How the Forest Service manages fires – examples

A couple of recent stories provide some information about how the Forest Service is “managing fire,” and might provide some insights into the opportunity for public involvement (or not).

The Lion Point Fire is burning on the Sierra National Forest in California. Here is an article that basically incorporates the language (which may be boilerplate) from the Forest Service on its Inciweb site. (As of today, it’s burned 9 acres.)

“This lightning caused fire started approximately two weeks ago. Forest managers are determining the feasibility to manage this fire for multiple resource and protection objectives.  Desirable fire effects that are consistent with the forest plan and beneficial outcomes to the resource values at risk will be the main objectives for this incident.”

If you were the Incident Commander, and looked at the forest plan to see what it says about the desired outcomes and values at risk, you would find this in the 2004 Sierra Framework amendment ROD:

“Lightning-caused fires may be used to reduce fuel loads or to provide other resource benefits, such as conserving populations of fire-dependent species. Before wildland fires can be used, national forest managers must prepare a fire management plan that describes how prescribed fires and naturally caused wildland fires will achieve resource management objectives.”

My search for “fire management plan” did not match any documents on the Sierra website. Does anyone know if such a document exists, or what the managers of the Lion Point Fire are using?

The Sierra forest plan is currently being revised, and the 2016 draft revised plan would create four “strategic fire management zones” with different desired conditions and guidelines. (“Fire management plans” are not mentioned.)

Meanwhile, the revised forest plan for the Coconino National Forest in Arizona has just been released; it emphasizes forest health and thinning initiatives to reduce the risk of catastrophic wildfire. The latest “update” says “the revised management plan provides greater flexibility on the management of wildland fires and seeks to return the forest to its nature-based fire dependent ecosystem.” The Forest Supervisor says the new plan includes updated guidance in managing naturally occurring wildfires to burn dry forest fuels.

I found this ecosystem desired condition and these guidelines in the “fire management” section:”


2 Wildland fires burn within the historic fire regime of the vegetation communities affected. High-severity fires occur where this is part of the historical fire regime and do not burn at the landscape scale.


1 WUI areas should be a high priority for fuels reduction and maintenance to reduce the fire hazard.

2 Fire management activities should be designed to be consistent with maintaining or moving toward desired conditions for other resources.”

The Coconino forest plan describes the decision process for managing fires as follows:

“Site-specific analysis is conducted for prescribed fires and for any wildfire that extends beyond initial attack. For prescribed burns, the decision document is the signed National Environmental Policy Act (NEPA) decision. For wildfires, an analysis is performed using a tool like the Wildland Fire Decision Support System, and signed by the appropriate line officer.”

Which is not a “decision document” subject to NEPA.  And this language does not appear to address how to make a decision whether there would be an “initial attack” in the first place.

My take-away?  Forest plan desired conditions relevant to fires are even more important than for most projects if there is no later opportunity to influence a decision, so it is important for them to be specific and for them to vary in the forest plan based on the ecosystem and values at risk.  (While I didn’t look for them here, there should also be forest plan standards or guidelines applicable to suppression activities.)

19 thoughts on “How the Forest Service manages fires – examples”

  1. Just to provide a bit of clarification… all wildfires are managed at some level. The way this post is written it sounds like the FS needs to consult their Forest Plans to determine whether to manage a wildfire or not. For example, it is a misunderstanding to state “…whether there would be an ‘initial attack’…” because all wildfires receive some level of initial attack/size up. The issue is how wildfires will be managed either for suppression or resource management. If a decision is made to manage a wildfire for resource benefits, suppression tactics may still be used on different parts of the fire depending on values at risk, etc. Also, it is important to know that the decision on how to manage a wildfire is based on a number of factors besides Forest Plan direction, such as available resources, national policy that human-ignited wildfires cannot be managed for resource benefit, or weather forecasts.

    It is likely the folks on the Lion Point Fire are using a site-specific fire management plan developed through the WFDSS tool. The WFDSS tool does document the decision to manage a wildfire for resource benefit or for suppression. Once a determination is made a wildfire may be managed for resource benefit, this decision and the rationale are documented in WFDSS, and it is designed to include rationale that ties to desired conditions in the Forest Plan. WFDSS is also used to identify and document rationale for the fire management plan, which may include elements of full suppression even in a wildfire managed for resource benefit, based on safety and resource management goals.

