Arizona Border Region: Federal Agencies Could Better Utilize Law Enforcement Resources in Support of Wildland Fire Management Activities
Published: 2011-11-08T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Wildland fires can result from both natural and human causes. Human-caused wildland fires are of particular concern in Arizona--especially within 100 miles of the U.S.-Mexico border because this is a primary area of entry for illegal border crossers and GAO has previously reported that illegal border crossers have been suspected of igniting wildland fires. Over half of the land in the Arizona border region is managed by the federal government--primarily by the Department of Agriculture's Forest Service and four agencies within the Department of the Interior. These agencies collaborate with state, tribal, and local entities to respond to wildland fires. GAO was asked to examine, for the region, the (1) number, cause, size, and location of wildland fires from 2006 through 2010; (2) economic and environmental effects of human-caused wildland fires burning 10 or more acres; (3) extent to which illegal border crossers were the ignition source of wildland fires on federal lands; and (4) ways in which the presence of illegal border crossers has affected fire suppression activities. GAO reviewed interagency policies and procedures; analyzed wildland fire data; and interviewed federal, tribal, state, and local officials, as well as private citizens..
section_title: What GAO Found
paragraphs: From 2006 through 2010, at least 2,467 wildland fires occurred in the Arizona border region. Of this number, 2,126, or about 86 percent, were caused by human activity. The majority of these fires--1,364--burned less than 1 acre each. About 63 percent or 1,553 of the 2,467 fires were ignited on federally managed land or tribal land. Human-caused wildland fires that burned 10 or more acres had a number of economic and environmental impacts on the Arizona border region, but these impacts cannot be fully quantified because comprehensive data are not available. Specifically, these fires resulted in (1) over $35 million in fire suppression costs by federal and state agencies, (2) destruction of property, (3) impacts on ranching operations, and (4) impacts on tourism. Similarly, these fires had several environmental impacts, such as the expansion of nonnative plant species, degraded endangered species habitat, and soil erosion. However, the full economic and environmental impacts cannot be determined because complete information about these impacts is not available. The total number of fires ignited by illegal border crossers on federal lands in the Arizona border region is not fully known, in part because federal land management agencies have not conducted investigations of all human-caused wildland fires that occurred on these lands, as called for by agency policy, and the agencies do not have a strategy for selecting fires they do investigate. Of the 422 human-caused wildland fires that occurred on Forest Service, Interior, or tribal lands and burned at least 1 acre from 2006 through 2010, only 77 were investigated. According to land management agency officials, the lack of trained fire investigators was the primary reason for the limited number of investigations. Of the investigations conducted, 30 identified illegal border crossers as a suspected source of ignition. Agency policy notes that identifying trends in fire causes is critical to the success of fire prevention programs, but without better data on the specific ignition sources of human-caused wildland fires in the region, the agencies are hampered in their ability to target their efforts to prevent future wildland fires. The presence of illegal border crossers has complicated fire suppression activities in the Arizona border region. According to agency officials, the presence of illegal border crossers has increased concerns about firefighter safety and, in some instances, has required firefighters to change or limit the tactics they use in suppressing fires. For example, the presence of illegal border crossers has limited firefighting activities at night and complicated the use of aerial firefighting methods. The agencies have taken some steps to mitigate the risks to firefighters by, for example, using law enforcement to provide security. However, none of the agencies have developed or implemented a risk-based approach for addressing these challenges. Consequently, law enforcement resources are routinely dispatched to all fires regardless of the risk, which may prevent the agencies from using their limited resources most efficiently. Moreover, while the Forest Service has developed a formal policy for addressing the risks to firefighters in the region, the other agencies have neither formally adopted this policy nor developed their own.
section_title: What GAO Recommends
paragraphs: GAO recommends, among other things, that the agencies develop strategies for selecting fires to investigate and establish a risk-based approach for utilizing law enforcement resources. In their comments on a draft of this report, the Forest Service and the Department of the Interior generally agreed with these recommendations.

section_title: Letter
paragraphs: A natural part of many ecosystems, wildland fires can have devastating  effects on communities, damage sensitive ecosystems, and be costly to  suppress. Wildland fires may be ignited by lightning or as a result of  human activities, such as improperly extinguished campfires, sparks from  equipment and vehicles, or recreational shooting. Fires triggered by  natural causes are inevitable and play an important ecological role on  many landscapes, but human-caused wildland fires can damage areas  that might not otherwise experience fire or that might burn with less  frequency or severity. The recent Horseshoe Two and Monument fires in  southern Arizona provide vivid examples of the devastation that can result  from human-caused wildland fires. The Horseshoe Two Fire burned  nearly 223,000 acres in May and June 2011, mostly on the Coronado  National Forest, and cost millions to suppress. Similarly, according to  preliminary estimates from the agencies, the Monument Fire burned more  than 30,000 acres in the Huachuca Mountains in June and July 2011,  destroyed more than 60 homes, and forced thousands of residents living  near Sierra Vista, Arizona, to evacuate.
Human-caused wildland fires are of particular concern in Arizona along the  Mexico border because southeast Arizona is a primary entry point for illegal  border crossers on the U.S. southwestern border. As we reported in  December 2010, illegal border crossers have been suspected of starting  wildland fires either by accident—for example, from cooking fires that  escape—or on purpose—for example, to divert law enforcement resources  away from a particular area. In this context, you asked us to examine  wildland fires that occurred in Arizona within 100 miles of the U.S.-Mexico  border during the previous 5 years. For such wildland fires, this report  examines (1) their number, cause, size, and location; (2) the economic and  environmental effects of human-caused wildland fires that burned 10 or  more acres; (3) the extent to which federal agencies determined that illegal  border crossers were the ignition source of wildland fires on federal and  tribal lands; and (4) ways in which the presence of illegal border crossers  has affected fire suppression activities in this area.
To determine the extent of wildland fire occurrence in the Arizona border  region, we collected federal and state wildland fire occurrence data from  databases at the National Interagency Fire Center (NIFC) for fires that  occurred within Arizona during calendar years 2006 through 2010. From  these data, we identified those wildland fires that occurred within 100  miles of the Arizona-Mexico border. For these fires, we then analyzed the  data to identify the acreage burned and general cause—human or  natural—cited for ignition. We assessed the reliability of the data we used  by reviewing information about the underlying database systems and  discussing the data with agency officials responsible for managing these  databases, and determined that the data were sufficiently reliable for the  purposes of presenting acreage burned and general cause of wildland  fires. We also obtained information from the Department of Defense  regarding wildland fire incidents on its lands in the region—which is not  included in NIFC’s data—and included these data in our overall analysis.  We identified those human-caused wildland fires that burned 10 or more  acres (referred to as significant fires for the purposes of this report) and  obtained data on suppression cost obligations for those fires as well as  available documentation of economic and environmental effects. In  addition, we visited the region and discussed with federal and nonfederal  fire suppression and law enforcement officials, as well as private industry  representatives and private citizens in the ranching community, their  experiences with wildland fire occurrence and suppression activities, as  well as the economic and environmental damage as a result of human- caused wildland fires. To assess the extent to which federal agencies  determined that illegal border crossers were the ignition source of these  fires, we reviewed agency documents to identify criteria for conducting  investigations into the ignition source of human-caused wildland fires. We  also collected and analyzed fire investigation reports to evaluate the  extent to which fire investigations were conducted for human-caused  wildland fires that burned 1 or more acres and, for those fires for which  investigations were conducted, the extent to which officials identified  illegal border crossers as the source of ignition. Additionally, we reviewed  fire incident reports created by fire response personnel to identify the  extent to which they cited illegal border crossers as a potential source of  ignition. To determine the ways in which the presence of illegal border  crossers has affected fire suppression in the Arizona border region, we  reviewed national and regional land management wildland fire guidance  to identify any practices unique to regional land management units  developed in response to illegal cross-border activity. During our site  visits, we also discussed with federal and nonfederal officials their  experiences fighting wildland fires in the region.
