Testimony

Before the Subcommittee on Forests and Forest

Health, Committee on Resources, House of

Representatives

United States General Accounting Office

GAO

For Release on Delivery

Expected at 3:00

Tuesday, July 31, 2001 THE NATIONAL FIRE

PLAN

Federal Agencies Are Not

Organized to Effectively

and Efficiently Implement

the Plan

Statement of Barry T. Hill

Director, Natural Resources and Environment

GAO-01-1022T
Page 1 GAO-01-1022T The National Fire Plan

Mr. Chairman and Members of the Subcommittee:

We are here today to discuss the results of our preliminary work for you

on the implementation of the National Fire Plan. The National Fire Plan is

not a single, cohesive document. Rather, it is composed of various

documents, including (1) a September 8, 2000, report1

 from the Secretaries

of the Interior and of Agriculture to the President of the United States in

response to the wildland fires in 2000; (2) congressional direction

accompanying substantial new appropriations for wildland fire

management for fiscal year 2001; and (3) several approved and draft

strategies to implement all or parts of the plan.

In addition, the 1995 federal wildland fire management policy,2

 updated in

2001,3

 provides the philosophical and policy foundation for federal

interagency fire management activities conducted under the National Fire

Plan. Incorporating the policy's guiding principles and recommendations

into the plan presents unusual, if not unique, challenges to traditional

organizational structures. Wildland fires do not recognize the

administrative boundaries of federal land units. Therefore, the policy

requires coordination, consistency, and agreement among five federal land

management agencies in two departments—the National Park Service, the

Fish and Wildlife Service, the Bureau of Land Management, and the

Bureau of Indian Affairs within the Department of the Interior and the

Forest Service within the Department of Agriculture. Moreover, an

effective strategy to reduce the risk of wildland fire requires a full range of

fire management activities, including management-ignited fires

(prescribed fires) and other fuel treatments, such as thinning. Therefore,

the policy requires an interdisciplinary approach in which federal fire

managers must forge new working relationships with other disciplines

 1 Managing the Impact of Wildfires on Communities and the Environment, A Report to

the President In Response to the Wildfires of 2000, Secretaries of the Interior and of

Agriculture (Sept. 8, 2000).

2 Federal Wildland Fire Management Policy and Program Review, Report to the

Secretaries of the Interior and of Agriculture by an Interagency Federal Wildland Fire

Policy Review Working Group (Dec. 18, 1995).

3 Review and Update of the 1995 Federal Wildland Fire Management Policy, Report to the

Secretaries of the Interior, of Agriculture, of Energy, of Defense, and of Commerce; the

Administrator, Environmental Protection Agency; and the Director, Federal Emergency

Management Agency, by an Interagency Federal Wildland Fire Policy Review Working

Group (Jan. 2001).
Page 2 GAO-01-1022T The National Fire Plan

within the agencies, including those responsible for wildlife and fisheries

and vegetation and watershed management.

Federal and state officials estimate that $30 billion will be needed over the

next 10 years to implement the National Fire Plan. Toward this end, the

Congress appropriated almost $2.9 billion for Wildland Fire Management

for fiscal year 2001. At your request, we are reviewing whether the five

federal land management agencies are spending this money in an efficient,

effective, and timely manner. To date, we have focused our work primarily

on efforts to reduce dangerous accumulations of hazardous fuels and

firefighting management and preparedness.

In summary, the preliminary information we have gathered to date

suggests the following:

• Human activities, especially the federal government's decades-old policy

of suppressing all wildland fires, including naturally occurring ones, have

resulted in dangerous accumulations of hazardous fuels on federal lands.

As a result, conditions on 211 million acres, or almost one-third of all

federal lands, continue to deteriorate. According to the federal wildland

fire management policy, these conditions have increased the probability of

large, intense wildland fires beyond any scale yet witnessed. Coupled with

the explosive growth of people and structures in areas where human

development meets or intermingles with undeveloped wildland—the

wildland-urban interface—these fires will, in turn, increase the risk to

communities, watersheds, ecosystems, and species. They will also place in

jeopardy the lives of the public as well as the lives of the firefighters

charged with controlling or suppressing them.

