Managing “Unplanned Fire”: Expert Advice and the Decimation of Our National Forests

Smog the Golden! Mythical Pyrodactyl aka “Smokey Dragon” (Frank Carroll, PFMc)

The following interview by Jim Petersen with Frank Carroll is nearly 2800 words long — which is kind of excessive for this forum but well worth the read for anyone who hasn’t done so already and is concerned with USFS wildfire history, politics, and economics over the past 35 years.

The interview is nearly four years old, but has just been republished in the current issue of Smokejumper magazine by editor Chuck Sheley and is a slightly abbreviated version of Petersen’s April 2020 publication in Evergreen Magazine:

Despite the interview’s age, it remains directly relevant to current discussions regarding the great cost, visual and air pollution, wildlife mortality, and damaged rural economies resulting from continuing practices of the modern US Forest Service — what Carroll refers to as the “New Wildfire Economy.”

In 2020, then-USFS Chief Vicki Christiansen’s directive was: “Using unplanned fire in the right place at the right time.” Today, current-USFS Chief Randy Moore says he is “pleased to report that we have made significant progress in implementing this daring and critical strategy,” and talks about “using” fire on a “record 1.9 million acres as a method of reducing hazardous fuels.” If that is the objective, then much safer and cheaper methods of reducing such fuels — and even showing a taxable income while doing so — were demonstrated over hundreds of millions of acres in the 20th century and continue to be effectively used on private, state, and Indian lands to this time. 

According to Carroll, the “New Wildfire Economy” has become “big business” for the USFS, “effectively replacing traditional forestry practices with unfettered wildfire tending.” This is presented as the difference between producing tax revenues for the government while creating needed local jobs, safe and beautiful environments, and maintaining abundant and diverse wildlife populations vs. using taxpayer dollars to economically bankrupt our rural forest economies, killing our wildlife, and replacing the once beautiful landscapes with a sea of ugly and dangerous snags. Not in those words exactly, but documented factual outcomes.

Sheley, Petersen, and Carroll are all experts regarding the responsible treatment of “unplanned fires” and the consequences for mismanaging them. Petersen’s book on the topic and Carroll’s qualifications are described in the interview and Sheley’s introduction:
Chuck Sheley: I found Jim’s interview of Frank Carroll, a Colorado forester and wildfire expert, to be educational and informative and something the readers of “Smokejumper” magazine would find interesting. Jim’s book, “First Put Out the Fire,” leads off the discussion. This interview is from several years ago, and during COVID, but very relative to what is going on today. I’ve shortened the word count to make it fit in this issue. Reprinted with permission.

Jim Peterson: I’ve yet to hear from anyone who thought my book wasn’t “a good read,” but Frank Carroll, a colleague of 20 years, thought I stopped the wildfire discussion 20 years too soon.

Frank was Public Affairs Director for Potlatch Corporation’s Eastern Region when we met in 2000. Today, he is the Managing Partner in Professional Forest Management (PFM), a Pueblo, Colorado, firm that does trial work with clients whose private forests have been overrun by “managed fires” that began on adjacent Forest Service land.

Frank wrote: “I just finished your book and have to say I have high hopes for your book. I thought you would step above the old swamp and take on the biggest gorilla in the room, ‘using unplanned fire in the right time and the right place’ to ‘reintroduce fire to fire depleted ecosystems’ as Chief Christiansen put it in her directive to the troops last year.”

“Using unplanned fire in the right place at the right time” appears in a note Forest Service Chief Vicki Christiansen sent to her line officers last year. It is a thinly veiled reference to “managed fire,” or applying wildfire like prescribed fire, in a directive agency fire crews are expected to follow whenever the opportunity to let a wildfire run presents itself. There are few places outside of designated Wilderness areas where this can be done safely, but the practice is used widely across the Western National Forests as a matter of policy. Certainly, nowhere near communities, municipal watersheds, or fish or wildlife habitat critical to threatened or endangered species, and, yet, it is precisely these locations that are increasingly overrun by managed fire.

Some people rejected forestry long ago. State foresters, Interior agencies, and local governments have stayed the course where wildfires are concerned. Put them out as quickly as possible. Hence, the title of my book: First, Put Out the Fire. I write that if we don’t put these fires out, we won’t have anything else to talk about after the smoke clears. So, by all means, let’s talk about a proper role for wildfire in a post-industrial society that depends on its national forests for far more than timber.

Appropriately, timber production has become a by-product of federal policies that favor wildlife habitat conservation. In my opinion, “managed fire” is on a collision course with every forest value our society holds dear, which brings me to what’s bothering Frank Carroll.
I’ll let Frank speak for himself in the question-and-answer interview below, but his main complaint is one with which I am familiar— “managed fires” have a nasty habit of becoming unmanageable wildfires that overrun adjacent and well-managed private forest lands.
Petersen: Frank, tell us about your new business venture.

Carroll: Professional Forest Management, LLC, does wildfire impact analysis for law firms and private clients in federal tort claims and legal actions. From a forest perspective, this rather simple aspirational objective—using unplanned fire in the right place at the right time—is the absolute worst development in the history of forests and forest conservation.

Petersen: How so?

