A Programmatic Interagency Managed Fire Review?

I’ve always thought that Managed Fire was a particularly interesting issue. We have folks like Sara Hyden and Frank Carroll raising questions, who otherwise might not agree on much about forest management. In June, I posted a five part series on Exploring Views on Managed Fire. If you search on Managed Fire in the search box you can find those and more.

I’ve noticed a pattern with some issues.. people have concerns and they are seemingly ignored, or at least not directly engaged with in any public form. People finally get together, involve those of a political persuasion, and try to do something, and it shows up as “too much” and “you shouldn’t fix it that way.” Or it can become partisanized because one party seems more sympathetic than the other. The Fire Service may be another example of that pattern.  Fortunately, Managed Fire has not been partisanized as far as I can tell… yet.  I hope we continue to resist any such efforts to partisanize.  Sadly, it has already started in letters like this..in the AZ central.. “one wonders?”:

When asked why this happened, perhaps it’s too early to know. But one wonders if the massive workforce cuts under the current federal administration in both the National Park Service the United States Forest Service, leaving many specific and essential jobs vacant, played a destructive role in the senseless burning of this national treasure.

And so it goes.. still here we are.

The Hotshot Wakeup discussed the Dragon Bravo fire, which was under a confine/contain strategy.

These confine/contain fire strategies are defined as:

“Restricting the spread of a wildfire to a defined area, using a combination of natural and constructed barriers that will stop the spread of the fire under the prevailing and forecasted weather conditions until the fire is out. This includes some actions (for example, line construction or bucket drops) to suppress portions of the fire perimeter.”

This is also different than a full suppression fire:

“A strategy to ‘put the fire out’ as efficiently and effectively as possible, at the minimum possible acreage, while providing for firefighter and public safety. Synonymous with Full Perimeter Containment and Control. (209 User’s Guide, NWCG)

As is so common with Managed Fire Exceedances/Blowouts/Problems, THW says:

However, I think it’s fair to say that these strategies were working up until they didn’t. Fire activity on the Dragon Bravo Fire back on July 9th is what I would consider fairly mellow.

Also there was another fire in an earlier year (the Dragon Fire 2022) where the same strategies worked.

THW asked these question:

So I ask this final question… It’s not who’s to blame; the question is, does the national wildfire response strategy need to shift to a more aggressive initial attack response across the board? National Parks, Forests, and other lands?

Is that the route to go IF we drastically increase prescribed fire and fuels management projects? Is it fine the way it is, and we just have to convince the public that this happens once in a while?

The comments to THW’s post are interesting, hope you can read them without a subscription.

If not, questions were raised about whether the lodge was adequately prepped.

Also according to Pecos Ranger:

The Dragon Bravo Fire was being managed by a T3 IMT until it wasn’t on July 13th. A T3 IMT with minimum staffing does not have an assigned MET, nor an FBA. So, this hard question needs to be asked.

And Derrick Holdstock suggested that folks upscale the management of managed fires:

There is a 3rd strategy. Throw the world at managing it. If you are managing a fire for resource benefit during fire season, then why not have a large organization creating the Altetnate, Contingency, and Emergency lines if the Primary line fails? I can tell you that I know of zero R3 VIPR contractors who were committed to a fire at the time this or the other fire blew out. Most are continuing to sit. I know VIPR resources are not the tip of the spear in some cases, but many are solid and all would be ecstatic to have an order to brush out a contingency line on a managed fire, instead of sitting around waiting to go out of business or to put a bullet in their head (whichever comes first).

I think each Managed Fire Escape (MFE) of course deserves its own lessons learned and review.  At the same time, as THW and others have said, we run the risk of losing public support if all they see is “one MFE at a time.” Which raises the question “what should happen with the overall USG policy on MF?” “By what kinds of discussion, by whom, should the broader policy implications be considered?” “How does that tie in to “lessons learned” from each MF that was not a success (and who decides what makes it a success?)”.

And I’m not thrilled with getting Congress to look at it (sorry, staff folks) because .. I don’t think that they’re good at this kind of thing. IMHO the desire to score political points and give favors to preferred groups doesn’t always make for the best design and improvement of processes.

To my way of thinking the FS model for their prescribed fire review (following Hermit’s Peak Calf Canyon PFEs) is a better example.  This kind of review for MFE, though, would have to be multi-agency, look at the entire USG MF program, and involve some representatives of affected communities as well as practitioners.  It would look at MFEs and also MF successes and see if there is a pattern.  Agencies and units have different approaches, are all equally successful? What seems to make the difference? What are the different approaches at involving communities in decisions? What do MF projects need more of to be successful? Are the agency incentives lined up in the same direction as what the communities want?  Should units have consistent approaches to any NEPA pre-planning efforts to outline MF sideboards?  What overlap, if any, is there between conditions for MFEs and Prescribed Fire Escapes (a guess would be predicting future weather)?

And some folks seem to be against MF in general, but MF can be many different things in different places, which perhaps need to be parsed out. For one thing, it would be handy to know how many MFEs there are each year, where, when, impacts and link to the lessons learned.