We conducted this performance audit from December 2010 to November  2011 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The Arizona-Mexico border extends about 370 miles, accounting for  almost 20 percent of the 2,000-mile U.S.-Mexico border. About 51  percent of the land in the Arizona border region is managed by the federal  government, primarily by the Forest Service within the Department of  Agriculture, four agencies within the Department of the Interior—the  Bureau of Indian Affairs (BIA), Bureau of Land Management (BLM), Fish  and Wildlife Service (FWS), and National Park Service (NPS)—and the  Department of Defense (DOD). The remainder of the land is local or  private (21 percent), state-managed (16 percent), or tribal (12 percent).  Figure 1 shows the areas managed by these various entities.
Each federal agency that manages land within the border region has a  distinct mission and set of responsibilities, which may include managing  the land for multiple uses, such as recreation; conserving natural and  historic resources; conserving and enhancing fish, wildlife, plants, and  their habitats; and providing rangeland for grazing. Federal agency  responsibilities for land units in the Arizona border region include the  following:    The Forest Service manages the Coronado National Forest, which  covers almost 1.8 million acres of southeastern Arizona and New  Mexico and ranges in elevations from 3,000 feet to over 10,000 feet.  In addition to the preservation of natural resources, the forest is used  for recreational purposes and ranchers use some of the forest for  grazing. In October 2010, we reported that more illegal border  crossers migrate through the Coronado National Forest than any  other federal land unit along the southwestern border. The Forest  Service has reported that the number of illegal border crossers  traveling in the area threatens natural resources and creates a  dangerous environment for the public and for Forest Service  employees.    BIA provides services to several Indian tribes, including the Tohono  O’odham Nation, Colorado River Nation, Fort Yuma-Quechan Nation,  Ak-Chin Tribal Community, and Gila River Indian Community within  the Arizona border region. The Tohono O’odham Nation, the largest  Indian tribe within the Arizona border region, covers about 2.9 million  acres, an area approximately the size of Connecticut. Tohono  O’odham officials have previously reported that illegal border crossers  cause significant damage to their lands.    BLM manages numerous public lands in the border region, including  the nearly half-million-acre Sonoran Desert National Monument, San  Pedro National Conservation Area, and Ironwood Forest National  Monument. BLM lands are used for multiple purposes, including  recreation, grazing, mining, and wildlife habitat. In our November 2010  report, we reported that BLM officials posted warning signs at 11  entrance locations of the Sonoran Desert National Monument to warn  the public against travel on portions of the monument because of  potential encounters with illegal border crossers.    FWS works to preserve and enhance fish, wildlife, plants, and their  habitats in wildlife refuges in the region, including the Buenos Aires,  Cabeza Prieta, Imperial, and Kofa National Wildlife Refuges. In  December 2010, we reported that the Refuge Manager of Buenos  Aires National Wildlife Refuge testified before Congress that illegal  border crossers have disturbed wildlife and created more than 1,300  miles of illegal trails, causing the loss of vegetation and severe  erosion. In addition, a portion of the refuge adjacent to the border  has been closed to the public due to safety concerns caused by illegal  border crossers.    NPS is responsible for conserving the scenery, natural and historical  objects, and wildlife of the national park system, which includes  Coronado National Memorial, Organ Pipe Cactus National Monument,  and Saguaro National Park in the Arizona border region. As was the  case with the Buenos Aires National Wildlife Refuge, the Organ Pipe  Cactus National Monument has previously been closed to the public  because of the safety concerns associated with illegal border  crossers. Officials at other sites, such as the Fort Bowie National  Historic Site, have reported that the cultural and historical integrity of  the site has been compromised by illegal border crossers because of  the waste they have left in the area—including clothing, cans, water  jugs, plastic bags, and human waste.    DOD manages a number of installations and facilities used for testing  and training its forces in the region, including Fort Huachuca, the  Yuma Proving Grounds, the Barry M. Goldwater Range, and Davis- Monthan Air Force Base. DOD officials told us that training missions  at the Barry M. Goldwater Range have been delayed or altered due to  the presence of illegal border crossers.
Additionally, agents of the U.S. Border Patrol—an office within the  Department of Homeland Security (DHS)—patrol federal and nonfederal  lands near the border to find and apprehend persons who have illegally  crossed the U.S. border. Border Patrol is responsible for controlling and  guarding the boundaries and borders of the United States against the  illegal entry of people who are not citizens or nationals. Border patrol  agents have the authority to search, interrogate, and arrest  undocumented aliens and others who are engaging in illegal activities,  such as illegal entry and smuggling of people, drugs, or other contraband  on federal lands and other areas up to 100 miles from the border.
Each of the federal land management agencies also has responsibility to  respond to wildland fires on federal lands, while the Arizona State  Forestry Division and other entities—including tribal and local fire  departments—have primary responsibility for responding to wildland fires  on state, local, and private lands. When a wildland fire starts on federal  land, federal policy directs federal agencies to consider land management  objectives—identified by land and fire management plans developed by  each land management unit—and the structures and resources at risk  when determining whether and how to suppress it. Historically, the Forest  Service and the Interior agencies attempted to suppress all wildland fires  quickly because of their potentially damaging effects on local economies  and natural environments; in recent decades, however, the agencies  fundamentally reassessed their understanding of naturally occurring  wildland fire’s role on the landscape, and they began to see more benefits  from these wildland fires. For instance, fire can limit the spread of insects  and diseases, reduce brush and weeds, and return the nutrients to the  soil, where they help produce a new generation of plants. For ranchers  whose cattle are dependent on the new generation of plants, fire can burn  unwanted brush and allow grasses to flourish in future years. If agencies  determine that a naturally ignited wildland fire can promote land  management objectives, they may use less aggressive fire suppression  strategies that not only can reduce fire suppression costs in some cases  but can also be safer for firefighters by reducing their exposure to  unnecessary risks. In contrast, interagency policy calls for these agencies  to initiate suppression activities immediately for all human-caused  wildland fires.
Fire suppression efforts are mobilized through an interagency incident  management system, which depends on the close cooperation and  coordination of federal, state, tribal, and local fire protection entities.  Fighting wildland fires—which can burn across federal, state, and local  jurisdictions—can require investments of personnel, aircraft, equipment,  and supplies and can result in substantial fire suppression expenditures.
To document fire occurrence, fire personnel prepare a fire incident report,  and the information from these reports populates the agencies’ fire data  management systems. The information collected in these reports includes  basic data such as date the fire started, location, general cause (natural  or human), number of acres burned, and the date the fire was  extinguished. Firefighters can also include narrative information in these  reports, such as information about suppression activities or fire cause.
section_title: Number, Cause, Size, and Location of Wildland Fires in the Arizona Border Region
paragraphs: From 2006 through 2010, at least 2,467 wildland fires occurred in the  Arizona border region. Most of these fires were caused by human activity,  burned less than 1 acre each, and were ignited on federal or tribal land.  Federal and state agencies determined that 2,126 of these fires, or about  86 percent, were caused by human activities (see fig. 2). This percentage  is consistent with the national average for wildland fires caused by human  activities; according to NIFC data, about 87 percent of all wildland fires  that occurred nationally from 2006 through 2010 were caused by human  activities.