Carroll: We are burning our forests to ruin, and we’re doing it on purpose. We got out of the thinning and prescribed fire business on federal land, and now we are in the Age of Fire for Fire’s Sake. I call it “Fire-first” forestry. Federally-funded wildfire crews are burning big boxes around the West and are now responsible for 40 to 60 percent of the acreage burned by any given large fire.

Petersen: And this is managed fire?

Carroll: This is managed fire. National forest supervisors are expected to maximize the management role of wildfire, and they are doing it with a vengeance.

Petersen: This doesn’t sound like good forestry.

Carroll: It isn’t, but it is what’s happening. The 2018 Pole Creek and Bald Mountain Fires in Utah and the earlier Lolo Pass Fire are great examples of the madness of managed fire. We are working on $40 million in claims on Bald Mountain and Pole Creek alone, and there are many more that will go unchallenged because there is no internal or congressional oversight.

Petersen: What does that mean?

Carroll: It means the USFS is violating the National Environmental Policy Act. These fires are major federal actions with environmental consequences. Where are the Environmental Assessments or the Environmental Impact Statements? They don’t exist. There is no Record of Decision, no public process, no paper trail, no recourse for the public. The agency can operate in complete secrecy without disclosing specific or cumulative consequences. It’s all illegal. You cannot use Congressionally-appropriated fire suppression funds to do resource management except wildfire suppression. If you or I did this, we’d be in jail.

Petersen: Yet from what I’m hearing, “using unplanned fire in the right fire in the right place at the right time” is currently giving way to more timely and direct attack.

Carroll: Congressional delegations from the West forced Chief Christiansen’s hand because of concerns about the impact COVID-19 will have on firefighting this year. She is suddenly in full suppression mode because of the risks the virus poses to crews that work, eat, and sleep in close proximity.

Petersen: I understand that, but how does it undermine managed fire?

Carroll: The virus prevents the Forest Service from operating in complex strategic environments that feature big, intricate burnouts covering hundreds of thousands of acres because they can’t coalesce in one giant fire camp and coordinate all the moving parts. But you can be sure they’ll be back to “using unplanned fire” as soon as possible.

Petersen: Why?

Carroll: First, because they can. It’s a management prerogative they control completely and requires no public oversight or interference from cooperating agencies. Even when cooperators protest, as the State of Utah did in 2018, the Agency moves ahead anyway without consequences. Second, they are strongly pressed by environmental groups like FUSEE and the DiCaprio Foundation to let fires burn. And, finally, fighting forest fires has become big business for the USFS and their firefighting contractors—a hog’s paradise allowing them to spend money like drunken sailors. So, no one realizes what they are doing except the special interests who want them to do it, and an ignorant Congress is giving them limitless money to burn. So, they burn.

Petersen: How do you know all this?

Carroll: It’s our business nowadays. We do the intensive and comprehensive analysis of entire records from large fires. We spend years in deposition and preparing for court and trial. Our sources keep us abreast of new developments in policy and practice in real-time. In its reports to Congress, the USFS is counting wildfire acres burned as acres treated.

Petersen: We’ve heard that before and it has always seemed like a misappropriation of taxpayer dollars.

Carroll: It is. The USFS is using federally appropriated wildland fire management dollars to practice a new kind of wildfire-based resource management that holds that, since we can’t do real natural resource management projects on an ecologically significant scale, we’ll just use wildfire on everything everywhere and call it good enough. Managed fire is the only form of management no one questions. Environmentalists can’t stop them and don’t want to, they don’t need anyone’s permission, and there is no oversight.

Petersen: Real resource management being the thinning and prescribed fire regime that states, private landowners and Indian tribes use perennially?

Carroll: Correct

Petersen: This goes back to my belief that the fault here rests with Congress and its failure to allow the USFS to undertake forest restoration projects on physical scales that are environmentally significant.

Carroll: It’s worse than that. What we have here is a federal forest management agency that can spend whatever it wants in any way it wants with no public input or oversight.

Petersen: Aren’t there auditors who go through the firefighting bills?

Carroll: There are, but no fiscal officer in the USFS has firefighting experience. They won’t challenge or second guess fire commanders or forest supervisors because if things go to hell, they’ll be blamed. This is the new Wild West and Wildfire is the name of the game.

Petersen: Keep your head down and don’t mess up.

Carroll: Climate change, fuels equilibrium, growth, harvest and mortality, and reforestation are all yesterday’s news. What we have today is a rogue federal agency burning its way into a new bureaucratic empire that is publicly unaccountable.

Petersen: Reminds me of Eisenhower’s warning about the dangers posed by what he called the military-industrial complex.

Carroll: That’s a good analogy. What we have here is an Industrial Wildfire Complex that is answerable to no one. The Forest Service today is a much different agency than the one that all of us knew for decades. The transition from forestry to fire has rendered every forest plan objective effectively moot.

Petersen: That’s a big statement, especially when we consider that this transition occurred in plain view of anyone who was watching. And you worked for the Forest Service, didn’t you?

Carroll: In the National Park Service and the Forest Service from 1972 through 2012. I held primary fire, forest staff, and leadership roles in the USFS in Arizona, New Mexico, Idaho, South Dakota and spent time in Washington, D.C. My time since my Forest Service years has been spent in wildland fire mitigation planning and implementation, remote sensing, wildfire impact, and suppression analysis.

Petersen: Based on all your experience, how do we reverse course?

