Has the Forest Service Done Its Homework?


Some have interpreted the Chief’s 2/20/13 fire letter as loosening last year’s ban on “let burn” fires. A closer look at the fine print suggests that’s not only easier said than done, but might not have even been said.

Here’s the relevant direction: “Line officers desiring to use wildland fire as an essential ecological process and natural change agent must follow the Seven Standards for Managing Incident Risk to the highest level of performance and accountability.”

And, “To be clear, Standards 1, 2, 3 and 4 need to be completed pre-season.

Standards 1, 2, 3 and 4 are:

1. Complete an Incident Risk Assessment
­ Develop an assessment of what is at risk (from preseason work or input from key stakeholders for boundary incidents), probabilities of harm, and possible mitigations.

2. Complete a Risk Analysis
­ Consider alternatives (objectives, strategies and tactics) against desired outcomes, respondent exposure, probability of success, and values to be protected.

3. Complete Two-Way Risk Communications
­ Engage community leaders, local government officials, partners, and other key stakeholders associated with the incident to share the risk picture and enlist input.

4. Conduct Risk Sharing Dialogue ( using “Red Book”, Chapter 05.11 framework’s 10 questions)
­ Engage senior line officers and political appointees (as appropriate) in dialogue aimed at understanding, acceptance, and support for the alternatives and likely decision.

So here’s how the process will work in the real world. Fire ignites in some out-of-the-way place where letting it burn makes sense. Line officer says to incident commander, “Let it burn.” Incident commander says, “Where’s your documented evidence that Standards 1 through 4 were completed during the pre-season?” Line officer says “Huh?”

Who wants to help me draft the FOIA letter I’ll send out to each line officer asking if she’s done her Seven Standards homework?

5 thoughts on “Has the Forest Service Done Its Homework?”

  1. Andy,

    I have a low tolerance for Tedious Fire Documentation (and Fire Consultant Jargon) but I see a problem which hopefully you can enlighten me about without my having to read this…

    It says to do it “preseason” but all the standards seem to have to do with a specific incident. Which can’t be known preseason. Unless fire models have gotten way more predictive. I also wonder if when you used to have to run it by the RF and now political appointees (as appropriate), how it is looser than last year (??). My view is that it’s never really appropriate, except perhaps last year, when all appeared to be managed to “avoid things that might look bad in the papers.”

    I suspect that I may be in agreement with you other than adding to the “Tedious Fire Documentation” with “Tedious FOIAs of seemingly unnecessary Fire Documentation.”

    • As it is now, some things do appear to “look bad in the papers”. We can start with the headline about Forest Service fire being over-budget by 400 million dollars. Why not just do all the EIS work to finally nail down the use of wildfires as land management solutions? *smirk*

      Be sure that the multiple EIS documents are site-specific to the forest types they want to burn.

  2. Larry, at risk of violating the “comment considerations” policy here (again), I’d offer that you could drop the “*smirk*” thing when making your point. I don’t necessarily have an axe to grind with you (and even agree with some of your points) but we all know your positions well enough now to know when you’re being “smirky” (which is seemingly a lot lately – cabin fever?). In my opinion it doesn’t help your credibility. With your experience you have a lot to offer here, if presented right…..As do the rest of us.

    Unsolicited friendly/unfriendly advice I realize….take/leave it for what its worth.

    • It is always very difficult to express humor over the Internet, sometimes. I use the smirk when I want to make sure people know there is a joke, or comedic irony in there. With difficult issues, it is easy for people to take things all too seriously, hence, the smirk. Does anyone else see the irony of requiring an EIS for fire salvage projects and thinning projects, while an EIS for a “Let-Burn” policy is deemed, by some, as not being needed?

      Finally, Sharon’s humorous dig at the media, and their penchant for bad things, inspired me to add my own dig at the current “bad things” dealing with the high costs of fire policy.

      Does anyone REALLY think that a lack of a “Let-Burn” policy last year resulted in going so far over budget?!?!?!?

  3. Andy,

    To address your points….maybe your influence with the Agency can actually make some of this a reality.

    First, completing the four Standards really aren’t that onerous. Any WFDSS assessment has to have (most) all of that documented for the decision. In reality (at least in my experience with the “new direction”), most of the “risk” stuff is ginned-up ahead of time and cut/pasted from one assessment to the next. Virtualy meaningless from a practical implementation standpoint, but an all important CYA “check-the-box” step – “Yes, we’re managing risk”. Good thing too, ’cause all those years prior, boy, we were really hanging out there and being reckless! I mean really? Throwing perfectly good firefighters out of a perfectly good airplane and such!?!?

    To my point….Standards 3 and 4 bring up an interesting twist with the obvious political overtones and NEPA-esque flavor to “alternatives” and “decision”. Here’s what I’d propose: Each Forest or Grassland would (in NEPA fashion) send out a letter requesting comment from the public, er, “stakeholders” describing the fire policy, appropriate responses to fire, when a fire may be allowed to burn, what the thresholds are, etc, etc, etc. It doesn’t have to be much…a couple pages at best (the talking points are already developed). Each Forest/Grassland would then take the time to read and respond (and make publicly available) to comments on proposed fire policy, response, risk management, etc. I seriously don’t see that exercise taking a huge amount of time and bet most of the comments could easliy be batched.

    It would be a good opportunity for the Agency to (ahead of time) state their intentions and work with local “stakeholders” in a broad sale and personal/local effort to get everyone ready, rather than waiting until there’s smoke in the air and the goofiness starts. Fire season happens every year and it’s kind of funnny how much of a surprise it always seems to be.

    The responses from such an effort would be a most worthy (if not entertaining) FOIA request. It would be intersting to see the public comments (and Agency response)…I’d be willing to bet most would be along the lines of “I hate smoke”, “cut it or it burns” or (my personal favorite) “thin the threat”. Yeah,yeah budgets are tough, but there are plenty of enviro groups advocating for fire, perhaps they could help with some of the responses. Matt, you in?

    Anyway, something fun to think about. I don’t see it as being outside the realm of possible. In fact the same efforts are likely being done in response to the direction linked above. The unfortunate part is no matter how much up-front work you do with “local Governmant Officials” it will not stop press releases to the tune of “millions of dollars worth of timber burned up” – (yeah – in some remote roadless/wilderness area). Oh, and in another press release we seemed to burn up more elk last year than the state claims they even have. WOW….now that’s a bad season. Took some pressure off the wolves though, for now.

    Count me in for the FOIA. Sharon has my contact info.


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