Comments Submitted on Draft Cohesive Strategy

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

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

A draft report entitled National Wildfire Management Report to Congress and Cohesive Strategy Draft has been issued [here, 3.2 MB] and comments were requested.

W.I.S.E. has complied and submitted our Comments today [here, 1.7MB].

Some additional comments:

From John M. [here].

From Bill D.

Thank you for the opportunity to provide general comments to the Cohesive Strategy Draft Report. I am a retired USDA, Forest Service employee and was with the Agency for 38 years. I held various positions in Fire Management and retired as the Special Agent in Charge, California Region, Regional Office, San Francisco CA.

Following are my recommendations for your consideration as you move forward in the strategy development process. I trust you have previously consulted with individuals from multiple jurisdictions with extensive wildland fire management experience and credentials who have had front line experience in suppressing wildfires.

1) Enhanced fire prevention and pre-suppression (preparedness) programs, development of infrared satellite/drone based early detection systems, and immediate initial attack and follow-up with sufficient resources are the most cost-effective measures in the prevention, containment, and control of wildfires. The increased use of night shift firefighters and night flying water dropping helicopters can provide an effective means to contain fires when they are least active. The previous Forest Service policy of containment and control by 10 a.m. ensured that sufficient resources were available to contain and control fires within reasonable time frames. Risk management objectives are met when fires are suppressed in the early stages with sufficient resources as opposed to having insufficient resources and allowing a wildfire to become a major conflagration where firefighters, persons, and property are exposed to risk over longer periods of time and valuable natural resources are placed at risk and/or severely damaged.

The August 26, 2009 Station Fire on the Angeles National Forest in California may have been a case where sufficient resources weren’t in place soon enough to contain the fire in the early stages wherein it escaped and burned 160,000 acres of the most valuable watershed in the United States. Two firefighters were killed, hundreds of structures destroyed, and suppression costs exceeded 100 million dollars with additional long term resource damage and associated costs predicted to run into the billions.

2) Hazardous fuel load reduction and thinning by mechanical and other non-fire use methods, and fuel and fire break construction are cost-effective ways to reduce fuel loads and establish containment lines prior to a fire.

3) Maintaining and restoring healthy and disease-free timber stands by increased forest and fiber product utilization, grazing, and timber harvesting contibute to the reduction of hazardous fuels. Lawsuits designed to prohibit logging in specific areas should be defended vigorously by Government Attorneys so that these areas, including fire damaged timber, can be properly harvested and salvaged.

4) Establishment or revision and modernization of pre-planning/attack programs with computer modeling of previous programs so that wildland fire suppression action strategies can be anticipated and planned for to facilitate early containment and control of fires.

5) Selective prescribed burning can be effective in reducing hazardous fuel loads when pre-planned, executed by competent personnel, kept within prescription, are an integral component of unit Land Management Plans, and coordinated with adjacent units.

6) Application of AMR and WFU on an existing fire often preclude adequate pre-planning and escape containment and control resulting in significant suppression costs and damage to property and resources and is not recommended except where there has been proper pre-planning and assurance that the fire will be kept within prescription.

7) Lightning fires should receive the same fire suppression priority and action as man-caused fires since both have the potential to escape early containment and control if not aggressively suppressed.

Whatever additional costs may be incurred by investing in the above recommendations before fires occur and during initial and extended attack will be more than compensated for since there is a far greater propensity for early containment and control resulting in less costs overall. The risk to firefighters, persons, and property will be reduced and valuable resources such as timber and watershed will be better protected ensuring the sustainability of our Nation’s natural resources. The overall costs of fire suppression, resource and other associated damage are greater when fires are not aggressively contained in the early stages.

These recommendations have wide application in multiple jurisdictions. Implementation requires well trained, experienced, and competent leaders, managers, and firefighters if risks and losses due to wildfires are to be held to a minimum. The application and understanding of the U. S. Forest Service “10 Standard Firefighting Orders” and “18 Watch Out Situations” by fire personnel is the best guarantee against injury and fatalities. Failure to follow this guidance has been a factor when firefighters have been injured or killed. Order number 10 “Fight fire aggressively, having provided for safety first” is the cornerstone of risk management. Aggressive suppression of wildfires reduces risks to firefighters, persons, property, and resources when “Safety” comes first.