Carroll: Not easily. The Forest Service today is a black box. It is immune to public scrutiny and led by fire officers who are not well-grounded in natural resource management. They have no interest in further fights with smoke regulators or anti-management environmentalists. Why would they when they can burn far and wide, accumulate political power, maintain their Smokey vibe, and enjoy vastly increased budgets in the New Wildfire Economy.

Petersen: New Wildfire Economy. I don’t even like the sound of those words.

Carroll: No one should, but it’s real and it’s here.

Petersen: Some of these big fires burn so hot that they cook the soil. It can take a century or more to rebuild the organic layer in which seeds germinate, so 200 to 300 years to grow a new forest where the old one stood.

Carroll: That’s true and the burners don’t care. They see big wildfires as a natural agent.

Petersen: Better than the thinning and prescribed fire combination I describe in my book.

Carroll: Yes, because the New Wildfire Economy makes it easy. No appeals or litigation. No nasty wild-eyed environmentalists. Just lumbermen who don’t seem to understand the problem or are under too much economic pressure to have any stomach for the fight.

Petersen: So, where is the good news?

Carroll: The good news is that the Forest Service will not go to public trial on these issues for fear of upending their new wildfire hegemony. They are doing their own version of stop, drop and roll so they can stay hidden in plain sight. They will settle every claim out of court, no matter how weak, rather than go to trial and have these issues openly reviewed. This is good for people harmed by these fires.

Petersen: The big issue is the transition from an agency that manages forests to one that favors applied wildfire to every natural resource management objective?

Carroll: That is precisely the biggest issue. It is the issue that has the USFS hiding behind things like 747s that dump fire retardant on fires. It makes great video on the evening news but does nothing to address the underlying causes of these enormous fires or the agency’s decision to favor fire over forestry.

Petersen: We’re told the public is very suspicious of thinning projects that are large enough to actually reduce the risk and size of these big wildfires.

Carroll: Some people don’t like logging of any kind. Others see its value. In our New Wildfire Economy, it doesn’t matter. Welcome to the world of blowtorch forestry.

Petersen: More than half the Forest Service’s annual budget is spent on wildfires. Most people think that’s what it takes to put these fires out. You’re saying the big expense occurs when the decision is made to “manage” the fire, meaning let the fire run rather than put it out quickly.

Carroll: That’s correct. I can show you one 1,600-acre managed fire that cost taxpayers $12.6 million. The whole idea of firefighting has been turned on its head. The USFS is using crews to light fires on an epic scale, not put fires out. They have no idea what they’re doing or what the implications of using unplanned fire are for the future.
Petersen: Maybe Congress needs to tell the USFS that for every blowtorched acre there will be an acre that is mechanically thinned in combination with prescribed fire. The way it was done for decades.

Carroll: Nice idea but it won’t happen.

Petersen: Why not?

Carroll: Two different worlds. In the blowtorch world, the USFS burns to its heart’s content with no oversight, no need to ask anyone for permission and no lawsuits. In the world of forest and range management, there are laws and regulations, there is oversight and there is litigation. Moreover, the Forest Service no longer has the skill sets needed to plan and execute large scale thinning projects.

Petersen: So, we’re stuck with blowtorch forestry?

Carroll: The Forest Service—and Congress by association—are rolling big dice. They are betting that blowtorch forestry will reset the biological clock in our forests and that they will be able to meaningfully manage the resulting brush fields for the greater good. That’s just a fantasy.

Petersen: Brush fields have overtaken much of the 500,000-acre Biscuit Fire that burned in 2002 on southern Oregon’s Siskiyou National Forest.

Carroll: You haven’t seen anything yet. Blowtorch forestry is creating millions of acres of sorrel monocultures that will burn and reburn and revert to the lowest common denominator, cheat grass and wild oats, like we’re seeing in California. The only way they can manage these newly created brush ecosystems is to keep burning them and the only time they can burn them is in high fire season. So, the blowtorch will be applied relentlessly until the world changes.

Petersen: There are still some dedicated professionals working for the Forest Service. I’m surprised no one has blown the whistle on this racket.

Carroll: I know, but you must realize that the USFS has no intention of returning to its roots. It has embraced wildfire because it’s easier. My partner and I are doing very well in this environment, but it’s so sad to watch.

Petersen: So, if I have followed the bouncing ball to its destination, what you are telling me is that the Forest Service will work harder on initial attack this year because the virus and the western congressional delegation have forced their hand.

Carroll: That’s correct. And because of much better initial attack—and no managed fires—you will see smaller fires this year unless they just let them burn, which is likely because moving armies around will be harder in most cases. But as soon as the virus passes, the Forest Service will go right back to blowtorch forestry.

Petersen: Unless we can find a way to stop them from burning the nation’s federal forest legacy to the ground.

Carroll: I am not optimistic. The forces that gave us a five-fold increase in fire suppression spending will not abate. The current Forest Service Chief is deeply and personally invested in the ascendance of fire management in her agency. The Deputy Secretary of Agriculture over the Forest Service is likewise a fire-first leader and the current Chief’s mentor. There is a fire dragon walking the halls of the Forest Service in Washington, D.C. and it will not be easily dislodged.

44 thoughts on “Managing “Unplanned Fire”: Expert Advice and the Decimation of Our National Forests”

  1. Years ago, I predicted that the Forest Service would use “wildfire acres burned” as an accomplishment. And here it is, front and center.