• The National Fire Plan represents the latest effort to address wildland fire

on federal lands. Two conditions set this effort apart from prior efforts to

reduce the risk of wildland fire: (1) congressional committee recognition

of the need to sustain increased funding for wildland fire management in

future fiscal years and (2) congressional committee direction to reduce the

risk of wildland fire in the wildland-urban interface. However, although

the federal wildland fire management policy is intended to provide the

policy foundation for the National Fire Plan, many of the policy's guiding

principles and recommendations—especially those that present challenges

to traditional organizational structures—have not been implemented.

Lacking the coordination, consistency, and agreement called for in the

federal wildland fire management policy, the five federal land management

agencies cannot ensure, among other things, that they (1) are allocating

funds to the highest-risk communities and ecosystems, (2) are adequately
Page 3 GAO-01-1022T The National Fire Plan

prepared to fight wildland fires in 2001, and (3) can account accurately for

how they spend the funds and what they accomplish with them.

• The failure of the five federal land management agencies to incorporate

into the National Fire Plan many of the federal wildland fire management

policy's guiding principles and recommendations can be traced to their

reluctance to change their traditional organizational structures of federal

wildland fire management. As a result, the five agencies continue to plan

and manage wildland fire management activities primarily on an agencyby-agency and unit-by-unit basis. Moreover, although implementing the

National Fire Plan in an efficient, effective, and timely manner will require

an interdisciplinary approach, federal fire managers and managers in other

disciplines within the agencies—including those responsible for wildlife

and fisheries and vegetation and watershed management—have been

reluctant to forge the necessary new working relationships.

For a number of years, both the Congress and the administration have

been made aware of the increasingly grave risk of wildland fire posed by

the buildup of brush and other hazardous vegetation on federal lands.

The 1988 wildland fires that burned Yellowstone National Park and

millions of acres of other public and private land resulted in a 1994 report

by the statutorily established National Commission on Wildfire Disasters.4

The Commission stated:

"The vegetative conditions that have resulted from past management policies have created

a fire environment so disaster-prone in many areas that it will periodically and tragically

overwhelm our best efforts at fire prevention and suppression. The resulting loss of life and

property, damage to natural resources, and enormous costs to the public treasury, are

preventable. If the warning in this report is not heeded, and preventative actions are not

aggressively pursued, the costs will, in our opinion, continue to escalate."

The Commission observed: "The question is no longer if policy-makers will

face disastrous wildfires and their enormous costs, but when." The when

came that very year. The 1994 fire season resulted in 34 fatalities, including

14 firefighters on Storm King Mountain in Colorado. These deaths, coupled

with a growing recognition of the fire problems caused by the

 4 Report of the National Commission on Wildfire Disasters (1994). The National

Commission on Wildfire Disasters was established on May 9, 1990, by the Wildfire Disaster

Recovery Act of 1989 (Pub. L. No. 101-286).

Conditions on Federal

Lands Continue to

Deteriorate
Page 4 GAO-01-1022T The National Fire Plan

accumulation of hazardous fuels, resulted in the first comprehensive

federal wildland fire management policy for the departments of the

Interior and of Agriculture. The December 1995 policy stated:

"The challenge of managing wildland fire in the United States is increasing in complexity

and magnitude. Catastrophic wildfire now threatens millions of wildland acres, particularly

where vegetation patterns have been altered by past land-use practices and a century of

fire suppression. Serious and potentially permanent ecological deterioration is possible

where fuel loads exceed historical conditions. Enormous public and private values are at

high risk, and our nation's capability to respond to this threat is becoming overextended."

In the aftermath of the escape of a prescribed fire at Cerro Grande, New

Mexico, in May 2000, the Secretaries of the Interior and of Agriculture

requested a review of the 1995 federal wildland fire management policy

and its implementation. According to the 2001 update, as a result of

excluding fire from federal lands, conditions on these lands continue to

deteriorate. The update observed that the fire hazard situation is worse

than previously understood and stated:

"The task before us—reintroducing fire—is both urgent and enormous. Conditions on

millions of acres of wildland increase the probability of large, intense fires beyond any

scale yet witnessed. These severe fires will in turn increase the risk to humans, to property,

and to the land upon which our social and economic well being is so intimately

intertwined."

