The GAO Let It Burn Policy

The newly reconstituted Wildland Fire Leadership Council (WFLC) has embarked on a “Cohesive Strategy” planning process [here, here, here].

The “Cohesive Strategy” was mandated by the Federal Land Assistance, Management and Enhancement or FLAME Act [here, here, here].

National Blueprint on Wildfire Management

by Phil Leggiere, HS Today, 26 April 2023 [here]

On Wednesday April 21 at the Wildland Fire Leadership Council in Washington, DC, Department of Homeland Security (DHS) Secretary Janet Napolitano, Secretary of Agriculture Tom Vilsack, and Secretary of the Interior Ken Salazar jointly announced a blueprint for the first comprehensive national strategy for wildfire management. …

The new strategy will analyze three key components: landscape restoration, fire-adapted communities, and response to wildfire and is scheduled to be completed this fall in accordance with a recent act of Congress.

The FLAME Act of 2009 requires the Forest Service and Department of Interior to submit to Congress a report that contains a cohesive wildfire management strategy consistent with recommendations in recent General Accountability Office (GAO) reports regarding management strategies. Following its formal approval by the Secretary of Agriculture and Secretary of Interior by October 2010, the Cohesive Wildfire Management Strategy is to be revised at least once during each five year period to address any changes with respect to landscape, vegetation, climate, and weather conditions.

According to the legislation the Cohesive Strategy is required to provide for the identification of the most cost effective means for allocating fire management budget resources. This includes the reinvestment in non-fire programs by the Secretaries of the Interior and Agriculture, employing the appropriate management response to wildfire, assessing the level of risk to communities, allocation of hazardous fuels reduction funds based on the priority of hazardous fuels reduction projects, and assessing the impacts of climate change on the frequency and impact of wildfire. …

Note two key points. First, the “Cohesive Strategy” is to be consistent with recent General Accountability Office (GAO) reports regarding fire management strategies. Second, the goal is “cost effective” fire management budgeting.

The most recent GAO fire management report is: Federal Agencies Have Taken Important Steps Forward, but Additional, Strategic Action Is Needed to Capitalize on Those Steps, GAO-09-877 [here]. That report is similar to other GAO and OIG reports in that it considers fire suppression costs only, not the economic damages that wildfires inflict.

In 2007 I wrote An Open Letter to the US Senate Regarding Fire Suppression Costs [here] regarding an obscure yet important document: the Audit Report on Large Fire Suppression Costs, by Robert W. Young, Asst. Inspector General, U.S. Department of Agriculture, Office of Inspector General, Western Region, Report No. 08601-44-SF, November 2006.

In that letter I pointed out that the Audit fails in three important ways:

1) The Audit fails to consider total costs per fire, and instead focuses analysis on fire suppression costs per acre.

2) The Audit fails to consider economic cost-plus-loss.

3) The Audit fails to consider the economic utility of fire suppression.

Some excerpts:

Cost-plus-loss: Almost since the founding of the US Forest Service in 1905, analysts have evaluated fire costs as suppression expenses plus the capital value of the resources destroyed. The cost of firefighting plus the lost value of whatever burned down is known as cost-plus-loss and is the standard parameter of forest fire cost accounting.

Federal fire suppression expenses were nearly $2 billion in 2006, but I estimate losses at 48 billion board feet of merchantable timber with an economic value of $24 billion. Therefore total federal forest fire cost-plus-loss was approximately $26 billion in 2006 alone. …

The Audit totally ignores cost-plus-loss and thus fails to provide the critical information that Congress and federal forest agencies need to evaluate true fire costs.

Utility: For the last fifty years, or more, fire cost analysis has focused on calculations of the economic utility of fire suppression.

We fight fire to prevent fire from destroying valuable resources. The prevention of destruction is what is useful about firefighting. In every fire there is some potential destruction that could happen, so we seek to prevent it by controlling and extinguishing the fire.

The potential destruction can be accounted for as probable cost-plus-loss should firefighting fail to stop the fire. That is, should the fire not be contained within a given perimeter, how much bigger could it get and how much additional firefighting expenses and resource destruction would likely occur?

The mathematical calculation of probable cost-plus-loss (if suppression had failed) minus the actual cost-plus-loss (assuming suppression was successful) represents the economic utility of firefighting.

In short, the dollar usefulness of firefighting is the value of what was saved (plus probable expenses) minus the total sum value of what was lost plus actual expenses. The result of that computation is called the economic utility of firefighting. The general goal of firefighting expenditures is to maximize the utility.

