The Big Bar Complex

The Kirk Complex

Table 2.
National Expenditures for Emergency Fire Suppression
1980 through 1999, USDA Forest Service.

Team Findings

The findings of this report are divided into three categories -- general themes that have surfaced, those specific to the Big Bar and Kirk Complexes, and those with broad national implications. The findings are as follows:

Themes:

Many federal, state, and local fire managers were interviewed about the Big Bar and Kirk Complexes and large fire management in general. Several themes, some critical of the current fire management program, have emerged. These themes help establish a foundation for the fire management program so realistic adjustments can be made. These themes include:

• The consequences of declining preparedness funding at the field level are not completely understood. For every dollar reaching the ground, there is a reduction of five to seven dollars in the cost of suppression and emergency rehabilitation, and a corresponding decrease in natural resource damage. By not funding preparedness close to the 100 percent of MEL, additional suppression and rehabilitation costs, and natural resources destroyed increase dramatically. Funding at the MEL does not mean there will be no losses, but these losses increase exponentially as funding for preparedness declines.
• Less preparedness funding is reaching the field level. There are numerous reasons, including budgeting changes, unplanned special projects, and the willingness to view suppression costs as "off-line" or "free." The Forest Service is making budget allocation choices that indicate fire is a low priority. By diverting preparedness funds and not requesting higher funding levels closer to the MEL, we are making other investments in natural resources that we cannot protect from destructive fire. In doing so, we are essentially devaluing natural resource losses.
• Fire suppression is much more complex than ever before. An experienced fire management workforce, once the hallmark of the Forest Service, is now in question. The initial strategic decision on a fire, pivotal to successful outcome of the incident, is often delegated away by line officers, in part because they do not feel qualified to address today’s complexities of fire suppression. An aging workforce within the agency will make this experience/fire complexity dilemma even more severe in the future.
• Fire management planning has not been a priority, with less than 5 percent of the National Forests having current approved fire plans. The agency is not in compliance with the National Fire Management Policy.
• Excessive forest fuel makes effective and efficient firefighting almost impossible.
• The traditional "militia" approach to large fire suppression is not working; the overall reduction of Forest Service field personnel over the last decade is a primary reason. This, combined with the decreasing availability of existing personnel to participate in fire suppression activities because of low pay incentives, higher priority work, and a variety of personal reasons, will require some changes to be made if we are to remain effective.
• The current organizational climate does not encourage acceptance of levels of risk consistent with achieving greater cost efficiency, regardless of how well analyzed and documented fire management decisions are.
• Suppression alternatives that address costs through the WFSA need improvement.
• The need to keep costs as low as practicable is not a predominant message during a fire incident.
• Fire management should be one of the agency’s top Policy Issue Areas. Currently it is mentioned only tangentially to issues associated with ecosystem health.

Big Bar and Kirk Complexes Findings

Neither comprehensive interviews of the leadership of the involved National Forests, nor discussions with a wide range of federal, state, and local fire managers, nor our analysis of the initial review of the incident (National Large Incident Cost Oversight Report, September 30, 1999), identified anything that would have significantly reduced the costs of managing the Big Bar and Kirk Complexes. We did, however, highlight a number of factors that contributed to the overall costs, and we believe the identification of these can provide opportunities for future efficiencies on similar incidents. These contributing factors for the two complexes are organized by the same groupings used in the executive summary.

Factors inherent in the location or nature of the work include:

• Continued hot dry weather with little or no humidity recovery at night had a significant effect on fire behavior, acres burned, and suppression difficulties.
• Multiple fires across the Region meant that both complexes were competing for resources that were already in short supply – especially crews and overhead – and thus increased both the time necessary to staff the fires and also the costs of doing so.
• Because of repeated and severe inversions on the Big Bar, aircraft could be used only for a two- or three-hour period each day. The inability to accurately scout fire perimeter and hotspots and thus effectively plan operations contributed to increased costs, more resource loss, and increased risk for firefighters and the public.
• A significant portion of each complex was in a wilderness area. Limited suppression tactics were planned to minimize long-term impacts.

Factors that require long-term strategies and significant investments to resolve:

• Limited access to the fires, along with extremely steep terrain, resulted in slow progress in containment efforts and repeated loss of completed fireline.
• Vegetation on the Kirk was so thick that retardant did not penetrate in several areas. Type I helicopters were used instead of fixed-wing airtankers in order to penetrate the canopy.
• Red-carded agency personnel did not participate and/or were not made available. In some instances, there were shortages of qualified resources. Accordingly, the majority of personnel on both these complexes were state and local firefighters, and the higher cost of state and local personnel increased costs on these fires. On the North Kirk Fire, for example, the use of local and state overhead rather than Forest Service employees resulted in an increased fire cost of about $13 million.
• Blowdown of several thousand acres on the Six Rivers National Forest occurred in 1996. This was not salvaged through logging. When the fire reached that area, its rapid rate of spread and the fuel loadings resulted in added cost and increased risk to firefighters.
• Over the last few years we have experienced a significant reduction of initial attack resources. For example, the Shasta-Trinity went from 27 to 18 engines and the Los Padres has gone from 25 engines to16, five helicopters to one, and two hotshot crews to one. Some believe this trend has reduced the Forests’ ability to contain single fires during the first burning period, let alone deal with multiple simultaneous fires. During this same period, the Los Padres has experienced a 50 percent increase in burned acres, the population of the state has increased, and the wildland/urban interface has grown significantly.
• The shortage of Type I crews and the lack of performance of Type II crews necessitated the use of indirect attack more often than would have been efficient. This resulted in both increased acreage loss and increased suppression costs.