The 2001 policy update also observed that the fire hazard situation in the

wildland-urban interface is more complex and extensive than was

understood in 1995. According to the update, the explosive growth in the

wildland-urban interface now puts entire communities and associated

infrastructure, as well as the socioeconomic fabric that holds communities

together, at risk from wildland fire. The update concluded that the fire

problem in the wildland-urban interface would continue to escalate as

people continue to move from urban to wildland areas in the twenty-first

Century.
Page 5 GAO-01-1022T The National Fire Plan

The National Fire Plan represents the latest effort to address wildland fire

on federal lands. Two conditions set this effort apart from prior efforts to

reduce the risk of wildland fire: (1) congressional committee recognition

of the need to sustain increased funding for wildland fire management in

future fiscal years and (2) congressional committee direction to reduce the

risk of wildland fire in the wildland-urban interface. However, although

the federal wildland fire management policy is intended to provide the

policy foundation for the National Fire Plan, many of the policy's guiding

principles and recommendations—especially those that present challenges

to traditional organizational structures—have not been implemented.

Lacking the coordination, consistency, and agreement called for in the

federal wildland fire management policy, the five federal land management

agencies cannot ensure, among other things, that they (1) are allocating

funds to the highest-risk communities and ecosystems, (2) are adequately

prepared to fight wildland fires in 2001, and (3) can account accurately for

how they spend the funds and what they accomplish with them.

The Department of the Interior and Related Agencies Appropriations Act

for Fiscal Year 2001 required the Secretaries of the Interior and of

Agriculture, after consultation with state and local firefighting agencies, to

publish jointly in the Federal Register a list of all urban-wildland interface

communities, as defined by the Secretaries, within the vicinity of federal

lands that are at high risk from wildfire, as defined by the Secretaries.

Despite this directive, the five federal land management agencies currently

do not know how many communities are at high risk of wildland fire,

where they are located, or what it will cost to lower the risk. Therefore,

they cannot set priorities for treatment or inform the Congress about how

many will remain at high risk after appropriated funds are expended.

Prior to publishing an initial list of communities, the Secretaries of the

Interior and of Agriculture did not define either "urban-wildland interface

communities" or "within the vicinity of federal lands that are at high risk

from wildfire." On January 4, 2001, the Secretaries published an initial list

in the Federal Register of 4,395 communities. However, as stated in the

notice, (1) 11 states did not respond or did not have lists of communities

available, (2) 5 states indicated that they did not have any at-risk

communities, and (3) each of the 34 states that did identify communities

used "criteria it determined appropriate for selecting communities at risk."

In February 2001, Interior and the Forest Service issued guidance intended

to refine and narrow the initial list of communities. The guidance defined

wildland-urban interface. It also identified three criteria for evaluating the

Implementation of the

National Fire Plan

Lacks the

Coordination,

Consistency, and

Agreement Called for

in the Federal

Wildland Fire

Management Policy

Highest-Risk Communities

Have Not Been Identified

Here is what we have learned

to date.
Page 6 GAO-01-1022T The National Fire Plan

risk to wildland-urban interface communities (fire behavior potential; risk

to social, cultural, and community resources; and fire protection

capability) and risk factors relating to each criterion. In addition, the

guidance included a discussion of fire behavior potential that provided

some general information on identifying fire risk. However, the guidance

did not specifically identify federal lands that are at high risk from

wildland fire rendering it difficult to identify urban-wildland interface

communities within the vicinity of such lands. Without this definition and

with the criteria and risk factors subject to broad interpretation by the

states, the list of at-risk communities ballooned to over 22,000 in May 2001.

In addition, two states with lands in the fire-prone interior West—

California and Idaho—did not revise their initial lists of communities on

the basis of the February guidance, stating that all of their communities on

the initial list should be considered high-risk.

At that time, the Secretaries of the Interior and of Agriculture said they

intended to continue to work collaboratively with states, tribes, local

leaders, and other interested parties to identify and set priorities for

specific treatment projects. However, rather than continue to work toward

a jointly published list of communities, Interior and the Forest Service

went their separate ways.

From the list of over 22,000 communities, Interior has identified 545

communities near its lands that it determined to be at "highest risk" by

assigning numeric values to the risk factors in the February 2001 guidance.

However, 278—or over half—of the communities are in three southeastern

states—Georgia, North Carolina, and Tennessee—that are not prone to

severe wildland fires. Conversely, since California and Idaho did not revise

their initial lists of communities on the basis of the February guidance,

Interior did not include any communities in these two fire-prone states.

(See app. I and II.)

Meanwhile, by October 2001, the Forest Service plans to develop its own

separate list of highest-risk communities from the list of over 22,000.