We have folks like the Coconino who seem to have almost a prescribed fire/managed fire hybrid and seem to be successful. Then we have the “lightning strike in area that “needs it” and is far from infrastructure, and even though it’s summer, we think we can watch it until winter” kind of MF. Which don’t seem to be the same thing at all. Yet if we talk about MF, probably everyone has their own scenario in their head.

As a non-expert, I would have to guess that some of the MFs escaping are due to their having started pre-season and perhaps it not being clear exactly if the season (according to the Chief’s letter of intent) started.  For example, the Laguna Fire on the Santa Fe as of 6/30:

The wildfire was first reported Wednesday June 25, 2025. Fire managers will start firing operations as early as this week with the aim of restoring the ecological process of fire across approximately 13,000 acres of forest land. A closure order for the area surrounding the Laguna Wildfire is expected to be issued for the safety of the public and firefighters.

It’s interesting that the words used were “restoring the ecological process of fire” and not necessarily “reducing fuels strategically to so that key resources and infrastructure might be more able to be protected from wildfire.” Which goes back to “how clear do units need to be in advance about goals and sideboards?” and “is there a role for the public and environmental analysis at some point?”

So back to… how would you organize some kind of programmatic inter-agency review of MF? Who would be involved? What questions would you ask? What data would you collect?

35 thoughts on “A Programmatic Interagency Managed Fire Review?”

  1. I think these issues are going to be a ‘popcorn moment’, where the general public will not be satisfied with anything the government does (or says).

    Some people actually think that safety issues are a cover for efforts to purposely burn more forests. Such conspiracy theorists will not be convinced otherwise. Other people think that every ignition should be smothered by an army of firefighters, regardless of the danger. There are even some who just don’t want smoke…. OR logging. Stomp every fire.

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  2. As a 20-year experienced fire fighter, rising to Type 1 Command level, one should NEVER use the so-called “managed fire” technique, and especially not when fuels are at their driest point in the entire year! This fire was the result of in-experience, lack of training, and or possibly stupidity.

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  3. I was the Fire Staff Officer for the Kaibab NF when the Warm Fire happened in 2006. This was on the North Kaibab RD, north of the GCNP North Rim. So not far from what recently happened. In fact, I have seen the Warm Fire brought up in a recent news article.

    The Warm Fire started in early June, which is typically in the middle of the Southwest’s fire season, pre-monsoons. However, we had had a good bit of moisture prior to the lighting that started the fire. The decision was made to manage it as a Wildland Fire Use (WFU) fire. Back in those days, there were WFU teams, which were an IMT specializing in WFU. We brought in a team from Colorado to manage the fire.

    I won’t go into all of the details, but suffice it to say that the plans to keep the fire west of Hwy. 67 (the road to the North Rim) were changed when the fire spotted across the road, and we greatly expanded where we would allow the fire to grow. In hindsight, this was the first decision that led to an undesirable outcome. Things went well for a number of days, then a major wind event with a shift in direction was predicted. We tried to get additional resources but since this was a WFU fire, we were low on the totem pole and there was a good bit of fire activity elsewhere in the Region, creating a demand for resources.

    Long story short, the wind came with a shift in direction and wind speed and ruined our day. The fire grew by 40,000 acres in less than a couple days. Fortunately, all we lost were trees. I was back there three years ago and most of the fire is now a beautiful stand of aspen. It is now maybe one of the largest stands of aspen in the country.

    So, all of the experts came out, telling us how we had messed up with knowing virtually nothing about what really happened. We conducted the review ourselves and I think we did a good job. A number of lessons learned were identified.

    Why were we doing WFU? And why did we get back in the saddle and do a lot more, very successfully? Just to be honest, it was a great way to treat acres, restore fire to the landscape, not have to do NEPA, and you knew the funding was there. The biggest lesson we learned going forward was that if you are going to manage a fire, help it along. Don’t be shy about it, get the helicopter up and drop balls. Identify a perimeter, and help it get there in a relatively short period of time. Otherwise, you risk, just as they recently did on the North Rim, that you will get a major wind event and it will ruin your day. This went against the WFU purists at the time, who believed you needed to let fire play a natural role, let it grow naturally. I say, if you believe that, you shouldn’t be in the managed fire business.

    I am withholding any judgment on what happened on the North Rim until I see the review/investigation.

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    • “since this was a WFU fire, we were low on the totem pole”

      Is this still the policy, if so where is it written, and does it make sense?

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      • I don’t even think it was policy back then, but at the Regional level, when resources are getting scarce, they have to make decisions on priorities. Back then, fires were clearly labeled as WFU fires. It was easy to assume that a WFU fire was a lower risk compared to a full suppression fire and, therefore, a lower priority for resources. I really don’t know how it works now. I imagine that when resources are getting thin, that same thinking creeps into the decision-making process.

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    • Thank you so much for this. I have worked with some very progressive FMOs that subtly managed wildfires as WFUs. By no means did they “let it burn”. If the conditions were right, they would build a bigger box and actively manage the fire throughout the box, using different strategies in portions of the fire where they had different goals. Their decisions achieved far more acres of treatment than anyone else in the region during that time, yet no one would ever know it.