Factors with potential to improve efficiencies in the short run:

• Because of the complexities of tribal issues and relationships with the Bureau of Indian Affairs, a significant part of Incident Commanders' time was diverted from the main job of fire management.
• Present contracts do not allow for reduced costs for long-duration events. Full daily rates over a long period resulted in our paying the equivalent of the full price of some equipment such as cars or trucks.
• Infrared capability by aircraft was not readily available for the Kirk Complex. This necessitated the use of indirect tactics in order to maintain crew safety, and resulted in diminished suppression effectiveness, unnecessary delays, and increases in both resource loss and suppression costs.

Factors under the control of a Line Officer or Incident Management Team:

• Because the safety of fire personnel and the public was the number one priority on fires, and because of the factors cited above (combined with difficulty in obtaining ordered resources), indirect attack became the overall strategy on both fires. This was necessary and prudent to maintain firefighter safety, and resulted in increased costs and decreased suppression effectiveness. This does not imply that all indirect strategies are inefficient.
• Lack of understanding of WFSA and participation by teams and line officers on the Big Bar may have resulted in increased costs.
• The use of Minimum Impact Suppression Techniques (MIST) required by the Land Management Plan resulted in increased costs.
• The Incident Business Advisor (IBA) on the Kirk could have been assigned throughout the incident.

National Findings

The following are national issues that must be fully addressed in order to help the agency achieve its goal of reducing the threat and impacts of wildfires in ways that are safe, cost-effective, and in balance with a wide range of values.

Preparedness:
The NFMAS is a tool to help determine the MEL for the fire management program. The MEL displays the tradeoffs between the dollars spent on fire preparedness versus the fire suppression costs, plus the change in value of the natural resources burned.

One critical component of the NFMAS model and the determination of MEL is Net Value Change (NVC). The NVC is the dollar difference between the natural resources before and after a fire. Two other components of the NFMAS model are costs of fire preparedness and the cost of fire suppression. The model optimizes the appropriated dollars spent on fire preparedness versus the costs of fire suppression plus the value of the natural resource after it has been burned. The number of acres burned is also displayed at each appropriated funding level.

Appropriated funds for the fire management program are typically referred to as a percent of MEL. For example, in FY 1999, the Forest Service was funded at 75 percent of MEL. In FY 2000, funding levels for the fire management program are expected to be 74 percent of MEL. Additional indirect costs in FY 2000 may require this funding level to be reduced even further at the field level – perhaps to about one-half of the MEL. If this happens, one projected impact includes an increase of about $600 million in fire suppression costs.

The NFMAS process considers only lands for which the Forest Service has direct fire protection responsibilities; costs associated with protecting non-federal lands, including protecting the wildland/urban interface from a fire originating on a national forest, are not incorporated into the NFMAS model. The cost of protecting these values and the wildland/urban interface can be significant in some areas.

This fact goes right to the heart of preparedness levels for initial attack and extended attack to control fires. If the fire management program is expected to manage for events that include the wildland/urban interface, then funding levels must be planned with this in mind. Funding at 75 percent of MEL, with no provisions for wildland/urban interface fire protection, almost guarantees inadequate resources, inefficiencies and excessive costs. The following table illustrates the MEL funding for the last ten years (in millions of dollars).

³Proposed Actual Funding

Dollars are constant

Improved state fire assistance, including assistance to volunteer fire departments, is an effective way to reduce the overall involvement of the federal government in the wildland/urban interface adjacent to the National Forest boundary. The Cooperative Fire Management program, within the State and Private Forestry mission area, provides for a federal role to help state and local governments become better trained and equipped to fight fires and fulfill their state responsibilities. However, the program is underfunded by about 60 percent.

A higher level of funding for initial and extended attack on the National Forests, coupled with an emphasized state assistance federal role, including additional emphasis to the rural volunteer fire departments, would begin to effectively address the urgent need to deal with wildfire in America’s wildland/urban interface.

A cohesive long-term budget strategy must be developed, including preparedness, emergency suppression, fuels management, and state fire assistance in order to implement an effective, cost-efficient fire management program. An example budget strategy might look like this (dollars in millions):

A primary point illustrated above is that either/or options are not feasible in the beginning years. For example, with an increase in fuel management in year 1, we cannot conclude that a corresponding decrease in emergency suppression is logical. The more cause and effect relationships will not kick in until later – perhaps by years seven or eight after the beginning of the fuel management strategy.