    The truth is that we HAVE to manage wildfires, these days. Otherwise, it’s just ‘free-range wildfires’, burning where they can. The safety issues will never go away, and we’re left with balancing competing impacts. The “balance of harms” must be addressed, for us to move forward on these dominant issues.

    The “Whatever Happens” concept, allowing serious damages to occur, while ignoring the human impacts, is a very poor ‘plan’.

  2. I used to work in the office next to Frank Carroll on the Black Hills NF. It’s been interesting watching what he has done since he has retired. Frank has brought up an issue that needs to be discussed. Many of the western forest ecosystems are fire dependent. If someone suggests that they can be healthy with just mechanical treatment, they are probably not looking at the situation from an ecological perspective. Mechanical treatments do nothing to reduce duff and needle cast. In some areas such as the Southwest, this can play a significant role in fire behavior.

    Thinning and prescribed fire combined can be a very effective treatment. The problem is that the Forest Service has not shown the capacity to do either of these at the levels needed to address the issues. Other than R8, the FS has not shown any significant accomplishments in prescribed fire, in spite of major funding increases. Hence, the major increase in the use of managed fire. For a variety of issues, managed fire is much easier to implement than prescribed fire.

    There can certainly be problems with managed fire. Often it is being implemented by Hotshot crews, etc., that if they are told to make it black, they know how to do that. Fire ecology concepts are not really front and center sometimes. I believe every IMT should include a Fire Ecologist than can play a planning and implementation role.

    So, have there been some real problems with managed fire? Most certainly. The whole process needs a serious review and improvements made. However, I don’t think it is time to through the baby out with the bathwater.

    Frank brings up another important issue regarding fire spending. There is much needed oversight on how fire suppression dollars are spent. There are very few incentives for Line Officers to watch how the dollars are spent, but lots of consequences if things go wrong. Therefore, just throw money at it.

      • Frank, I wondered where you were at and that you hadn’t already jumped in on this! It is an important subject. The Forest Service deserves more scrutiny on this, and you have certainly done your part in raising awareness! I think that the FS needs to get a lot better at managed fire and typically, the Agency doesn’t make real change until they feel significant pressure. Rather than senior leadership just taking credit for additional acres treated, they need to support a whole lot more training and experience for the people doing the actual work. Put some funding into that rather than some of the other crazy stuff that gets funded.

  3. Exactly. Ditto the above. Mechanical treatments do nothing to remove surface fuels, and only by breaking that continuity do you actually stand any chance of stopping a fire. Thinning, particularly of merchantable only has an influence on crown fire propagation. Sure, let’s go back to the 10 a.m. policy, since that’s worked so well to date. It is precisely what you would expect from an industry hack, since protecting timber baron investments is at the core of the FS mission. Now they and the other land management agencies have that pesky requirement to do right by the land, not just doing right by extractive industry. Most large trees today would be better left in place to sequester carbon, rather than cutting them and replacing them with highly flammable plantations. If you really have a hard on against the fire industrial complex, maybe you should check the efficacy of spending unlimited sums on suppression – air tankers, night-flying helicopters, dozers and so on. Managed wildfires will always occur of necessity in remote places when all other resources are tied up protecting homes and communities. Carroll needs to get over himself. He cares more about about harvesting trees than he does in his shedding of crocodile tears over forest ecosystems.

      • Good question. Not questioning a wildfire use policy that is burning to oblivion everything we all worked to conserve our entire careers is folly. The industry considers the USFS to be out of business where timber harvest is concerned. Now they’re trying to defend private forests against FS “drip torch/fire drone” collaboration. Individual hotshot crew dupes and out of town ICs are using the straw man of “firefighter safety” to burn millions of acres of mature old growth and entire communities. No oversight. No cumulative effects disclosures. No public involvement. No objections. Just light it cuz #BurnBackBetter. Get a grip. Our current fire management strategies look like a criminal conspiracy to everybody but the serving FS.

    • Ahhh. You really should get out in the field now and then. The huge fires of the past five years were lit by the Midnight Suns and Gila Hotshots with no adult supervision. Go lol around at the absolute devastation of current policies. This isn’t a discussion between the merits of thinning/burning. It’s a 5 alarm fire with FS burners destroying everything we all swore to protect. If you’re still ambulatory, give me a call and we’ll do a six day, 4,000 mile drive by. Do you some good.

  4. Here are my thoughts.
    1. We are not going back to the past. Time’s arrow is one way. I believe that with regard to this as much as with HRV.. what we can do is learn from things that worked in the past. But first we would have to agree that they “worked.” Which I don’t think we are going to do.
    2. Many of us live in places where there is no timber industry. Even much of the material needing to be removed for fuel reduction is not merchantable. So while we try to get new uses for this material, we haven’t yet, so while I think the timber industry is a piece of the puzzle, we can’t rely on them to dig the whole country out of the “too much fuel” hole.

    3. Indeed, as others have pointed out WFU is a great way to reduce fuels on large numbers of acres. Thinning and prescribed fire can also do that, but the FS has trouble getting to the same number of acres.

    a) WFU can be dangerous and get out of control, potentially harming firefighters, communities, infrastructure, watersheds and wildlife habitat.
    b) it doesn’t respect carefully derived plan desired future conditions.
    c) so far, there is no required opportunity for public review or involvement in those decisions
    d) if we incentivize burning for feds (like timber targets), one can imagine that folks would be less concerned about risks to the communities than risks to their own careers. Appropriate levels of incentives for agencies to be accountable without getting carried away is indeed a challenge.