No rational discussion of fire suppression costs can happen without reference to the economic utility of firefighting. Maximizing utility is the only rational reason we spend any money on firefighting at all.

The primary consideration in firefighting funding should be to reduce damages. Economically speaking, the utility of fire suppression is minimizing cost-plus-loss from fires.

If your home was on fire, you would not be worried about reducing the fire suppression outlays; you would be worried about the damages to your home and possessions. You would be in favor of rapid and aggressive actions to put the fire out.

If you ran an insurance company, you would not be motivated to cut back on fire suppression expenses. You would wish to minimize the losses from fires. Insurance companies support increases in fire suppression expenditures because it is the economic damages from fire they wish to avoid or minimize.

In the case of Federal land management agencies, the public is the landowner, the fire department, and the insurance company. But the same logic should apply: the utility of fire suppression is minimizing cost-plus-loss.

The GAO reports regarding fire management strategies fail to consider cost-plus-loss. They seek to minimize fire suppression expenses without regard to damages. The GAO (and the WFLC) go so far as to advocate Let It Burn because their concern for damages is nil.

I submit that is fiduciary incompetence at its worst. Their logic is flawed and the outcomes are hugely destructive and expensive.

In April, 2009, the Western Forestry Leadership Coalition (a different WFLC, same initials but entirely different group) published an excellent report entitled The True Cost of Wildfire in the Western U.S. [here]. That report pointed out:

The millions of dollars spent to extinguish large wildfires are widely reported and used to underscore the severity of these events. Extinguishing a large wildfire, however, accounts for only a fraction of the total costs associated with a wildfire event. Residents in the wildland-urban interface (WUI) are generally seen as the most vulnerable to fire, but a fuller accounting of the costs of fire also reveals impacts to all Americans and gives a better picture of the losses incurred when our forests burn.

A full accounting considers long-term and complex costs, including impacts to watersheds, ecosystems, infrastructure, businesses, individuals, and the local and national economy. Specifically, these costs include property losses (insured and uninsured), postfire impacts (such as flooding and erosion), air and water quality damages, healthcare costs, injuries and fatalities, lost revenues (to residents evacuated by the fire, and to local businesses), infrastructure shutdowns (such as highways, airports, and railroads), and a host of ecosystem service costs that may extend into the distant future.

Day-lighting the true costs of fire highlights opportunities to use active management to curb escalating costs. Unhealthy forests can increase the risk of fire. Investing in active forest management is therefore valuable in the same way as investing in one’s own preventative health care. Upfront costs can be imposing, and while the benefits may seem uncertain, good health results in cost savings that benefit the individual, family, and society. This analogy helps to highlight the importance of fostering resilient ecosystems before fires occur, as a tool for reducing the costs associated with suppression and recovery as well as extending the potential benefits of fire.

Last Fall the Wildland Fire Lessons Learned Center published U.S. Wildfire Cost-Plus-Loss Economics Project: The “One-Pager” Checklist by Bob Zybach, Michael Dubrasich, Gregory Brenner, and John Marker [here]. The authors wrote:

Official Forest Service tallies usually include suppression expenses only. Media reports sometimes include estimates of damage to homes and infrastructure. But the economic impacts of wildfires are far-reaching, and recent research shows the need for improved cost estimates of wildfire.

The escalating frequency, severity, and costs over and above fire suppression associated with large-scale forest wildfires1 include losses of human lives, homes, pets, crops, livestock, and long term environmental and infrastructure damage. Many destructive megafires have made international news, such as the lingering California wildfires of 2008, or the February, 2009 Australian fires, which claimed more than 200 lives and leveled several small towns.

Yet wildfire costs and losses are often considered in terms of suppression costs only, with relatively little attention given to related losses of timber and forage values, wildlife habitat and populations (including endangered species and their critically protected habitat), air and water quality, recreational opportunities, local economies, and other resources and amenities important to all citizens. Human lives and adverse health effects are usually not considered in terms of dollar losses at all, and tallies of domestic animal or wildlife fatalities are rarely attempted or even mentioned. Rarely is there any attempt to quantify the long-term consequences of a damaged renewable resource base to provide for the needs of an ever increasing present and future human society (e.g. Bowman et al. 2009).

Consideration of an inclusive and comprehensive cost-plus-loss evaluation could be a helpful exercise when evaluating suppression/readiness need and effectiveness appropriation (Rideout et. al. 2008) as well as offering a more complete picture of wildfire effects.