From Troy K.

Wow! I read through the document, peeled an orange and found apples, pears, and grapes together with some orange here and there. Reminded me of my Fruit of the Loom underwear which I had to change after reading the document! This could be edited down to about 8-10 pages and someone might understand the direction. And to lump the entire western USA into one region? One policy group? Who wrote this?

First impressions: this is a self serving document in great need of a professional writer editor. It appears to be way off the target, incorporates a lot of wish stuff not called for by Congress and does not meet the questions asked with answers. The scope is way to large and fails to target the real issue: strategic direction for federal action on federal land by federal agencies and what will federal agencies do when their actions impact the state lands that are mostly in private ownership. The strategy seems to place secondary value on the national natural resources: food, fiber, energy, water, air, soil! Our timber, range, wildlife, water, air and soil are sustainable natural resources produced on the national forests. That is what we need to manage and protect.

This is a document attempting to support an internally developed policy whereby we allow lightning fires to burn without meeting measurable objectives set to attain natural resource management goals. Yes, a wildfire can do a good job of under burning as it backs down the hill, then head fires up the other slope. What? We accomplished fuel reduction on 50% of the land? How do we reduce cost when a spot could be extinguished by the people sent to monitor it? and monitor it? and monitor it? Until we spend 9 million dollars monitoring and guiding a fire over 3,000 acres?

If they put this to a vote in Montana it would go down in flames. (Pretty good uh? Just thought that up but it is true!)

We may have just lost sight of the Forest Service Mission to manage 190 million acres for the national good. Did we really have line officer involvement here like rangers and forest supervisors? Never found them mentioned in report… just fire managers and fire experts and scientists.

From Larry H.

I read bits and pieces of the report and have a few suggestions that might be pretty obvious.

1) There is NO reason to keep meetings closed. We need full transparency and access to the process.

2) If they are going to allow eco-groups to participate, they have to open it up to more representation from other points of view.

3) Making National policies on wildfires cannot hope to satisfy local conditions and situations. Flexibility and responsiveness are keys to making treatments and activities the best fit for the land.

4) Use only established and non-anonymous peer reviewed studies in decisions. Studies MUST address the fact that humans have always lived in our forests.

5) All plans MUST follow formal NEPA laws. This not-so-simple process includes essential features that the public deserves to know and comment about.

From Scott A.

Having secret closed door meetings is a bad idea. Especially when it favors one group’s input over another. It promotes bias, close-minded-ness and spurs mistrust and suspicion amongst those who were purposely left out of the process. The group which is feeling left out right now is a small, unimportant group the USFS refers to as “the American people/taxpayer.”

National policies towards fire management do not work. What is good for West Virginia doesn’t always work in Washington State or Utah and Arizona.

More public involvement, transparency should be considered. And more emphasis should be put on public comment instead of bad science. I grew up at the gateway of the Frank Church River of No Return Wilderness. The good intentions of over-educated scientists and bureaucrats have laid 80% of said wilderness in ruin, ashes, out-of-control-insect/disease infestations. Thousands of endangered species have died in out of control wildfire, needlessly. The fires have destroyed critical endangered species habitat and only the highly flammable sub-species of vegetation have come back, which will make future fires more frequent and more out of control.

More comments will be posted as received.

6 Sep 2010, 11:15pm
by Mike

The following comment came to me indirectly, but I am posting it because (1) it was written by a public official as part of this public process, and (2) it is excellent.

Subject: Cohesive Strategy Comments
Date: 9/5/10
From: “Marcia Armstrong” (District 5 Supervisor, Siskiyou County)
To: “Cohesive Strategy Group”

Cohesive strategy comments

District 5 in Siskiyou County is a sparsely populated frontier area. Historic communities dating back to the California Gold Rush are surrounded by USFS and occasional BLM lands. All of the communities were listed as “at risk” of wildfire in the Federal Register. Lightning storms are common and fires are frequent. In the past twenty years, we have seen a dramatic increase in very large fires. In 2008, about 250,000 acres of forest burned. The western part of the county has steep slopes and many Wilderness Areas.

