHAIRMAN. Mr. Judd, in your view, is that the main reason? 

Mr. JUDD. It used to be. Obviously, when CAL FIRE—and I’ll use 

this as an example, because there seems to be a lot of focus on 

California—CAL FIRE’s firefighters developed a very lucrative retirement package, and we knew, several years ago, that, come 
53 

2007–2008, this would have an impact, where they would look for 

wildland firefighters to fill in the ranks of those that were retiring. 

Obviously they can provide better pay and benefits. But, what has 

happened over the last year and a half is the sense that, ‘‘Yes, I’m 

going for pay and benefits, but I’ve lost any sense of worth with 

the agency, as though the agency doesn’t give a damn about me. 

So, why not go and take better pay and benefits for someone that 

may actually care about me?’’ 

I think, the initial intrigue of leaving is for pay and benefits, but, 

as we’ve seen from our members, which go from entry level all the 

way up to forest fire chiefs, it’s the lack of recognition, it’s the lack 

of any caring, if you will, on the part of the employer. 

The CHAIRMAN. So, you’re just describing a general lack of morale, or poor morale, throughout the—this work force. 

Mr. JUDD. Oh, absolutely. It’s not limited to California, because 

obviously these crews are transient across the country, depending 

on where fires are on any given—— 

The CHAIRMAN. Is this poor morale that you’re describing to us 

a new thing, or is this something that’s been there since time immemorial—what’s the circumstance here? 

Mr. JUDD. Interestingly enough, the issues that we’re tackling 

are decades old, and they’ve been made aware to the agencies for 

decades, and there has been staggering numbers of discussions and 

meeting groups saying, ‘‘This is what needs to be done to make 

your fire organization more effective and efficient and stronger.’’ 

Rather than take steps to support those initiatives, we believe the 

agency has simply ignored those voices from the fire service. As a 

result, you have archaic classification standards, you have less pay 

and benefits. As a result of the agency simply doing nothing for its 

firefighters, there’s no other choice but to say, ‘‘OK, well, I’m leaving, I’m going.’’ 

I think, on April 1—Chief Kimbell referred to this as an entrylevel problem. This is not an entry-level problem. We’re losing folks 

that have had 10, 15, 20, 20-plus years in the fire service—of the 

Forest Service, especially—that are saying, ‘‘I’ve had enough of 

this,’’ because there is no agency support for those firefighters. 

Again, it’s a combination of pay and benefits, but it’s also part of 

how that fire program is managed by folks that, with all due respect, don’t have a lick of firefighting experience. 

Mr. THATCHER. Mr. Chairman. 

The CHAIRMAN. Yes. 

Mr. JUDD. If I could—— 

The CHAIRMAN. Yes, go ahead. Why don’t you add to that, and 

then I’ll call on Senator Craig for his questions. 

Mr. THATCHER. One of the morale issues that these dedicated 

firefighters, as Casey has said, that some have 10, 15, 20 years, 

and now they’re being told, ‘‘Well, we’re going to be looking at 

changing from the series that you’re in currently to a 401, and 

we’re going to professionalize you. Now, it’s either you’re going to 

get what you need to get through academia to qualify for the 401 

series, or we’ll probably having to sunset you out.’’ So, here are 

these career employees, who are some of the finest firefighters we 

have on the books, are now being told, ‘‘The 20 years of experience 

that you have in fighting fires and protecting and caring for the 
54 

precious resources we’re obligated to protect, is no longer going to 

qualify you to do that job.’’ That is a serious hit in morale with 

our—and there’s thousands of them that have come through the 

system, gone through the classwork, gone to the specialized training the agency provides, and now they’re being told, ‘‘Sorry, you 

don’t qualify.’’ 

The CHAIRMAN. Senator Craig. 

Senator CRAIG. Thank you very much, Mr. Chairman. 

Ron, help me understand this. If we go to all, say, 301 forest— 

firefighters in the Forest Service, and DOI stays at 401 firefighters, 

how will the Forest Service employees compete with the DOI employees when they apply for Forest Service fire positions? 

Mr. THATCHER. My understanding—— 

Senator CRAIG. Haven’t we created an internal conflict there? 

Mr. THATCHER. I believe that employees will always need to 

know that if they leave an agency and go to another agency, they 

will have to compete to get promotions in that other agency. So, I 

mean, they’re going to that, fully well knowing what is going to be 

required if they change agencies. 

We believe, the 301 series—we currently have grades up to the 

14 level. I mean, that is a pretty high echelon for firefighters that 

is provided in the 301 series. So, we see career potential to very 

high grades by utilizing the 301 series. 

Senator CRAIG. OK. I’ll try to figure that out, then. I think I understand what you’re saying. 

Deborah, are you aware of any concerns related to dispatching of 

private fire engines into local fires? If so, could you please express 

your concern or explain that? 

Ms. MILEY. I think, just over the years, we’ve had dispatch 

issues, and that’s part of being in private sector; people knowing—— 

Senator CRAIG. Yes. 

Ms. MILEY [continuing]. What to do with us and how to use is 

has always been an issue. I know that last year there was a concern on behalf of a lot of our members on why some of the engines 

out of Region 6 weren’t being dispatched to Region 1, which—— 

Senator CRAIG. Right. 

Ms. MILEY [continuing]. Would be Montana. That issue did come 

up. Now, I had done some calls and tried to see what I could find 

out about why that was, and my understanding was that, in Montana, that they were using a new fire management program in 

Montana that didn’t promote the use of outside resources as much 

as some of the other States use them. We also have the same problem in California. California doesn’t particularly care for privatesector resources, and, a lot of times, you’ll hear on the news where 

they’ve got houses burning down, they can’t get enough crews, and 

we’ve got crews sitting that could go. But, that’s kind of a dispatch 

problem that we’ve had over a long period of time, and it’s just a 

matter of, I think, education, and people don’t know that our resources are out there and that they can be made available. 

Senator CRAIG. Thank you, Mr. Chairman. I don’t think I have 

any other questions. 