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      • Exactly! Do what needs to be done and keep it on the downlow! Our costs to do WFU on the Kaibab at that time were incredibly low. Much lower than prescribed fire or mechanical treatment. Done correctly with common sense, it can be very cost-effective and return wildfire to fire-adapted ecosystems.

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      • I agree that there is no one WFU.. it sounds like your example is more of a Coconino-like hybrid of PF and MF.
        Did the FMO communicate the strategies to the public in real time?

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  4. I’ve taken a while to respond to this but have been discussing it on Facebook since the Lodge burned. I want to be very careful in what I say, but we really do need “Managed Wildfire for Resource Benefit” (MF)! Where and when is the sticking point, and how the decision maker and IC are trained.

    The fire section of the FS is full of an almost cult like group of folks who do great jobs at suppression. In the older days, these folks were mainly made up of professional foresters that were the timber program and rec programs on a District. That education component comes into play as prescribed fire and MF vector into use. Do they have to have a degree? Nope, but it helps!

    In Region 3, you can almost set your watch for fire season starting in April, and ending in September. When monsoons are strong and reliable the MF folks can usually start in mid-August, after the atmosphere begins to calm down. As I’ve said before, our Regional Fire Staff would not allow MF until August, based on his experience and management education; he had been a Forest Sup and came up in the early fire world.

    The mistake of losing the Lodge was made by managing a wildfire too early in the season! Also, the whole country – or at least the West, was entering an excited wildfire occurrence and the NPL was going up weekly. I’m not familiar with North Rim conditions but it must be pretty similar to South Rim. Ponderosa pine with patchy to dense understory, and where understory is lacking would have a high grass component.

    The “Stomp ever fire and save every tree” crowd, as Rodney mentions will certainly be on point on this one! Willy-nilly decisions from inexperienced decision makers and IC’s seem to keep popping up at the most inoperative time, and of course our government generally rewards these knot-heads.

    Take MF out of the priority list of funding and Primary Purpose and use it as a bonus for Program of Work instead of a target! How the new organization unfolds will be an interesting experiment! Hell, it can’t get much worse…..

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    • Do know the North Rim starts at about 1,000 feet higher than the South and is cooler and a little bit wetter, with quite a bit more spruce, fir and aspen.

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  5. Reminds me of the situation with self-driving cars. Even though self-driving cars are safer than people driven cars, people still go crazy if someone is killed by one and think that they shouldn’t be allowed until they are 100% effective. There’s an overwhelming body of literature finding that fire is essential to resilience and thinning is not all that effective without fire. Without resource benefits fire, we will be unable to get enough good fire on the ground with drip torches to actually turn the tides because our Rx fires are just too small to be effective when fire weather is extreme. Fire vs. no fire is not the choice before us. We can choose when we want the fire, or it will be chosen for us.

    Also note, this is by no means the driest time of year in this part of AZ. This is “monsoon” season. The worst fire weather occurs in June, and it often ends around the first week or so of July.

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    • So, I vaguely remember some social science around risks. People feel differently about ones they choose (cell phones, sugar, smoking various items) than ones that they don’t have a choice about. I think having your house/livelihood/animals burned up would be the latter.

      “we can choose when we want the fire”.. up until a point -apparently- and sometimes for fairly clear reasons, we are unable to shut it down in a timely way when conditions change. Resource availability? Bureaucratic problems? Poor weather prediction? We’ll find out hopefully.

      I think folks will have a problem telling people who lose their livelihood “we did it so something worse wouldn’t happen.” What could a “true” wildfire do that would be worse for them? In fact, at some point the WFU fire becomes a wild wildfire for all practical purposes.

      I think the question is simple “how can we keep WFU fires from becoming wild wildfires?”

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      • You are reiterating the point made with the self-driving car analogy. The family members of someone killed by a self-driving car certainly have a problem with the outcome, even if fewer people die from self-driving cars. Just like someone that loses their home in an escaped Rx fire or WFU fire is not stoked about it. Another example is a healthy person relying on herd immunity from vaccines and not getting vaccinated themselves for fear of complications.

        I think it goes beyond one simple question. As important as it is to minimize the probability of a WFU getting away from managers, it is as important, if not more so, to create fire resistant WUIs and maintain defensible space. The GC Lodge had a shake roof and a more than inadequate defensible space. No insurance company on the planet would take on a fire policy for that place in the condition it was in. Our local ranger district, which is in a WUI, put on a new shake roof a couple years ago. It makes me cringe each time drive up thinking about the message that sends to the public.

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        • To be clear: I think MF has a place, but I think 1)the public needs to be more involved
          2) people need to be clearer about the goals of each one (some Forests do this well, so it shouldn’t be a problem.)
          3) The public needs to know that there are systemic improvements made when things go wrong (think NTSB).
          4) with the military industrial technological folks getting involved, MF and PF will be able to be managed better to avoid escapes, conceivably.

          I just think the “it’s OK for some people/animals to suffer in the pursuit of a higher good”, in a society such as ours, requires some public acceptance and oversight that develops trust in the technology.
          I seem to remember a FS training about “understanding, acceptance and support.” This example reminds me a bit of discussions of NIMBY, “it’s OK for you all to suffer because we have an idea that dense housing and no cars is generally better.” Or even “it’s OK to shoot barred owls because.. spotted owls.”
          What is says is “your well being counts less than our ideas about how things should be.” And we have studies that support our views! Unfortunately you don’t have access to developing your own studies, and there are no places where the topic can be questioned.