The Federal Wildland Fire Management Policy says that "every area with burnable vegetation will have an approved Fire Management Plan." Today less than 10 percent of these lands have approved and current Fire Management Plans. When asked whether a Fire Management Plan would have made a difference in the effectiveness of the suppression efforts for the Big Bar and Kirk Complexes, the answer was “YES.” When asked why there was no approved Fire Management Plans for the two involved Forests and other National Forests in general, the most common reason was lack of priority and resources.

Sound wildland fire management decisions and resource management decisions go hand in hand, and are based on approved Fire Management Plans ttiered to the Forest Land Management Plan. Within the Fire Management Plans we may want to include specific tactical emphasis for agency administrators and incident commanders on the development and use of “guerilla” firefighting tactics. These tactics are not new, but are not commonly used. Guerilla tactics involve limited firefighting resources, “best ridge” ideas noted in past reports, specific identification of agency administrator objectives, and National Forest System lands with low to high resource/political values.

Across a range of wildland resource/political values, we apply the appropriate suppression response on National Forest System lands ranging from wilderness to high-value private land and structures. We typically apply tactics consistent with either end of the range in values; we may only monitor or confine wilderness fire while controlling (at minimum loss) fires near private land and structures. Tactics at each end of the scale are fairly well developed. We use extensive resources, with associated high cost, on one end of the scale, but use very limited resources with low costs on the other end of the scale. We need to improve the development of tactics to respond to those incidents in the middle.

These tactics would involve applying operations on the ground where they would matter most to agency administrator objectives, and would be applied by highly skilled professionals. These tactics would typically involve higher uncertainty and greater risk than either side of the current scale. The compelling reason for dealing with higher risk and uncertainty is the reward of lower cost for the agency.

Fuel Management

Many earlier reports, including the Federal Wildland Fire Management Policy, the General Accounting Office Report GAO/RCED-99-65, and "Course to the Future: Positioning Fire and Aviation Management" (May 1995, USDA Forest Service), emphasize the need for fuel management. The GAO report concludes that the most extensive and serious problem related to the health of forests in the interior West is the overaccumulation of vegetation, which has caused an increasing number of large, intense, uncontrollable, and catastrophically destructive wildfires.

A strategy is being developed to help solve this critical issue. "Protecting People and Sustaining Resources in Fire-Adapted Ecosystems: A Cohesive Strategy" (Draft Report, December 3, 1999, USDA Forest Service) calls for a targeted approach to removing excessive fuel through prescribed fire and mechanical treatments. The strategy is ambitious and will require significant increases in funding, even after base program funding shifts are made to reflect this priority.

Without an aggressive program in fuel management, especially in the interior West, effective cost-efficient fire suppression to protect lives, property, and natural resources will not be possible.

Line Officer Responsibilities and Oversight

When an incident begins on a National Forest, the Forest Supervisor is in charge. When an Incident Management Team arrives to take over the management of the incident, the Forest Supervisor must stay engaged in the process. The Delegation of Authority letter is a contract between the Forest Supervisor and incident commander, and it ensures all fire suppression actions are managed in a safe and efficient manner. However, the overall responsibility and accountability for the incident rests with the line officer.

Proper oversight becomes a very important ingredient to the overall success of the management of the incident. Who provides the oversight to the line officer to ensure the best chance for success? The answers are mixed, ranging from discussions with trusted staff to checking with past experienced colleagues. By most accounts, line officer involvement on the Big Bar and Kirk Complexes was good. Nevertheless, there does not seem to be a systematic approach to ensuring strong oversight of the line officer (as indicated by the line officers themselves for these two complexes).

Consider the flip side in the case where the line officer wants to more readily delegate roles and responsibilities to the Incident Commander. While perhaps not the desired condition, who provides the oversight for the Incident Commander, especially if there is no Area Command in place?

Improved oversight and more aggressive engagement by the line officer with the incident offers the chance to communicate that costs are a priority and keeping costs as low as practicable is expected. This can be and should be a predominant message.

National Large Incident Cost Oversight

The Forest Service Manual, regarding Large Incident Cost Review Procedures, specifies that a national oversight team will be called when one or more of the following criteria are met:

• The incident has a control objective, and the predicted time of control exceeds five days.
• A Type I or Type II incident management team is assigned to the incident.
• Actual or expected expenditures exceed $5 million.
• There are significant political, social, natural resources, or policy concerns.
• The affected Regional Forester requests a review team.

The team shall comprise:

• The Associate Deputy Chief for State and Private Forestry, or a representative.
• An Assistant Director, Fire & Aviation Management, or a representative.
• An Assistant Director, Financial Reports and Analysis Staff, or a representative.
• The National Safety Officer, Human Resources Management Staff, or a representative.
• A representative of the Regional Forester.
• A Staff Director or representative from the affected natural resource functional area or administrative unit of concern.
• Representatives from affected agencies, if the incident is using multi-jurisdictional command.

This direction must be applied more consistently, especially the direct engagement of the top leadership of the State and Private Forestry mission area.

