Wildland Fire Suppression: Lack of Clear Guidance Raises Concerns about Cost Sharing between Federal and Nonfederal Entities
Published: 2006-05-30T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Wildland fires burn millions of acres each year, requiring substantial investments of firefighting assets. Since 2000, federal suppression costs alone have averaged more than $1 billion annually. Wildland fires can burn or threaten both federal and nonfederal lands and resources, including homes in or near wildlands, an area commonly called the wildland-urban interface. Cooperative agreements between federal and nonfederal firefighting entities provide the framework for working together and sharing costs. GAO was asked to (1) review how federal and nonfederal entities share the costs of suppressing wildland fires that burn or threaten both of their lands and resources and (2) identify any concerns that these entities may have with the existing cost-sharing framework.
section_title: What GAO Found
paragraphs: Federal and nonfederal entities used a variety of methods to share the costs of fighting wildland fires affecting both of their lands and resources. Cooperative agreements between federal and nonfederal firefighting entities--which are developed and agreed to by the entities involved--provide the framework for cost sharing and typically list several cost-sharing methods available to the entities. The agreements GAO reviewed, however, often lacked clear guidance for federal and nonfederal officials to use in deciding which method to apply to a specific fire. As a result, cost-sharing methods were applied inconsistently within and among states, even for fires with similar characteristics. For example, GAO found that in one state, the costs for suppressing a large fire that threatened homes were shared solely according to the proportion of acres burned within each entity's area of fire protection responsibility. Yet, costs for a similar fire within the same state were shared differently. For this fire, the state agreed to pay for certain aircraft and fire engines used to protect the wildland-urban interface, while the remaining costs were shared on the basis of acres burned. In contrast to the two methods used in this state, officials in another state used yet a different cost-sharing method for two similar large fires that threatened homes, apportioning costs each day for personnel, aircraft, and equipment deployed on particular lands, such as the wildland-urban interface. The type of cost-sharing method ultimately used is important because it can have significant financial consequences for the entities involved, potentially amounting to millions of dollars. Both federal and nonfederal agency officials raised a number of concerns about the current cost-sharing framework. First, some federal officials were concerned that because guidance is unclear about which cost-sharing methods are most appropriate in particular circumstances, it can be difficult to reach agreement with nonfederal officials on a method that all parties believe distributes suppression costs equitably. Second, some nonfederal officials expressed concerns that the emergence of alternative cost-sharing methods is causing nonfederal entities to bear a greater share of fire suppression costs than in the past. In addition, both federal and nonfederal officials believed that the inconsistent application of these cost-sharing methods has led to inequities among states in the proportion of costs borne by federal and nonfederal entities. Finally, some federal officials also expressed concern that the current framework for sharing costs insulates state and local governments from the increasing costs of protecting the wildland-urban interface. Therefore, nonfederal entities may have a reduced incentive to take steps that could help mitigate fire risks, such as requiring homeowners to use fire-resistant materials and landscaping. On the basis of a review of previous federal reports and interviews with federal and nonfederal officials, GAO believes that these concerns may reflect a more fundamental issue--that federal and nonfederal entities have not clearly defined their financial responsibilities for wildland fire suppression, particularly those for protecting the wildland-urban interface.

section_title: Letter
paragraphs: Wildland fires burn millions of acres of land each year. Although wildland  fires triggered by lightning are a natural, inevitable, and necessary  ecological process, past federal fire suppression policies have led to an  accumulation of fuels and contributed to larger and more severe wildland  fires. In addition, as human development continues to expand in or near  wildlands—an area commonly known as the wildland-urban interface— wildland fires increasingly threaten not only federal lands and public  resources, such as forests and watersheds, but also nonfederal lands and  resources, including homes and other structures.
Fighting wildland fires—which can burn across federal, state, and local  jurisdictions—requires significant investments of firefighting personnel,  aircraft, equipment, and supplies, resulting in substantial and increasing  fire suppression expenditures. Since 2000, federal suppression  expenditures alone have averaged more than $1 billion annually. In  addition, nonfederal entities, such as state and local governments, can  spend hundreds of millions of dollars during severe fire years. Firefighting  efforts are mobilized through an interagency incident management system,  which depends on the close cooperation and coordination of federal, state,  tribal, and local fire protection entities. At the federal level, five principal  agencies are involved in firefighting efforts—the Forest Service within the  Department of Agriculture and four agencies within the Department of the  Interior. Federal and nonfederal firefighting entities share their personnel,  equipment, and supplies and work together to fight fires, regardless of  which entity has jurisdiction over the burning lands. Agreements between  cooperating entities, commonly referred to as master agreements, govern  these cooperative fire protection efforts and include general provisions for  sharing firefighting costs. According to federal officials, these provisions,  and the guidance on available cost-sharing methods, have been changing  over the years, in part, to address the continuing expansion of the  wildland-urban interface and the resulting increase in nonfederal  resources at risk from wildland fire.
In this context of both the increasing size and severity of wildland fires  and the rising costs of suppressing fires and protecting federal and  nonfederal lands and resources, you asked us to (1) review how federal  and nonfederal entities share the costs of suppressing wildland fires that  burn or threaten both of their lands and resources and (2) identify any  concerns federal and nonfederal entities may have with the existing cost- sharing framework. To address these objectives, we reviewed federal  statutes governing cooperative fire protection activities; federal and  interagency wildland fire policies and procedures; master agreements  between federal and nonfederal entities governing cooperative fire  protection in 12 western states that frequently experience wildland fires;  and federal, state, and nongovernmental entities’ reviews of recent large  fires or other reports related to wildland fire suppression costs. We also  interviewed national, regional, and local firefighting officials from the  Forest Service and Department of the Interior agencies as well as state  officials from Arizona, California, Colorado, and Utah. In addition, for two  recent fires that burned or threatened both federal and nonfederal lands  and resources in the 4 states, we reviewed the records listing the  firefighting resources deployed, their costs, and the methods chosen to  share these costs. We determined that these data were sufficiently reliable  for the purposes of this report. Appendix I contains a more detailed  description of our scope and methodology, and appendix II contains  additional information on the fires we reviewed. We performed our work  in accordance with generally accepted government auditing standards  from May 2005 through May 2006.
subsections: section_title: Background
paragraphs: Wildland fires triggered by lightning are both natural and inevitable, and  they play an important role on our nation’s lands. Many ecosystems have  adapted to periodic wildland fires, which help control vegetation levels  and stimulate seedling regeneration and growth. Past land management  practices, including effective fire suppression, have disrupted the historic  frequency of wildland fires. As a result, a decrease in the number of acres  burned nationwide during much of the twentieth century has led to an  accumulation of dense vegetation that now fuels larger, more severe, and  sometimes catastrophic wildland fires.