The CHAIRMAN. OK. 
55 

I think this has been useful testimony. We appreciate you being 

here, appreciate the recommendations. We will try to act on some 

of them. 

Thank you very much. 

[Whereupon, at 3:30 p.m., the hearing was adjourned.] 

[The following statement was received for the record.] 

June 13, 2008. 

To: Senate Energy & Natural Resources Committee. 

DEAR MEMBERS: I am the wife of a Forest Service Fire Captain who was dispatched to the Indians Fire. At this time I would like to address the main issue 

I face by the lack of attention and action by Forest Service leadership, the safety 

of my husband and our ‘‘fire’’ family. 

Statistics show that there is an 8.5% deficit in personnel. While that number may 

be true for the entire nation, in our region, Region 5, I would guess the number 

to be closer to 30% or higher. How else can you explain that only 186 out of 276 

engines were available to respond to the recent fires in state? This number is staggering to me and makes me very afraid for the safety of all. 

The retention issue is no longer just an issue of pay, but of safety and belief in 

the core values of leadership. Safety is jeopardized when crews are stretched to the 

limit and inexperienced firefighters are forced into details they do not have the experience to execute. First and second year firefighters are fast tracked to make up 

for the loss of experienced firefighters to other agencies, positions remain un-staffed 

and engines sit idle. It is just a recipe for disaster. 

When disaster does happen, the agency does not stand by its employees as do 

other agencies. Families are further burdened financially with the need to carry 

Professional Liability Insurance because the agency has historically chosen to do 

nothing. Many families can not afford this burden. 

I believe in my husband and stand by his choice to stay with the Forest Service. 

We are lucky, unlike many other families we can afford financially to believe that 

leadership will pull their heads out of the sand. We can afford to wait for them to 

face up to their twisted facts of retention and pay and stop hiding behind reports 

that anyone with knowledge of simple math can reasonably tear to shreds. What 

we can’t afford to wait for are additional personnel. 

There is always a risk associated with fighting fire, but the risk can be minimized 

and you have the ability to help make that happen. Please do what is expected of 

you, the right thing. 

As you move forward with your process, I would like all of you to ask yourselves, 

‘‘How fast would I fill a vacancy of 30% in my staff?’’ I’m guessing pretty fast. No 

matter how good the staff, a deficit of just one person puts a burden on all. Just 

think of how the deficit of just one man would affect a fire crew? The affect could 

be deadly. 

In closing, I would like to thank Senator Feinstein for all her efforts on behalf 

of the firefighters and their families. Your efforts are greatly appreciated! 

Best regards, 

CHRISTINA M. STANLEY. 

(57) 

APPENDIX 

RESPONSES TO ADDITIONAL QUESTIONS

RESPONSES OF CASEY JUDD TO QUESTIONS FROM SENATOR WYDEN

Question 1. Mr. Judd, in your testimony you stated that ‘‘the diversion of fuel reduction dollars reduces the number of treated acres’’ and the result is that reduced 

preparedness resources allows many small fires to grow in size, intensity and ultimately cost. You suggest that federal land management agencies and their fire programs are not as prepared for the wildfire season as they need to be. 

a. Would you agree that the diversion of funds played a role in less treatment resources being in place which ultimately increased the costs of fires needlessly? Can 

you provide examples where you have seen this happen on the ground? 

Answer. Thank you for the honor & opportunity to provide additional information 

on our perspective of Agency preparedness for the fire season. To amplify the seriousness of this issue, it is important for all the members of the Committee to know 

that just in the past few days, Northern California has experienced over 600 fire 

starts stretching already thin resource availability. Additionally, there is significant 

concern among fire managers that with respect to the Indian Fire on the Los Padres 

National Forest, huge areas of the forest will have to be ‘‘fired’’ in order to keep the 

fire from getting to the Pacific Ocean. 

Our Nation’s federal wildland firefighters absolutely agree that the continued, 

systematic diversion of funds appropriated for hazardous fuels reduction and for the 

funding of fire preparedness resources for non-fire purposes is reducing the number 

of acres treated as well as reducing the available preparedness resources IAW the 

National Fire Plan in order to keep fires small and thus less costly. 

A vast amount of these funds have gone to finance what we consider to be the 

‘‘White Elephant’’ Albuquerque Service Center in New Mexico. Despite staggering 

sums of FIRE dollars invested in that site, even the Forest Service acknowledges 

that it is not functioning as desired. One needs only look at costly fires such as the $118 million Zaca Fire in California last year. The vast majority of the suppression costs were for non-federal resources (cooperators) that were brought in as a result of federal resources being unavailable. Federal resources I might add that would have been available had they 

been funded rather than non-fire line officers from the Forest Service diverting such 

funding. 

A classic example of the impact of reduced federal preparedness resources in the 

field was a 2006 fire in Elko Nevada. An order was placed for dozers. Had preparedness funds not been diverted but actually used to properly fund and allocate preparedness resources in the field, these resources would have been on site immediately. However the dozers finally had to come from Florida which took additional 

time and thus allowed the fire to grow in size, intensity & cost. This scenario plays 

itself out frequently during the season in many locations. 

As I write this, Northern California Fire Management officers (FMOs) are being 

told by Boise that there are no Type 3 resources available. More and more reliance 

is being placed on non-federal resources costing taxpayers 3-5 times what federal 

resources would cost. 

The Forest Service, under the guidance of Mark Rey does an excellent job of 

masking its fiscal mismanagement with respect to the fire program. Suffice it to say 

it might require a GAO report to examine just how much hazardous fuels reduction 

funding & fire preparedness funding is being utilized for non-fire purposes. We can 

however provide communication with current and former Fire & Aviation Management Directors, FMOs and others who can validate this assessment. 

Please understand that the diversion of said funds goes hand in hand with a 

weakening of the infrastructure of our Nation’s federal wildland firefighting forces 

as a result of being burdened by archaic pay & personnel policies. We continue to 

lose unacceptable numbers of firefighters to other non-federal agencies. Add these 
58 

losses to the diversion of funds and you have a recipe for increased suppression 

costs. 