The WFSA and the “Well Analyzed Fire Management Decision”

The WFSA provides a systematic approach to strategic decision-making for fire suppression. Overall, it is accepted as a very good tool. Some consider it only a communications tool, while others find it useful for documenting decisions. Few use its full potential to display the tradeoff between costs and risk. The analytical components of the WFSA must be expanded to better reflect issues associated with the wildland/urban interface and its use by line officers should be more consistent. Because of its potential, a more focused discussion of the WFSA is warranted.

The current WFSA process is too much a stand-alone tool, and set too far apart from the Land Management and the Fire Management planning processes on which it depends. The WFSA and the Land Management Plan should be more integrated, not only in terms of information needs but also conceptually in thow the LMP represents fire-related values, goals, and objectives such that they are meaningful and useful as inputs to the WFSA.

The WFSA process cannot reasonably be accomplished within the timeframe allowed between a determination that a fire has exceeded local suppression capabilities and the time an incident team arrives. The WFSA process, to be completely successful, must benefit from some prework or templating that allows the WFSA team to draw from work done with the Land Management and the Fire Management planning processes. Priority should be given this prework, including relevant training in constructing and implementing WFSA templates.

Though the WFSA is generally regarded as a good and useful tool, many users aren't sure they know what the WFSA is actually doing. Users need to understand in greater detail how the process operates to become comfortable with what is going on inside the WFSA.

Expertise in WFSA is inconsistent across fire management organizations. Better and more consistent training iis needed, along with a set of benchmarks or standards for proficiency. Because of the relative infrequency with which WFSAs are done, a consistent program of retraining is needed.

Better integration of WFSA into fire management team activities is needed. Current practices often result in the WFSA's being done by one or two individuals with relatively little involvement by the line officer or other natural resource area specialists.

The current WFSA implementation is too limited as a risk analysis and risk assessment tool. The focus is on problem structuring, values structuring, evaluation criteria, and economic assessment. Current implementation makes minimum use of uncertainty assessment techniques, and does not support methods for improving the quality of uncertainty assessments. To accomplish the goal of “well analyzed risks” would require an integration with other tools, particularly the Rare Event Risk Analysis Program (RERAP), Fire Area Simulator (FARSITE), and other fire behavior analysis methods. This would require better integration with information resource, such as GIS. Such integration would impose new training requirements. Also, a risk analysis approach would require modeling of the effectiveness of suppression resources, both in terms of theoretical production rates (e.g., chains of line per hour per hand crew), and in the actual conditions under which the resources are deployed (e.g., environmental conditions, terrain, fatigue).

We need to understand that the WFSA does not guarantee well-analyzed decisions. Very often, the process is approached as something that must be done. To make better decisions requires a better job of analysis. The WFSA is a tool to aid that activity, but to do so effectively, it must be used with full knowledge of its capabilities and limitations, and it has to be used constructively and creatively. Stepping through the WFSA software one screen at a time does not ensure a well analyzed decision; indeed, it may actually lead to poorer decisions, particularly when its use leads to fewer or lower quality inputs to the process. This can happen when critical resource area expertise is not consulted, when LMP information is not included, or when the various inputs called for in the software are not carefully thought through and critically evaluated. All fire suppression/management decisions should be made with good quality analysis, even if the WFSA software is not available.

The Militia Approach

In the past when a fire occurred, non-fire personnel would make themselves available. This is the Forest Service “militia,” and it has worked exceedingly well. However, there is now an increasing shortage of militia available for extended attack and large fire support in both direct suppression and fire support positions. There are many causes, including overall reduction of personnel at field locations, lifestyle, economic, family, local work priorities, and career tracks.

One of the past recommendations was to move toward preparing 75 percent of the workforce to be trained, qualified, and available to support fire emergencies by the year 2000. This has not happened, and probably won't, for many of the reasons cited above. One of the responses noted in an availability study conducted by Region 5 that "the Forest years ago lost its effective militia. While the Forest Supervisor supports participation, individuals are not willing to abandon critical items in their program of work. Further, relief from targets is not granted and competing demands make it impractical for many employees to accept fire assignments."

The report concluded that "this issue cannot be reconciled in the field and, unless it is seriously and definitively addressed at the Secretary’s or Chief’s level, we will remain in the unrealistic posture that professes to support employee involvement with fire while imposing roadblocks and providing relatively few incentives for those who serve."

There are many reasons, other than demands of current work, that people in the agency no longer view a fire suppression assignment as desirable. Frequently cited reasons include:

• Family commitments, especially childcare, with single parents or two-career families pose too great a conflict.
• The 21-day standard assignment is too long.
• Pressures to meet due dates and complete home unit work.
• Pay is not adequate.
• Supervisors are reluctant to let their people go, especially after multiple assignments.
• Fire management does not recruit, train, and qualify employees efficiently; employees grow weary of being in trainee status and not being called for assignments.
• Some people are never called, even though they are qualified. Some view this as "favoritism" and say the same people always get called, and that "non-fire people" are not welcome. Others, though, say that the employees who will always accept an assignment are more likely to be called.
• Dispatch processes are inefficient and inconsistent.