In recent years, both the number of acres burned by wildland fires and the  costs to suppress fires have been increasing. From 1995 through 1999,  wildland fires burned an average of 4.1 million acres each year; from 2000  through 2004, the fires burned an average of 6.1 million acres each year— an increase of almost 50 percent. During the same periods, the costs  incurred by federal firefighting entities to suppress wildland fires more  than doubled, from an average of $500 million annually to more than  $1.3 billion annually. Although efforts to fight these larger, more severe  fires have accounted for much of the increase in suppression costs, the  continuing development of homes and communities in areas at risk from  wildland fires and the efforts to protect these structures also contribute to  the increasing costs. Forest Service and university researchers estimate  that about 44 million homes in the lower 48 states are located in areas that  meet or intermingle with wildlands—commonly referred to as the  wildland-urban interface. When fire threatens the wildland-urban  interface, firefighting entities often need to use substantial resources to  fight the fire and protect homes, including firefighters, fire engines, and  aircraft to drop retardant. Although firefighters are able to protect many  homes threatened by wildland fires, these fires have burned an average of  about 850 homes each year in the United States since 1984.
Because one firefighting entity alone cannot handle all wildland fires that  may occur in its jurisdiction, federal and nonfederal entities work together  to protect lands and resources and to fight fires. At the federal level, five  principal agencies are involved in fire suppression—the Forest Service  within the Department of Agriculture and the Bureau of Indian Affairs,  Bureau of Land Management, Fish and Wildlife Service, and National Park  Service within the Department of the Interior. In addition, nonfederal  entities—including state forestry entities and tribal, county, city, and rural  fire departments—play an important role in protecting resources and  fighting fires. Federal and nonfederal entities enter into master agreements  that govern their cooperative fire protection activities, including wildland  fire suppression, and provide for sharing the costs of these efforts. To  share suppression costs for a specific fire, local representatives of federal  and nonfederal firefighting entities responsible for protecting lands and  resources affected by the fire decide which costs will be shared and for  what period. They document their decisions in a cost-sharing agreement  for that fire. These local representatives can include federal officials from  a national forest, a Bureau of Land Management district office, or a  national park and nonfederal officials from the state or other entities. In  developing the cost-sharing agreement for a specific fire, these officials  are guided by the terms of the master agreement.
As wildland fire suppression costs have continued to rise, increasing  attention has focused on how suppression costs for multijurisdictional  fires are shared. According to federal officials, in the past these  cooperating entities often shared suppression costs on the basis of the  proportion of acres burned in each entity’s protection area. These officials  explained that this method is relatively easy to apply and works well when  the lands affected by a wildland fire are similar. In 2000, federal officials  updated interagency policy to include, among other things, additional  information about alternative cost-sharing methods. According to a federal  official, the interagency policy was updated, in part, in response to  requests for additional guidance on cost sharing. In addition to the acres- burned method, the policy describes two alternative methods for sharing  the costs of fire suppression efforts. Under the first alternative—you  order, you pay—each entity pays for the firefighting personnel, aircraft,  and equipment it orders, regardless of where these resources are deployed  during a fire. Under the second alternative—cost apportionment—entities  share total fire costs according to the assignment or actual use each day of  firefighting personnel, aircraft, and equipment in federal or nonfederal  protection areas. Indirect costs can then be shared in the same  proportions as these direct costs. According to the interagency policy,  however, the cost-sharing terms of the master agreements take  precedence.
To facilitate an effective response to wildland fires—including those  affecting both federal and nonfederal jurisdictions—firefighting entities in  the United States use an interagency incident management system. This  system provides an organizational structure that expands to meet a fire’s  complexity and demands and allows entities to share firefighting  personnel, aircraft, and equipment. When a fire is first detected,  firefighting entities normally follow a principle of “closest available  resource,” whereby, regardless of jurisdiction, the closest available  firefighting personnel and equipment respond to the fire. The firefighter  managing the suppression efforts is called the incident commander.  Typically, when a fire is first detected, it is classified as a type 5—the least  complex—or type 4 fire, depending on the fire and the number of  firefighters needed to fight it. If additional firefighting assets are needed,  the incident commander orders them through a three-tiered system of  local, regional, and national dispatch centers. Federal, state, tribal, and  local entities and private contractors supply the firefighting personnel,  aircraft, equipment, and supplies, which are coordinated and dispatched  through these centers. If the fire escapes initial suppression efforts,  officials may request a type 3 incident commander and additional  firefighting assets. The fire may grow in size or complexity into a type 2 or  type 1 fire, the latter being the most complex. For such fires, officials may  request an incident management team that includes not only an incident  commander but a cadre of personnel to handle command, planning,  logistics, operations, and finance functions. Nationally, there are 17 type 1  incident management teams available to manage the most complex fires.  An additional 38 type 2 teams are available to manage large fires that are  less complex.
In 2000, in response to a decade of severe wildland fires, the Departments  of Agriculture and the Interior developed a National Fire Plan. This plan  comprises several strategic documents that together address how to  respond to wildland fires, reduce the impacts of these fires on  communities and the environment, and ensure sufficient firefighting  resources for the future. The National Fire Plan encourages collaboration  and cooperation among a variety of stakeholders, including federal, state,  and local firefighting and other government entities; nongovernmental  entities; and property owners. The plan includes a 10-year comprehensive  strategy and an associated implementation plan that outline a  collaborative approach for reducing wildland fire risks to communities  and the environment. The implementation plan includes steps addressing  four key areas—improving fire prevention and suppression, reducing  hazardous fuels, restoring fire-adapted ecosystems, and promoting  community assistance—and identifies parties to help carry out these steps.  For example, to help protect structures and communities, state and local  entities are encouraged to develop and adopt local land-use plans and  ordinances to help reduce the wildland fire risks to homes and other  structures. To help meet National Fire Plan goals, Congress provided  funding for programs to assist not only federal firefighting entities but also  nonfederal entities and communities. For fiscal years 2001 through 2005,  assistance to nonfederal entities and communities totaled $436 million  ($462 million adjusted for inflation). These funds—in the form of grants or  other assistance administered by the Departments of Agriculture and the  Interior—were used to train state and local firefighters and acquire  firefighting equipment, carry out hazardous fuel treatments, conduct  hazard assessments and assist communities in developing community  wildland fire protection plans, and educate homeowners and others on  preventive steps to help reduce their risk from wildland fires.
section_title: Unclear Guidance and Inconsistent Application of Cost- Sharing Methods Can Have Significant Financial Consequences for Entities Involved
paragraphs: Federal and nonfederal entities included in our review used a variety of  methods to share the costs of fighting fires that burned or threatened both  federal and nonfederal lands and resources. Although master agreements  between federal and nonfederal entities provided the framework for cost  sharing and, typically, listed several cost-sharing methods, the agreements  often lacked clear guidance for officials to follow in deciding which cost- sharing method to apply to a specific fire. Consequently, for eight fires we  reviewed in four states, we found varied cost-sharing methods used and an  inconsistent application of these methods within and among states,  although the fires had similar characteristics. The type of cost-sharing  method chosen is important because it can have significant financial  consequences for the federal and nonfederal entities involved.