While the Agency suggests climate and WUI are the primary reasons for increased suppression costs, firefighters believe Agency policy is the key. The impact 

that climate and WUI has on any given fire can be mitigated to a large degree by 

having adequate preparedness resources in place, a strong federal infrastructure 

which is inherently less costly than non-federal resources and the successful treatment of hazardous fuels. 

If we can provide contact information for those who can validate this information, 

please let us know. Please recognize however that the Forest Service has sent ominous messages to its firefighters about the consequences of speaking to Congress or 

the press about these issues, hence my testimony. There are those that would relish 

the opportunity to speak out though. 

Our sincerest thanks for your interest and attention to this serious matter. 

RESPONSES OF DEBORAH MILEY TO QUESTIONS FROM SENATOR WYDEN

Question 1. Ms. Miley, during the hearing I asked Mr. Rey and Cason about rising 

fuel prices and how their agencies plan on address this issue as it relates to contractors. 

a. How are rising fuel prices impacting your members? Do you anticipate any reduced capacity in firefighting response abilities due to rising fuel costs? 

Answer. While fuel prices continue to affect all of us, the unfortunate reality for 

our members is that most the contracts we are currently working under DO NOT 

have escalators built into them for fuel prices, therefore the majority of the contractors will have to absorb the rising cost of fuel. This is the case until such time as 

the contractors come up for bid again at which time I am sure that the agencies 

will see a change in the bids to reflect fuel costs at that time. 

If they are given enough work days during the fire season this will make it easier 

to absorb those costs, but if we are not given enough days the impact will be greater. 

At this time I do not see a reduced capacity in firefighting response due to fuel 

prices, but the impact will probably not reflect on the industry until contracts are 

renewed, and again if they are given enough days to absorb those costs the impact 

may not be great. 

RESPONSES OF MARK REY TO QUESTIONS FROM SENATOR BINGAMAN

Question 1. According to the NICC report entitled ‘‘Wildland Fire Summary and 

Statistics: 2007’’, 1,199 of the 3,178 requests for Type 1, 2, and 2-IA were unable 

to be filled. How many of the 3,178 requests were made during National Preparedness Levels 4 and 5? How many of the 1,199 unfulfilled requests were during National Preparedness Levels 4 and 5? 

Answer. It is important to note that Unable to Fill (UTF) orders are a static statistic that indicate an order was placed and was not able to be filled at that specific 

time. The list is a display of those resource orders on the date specified that a coordination center is been unable to fill by personnel within its geographic area. The 

filling of firefighting resources is dynamic and an order placed may, in fact, have 

been filled a short time after the order was placed, or if conditions change, dropped. 

In addition, during Planning Levels 4 and 5, resources are assigned based on the 

priority of the fire incident. As orders come in they are sent to meet priority needs 

on priority fires. Though this process, the wildland fire management agencies can 

efficiently and effectively address wildland fire suppression needs in a manner that 

balances local, regional, and national wildfire suppression capacity. 

The responses to questions 1 through 5 are based on a June 25, 2008 query of 

the January 1 through December 31, 2007 resource data from the ROSS database. 

Please note that some of the numbers below vary slightly from those in the NICC 

report. This is likely due to data updates between the different individual queries, 

but would not be expected to influence the overall conclusion. 
59 

Total Requests .................................................................................. 3,305 

Total UTF .......................................................................................... 1,292 

Total Request while at PL 4 & 5 .................................................... 2,861 or 87% 

Total UTF at PL 4 & 5 .................................................................... 1,245 or 96% 

Question 2. The same report indicates that the agencies were unable to fulfill 270 

of the 2,944 requests for engines. How many of the 2,944 requests were made during National Preparedness Levels 4 and 5? How many of the 270 unfulfilled requests were during National Preparedness Levels 4 and 5? 

Answer. (See below) 

Total Requests .................................................................................. 2,994 

Total UTF .......................................................................................... 330 

Total Request while at PL 4 & 5 .................................................... 1,963 or 66% 

Total UTF at PL 4 & 5 .................................................................... 193 or 58% 

Question 3. The report also indicates that the agencies were unable to fulfill 9,184 

of the 27,592 overhead requests. How many of the 27,592 requests were made during National Preparedness Levels 4 and 5? How many of the 9,184 unfulfilled requests were during National Preparedness Levels 4 and 5? 

Answer. (See below) 

Total Requests .................................................................................. 29,334 

Total UTF .......................................................................................... 10,034 

Total Request while at PL 4 & 5 .................................................... 22,398 

Total UTF at PL 4 & 5 .................................................................... 9,043 or 90% 

Question 4. Similarly, the report indicates that the agencies were unable to fulfill 

474 of the 1,298 requests for helicopters. How many of the 1,298 requests were 

made during National Preparedness Levels 4 and 5? How many of the 474 

unfulfilled requests were during National Preparedness Levels 4 and 5? 

Answer. (See below) 

Total Requests .................................................................................. 1,323 

Total UTF .......................................................................................... 511 

Total Request while at PL 4 & 5 .................................................... 1,000 or 76% 

Total UTF at PL 4 & 5 .................................................................... 496 or 97% 

Question 5. Finally, the report indicates that the agencies were unable to fulfill 

624 of the 2,780 requests for aircraft. How many of the 2,780 requests were made 

during National Preparedness Levels 4 and 5? How many of the 624 unfulfilled requests were during National Preparedness Levels 4 and 5? 
60 

Answer. The following do not include helicopter orders; they are reported in question 4. 

Total Requests .................................................................................. 3,787 

Total UTF .......................................................................................... 693 

Total Request while at PL 4 & 5 .................................................... 2,860 or 76% 

Total UTF at PL 4 & 5 .................................................................... 605 or 87% 

Question 6. Last year, Senator Cantwell, Senator Domenici, and I introduced a 

bill to help cover a portion of personal liability insurance costs for Federal firefighters, and Senators Feinstein and Craig helped to get that enacted through the 

Interior Appropriations bill. Can you tell me whether the Forest Service currently 

is using that authority to help cover those costs for all of its firefighters that elect 

to get that insurance? 