However, it plans to allow its nine regional offices to work individually

with states within their boundaries to develop nine separate lists of

highest-risk communities.
Page 7 GAO-01-1022T The National Fire Plan

In the interim, a group of federal, state, and private individuals has

prepared a draft 10-year strategy to implement the National Fire Plan.5

This draft strategy emphasizes not only locally driven priority-setting but

also locally driven budget development, project planning and

implementation, monitoring, and reporting. However, without nationwide

criteria to differentiate risks among wildland-urban interface communities

in different states and geographical regions, the National Fire Plan will

become little more than a funding source that will not allow for

accountability at the national level and will not ensure that federally

appropriated funds are being spent in those wildland-urban interface

communities at the highest risk of wildland fire.

The coordination, consistency, and agreement required by the federal

wildland fire management policy is also missing from efforts by Interior

and the Forest Service to ensure that the nation is fully prepared to fight

future wildland fires.

For instance, the five federal land management agencies cannot agree on

the priority to be given to preparing fire management plans. Since 1995,

federal wildland fire management policy has required that every federally

managed area with burnable vegetation must have an approved fire

management plan. These plans are critical to determining preparedness

needs for fighting wildland fires because they identify, among other things,

which wildland fires should be suppressed and which should be allowed to

burn. However, 6 years later, only the 60 units managed by the Bureau of

Land Management have fully complied with the policy. Of the remaining

1,323 units managed by the other four federal land management agencies,

768—or 58 percent—still do not have a plan that complies with the policy.

These 768 units encompass about 121 million acres—or 31 percent—of all

the acres with burnable vegetation managed by the four agencies. (See

app. III.) Moreover, although wildland fire does not recognize the

administrative boundaries of federal land units, federal fire management

plans have been, and continue to be, prepared on a unit-by-unit basis.

Similarly, rather than using one computer model to identify their firepreparedness needs, the five federal land management agencies use three

different models. The Forest Service, the Bureau of Land Management,

 5 A Collaborative Approach for Reducing Wildfire Risks To Communities and the

Environment: Ten-Year Comprehensive Strategy (Draft for Signature)(May 2001).

Neither the Forest Service

Nor Interior Is Fully

Prepared to Fight Future

Wildland Fires
Page 8 GAO-01-1022T The National Fire Plan

and the Bureau of Indian Affairs use one model to determine their

preparedness needs, the National Park Service uses another, and the Fish

and Wildlife Service uses a third. Moreover, we have concerns about all

three models because they (1) do not consider conditions on non-federal

lands in the wildland-urban interface and elsewhere, and (2) stop at the

administrative boundaries of land units as opposed to providing the

broader-scale planning embraced in the federal wildland fire management

policy.

Further, using the existing fire preparedness models, all five of the federal

land management agencies requested funds to hire, develop, and support

additional fire managers and firefighters, and all five have made

substantial progress in hiring the additional personnel. (See app. IV.)

However, in addressing firefighting equipment needs, it is a different story.

Even though the Congress gave the agencies the opportunity to request the

equipment needed to be fully prepared to fight future wildland fires, the

agencies did not identify their funding needs in a coordinated or consistent

fashion. Instead, each agency identified its own equipment needs. Two of

the agencies—the Forest Service and the Fish and Wildlife Service—did

not request the funding needed to procure the firefighting equipment

called for in their existing fire preparedness models. So for these two

agencies it is not clear when they will reach the firefighting capacity

envisioned with the funding provided for fiscal year 2001. The Forest

Service failed to ask for about $44 million that it needs to procure

hundreds of pieces of equipment, including fire engines, bulldozers, water

tenders, and trucks, as well as associated supplies. According to the Fish

and Wildlife Service, it was not aware that it was supposed to request

about $8 million that it needs to procure about 90 pieces of firefighting

equipment.

Lack of coordination, consistency, and agreement among the five federal

land management agencies extends to how they plan to measure

accomplishments and how they account for funds.

For instance, to ensure that the National Fire Plan accomplishes its

intended goals and objectives, the federal wildland fire management policy

requires federal agencies to establish and implement a clear, concise

system of accountability. However, Interior has not established any

quantifiable long-term or annual performance measures to gauge its

progress in reducing hazardous fuels. Conversely, the Forest Service plans

to measure and report on (1) the percent of wildland-urban interface areas

with completed fuels treatments and (2) the percent of all acres with fuel

Lack of Coordination,

Consistency, and

Agreement Extends to

How Accomplishments

Are Measured and How

Funds Are Accounted For
Page 9 GAO-01-1022T The National Fire Plan

levels meeting "condition class 1;" that is, where human activities have not

significantly altered historical fire regimes or where management activities

have successfully maintained or restored ecological integrity.

