11 Apr 2011, 1:17pm
Federal forest policy Saving Forests
by admin

Cohesive Strategy Promising

Review by Mike Dubrasich, Exec Dir W.I.S.E.

Last month without fanfare the Wildland Fire Leadership Council (WFLC) released the final version of the National Cohesive Wildland Fire Management Strategy Report (aka the CS Report).

The Secs of Agriculture and the Interior had been directed by Congress through the “Federal Land Assistance, Management, and Enhancement Act of 2009″ (aka the FLAME Act) to develop a comprehensive wildland fire management strategy and present it to Congress last November. The process took a little longer than expected, in part because the WFLC held fourteen forums across the country to discuss the issues with interested citizens. That effort at dialog was serious and it took time, as well as generating significant input for consideration.

We have discussed the Cohesive Strategy previously [here, here, here, here, here, here, here]. The final (March 17, 2011) version of the National Cohesive Wildland Fire Management Strategy Report is [here]. A companion report, entitled The Federal Land Assistance, Management and Enhancement Act of 2009 Report to Congress, is [here].

The CS Report is technically Phase I. Phase II will be Development of Regional Strategies and Assessments, and Phase III will be National Trade-Off Analysis and Execution. The nominal purpose of this 3-Phase project is to “systematically and thoroughly develop a shared national vision for present and future wildland fire and land management activities in the United States,” including “a dynamic approach to planning for, responding to, and recovering from wildland fire incidents”.

The CS Report identifies three “challenges” associated with fire management:

* Restoring and maintaining resilient landscapes. The strategy must recognize the current lack of ecosystem health and variability of this issue from geographic area to geographic area. Because landscape conditions and needs vary depending on local climate and fuel conditions, among other elements, the strategy will address landscapes on a regional and sub-regional scale.

* Creating fire-adapted communities. The strategy will offer options and opportunities to engage communities and work with them to become more resistant to wildfire threats.

* Responding to wildfires. This element considers the full spectrum of fire management activities and recognizes the differences in missions among local, state, tribal and Federal agencies. The strategy offers collaboratively developed methodologies to move forward.

While there is plenty of bureaucratic obfuscation in the CS Report, careful parsing reveals some elements that represent real progress forward. This review “reads between the lines” and highlights selected phrases and sentences from the CS Report for interpretation. Other reviewers may interpret it differently.

1. Cost-plus-loss risk assessment

The CS Report delves into “risk assessment”. The authors define “risk” in various ways, but include the following verbiage:

Risk is an inescapable component of living with wildfire. Whether one uses risk in the conventional sense of “something bad may happen” or a more precise definition such as the expected loss from an uncertain future event(s), the basic elements of uncertainty and loss are there. Following this basic reasoning, one can view the National Cohesive Strategy as a classic problem of risk management. That is, effective management requires understanding the nature of wildfire and its contributing factors, recognizing the consequences-good and bad-of fire, addressing uncertainty, and crafting plans that reduce the chances of catastrophic losses. Realworld constraints on funding, available resources, and administrative flexibility further require consideration of economic efficiency and practicality.

What this means is that wildfires do damage to resource values, and the authors recognize that purpose of fire suppression is to minimize those damages in an efficient manner.

The CS Report includes discussion of “the probabilistic expectation of net resource value change in response to fire.” Net resource value change (NVC) is roughly equivalent to cost-plus-loss. The key is in how “resource values” are defined. If they includes government-owned resource values (such as timber, water, wildlife, soils, air, etc.); and private property, businesses, and public health and safety values; and the costs of fire prevention and suppression, then NVC is the same as cost-plus-loss. That is certainly how it is treated in the forest economics literature. What the literature points out, although the CS Report does not, is that minimizing the NVC econometric function is the goal of fire management.

The CS Report correctly identifies risk assessment as “a long standing and mature scientific approach to quantifying risk,” and that the new Strategy will be to “assess, monitor, and respond to wildfire risk.”

Assessing and monitoring risk were explained in: Zybach, Bob, Michael Dubrasich, Gregory Brenner, and John Marker. 2009. U.S. Wildfire Cost-Plus-Loss Economics Project: The “One-Pager” Checklist. Wildland Fire Lessons Learned Center, Advances in Fire Practices, Fall 2009 [here]. In that paper we listed the types of risks as direct, indirect, and post-fire and included as value categories: Suppression costs, Property, Public health, Vegetation, Wildlife, Water, Air and atmosphere, Soil, Recreation and aesthetics, Energy, and Heritage. We noted that:

Suppression costs, however, represent only a small fraction of over-all wildfire cost-plus-loss. Other concurrent direct and indirect losses together with long-term post-fire losses can total 10 to 30 times the suppression costs. A more comprehensive economic and risk analysis and awareness on the part of decision-makers and the public of wildfire cost-plus-losses is needed, as are land and property management reforms, to help reverse these trends.