    (it seems to me that)

    4. the following things would help, although by themselves not be a complete solution:

    a) We can make prescribed fire (with mechanical treatment where needed) easier. AND
    b) Do fire amendments to Forest Plans that involve working with the public, outlining PODs and so on.. so-called “pre-planning” AND
    c) Build trust with communities where WFU is planned to be used, by being transparent, listening to communities in real time (as major decisions are made), being open about mistakes (indeed that’s part of fire learning culture), and paying people who are harmed.

    Finally, there is no reason to call each other names when we disagree. I’m actually concerned that if we continue to disagree our entire forest/fire world will be taken over by the Fire-Industrial-Tech complex and be further and further removed from natural resource specialists and scientists, and affected communities and into international groups, satellite data, and AI. It’s too easy for people who develop or use tools to see them as defining reality and ultimately want authority for making decisions based on their views of reality.

    When I worked with USDA research, I often heard about our community “the soybean folks get together, grab the money and fight later, forest folks always turns up fighting and never get the money.”If we look at mainstream media reports on wildfire, they often go to climate modelers, not fire scientists nor practitioners. Let’s not do that with wildfire.

  5. I am encouraged by the Bitterroot NF and the efforts the Forest has gone to in the last year or so. The line officers are involved and taking leadership. The BNF has done a good deal of prescribed fire, thinning followed by prescribed fire and now working with adjacent private landowners for coop prescribed fire as well as local partners for planning and connecting the projects done by the BNF and partners such as the Bitter Root RC&D, NRCS and the State of MT DNRC as well as Ravalli County. I am optimistic!!

    • This is encouraging! The focus was increasingly on prescribed fire in the 1970s, but in the 1980s the “smoke management” folks got involved, prescribed burning became a lot more expensive and limited with ephemeral “burning windows” and the ESA and EAJA legal teams jumped in and we began the current era of predictable catastrophic wildfires. You could look it up.

      Roads, logging, thinning, prescribed fire, improved reforestation planning, and forest maintenance would resolve this situation, strengthen our rural communities, and make our forests more beautiful and safer for both people and wildlife.

      We know how to do it, and probably should never have stopped. Better late than never, and hopefully the Bitterroot is showing us how. People under 40 are too young to remember how nice things were before college professors and modelers replaced experience foresters and scientists in the management of our public lands.

      • Of course. Back “in the old days” was during a cool climactic period, before fuels had built up to a ridiculous level, before suburbia had pushed well into the WUI, and the woods were crawling with people involved in logging. That doesn’t mean that it was the logging that was the sole reason the were no massive fires. Every generation wants to believe that “they” had all the answers, were the heroes, or that there are simple solutions to complex problems. Don’t get me wrong. I agree that walking away from every plantation on public lands after the Northwest Forest Plan was a mistake. If you harvest all the old growth off a site, you own that mess, and should nurture it back to a climax forest, but actual “sustainable” forestry is rare in the West. Privately owned clearcuts and the young plantations that follow are being vaporized in today’s climate-charged wildfires. At the peak of the season with higher wind speeds and unprecedented fuel aridity, there is no suppression happening, no matter how much technology and handcrews you have at your disposal. Alternatively, putting all the fires out on the shoulder season when there may be some good coming from the effects and claiming victory to pad those 98% successful I.A. stats is also self-defeating. I do agree with Sharon that we need broad solutions that include all options – suppression, thinning, prescribed fire & WFU – otherwise the suppressionists, who wish to express vanity in their “dominance” of nature will force some kind of dystopic A.I. driven madness upon us. All these solutions need to be community-based, as well. The only way to build support for a prescribed fire program is from the grassroots up, not top down. Otherwise, you have no support if there is a smoke event or more rarely an escape. The most efficient use of funds would be to focus on zoning, appropriate building materials, zoning rules, and other investments inside the home ignition zone, but I imagine we’ll keep bickering and quarreling about what’s happening way out in the undeveloped areas where fire will always have an important role to play.

        • Mike said:

          The most efficient use of funds would be to focus on zoning, appropriate building materials, zoning rules, and other investments inside the home ignition zone, but I imagine we’ll keep bickering and quarreling about what’s happening way out in the undeveloped areas where fire will always have an important role to play.


          I completely agree, but an additional critical component is finding the places where this can be done with the greatest collective local buy-in. For a variety of reasons I’m not a huge fan of the phrase “coalition of the willing,” but I think state and federal resources should be directed, to the extent consistent with applicable law, to those localities with a demonstrated willingness and ability to prioritize funds as Mike described.

          To move forward in managing federal forested lands, I believe we must steer between the traditional and the revolutionary, each of which offers more satisfaction than achievement. Practicable measures to minimize the number of firefighters, civilians, and buildings that get crisped annually would not be the worst start.

        • Mike: No one is saying that it was “only the logging” that kept the woods from burning all of this years, but there is little or no evidence that the climate was involved, either. Rather, I ‘m agreeing with your observation that the woods were “crawling” with loggers and logging equipment — and also sight-seers, treeplanters, berry pickers, campers, fishermen, school kids, hunters, and road maintenance workers; i.e., lots of local traffic on good roads by visitors very familiar with the landscape. That’s what kept the fires from getting out of control for nearly 40 years. Two generations of local folks and experts.