Several realities struck me as not being anticipated by the report.

(1) The number of regions is unrealistic. The Western region is enormous. There is very little in common with the Pacific Northwest (including northern California ) and the southwest or central plains states.

(2) There appear to be expectations that local government will assume a greater portion of the costs of wildfire suppression. We have seen attempts to evoke a NIMS style Unified Command with the Forest Service on local fires. In our neck of the woods, the reality is that this will not work for us.

All of our non-city fire departments are 100% volunteer. Some are Districts or Zones of Increased Benefit (ZIBs) supported by a very small levy on property tax bills. Many of the units in the Forest communities are Hose Companies supported strictly by bake sales and donations. These fire departments rely heavily on grant funding and surplus equipment for outfitting. Unified Command requires shared fiscal responsibility. These departments have strict orders from the County Fire Warden not to enter into Unified Command as they would be bankrupted within seconds.

Siskiyou County has no County fire department. Although the County helps to offset the costs of dispatch, there are no County fire services. Years ago, the voters took all the area of the county not already in a city or district fire department and placed that under a Community Services Area. They did not, however, vote to fund it. Subsequently, small pockets of ZIBs have been created where populations have chosen to self-fund services.

Normally, when a local agency is overwhelmed, County resources would kick in, and then regional. Here, there is a lack of vertical connectivity relied upon by the NIMS system in our fire service. Because we do not enter into Unified Command, local fire resources hang out there in limbo. hey are not in the loop. In past circumstances, dispatch has even been done out of county (Fortuna) leaving local fire departments, dispatch and CalFire completely uninformed as to what is happening.

Our fire department’s principle mission is the suppression of a single structural fire incident. Our Fire Departments are tied together by Mutual Response Agreements for those purposes. They will do an occasional initial attack on a wildfire start. Some of them have the capability f providing a strike team to state forces when local fire incidence is not active. The money they get for the use of their equipment partially offsets operating expenses. Outside of this, as a volunteer force, they cannot be counted upon to provide sustained services. Many cannot be called upon to be away from regular jobs for any length of time. In addition, as the population ages, it becomes increasingly more difficult to find qualifiable volunteers.

One of the biggest problems that we have encountered in the past is the State Responsibility Area/Federal Responsibility Area (SRA/FRA) agreement. This swaps responsibilities in blocks between the USFS and CalFire on a statewide basis for better efficiency. The problem is that in the SRA, when a local department needs backup on a structural fire, the State will ultimately step in under NIMS. What is happening in the FRA is that the local department is out of the loop and the USFS will not call in the State CalFire resources to assist in structural fires because of the fiscal responsibility dispute. The State is reluctant to provide forces because of the SRA/FRA agreement.

In addition, rather than covering vegetation fire wherever in the FRA, the USFS has been disavowing any responsibility beyond an imaginary perimeter line it has drawn around a settlement. What this means is that under wildfire conditions, local forces are overwhelmed in trying to protect against vegetation fires, multiple structural fires (as in Happy Camp) or the homeowners have to fight the fires themselves (as in Salmon River.) Our communities become orphaned and less than equal under these agreements. Where you see a fire truck in every driveway in southern California, you see neighbors with chainsaws and hoses in our county.

The other issue we have worked out locally is the lack of continuity between the various USFS wildfire management units that come in and out of our area in a prolonged fire. Local knowledge, specialized maps and CWPP plans were not making the transition. Being sensitive to the concerns of the local community was not making the transition. Communications were rough and confusing. For instance, one team used a map showing miner’s cabins that had been forcibly taken down in the past by the USFS in a map of structures of concern. That evoked memories of hard feelings in the community and made communication difficult. Now, “community liaison” positions have been created in several wildfire prone communities. This person provides continuity of local information from the fire safe councils and past fire knowledge to the USFS teams that rotate through. They also pass on questions from the community and answers back from command. It should be remembered that several of these areas experience wildfire just about every year and many have spent a lifetime fighting these fires, so they have an abundance of local knowledge on wind patterns etc.