Most of the human-caused wildland fires—1,364, or 64 percent—burned  less than 1 acre of land each; 508 fires burned from 1 to 10 acres each;  and 241 fires were significant, burning 10 or more acres each. These  241 significant human-caused wildland fires burned a total of more than  123,000 acres, which accounts for about 99 percent of all acres burned  during this time by human-caused wildland fire in the region; the largest of  these wildland fires—the 2009 Elkhorn Fire—burned more than 23,000  acres. See figure 3 for the location of significant human-caused wildland  fires during this period. The 2011 Horseshoe Two and Monument fires,  which occurred after the period for which we analyzed data, were much  larger than any of the fires that occurred from 2006 through 2010. Based  on preliminary information, federal agencies reported that these two fires  burned more than 250,000 acres—more than twice the cumulative total of  all significant human-caused wildland fires in the area during the previous  5 years.
Of the 341 fires that federal and state agencies determined to be natural  ignitions—caused by lightning—156, or 46 percent, burned less than 1  acre each; 87 burned from 1 to 10 acres each; and 98 fires were  significant, burning 10 acres or more. Naturally ignited wildland fires  burned nearly 74,000 acres, although agency officials explained that  some of these fires were allowed to burn (i.e., they were not suppressed  by firefighters) for ecological and resource management purposes.
Of the 2,467 wildland fires included in our review, the majority of the  fires—1,553, or 63 percent—were ignited on federal or tribal lands. The  remaining fires were ignited on state, local, or private lands (see table 1).
section_title: The Economic and Environmental Effects of Significant Wildland Fires in the Arizona Border Region Are Not Fully Known
paragraphs: Significant human-caused wildland fires in the Arizona border region have  resulted in a number of economic and environmental impacts. Economic  impacts include millions of dollars in fire suppression costs, destruction of  homes and ranching operations, and impacts on regional tourism.  Environmental impacts include damaged habitat for endangered species  and expansion of nonnative plants in the region. However, it is not  possible to fully quantify the effects of these fires on the region’s economy  or environment because complete information needed for such analyses  is not available.
subsections: section_title: Significant Human-Caused Wildland Fires Have Resulted in Various Economic Impacts, but the Full Impact on the Region Is Unknown
paragraphs: Significant human-caused wildland fires in the Arizona border region have  had various economic impacts. These impacts include (1) the costs  associated with suppressing wildland fires; (2) the destruction of property,  including homes and ranching infrastructure; and (3) impacts on tourism.  While we were able to identify specific examples of these fires’ impacts  on the area’s economy, we could not determine the overall impact of  these fires on local economies because complete information is not  available that would allow such an analysis.
Fire suppression costs. In response to significant human-caused wildland  fires that occurred from 2006 through 2010 in the Arizona border region,  federal land management agencies obligated more than $33 million for  suppression activities, and the state of Arizona obligated almost $2  million. Forest Service suppression obligations accounted for more than  $26 million, or about 80 percent of all federal obligations to suppress  these fires. The amount of funding obligated for individual significant  human-caused wildland fires varied widely. For a majority of these fires,  federal and state agencies obligated less than $25,000 per fire.  Conversely, for 23 fires, or about 10 percent, agencies obligated more  than $250,000 each, with the 2010 Horseshoe Fire, which burned more  than 3,400 acres on the Coronado National Forest, accounting for more  than $10 million—nearly a third of all federal obligations for significant  human-caused wildland fires in the region from 2006 through 2010.  Characteristics affecting suppression costs include fire size; fuel types;  fire intensity; physical terrain; proximity to the nearest community; total  value of structures close to the fire; and special management  considerations, such as whether the fire was burning in a wilderness or  other designated area. It is also important to note that suppression costs  may represent only a fraction of the total true costs for these fires. For  example, one study that reviewed six fires of at least 40,000 acres in the  western United States found that, in these cases, other costs associated  with the fires, such as damage to properties and ecosystems and loss of  economic activities, were generally several times higher than suppression  costs.
Destruction of property and injuries to homeowners. Significant human- caused wildland fires in the region have destroyed houses and other  property and injured residents. For example, according to the Forest  Service, the 2009 Canelo Fire, which burned over 4,000 acres, destroyed  at least three residences, several outbuildings, and numerous vehicles. In  addition, one homeowner was seriously burned during that wildland fire  and required hospitalization. Similarly, the 2011 Monument Fire destroyed  more than 60 homes, according to preliminary agency estimates.
Impacts on ranching operations. Significant human-caused wildland fires  have also affected ranching operations in the region. Such fires have  damaged grazing allotments and related improvements—such as  fences, water tanks, and pipelines—located on federal lands and used by  private ranchers. The Forest Service reported obligating more than  $100,000 in long-term restoration and rehabilitation funds to repair  fences, protect watersheds, and clean water tanks on federal grazing  allotments damaged by four significant human-caused wildland fires.  Additionally, from 2006 through 2010, Forest Service officials told us they  provided about $56,000 in fencing and pipeline materials to repair  damage on 15 allotments burned by significant human-caused wildland  fires. Forest Service officials told us the agency does not always have  supplies to provide, however, and generally does not provide labor to  repair damage to allotments. As a result, local ranchers can incur costs  for labor and materials to repair damage to allotments. One rancher  whose federal grazing allotment was burned during the 2009 Hog Fire  told us that, although the Forest Service has offered to provide the  materials to replace fencing that was burned during the fire, in order to  use the allotment again, he would have to spend about $250,000 for labor  costs to build the new fence to Forest Service specifications.
Additionally, federal agency officials and private ranchers told us that, in  some circumstances, ranchers must move their cattle from federal  grazing allotments because agencies have determined that the damage  to the vegetation on which the cattle feed requires time to recover— typically 1 to 3 years, according to federal officials. As a result of  significant human-caused wildland fires from 2006 through 2010, Forest  Service officials reported that some cattle were removed from 20  allotments, and grazing schedules were altered for at least an additional  5, to allow vegetation to recover. A Forest Service official told us that the  grazing capacity for 17 of these allotments has been reduced by 25  percent because of wildland fires. Additionally, one allotment that covers  more than 50,000 acres was affected by 13 significant human-caused  wildland fires from 2006 through 2010, according to federal agency  officials, resulting in the repeated removal of cattle from the allotment and  an altering of grazing schedules. According to industry representatives  and private ranchers, moving cattle from an allotment negatively affects  ranchers because they must either find alternative locations to graze their  cattle or purchase additional feed. Further, private ranchers stated that  the value of their cattle can potentially decrease as a result of the  stresses to the animals associated with the fires and transfers between  allotments.
Impacts on tourism. Significant human-caused wildland fires can also  affect tourism. According to a representative from the Cochise College  Center for Economic Research, as well as local residents that we spoke  with, fires can affect tourism because access to trails, campgrounds, and  roads can be temporarily restricted and, more broadly, fires can diminish  the appeal of the region for tourists. For example, local residents told us  that hospitality businesses in Portal, Arizona, have been particularly  vulnerable to the economic impacts of wildland fires because these  businesses are dependent on visitors to the Coronado National Forest. If  access to the forest is restricted, as it was in 2010 as a result of the  Horseshoe Fire, these residents told us it can have a direct impact on  local businesses.