          Not “roadless areas” and “limited access” allowing migrant work crews while barring local taxpayers as has become an all-too typical condition in our public forests during the past 30+ years — i.e., the “current generation.” My thought remains that the USFS was doing a whole lot better job before they were replaced with judges enforcing ever-growing ESA regulations and EAJA-funded lawyers working for non-profit “environmental” groups during that time. These fires were scientifically predicted for those reasons, and it has nothing to do with “climate change” which has become the excuse du jour for these costly and deadly failures.

          If local Tribes and counties were managing these forests again — as they had been essentially doing when District Rangers were members of the local communities they worked in — most of these problems would go away. Again. And for eat same basic reasons, no matter the weather.

  6. The idea that the bad-old days of big tree liquidation and conversion to industrial timber plantations was the thing that kept wildfires at bay simply because wildfires began to ramp up a decade after NSO was listed is a spurious correlation easily refuted by current science. Simply compare how industrial timber lands are burning today compared to the national forests:

    Had the USFS continued down the path of following the industry model, the wildfire situation would be worse. Managing wildfires for resource benefits isn’t an option if we want to hold on to green trees throughout much of our fire adapted forests. Regulatory constraints aside, it is not feasible (economically or logistically) to treat a large proportion of the landscape with machines, let alone do it in perpetuity. Even on the acres that can support a green tree project, treatments are taking stands down to really low basal areas and TPAs. So low that many of these landscapes wont be able to support a green tree commercial harvest for at least 40 years, maybe longer on lower quality sites. At the same time, opening stands up that much releases the understory on sites that have a shrub component and dependable tree regeneration. Frequent fire was the thing that maintained those open stand structures in a condition that was not susceptible to high severity fire. Mimicking historical TPAs and basal area is not sustainable without frequent fire. The idea that fire is a choice is not supportable.

    I could toss in dozens of papers supporting the theory that human caused climate change is a driver of wildfire increases, but spending the time to do that would be futile. Honestly, I am not sure why I am bothering to comment on any of this.

  7. In 20 years, people will be demanding that the Forest Service will “do something to save our forests”, on the small chunks that have survived. We’re already seeing the options dwindle on current forests. Many in the Forest Service have become jaded to the politics, litigation and ‘spin’, diverting attention away from site-specific conditions. Both extremes are fighting for impossible outcomes, despite the reality all around them. Sadly, we seem to have to welcome longterm damages to our public forests.

    How can the public fight the extremists?

  8. See the Bridger-Teton Roosevelt Fire case summarized here
    Maybe an example of the cases Carroll works on? Meaning the FS will settle?

    I’ve argued that NEPA and ESA procedures for long-term fire management direction must be followed at the forest plan level. However, any decision during an actual fire is subject to this language in NFMA – “Resource plans and permits, contracts and other instruments for the use and occupancy of National Forest System lands shall be consistent with the forest plan.” If there is an argument that fire management is not one of these things, I haven’t heard it yet. And it doesn’t seem like a consistency determination for suppressing or not suppressing a fire would be very hard to do.

    It is interesting to think about the FS settling cases so that they can keep doing what they are doing (and not doing what they are not doing). Probably because in these cases plaintiffs are looking for money damages rather than injunctions.

    • Interagency Federal fire policy requires that every area with burnable vegetation must have a Fire Management Plan (FMP). These plans identify those areas where fire use or managed fire can take place. The FMP is tiered to the Forest Plan. As I recall, the FMP’s are not subject to public comment but maybe they should be.

      • I remember many discussions of whether or what parts of FMPs trigger NEPA, or more to the point, how FMPs could be designed to NOT trigger NEPA. As it apparently turned out, the NPS does apply NEPA to FMPs but BLM and FS do not. See p. 64 here:

        If FMPs in fact designate fire strategies available for different locations (as opposed to just “identifying” the areas where the forest plan already made these decisions), that would be a plan-level long-term management decision that should follow the public participation process used for forest planning.

          • It’s hard to find the actions to challenge, and it’s also hard to picture who a plaintiff would be. It looks like the same decisions get made different places by different agencies, and like they don’t really want to highlight where that is. Enviros tend to want more fire, but it might not put them in a good light to sue over not enough fire or putting fires out. For those who want less fire, they tend to be less knowledgeable, organized or litigious. (Just thinking out loud.)

            • In addition to Jon’s good observations, enviro groups (except perhaps the largest four or five) generally have limited resources. These groups will, therefore, allocate responsibility amongst themselves to different regions and issues, and generally sue only where a favorable verdict might have regional or nationwide significance.

              FMPs, properly constructed, should seldom have regional or nationwide significance. A burnable acre on, say, the Routt and a burnable acre on the Arapaho will have mutual fire management relevance only by accident. (Readers can substitute their own two favorite NFs here.)

              • I guess I was thinking more generically of the principle that FMP’s should have NEPA and public comment; seems like that would have national significance. But I guess the end is thought to be OK by those groups, so the means is not litigated.