  2. All the forests were required to have Fire Management Plans back in the early 2000s. Some went through NEPA and became plain amendments. Some did not. At the time, I believed they should all be subject to NEPA.

    • Seems to me like maybe getting all those amendments done would be high priority (like the GMUG’s with NEPA). possibly more important than plan revisions in terms of practical and useful effects?

  3. Here in California, there is no difference between a human-caused firestorm and one started by lightning. In theory. well-behaved fires. produce “resource benefits” but, in practice, conditions ALWAYS change (for the worse) before firefighters can change tactics. Again, in some Regions, we need a summertime ban on Fire Use. Additionally, such ‘projects’ are very costly, and use up scarce firefighting resources during the time we need them the most.

    ‘Preserve Wildfires’ seems to be the battle cry of preservationists.

  4. I successfully “smoked out” someone who knows more about this than I do, so thanks. I recall the same mess that Bryan does about fire management plans, and my impression was that it led the FS to quit doing plan amendments for fire plans, NEPA for fire plans, and fire plans at all, and that it was in practice replaced with the WFDSS process MD describes. They’ve created a process where they can avoid using NEPA, and that may not be legal. (See also:

    I would like to see how a WFDSS documents a “rationale that ties to desired conditions in the Forest Plan,” but that doesn’t seem to be something included on Inciweb (for the Lion Point Fire any way). I think that would help contribute to public understanding and support.

    NFMA does require that national forests consult their forest plans prior to “resource plans and permits, contracts and other instruments for the use and occupancy of national forest lands” and these things must be consistent with the forest plan. The Sierra and Conconino forest plans acknowledge this regarding fire management.

  5. Small lightning fires in June and July often become catastrophic wildfires when the East winds arrive.
    There are many examples, every year, of this happening. They end up costing tens to hundreds of millions of dollars. (Not including lost of resource.)
    This is not a good time of year to play with fire.
    It will be interesting to see what happens to the Lions Point fire. I hope if we get lightning strike fires in Oregon, that they put them out as fast as possible.

  6. I want to say a little more about desired conditions using this example from the Coconino:
    “Wildland fires burn within the historic fire regime of the vegetation communities affected. High-severity fires occur where this is part of the historical fire regime and do not burn at the landscape scale.”

    This is common in recent and pending revised forest plans. Instead of including the actual desired fire regime (or other ecological conditions), they just restate the generic requirement to manage within the natural range of variation. The assumption seems to be that they’ll figure out what that is later. And instead of a forest plan telling us where high severity fires may be desired, we have to figure that out later, too. Now what happens if “later” is when a fire starts? Time to call in the ecologists? (Certainly no time to include the public when determining the desired condition, which is what NFMA requires. And once they do figure out the desired condition, which is a long-term programmatic decision for future activities in the same area, there will need to be a forest plan amendment to incorporate it.)

    • Well, another problem is that what is historic can change through time and with more info, so you don’t want to be locked into specifics that might change in a forest plan.. otherwise you would have to amend your plan every time some “latest science” shows up.

      • NFMA sets up a 15-year plan, and criteria for whether you need to change it sooner (a very high bar of when “conditions in a unit have significantly changed”). The expectation (explicitly incorporated in the 2012 Planning Rule, 36 CFR §219.5(a)) is that adaptive management is to use the plan amendment process. If you don’t lock in specifics you don’t have a plan.

        The latest science normally “shows up” during the project planning NEPA process, where it can be used to modify a project, and if a change in plan direction is needed it can be used for that. If there is no project NEPA the new information should still be applied to the fire incident if relevant, and a subsequent plan amendment could occur.

        In response to Conor, I’m not advocating NEPA for WFDSS. I do think NFMA requires documentation of how a management action is consistent with a forest plan. I am also asking for better integration of fire into the forest planning process, including NEPA. NEPA only requires disclosure of reasonably foreseeable effects sufficient to develop and compare alternatives. At the plan level, if there are not going to be alternative desired conditions for vegetation or fire regimes, or if there are not going to be alternative levels of emphasis on wildfire use, or there are not going to be alternative locations for where it could be used, that needs do be stated and effects discussed regardless. (The decision-maker doesn’t get paid our tax dollars to hide the facts or an “unpalatable” decision rationale from the public. It sounds like people’s lives may even be at stake.)