subsections: section_title: Master Agreements Provided Cost-Sharing Framework, but Those We Reviewed Lacked Clear Guidance
paragraphs: Master agreements provide the framework for federal and nonfederal  entities to work together and share the costs of fighting wildland fires. The  master agreements we reviewed for 12 western states all directed federal  and nonfederal entities to develop a separate agreement, documenting  how costs were to be shared for each fire that burned—or, in some cases,  threatened to burn—across multiple jurisdictions. The master agreements  also listed one or more methods that could be used for sharing costs (see  table 1). The master agreement for Idaho was the only one of the  agreements reviewed that did not cite any specific methods for sharing  multijurisdictional fire suppression costs. Three other master  agreements—for Alaska, Arizona, and New Mexico—provided that  firefighting entities should distribute suppression costs exclusively or  primarily on the basis of the percentage of acres burned in each entity’s  jurisdiction, although two of the agreements permitted another method if  all parties agreed to use it. The master agreements for the remaining 8  states listed a variety of methods that could be used to share suppression  costs. Although, the specific methods varied from agreement to  agreement, they included acres burned, cost apportionment, or variations  of these or other methods.
The master agreements we reviewed provided a framework for cost  sharing, but they did not provide clear guidance for federal and nonfederal  officials to follow in deciding which method to use for a specific fire. Only  one master agreement, the agreement for Alaska, clearly stated that an  acres-burned method should always be used. The agreement noted,  however, that this method may distribute suppression costs  disproportionately to the cost of protecting lands and resources in a  particular jurisdiction. The acres-burned method spreads fire suppression  costs evenly across the affected landscape, a distribution that may not  recognize extra fire suppression costs incurred to protect lands and  resources in one entity’s jurisdiction. Most of the master agreements we  reviewed for the remaining 11 states listed multiple, alternative cost- sharing methods but did not provide clear guidance on when each method  should be used. For example, master agreements for several states defined  three cost-sharing methods, including cost apportionment. These master  agreements noted that the cost-apportionment method was “the most  equitable method and should be used when a type 1 team is assigned” to  manage a wildland fire, but they provided no further guidance about when  the other methods should be used. Similarly, the master agreement for  another state, Montana, suggested that an acres-burned method be used  when entities’ responsibilities, objectives, and suppression costs are  similar, but the agreement did not describe when the other three listed  methods should be used. Finally, the joint master agreement for Oregon  and Washington listed five possible cost-sharing methods. The agreement  stated that some of the cost-sharing methods described were typically  used on “smaller, less complex” fires and others were typically applied to  “larger, more complex” fires. It did not define, however, at what point a  fire crosses the threshold from smaller and less complex to larger and  more complex.
Two other master agreements prescribed a primary cost-sharing method  but allowed the use of alternative methods without explicitly stating under  what circumstances an alternative method would be appropriate. The  master agreements for these states—Arizona and New Mexico—stipulated  that firefighting entities share suppression costs on an acres-burned basis  unless federal and nonfederal officials jointly agreed to use an alternative  method. But the agreements for these states did not clearly delineate the  circumstances that would warrant use of such an alternative. The master  agreement for New Mexico, for example, cited “extra suppression effort,”  and the agreement for Arizona referred to “an unusually high amount” of  suppression activity as prerequisites for distributing suppression costs on  a basis other than acres burned. The agreements did not define what  constitutes “extra suppression effort” or an “unusually high amount” of  suppression activity.
In addition to providing limited guidance on cost-sharing methods, the  master agreements we reviewed also provided unclear guidance on  whether estimated or actual costs should be shared between federal and  nonfederal entities. Although estimated costs can be more quickly  determined than actual costs—often by the end of a fire—estimated costs  can be incomplete or inaccurate. For example, federal and nonfederal  officials with whom we spoke in California said that in their experience,  estimated costs could differ from actual costs by as much as 30 percent.  Such discrepancies can occur because not all costs are available and  entered into the accounting system at the time of a fire. In addition, some  costs entered into the accounting system at the time of a fire, such as  federal personnel costs, are in fact estimated costs. According to federal  officials, actual cost data may take from several weeks to several months  to become available.
For several of the fires we reviewed, total actual fire costs were much  higher than the costs estimated immediately after the fire. For one fire we  reviewed in Colorado, for example, total estimated fire costs increased  from $5.4 million at the end of the fire to $7 million as of February 2006— an increase of 29 percent. Federal and state officials have been using  actual costs to finalize federal and nonfederal entities’ shares. In another  example, for a fire we reviewed in Arizona, total costs increased from an  estimated $17.3 million at the end of the fire to $19.4 million as of February  2006—an increase of more than 12 percent. In this case, nonfederal  entities’ share of costs was agreed to on the basis of estimated costs. As a  result, federal entities will bear the total increase.
section_title: Cost-Sharing Methods Were Inconsistently Applied for the Eight Fires We Reviewed
paragraphs: Federal and nonfederal entities used varied cost-sharing methods for the  eight fires we reviewed, although the fires had similar characteristics. As  shown in figure 1, the cost-sharing methods used sometimes varied within  a state or from state to state.
The costs for the two fires that we reviewed in Utah were shared using  two different methods, although both fires had similar characteristics. For  the Blue Springs Fire, federal and nonfederal officials agreed that aircraft  and engine costs of protecting an area in the wildland-urban interface  during a 2-day period would be assigned to the state and that the  remaining costs would be shared on the basis of acres burned. Federal and  state officials explained that, because the Blue Springs Fire qualified for  assistance from FEMA, state officials agreed to bear a larger portion of the  total fire suppression costs. In contrast, state officials were reluctant to  share costs in the same manner on the Sunrise Complex of fires. Although  these fires also threatened the wildland-urban interface, they did not meet  the eligibility requirements for FEMA reimbursement of nonfederal costs.  Consequently, federal and nonfederal officials agreed to share costs for  the Sunrise Complex on the basis of acres burned.
The costs for the two fires we reviewed in Arizona were also treated  differently from each other. For the Cave Creek Complex, federal and  state officials agreed to share suppression costs using an acres-burned  method for the southern portion of the fire, which encompassed federal,  state, and city lands and required substantial efforts to protect the  wildland-urban interface. The federal government paid the full costs for  the northern portion of the fire, which burned almost exclusively on  federal land although some efforts had also been taken on federal lands to  protect an area of wildland-urban interface northeast of the fire. Forest  Service regional officials who conducted a postfire review expressed  concern about the method chosen for the Cave Creek Complex because  they believed that it did not equitably share the fire suppression costs  among the affected entities, especially the costs of protecting the wildland- urban interface. The Arizona state forester explained, in contrast, that he  and local forest officials agreed to use an acres-burned method because  they did not believe that an unusually high amount of suppression effort  had gone toward protecting nonfederal lands and resources.