The commitment by the WFLC to pursue risk analysis is welcomed because we are suffering tens of $billions in wildfire costs-plus-losses (serious loss of multiple values, large negative NVC) every year. One goal of the new risk assessments should be to make them comprehensive; that is, to include all the values impacted by wildfire, even those many miles away.

It is also worth noting that NVC estimates are econometric. The units of value estimation are monetary, i.e. dollars. Not acres, not “satisfaction”, not some other unit of value measure — dollars are the accepted standard unit of value.

There are some defects in CS Report concerning risk assessment. Figure 1 on page 14 is incorrectly drawn and poorly explained. It is an exercise in hypothetical statistics and can be safely ignored. A more important error is the repeated conflation of fire intensity with fire severity.

Intensity and severity are not the same things. Fire intensity is the rate at which a fire produces heat, expressed in terms of temperature or heat yield. Fire severity is the degree to which fires consume the available biomass, kill living plants (especially trees), and inflict other types of resource damages.

While high intensity fires may often be severe, such is not always the case. A low intensity fire may do severe damage (for instance, by generating health-debilitating smoke for months on end). Conversely, a high-intensity fire may do little damage (for instance, a hot and rapid grass fire may not damage resources significantly).

The NVC analytical method presented in the CS Report uses intensity and severity interchangeably. That is improper. Severity is the appropriate factor to use. Intensity has received much attention in fire studies, and is something that that fire scientists think they can predict. But intensity is a cludge, an attribute that is relatively easy to measure but is the wrong attribute to use in the desired analysis.

So that wrinkle needs ironing. But overall, the emphasis on assessing the impacts to values by wildfire is a step forward for the WFLC.

2. Restoration

The CS Report mentions “restoration” numerous times. “Restoring and maintaining resilient landscapes” is a primary goal.

To be sure, the CS Report does not define “restoration”, other than tangential reference to “ecosystem health” and “fuel treatments… to address forest restoration and create fire resilient forests” to reduce “risk to landscapes”. But the CS Report authors included a long section on historical fire, tout “traditional ecological knowledge”, and even use the phrase “historical fire regimes”.

History is an important element in restoration. To restore something means to bring it back to an earlier and (presumably) better condition. The earlier (historical) condition thus is the benchmark or target, and we need to study history in order to understand how and why that condition existed.

Forest restoration specifically means active management to recover historical cultural landscapes, historical vegetation development pathways, and traditional (historical) ecological stewardship to achieve resiliency to fire and insects, provide sustainable resource products and services, and to preclude and prevent a-historical catastrophic fires that degrade and destroy myriad resource values [here, here, here].

The CS Report authors go so far as to state:

The historical contribution of Native American burning practices to the historical fire regime in many of these areas would probably have to be considered dominant over natural ignitions.

That statement speaks volumes. If historical burning rates were anthropogenic, then lightning will not provide the desired fire frequency (assuming on ample evidence that the putative “goal” of the WFLC is “to return fire to the landscape”). Furthermore, anthropogenic fires were deliberate, planned, and skillfully executed by human practitioners. It was anthropogenic fire, not lightning fire, that shaped the anthropogenic mosaic imprinted on North American landscapes.

From: Dubrasich, Mike. 2010. Stand Reconstruction and 200 Years of Forest Development on Selected Sites in the Upper South Umpqua Watershed. W.I.S.E. White Paper 2010-5. Western Institute for Study of the Environment [here]:

Several lines of evidence suggest that the prairies, savannas, and open forests have been persistent vegetation types in the Upper South Umpqua Watershed for the last few thousand years, at least. Precontact forest development pathways were mediated by frequent, purposeful, anthropogenic fires deliberately set by skilled practitioners, informed by long cultural experience and traditional ecological knowledge in order to achieve specific land management objectives. At a landscape scale the result was maintenance of an (ancient) anthropogenic mosaic of agro-ecological patches. In the absence, over the last 150 years, of purposeful anthropogenic fires, the anthropogenic mosaic has been invaded and obscured by (principally) Douglas-fir. As a result, the Upper South Umpqua Watershed is now at risk from a-historical, catastrophic stand-replacing fires.