Similarly, Interior and the Forest Service are using different measures to

gauge their progress toward being fully prepared to fight future wildland

fires. Interior measures the percent of wildland fires contained during

initial attack while the Forest Service measures the amount of firefighting

resources that it can make available to fight a wildland fire.

Interior and the Forest Service also do not consistently account for how

they spend funds appropriated for wildland fire preparedness and

suppression. Prior to fiscal year 2001, both Interior and Forest Service

personnel normally assigned to managerial, administrative, and other staff

positions in their wildland fire management programs charged the first 8

hours of every workday to funds allocated for firefighting preparedness,

even when they were assigned to fighting wildland fires. However,

beginning with fiscal year 2001, all Forest Service personnel assigned to

fighting wildland fires now charge their entire time to funds allocated for

firefighting suppression. Although our ongoing work has not determined

which is more appropriate, the Forest Service's accounting change will

reduce funds charged to preparedness and increase funds charged to

suppression, in comparison with prior years and Interior's accounting for

its funds allocated for similar activities. As a result, the Congress has no

consistent basis for holding Interior and the Forest Service accountable.

According to the 2001 update, the failure to fully implement the 1995

federal wildland fire management policy resulted, in part, from the lack of

an entity with the authority to provide the necessary strategic direction,

leadership, coordination, conflict resolution, and oversight and evaluation

to the full range of affected agencies and disciplines. Although it is early in

the implementation of the National Fire Plan, it is clear that its

implementation also suffers from the lack of such an entity.

The five federal land management agencies have been reluctant to change

their traditional organizational structures of federal wildland fire

management. Because of this reluctance, they have failed to incorporate

into the National Fire Plan many of the federal wildland fire management

policy's guiding principles and recommendations. As a result, the five

agencies continue to plan and manage wildland fire management activities

primarily on an agency-by-agency and unit-by-unit basis. Moreover,

although implementing the National Fire Plan in an efficient, effective, and

Effective

Implementation of the

National Fire Plan

May Require Changes

to Interior's and the

Forest Service's

Existing

Organizational

Structures
Page 10 GAO-01-1022T The National Fire Plan

timely manner will require an interdisciplinary approach, federal fire

managers and managers in other disciplines within the agencies—

including those responsible for wildlife and fisheries and vegetation and

watershed management—have been reluctant to forge the necessary new

working relationships.

From a budgetary perspective, this continuation of a narrowly focused,

stovepipe approach will mean that funds appropriated for wildland fire

management may not be used in an efficient, effective, and timely manner.

There may be human consequences as well. For instance, the failure to

allocate funds for fuels reduction to the highest-risk communities and

ecosystems increases future risks not only to those communities and

ecosystems, but also to firefighters charged with controlling and

suppressing wildland fires.

We are continuing our review of the implementation of the National Fire

Plan. However, we agree with the federal wildland fire management policy

that the federal land management agencies must take action now to

resolve the wildland-urban interface problem. We would encourage the

administration and the Congress to consider all of the alternative

organizational structures identified in the policy, including establishing a

single federal wildland fire management entity with the authority to

provide the necessary strategic direction, leadership, coordination,

conflict resolution, and oversight and evaluation to the full range of

affected agencies and disciplines.

Mr. Chairman, this concludes my formal statement. I will be pleased to

respond to any questions that you or other Members of the Subcommittee

may have.

For future contacts regarding this statement, please contact Barry T. Hill

on (202) 512-3841. Individuals making key contributions to this testimony

were Ron Belak, Paul Bollea, Charlie Cotton, Alan Dominicci, Cliff Fowler,

Ches Joy, Paul Lacey, and John Murphy.

Contacts and

Acknowledgment
Page 11 GAO-01-1022T The National Fire Plan

Appendix I
Page 12 GAO-01-1022T The National Fire Plan

Appendix II
Page 13 GAO-01-1022T The National Fire Plan

Appendix III
Page 14 GAO-01-1022T The National Fire Plan

Appendix IV

(360019)(360036)