Answer. Yes, the authority is being used to assist temporary wildland fire supervisors and managers meet the cost of professional liability insurance. A letter was 

issued by Chief Kimbell on March 14, 2008 outlining the availability of the personal 

liability insurance benefit. Attached to the letter were procedures for claiming the 

benefit and a list of approved positions that were either specifically mentioned in 

or meet the intent of the authorizing and accompanying report language. We appreciate the work of the Committee for this authority. 

Question 7. The same report reveals that the agencies operated at National Preparedness Level 5 (when geographic areas are experiencing major incidents which 

have the potential to exhaust all agency fire resources) for an average of about 7.4 

days during the 1990s and for an average of about 32 days since 2000. Does this 

indicate that the agencies are less prepared to manage the fires we have experienced in recent years than they were for the fire activity we experienced during the 

1990s? 

Answer. As a result of the National Fire Plan, the agencies’ fire fighting capability 

expanded. However, the increased capability is being challenged by environmental 

and social changes such as climatic conditions, increased fuels load and expanded 

development in the wildland-urban interface. National Preparedness Levels are influenced significantly by factors associated with large fire activity. We have experienced an increase in acres burned and several years of large, multi-incident complexes. The agency can and has called upon temporary crews from other Federal 

and State agencies, Tribal and local governments, contract crews, Department of 

Defense, and if conditions are extreme, assistance from Canada, Mexico, Australia, 

and New Zealand, using established agreements and protocols to meet fire fighting 

needs. The agency is also reflecting risk management, performance measures, and 

monitoring—both effectiveness and performance—in its allocation, command and 

control decisions. In the face of these challenges, the agency has dedicated additional resources to prepare for wildland fire seasons and has performed consistently 

well, maintaining a high level of initial attack capability and success. 

Question 8. The independent panel report the Forest Service released today calls 

for increased transparency and collaboration in the development Fire Management 

Plans. A similar report made the same recommendation last year. Despite the fact 

that you had said you would act on those recommendations immediately, when I 

asked you about this for the record last year, the agency’s response was basically 

that public participation is unnecessary for fire plans because the public can participate in the development of the broader land management plan. But under the agency’s new planning rule, those land management plans would include only very broad 

guidance, not specific direction—something that the report also identified as problematic. Can you explain why you oppose including the public in the development 

of the Forest Service’s fire management plans? 

Answer. The Forest Service strongly supports public participation in land management decisions, including the role of fire on the landscape. Fire Management 

Plans (FMP) are an operational extension of individual National Forest Land and 

Resource Management Plans. The FMP reflects decisions that are made in the Forest Plan and other documents. We believe that having public participation in land 

management plan revision is the best and proper venue for discussing fire management strategies. The Forest Plan clearly outlines desired conditions, guidelines and 

objectives for the forest and includes fire considerations. The FMP provides informa-
61 

tion on conditions to help fire managers at the time of ignition. The Forest Service 

frequently involves partners and the public in developing FMPs. 

Question 9. Will the Forest Service implement all of the recommendations made 

in the report released today? If not, which recommendations will not be implemented and why? 

Answer. The agency will develop an action plan to implement all of the Panel’s 

recommendations. 

Question 10. A few years ago, the GAO reported serious problems with some firefighting contract crews showing up unfit for duty. Have those problems been fixed? 

Answer. The Forest Service has evaluated these reports and has taken action to 

address recommendations made by GAO. In April 2004, the GAO issued report 

GAO-04-426—BISCUIT FIRE: Analysis of Fire Response, Resource Availability, and 

Personnel Certification Standards, in which it was reported that some insufficiently 

trained or inexperienced contract crews negatively impacted firefighting efforts on 

the Biscuit Fire. GAO also reported that poorly trained and inexperienced contract 

crews presented significant operational concerns. And, in March 2006, the USDA Inspector General issued report No. 08601-42-SF—Forest Service Firefighting Contract Crews. In that report, the IG found that the agency needed to improve contract 

oversight, strengthen training and experience requirements, address control weaknesses at wildfire suppression associations, improve language proficiency assessments, and coordinate with other Federal agencies to identify undocumented workers. The IG issued nine specific recommendations to address these problems. 

The Forest Service agreed with all nine of the recommendations and outlined 

planned actions to address each in the report. Since that time we have acted to implement four of those recommendations (modifying the national contract to incorporate experience requirements, specifying minimum training and experience prerequisites, adopting a standardized field language assessment for contract crews, 

and coordinating with other Government agencies to develop expedited procedures 

for identifying counterfeit documents). Actions required to implement four others 

(establishing and implementing procedures to ensure adequate review of firefighter 

qualification records, verifying that associations’ training sessions receive sufficient 

monitoring to ensure they are in accordance with standards, ensuring that associations restrict privileges to create and modify electronic training records to personnel 

who do not have financial interest in any contractors’ business, and ensuring that 

the PNWCG completes the pre-season language assessment and certification) are 

nearly complete. We continue to work on improved training requirements to meet 

the remaining recommendation. 

Question 11. Is the Forest Service on track to meet all of the timelines stated in 

the June 12, 2008, GS-401 Update briefing paper? If not, which timelines will not 

be met and what is the new timeline? 

Answer. The Forest Service is committed to accomplishing the actions outlined in 

the USDA/USDOI GS-401 Plan, dated June12, 2008. We have amended the Plan to 

include specific deadlines for each activity. The Forest Service has notified every 

employee affected by the qualification change and is working with them to plan to 

achieve the positive educational requirements. The agency is working with universities and colleges to enter into agreements to accept National Wildfire Coordinating 

Group courses within their existing curriculum or to expand their curriculum to accept those courses toward natural resource degrees. 

Question 12. Will the Forest Service pay for leave and tuition and for all of its 

employees that are in GS-401 positions or slated to transition to such position in 

the next two years as necessary to meet the new qualifications? 