          • It’s coming. SCOTUS has overturned the Chevron deference for FWS and will for every agency this summer. Heard from a FEMA contractor yesterday that FWS NEPA teams are tearing their hair about what they’re going to do now that the agency can no longer write its own laws under the Chevron deference umbrella. I told him he should tell them Merry Christmas! You’re going back to earning a living in public involvement and planning. Same with USFS. Agency opinion won’t cut it in September 2024. You want WFU you’re going to go through every step of legal Forest Plan revision.

    • Oh my. You have no idea if burning 300,000 acres of the Gila and Aldo Leopoldo was aligned with Forest Plans. Where is the discussion and disclosure of cumulative effects? Where are the issues laid out and public scoping diiscussed? What were the alternatives to free-range burning 10 miles south of the Black Fire? Who decided? Lots of Forest Planners here. Be offended. We’re allowing a handful of Hotshot captains to burn our mature old growth to cinders with no outside counsel.

  9. There are places where MFU and prescribed fire ARE working… Gila NF had a 90,000 acre lightning ignition this summer that burned at low intensity, constantly monitored, for weeks. The huge Black Fire of 2022 burned over 320,000 acres, but about 83% at “low intensity” (most all of Aldo Leopold Wilderness burned, as it has done in the past, limiting fuel loads.) The West is burning, more than in the recent past, but we need to learn to LIVE with fire — got here long before we did, will be here long after we’re gone

    • Hi Jim: How much did it cost to MFU this fire, and how much would it have reasonably cost if it had been a prescribed fire instead? A huge problem with the USFS is scale — catastrophic-scale wildfires are a 100,000 acres or more in size, while environmentalists have been known to legally challenge 80-acre timber sales and most prescribed fires are only a few dozen acres in size, or a couple hundred at most. I have long advocated good landscape-scale site prep following a wildfire, and prescribed fires that are thousands of acres in size in order to effectively defer the more deadly and destructive wildfires we have been experiencing the past 35 years.

      • good questions… and I don’t know the answer. I heard they had a “nominal” crew on the ground, implying 20+? Fire behaved well due to a few low intensity afternoon wetting showers. Cost was certainly quite low in my estimate for a 90K acre fire! Gila is not “every forest” – they do a lot of large scale prescr fire here in spring and fall (right NOW, too, in fact). The MFU fire was “bonus” acreage, since they conducted prescr fires anyway,

        • No on crew size. They spent millions and tied up crews for weeks. Big air show. Burning juniper which is a noble pursuit. But they misappropriated WFM dollars for “emergency fire suppression” to do it. Illegal.

    • Hi Jim,

      During the Black fire, the USFS themselves burned most of the Aldo Leopold Wilderness with aerial firing operations. The Forest Service has verified that. They started firing with helicopters and drones 10 miles to the south of the fire front and herded that intentionally-set fire up to the main fire over several days. They also ignited fire about 6 miles to the northwest.

      There were substantial collateral damages. Cutthroat trout habitat was damaged and large sections of the Continental Divide Trail were decimated. There was infrastructure damage on both public and private lands.

      Although the Black Fire was under full suppression, the Forest Service said they carried out the firing operations for “resource benefit objectives,” ie. the operations were a very large fuels treatment. This fuels treatment was done with no NEPA analysis or public input. That is illegal and wrong.

      • Sarah, as described, I agree with you. It raises all kinds of other questions in my mind. Like, how could a non-suppression person understand whether they could have done the backfire within 5 miles and it would have worked as well? How much could/did they claim as WFU – and are there standard approaches to deciding that that all suppression folks use? Does Inciweb show how much is designated as resource benefit vs. “bad” fire?

        I keep thinking about trust.. transparency, accountability, opportunities for the public to weigh in..

        • I believe that the unit still needs to complete a Wildland Fire Decision Support System (WFDSS) analysis and this is documented and signed by the responsible Line Officer. I also believe that this analysis is available to those who request it. It is not open for public comment as there is simply not enough time for that, and also it would not be appropriate. Usually, on a large incident, public meetings are held where information is shared with the local public.

          Earlier philosophy on wildland fire use was that you should more or less take a hands-off approach. Let the fire do its thing. Even if it was allowed to burn for weeks at a time. When I worked on the Kaibab NF, this approach literally burned us. The lesson we learned was that the longer a fire burns, the more chance of the inevitable wind event coming along and creating a real problem. Subsequently, we took the approach that it was much better to aid the fire, sometimes significantly so, in order to wrap things up before a major wind event came along. The purists in WFU probably have a problem with that, but if you are going to be in the managed fire game, you have to be proactive. Prolonged fires can be too much of a risk.

          I don’t know if this was part of the thinking on the Gila or not, but I am guessing it could be. When you have managed fire, you are going to have some undesirable things happen. It is not precise. Part of the WFDSS process is weighing the cost/benefit.

          • Thanks, Dave, that explains a lot! It does seem likely that the longer it goes on, the more likely a wind event is. At the same time, as Jim F. points out some forests had WFU fires burning all summer. Perhaps the monsoon weather patter or something else made that safer. Would be interesting to learn more from the folks with the long-term success.

          • This went way beyond aiding fire, the USFS actually ignited fire so far from the fire front that it could not reasonably be considered to be related to the fire. And while the fire was under full suppression. The Black Fire was basically used as a cover for a very large fuels treatment that the USFS had been wanting to carry out for some time.