          And not to put too fine a point on it, self-driving cars, no cars, and MF all take some degree of independence away from individuals and give it to somewhat opaque bureaucratic entities. So people are wary.

          It’s not rocket science. Involve people upfront, be transparent about what went wrong and how you’re going to fix it. Be a face that takes responsibility and not an algorithm. As in “it’s not our fault.. climate change!” or “it’s not our fault, our AI told us to do it!”

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          • “your well being counts less than our ideas about how things should be.”

            But isn’t “our ideas about how things should be” really “the greatest good for the greatest number?” (I agree that people need to understand how that conclusion is reached and by whom.)

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            • Not exactly.. I was actually thinking of the poor wolves familiar with their territories and prey sent down from beautiful British Columbia to dry Colorado.. for an idea.

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        • I’d only add this doesn’t help ranchers with livestock. I think WUI, yes, MF, yes, but we can’t forget animals and evacuations. All of the above.

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  6. But for the loss of the north rim’s historic lodge, would the Dragon Bravo fire have even made the news? Probably not. Which suggests that people who care uniquely about the lodge may be asking the wrong questions.

    Here are some questions I would ask:

    1) What role did the Historic Preservation Act play in banning Firewise construction practices, e.g., metal roofs, at the historic lodge and its associated cabins? The lodge and cabins appear to have wood shake roofs. Ironically, perhaps the HPA succeeded by ensuring that this historic lodge burned again just as it had 100 years ago — this was not the lodge’s first fire rodeo. In other words, this lodge’s history was never static; just as fire-dependent ecosystems burn regularly, so, too, do historic buildings built from flammable materials.

    2) Were the lodge and other structures ignited by wind-blown fire brands and embers far distant from the active fire front? The few photos of the burned area from the last couple of days show lots of unburned tree canopy next to incinerated structures. This pattern is typical, e.g., Paradise, California, where structures ignited while the fire front was still a mile or more away from town. Most of Paradise’s homes were more flammable than their surrounding vegetation. So, too, wood shingles (with a moisture content in the single digits) are much more flammable than trees.

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    • Thank you so much for pointing out the roofing material. I have not been out there for 20 years. Absolutely insane to blame this squarely on fire managers. Alas, I have no doubt we will not learn the right lesson from this. It’s way too easy to frame this as the fault of fire managers and too nuanced to convey how important fire-wise planning is.

      I am resigned to the fact that these issues are too complex for elected officials and the general public to grapple with and managing wildfire for ecosystem benefits will be largely removed from the toolbox. There are too many full suppression advocates out there (TSW is littered with them). Yet, I am not aware of any data supporting the idea that full suppression, thinning, and the current rate of Rx fire is a viable strategy. When humans take the risk to proactively address the larger fuels issue, they are blamed if it goes wrong. It’s really hard to prove that a wildfire managed for ecological benefits allowed fire managers to suppress a fire start under really bad conditions and prevented a cherished historical structure from burning, but it’s clear when something goes wrong from human choices to use fire. NTM, the photos of a burned-out building that people loved is emotionally very powerful.

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  7. Thank you Anonymous for the outstanding analogy using self-driving cars. Many forget that fires don’t just go out because they aggressively attacked from Day 1, and forget the vast number of contained fires which have been blown out and escape due to a severe wind event. It is hard for some to grasp that we could have likely had the same outcome if more aggressive measures were taken.

    For better or worse, wildfire behavior and outcomes are determined by unpredictable conditions and circumstances, and firefighters and fire managers have to play the odds when they make their plans. That’s why Burn Bosses don’t use the term “controlled burn” – we can prescribe conditions and mitigations for a burn or fire, but we do not control them. The unfortunate truth is that you can make all the right decisions and mitigations in managing a fire (suppression, managed, or prescribed – the type doesn’t matter), and still have your ass kicked.

    I would urge everyone to wait for the results of the review before drawing any conclusions. GRCA has a long history of managing wildfires on the North Rim. Almost 20 years to the day I served as an Operations Chief with a Type 2 Fire Use Team/IMT on the Dragon Complex which appears to have burned in much of the footprint of the current fire, and I know there have been successfully managed fires in this general are both before and after my experiences (and I suspect that many of them were in July). We should also keep in mind that many of the NPS staff working the fire lived at North Rim with their families, and were highly motivated to make accurate risk assessments and to take actions accordingly.

    This is a complex issue that predates my career and has still not been resolved because there is no common definition of success and there is wide variability in what people consider “acceptable risk”. Over the years many have argued that aggressive prescribed fire and/or mechanical treatment could solve the problem, but when do we admit that wishful thinking isn’t a realistic way to solve the problem? I hope the next generation of managers have more success.

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    • For decades, fire units have cared way-too-much about having “good burning conditions” when doing prescribed fire. Luckily, the USFS does consider fuel moisture and other weather conditions. However, the Park Service doesn’t care as much about hot temps and dry air. They expect and plan for actual tree mortality, as part of their plans. A ‘thinning’, so to speak.