Answer. Yes, the Forest Service will support employees to achieve the positive 

education requirements needed to convert to GS-401 Fire Management Specialist 

positions. Our commitment to support employees has been expressed several times. 

In March 2004, a joint Department of Agriculture and Department of the Interior 

White Paper stated, ‘‘IV. Agency support to assist workforce development: The agencies have collectively agreed to provide the funding and opportunities (e.g., training, 

compensated time) for employees in Key Fire Program Positions to meet the minimum qualification requirements of the IFPM Standard.’’ In addition, a March 8, 

2007 letter from Tom Harbour (Director, Fire and Aviation Management) to the 

field stated, ‘‘Financial support of those pursuing 401 position education standards 

should be focused on a land management curriculum.’’ Supervisors will be working 

with each employee to establish an individual development plan to meet these qualifications, if the employee desires, and support will be made available. 
62 

RESPONSE OF MARK REY TO QUESTION FROM SENATOR WYDEN

Mr. Rey and Mr. Cason, in 8 of the last 12 years, the Forest Service has exceeded 

the ten-year average of fire suppression expenditures. This year, the growing cost 

of fire suppression could be driven even higher by the skyrocketing cost of oil. In 

recent years, the Forest Service has frequently ‘‘borrowed’’ money from fire suppression and other programs and currently carries a debt of $509 million. A witness on 

the second panel for the hearing, Mr. Judd, testified that the ‘‘diversion of fuel reduction dollars reduces the number of treated acres’’ and this, in turn, allows many 

small fires to grow in size, intensity and cost. 

Question 13. Don’t your agencies’ money ‘‘borrowing’’ practices divert funds from 

needed preventative fire treatment and increase the costs of firefighting expenses? 

Answer. The practice at the Forest Service is to transfer unobligated balances 

when necessary from non-suppression fire funds that cannot be spent prior to the 

end of the fiscal year to fund emergency fire suppression. Reprogramming a portion 

of these funds demonstrates fiscal discipline and ensures the Forest Service does not 

borrow funds outside the fire account unnecessarily. Further, the Forest Service is 

aware of the need to retain adequate funding to ensure hazardous fuels reduction 

treatments continue at the beginning of the next fiscal year. The Forest Service has 

not used hazardous fuels funds as transfers to the suppression account to cover firefighting expenditures for almost 5 years. The agency has made a conscious decision 

to not use these funds for transfers because of the relationship you’ve noted between 

fuels project work and fire suppression. However, maintain sufficient funds this fiscal year, some hazardous fuels funding was used to cover fire suppression expenditures, including some project funds targeted for the wildland urban interface. 

RESPONSES OF MARK REY TO QUESTIONS FROM SENATOR DOMENICI

In your testimony you state that the Forest Service and Department of Interior 

treated over 26 million acres of their lands from 2001 through May 2008. 

Question 14. What was the total cost to the Forest Service for those treatments 

through that time period? 

Answer. Between 2001 and 2008, the Forest Service funded projects with over $2 

billion specifically targeted to hazardous fuel reduction. In addition, the Forest Service has leveraged efforts from other compatible programs managing vegetation to 

further reduce hazardous fuels while meeting other management objectives. 

Question 15. Can you forecast how many acres will be slated for treatment in FY 

2009? 

Answer. In FY 2009 the Forest Service plans to treat a total of 2.4 million acres 

for hazardous fuel reduction and landscape restoration accomplished through other 

land management activities. We expect approximately 1.6 million acres of treatment 

to be funded out of hazardous fuel reduction accounts, and another 843,000 acres 

of fuel treatment from complimentary vegetation management work done by other 

program areas. 

Question 16. Would you provide the Committee a chart that shows a breakdown 

of the 26 million acres you say were treated since 2001? 

Answer. (See below) 
63 

Question 17. Please include the method of treatment, the percentage of treatments 

that occurred within commercial forest land (stands capable of growing 20 cubic feet 

per year); non-commercial forest lands; and non-forested lands in each region for 

each year. 

Answer. Our data can show where our fuel treatments have been accomplished 

using prescribed fire (65% of our acres) versus mechanical fuel manipulation (35% 

of acres treated). A more detailed determination of what proportion of our mechanical fuels program has been accomplished on commercial forest lands and in various 

vegetation types would require data and analysis that are not available currently. 

We are designing our data systems to include spatial information beginning in FY 

2009, but for the 2001 to 2008 period, we do not have that capability. 

Question 18. Using data provided by the Forest Service, I had my staff analyze 

the acres treated from 2005 through 2007, the amount of wilderness, and the rate 

of escaped fires from 2002 to 2007 for each national forest and region of the National Forest System. This analysis revealed that there are striking differences in 
64 

trends between fuels treatment and escaped fires throughout the National Forest 

System. In Regions 1 and 2 there is, for the most part, a distinguishable trend 

among the amount of wilderness in a forest, the amount of acres treated, and the 

rate of escaped fires. However, in other regions this trend is less apparent. 

In New Mexico, there are several forests that received a moderate amount of 

treatment and have relatively low amounts of wilderness area that still saw their 

escaped fires increase (i.e. Carson, Cibola, Lincoln, Santa Fe). The Cibola National 

Forest in particular is only 22% roadless and/or wilderness, had 2.4% of its acres 

treated, and had a 3.1% increase in escaped fire. 

18.Could you elaborate on what factors led to an increased rate of escaped fire 

despite these forests having an average of nearly 2% of their acres treated? 

Answer. Successful initial attack of unplanned ignitions depends on a variety of 

factors, largely including the condition of the fuels, topography, draught and weather conditions. The availability of suppression resources and access to the burning 

area are also factors. Fuel treatments can change fire behavior and lower resistance 

to control, but the Forest Service treats a very small percentage of the total hazardous fuels in any given year. Time after time we have observed that fuels reductions projects have had a positive affect on fire severity. However, depending on the 

site-specific location and the specific timing of a given fire, weather and topography 

can overwhelm the influence of fuel conditions on fire behavior. Our ability to predict when and where a fire will start is obviously limited, so fuel treatments are 

located in areas where we have the greatest chance for success and adjacent to valuable resources and assets that require additional protection. 