“An Agency Strategy For Fire Management” recommends a possible, partial solution through a national incident management organization for large fires and other disasters, in essence moving away from the militia approach to large fire suppression.

However, there is clearly not a consensus that discarding the traditional militia approach is the answer. A thorough analysis of this situation is important before we make any precipitous adjustments. Some believe there is much more we can do right now to get employees better involved. For example, the financial management specialists are busiest and generally unavailable during the two months before the fiscal year closeout, which happen to be the busiest fire months. Perhaps we can adjust the agency’s financial management closeout requirements to be more flexible with fire suppression needs. Other items such as pay, workload, feelings of inclusion, etc., have already been mentioned.

Over the years, many have written about the issue of the inequity of pay between Forest Service and other federal firefighters and local/state resources. The issue centers on the Exempt/Non-Exempt rules for pay, a pay cap at the GS-10, Step 1 level, and time allowed for a given shift.

For example, on the Kirk Complex, state and local employees were paid on a portal-to-portal basis; i.e. from the time they left their official station to the time they returned. Their hourly rates are also more – about $42 per hour for state and local fire employees compared to about $24 per hour for a federal employee. A typical shift length for a federal employee was 14 hours; 24 hours for a nonfederal employee. In terms of costs to the fire, this translates into about $1,006 per shift for the state and local employees and $360 per shift for the federal employees. Clearly, this creates an issue of morale. Working side by side, one would expect equal pay for equal work. This inequity must be corrected.

Because of the pay issues associated specifically with California, it is estimated that about $25 million could have been saved on the two complexes if only federal employees had staffed both incidents.

A compromise is probably the better solution. That is, continue to use state and local resources for fire suppression on public lands, but at a more limited rate, and increase the incentives for federal employees who are on the front line or in some way involved with the incident. This will also have significant positive impacts on issues associated with fire preparedness.

This pay issue affects the availability of personnel for key fire management positions. In many cases, largely due to the pay cap, highly qualified personnel will not work on fires because their overtime pay is less than they normally earn in straight pay status in their normal job. Fighting fires is hard, hazardous work. We should provide some incentive for the federal employees who take on fire suppression assignments.

There may be some relief in sight. Current legislation being considered by Congress would provide relief from the GS-10, Step 1 pay cap.

Pay issues, including the Fair Labor Standards Act (FSLA) and Hazard Pay, also affect the Burned Area Emergency Rehabilitation (BAER) program. Some BAER specialists are more willing to work on a fire in a labor position than in a management or technical position for which they are qualified, because they prefer to be non-exempt from the FSLA for pay purposes. Further, it is demoralizing for BAER personnel to be working on a damage survey within the burned area, side by side with mop-up firefighters, without getting Hazard Pay. These two issues have resulted in difficulty of forming BAER teams and a need to fill specialist positions with contract employees at a higher wage scale.

This issue should be applied to state and local employees who also experience lower pay rates. Fundamentally, all personnel who participate in fighting fires should expect to receive equal pay for equal work, regardless of the organization.

Siege Fires

Fires become costly, in part, because of factors that influence the time span over which an incident continues. Some incidents become “siege fires,” in which a combination of national priorities, environmental conditions, and social factors (including human resource factors) lead to circumstances characterized as a “siege mentality.” These circumstances affect personnel in terms of their perception of control of the incident, and may reduce their ability to sustain both the physical and psychological workload necessary on such fires.

Team Recommendations

The following are recommendations to improve the overall effectiveness and cost-efficiency of large fire management. Many of the recommendations, even though specific to the two complexes examined, have national implications. Accordingly, the team recommendations will not be separated (like in the findings) in this section of the report.

Increase initial and extended attack resources. This includes:

• Budgeting for preparedness resources at the Most Efficient Level to the field.
• Developing a cohesive, long-term budget strategy that includes preparedness, emergency suppression, fuel management, and state fire assistance in order to implement an effective, cost-efficient fire management program.
• Reducing the administrative support cost of the fire management program.

Implement fire management planning on a large scale, with a consistent basis. This includes:

• Incorporating wildland fire into the Natural Resource Agenda and ensuring that it is recognized as critical to the health and sustainability of our forests and range ecosystems.
• Tiering fire management planning to the Forest Land Management Plans.
• Considering fire an equal resource in the land management planning process. Community involvement and education is important.
• Highlighting the use of specialized or guerilla firefighting tactics, with limited firefighting resources, “best ridge” concepts, specific identification of agency administrator objectives, and lands with low- to high-range resource/political values.

Implement an aggressive fuel management program. This includes:

• Implementing “Protecting People and Sustaining Resources in Fire-Adapted Ecosystems."
• Providing for the Fire & Aviation Management staff, at the national level, to lead and coordinate the above strategy as an “incident concept” through a fuel reduction group.

Line officers remain engaged in fire suppression actions to ensure the fire is managed in a safe and efficient manner. This includes:

• Constructing a more systematic and consistent approach to oversight of line officers.
• Providing a predominant message that costs are a priority and are expected to be as low as practicable in the management of the incident.
• Ensuring that tribal relations are well managed on incidents through an experienced local liaison. This includes having in place all appropriate agreements with tribes.
• Adjusting terms for fire contractors (goods and services) to allow for cost adjustments on long-duration fires (economies of scale).