        (Craig, thanks for your info on the process also.)

  7. Interesting issue. Certainly the more recent Forest Plans that mention specific ecosystem desired conditions are a move to broadly include fire management in NEPA, and my understanding is that this is being included in WFDSS. But I wonder how much information can be realistically included in Forest Plans and subject to NEPA. I think some of the people on this blog are more optimistic about the NEPA process than I am…

    There are two issues. One is the unpalatability of publicizing triage decisions. For example, I lived in an area of WUI that a fire manager once told me was undefendable and that if fire entered the area the plan was for ground resources to fall back to the highway. I don’t live there anymore, and I certainly understand that tough choices like that may need to be made…. But putting that down on paper could be extremely problematic for the forest service and landowners alike (insurance, property values, etc).

    The other issue is that after an initial assessment of a fire, the response decision comes down to a whole host of dynamic factors including ERC, weather, resource availability, a complexity analysis if there are other fires burning in the area, and ultimately professional judgement. There is no way to include this information in a written document. A decision-support tool like WFDSS is too dynamic and complex to be subject to NEPA, let alone the leeway necessary for Incident Commanders to exercise best professional judgement.

    There are some great aspects of NEPA (thorough environmental review and analysis, public involvement) but there are some significant downsides and limitations as well. I don’t think NEPA is a panacea for every land management issue.

    • I agree with you, but also think that there might some broader decisions about fire use for which NEPA analysis could be helpful (it would be interesting to hear from folks like the GMUG who did a fire use amendment with NEPA and have them reflect on how helpful it was).

      Sometimes people equate “doing NEPA” with “public involvement”.. so perhaps NEPA has a value not for the technical analysis (in this case of varying “might coulds” that could happen, I always wonder how useful this is), but for building a coalition and educating folks about fire use. Yes, I know people do public involvement without NEPA, but then some people say “why don’t you do NEPA, we know and understand that process, are you short-cutting something?”.

  8. Unless the existing forest plan has been amended to allow a stated managed use of a natural ignition for resource benefits the Forest Service will adopt a “confine and contain strategy” that includes several options from full suppression mode to one where they back off and allow an area to burn through one or multiple burn periods. These decisions are based on multiple factors including observed fire behavior, terrain, fire fighter safety, current and forecasted weather, staff commitments and draw down levels, smoke impacts, etc. in a declared ignitions for resource benefits. Some air regulators believe a smoke mgt. plan is then required because the FS in not in full suppression mode. Confine and contain is suppression with choices. It is critical that those of us who work on expanding fire restoration build strong relationships with air regulators and underscore the emissions trade offs between current uncharacteristic fire trends and outcomes and scenarios where we are working with fire when we have some choice over outcomes. It is complicated—but we are seeing real progress in understanding what the choices are and that there is No-No Fire option in California. Sierra Nevada National Forests are all moving (at different schedules) to officially adopt a thoughtful and rigorous risk assessment, decision protocols and communication strategies pertaining to the use of natural ignitions for resource benefits when conditions are right. The Fire MOU Partnership is one way we have brought air and fire managers together to expand efforts to restore fire in fire adapted ecosystems.

    • Sadly, the CARB doesn’t really cooperate with the USFS. They do, however, routinely issue waivers to Sierra Pacific Industries, for burning slash piles and other burning activities.

      Unfortunately, there are multiple barriers to doing more burning, and some of them are controlled by the Agency.

  9. The Fire MOU Partnership is working with CARB and air districts to expand ecological fire in California. Emissions trade offs support expanding controlled burns and our partnership has multiple air regulator partners.
    The past is over. Collaborative partnership and shared goals is the future of the Fire and Air Partnership.

    • The Forest Service has neither the budgets, nor the manpower, nor the expertise to do more than the pitiful acreages they do today, in California National Forests. Burning logging piles should be the responsibility of timber crews, and not dedicated firefighters. Every Ranger District needs a permanent seasonal crew of ‘Super-Techs’, who can do multiple types of jobs, in multiple fields. The work is there but the multiple barriers remain.

      Another key is the liability issues. If the USFS lights a burn and it escapes, they are responsible for ALL COSTS!


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