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  8. Setting a new, clear goal for fire on federal public lands seems like a good place to start. I think there’ve been numerous reviews of MF and F over the years. Those can be helpful to changing course which, I believe is necessary and more difficult. Putting fire out as the overarching goal is not realistic or sustainable. Labeling fire response seems to enflame (pun intended) the conversation and I think, should be avoided. Many seem to think fire response is binary — Let it burn or put it out. We need to extinguish that thinking.

    Maybe a new goal — something like:
    Each fire on public land receives a strategic response that can and will be shared with the public. These responses to each ignition (human or otherwise) are based on landscape conditions, current and future risk, community interests and above all firefighter and public safety they also evolve over time as weather, landscape or other conditions (like resource availability) may change. Not all outcomes with fire can be predicted or controlled. Leveraging the best analytics and public engagement are key to informing chosen tactics.

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    • Jane, I think many of us do understand this and would generally agree with the new goal. I also think that it kind of implies that the current situation is fine and the fire community can be trusted to make decisions on its own (“shared with the public”) and improve procedures and practices on its own. It seems to me that there is much fertile ground for discussion between “put them all out” and “trust us to make decisions and improve, basically things are fine.”
      How about instead of “Not all outcomes with fire can be predicted or controlled.” “We are constantly improving our responses and using learning and advances in technology to improve predictions and to apply control effectively when needed?”

      Thanks for your comment, I will be reflecting on it and the others.

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      • I like your suggestion — “We are constantly improving our responses and using learning and advances in technology to improve predictions and to apply control effectively when needed”

        And, appreciate the forum for discussion. The broader conversation can inform that future mission and a National Wildfire Agency is an opportunity to not “do what we’ve always done” or go back to whatever we thought we were doing in the past.

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    • Jane: This is pulled from a 1977 Forest Service FACT sheet regarding the move away from the 10 am policy. I know the world has changed in the past 45 years, but…
      (happy to provide the entire document)

      Forest Service Fact Sheet 1978
      Key Facts – Revised Fire Management Policy
      •Every wildfire requires an appropriate suppression action. The revised policy does not allow for a weakened fire protection posture. The Forest Service will continue to take immediate action to control wildfires.
      •The initial attack policy has not changed. Fire suppression will continue to be fast, energetic, thorough, and conducted with a high degree of regard for personal safety.
      Through the policy revision,.-the Chief has replaced the very rigid direction, known as the 10 A.M. Control Policy, which has guided control of escaped fires since 1935. If a fire escapes initial attack, an escaped fire situation analysis will be made by the land manager. These situation analyses will include cost­ effective fire suppression alternatives and will serve as the basis for deciding which alternative to use.
      Fire protection and use programs will be planned to be cost­ effective and will provide protection for life and property, public safety, values, and natural resource management programs.
      The revised policy encourages land managers to make more use of prescription fire to protect, maintain, and enhance the natural· resource values and aesthetics within approved areas on the National Forest. ‘
      The revised policy requires that fire management planning be totally integrated into the Forest Service land management planning process. As an interim step, “fire management areas” will be established to provide for an orderly transition from the former fixed protection objectives to interim fire management objectives. · Until the fire management areas are established or the land management planning job is done on an area, current protection objectives and standards will remain in effect.
      In areas where natural resource conditions, such as wildlife habitat, can be improved by prescription fire and where plans have been approved for this purpose, the fire suppression action may be modified to meet these resource management objectives.

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  9. The 2001 Interagency Wildland Fire Management Policy covers much of what Sharon and others have been suggesting, but individual agencies started relying more on their own internal policies after 2001, and the interagency policy hasn’t been updated since then to reflect the lesson’s we should have learned. It will be interesting to see how those efforts will fare under the new Executive Order.

    We obviously need a better a way to involve the public in fire decisions, but I think it is important to realize that GRCA works under a Fire Management Plan and associated NEPA where the public was involved, and the Initial Attack Incident Commander or Duty Officer don’t have the capability of polling neighbors or politicians when deciding how to respond to a fast moving wildfire. Even if something better was developed, I find it difficult that people won’t suddenly change their minds in the event of an unwanted outcome.

    I’ve managed a lot of wildfires in my career, both on the ground and in a management capacity, and I have seen nothing to give me any hope that mechanical or prescribed fire treatments will significantly solve our fire management issues. Managing wildfires does offer our best chance of some success, but it is difficult to suggest that to others because it is very similar to playing Russian Roulette in our current social media, political, and legal environment. The best thing we could do to provide some support to those who are trying is call a wildfire a wildfire, and stop trying to differentiate into other management category types.

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    • John, it is seldom that I totally agree with something that someone writes on here, but I completely agree with you. I had forgotten about the GCNP’s Fire Management Plan and how they approach it differently from the FS. As I recall, they completed an EIS, and it took some time to do that. And, of course, there was the associated opportunity for public comment. Assuming that the Fire Management Plan is still in effect, it would have covered the Dragon Bravo fire. I also appreciate your comment, “I’ve managed a lot of wildfires in my career, both on the ground and in a management capacity, and I have seen nothing to give me any hope that mechanical or prescribed fire treatments will significantly solve our fire management issues.” I completely agree. However, this is considered to be heresy to those who believe that removing any impediment to timber sales will solve all of our problems. We need highly skilled, professional fire managers who know how and when to get fire benefits from a fire. Calling out scapegoats when something goes wrong can drive away good, talented people from fire management. The ones remaining are the ones who think it will never happen to them.