Question 19. Please provide the annual fuels treatment funding for these forests 

from 2005 to 2007 and an explanation of how this compares to the rest of the NFS. 

Answer. (See below) 

Question 20. Could you elaborate on why, as a whole, Region 3 saw an increase 

in escaped fire even though it has considerably less wilderness than other western 

regions and treated a comparable amount of its acreage? 

Answer. There is not a clear linear relationship between the amount of wilderness 

and initial attack success. The ‘‘increase’’ could be attributed to variable climates 

and random events like lightning/thunderstorms with wildly variable spatial and 

temporal characteristics. 

Question 21. It appears that Region 2 saw the largest decrease in escaped fire by 

a considerable margin (5.38%, Region 5 was the next closest with a 0.75% decrease). 

Please elaborate on the factors that occurred in Region 2 during this time period 

that allowed such a decrease in the rate of escaped fire. 

Answer. Overall the period from 2001 to 2007 included average to below average 

fire seasons, with 2002 being an above average year anomaly. Short periods of 

drought existed in isolated areas across the geographic area along with periods of 

higher snow pack. Difficult fires appear to have occurred when dry conditions coincided with heavy, dry fuel conditions. This can be seen in the instance of the 

Hayman fire during the hot, dry 2002 fire season. Prior to the 2001 fire season, the 

five year average for fire conditions seems to have been drier, with a higher resistance to control and thus more escapes. 

Beginning in the mid 1990’s the Region, in cooperation with its partners, developed a strong fire prevention message that emphasized Firewise protective measures near State and private land. This program raised the visibility of the fire problem in the wildland-urban interface, particularly on the Front Range, and promoted 

increased cooperation with its partners. This greater cooperative effort surely helped 

to increase the efficiency of the initial attack response. 

Finally, the 2001 fire season was the first to benefit from the National Fire Plan 

which was established in August of 2000. The emphasis during the first three years 

of the plan was to improve the initial attack capability through the increased staffing of the fire preparedness organization. The fire and fuels conditions, coupled with 

the management actions of the Region and its partners, additional resources also 

contributed to the improved initial attack success of the Region. 
65 

Question 22. You stated in your testimony that there is expected to be ‘‘above normal significant fire potential’’ in the Rocky Mountains for the 2008 wildfire season. 

What was the forecasted fire potential for this region during the time period 

(2002-07) that escaped fires decreased? 

Answer. As stated above, 2001 to 2007 was considered average to below average 

fire seasons, with 2002 being an above average year anomaly. Please reference question 23 for a summary of the annual significant fire potential outlooks. 

Question 23. Please also provide a comparison of your potential fire forecast for 

the Rocky Mountain region vs. what actually occurred each year from 2002—2007. 

Answer. Verification of the monthly and seasonal outlooks has proved to be difficult since fires occur only if there is an ignition source. In the west, ignitions primarily come from lightning, however human caused fires also account for some of 

the more significant fires. Consequently, if pre-disposing conditions exist (e.g. dry 

fuels, hot temperatures, low relative humidity, and winds), but there are no ignitions, there will be no fire even though the potential was there. Below is a comparison of the early season ‘‘significant fire potential’’ outlook and the reported fire activity. 

Question 24. Could you estimate how much funding for fuels treatment in Region 

2 will be allocated in FY 2009 by forest or grassland? 

Answer. (See below) 

Question 25. How does this compare to the funding it received from 2002 to 2007 

for fuels treatment? 

Answer. (See below) 
66 

Regions 8 and 9 have comparable amounts of wilderness/roadless area (14.5% and 

17.8% respectively), yet Region 8 treated approximately 10 times as many acres as 

Region 9. 

Question 26. How do you explain such a drastic difference in treated acres between the two eastern regions? 

Answer. The natural resource character, land use history and management requirements of the two regions are very different. Region 8 with its milder winters, 

longer growing seasons, and generally more gentle topography create an excellent 

environment for successful prescribed burning. Forest ecosystems in Region 8 are 

adapted to frequent fire disturbance, creating a need for frequent burning or other 

vegetative manipulation to meet hazardous fuel reduction and ecological restoration 

and maintenance objectives. Public acceptance of prescribed fire in the southeastern 

U.S. is very strong, in contrast to the reluctance toward burning that is common 

in much of the rest of the country. In the northeastern Region 9, the cooler climate 

supports different vegetation types that are less fire adapted, less fire prone, and 

have different management needs. 

Question 27. How does fuels treatment funding for these two regions compare to 

the rest of the National Forest System? 

Answer. (See below) 

Question 28. Could you breakdown your costs for outside fire fighters, overhead 

personnel, caterers or other service providers by: California fire crews, other Statesupplied fire crews, and outside contract crews, caterers, or other service providers? 

Answer. The Forest Service does not track these specific costs at a national scale. 

Information on aspects of these costs could be obtained, but would require a national data call to the field and additional analysis. Please reference question 31 for 

additional information. 

Question 29. Please describe how the Forest Service currently allocates funding 

for fuels treatment to the NFS. Does it take into account past fire frequency and 

intensity? 

Answer. The allocation of hazardous fuel dollars is based on a combination of 

need, ability and opportunity. The Forest Service uses the Hazardous Fuels 

Prioritization Allocation System to determine regional priority for hazardous fuel reduction funding. The criteria to determine priority include: 

• Wildfire Potential—Fuels potential, weather potential, historical fire occurrence 
67 

• Negative Consequence (values at risk)—Wildland Urban Interface (WUI), timber, emissions, ecosystem vulnerability, municipal water supply • Performance—Proportion of prior-year WUI program associated with Community Wildfire Protection Plans, proportion of recent year’s program using 

Healthy Forests Restoration Act and Healthy Forests Initiative authorities, 

maintenance acres • Opportunities—Restoration needs (FRCC), biomass, insect and disease risk 

These factors are taken together using a tool developed by the Pacific Northwest 

Research Station with methodology that uses existing, nationally-consistent 

geospatial information to prioritize Regions for Hazardous Fuels Reduction program 

funding. 