(3) Unrealistic expectations appear to be that homeowners will be able to accept responsibility for reducing fuels on their property and for using fire-resistant materials. Indications are that funding for local fire safe councils previously offered under the National Fire Plan will be diverted to large landscape treatment projects. This could collapse the Fire Safe program.

Rural populations are notoriously older and much poorer than the rest of the country. For instance, most of my communities have a senior population of at least 30%. By 2020, that is expected to increase another 10% and continue increasing until 2030. From the year 2000-2030, it is expected that the population over the age of 85 in northern CA will increase 150%. Unemployment is currently around 18.5%. The poverty rate is about 16% for all populations and 25% for children under the age of 18. Median Household Income is around $36,823 (compared to $61,000 for California.)

As a member of the Siskiyou County Resource Advisory Committee (RAC) and as a member of the county Sub-Committee on Aging, we are increasingly seeing elders cited by CalFire for noncompliance with defensible space laws. They are often disabled and living in poverty and physically and financially unable to comply. Local fire safe councils have started to come forward asking for funds to hire contractors to do the job. We have funded one project that uses neighbor volunteers to do some of the work, with the heavier limb cutting and chipping work being done by a contractor. But it is becoming apparent that this is a larger problem to which we need to find a solution.

Siskiyou County is about 6,300 square miles large and has about 20 fire safe councils, one regional coalition of councils, a countywide fire safe council and an official Fire Panel appointed by the Board of Supervisors. The individual councils work on specific local projects; the coalition shares resources and education; the countywide fire safe council provides grant writing resources; serves as a non-profit fiscal agent; and provides public education. The Panel is creating consistency among various CWPPs and is creating a countywide strategy and priorities geared more to the landscape level.

Grant funding makes the wheels go around. It pays for capacity –- such as refill tanks for storing water for fighting fire. It pays for equipment such as industrial quality chippers to support a local crew. It pays for a contractor to come in for chipper days. It pays for the creation of large shaded fuel breaks around towns, clearance of ingress and egress along roads into settlement areas, and the creation of safe areas for staging and evacuation. Generally, most individuals work their own property at their own expense. On larger properties, there are USDA projects that can help offset the cost of managing small forests. Should Clearinghouse money from the Fire Plan be diverted and the Secure Schools and Rural Communities Self-Determination Act money be eliminated, there is a very real question as to whether this system is sustainable. Due to severe budget constraints, the County has laid off a quarter of its General Funded employees. We no longer even have a code enforcement officer. We do not have the resources to take on the burden of passing new ordinances or providing project funding.

(4) On the larger issue of sustainability, it is clear that we have to move away from simply demanding of a population that they remove fuels and use fire resistant materials when they have little to no capacity to comply with that demand. Where possible, we must gradually move to a market-driven system that will support a private enterprise solution.

First, there is the piece that gets the material to the logging deck. People have to accept that a few merchantable trees must be included in a project for sales to subsidize the costs of removing the sub-merchantable stuff. This can be done with a stewardship contract or a subcontract on a timber sale. With the over-stocked state of our forests, this would be entirely consistent with the goals of forest health. NEPA and CEQA reform or exemption may be required to prevent these types of projects from being constantly appealed and litigated.

The next piece is the transportation of materials to the sorting yard, sorting, preliminary processing and sales. Depending on the market for by-products such as poles, chips and firewood, this could also be a self sustaining piece. Federal environmental policies and subsidies must be aligned to support a secure market for the material –- this includes sorting out air quality issues on cogeneration plants and taking into consideration the offset of reduced fire/smoke exposure; recognizing US Forest biomass as acceptable for renewable clean energy; sizing transmission lines to accommodate electrical generation from remote areas; and price subsidies to support the competitiveness of biomass with solar and wind. The Forest Products Lab also needs to look at products that can be created from fuel reduction that will meet the new fire resistant building standards.