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      • Pretty much so Dave, but the Agencies have evolved into “checklist cowboys”, who really do not need to turned loose without verifiable experience. It happens with Line Officers as well as fire managers. The public will not stand for MF destroying infrastructure and taking lives, nor should they!

        The Lodge issue will boil down to “cascading errors – or bad judgement”, however it goes. I doubt the people of New Mexico will be as forgiving as those who have never been affected. Until we get a better handle on weeding out more of the unknowns, managers will need to tread very lightly….

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        • Jim, I don’t disagree that experience and training need to be ramped up. I don’t know how future line officers will get fire experience if this new fire organization actually happens. The militia may become a thing of the past. In order to develop excellent leaders and practitioners of wildland fire management, it will take a significant investment of time and dollars. But it really is a case of pay me now or pay me later. The military puts an enormous investment into training, as they should. Fire training and apprenticeship are not the place to skimp on dollars. While wildland fire training has improved over the last 20 or so years, it needs to be greatly improved if we want to prevent bad outcomes. 20-30 years ago, it was a given that line officers had come up through the system and had on-the-ground fire experience. I don’t think that it is the case any longer, and with the planned changes, it will get worse.

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    • At the risk of bringing the wrath of many people on my head..and I am not an aficionado of One Fire Agency, but it sounds like agencies got together and then drifted apart. It doesn’t sound like “drifting apart in their own inventions” in this case was necessarily a good thing. Because people don’t necessarily differentiate when things go bad.

      The 2001 Interagency Wildland Fire Management Policy covers much of what Sharon and others have been suggesting, but individual agencies started relying more on their own internal policies after 2001, and the interagency policy hasn’t been updated since then to reflect the lesson’s we should have learned.

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      • The Interagency Wildland Fire Management Policy documents were put together in a much simpler time (1995-2001) when the powers that be in DC largely stayed out of fire policy and allowed Agency Fire Directors try to find some consensus. Then fire management began to become more politicized and DC became much more involved in policy discussions. In many ways, I personally think the old interagency policy was simpler and better than what has evolved since. It’s possible that One Fire Agency might reverse that trend, but improbable given the politics and egos involved.

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      • There has been historical friction between the Agencies in places where National Parks and National Forests are adjacent. When a fire starts in the Park, managers have allowed those fires to grow, without suppression activities. When it reaches the Park/Forest boundary, it’s really cooking. I think leadership on both sides changes so quickly that those issues don’t always get addressed. It’s not practical to install cat lines adjacent to Park boundaries. In some places, there are unofficial ‘buffer zones’ along those boundaries. No visible stumps from inside the Park.

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  10. This will be the 28th thought on how I would organize some kind of programmatic inter-agency review of MF? Who would be involved? What questions to ask? What data to collect?

    I am the Pecos Ranger from the THW who described the shortfalls of the T3 IMT in The Smokey Wire post identifying the absence of an IMET. Arizona media is reporting that the resource order for an IMET was not placed until the 14th of July (https://www.azfamily.com/2025/07/13/historic-grand-canyon-lodge-destroyed-by-wildfire/). This means the Dragon Bravo IC3 was relying on daily weather forecasts beamed in over the “short-wave” from Flagstaff. Shameful for suppression operations and “contain & confine” too. Through human prowess many think the dragon can be controlled.

    The banner for this post is Arizona Governor Katie Hobbs who is demanding that there be a Federal investigation of Dragon Bravo. She wants to tag the Trumpster. But if it’s federal, see Jeffery Epstein. I take a different tact to tag the Trumpster. She should conduct the investigation herself to expose the Feds. Her State Forester – Tom Torres should lead it, having been the deputy forest supervisor of the Tonto, which burns saguaro cactus and Arizona cypress, in returning fire to “fire deprived” ecosystems. See Bush Fire May/June 2020.

    Friday, the Department of the Interior sternly cajoled the media that “confine & contain” is a full suppression strategy! “Now damn it, get it right!” said the memo to the media. Long live Big Brother and newspeak.

    Fire in all its forms has been partisanized. But it is not a D & R breakdown, it is through a corruption of understanding our governmental system and how it works.
    All Executive power comes from Congress. The Executive has no power to command managed fire or fire use without legislation passed by Congress and signed by the President. Notwithstanding the 209, there is a legislative requirement to suppress any wildfire as an emergency. This is clear in the annual Interior and Related Agencies Appropriations Act and the Organic Acts for both the Forest Service and the Park Service.

    The annual appropriations bills or continuing resolutions provide the legal requirement for forest fire presuppression, emergency wildland fire suppression and the emergency rehabilitation of burned over National Forest System lands and waters, Public Lands and waters, National Parks, Fish and Wildlife Refuges and Indian Reservations. The Appropriations Act does not state manage wildfire; it states and requires suppression which means to inhibit the growth of a wildfire and emergency means an urgent need for assistance or relief. When it comes to wildfire a “confine and contain” strategy is not legal, even on the Kaibab Plateau and the Grand Canyon National Park.