Question 30. During the last two fire seasons (2006 and 2007), how many nonfederal firefighters—state and/or private—did your agencies utilize to assist firefighting efforts? 

Answer. In calendar year 2006 and 2007 the five federal wildland fire agencies 

(the US Forest Service of the Department of Agriculture and the National Park 

Service, the Bureau of Land Management, the Fish and Wildlife Service, and the 

Bureau of Indian Affairs of the Department of the Interior) were assisted by 21,266 

non-federal firefighters. Please reference the table below for more detailed information, including data limitations. 

Question 31. How much did these outside firefighters cost your agencies in 2007? 

Answer. The Forest Service does not track specific salary costs for non-federal 

firefighters at the national level. In FY 2007, total cooperator costs were $159 million—these costs included personnel, travel, equipment, aircraft and other costs related to fire fighting services. Total contractor costs were $362 million—these costs 

were comprised of personnel and equipment for items such as crews, engines, heavy 

equipment, caterers, showers, etc. 

Question 32. What proportion of the total suppression cost does this represent for 

each of your agency? 

Answer. In FY 2007, cooperators accounted for approximately 12% of suppression 

costs and contracts, exclusive of aviation contracts, accounted for approximately 26% 

of suppression costs. Combined, they accounted for 38% of Forest Service costs. 

Question 33. One of the witnesses expressed his opinion that the Forest Service 

and Department of Interior should pay their firefighters on a ‘‘portal-to-portal’’ system, similar to the State of California’s Department of Forestry and Fire Protection 

(CAL-FIRE). 

How much might it cost to pay Forest Service and Interior firefighters for twentyfour hours a day while they are on a fire assignment? 

Answer. It is important to note that the cost to pay Forest Service firefighters for 

twenty-four hours a day can vary quite a bit depending upon the criteria for how 

portal-to-portal pay is calculated. 

In 2005, an analysis was completed on the estimated cost of implementing HR 

408, ‘‘Federal Wildland Firefighter Emergency Response Act of 2005’’, a bill that 

proposed a ‘‘portal-to-portal’’ pay system for certain wildland firefighting positions. 

This analysis concluded that 30-40 percent of the total Forest Service wildland fire 

suppression expenditures were personnel costs. It estimated, on average, an individual firefighters’ pay would be increased by 42 percent when in time with hazard 
68 

pay and 28 percent when in time without hazard pay. In total the increase to personnel costs in suppression expenses would be about 8.2 percent. 

Currently, personnel costs still average between 30-40 percent. Using this same 

analysis and the total suppression costs in 2007 of $1.4 billion, a portal-to-portal pay 

system, similar to the one proposed in HR 408, would increase the Forest Service 

suppression costs by approximately $115 million. 

Question 34. How would a shift to portal-to-portal pay for federal agencies affect 

the ability of the states (outside California) to maintain state firefighting crews? 

Answer. We would not anticipate that implementing portal-to-portal pay for federal firefighters would affect the states’ ability to maintain firefighting crews. The 

potential increased firefighter pay may enhance the desirability of a federal position, 

but without an increase in the number of firefighter positions, the effect should not 

be significant. 

Question 35. In your estimation, would a federal portal-to-portal pay system make 

it too expensive for some states to field wildland firefighting crews? 

Answer. There would be an increase in costs to states from a federal portal-toportal pay system. The increase would be applicable for federal salaries in support 

of state incidents. Approximately 15% of federal costs on state incidents are associated with federal employee’s base and overtime salary. The impact to states by this 

increase is unknown. It may be negligible for some States while others may find 

it cost-prohibitive to use federal firefighters on State fires. 

Question 36. If a portal-to-portal pay system were implemented for federal crews, 

would they still be required to pay overtime to those crews after they have worked 

their normal 8 hour shift? 

Answer. Under a portal-to-portal pay compensation system, wildland firefighters 

would not receive overtime after an 8 hour shift. This is evident both in the special 

overtime standard established as part of Section 7(k) of the Fair Labor Standards 

Act (FLSA) for non-exempt structural firefighters as well as by a number of Congressional bills that have recently been proposed for wildland firefighters. 

Currently only structural firefighters classified in the GS-081 series that provide 

round-the-clock fire protection at certain DOD military installations receive portalto-portal pay under Section 7(k) of the FLSA. They typically work 24-hour shifts 

within limited geographic areas of responsibility that include sleep, meals, and other 

personal standby time. Most have a 72-hour workweek consisting of three 24-hour 

shifts because sleep and personal time is included in their duty shift. Under FLSA 

Section 7(k), GS-081 firefighters have no overtime pay until they have worked 53 

hours in a week or 106 hours in a biweekly pay period. As a result, non-exempt GS081 firefighters at the grades GS-5 through GS-9 receive a lower hourly rate of basic 

pay than other employees such as our wildland firefighters. 

Question 37. Would you continue to pay hazard pay or Sunday differential payments? 

Answer. Generally, under a portal-to-portal pay system, we believe that wildland 

firefighters would not receive hazard pay or Sunday differential payments. Hazard 

pay is currently not payable to GS-081 structural firefighters receiving portal-to-portal pay under Section 7(k) of the FLSA, since the typical hazards of firefighting are 

already taken into account in the classification of their job by the Office of Personnel 

Management. 

Question 38. Can you estimate how many state or private contract firefighters you 

might lose if a portal-to-portal pay system were implemented? 

Answer. There is no way to estimate reliably such potential losses. 

Question 39. If the federal agencies where forced to pay on a portal-to-portal basis 

and fire suppression and fire preparedness budgets remain static: relative to 2007 

or 2008 how many additional, non-federal fire crews would you have to hire to maintain your 97% initial attack success rate? 

Answer. Implementation of a portal-to-portal pay system would not impact our 

initial attack success rate, nor would it require the recruitment of additional nonfederal fire crews. Our ability to contain fires during the initial attack phase is more 

directly influenced by our preparedness capability. 