While the preceding examples provide some understanding of the nature  of the economic impacts of significant human-caused wildland fires in the  Arizona border region, we could not quantify the overall effect of these  fires on the region because comprehensive and consistent data are not  available. For example, we found no data that would allow us to  determine the extent to which the closures of national forests and other  public lands have affected tourism in the region, and we likewise did not  find data that would allow us to identify the cumulative impact of  significant human-caused wildland fires on tourist-related businesses.  Moreover, the economic researcher from the Cochise College Center for  Economic Research noted that it is difficult to assess the overall  economic impact of such incidents because the Arizona border region is  rich in ecotourism resources. As a result, it is possible that visitors who  could not visit a specific location may have still visited the region, simply  choosing to visit other local areas. Additionally, as noted in one study we  reviewed, identifying the real cost of wildland fires on the economy is  difficult because few data sources are consistent from fire to fire, and  many lack any data at all. According to this study, the effects resulting  from individual fires are unique to each fire and cannot be generally  extrapolated to other fires. The representative we spoke to from the  Cochise College Center for Economic Research also noted that the  economic effects of wildland fire can be mixed and, therefore, difficult to  delineate. For example, while wildland fires can provide a temporary  boost to several industries in the region—such as construction and retail  and restaurant sales—that boost could be offset by increases in home  insurance premiums in the area and lost revenue and wages from other  displaced businesses or workers.
section_title: Significant Human-Caused Wildland Fires Have Damaged the Environment, but the Full Extent Is Unknown
paragraphs: Significant human-caused wildland fires have damaged the natural  environment in the Arizona border region, but the comprehensive effects  are unknown, in part because—as with the economic effects of wildland  fires—complete information is not available on the environmental effects  of wildland fire. According to our analysis of federal emergency treatment  plans and discussions with federal agency and tribal officials, the most  common environmental effects of wildland fire in the region are expansion  of nonnative plant species, degraded endangered species habitat, and  soil erosion. These effects may result from both significant human-caused  wildland fires and other fires. The following are descriptions of these  environmental effects and examples of the effects that have been noted  from individual instances of significant human-caused wildland fires in the  region.
Expansion of nonnative plant species. Plant species that are not native to  southern Arizona, such as buffelgrass and tamarisk––commonly known  as salt cedar––can regenerate more quickly following wildland fires than  native species and may displace such species from their traditional  ranges. The expansion of these species can also alter natural fire  patterns by making areas susceptible to burning with more severity or  frequency than they traditionally would. For example, the 2009 Powers  Fire, a human-caused wildland fire that burned 260 acres, destroyed  native vegetation such as cottonwood and willows along the Gila River.  As a result, BLM predicts that nonnative salt cedar will increase in density  along the river. BLM noted in its postwildfire environmental damage  assessment that the increased density of salt cedar will degrade the  habitat because salt cedar actively resprouts after wildland fires and can  create enough fuel to burn again within 5 years.
Damage to endangered species habitat. Southern Arizona is home to a  number of federally listed threatened and endangered plant and animal  species. Some wildland fires can damage the habitats of these species  and, in turn, threaten their continued existence. For example, the 2007  San Luis Fire—a human-caused wildland fire that burned 68 acres of  mostly BLM land—damaged riparian areas that are habitat for two bird  species federally listed as endangered, the Southwestern Willow  Flycatcher and the Yuma Clapper Rail, as well as another that is a  candidate for listing, the Yellow-Billed Cuckoo.
Increased soil erosion. Soil erosion can also result from wildland fires in  the region. During the seasonal “monsoon rains” that Arizona typically  experiences in the summer, areas where wildland fires have burned away  the vegetation holding soil together may experience increased runoff and  mudslides that can damage natural habitats, watersheds, roads, and  trails. For example, an official with the Tohono O’odham Nation told us  that the nation is concerned about the impact the human-caused 2009  Elkhorn Fire will have on the Kearney’s Blue Star, which is an  endangered plant species. The fire itself did not damage the plant’s  population, but as a result of the fire, water runoff and soil erosion are  expected to increase, which would threaten the plant’s population at lower  elevations.
To mitigate such impacts on federal lands in the region, from 2006  through 2010, federal agencies obligated nearly $1.9 million through the  Burned Area Emergency Response program—a federal program that  provides funds to stabilize and prevent degradation to natural and cultural  resources resulting from the effects of wildland fires. Agencies prioritize  and fund emergency treatments based on risks identified in damage  assessments. According to Forest Service guidance, Burned Area  Emergency Response program assessments should be conducted for  fires that burn more than 300 acres, though damage from smaller fires  can be assessed if federal land management agency officials believe that  life, property, or damage to natural or cultural resources are at risk. From  2006 through 2010, federal agencies assessed damage from 20  significant human-caused wildland fires in the Arizona border region for  emergency treatment funding under this program. Based on these  assessments, federal officials recommended that funds be used to  provide emergency treatment in response to damage from 9 of these fires  and approved at least partial funding for 7 of these fires. For 10 of the 11  assessed fires for which they did not recommend emergency treatment  funding, officials believed that the damaged areas would recover naturally  in 5 years or less without any treatment program.
The above examples provide some understanding of the types of  environmental effects of significant human caused wildland fires in the  Arizona border region, but we were unable to quantify the full  environmental impacts for the region because comprehensive information  is not available. For example, according to federal agency officials, the  amount of funding provided through the Burned Area Emergency  Response program reflects only a portion of the total monetary value of  the environmental damages resulting from significant human-caused  wildland fires, in part because not all such fires receive funding under the  program. In addition, federal officials told us that many of the significant  human-caused wildland fires that have occurred in the Arizona border  region have likely resulted in at least some environmental damage, but  these effects are generally not formally documented or recorded by  federal agencies, and often it is many years before the extent of the  damage is fully evident. Similarly, state agencies such as the Arizona  State Forestry Division and the Arizona State Land Department could not  provide us with data regarding the environmental consequences of  significant human-caused wildland fires that occurred on state lands  because, according to state officials, they do not maintain such data.
section_title: Federal Agencies Did Not Conduct Investigations of All Human-Caused Wildland Fires and Thus Cannot Determine the Number Ignited by Illegal Border Crossers
paragraphs: The frequency with which illegal border crossers have caused wildland  fires on federal lands in the Arizona border region is not fully known, in  part because federal land management agencies did not conduct  investigations of all human-caused wildland fires that occurred on their  lands as called for by interagency policy. Further, the fires that were  investigated—about 18 percent of the fires we examined (77 of 422  fires)—were selected for investigation based primarily on the availability  of fire investigators, according to agency officials, rather than on the  specific characteristics of the fires, such as their size or location. Without  more information on the specific causes of these fires, the agencies lack  key data that could help them target their fire prevention efforts.
subsections: section_title: Federal Agencies Did Not Conduct Investigations of All Human-Caused Wildland Fires As Called for by Interagency Policy
paragraphs: Federal agencies cannot identify all of the human-caused wildland fires  that were ignited by illegal border crossers on federal lands, in part  because they did not conduct the investigations called for by interagency  policy. This policy—Interagency Standards for Fire and Fire Aviation  Operations, which applies to the Forest Service, BLM, FWS, and NPS— calls for these agencies to determine the general cause—human or  natural—for all wildland fires on federal lands they manage. If a wildland  fire is determined to be human-caused, the interagency policy calls for a  more in-depth investigation to be conducted, typically by personnel  trained to conduct fire cause investigations. Similarly, the Wildland Fire  and Aviation Program Management Operations Guide, which applies to  BIA, also calls for thorough cause investigations for all wildland fires  suspected to be human caused.
There were 422 human-caused wildland fires that burned 1 or more acres  on federal or tribal lands between 2006 and 2010. Of these, federal fire  investigators conducted investigations for 77—or about 18 percent. Table  2 and figure 4 provide additional information on the fires investigated.