The top leadership of the State and Private Forestry mission area, specifically the Deputy Chief and the Associate Deputy Chief, need to be more consistently involved in large fire incident cost reviews.

Update fire management technology to keep pace with today’s fire suppression complexities. This includes:

• Adjusting the NFMAS model to include the values associated with the wildland/urban interface adjacent to the National Forest Boundary and generally improves the quality of information included in the system.
• Expanding the capability of the WFSA to better reflect issues associated with the wildland/urban interface. The WFSA use should be more consistent and aggressive, including its use in pre-fire planning.
• Developing training and certification programs for the WFSA.
• Developing fire behavior software that can be used for regional priority assessment.
• Standardize, improve, and institutionalize models such as the Fire Area Simulator (FARSITE) and Rare Event Risk Analysis Program (RERAP) to improve fire suppression capabilities.

Reassess the militia approach to large fire suppression. This includes:

• Implementing “An Agency Strategy for Fire Management."
• Reviewing red-carded employees. Those who do not participate should be removed from the system.
• Implementing a mentoring program to improve fire management skills for all engaged in fire suppression.
• Eliminating the GS-10/1 pay cap to create better pay incentives for federal employees who participate in wildland fire suppression.
• Using only crews with proven qualifications who are sanctioned or certified as wildland firefighting crews.
• Being more aggressive in calling for available crews nationwide. Some crews, especially those in the East, are well qualified but are not being called to participate on Western fires.
• Begin a study of selected large fires to develop a better understanding of how incidents are at risk of becoming siege fires, and what steps can be taken to reduce the risk.

Conclusions

The examination by this team did not identify anything that could have significantly reduced the costs of managing the Big Bar and Kirk Complexes. However, other factors might have improved the overall efficiency of fire suppression efforts, and thus have reduced some costs. Several recommendations have been made. This is not new and most of our recommendations are not new. Over the past several years, many reports have made over 100 recommendation that, if implemented, would have improved the fire management program and perhaps kept the agency from the current crossroads that suggests more extreme action is required.

This report concludes the following:

• Fire management should be and must be one of the agency’s top priorities.
• Adequate funding to ensure effective initial and extended attack cannot be overstressed.
• Fire planning and fuel reduction must be approached much more aggressively to improve our ability to manage large fires safely and at a reasonable cost.
• The analytical tools of fire management are no longer adequate to keep pace with today’s complexities of fire suppression.
• The traditional militia approach to firefighting is no longer valid.

The answer seems so simple: act now, establish wildland fire management as a top priority, and implement the recommendations that will ensure we fulfill our role and responsibility in protecting lives and property from wildland fires.

Note:  The following are the questions and answers from the interview by the team with the Forest Supervisors and their staffs on November 30 regarding the Kirk Complex on the Los Padres National Forest and the Big Bar Complex on the Shasta-Trinity National Forest. The Six Rivers National Forest was included in the interview.

1. Are the current fire management policy and direction adequate to ensure effective and cost-efficient fire suppression?

   Generally, the fire policy and direction are adequate. Costs could be reduced if there was a better recognition of the duration of fires in dealing with contracts for services. In other words, economies of scale should be instituted. Clearly, cost considerations are a national issue. There needs to be a much more focused national effort to ensure that reasonable fire suppression costs are always a top consideration.

2. Are fire preparedness levels adequate to offer a wide range of suppression alternatives?

   There were adequate resources, initially. However, as conditions changed, levels of resources and types of resources became inadequate to meet the planned fire suppression strategies. It is not realistic to plan for the worst-case scenario. Most of the time, our preparedness levels and the funding proposed through the National Fire Management Analysis System (NFMAS) have been adequate. However, over the years the resource levels for initial attack and extended attack have eroded due to funding reductions -- and now our ability to offer an adequate range of fire suppression alternatives is beginning to be in doubt. However, a lack of resources for initial and extended attack was not an obvious issue, at least in the Big Bar Complex.

   An important question to ask is, "What is the public willing to accept in the short term concerning damages to property and lives?" Currently, that threshold, set by the public, on accepting damages is extremely low; the expectation on all fires is that we aggressively try to control them. We may not have the capability to do this effectively or cost-efficiently, at least in the near future if the current trend continues.

3. Was cost a priority on the Big Bar and Kirk Complexes? If so, how did costs rank with other issues such a safety, ecosystem management, and other social values?

   Costs were always a high priority, but never more than the safety of the firefighters. We believe we consistently looked for ways to reduce costs, but social and political concerns were often competing objectives. There was adequate oversight regarding costs on a continual basis. We are not sure we could do much more about reducing the costs associated with these two complexes. Once it became clear that the fire might reach the Hoopa Indian Reservation (on the Big Bar Complex), the fire suppression strategy changed to a more expensive enterprise. This probably could have been improved with a more effective liaison with the Bureau of Indian Affairs.