Unlike the Cave Creek Complex, federal and nonfederal officials were  unable to reach any agreement on how to share costs for the Florida Fire  in Arizona. Officials from the affected national forest had proposed a cost- sharing agreement, whereby the state would pay the costs of firefighting  personnel, equipment, and aircraft used to protect the wildland-urban  interface, and all other fire suppression costs would be paid by the federal  government. The state forester, however, did not agree with this proposal.  He explained that he believed that the Forest Service, not the state, was  responsible for protecting areas of the wildland-urban interface threatened  by the Florida Fire and that he was not authorized to agree to the terms of  the proposed agreement. Federal and state officials were not able to  reach agreement, and, according to federal officials, no further discussions  were planned.
Methods used to share suppression costs for fires with similar  characteristics also varied among states. For example, costs for the fires  we reviewed in California and Colorado were shared using methods  different from those used for similar fires we reviewed in Arizona and  Utah. In California, federal and nonfederal officials agreed to share the  costs of two fires using the cost-apportionment method—that is, costs  were apportioned on the basis of where firefighting personnel and  equipment were deployed. Officials said that they had often used this  method since the mid-1980s because they believed that the benefit it  provides in more equitable cost sharing among affected firefighting  entities outweighs the additional time required to apportion the costs. In  contrast, federal and state officials in Colorado shared suppression costs  for both of the fires we reviewed in that state using guidance they had  developed and officially adopted in 2005, called “fire cost share  principles.” Under these principles, aviation costs for fires burning in the  wildland-urban interface are shared equally for 72 hours, and other fire  suppression costs, such as firefighting personnel and equipment, are  shared on the basis of acres burned. State officials said that they  developed the principles because they did not want firefighting officials to  be reluctant to order needed resources due to concerns about which entity  would pay for them. They added that using the principles is less labor- intensive than cost apportionment and better distributes the cost of  expensive aviation assets than an acres-burned method alone. In addition,  for the Mason Gulch Fire, Colorado officials agreed to pay for some fire  engines that were used to protect homes in the wildland-urban interface  during one operational period.
section_title: The Cost-Sharing Method Used Can Lead to Significantly Different Financial Outcomes
paragraphs: Having clear guidance as to when particular cost-sharing methods should  be used is important because the type of method ultimately agreed upon  for any particular fire can have significant financial consequences for the  firefighting entities involved. To illustrate the effect of the method chosen,  we compared the distribution of federal and nonfederal costs for the five  fires we reviewed in which the actual cost-sharing method used was not  acres burned with what the distribution would have been if the method  used had been acres burned (see fig. 2).
We found that the distribution of costs between federal and nonfederal  entities differed, sometimes substantially, depending on the cost-sharing  method used. Of the five fires included in our review, the largest  differences occurred for the two fires in California. Officials shared the  costs for each of these fires using a cost-apportionment method. For the  Deep Fire, federal entities paid $6.2 million, and nonfederal entities paid  $2.2 million. Had the costs been shared on the basis of acres burned,  federal entities would have paid an additional $1.7 million, and nonfederal  entities would have paid that much less because most of the acres burned  were on federal lands. According to federal and state officials, the  nonfederal entities bore a larger share of the cost than they would have  under an acres-burned method because (1) substantial aircraft, fire  engines, and personnel were used to protect nonfederal lands and  resources, primarily in the wildland-urban interface, and (2) the costs for  protecting these nonfederal lands and resources were assigned to the  nonfederal entities. In contrast, for the other California fire we reviewed,  the Pine Fire, federal firefighting entities would have paid about $2 million  less, and nonfederal entities would have paid that much more under an  acres-burned method. Under the cost-apportionment method, federal  entities paid $5.2 million, and nonfederal entities paid $8.1 million.  According to a federal official who worked on apportioning costs for that  fire, the higher costs that the federal entities paid under cost  apportionment were largely due to extensive firefighting efforts on federal  land to ensure that the fire was extinguished.
In Colorado and Utah, which for three fires used cost-sharing methods  other than cost apportionment and acres burned, the differences in federal  and state entities’ shares between the methods used and the acres-burned  method were less pronounced. This is likely because the cost-sharing  methods used still relied heavily on acres burned. In each case, federal  entities’ shares would have been more and nonfederal shares less had an  acres-burned method been used, due to the efforts to protect the wildland- urban interface. For example, the federal share of costs for the Blue  Springs Fire in Utah would have been about $400,000 more and the  nonfederal share that much less if an acres-burned method had been used  for the whole fire. In Colorado, we estimated that the federal share of  costs for the Mason Gulch Fire would have been about $200,000 more and  the nonfederal share that much less under an acres-burned method. For  the McGruder Fire, where the number of federal and nonfederal acres  burned were nearly identical and the total fire cost of about $800,000 was  much less than the cost of other fires we reviewed, the change in the  distribution of costs between the method used and acres burned—about  $30,000—was much less than for the other fires.
For two other fires we reviewed in which federal and nonfederal entities  had agreed to use the acres-burned method, nonfederal entities might have  borne a greater proportion of the costs had a different cost-sharing  method been used. For these two fires, in Arizona and Utah, federal and  state officials we interviewed had identified many aviation and ground  firefighting assets that went toward protecting nonfederal lands and  resources. Although we were unable to fully estimate a distribution of  costs using an alternative method due to limitations in the data available,  our analysis suggested, and many of the officials we interviewed  acknowledged, that the nonfederal entities would have borne a larger  share of the costs.
section_title: Current Cost-Sharing Framework Raises Several Concerns
paragraphs: Federal and nonfederal agency officials we interviewed raised a number of  concerns about the current cost-sharing framework. First, some federal  officials said that because master agreements and other policies do not  provide clear guidance about which cost-sharing methods to use, it has  sometimes been difficult to obtain a cost-sharing agreement that they  believe shares suppression costs equitably. Second, nonfederal officials  were concerned that the emergence of alternative cost-sharing methods  has caused nonfederal entities to bear a greater share of fire suppression  costs than in the past. Finally, some federal officials expressed concern  that the current framework for sharing costs insulates state and local  governments from the cost of protecting the wildland-urban interface,  thereby reducing their incentive to take steps that could help mitigate fire  risks and reduce suppression costs in the wildland-urban interface. On the  basis of our review of previous federal reports and interviews with federal  and nonfederal officials, we believe these concerns may reflect a more  fundamental issue—that federal and nonfederal entities have not clearly  defined their financial responsibilities for wildland fire suppression,  particularly for the wildland-urban interface.