That inference can be safely extended to all of North America as well as to other continents. The CS Report authors reasonably state:

It is becoming increasingly clear that landscape scale changes in vegetation structure and fuel loadings are needed to significantly alter wildfire behavior, reduce wildfire losses, and achieve longer term fire resiliency.

But The CS Report drifts occasionally back to old paradigm thinking. For instance, the authors state:

The most efficient way to achieve these long-term landscape goals remains unclear, and there are different perceptions on the relative role and effectiveness of management activities versus natural and managed wildfire to reduce fuels.


Fire management objectives determine whether mitigation emphasizes restoring natural fire regimes, or suppression to protect highly valued resources (HVR), or a strategy in between. All of these components inform operational fuel treatment strategies.

That latter statement is incorrect. “Natural” fire regimes have not existed on this continent during the last 12,000+ years. “Natural” fire regimes are not historical; they are imaginary. Restoration does not seek to impose imaginary, a-historical conditions on landscapes.

Or should not. It is not the job of the federal fire community to incinerate our landscapes in a-historical fires, no matter how attractive the prospect may appear. Unmanaged wildfires (implied by the former statement) are not restoration, but they are illegal (see the next section on fire use).

We need to rid ourselves of the myth of “natural” fire. That is not what our forests “need”. Junk ecology leads to junk policy, and reliance on the junk notion of “natural fire” sets fire policy off track.

The CS Report does make an attempt to place fire management in its proper place: as an adjunct to land management. Land management describes the objectives; fire management is one aspect or attempt to achieve those objectives. What is important, and is recognized in the CS Report, is that fire management does not dictate land management goals — instead fire management is subservient to land management. The authors state:

Addressing wildfire is not simply a fire management, fire operations or wildland-urban interface problem -– it is a much larger, more complex land management and societal issue.

Indeed. But there is still an annoying tendency in the fire community to describe forestry as “fuel treatment”. Forests are more than fuels. The fire community still suffers from the hammer syndrome — their hammer is fire and everything looks like fuel to them.

Forests are much more than fuels. They are living systems and repositories of myriad natural resources and heritage. Burning forests down is not what the fire community was developed to do. Slowly that realization is dawning, although the fire community demonstrates much reluctance towards it.

The CS Report authors mention “statutory responsibilities, but they fail to specify those. Among the laws that govern Federal actions on forests are the Healthy Forests Restoration Act (HFRA) of 2003 and the Forest Landscape Restoration Act of 2009 (Title IV of the Omnibus Public Land Management Act of 2009). Those Acts add forest restoration to the statutory mandates of our federal land management agencies.

Title IV — now known as as the Collaborative Forest Landscape Restoration Program (CFLRP) — adopted a landscape restoration strategy that identifies and prioritizes ecological restoration treatments within landscapes that are least 50,000 acres in size.

* It includes restoration of the structure and composition of old growth stands according to the precontact old growth conditions characteristic of the forest type, maximizing the retention of large trees, as appropriate for the forest type, to the extent that the trees promote fire-resilient stands.

* Treatments must be in accordance with the Endangered Species Act of 1973 and the National Environmental Policy Act of 1969 (no poison pill “categorical exclusions”).

* It calls for reducing the risk of uncharacteristic wildfire, improving fish and wildlife habitat, including for endangered, threatened, and sensitive species, and maintaining or improving water quality and watershed function.

* It benefits local economies by providing local employment and training opportunities and the production of forest products including biomass for energy generation.

Nowhere does the HFRA or the CFLRP call for incinerating forests in lightning fires to achieve a-historical conditions. In fact, there is no law whatsoever that calls for such nonsense. The fire community needs to understand, and state more clearly, that it is illegal for them to operate outside the law and adopt programs that are in direct conflict with the law.

Restoration, however, is the statutory mandate, and it is good to see that the WFLC plans to conform to those land management laws.

The CS Report authors note a study made by the Deschutes National Forest that found restoration treatments to be effective at reducing risk to “highly valued resources”. They also note the conflict between “biodiversity conservation efforts” and reducing wildfire risks.

The work also illuminated the conflict between biodiversity conservation efforts on Federally managed lands and the high wildfire risk on fire-prone landscapes. … Specific designations and conservation reserves showed markedly higher conditional flame lengths, such as spotted owl active and potential home ranges. In contrast, the general forest matrix showed relatively high burn probabilities and lower conditional flame length. Most of the urban interface showed lower burn probability and expected flame length.