Despite all these admonishments, the GAO has not gotten the message. Instead of considering the economic damages that wildfires inflict, or the fundamental utility of firefighting, the GAO remains committed to cutting suppression costs:

GAO has recommended several key actions—including development of an overarching fire management strategy—that, if completed, would substantially improve the agencies’ management of wildland fire. Nonetheless, the agencies have yet to:

* Develop a cohesive strategy laying out various potential approaches for addressing the growing wildland fire threat, estimated costs associated with each approach, and the trade-offs involved. Such information would help the agencies and Congress make fundamental decisions about an effective and affordable approach to responding to fires.

* Establish a cost-containment strategy that clarifies the importance of containing costs relative to other, often-competing objectives. Without such clarification, GAO believes managers in the field lack a clear understanding of the relative importance that the agencies’ leadership places on containing costs and are therefore likely to continue to select firefighting strategies without duly considering the costs of suppression. …

* Take action to mitigate the effects of rising fire costs on other agency programs. The sharply rising costs of managing wildland fires have led the agencies to transfer funds from other programs to help pay for fire suppression, disrupting or delaying activities in these other programs. …

Read those recommendations carefully. In every case the concern is over fire suppression budgets, not the damages that fires cause.

And that incompetent logic is driving the WFLC’s “Cohesive Strategy” program.

One way to cut suppression costs is to dismantle the fire suppression program entirely and just let fires burn unimpeded. Sure enough, that’s a major component of the plan.

The “Cohesive Strategy” will include the “Leave Early Or Stay And Defend” policy that resulted in 200 deaths and more than 2,000 homes incinerated in Australia in February 2009. That policy that calls for homeowners to evacuate or else defend their own properties from wildfires. No fire department will come when the alarm sounds. Either flee in a panic or put the fire out yourself.

Last month U.S. Forest Service Chief Tom Tidwell reiterated the mantra that all private land within 30 miles of any National Forest is doomed to be burned by unfought fires raging off the Federal Estate [here]. The Feds are not going to fight fires anymore, and so holocausts are expected to incinerate land as much as 30 miles away.

The Federal Government is out to burn down the West. They are going to save a bundle on fire suppression by walking away from fires. They don’t care what damages might ensue. Whole cities can burn to the ground for all the GAO cares, just as long as fire suppression budgets are pinched off.

This is more than a question of resource management — it is a question of homeland security. The Government will take over banks and car companies, but they will not defend our borders nor will they fight fires. They will spend $trillions on “stimulus” pork barrel graft, but when it comes to basic public safety and security, the cupboard is bare.

As for resource management, that’s not in the cards. Let It Burn is the new forestry. Watersheds, wildlife, timber, recreation, whatever the natural resource is, the new management regime is burn it but good. The Desired Future Condition is scorched earth moonscape. No resource expertise is needed for that. No compliance with environmental laws such as NEPA or ESA is contemplated. Just burn, baby, burn.

That’s been the strategy throughout the West. In the last ten years the largest and most destructive fires in state history have burned in every state in the West. Let it Burn fires called Wildfire Use or “fires used for resource benefits” have incinerated forests, watersheds, farms, ranches, homes and even towns and cities.

It’s going to get worse before it gets better. The new strategy is “cohesive”. All fire departments, not just the Feds, will cohere to the policy. No putting the fires out — it costs too much. Our profligate leaders have decided to cut costs in the most egregious fashion, by eliminating fire departments.

You can get free heroin and needles from the Government. You can get free condoms and abortions. The message is kill yourself with drugs but don’t breed beforehand. The Government will pay for all that.

But fire suppression? Nope, we have to save the taxpayer’s money somewhere. Might as well shut down basic services like firefighting.

Another approach would be to shut down the Government entirely. Who needs it? What good is it? Why do we pay anybody at the GAO, for instance? What’s the point of that?

28 Apr 2010, 3:49pm
by bear bait


So do you really think CalFire will allow fires up against LA or any other major city in California to burn unfought?

Will the grand redwoods of the Sierras get any protection? Or the NPS areas like Yosemite? Or the redwoods of the coast?

Those people can talk tough, but they still have to answer to a Congress. I would hope that a few megafires that kill some people and burn many more out of house and home don’t happen, but I know they will with that kind of approach and hangman’s ethics. Afterward, have your congressman or woman demand the policymakers face a Congressional committee hearing right smack dab in the middle of the congressional district recently incinerated with no fire fighting effort. Require by subpoena that each and every member of the decision-making board is present at that hearing to answer questions. And include the GAO. Make them defend their decision at ground zero. On TV. To the world. I mean tables set up out of doors in the midst of ash, char, and destruction. Not in some cushy building. Defend their decision surrounded by the results. And by the people who now have to pay for their objectivity. As the man says, we are close to having to ask why do we need government?

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