subsections: section_title: Lack of Clear Guidance Can Lead to Difficulties in Sharing Costs
paragraphs: Some federal officials said that the lack of clear guidance can make it  difficult to agree to use a cost-sharing method that they believe equitably  distributes suppression costs between federal and nonfederal entities,  particularly for fires that threaten the wildland-urban interface. For  example, different cost-sharing methods were used for the two fires we  reviewed in Utah, even though both fires required substantial suppression  efforts to protect the wildland-urban interface. For the Blue Springs Fire,  nonfederal officials agreed to pay a higher proportion of the suppression  costs than they would have paid had an acres-burned method been used,  because they recognized the substantial effort undertaken to protect the  wildland-urban interface and because most of the state’s costs for that fire  were eligible for FEMA reimbursement. For the Sunrise Complex, the  federal official who negotiated the cost-sharing agreement said that using  a method other than acres burned might have better recognized and  distributed the costs of the suppression effort necessary to protect the  wildland-urban interface. Nonfederal officials, however, said they were not  willing to pay a higher proportion of costs for the Sunrise Complex  because for that fire, the state was ineligible for financial assistance from  FEMA. The federal official said that because of the state officials’  unwillingness to use a method other than acres burned, and because of the  lack of clear guidance about which cost-sharing method should be used,  he agreed to use an acres-burned method and did not seek a cost-sharing  agreement that would have assigned more of the Sunrise Complex’s costs  to the nonfederal entities. Some federal officials in Arizona expressed  similar views, saying that the lack of clear guidance on sharing costs can  make it difficult to reach agreement with nonfederal officials. For  example, federal and state officials in Arizona did not agree on whether to  share costs for the Florida Fire in that state.
Officials from NASF and the Utah Division of Forestry, Fire and State  Lands raised a related issue—that existing guidance does not specify how  costs should be shared when one entity’s management goals alter fire  suppression strategies and increase costs. For example, these officials said  that federal agencies may restrict the use of mechanized equipment in  wilderness areas or in sensitive wildlife habitat and increase the use of  aircraft instead. The officials did not believe that nonfederal entities  should have to pay for the resulting higher costs. Utah officials said that  although they have been able to reach cost-sharing agreements they  believe are appropriate in such cases, guidance should be improved to  recognize these situations.
Officials from the Forest Service’s and the Department of the Interior’s  national offices agreed that interagency policies for cost sharing could be  clarified to indicate under what circumstances particular cost-sharing  methods are most appropriate. They said that the acres-burned method,  for example, is likely not the most equitable method to share costs in cases  where fires threaten the wildland-urban interface. But they also said that it  would be difficult to develop universal guidance requiring a particular  cost-sharing method for fires with certain characteristics. They explained  that the organization, responsibilities, and funding of state and local  firefighting entities vary from state to state, and flexibility is therefore  needed. The National Fire and Aviation Executive Board was developing a  template for both master and cost-sharing agreements. As of May 2006,  this template had not been finalized, but our review of a draft version  indicated that the template might not provide additional clarity about  when each cost-sharing method should be used.
section_title: Nonfederal Officials Were Concerned about Increased Costs and Equity among States
paragraphs: While federal officials expressed the need for further guidance on how to  share costs, nonfederal officials were concerned that the emergence of  alternative cost-sharing methods was leading state and local entities to  bear a greater share of suppression costs than in the past, and they  questioned whether such an increase was appropriate. Nonfederal officials  also said that wildland fire suppression costs already posed budgetary  challenges for state and local entities and that using alternative cost- sharing methods more often could exacerbate the situation. State officials  said that if a state’s suppression costs in a given year exceed the funds  budgeted, they must seek additional state funds, which can be difficult.  Moreover, they said, in many states, protecting structures is primarily a  local responsibility, and many local entities are unable to pay the costs of  fighting a large fire that threatens the wildland-urban interface. Although  clarifying guidance about which cost-sharing methods are most  appropriate for particular circumstances could cause nonfederal entities  to bear more wildland fire suppression costs, over the long term, such  clarification would also allow each entity to better determine its budgetary  needs and take steps to meet them.
In addition to their concerns about increased costs, nonfederal as well as  federal officials were concerned that the federal government was treating  nonfederal entities in different states differently, thereby creating  inequities. Federal and nonfederal officials said that because some states  use particular cost-sharing methods more often than other states, the  proportion of costs borne by federal and nonfederal entities likely varies  from state to state, resulting in nonfederal entities’ paying a higher  proportion of costs in some states and a lower proportion in other states.  For example, nonfederal officials in Utah said that even though they  agreed to pay certain aircraft and fire engine costs to protect the wildland- urban interface on the Blue Springs Fire, they were uncertain if this  method was equitable, particularly if nonfederal entities were not paying  for similar costs in other states. Clarifying which cost-sharing methods  should be used in particular situations could increase nonfederal officials’  assurance that the federal government is treating them equitably relative  to other states.
section_title: Cost-Sharing Framework May Reduce Incentives to Mitigate Fire Risks in the Wildland-Urban Interface
paragraphs: In addition to the concerns raised about obtaining equitable cost-sharing  agreements and about the increased costs to nonfederal entities, federal  officials said that the current cost-sharing framework insulates state and  local governments from the cost of protecting the wildland-urban  interface. A variety of protective measures are available to help protect  structures from wildland fire, although they are not consistently used in  areas at risk. Some federal and nonfederal officials noted that the current  framework for sharing costs—combined with the availability of funds  from FEMA for some emergency fire suppression costs—may reduce the  incentive for state and local governments to require that such measures be  taken.
subsections: section_title: Measures Are Available to Mitigate Fire Risks in the Wildland-Urban Interface, but They Are Not Consistently Used
paragraphs: Firefighting officials and researchers have identified a variety of measures  that can mitigate the risk to structures from wildland fire. As we have  previously reported, key among these measures are (1) reducing  vegetation and flammable objects within an area of 30 to 100 feet around a   structure, often called creating a defensible space, and (2) using fire- resistant roofing materials and covering attic vents with mesh screens. In  addition, fire-resistant windows and building materials can help prevent  structures from igniting. Other measures, such as designing communities  to ensure an adequate water supply for fighting fires and access for  emergency vehicles, can assist fire suppression efforts and further reduce  the risk to structures. Taken together, these measures can help reduce the  likelihood that a wildland fire will damage a structure.
Increasing the use of protective measures to mitigate the risk to structures  from wildland fire is a key goal of the National Fire Plan. This plan— developed by federal wildland fire agencies and state governors— encourages, but does not mandate, state or local governments to adopt  laws requiring homeowners and homebuilders to take measures to help  protect structures from wildland fires. Because these measures rely on the  actions of individual homeowners or on laws and land-use planning  affecting private lands, achieving this goal is primarily a state and local  government responsibility. The National Association of Counties supports  this goal.