The lesson learned is that set-asides to allegedly “protect” highly valued resources often lead to the destruction of those very resources by severe wildfire. Restoration seeks to mitigate that Catch-22.

Restoration includes prescribed fire. The historical fire regime was anthropogenic. Prescribed fire has been the dominant historical norm. The CS Report notes that in the Western U.S. the historical fire extent was 2 to 10 times what it is today. That is not just because there was no fire suppression in precontact forests; it is because humans deliberately burned the landscape, igniting thousands of times more fires than lightning [here].

The fire community should realize that the future, if it includes forest restoration, involves a great deal of work for them — not merely in managing lightning fires but in deliberately burning restored landscapes that have been prepared to receive certain types of fire (i.e. low-severity) without damaging resources.

3. Fire Use

The CS Report does not include mention of “wildfire use” or “appropriate management response”. This is in keeping with the WFLC February 13, 2009 Guidance for the Implementation of Federal Wildland Fire Policy in which the use of those terms was proscribed [here]. For that matter, the CFS Report does not mention the new term of art for Let It Burn either: “natural ignitions to achieve desired objectives” or “niados”.

To be sure, the CS Report includes the following statement:

The risk map suggests the beneficial influence of wildfire to fire-adapted ecosystems throughout the interior Great Basin and Northern Rockies regions.

but that statement is not elaborated upon. Whatever the alleged “benefits” of wildfire might be are not listed or quantified.

The absence of “wildfire use” and other terms of art for Let It Burn is significant. It could be that the WFLC has finally realized that Let It Burn has two major problems:

* Wildfires do not achieve any resource enhancements; they only degrade resources

There have been some faulty attempts to ascribe resource benefits to Let It Burn. For instance, last summer the Fishlake National Forest allowed the Twitchell Canyon Fire [here, here, here, here, here, here, here]to burn unchecked for months. The stated rational applied was:

The fire is being managed for multiple objectives, which included providing for the safety of the public and firefighters, to increase structural diversity in forest and shrubland ecosystems through use of fire, reducing fuels in a mosaic pattern to effectively manage future fires, and to manage the fire for a scenic vegetation mosaic effect in the Manderfield Reservoir viewshed.

Not one of those alleged “objectives” was quantified beforehand, nor were any of them achieved. Instead the Twitchell Canyon Fire blew up, burned 45,000 acres, destroyed vegetation, wildlife habitat, historical structures, and powerlines, and caused extreme air pollution for months on end. Eventually over $17 million was spent to contain a holocaust that could have been controlled at less than 500 acres for less than $100,000.

Safety to the public and to firefighters was severely compromised. Structural diversity in the forest was eliminated. Fuels were reduced only temporarily, and dead fuels were actually increased. No mosaic pattern resulted. The viewshed was uglified.

The larger tragedy is that, over the last 20 years or so, dozens of “wildfire use” fires have blown up and done severe damage at enormous costs with no significant “benefits” achieved.

* Let It Burn is illegal

The National Environmental Policy Act (NEPA) is quite clear in stating that any major Federal action that will have significant effects and impacts on resources and the human environment requires an Environmental Impact Statement (EIS) prior to implementation of that action. Potential “significant effects” require an EIS whether or not those effects are characterized as detrimental or beneficial.

Neither the WFLC nor the five Federal land management agencies under their purview have ever implemented any NEPA process prior to a Let It Burn fire. There has never been any public process, public comment, or public review of any “wildfire use” fire, in direct violation of NEPA as well as the National Forest Management Act (NFMA), the Endangered Species Act (ESA), the National Historic Preservation Act (NHPA), and the Administrative Procedure Act (APA).

The CS Report does not mention those problems, but the authors did note:

There are social and regulatory challenges to the active management of landscapes and biomass utilization. Because of fire’s impact on air quality and water resources, and on commodity and community values, there are regulatory and social constraints on its use and management.

That’s a half-way statement. Fire also impacts non-commodity values such as wildlife, soils, scenery, water quality, etc. NEPA is not limited to commodities only. The NEPA process includes examination of effects of Federal actions on all environmental resources, commodities or not. The “regulatory” challenge extends to “wildfire use” as well as other Federal projects.