Officials from the Forest Service, BIA, BLM, and FWS told us that the  primary reason that many human-caused wildland fires were not  investigated was because the agencies lacked available trained fire  investigators. For example, both BLM and Forest Service officials told us  the agency’s law enforcement officers, who are trained to conduct such  investigations, do not have the time to investigate all human-caused  wildland fires because of other responsibilities, such as providing security  for firefighters and their equipment. Similarly, an official from the Tohono  O’odham Nation stated that, although he believes it is important to  determine the cause of these fires, the nation’s fire management program  does not have adequate funding to support a wildland fire investigator.
This official also stated that he has requested assistance from federal  agencies to investigate some fires, but the agencies have been unable to  provide such assistance because of other priorities.
The lack of fire investigations is not a recent issue. A 1998 Department of  the Interior Inspector General report found weaknesses with the agency’s  ability to investigate fires, stating that seven of the eight BLM district  offices reviewed by the Inspector General did not give sufficient priority to  fire investigations and did not adequately document the fire investigations  that were completed. Even for those fires that are investigated, federal  officials told us a decision on whether to investigate a fire is generally not  based on the specific characteristics of the fire, such as its size or  location. Rather, they said the decision generally depends on the  availability of a trained wildland fire investigator at the time of the fire.  Although it appears the agencies have concluded they cannot investigate  all fires because they do not have sufficient resources, they have not  developed a strategy for determining which fires to investigate. Such a  strategy could include specific criteria for identifying which fires to  investigate, such as fires that are larger than average, that stand to burn  sensitive areas, or that otherwise may have effects that make their origins  important to understand. Without such a strategy, the agencies are  unable to ensure that those human-caused wildland fires with the greatest  effects are consistently investigated.
section_title: Federal Fire Investigators Identified Illegal Border Crossers as a Suspected Cause of Ignition in 30 of the 77 Fires They Investigated
paragraphs: Based on our review of agency investigation reports, illegal border  crossers were a suspected cause of ignition for 30 of the 77 investigated  wildland fires, or about 39 percent. Five of the 30 wildland fires in which  illegal border crossers were a suspected cause burned less than 10 acres  each, 16 burned from 10 to 100 acres each, and 9 burned more than 100  acres each. These 30 wildland fires were all located within 40 miles of the  U.S.-Mexico border and occurred on the Coronado National Forest,  Buenos Aires National Wildlife Refuge, or Organ Pipe Cactus National  Monument (see fig. 4 for the location of wildland fires that occurred on  federal lands and which illegal border crossers were identified as a  suspected cause).
Investigation reports identified illegal border crossers as a suspected cause  of 15 wildland fires that resulted from efforts to signal for help, provide  warmth, or cook food. For example, the investigation report for the 2006  Black Mesa Fire, which burned about 170 acres, states that the wildland  fire was ignited because a border crosser was injured and needed  assistance. According to the report, a group of about 20 individuals crossed  illegally into the United States and, during the trip, one person was injured  and could not continue. The group continued without the injured person,  but first started a fire to keep animals away and to attract attention in the  hope that someone would rescue the injured person. In another instance— the 2009 Bear Fire, which burned 15 acres—the investigation report states  that a campfire was the probable cause, noting several indicators regarding  a potential source of ignition: (1) discarded bottles and food wrappers with  Spanish language labels were found in the area of origin; (2) the area is  frequented by illegal border crossers and is adjacent to a heavily used  smuggling trail; and (3) the fire was ignited at a time when illegal border  crossers are often known to travel.
The investigation reports for the remaining 15 wildland fires suspected to  be ignited by illegal border crossers did not explicitly indicate a purpose  for the ignition, though a couple of investigation reports for these fires  noted that the area of ignition is known for drug smuggling. For instance,  the investigation report for the 2010 Horseshoe Fire, which burned about  3,400 acres, stated that evidence found during the investigation suggests  that drug smugglers were in the area of ignition.
For the other investigated human-caused wildland fires that were not linked  to illegal border crossers, federal agency investigation reports identified a  number of other potential human causes that could have caused the  ignition, and in some cases the investigation reports did not identify any  specific cause. Examples from investigation reports include the following:    Resident campfires were a suspected source of 13 wildland fires,  including the 2009 Carr Link Fire, where a visitor to the Coronado  National Forest was suspected of leaving a campsite for a day hike  without properly extinguishing the campfire.    Other activities such as recreational shooting, welding accidents,  sparks from all-terrain vehicles, and fireworks were a suspected  source of 25 fires, such as the 2009 Mile Post 6 Fire on the Coronado  National Forest, where target shooters shot rocks and sparks from the  bullets ignited dry grass; and the 2007 San Antonio Fire, where a  resident accidentally ignited the fire while welding.
Investigation reports indicate that investigators could not determine a  cause or did not document a suspected cause for 17 fires. These  wildland fires ranged in size from 1 acre to 5,070 acres.
To obtain additional information on possible causes of wildland fires, we  also reviewed fire incident reports for the 1,123 human-caused wildland  fires that occurred on federal and tribal land in the region from 2006  through 2010. Fire incident reports are distinct from investigation reports  in that they are completed for each wildland fire and contain overall  information on the fires’ size, location, and general cause, but they are  not formal investigations into the fire’s origin. In addition to collecting  general fire information, these incident reports allow firefighters to include  comments regarding their views on the fires’ causes—although such  comments are not mandatory and firefighters completing the fire incident  reports often choose not to include this kind of information. Of the fire  incident reports we reviewed, 57 included firefighter comments noting  illegal border crossers as a suspected cause of the fire. Most of these (32  of the 57) were for wildland fires that occurred on the Tohono O’odham  tribal land. According to a tribal official, illegal border crossers are a  significant cause of wildland fires on tribal land and the purpose of the  fires is usually to signal for assistance, cook food, or to provide warmth.  Appendix III includes additional information about the fire incident reports  we reviewed and a map identifying the location of the 57 wildland fires.
section_title: Without Comprehensive Fire Investigation Results, Federal Agencies Lack Key Data Needed to Target Their Fire Prevention Efforts
paragraphs: Without complete data on the cause of wildland fires on the lands that  they manage, federal agencies are hampered in their ability to target their  efforts and resources at preventing future wildland fires. According to  interagency guidance, the Wildfire Origin and Cause Determination  Handbook, identifying trends in fire causes is critical to the success of fire  prevention programs, and the results of fire investigations can assist in  policy development. Similarly, a Forest Service document states that the  first step in the prevention of human-caused wildland fires is to determine  the group most likely to start fires. However, in reviewing several agency  fire prevention plans for the region, we found that they included only  broad wildland fire awareness programs and activities but did not identify  specific trends or discuss groups likely to start fires or discuss the  possible role of illegal border crossers in contributing to fires in the region.  Without either additional data on the ignition source of fires in the Arizona  border region or a systematic process for using the information identified  in investigation reports, it will be difficult for the land management  agencies to identify more specific wildland fire prevention activities or  better target fire prevention efforts and resources.