Federal and nonfederal officials told us that the use of measures to help  protect structures from wildland fires has become more common, but that  such measures are not consistently used in areas at risk. The increased use  of these measures in recent years is due in part to continuing federal and  nonfederal efforts to educate homeowners in the wildland-urban interface  and to state and local governments’ adopting laws requiring that such  measures be used. Education efforts, such as the Firewise Communities  program, seek to increase the voluntary use of such measures by working  with community leaders and individual homeowners. As wildland fires  have become more severe and the number of damaged homes has grown,  more state and local governments have adopted laws requiring  homeowners or homebuilders to use measures to reduce the risk to  structures from wildland fires. Nevertheless, federal and nonfederal fire  officials told us that protective measures are not used consistently in many  areas at risk from wildland fire. Some homeowners and homebuilders, for  example, resist using fire-resistant landscaping and roofing because they  are concerned about aesthetics, time, or cost. As a result, federal and  nonfederal officials said, it can be politically difficult for state and local  governments to adopt—and enforce—laws requiring such measures, and  many at-risk areas have not done so. In 2004, the Western Governors’  Association reported that greater use of protective measures was urgent,  but the progress made was unknown.
The states and communities we visited exhibited various degrees of  progress in adopting laws requiring protective measures. Since 1965, for  example, California has required homeowners in the wildland-urban  interface to maintain 30 feet of defensible space around their homes, a  requirement that was increased to 100 feet in 2005. This law applies to  existing homes as well as to new construction and specifically allows local  jurisdictions to adopt stricter standards. In areas at particularly high risk  from wildland fires, California regulations also require new structures to  be constructed with fire-resistant roofing materials and vents. The other  states we visited do not have such statewide requirements, but they are  taking a variety of steps to require or encourage protective measures.  Utah, for example, passed a law in 2004 requiring its counties to adopt  standards for landscaping and building materials if they want to be eligible  to receive state funds to assist with fire suppression costs. According to  state officials, exactly what will be required under these standards was  still being determined, but once final, the standards will apply only to new  construction, not existing structures. Similarly, Arizona did not have any  statewide requirements, although it adopted a law in 2004 explicitly  granting local governments the authority to establish codes to mitigate  wildland fire risk in the wildland-urban interface. Finally, in Colorado,  laws requiring protective measures have been adopted primarily at the  local, not state, level. Although some counties, such as Larimer County,  required owners of new structures in the wildland-urban interface to use  measures to help mitigate fire risk, others—including the three counties  affected by the wildfires we reviewed—were educating homeowners  about measures they can use to reduce their risk, without requiring that  such measures be used.
section_title: Cost-Sharing Framework and Federal Assistance May Reduce the Incentive to Require the Use of Protective Measures
paragraphs: Although measures are available to help protect structures in the wildland- urban interface from wildland fires, federal officials expressed concern— and some nonfederal officials acknowledged—that the use of cost-sharing  methods that assign more costs to federal entities, and the availability of  federal emergency assistance, insulate state and local governments from  the cost of providing wildland fire protection. These federal officials  pointed out that wildland fires threatening structures often require added  suppression effort, such as an increased number of aircraft and fire  engines or firefighters to remove vegetation around individual structures.  Under some cost-sharing methods, such as acres burned, federal entities  often end up paying a large proportion of the costs for these efforts. Some  federal and nonfederal officials also noted that the availability of FEMA  assistance to nonfederal entities—which can amount to 75 percent of  allowable fire suppression costs for eligible fires—further insulates state  and local governments from the cost of protecting the wildland-urban  interface. Of the eight fires included in our review, nonfederal officials  were seeking reimbursement for the allowable costs of the five fires that  FEMA determined met eligibility requirements.
Federal officials suggested that to the extent that state and local  governments are insulated from the cost of protecting the wildland-urban  interface, these governments may have a reduced incentive to adopt laws  requiring homeowners and homebuilders to use protective measures that  could help mitigate fire risks. Homeowner and homebuilder resistance  make it politically difficult to adopt and enforce such laws. Both federal  and nonfederal officials noted, however, that greater use of fire-resistant  building materials and landscaping could help reduce the cost of  protecting the wildland-urban interface. Some officials also said that by  requiring homeowners and homebuilders to take such measures, more of  the cost of protecting the wildland-urban interface would then be borne by  those who chose to live there. The Colorado State Forest Service, for  example, has reported that the expansion of the wildland-urban interface  has increased wildland fire suppression costs, but that these costs have  not been equitably divided because all taxpayers—not just those who live  in areas threatened by wildland fire—fund the cost of suppression.
section_title: Officials’ Concerns May Reflect Ambiguity over Financial Responsibilities
paragraphs: On the basis of our review of previous federal reports and interviews with  federal and nonfederal officials, we believe that the concerns we identified  may reflect a more fundamental issue—that federal and nonfederal  firefighting entities have not clearly defined their financial responsibilities  for wildland fire suppression, particularly those for protecting the  wildland-urban interface. Federal officials said that the continuing  expansion of the wildland-urban interface and rising fire suppression costs  for protecting these areas have increased the importance of resolving  these issues. First, federal wildland fire management policy states that  protecting structures is the responsibility of state, tribal, and local entities;  but the policy also says that, under a formal fire protection agreement  specifying the financial responsibilities of each entity, federal agencies can  assist nonfederal entities in protecting the exterior of structures  threatened by wildland fire. Forest Service guidance defines actions to  protect the exterior of structures to include removing fuels in the vicinity  of structures and spraying water or retardant on structures or surrounding  vegetation. Federal and nonfederal officials agreed that federal agencies  can assist with such actions, but they did not agree on which entities are  responsible for bearing the costs of these actions. Federal officials told us  that the purpose of this policy is to allow federal agencies to use their  personnel and equipment to help protect homes but not to bear the  financial responsibility of providing that protection. Nonfederal officials,  however, said that these actions are intended to keep a wildland fire from  reaching structures, and financial responsibility should therefore be  shared between both federal and nonfederal entities.
Second, the presence of structures adjacent to federal lands can  substantially alter fire suppression strategies and raise costs. A previous  federal report and federal officials have questioned which entities are  financially responsible for suppression actions taken on federal lands but  intended primarily or exclusively to protect adjacent wildland-urban  interface. Fire managers typically use existing roads and geographic  features, such as rivers and ridgelines, as firebreaks to help contain  wildland fires. If, however, homes and other structures are located  between a fire and such natural firebreaks, firefighters may have to  construct other firebreaks and rely more than they otherwise would on  aircraft to drop fire retardant to protect the structures, thereby increasing  suppression costs. For example, for the Sunrise Complex fires in Utah,  federal and nonfederal officials agreed that if structures had not been  present, they could have used easily accessible roads to contain the fire  and would not have used as many aircraft. Nonfederal officials in several  states, however, questioned the appropriateness of assigning to nonfederal  entities the costs for suppression actions taken on federal lands. These  officials, as well as NASF officials, also said that accumulated fuels on  federal lands is resulting in more severe wildland fires and contributing to  the increased cost of fire suppression. They also said that federal  agencies are responsible for keeping wildland fires from burning off  federal land and should, therefore, bear the costs of doing so. Federal  officials in the states we visited recognized this responsibility, but some  also said that with the growing awareness that wildland fires are inevitable  in many parts of the country, policy should recognize that wildland fires  will occur and are likely to burn across jurisdictional boundaries. In their  view, those who own property in areas at risk of wildland fires share a  portion of the financial responsibility for protecting it. Previous federal  agency reports have also recognized this issue and have called for  clarifying financial responsibility for such actions.