    For the Forest Service the Organic Administration Act is the controlling statute for the national forests and requires that the secretary “…shall make provisions for the protection against destruction by fire and depredations upon the public forests and forest reservations which may have been set aside, or which may be hereafter set aside under said Act of March third, eighteen hundred and ninety-one.” (16 U.S.C. §§ 473-478, 479-482 and 551).” The Organic Administration Act is supplemented and supported by the Multiple Use Sustained Yield Act and amended by the National Forest Management Act which is an amendment to the Resources Planning Act to further the conservation and multiple use mission of the Forest Service. Neither of the supporting acts authorize managed wildfire or controlled burning. Fire is not a multiple use. It is of dubious legal status that activity slash disposal through piling and burning or clear-cut unit activity slash disposal by broadcast burning is authorized under the Organic Act or the NFMA. And most clearly wildfire suppression is non-discretionary.

    The drafters of the Organic Administration Act were common sense 19th Century legislators. Few if any were professional politicians, rather they were citizen legislators who actually worked for a living. The drafters understood that the two most important out puts from a forest are a continuous supply of water and timber. Thus, the Organic Act was drafted to “improve and protect the forest,” particularly for maintaining favorable waterflows and a continuous supply of timber. Fire nullifies both legislative requirements.

    Indeed, the National Forest Management Act was enacted in the 94th Congress to amend the Resources Planning Act (93rd Congress) because the Isaac Walton League of West Virginia filed a complaint against the Secretary of Agriculture in 1973 under the Organic Administration Act of 1897.

    The Izaak Walton League filed suit versus the Secretary of Agriculture (Izaak Walton League v. Butz (367 F. Supp. 422 (1973)) over timber harvest clear-cutting of intermediate aged and sized trees in the Monongahela National Forest. Forest Service people know this as the “Monongahela Decision.” The specific challenge brought by the Izaak Walton League was that the Forest Service was in violation of the Organic Act of 1897’s discretionary provision authorizing timber harvesting because the trees that were offered for timber harvest were not dead, mature or large growth trees and that the trees offered for harvest were not marked and designated as required by the act as they were being clear-cut. The Organic Act required the Secretary subject to discretion to explicitly offer dead, mature or large growth trees that were individually marked, appraised and sold at a high bid auction. The Organic Act did not authorize clear-cutting. From the act: “For the purpose of preserving the living and growing timber and promoting the younger growth on forest reservations, the Secretary of the Interior (Agriculture), under such rules and regulations as he shall prescribe, may cause to be designated and appraised so much of the dead, matured, or large growth of trees found upon such forest reservations as may be compatible with the utilization of the forests thereon, and may sell the same for not less than the appraised value in such quantities to each purchaser as he shall prescribe, to be used in the State or Territory in which such timber reservation may be situated, respectively, but not for export therefrom.”

    The United States District Court Northern District West Virginia in Izaak Walton v, Butz found that the Secretary acting through the Forest Service had violated the Organic Administration Act of 1897 in the sale and harvesting of national forest trees that did not meet the Congressionally authorized manner of harvesting and the character of trees that the Secretary may harvest and that the trees made available for harvest were not marked and designated as such.

    The Court in part ordered that “Defendants, their agents, officers, servants, employees, attorneys and all in concert therewith be, and they are hereby permanently enjoined from directly or indirectly, in the contracting for timber sales, under the authority of the Organic Act of 1897…”
    The nationwide Federal District Court injunction applied to the Forest Service timber sale program and was only lifted by the enactment of the National Forest Management Act, which among other things repealed and replaced the 1897 Organic Act’s requirement that timber sales be comprised of individually selected (marked) trees that were dead, mature or large growth trees as described above. The NFMA legalized clear cutting.

    For the Park Service, the Organic Administration Act (P. L. 64 – 235) (G:\COMP\PARKS\NATIONAL PARK SERVICE ORGANIC ACT.XML) is silent on fire, meaning it is not mentioned at all and therefore not authorized. Ironically though in section 3 of the Act, it allows the Director to conduct timber sales in all lands under his jurisdiction and graze livestock in all parks, monuments and other holdings, except Yellowstone. Who knew?

    In 2002, serving with the Dixie National Forest, I was involved with the Sanford Burn (https://www.fs.usda.gov/rm/pubs_journals/2003/rmrs_2003_conroy_s001.pdf) on the Markagunt Plateau. At the time the largest escaped “controlled” burn for the Federal Government. Only two years out from the infamous Cerro Grande Fire where the Park Service burned down the Los Alamos Nuclear Lab, the Sanford Burn exceeded the Cerro Grande by 28,000 acres but fortunately did not release any plutonium. The forest supervisor went on to retire as associate chief, the forest fire staff received a plum assignment with the Fish & Wildlife Service and the district FMO promoted to a service first wildland fire position that covered nearly 1/3rd of Utah between the Forest Service and the BLM. The district ranger was “thrown under the bus” and the residents of Garfield County Utah were left to pick up the pieces.