Question 40. Mr. Casey Judd of the Federal Wildland Fire Service Association 

made some pointed accusations about mismanagement of the federal fire fighting 

agencies and their management of fire funding. 

Please review his written testimony and respond to his charges about your agencies’ management of funding and the fire program. 

Answer. The Forest Service takes these statements regarding management of 

funding and the fire program very seriously. We believe they are not based on data 

or credible analysis. The Department has requested that the USDA Office of the Inspector General look into the allegations by Mr. Judd to determine their validity. 
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The agency will await the outcome of the inquiry and take corrective action if necessary, based on findings of the IG. 

[Responses to the following questions were not received at the 

time the hearing went to press:] 

QUESTIONS FOR JAMES CASON FROM SENATOR BINGAMAN

Question 1. Last year, Senator Cantwell, Senator Domenici, and I introduced a 

bill to help cover a portion of personal liability insurance costs for Federal firefighters, and Senators Feinstein and Craig helped to get that enacted through the 

Interior Appropriations bill. Can you tell me whether the Department currently is 

using that authority to help cover those costs for all of its firefighters that elect to 

get that insurance? 

Question 2. Please describe what each agency in the Department of the Interior 

is doing to assist employee’s achieve the necessary accredited courses to continue 

their current 401 job series positions? 

Question 3. How will DOI agencies ensure that the valuable fire management experience is not lost for those employee’s who cannot achieve the newly required positive education credits within the allowed timeframe? 

Question 4. How do you plan to support the career progress and aspirations for 

those employees who are caught in the firefighter qualifications issue and at no 

fault of their own, especially those with considerable fire management experience? 

Question 5. Is the Department on track to meet all of the timelines stated in the 

June 12, 2008, GS-401 Update briefing paper? If not, which timelines will not be 

met and what is the new timeline? 

Question 6. Will the Department pay for leave and tuition and for all of its employees that are in GS-401 positions or slated to transition to such position in the 

next two years as necessary to meet the new qualifications? If not, why not and how 

will it decide which employees should receive such support? 

QUESTIONS FOR JAMES CASON FROM SENATOR WYDEN

Question 7. Mr. Cason, in 8 of the last 12 years, the Forest Service has exceeded 

the ten-year average of fire suppression expenditures. This year, the growing cost 

of fire suppression could be driven even higher by the skyrocketing cost of oil. In 

recent years, the Forest Service has frequently ‘‘borrowed’’ money from fire suppression and other programs and currently carries a debt of $509 million. A witness on 

the second panel for the hearing, Mr. Judd, testified that the ‘‘diversion of fuel reduction dollars reduces the number of treated acres’’ and this, in turn, allows many 

small fires to grow in size, intensity and cost. 

a.Don’t your agencies’ money ‘‘borrowing’’ practices divert funds from needed preventative fire treatment and increase the costs of firefighting expenses? 

Question 8. As discussed in the hearing, your agencies’ contracts for firefighting 

airplanes and helicopters are negotiated annually; I brought up a question about the 

rising cost of fuel and impacts on firefighting abilities of airplane and helicopter contractors who are unable to offset these cost. Mr. Cason, you stated that your contracts have built in ‘‘escalators’’ that provide for increased fuel prices. According to 

the Department of Energy’s statistics, one year ago the average price of diesel fuel 

was $2.90 per gallon. The June 2008 average price of diesel fuel is $4.70 per gallon 

and currently the price trend continues to increase. We have seen a 62% increase 

when comparing June 2007 diesel fuel prices to June 2008 prices. 

a.Does your contract ‘‘escalator’’ mechanism for fuel prices take into consideration 

a 62% increase in fuel prices? If your ‘‘escalator’’ truly compensates for these type 

of rising fuel prices, then why did you state during your testimony that at the ‘‘end’’ 

of the fire season your agency may need to borrow money from other programs to 

pay for increased fuel cost? 

b. Will the higher cost of aviation fuel mean reduced firefighting resources? 

c. Finally, as mentioned above, will your ‘‘borrowing’’ practices increase the ability 

of many small fires to grow in size, intensity and cost due to the diversion of funds 

from preventative fire treatment programs? 

QUESTIONS FOR JAMES CASON FROM SENATOR DOMENICI

Question 9. During last year’s fire season, how many non-federal firefighters— 

state and/or private—did your agencies utilize to assist firefighting efforts? 

Question 10. How much did these outside firefighters cost your agencies in 2007? 
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Question 11. Could you break those costs out by California crews or overhead, 

other States supplied crews or overhead, and outside contract crews, caterers, or 

other service providers? 

Question 12. What proportion of the total suppression cost does this represent for 

your agencies? 

Question 13. One of the witnesses expressed his opinion that the Forest Service 

and Department of Interior should pay their firefighters on a ‘‘portal-to-portal’’ system, similar to the State of California’s Department of Forestry and Fire Protection 

(CAL-FIRE). 

How much might it cost to pay Interior firefighters for twenty-four hours a day 

while they are on a fire assignment per season? 

Question 14. How might a shift to portal-to-portal pay affect the ability of the 

state firefighting crews—outside of California—to participate in federal fires? Could 

it result in some states choosing to forgo fielding wildland fire crews? 

Question 15. In your estimation, would a portal-to-portal pay system make 

wildland firefighting too expensive for some states? 

Question 16. If a portal-to-portal pay system were implemented, would there be 

any logic for paying overtime? 

Question 17. Can you estimate how many state or private contract firefighters you 

might lose if a portal-to-portal pay system were implemented? 

Question 18. If the federal agencies are forced to pay on a portal-to-portal basis 

and fire suppression and preparedness budgets remain static: relative to 2007 or 

2008 how many additional, non-federal fire crews would you have to hire to maintain your 97% initial attack success rate? 

Question 19. Mr. Casey Judd of the Federal Wildland Fire Service Association 

made some pointed accusations about mismanagement of the federal fire fighting 

agencies and their management of fire funding. 

Please review his written testimony and respond to his charges about your agencies’ management of funding and the fire program. 

Æ