section_title: Conclusions
paragraphs: Wildland fires are an enduring part of the landscape, and they will  continue to affect both federal and nonfederal lands and resources.  Federal, state, and local firefighting entities have taken great strides to  develop a cooperative fire protection system so that these entities can  effectively work together to respond to these fires. Nevertheless, where  federal and nonfederal lands and resources are adjacent or intermingled,  particularly in the wildland-urban interface, different views prevail about  which entity is responsible for the costs of protecting these lands and  resources. Without explicit delineation of each entity’s firefighting  financial responsibilities, federal and nonfederal entities’ concerns about  how these costs are shared are likely to continue. In addition, lack of  clarity about respective financial responsibilities can also make it more  difficult for both federal and nonfederal entities to accurately forecast and  plan for future budget needs. As the wildland-urban interface continues to  become a more prominent feature of the fire suppression landscape,  contributing to rising suppression costs, the need for clarity is becoming  more acute. Improved guidance that clearly delineates federal and  nonfederal entities’ financial responsibilities for suppressing wildland fires  could assist all entities in better planning for, and during, a fire season.
section_title: Recommendations for Executive Action
paragraphs: To strengthen the framework for sharing wildland fire suppression costs,  we recommend that the Secretaries of Agriculture and the Interior,  working in conjunction with relevant state entities, take the following two  actions:    provide more specific guidance as to when particular cost-sharing  methods should be used and   clarify the financial responsibilities for suppressing fires that burn, or  threaten to burn, across multiple jurisdictions.
section_title: Agency Comments and Our Evaluation
paragraphs: We received written comments on a draft of this report from the Forest  Service and Interior. Both agencies generally concurred with our findings  and recommendations. The Forest Service stated that it will clarify the  guidance to the field regarding the most appropriate cost-share method to  use in a given situation, which will serve as a place to begin negotiations  with its partners. We recommended, however, that the Secretaries of  Agriculture and the Interior work in conjunction with relevant state  entities to develop more specific guidance. If the Forest Service  independently clarifies guidance without engaging state entities that also  will be affected by any changes, there is no assurance that these state  entities will agree to the changes in cost-sharing methods. Interior stated,  however, that it would work closely with the Forest Service and state  agencies to clarify such guidance to the field.
The Forest Service also stated that its financial responsibilities are clearly  defined in policy. Several federal officials with whom we spoke during our  study disagreed, however, stating that these policies do not clearly  delineate federal entities’ financial responsibility for fire protection,  especially in regards to the wildland-urban interface. Although Forest  Service policy states that structural fire suppression is the responsibility of  tribal, state, or local governments and the Forest Service’s primary  responsibility and objective for structure protection is to suppress  wildland fire before it reaches structures, it does not clearly define what  this would constitute. Officials told us that such actions could include  efforts on Forest Service lands to keep fire from crossing jurisdictional  boundaries or suppression actions in closer proximity to a structure, such  as removing vegetation or other flammable objects. Without a clear  definition of each entity’s protection and related financial responsibilities,  it will be difficult to determine how to appropriately share the costs of the  efforts. The Forest Service also provided additional comments that we  have incorporated in this report where appropriate. The Forest Service’s  and Interior’s letters are reprinted in appendixes III and IV, respectively,  along with our evaluation of specific Forest Service comments in appendix  III.
In addition to these federal agencies, we also sought comments from  NASF because of our report’s potential financial implications for states  and other nonfederal entities. NASF provided both oral comments and a  written response to our report. NASF did not agree with our  recommendations, stating that developing national guidance specifying  appropriate cost-sharing methods and clarifying financial responsibility for  fire suppression costs would not provide the flexibility needed by local  federal and nonfederal officials to address the variability in local  circumstances and state laws. We agree that a certain amount of flexibility  is needed. However, without more specific guidance to assist federal and  nonfederal officials when developing cost-sharing agreements for  particular fires, inconsistencies in the methods used—as well as perceived  inequities in how costs are shared between federal and nonfederal entities,  as expressed by many officials with whom we spoke—are likely to  continue. A copy of NASF’s letter and our evaluation of its specific  comments are included in appendix V.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to interested  congressional committees, the Secretaries of Agriculture and the Interior,  the Chief of the Forest Service, the Director of the Bureau of Land  Management, and other interested parties. We will also make copies  available to others upon request. In addition, this report will be available  at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have questions about this report, please contact me at  (202) 512-3841 or nazzaror@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix VI.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine the general framework for how federal and nonfederal  entities share suppression costs when fires burn or threaten both their  lands and resources, we reviewed federal laws and interagency policies  governing cost sharing for cooperative fire protection efforts. To identify  similarities and differences in the cost-sharing framework and available  methods from state to state, we obtained and reviewed master agreements  between federal and nonfederal entities for 12 western states. Although  wildland fires can affect all states, we focused our review on these  western states, which have substantial federal lands and often experience  wildland fires.
To identify how cost-sharing methods are applied in different states, we  selected a nonprobability sample of four states—Arizona, California,  Colorado, and Utah—that used a variety of different methods to share  wildland fire suppression costs between federal and nonfederal entities. In  each of the four states, we selected a nonprobability sample of two fires  that occurred in 2004 or 2005 and were managed by either the Forest  Service or the Bureau of Land Management. The eight fires all burned or  threatened to burn both federal and nonfederal lands, burned or  threatened both natural resources and wildland-urban interface areas, and  were of sufficient size and complexity to require type 1 or type 2 incident  management teams for a portion of the fire. For each of the eight fires, we  reviewed available records on firefighting personnel, aircraft, and  equipment used for fire suppression efforts; reviewed fire cost data;  reviewed the cost-sharing agreement that federal and nonfederal officials  negotiated, if any; interviewed federal and nonfederal officials to identify  the process used to select the cost-sharing method; and obtained agency  estimates of total suppression costs that were based on data collected by  federal agencies for each fire. Using this information and working with  federal and nonfederal officials, we estimated the federal and nonfederal  shares of the suppression costs. To determine the effect of the cost- sharing method selected on the relative proportion of costs borne by  federal and nonfederal entities—for the five fires that used a cost-sharing  method other than acres burned—we compared the estimated federal and  nonfederal shares of costs resulting from the cost-sharing agreement to  our estimate of what the federal and nonfederal shares of costs would  have been if an acres-burned method had been used. We used estimates of  suppression costs for some of the fires because the entities had not yet  determined the actual total cost for all eight fires we reviewed. To  determine the reliability of the data used, we reviewed previous audits of  the federal financial systems used for the accounting of fire costs;  interviewed federal officials knowledgeable about these systems to  identify how data are entered into the system and what steps are taken to  help ensure accuracy; and, working with federal and nonfederal officials,  reviewed data on the specific firefighting assets used and the related costs  for the eight fires. Because we were primarily interested in the relative  proportions of fire costs borne by federal and nonfederal entities using  different cost-sharing methods, we determined that these data were  sufficiently reliable for the purposes of this study. The 12 master  agreements reviewed, the four states visited, and the two fires we  reviewed within each state are all nonprobability samples. The results of  these samples, therefore, cannot be used to make inferences about all  master agreements, states, or wildland fires.