    The Dragon Bravo wildfire is similar to the Pole Creek Fire/Bald Mountain Fire brought to the public by the Wasatch-Cache-Uinta National Forest. The Uinta forest plan illegally allowed for natural ignitions to burn on a green colored forest plan map. The red colored forest plan map required suppression. Pole Creek and Bald Mountain being in the green zone were given maximum management areas within which to “restore ecological processes.” The Forest Service using the admonishment to add copious amounts of fire did so, until the weather changed to days-on-end of red flag weather for high wind and low humidity. The fires combined and burned tens of thousands of acres of private land and causing millions of dollars of post fire flooding to the infrastructure of the Strawberry Water Users Association. Both US 89 and US 6 over Soldier Summit, the major Utah connector to I70 were closed for weeks.

    The North Fire Complex of 2020 burned 318,000 acres including Camp Okizu a children’s oncology retreat in the Sierras. Sixteen people were killed largely due to cavalier firing operations.

    The HP/CC review of 2022 was a JOKE. The forest supervisor Debbie Cress was promoted twice by Randy Moore (former Chief) within in two years of her debacle. She is now the Deputy Regional Forester in Alaska, after serving as the Agency’s deputy chief of staff, her promotional reward after immolating Northern New Mexico. Moore was the keynote speaker at the California Forestry Association Forest Strategies and Innovation conference in late February 2024. In his opening remarks, he claimed the “New Mexico fires (Hermits Peak/Calf Canyon and Cerro Pelado) …were snowed on twice and rained on once…” and it was “global warming” that caused the largest fire in New Mexico’s history. I was possibly the only person in room to understand that he was absolving his agency from the $5.5 billion disaster that his outlaw fire policies caused. The USG fire program is an abuse of power. MF is an outlaw program!

    Now the Laguna Fire – cattle burned alive, private property damaged and burned with no legal authority to restore “ecological process” whatever that is? Now the Rio Arriba County town of Gallina and its watershed are being toasted in the Don Quixote quest for the “ecological process.” The Sant Fe NF forest supervisor Sean Sanchez is not satisfied that the Gallinas Watershed (Las Vegas, New Mexico) is already toast, so he is pursuing to restore “ecological process” across the land grant land of Northern New Mexico.

    So back to the questions posed by Sharon. How would you organize some kind of programmatic inter-agency review of MF? Who would be involved? What questions would you ask? What data would you collect?

    I would hold House and Senate oversight hearings, then legislative hearings, with the intent on passing meaningful reforms and preclude controlled burns, fire use, managed/unmanaged fire and all of the fire and aviation management newspeak. Full suppression would be the legal outcome. This review is beyond the inter-agency and commission world and is Congress redeeming its Article I role in our government. That is because the Executive’s outlaw use of fire rather than suppression is a “major questions” issue as defined by the Supreme Court in WV v EPA (597 U.S. 697 (2022).

    I would hold Cabinet Officers, sub-Cabinet Officers, political appointees and Senior Executives accountable through oversight and financial penalties. I would reform the Federal Tort Claim Act by narrowing the Discretionary Function Exemption where it would not apply to the Land Management Agencies if their fire use trespassed upon private property, whether damaging or not and hold agency administrators and incident commanders personally and financially liable for private property damage restitution including indictment and arrest by local and state law enforcement for property destruction, vandalism and trespass fire and homicide, if deaths occurred. Second, I would require through legislation the forfeiture to the injured private land-owning parties land from the National Forest System, National Park System, Public Land, Refuge System at three acres for every acre of private land affected by the Agencies use of an uncontrollable physical force – fire. If an agency can demonstrate that their fire was under the legally required direct suppression as required in both authorization and appropriations legislation, then those sanctions would not apply. The findings of such a review would be scrutinized and approved by the Four Corner Committees (Senate Agriculture, Senate Appropriations, House Committee on Agriculture and House Appropriations Committee).

    The precedence of land forfeiture is already in effect where Sierra Pacific Industries was compelled in a settlement to forfeit 22,500-acres to the Forest Service. But I do know that land forfeiture will get the Feds attention. Harsh as this sounds, land forfeiture is a mild sanction compared to the impact the out-of-control Federal fire response has on the people of the communities and their property.

    Reply
    • “The drafters understood that the two most important out puts from a forest are a continuous supply of water and timber.”

      As and uneducated reader of this website, but 70-years of living in the same forest from the days of 1950’s clear-cuts through the aftermath of “roadless”, thank you Mr. Reddon for historical renditions of original legislation long dismissed and/or watered-down. Sadly, a majority of Americans are far removed from the lands they covet to visit, and animals they love, to witness the dramatic change.

      Your reminders and possible solutions to conundrums generational rural families (associated with land grants and otherwise) living west of the 100th have found themselves in since the Outfit was re-organized are most welcome to read.

      Cause and effect of 21st Century Interim “surplus” discussions of the Upper and Lower states in the Colorado River System is as good example of any, of the difference between many of today’s politicians and, ” The drafters of the Organic Administration Act [who] were common sense 19th Century legislators. Few if any were professional politicians, rather they were citizen legislators who actually worked for a living.”

      Reply

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