Long term large (15-20 year) stewardship contracts or sustained yield units must be created to secure the underlying stability of supply. For investment to occur, the flow of raw materials cannot be subject to the constant threat of an environmental injunction. Also, most larger users such as pellet or bio-brick manufacturers need to locate their operations side-by-side with existing mills because of the need for heat in processing. When selecting initial landscape level projects, sites should be close to existing infrastructure, if possible, to take into consideration the transportation costs of sub-merchantable material (golden hour.) This will create successful models that can be more easily replicated. Smaller gassifier or bailer units should be investigated for serving the entire energy needs of small Forest towns.

Subsidies and legislation should be aligned to encourage the use of wood heat along the model that Europe has successfully implemented where chips are blown into basement holding areas for use in home sized boilers.

(5) The use of fire as a broad management tool (“let it burn policy”) simply has not earned the necessary social license. A few years ago, Siskiyou County experienced an escaped prescribed burn from the Shasta Trinity National Forest. It destroyed private property (structures.) If I recall, many people have never been compensated for their loss. (Prescribed fires should never be used where high afternoon winds are common.) Last year, a Wilderness burn on the Klamath escaped and caused substantial suppression costs to stop it as it threatened other land and settlements.

In the Backbone fire, folks were very concerned that the fire would move into Nordheimer Creek –- an area that had burned about two decades ago and had regenerated among untreated tangles of downed and standing fuel. Concerns were that a fire now would nuke the entire area. After a hundred years of fire suppression and a prohibition on salvage logging, much of this land is so overgrown with decadent brush and ladder fuels on steep slopes and is unable to safely carry resource fires. As fire is being steered around the Forest with backburns to accomplish resource goals, bad things are happening in many areas and adjacent private forest lands are being destroyed.

In the fires of 2008, which exceeded 600,000 acres in Siskiyou and Trinity Counties, the greatest backlash against “Appropriate Management Response” was from retired Forest Service and CalFire employees. They were shocked at the failure to immediately suppress these early season fires. They were concerned at the use of large backburns and the broad ridge to ridge scale attack. They were concerned at the dramatic increase in the incidence of very large fires. Folks were concerned about the constant gearing up and gearing down caused by the never-ending series of fire management teams.

County government was concerned that we were relegated to the last on the list for suppression resources as a “throw away” area with nothing at risk. The County is concerned that when you fly over the forest, more and more of it is blackened sticks as far as the eye can see. It is difficult to see this as a “resource benefit.” The two Counties, the Hoopa and Karuk Tribes were concerned about the health effects of months of thick smoke. The Hoopa tribe documented the increase in medical incidences and how it affected vulnerable populations. The smoke also affected tourism and agricultural yield. The frequent exposure of local populations to smoke situations every year or so is of great concern. We have children who have rarely seen a summer without smoke.

In the formation of our seven county energy independence project, it was determined that Trinity and Siskiyou County contributed by far the greatest amount of carbon to the atmosphere due to our frequent forest fires. This amount was far greater than larger urban areas in Sonoma, Mendocino and Humboldt Counties .

We do appreciate the appropriate use of controlled burns as a maintenance tool in areas where the accumulation of fuels has been reduced and stands have been thinned. Unfortunately, air quality regulations have reduced that window of opportunity to about one month right at the end of fire season. In many years, there are already fires burning or the population is so sick of smoke that it cannot be allowed.


Fire suppression, forest management and the social and economic welfare of our Forest communities is intimately inter-related. The Cohesive Strategy appears to have largely glossed over the economic enterprise facet of the strategy and in doing so leaves management of the problem of fuel reduction to the drip torch and slash pile. What could be viewed as a fantastic opportunity for rural economic revival and the creation of sustainable systems to support a long term cycle of fuels reduction and maintenance appears to be relegated to a sentence or two. Biomass utilization is not another issue altogether, it is part and parcel of the fuels reduction and management equation.

In balancing “trade-offs,” Siskiyou County has declared the condition of the five National Forests within our boundaries to constitute a public nuisance due to threat of wildfire and have demanded the accelerated abatement of that nuisance for the interests of public health and safety. At this point, the threat is of such great magnitude that abatement must take precedence over “ecosystem management.”

Marcia H. Armstrong
District 5 Supervisor
Siskiyou County
P.O. Box 750
Yreka , CA 96097



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