            In June of this year, the USFS made the decision to expand the Comanche Fire in the Carson NF to 100X its size when the decision was made (from 99 acres to 10,000 acres). It was even broken up into burn units! The lightening strike was only the “match” that lit a large prescribed burn. This was a confine and contain operation, so it was more in the legal grey area than the Black Fire, but the trend is still wrong and against the interests of the forest and the public. An intentionally-ignited fuels treatment requires NEPA analysis. This was not any kind of allowing a natural wildfire to burn (with perhaps some limited burnouts to protect communities.) Rain did eventually put an end to the intended fuels treatment long before the full planned 10,000 acres were completed.


            Sometimes these spontaneous fuels treatments can work out well enough ecologically, but other times they do not, such as occurred with the Black Fire and a number of other fires, including the North Complex Fire.

            We have a NEPA process for fuels treatments for a reason — and one reason is to avoid environmental catastrophes. Advanced analysis and planning can help avoid burning old growth, endangered and sensitive species and infrastructure. There needs to be some consideration of how much fire we want on the landscape, and will the burn be an overall benefit.

            The Black Fire was expanded at the height of the worst NM fire season in many years, with ignitions just dropped from the sky during high winds What could go wrong? A lot. Ask the Sierra County Commission.

            • Thank you, Sarah, I appreciate the additional information. The map of the Commanche Fire was quite interesting! I understand how something like that happens but without knowing more of what their thinking was, it certainly appears like it was pretty aggressive. Especially after the recent history in NM. It would be really good to see a copy of their WFDSS analysis. Also, it would be good to hear from someone involved in the management of the fire to hear their thinking. That would be true of the Black Fire as well. Having been on the implementation side of similar things, I know there is usually more to the story. But also, sometimes mistakes are made and there are bad judgment calls. I have been there as well.

              I agree with your statement that generally, large fuels projects should go through NEPA. If you’re going to try and pull off a large treatment with managed wildfire, you better make sure you have solid support for it and that you work extra hard to bring the public along. The old “trust us, we know what we are doing” will no longer work. Too many things have happened.

              • “Too many things have happened.”

                That’s for sure. In the Santa Fe National Forest in the past decade, 387,000 acres burned due to escaped prescribed burns in three separate 2022 wildfires. 57,000 acres burned from all other types of ignitions, including all other human ignitions.

                The 2022 fires were not an anomaly. There was the NPS escaped prescribed burn, the Cerro Grande Fire, in 2000 and in 2018, there was an escaped pile burn in the Calf Canyon area of the SFNF, not far from where the pile burns escaped and caused the 2022 Calf Canyon Fire. There was a FLA done, and then essentially the same kind of pile burn escape happened in 2022, but exponentially worse.

                So all trust is gone. The USFS refused to consider the potential for escaped prescribed burns in the Santa Fe Mountains Project analysis, even after the Hermits Peak/Calf Canyon Fire had broken out.

                Add to that firing operations that expand wlldfires without NEPA, the public will not trust the Forest Service for a very long time, if ever. To regain trust the USFS would have to reconsider wildfire and forest management from the roots up, and a cogent National wildfire policy would have to be created within a genuine NEPA process. I mean the kind of NEPA process where the USFS actually listens to all parties. The open-minded kind that recognizes what they are doing at this point is not working, and we need to put all options on the table.

                • Well stated. You make an excellent case. I don’t blame you and others in New Mexico for not trusting the Forest Service (and the NPS, because of Cerro Grande) with all that has happened there. I really see your point. They need to go the extra mile on working with the public prior to initiating fire management activities. They have earned that. Trust is an easy thing to lose and difficult to earn back.

                  • Thanks for understanding Dave. Having almost half the forest to the east of Santa Fe burn was heartbreaking to those who love the forest. Of course much more so for the local residents, many who lost all their material possessions, home and family land.

                    And some people’s lungs have never been the same.

          • Hi Dave. Nah. I love your optimism but the WFDSS does not relieve the agency of its responsibilities under administrative and substantive laws in any way. A fuels AFMO and a fire planner sit down In the middle of the night, scratch out the first iteration of the WFDSS, then turn it over to a Southern Region IC and an Alaska hotshot crew? Nope. Not legally, morally, or ethically sufficient. Where are the Records of Decision that allowed or authorized fire teams to light the September 3-7, 2020 Bear Firing op in a red flag that burned 180,000 acres from Quincy to Oroville, killed 16 civilians, and burned two communities including Berry creek? No paper trail. No consultation. No accountability. That action is headed for a criminal referral for negligent homicide in Butte County. Our insane fantasy construct about firefighter safety above all is coming home to roost. Can you imagine? What if ambulance drivers and structural firefighters adopted current FS policies? They’d never enter a burning house to save anyone cause “too steep too hard.” I’m carried away by the anger I feel about what our agency and its apologists are perpetrating. Let’s just stop it, pause, open a National debate, follow the law, revise Forest Plans, and move forward.

  10. Frank Carroll is a timber industry toady who uses loaded language like “blowtorch forestry” and likes Bobby Kennedy, Jr. But when he lived in the Black Hills he called the 2015 Cold Brook Fire in Wind Cave National Park a “roaring success.” Why? Because it was conducted by the Park Service and not the Forest Service even though it burned beyond what was prescribed and six times better for Wind Cave National Park than fire managers had expected.


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