   Weather, access, and terrain are factors that have dramatic impacts on the cost of fighting fire. All of these were critical issues on both complexes. Fighting these fires was an expensive proposition from the beginning.

   A catastrophe to one is an opportunity to another. The funding associated with large fires can contribute significantly to local economic conditions. A well-analyzed strategy through a WFSA may call for an indirect and “let-burn” suppression tactic. External forces may view a more direct tactic as better even if a more aggressive approach will ultimately make little or no difference in outcome of the fire. External forces exert influence, and additional resources may be employed for other than a tactical fire management reason. Costs will soar. This scenario must be resisted.

4. When it comes to costs, what threshold levels or “red flags” do you have available to signal a major decision point?

   After $5 million, it is really not clear what level begins to trigger a concern or re-evaluation of a strategy. We are all aware that costs are increasing, but after a certain point people just knew these were going to be very costly fires to fight. There were no black or white thresholds, but we did keep the regional and national offices informed so there would be no surprises.

5. Which items contributed most significantly to the costs of the Big Bar and Kirk Complexes?

   Primarily the way the fires had to be fought (the tactics) to ensure safety, dealing with the rugged terrain, meeting wilderness values, endangered species management, and the extensive use of interagency teams, which are very expensive to operate. Smoke inversions caused some equipment to be grounded. Inadequate overhead to control equipment caused some heavy equipment to go unused. Examples included dozer bosses, falling bosses, etc.

   Also, there is a changed expectation in the use of electronic technology and “creature comforts." These may help improve fire control strategies and ultimately affect the safety of the firefighters. However, they also add to the overall cost of fire suppression.

   Finally, there is the makeup and specific culture of the Incident and Area Management Teams. Candidly, some are more aggressive than others, and this affects the resource levels applied to manage the incident. This is not to second-guess which is right or wrong. It is simply a fact, and costs are influenced accordingly.

6. If you could change anything regarding the fire control strategy for these two complexes, would you? If yes, what were the three primary things you would change?

   We have thought about this a lot, and on the Kirk Complex we would not change the way we managed this incident initially. On the Big Bar Complex, better pre-planning of camp locations and detailed agreements in place with the tribal governments would have improved our overall efficiency. We would not have changed the fire tactics, however.

   There needs to be better flexibility in team composition and rotation. Having these flexible standards in place significantly improves the overall effectiveness of the management of the fire.

   Certainly there are operational actions that can always be improved upon. However, in the larger context of managing these two complexes, with the ebb and flow of the conditions that were present, the three Forests believe their overall approach was appropriate.

7. If there is an opportunity to change the Forest Land Management Plans, what would you change based on what you have learned from these two fire complexes?

   The need for fire planning tiered to the Forest Land Management Plan is critical and needs to be emphasized. This will improve our abilities to manage ecosystems and smoke from fires, improve strategies for large fire management, and define effective rehabilitation tactics. The Forest Land Management Plan should bring fire online as an equal resource.

8. Is there any other information you would like to provide to this team?

   The Los Padres National Forest is 50 percent wilderness and 80 percent unroaded. When the Forest went from two helicopters to one, their ability to manage multiple fires was compromised. Some Type II teams need reminders for managing the expected transitions to Type I teams. There needs to be a national effort on fireline rehabilitation. The Burn Area Emergency Rehabilitation (BAER) national direction is not clear. There are differences in interpretation of BAER team responsibilities and expenditure authorities among federal agencies in the Departments of Interior and Agriculture. Structure protection and the federal role of wildland fire suppression remains an issue. We want to do what is right, but the cost of this role is very expensive. Information management could be improved to emphasize the importance of community liaison roles, not just fire information updates. We need to involve people in the affected communities. We need to make decisions more transparent and available to enable the public to understand resource tradeoffs and costs, when communities are truly in harm's way, and what fire management can do to ultimately prevent the loss of property and lives through tactics such as fuels management. Keeping people better informed with clear, timely, and accurate information while the incident is underway is critical.

   Many communities in the vicinity of wildfire suppression show some level of economic dependence. Those communities recognize that the federal government needs resources to fight the fires and they want to provide as many of those resources (people, supplies, etc.) as they can, if for no other reason than the economic expansion this represents.

   Some communities are more aggressive than others in seeking to participate. Often the government is viewed as an open checkbook, at least that is the perspective of some. On the other hand, from the Forest Service perspective, using local resources may well be more cost-effective than bringing resources from remote locations. Also, the use of local resources often results in additional, although often intangible, benefits to the government, including better relationships, enhanced flow of information, local knowledge, etc.

