SOS Forests

Montana DNRC Advises Against “Fires for Resource Benefit”

The Montana Department of Natural Resources and Conservation convened a working group to evaluate “lessons learned” from the 2009 Fire Season. Their conclusions matched those of the Oregon Department of Forestry Perspective on 2009 Federal Wildfire Policy Guidance [here] — let it burn fires use for “resource benefit” don’t benefit resources and should not be allowed:

Given the breadth and scope of the concerns raised by use of resource benefit fire management strategies, many state fire agencies agree that broad application of such strategies –- particularly adjacent to the WUI, commercially viable timber stands, or critical watersheds/wildlife habitat is not advisable.

Which watersheds are not “critical”? None — all the watersheds in Montana are critical and vital to the well-being of society and the environment. The Montana DNRC would just as soon the USFS and BLM bagged the concept of “resource benefit” wildfires. They said it nicely, though:

Here are some recommendations that merit additional discussions by the work group:

1. The USFS should limit the use of resource benefit fire strategies to those areas where priority areas identified in local CWPPs have been treated either through mechanical means and/or prescribed fire.

2. Expanded use of resource benefit fire management strategies may transfer a significant amount of financial and safety risk to state and local governments. Consequently, representatives from these entities should be informed well before the fire season and directly involved with any decisions to expand use of this tool.

In other words, Let It Burn wildfires (LIBWF’s) should only be undertaken where the watershed has been prepared to receive the wildfire via “mechanical means and/or prescribed fire” — the techniques of restoration forestry. Hopefully, the mechanical means and prescribed fires are not ends in and of themselves, but rather treatments carried out under a framework of scientific restoration to achieve multiple resource goals based on a collaboratively agreed upon desired future condition.

Simply put, first we agree on the multiple resource goals, then we apply active management to establish those desired conditions, and then and only then do we allow wildfires to burn through (only) the treated areas.

Fire can be a useful tool to achieve resource goals, but it is a tool, not a weapon. You don’t throw hammers and nails at the boards — you use the hammers and nails in a thoughtful and expert way to build the desired structure.

If our land management agencies allow LIBWF’s to run willy-nilly wherever and whenever such wildfires accidentally erupt, then we might as well use our national forests as bombing ranges — the real world impacts are very similar.

The Montana DNRC report does not seem to be on their website, so we post it here in full:

Montana DNRC Perspectives Regarding 2009 Federal Wildfire Policy Implementation

Introduction

In 2009, the USDA Forest Service clarified existing agency fire policy, leading to changes in terminology and how some wildland fires were managed.

The agency has grappled in recent years with the same issues as their state partners: longer fire seasons, larger incidents, limited fire suppression resources, escalating costs, firefighter and public safety, fires in the interface, and the appropriate role of fire protection entities regarding structure protection.

To proactively address these issues within the construct of resource benefit fire management strategies, the Montana DNRC and Region 1 of the USDA Forest Service have recently tasked a small work group to capture lessons learned from the 2009 season and provide recommendations as to how they can be incorporated in future fire incidents. The intent is to help define the roles, responsibilities, and liabilities for fires managed for multiple objectives that may cross jurisdictional boundaries.

This paper is an attempt to convey some of the issues and recommendations based on states’ experiences from the 2009 wildfire season in the hopes of making improvements ahead of the 2010 season.

As the foundation for this discussion, it is important to re-emphasize a few widely accepted truths regarding the state-federal relationship/philosophy regarding fire management. Specifically:

1. Continued cooperation and communication are essential to our success. States will continue to work with their federal partners on an integrated response to wildfires, particularly those on shared protection.

2. All wildland agencies have the prerogative to determine their management response for any fire that lies solely on their protection. This response may be dictated by a number of factors, including resource objectives, available suppression resources, and state law.

3. Ultimately, public agencies are accountable to the people they serve and thus are obligated to be as forthright and clear as possible in communicating their intent in responding to wildfires.

4. Wherever possible, successful initial attack is still the best suppression response to keep fires small and costs down. Local, state and federal agencies should continue to support one another with fire response and initial attack efforts.

5. The individual circumstances for each wildfire should drive the decisions about response. For a variety of reasons, sometimes a response other than full suppression is not simply the only option, but the preferred choice.

6. As expected, the greatest area of concern lies with wildfires that are or have the potential to become multi-jurisdictional. The concerns shared by state fire protection agencies can be categorized into the following areas of emphasis:

* Firefighter & public safety;

* Threats to private property;

* Validity of decision-making models;

* Effects on interagency relationships;

* Impacts to available suppression resources;

* Air Quality;

* Poor public relations due to unclear communication; and

* Cost

These are very likely the same concerns that the federal agencies have whenever they determine that a fire will be managed for resource benefit.

Just as wildfires are dynamic, the decision-making process regarding management should be as well. To that end, all stakeholders need to continue to work together, communicate effectively, and be active participants in decisions that could ultimately affect them. In turn fire managers must understand and respect the policies and legal mandates of each agency that drive their decisions regarding fire suppression.

As we look ahead to the 2010 fire season, here are some recommendations that should be considered for fires that are managed for multiple objectives which may cross jurisdictional boundaries:

* On incidents where the decision is made to manage a fire or portion thereof for resource benefits, the federal agency should be prepared to assume all suppression costs.

* A broad and extensive information and education effort should be made to clearly explain the federal fire policy to cooperators, local government representatives, and private property owners. Consistent use of terminology (i.e. “fire use, appropriate management response, or resource benefit”) and a clear explanation of related processes (i.e. WFDSS, Management Action Points, Long Term Implementation Plan, etc.) should be included.

* Impacts to other agencies from a management decision to manage a fire for resource benefit should be acknowledged and mitigated to the extent possible. It is incumbent upon state and local governments to seek a seat at the table during these discussions.

* Any available claims process for resource losses from a fire managed for resource benefit should be made known and available to all potentially affected parties.

* As much as possible, implementation of the federal fire policy should be consistent across a geographic area and across the various federal agencies.

Mitigating impacts to state and private land

Here are some recommendations that merit additional discussions by the work group:

1. The USFS should limit the use of resource benefit fire strategies to those areas where priority areas identified in local CWPPs have been treated either through mechanical means and/or prescribed fire.

2. Expanded use of resource benefit fire management strategies may transfer a significant amount of financial and safety risk to state and local governments. Consequently, representatives from these entities should be informed well before the fire season and directly involved with any decisions to expand use of this tool.

Conclusion

Given the breadth and scope of the concerns raised by use of resource benefit fire management strategies, many state fire agencies agree that broad application of such strategies – particularly adjacent to the WUI, commercially viable timber stands, or critical watersheds/wildlife habitat is not advisable.

In areas where resource benefit fire management strategies are appropriate, stakeholders must continue the dialogue aimed at clearly conveying the roles, responsibilities and liabilities that may come with such strategies.