In contrast, the experience of the Cleveland National Forest in California  provides an example of the potential benefits of better targeting fire  prevention efforts. In 1996, the Forest Service formed the Border Agency  Fire Council in Southern California to help identify activities that could  prevent future wildland fires. Using data on the cause of wildland fires,  the council determined that a number of wildland fires were the result of  improperly extinguished campfires left by illegal border crossers. In  response, officials from the Cleveland National Forest created a border  fire prevention crew that hikes daily on trails known to be used by illegal  border crossers and extinguishes abandoned campfires. In 2008 alone,  the forest reported that the fire prevention crew extinguished 101  abandoned campfires that, had they not been suppressed, could have  grown into larger and more damaging wildland fires. This example  demonstrates that with better information about the specific ignition  source of human-caused wildland fires, the agencies could be better  equipped to take actions that may prevent future wildland fires.
section_title: The Presence of Illegal Border Crossers Has Complicated Fire Suppression Activities, and Agencies’ Responses May Not Fully Address the Issue
paragraphs: The presence of illegal border crossers has increased the complexity of  fire suppression activities in the border region, according to federal  agency officials, because it can endanger firefighters’ safety, complicate  the use of radio communications, and limit the use of certain types of fire  suppression activities. Agencies have taken a number of actions to  mitigate the threats to firefighters in the Arizona border region, but these  actions may not be sufficient to ensure that agency resources are being  used most effectively, and none of the agencies has developed a risk- based approach for using resources to support fire suppression activities  in the region.
subsections: section_title: The Presence of Illegal Border Crossers Has Complicated Wildland Fire Suppression Activities in the Arizona Border Region
paragraphs: The presence of illegal border crossers has complicated wildland fire  suppression activities in the Arizona border region, according to federal  agency officials, largely because of concerns about firefighter safety. In  2006, the Forest Service issued a report stating that the Arizona border  region is made more dangerous for firefighters because they may  encounter smugglers; high-speed law enforcement pursuits;  environments littered with trash and other biological hazards; and illegal  border crossers who are seeking food, water, transportation, or rescue.  While federal agency officials we interviewed, including fire response and  law enforcement officials, did not identify any specific incidents in which  firefighters had been assaulted or threatened by illegal border crossers,  they identified several aspects of illegal cross-border activity that  firefighters must account for while suppressing fires in the region.
Firefighters may encounter armed smugglers. Federal agency officials told  us that violence could result if firefighters encounter armed smugglers while  suppressing fires in remote areas. They did not provide any examples of  specific situations in which firefighters had experienced such violent  encounters with smugglers; however, officials cited instances in which  individuals they believed to be illegal border crossers were encountered  during fire suppression activities. The fire investigation report for the recent  2011 Horseshoe Two Fire indicates that drug smugglers continued to use  that area even as fire suppression activities were underway.
Illegal border crossers may be injured or killed by suppression activities.  A number of fire response officials told us that they believe many illegal  border crossers generally try to avoid contact with firefighters in the  region—which, while reducing concern for firefighters’ safety, raises  concerns about the safety of illegal border crossers who could be harmed  or killed by fire suppression activities. For example, firefighters sometimes  set backfires—the burning of grass, leaves, brush, and other fuels located  between an advancing fire and an established control line, such as a  road—to halt the spread of wildland fires. Given the concern about the  possible presence of illegal border crossers in the Arizona border region,  firefighters—or, in some cases, U.S. Border Patrol agents—will, in some  instances, first conduct a search of an area to attempt to identify whether  illegal border crossers are in harm’s way before igniting a backfire. This  additional step can increase the resources and time needed to suppress  the fire.
Firefighters may reduce their use of nighttime firefighting activities. The  potential presence of illegal border crossers has caused agencies to  reduce their use of nighttime fire suppression activities and temporary  overnight camps for firefighters because of the perceived threat to  firefighters’ safety. As a result, firefighters may have to forgo or delay  some firefighting tactics, which in turn may allow fires to grow larger and  more damaging. For example, a Forest Service official told us that on the  first day of the 2009 Hog Fire, firefighters were unable to set up an  overnight camp at the scene of the fire because no law enforcement  support was available to provide security. According to this official, this  allowed the fire, which had burned 200 to 300 acres at the time, to grow  to more than 3,000 acres by the next morning; the fire ultimately burned  nearly 17,000 acres and cost more than $700,000 to suppress.
Illegal cross-border activity may interfere with radio communications.  According to agency officials from several land management agencies,  communicating by radio is difficult as a result of illegal cross-border  activity in the Arizona border region. For example, according to federal  agency and tribal officials, illegal border crossers may use the same radio  frequencies as firefighters, causing interference and limiting their ability to  safely coordinate fire suppression activities. In one instance, a tribal  official told us that the Tohono O’odham Nation’s sole radio repeater— which allows firefighters to communicate over long distances—had its  frequency taken over by illegal border crossers and is now unusable to  firefighters. The tribal official stated that the lack of access to a repeater  limits firefighters’ ability to communicate. We were also told by Forest  Service officials that firefighters are instructed not to use radios when they  encounter illegal border crossers because illegal border crossers may  believe that firefighters are reporting their location to law enforcement and  react violently.
Volume of air traffic increases the importance of interagency coordination.  According to federal and tribal officials, aerial fire suppression activities in  the Arizona border region require extra caution because of the high  volume of other federal air traffic in the area—particularly DHS aircraft  conducting border security operations, such as drug interdiction or search  and rescue, and DOD aircraft conducting training flights. According to the  officials, both fire suppression and DHS aircraft often operate at low  altitude and in the same areas along the border, making the risk of a  midair collision higher than in other areas across the country. To enhance  safety, they emphasize the importance of coordinating with agency  dispatch centers to ensure that airspace is clear of other traffic when  conducting aerial fire suppression activities.
Firefighters may be distracted by the presence of illegal border crossers.  More broadly, officials from several land management agencies told us  the potential presence of illegal border crossers is a distraction to  firefighters that can result in firefighters focusing more on their own  security, or that of illegal border crossers, than on suppressing the fire. In  addition, agency officials stated that firefighters have discovered the  bodies of illegal border crossers, which further distracts them and affects  their morale.
section_title: Agencies Have Taken Steps to Mitigate Threats to Firefighters in the Arizona Border Region but Do Not Have a Formal Risk-Based Approach for Using Their Resources
paragraphs: The Forest Service has taken a number of actions to mitigate the threats  to firefighters’ safety in the Arizona border region—which other agencies  have generally followed. In 2008, the Forest Service published an  instructional DVD to educate federal, state, local, and tribal employees  working along the U.S.-Mexico border on safety concerns and work  practices that can reduce on-the-job risks. One of the training modules  specifically discusses illegal border crossers’ effects on fire suppression  activities in the region and special precautions that firefighters should  take. The Forest Service also produces and distributes “International  Border Watchouts” cards to all firefighters conducting suppression  activities on the Coronado National Forest. These cards highlight specific  risks that firefighters might face when suppressing fires on the forest and  include a map identifying where—based on proximity to the border—they  are most likely to encounter these risks.
1. Expect high speed driving and law enforcement        pursuits   2. Expect drivers to be distracted   3. All aircraft operations have increased collision       risk   4. Radio frequency interference from Mexico likely   5. Radio/cell phone dead spots increase employee        risks   6. Cell phone connections to Mexico likely   7. Language barriers increase risk   8. Threats to employees are present 24/7/365   9. You are not clearly identified as F.S. employee 10. Every visitor contact has potential risk 11. Higher occurrence of unexpected visitor        encounters 12. Traditional responses may not be appropriate,        check your gut 13. Responding to situations inconsistent with        assigned authority and training 14. Night operations require special considerations 15. Unattended vehicles will be damaged or stolen 16. Illegal uses in remote areas likely 17. Heightened risk of biological contamination 18. Always know your location and be able to        describe it 19. Let others know your expected route and        destination (checkin/check-out)
The Forest Service has also developed a Border Fire Response Protocol,  which recommends that firefighters working in the Arizona border region  consider taking certain actions to mitigate the potential risks posed by  illegal cross-border activity. One of the recommended actions is for fire  responders to request that law enforcement support be dispatched to fires  in the region to provide security for firefighters and their equipment.  Officials from all five federal land management agencies explained that  law enforcement provides security in multiple ways, including providing an  armed presence while firefighters are suppressing fires or camping  overnight, clearing areas of any illegal border crossers that might be  hiding in an area where fire suppression activities—such as backfires— are going to occur, and guarding fire suppression vehicles and equipment  to prevent theft.