To identify concerns that federal and nonfederal entities may have about  the existing cost-sharing framework, we reviewed previous reports on  wildland fire suppression, including large fire cost reviews conducted by  the Departments of Agriculture or the Interior, a series of reports by the  National Academy of Public Administration, and reports by state entities.  We interviewed federal officials from the Department of the Interior’s and  Forest Service’s national offices and the National Interagency Fire Center  in Boise, Idaho; Forest Service officials from the four regional offices and  other Forest Service officials involved with the fires we reviewed; and  Bureau of Land Management officials from the two state offices and  several district offices involved with the fires we reviewed. We also  interviewed additional federal officials in other regions and states to  obtain a broader perspective on any concerns with the cost-sharing  framework. Nonfederal officials that we interviewed included state—and,  in some cases, local—officials from the four states we visited, as well as  officials from Montana, Oregon, and Washington. We also reviewed  reports by or interviewed officials from the National Association of State  Foresters (NASF), the Western Governors’ Association, and the National  Association of Counties. To better understand the concern officials raised  about the cost-sharing framework and incentives to increase the use of  protective measures, we reviewed federal policies and reports on  protecting the wildland-urban interface, including the National Fire Plan  and the federal wildland fire management policy; federal laws and  regulations governing Federal Emergency Management Agency (FEMA)  assistance; and reports by GAO, the American Planning Association, and  state audit entities.
We performed our work in accordance with generally accepted  government auditing standards from May 2005 through May 2006.
section_title: Appendix II: Characteristics of the Eight Fires That GAO Reviewed
paragraphs: Appendix II: Characteristics of the Eight  Fires That GAO Reviewed   Number of acres burned (percentage of total)    231,171 (94%)
15,543 (6%)
22,549 (97)
634 (3)
2,928 (93)
220 (7)
4,180 (24)
13,238 (76)
9,124 (80)
2,233 (20)
1,404 (50)
1,402 (50)
10,331 (84)
1,955 (16)
18,186 (85)
3,272 (15)
section_title: Appendix III: Comments from the USDA Forest Service
paragraphs: The following are GAO’s comments on the USDA Forest Service’s letter  dated April 18, 2006.
subsections: section_title: GAO Comments
paragraphs: 1.  We modified the language of our report to clarify that the cost-sharing  method chosen can have significant financial consequences for the  entities responsible for providing fire protection to the lands involved.  Although we agree that fires affecting the wildland-urban interface  may be costly, regardless of the method used, it is precisely these high  costs that make it critical for federal and nonfederal entities to agree  on appropriate cost-sharing methods.  2.  We modified the language of our report to clarify that for the two fires  discussed, nonfederal entities would likely have borne a greater  proportion of the costs if another cost-sharing method had been used  that better recognized the many aviation and ground firefighting assets  that went toward protecting nonfederal lands and resources. We are  not implying that costs should be shifted to the state or nonfederal  entities without any basis. Rather, federal and nonfederal partners  need to agree on cost-sharing methods that appropriately distribute  wildland fire suppression costs on the basis of the federal and  nonfederal lands and resources requiring fire protection and the extent  of firefighting assets used to protect each.
section_title: Appendix IV: Comments from the Department of the Interior
section_title: Appendix V: Comments from the National Association of State Foresters
paragraphs: The following are GAO’s comments on NASF’s letter dated May 5, 2006.
subsections: section_title: GAO Comments
paragraphs: 1.  NASF stated that it believes that the national template currently being  developed for master cooperative agreements will provide appropriate  guidance for cost-sharing agreements. As NASF noted, the draft  template lists several options for sharing suppression costs but does  not provide definitive guidance as to when each cost-sharing method  should be used. NASF stated that it does not believe that further  efforts to define the specific circumstances that would warrant the  selection of one cost-sharing method over another would be either  productive or helpful. We continue to believe that more specific  guidance—which could consider local characteristics and  conditions—would assist local federal and nonfederal officials in  negotiating cost-sharing agreements for individual fires. Without such  guidance, inconsistencies in how costs are shared are likely to  continue, along with perceived inequities within and among states.  2.  NASF strongly believes that it is not the responsibility of the  Secretaries of Agriculture and the Interior to clarify the financial  responsibilities for suppressing fires that burn or threaten to burn  across multiple jurisdictions. We agree with NASF that the Secretaries  alone cannot clarify these responsibilities, and for that reason, we  recommended that the Secretaries do so in conjunction with relevant  state entities. Further, NASF stated that it is neither feasible nor  appropriate to attempt to define at the national level the financial  responsibilities for these fires. Ultimately, however, one or more  entities will end up paying for the costs of fighting a particular fire,  whether by explicit agreement beforehand or by negotiation afterward.  To avert decision making after the fact, we maintain that federal and  nonfederal entities—which have developed an effective cooperative  firefighting relationship—need to further clarify their respective  financial responsibilities in guidance articulated in advance of the fire  season.
In addition to written comments, NASF also commented orally about two  other issues discussed in our report. First, NASF officials expressed  concern about our example illustrating the influence of FEMA assistance  on the selection of a cost-sharing method for a particular fire. They said  that, in their experience, the availability of FEMA assistance does not  influence a state’s willingness to use certain cost-sharing methods, some  of which may lead states to pay higher costs. Although we did not attempt  to determine how often the availability of FEMA assistance affected a  state’s choice of cost-sharing method, we believe that our example  illustrates how, without specific guidance, costs for similar fires have been  shared in different ways. In its written comments, Interior also raised a  related concern about federal assistance such as FEMA’s. Interior  commented that it has already seen the issue arise several times this year,  when states have requested, then canceled, federal firefighting resources  seemingly on the sole basis of whether federal reimbursement was  available. Second, with regard to state and local governments’ incentives  for protecting the wildland-urban interface, NASF officials said that  reducing the potential loss of life and property provides sufficient  incentive for state and local governments to adopt laws requiring the use  of protective measures against wildland fire. As we noted here and in a  previous report, however, many jurisdictions at risk from wildland fire  have not yet adopted such laws. We have incorporated other NASF  comments into our report as appropriate.
section_title: Appendix VI: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, David P. Bixler, Assistant  Director; Ellen W. Chu; Jonathan Dent; Janet Frisch; Timothy Guinane;  Kevin Jackson; Richard Johnson; Chester Joy; Winchee Lin; Tom  Moscovitch; and Jena Sinkfield made key contributions to this report.
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