   We do not think any of our decisions to use local resources prolonged the fires. The majority of these choices were cost-neutral or beneficial to the government. However, some decisions did increase costs. These included:

   • The community of Denny is very remote, with many of its citizens accustomed to the lifestyle that remoteness affords them. Relationships with some community members and communication/information flow with the community were two issues we dealt with the entire time Denny was threatened by fire. For several weeks we had a camp in Denny, which the community did not want. They considered it intrusive, at best. We kept the camp there as long as we thought it was tactically advantageous. However, we employed local fire engines to patrol the community longer than was tactically necessary. This provided a good pipeline of information to the community and seemed to enhance our relationship with them.
   • The Hoopa tribal chairman stated numerous times that his primary objective in addressing the fire was employment. The Memorandum of Understanding, signed with the tribe months before, did not address roles and responsibilities for firefighting. The MOU the Klamath National Forest signed with the Karuk, as an example, did clarify the roles. One of the ICs negotiated the hiring of cultural monitors (number as well as pay rate) with the Hoopa; the rate in this case was above the maximum described in the Karuk-Klamath MOU. When this became known, the Karuk wanted parity.
   • An additional complication involved the perceived complexity of duties. Apparently, the duties being performed by the Hoopa monitors were recognized as lower-graded duties in the Karuk-Klamath MOU. So effectively, the Karuk monitors were performing higher-graded duties and being paid less.
   • Discussions with the Hoopa about reducing the number or pay rate of their monitors resulted in threats and suggestions that the Forest Service was racist. To try to preserve the relationship, we honored the initial negotiations, even though it resulted in increased costs and perhaps questionable benefits.

9. What fundamental points should this report on the “Policy Implications of Large Fire Management” include?

   The report needs to highlight actions and activities that increase costs, such as interagency teams, the use of high-end technology, maintaining a wide range of “creature comforts," and ensuring firefighter safety. We should strive to not compare fire suppression costs of the '60s with today’s costs. Today fire management is much more complex. Fundamentally, to meet environmental, social, political, and safety issues that we are faced with, a large fire is going to cost $1 million or more each day to manage. Also, fighting fires in remote locations requires a different strategy. Remember, terrain and access (or lack of) can dramatically increase the cost of fire suppression, depending on the specific strategy. The Kirk and Big Bar Complexes reflected many of these actions, activities, and conditions. Tribal issues were an additional complexity and challenge on the Big Bar Complex. We must be better prepared to deal with these issues in the future.

   In the future, we will have to depend more on contract crews, and we will need better controls for contract preparedness, training, equipment, and safety.

10. Were Forest personnel assigned to the fires adequately skilled?

    Generally, we had the skills that were needed, but adequate resources were slow in arriving. Some of the expertise was lacking. On the Big Bar Complex, the crews from Region 6 were from contract sources and some were good and some not so good. People who arrived with skills based on self-study courses were not well prepared. A skilled liaison dealing with tribal issues would have been extremely helpful.

11. Was the WFSA helpful?

    On the Kirk Complex, the WFSA was an effective tool. On the Big Bar Complex, there were reservations in its use. Some thought they did not clearly understand what the system was providing them. Trying to get the IC teams involved with the WFSA on the Big Bar was at times an issue. It appears that the Shasta-Trinity National Forest actually did the WFSA on the Big Bar Complex with the IC teams coming along.

12. Did the Forest Supervisors establish spending conditions and guidelines for the IC teams during the transition briefings at the beginning of each new team assignment?

    The Forest Supervisor for the Los Padres National Forest established conditions and guidelines through the WFSA, which guided costs. Cost efficiency was always emphasized at transition meetings and briefings.

    The Shasta-Trinity Forest Supervisor established the management of costs as an objective in all letters delegating authority to the various Incident Commanders. A full-time Forest Incident Business Advisor (IBA) was assigned to all teams at Big Bar. A Forest-wide IBA was established to coordinate the team IBAs. The Forest IBA, at all briefings, provided verbal direction. Language in the Delegation of Authority included, "You are expected to do a complete and efficient job, while providing for SAFETY. Cost-effective incident management should be a significant consideration for the decisions made by you and your team."

13. What type of guidelines on spending did the Area Command and ICs establish?

    Costs were guided by the most effective methods of ensuring firefighter safety while being employed in rugged, remote terrain and using suppression methods that were light on the land to help meet wilderness objectives.

    Written guidelines were provided to the Area Command from the Forest IBA. The Area Command attached these to the delegation memos to the Incident Commanders.

14. A member of Congress recently asked why we did not use more of a "let burn" approach for strategy on the Kirk Complex. Would the Los Padres National Forest please answer this specific question?

    The Los Padres National Forest does not have the option, under the current Land Management Plan, to use a “let burn” strategy. All fires must be suppressed with appropriate tactics. However, the Forest does acknowledge that a Fire Management Plan for the Ventana Wilderness is needed and intends to develop this plan from the Kirk Complex and the records from the 22-year-old Marble Cone Fire, which occurred under similar conditions. The Forest is depending on Regional Office support to help accomplish this.

Appendix C

Literature Review Analysis
Large Fire Strategy, Committee Report
May 1996, USDA Forest Service

Note:  The following matrices, Appendices C through I, list some of the key recommendations in the listed subject matter literature and how the Big Bar and Kirk Complexes seemed to address or respond to these recommendations. A rating of 10 is the highest; 0 is the lowest.

Appendix D

Literature Review Analysis, Large Fire Strategy
Fire Suppression Costs on Large Fires:
A Review of the 1994 Fire Season
August 1, 1995, USDA Forest Service

Appendix E