Officials from all of the other federal land management agencies in the  region—BIA, BLM, FWS, and NPS—told us they generally follow the  Forest Service’s fire response protocol informally but that they have  neither formally adopted it nor developed their own guidance to account  for the impacts that illegal border crossers have on wildland fire  suppression activities in the region. A number of federal officials in the  border region from these agencies identified the lack of formal protocols  for the four Interior land management agencies as a major concern, in  part because without formal policies it is unclear that these agencies will  provide the most appropriate and consistent fire response actions for the  region. Under the Standards for Internal Control in the Federal  Government, agencies are to employ control activities, which are the  policies, procedures, techniques, and mechanisms to ensure effective  program management and help ensure that actions are taken to avoid  risk. In this case, such activities would include protocols for federal land  management agencies responding to wildland fires in the region.
More broadly, the land management agencies have recognized risks  associated with fighting wildland fires in the Arizona border region, but  none of the agencies use a risk-based approach for allocating law  enforcement resources in support of wildland fire suppression activities  specific to the region. Instead, law enforcement is dispatched to most  wildland fires whether any specific threats have been identified or not. Both  federal fire response and law enforcement officials told us that not all fire  suppression activities need security because the threat posed to firefighters  by illegal border crossers varies by fire. Further, fire response officials told  us that waiting for law enforcement to arrive can delay firefighting efforts;  similarly, law enforcement officials told us that being dispatched to all fires  regardless of the level of safety concerns has hampered their ability to do  other high-priority work, such as conducting drug interdiction or fire  investigations. We have previously recommended that, when making  decisions about needed law enforcement resources and how to distribute  those resources, federal land management agencies should adopt a risk  management approach to systematically assess and address threats and  vulnerabilities. This recommendation, which the agencies agreed with,  noted that, in keeping with the Standards for Internal Control in the Federal  Government, such an approach should identify risks, assess their  magnitude and likelihood of occurrence, and use information from these  assessments in determining the law enforcement resources needed and  the best way to distribute those resources. However, such an approach has  not been developed or implemented for the Arizona border region. Without  a systematic risk-based approach that incorporates a consideration of the  threats associated with individual fires, the agencies lack assurance that  they are using their limited law enforcement resources in the most efficient  manner.
section_title: Conclusions
paragraphs: Federal land management agencies in the Arizona border region face a  set of complex and diverse challenges in carrying out their  responsibilities, including those posed by illegal border crossers and  wildland fires. In general, the agencies are well aware of the threats  associated with wildland fire suppression activities in the border region  and have taken some steps to address them, such as following the Forest  Service’s Border Fire Response Protocol. However, gaps in information  and inefficient deployment of limited law enforcement resources create  operational challenges limiting the agencies’ ability to fully address the  complications they face. The agencies do not have in-depth information  about the specific ignition sources of human-caused wildland fires in part  because they have not conducted investigations for all human-caused  fires—often because of limited resources—as called for by interagency  policy. In a time of constrained resources and competing needs, we  recognize that investigating all human-caused wildland fires in the  Arizona border region may not be feasible. However, the agencies have  not developed a strategy for determining which fires to investigate,  including specific criteria to help identify and prioritize those fire incidents  that should be investigated. Further, agencies do not have a systematic  process for using the information identified in the investigations to inform  decisions on prevention efforts. Without this information, it will be difficult  for agency efforts to target fire prevention activities and resources and  potentially reduce the incidence of human-caused wildland fires in the  region. Further, the practice of dispatching law enforcement support to  most fires, rather than considering the risk or safety concerns associated  with individual fires, may delay fire suppression activities and prevent law  enforcement from conducting other high-priority work, such as drug  interdictions or fire investigations. Without a systematic risk-based  approach that incorporates a consideration of the risks associated with  individual fires, the agencies lack assurance that they are using their  limited law enforcement resources in the most efficient manner. Finally,  the Interior agencies have taken an important step by informally following  the Border Fire Response Protocol developed by the Forest Service, but  without formally adopting the protocol or developing corresponding  protocols of their own, they lessen the chances that the procedures in the  protocol will be consistently followed.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the following five actions be taken:    To ensure agencies have the data needed to identify wildland fire  prevention activities and to ensure resources are effectively targeted,  the Secretaries of Agriculture and the Interior should direct the Chief  of the Forest Service, the Directors of the Bureau of Land  Management, Fish and Wildlife Service, and National Park Service,  and the Assistant Secretary for Indian Affairs to take the following  actions: (1) re-examine the policy that all human-caused wildland fires  be investigated; (2) once the agencies have determined the  appropriate level of investigations, develop a strategy for determining  which fires to investigate, including specific criteria to help select and  prioritize those fire incidents that should be investigated; and (3)  develop a systematic process to use the information identified in the  investigations to better target fire prevention activities and resources.    To ensure that fire suppression activities are not unnecessarily  delayed and that law enforcement resources are efficiently allocated,  the Secretaries of Agriculture and the Interior should direct the Chief  of the Forest Service and the Directors of the Bureau of Land  Management, Fish and Wildlife Service, and National Park Service to  develop a coordinated risk-based approach for the region to  determine when law enforcement support is warranted for each  wildland fire occurrence and adjust their response procedures  accordingly. In developing this approach, officials in the region should  consult with agencies’ headquarters to ensure consistency in the  approaches being developed for the region and for all land  management agency units nationwide.    The Secretary of the Interior should direct the Directors of the Bureau  of Land Management, Fish and Wildlife Service, and National Park  Service, and the Assistant Secretary for Indian Affairs to develop  border-specific fire response guidance or review existing guidance to  determine whether it is sufficient and, if so, formally adopt it.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided the Departments of Agriculture, Defense, Homeland  Security, and the Interior with a draft of this report for their review and  comment.
In its written comments, the Forest Service, responding on behalf of the  Department of Agriculture, agreed with our observations and the two  recommendations addressed to the agency. The Forest Service’s  comments are reproduced in appendix IV.
The Department of the Interior did not provide written comments to  include in our report. However, in an e-mail received October 24, 2011,  the agency liaison stated that Interior generally concurred with our  recommendations and that implementing the recommendations will  require consultation with the Department of Agriculture to ensure  interagency consistency. Regarding our second recommendation, Interior  noted that it disagrees that there is a lack of coordinated risk-based law  enforcement support, but concurred that improvements and adjustments  can be made. While we are encouraged that Interior acknowledges  improvements can be made, based on our observations we continue to  believe that the agency does not use a systematic risk-based approach  that incorporates a consideration of the risks associated with individual  fires when allocating law enforcement resources. Interior also noted that it  agrees that coordination and consultation within the region and across the  nation for both responses with wildland fire and law enforcement in a  refined risk-based approach can ensure that appropriate fire suppression  responses are implemented. Interior also provided technical comments in  its e-mail response, which we have incorporated as appropriate.
In its written comments, the Department of Homeland Security agreed  with our observations about the complex and diverse challenges that  federal land management agencies face in the Arizona border region. The  department’s comments are reproduced in appendix V.
The Department of Defense did not provide written or technical comments  in response to our report.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Secretaries of  Agriculture, Defense, Homeland Security, and the Interior; the Chief of the  Forest Service; the Assistant Secretary for Indian Affairs; the Directors of  the Bureau of Land Management, Fish and Wildlife Service, and National  Park Service; appropriate congressional committees; and other interested  parties. In addition, the report will be available at no charge on the GAO  website at http://www.gao.gov.