The CS Report does include the following statements:

Safe aggressive initial attack is often the best suppression strategy to keep unwanted wildfires small and costs down. …

As fires grow large, they spread long distances and burn locations distal to the ignition. …

Wildfire Response GOAL: … Pre-fire multi-jurisdictional planning occurs. …

The process can be used to weigh management options within the context of land and resource management plans, collaborative frameworks, community protection plans, and other landscape planning efforts.

Unplanned ignitions cannot be “used” to “achieve desired objectives” without violating a stack of laws. The WFLC may be finally getting that message.

4. Collaboration

The CS Report makes collaboration with “stakeholders” a primary goal:

The key to a cohesive strategy is its inclusiveness. A national strategy must be just that — one that has applicability and relevance across the board from the small, rural fire department in Maine, to a large city in California, to a state forestry department in North Carolina or a tribal community in the Midwest, as well as to the Federal agencies. Simply including all stakeholders is not enough. A strategy, shaped by a shared vision, requires building new relationships among those stakeholders. Skepticism and issues of trust must be recognized and overcome; all voices must be acknowledged and heard.

The CS Report also defines “stakeholder” to mean:

A person or group of people who has an interest and involvement in the process and outcome of a land management, fire management, or policy decision.

That’s pretty inclusive.

Historically the WFLC has been exclusionary and non-transparent, but last February they established a new Wildland Fire Executive Council (WFEC) to advise the WFLC [here]. The WFEC will hold meetings will be open to the public, something the WFLC has never done. Furthermore, the WFEC will be instrumental in Phase II of the Cohesive Strategy:

The WFLC designated the Wildland Fire Executive Council (WFEC) to oversee implementation of the Cohesive Strategy. The WFEC’s organizational structure closely mirrors that of WFLC; thus, the same broad representation of local, state, tribal and Federal organizations remains intact. As Phase II of the Cohesive Strategy begins, regional strategy committees will be established. Local and regional plans and direction will take form during Phase II. Regions may elect to establish sub-regions to ensure inclusivity. The delegation of responsibility and authority for the Cohesive Strategy ensures a voice in governance at all levels and fire jurisdictions. …

Regional Strategy Committees will include members from the DOI agencies, USDA Forest Service (Forest Service), tribes, state foresters, and representatives of the following elected officials: a governor, county commissioner, and mayor. Additional members may be added to the regional strategy committees as the committees see fit.

It is not clear whether Regional Strategy Committees will hold open and transparent meetings, but we expect that they will. Otherwise the new spirit of collaboration will be thwarted. Two of their tasks are:

* Relying on local and regional knowledge and insights, describe a small set of regional alternatives. This exercise draws from the understanding gained from analysis of the initial alternatives. These alternatives would be shared with and shaped by regional stakeholders.

* Analyze the regional alternatives and share the results with stakeholders. Update content based on regional feedback.

The WFLC may find public involvement to be a challenge, but it is in their long-term best interests and in the best interests of the public to open up a dialog regarding wildfire.

In summation, there are several aspects of the National Cohesive Wildland Fire Management Strategy Report that hold promise. We offer SOS Forests kudos to the authors and the WFLC, and hope that the promises are kept and realized.

11 Apr 2011, 2:23pm
by John Marker

Mike you have done what I consder a superb job of analyzing the Cohesive Strategy and pointing out its positive potential as well as its discussions needing more thinking and some rewriting. However, as you point out there is hope this document can be the start of some serious work to really protect our forests from serious fire loss, and do so using good information rather than the all too abundant mythology about fire.

12 Apr 2011, 5:26pm
by Larry H.

This is excellent and hopeful news. The mythological inertia about fires being “natural and beneficial” is going to be hard to overcome. If these fire experts can alter their ways of thinking, so can Congress, Joe Public and maybe even some eco groups.

I have to think that Mike has had something to do with this turnabout, by fighting the Rogue River-Siskiyou NF plans to bring Let-Burn under NEPA. Sometimes the Forest Service tries to sneak things past the public they know aren’t exactly kosher, under law. They have succeeded in doing that in the past. It seems like they may have decided that it is easier to just follow the law, because people like Mike show them they cannot get away with it.

Thanks for all you do, Mike!

15 Apr 2011, 11:39am
by bear bait

Marbled murrelets were ESA listed based on a Master’s Paper that was far inferior to this discussion of wildland fire and our governments. Where are the academics in this question of legality and forest management? Still fighting who will represent them in the Faculty Senate??

Good job, Mike. Even I can understand it. Thank you!!!



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