If you or your staffs have questions about this report, please contact me  at (202) 512-3841 or mittala@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix VI.
section_title: Appendix I: Scope and Methodology
paragraphs: The objectives of our review were to determine (1) the number, cause,  size, and location of wildland fires in Arizona that occurred within 100  miles of the U.S.-Mexico border from 2006 through 2010; (2) economic  and environmental effects of significant human-caused wildland fires (i.e.,  those fires that burned 10 or more acres); (3) the extent to which federal  agencies determined that illegal border crossers were the ignition source  of fires on federal lands; and (4) ways, if any, in which the presence of  illegal border crossers has affected fire suppression activities in the  Arizona border region.
To determine the extent of wildland fire occurrence in the Arizona border  region, we collected federal and state fire occurrence data from  databases at the National Interagency Fire Center (NIFC) for fires that  occurred within Arizona during calendar years 2006 through 2010. We  obtained data for the Forest Service through its Fire Statistics System,  extracting data from this system for all fires that occurred within the  Coronado National Forest. We obtained data for the Department of the  Interior’s Bureau of Indian Affairs (BIA), Bureau of Land Management  (BLM), and National Park Service (NPS) through its Wildland Fire  Management Information Database, extracting data for all fires that  occurred on Interior land units in Arizona. We obtained data for the  Department of the Interior’s Fish and Wildlife Service (FWS) through its  Fire Management Information System, extracting data for all fires on the  agency’s land units within the Arizona border region. Lastly, we obtained  data for lands managed by the state of Arizona, local governments, and  private residents through the Fire and Aviation Management Data  Warehouse, extracting data for all fires in the state of Arizona. From these  data, we geographically located each fire based on latitude and longitude  coordinates using geographic mapping software. We filtered the data to  include only fires that occurred in Arizona within 100 miles of the U.S.- Mexico border. A number of records in the data set did not include  geographic coordinates, preventing us from verifying the location of the  fires—and, as a result, these fires are not included in our analysis. For the  fires we were able to verify as within the Arizona border region, we then  analyzed the data to identify the acreage burned and general cause— human or natural—cited for ignition. We assessed the reliability of the  data we used by reviewing information about the underlying database  systems and discussing the data with agency officials responsible for  managing these databases, and determined that the data were  sufficiently reliable for the purposes of presenting acreage burned and  general cause of fires occurring during calendar years 2006 through  2010. Because NIFC does not manage the Department of Defense’s  (DOD) fire occurrence data, we also obtained information from DOD  regarding wildland fire occurrence on its lands in the region and included  these data in our overall figures. DOD officials identified and provided  data for those fires on DOD-managed lands located within the Arizona  border region. In our assessment of the data, we determined that these  data were not sufficiently reliable for our purposes of presenting a  comprehensive account of fires and acreage burned on DOD lands during  calendar years 2006 through 2010. However, we included the information  we were provided because they were the only data available.
During the course of our review, in 2011, two significant fires occurred in  the Arizona border region—the Horseshoe Two and Monument fires. We  could not include information on these two fires in our data analysis  because at the time of our review, the data from the federal agencies on  these fires were not complete and could not be determined as reliable.  However, given the significance of these fires, we have included some  descriptive and preliminary information about them throughout the report,  as appropriate.
To determine the economic and environmental effects of significant  human-caused wildland fires, we first identified those human-caused fires  that burned 10 or more acres (which we consider significant fires for the  purposes of this report) using the data collected in the previous objective.  We then obtained additional information on these fires from the federal  and state land management agencies included in our review. Each  agency provided us with the amount of funds obligated to suppress the  fires. Because some funding obligations for individual fires occurred over  multiple years, we did not adjust these figures for inflation. In addition, the  federal land management agencies provided us with data on  environmental assessments conducted in response to these fires, as well  as data on environmental restoration funds requested or provided in  response to significant human-caused wildland fires. (The state of  Arizona does not conduct such assessments or provide such funds.) We  also identified the grazing allotments on Forest Service lands that were  within the Arizona border region and could have been affected by human- caused wildland fires. For these allotments, we requested data from  Forest Service’s range management officials for any damages and  repairs to these lands as a result of significant human-caused wildland  fires. In addition, we reviewed studies conducted by academicians and  wildland fire organizations on the economic impact of wildland fires. Our  review of the economic impact studies was not comprehensive to include  all studies that may exist. Finally, we visited the region and discussed  with federal, tribal, and state officials, as well as private industry  representatives and private citizens in the ranching community, the  economic and environmental damage that has occurred as a result of  human-caused wildland fires.
To determine the extent to which federal agencies determined that illegal  border crossers were the ignition source of wildland fires on federal lands,  we reviewed agency documents to identify criteria for conducting  investigations into the ignition source of human-caused wildland fires. We  then identified all human-caused wildland fires and requested fire  investigation reports for each fire from Forest Service and the Interior  agencies. Because of extensive resource commitments on the part of the  agencies in response to the severe 2011 wildland fire season in Arizona  and the amount of resources needed to provide us with investigation  reports, we limited our request to investigation reports for human-caused  wildland fires burning at least 1 acre, which cumulatively comprised more  than 99 percent of the acreage burned by human-caused wildland fires in  the region from 2006 through 2010. We reviewed and evaluated the fire  investigation reports to determine the extent to which fire investigations  were conducted for human-caused wildland fires, and, for those fires for  which investigations were conducted, we identified the extent to which  officials identified illegal border crossers as the source of ignition.  Additionally, we reviewed fire incident reports created by fire response  personnel for all human-caused wildland fires to identify the extent to  which they cited illegal border crossers as a potential source of ignition.
To determine ways in which the presence of illegal border crossers have  affected fire response activities in the Arizona border region, we reviewed  national and regional land management wildland fire guidance to identify  any practices unique to regional land management units developed in  response to illegal cross-border activity. We also identified and reviewed  training materials and other documentation, such as the Forest Service’s  Working Along the United States-Mexico Border DVD and the Coronado  National Forest’s Border Fire Response Protocol, and interviewed land  management, firefighting, and law enforcement officials to further identify  specific actions taken in the border region. Further, during our site visits,  we discussed with federal and nonfederal officials their experiences  fighting wildland fires in the region.
We conducted this performance audit from December 2010 to November  2011 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Information on Significant Human-Caused Wildland Fires in the Arizona Border Region, 2006 through 2010
paragraphs: Table 3 shows size, duration, and suppression cost data for all significant  human-caused wildland fires in the Arizona border region from 2006  through 2010.
section_title: Appendix III: Additional Information on Wildland Fires That Federal Agencies Suspect Were Ignited by Illegal Border Crossers
paragraphs: Table 4 provides information on those wildland fires in which officials  documented through formal fire investigations that illegal border crossers  are a suspected cause for the wildland fire.
In addition to the formal investigations into ignition sources, fire incident  reports—documentation completed by fire responders on the size,  location, and general cause of each fire—sometimes contain fire  responders’ views on the cause of the wildland fire. Fire incident reports  we reviewed noted illegal border crossers as a suspected cause for 57  wildland fires in the region. However, the purpose of these reports is to  document general wildland fire occurrence data and the reports are not  indicative of a formal investigation into the fire’s origin (see fig. 5 for  location of wildland fires). Table 5 provides information on wildland fires in  which officials documented through fire incident reports that illegal border  crossers are a suspected cause for the wildland fire.
section_title: Appendix IV: Comments from the U.S. Department of Agriculture
section_title: Appendix V: Comments from the Department of Homeland Security
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Steve Gaty, Assistant Director;  Mehrzad Nadji; Alison O’Neill; Steven Putansu; Jeanette Soares; Jay  Spaan; and Matt Tabbert made significant contributions to this report.