Thanks to all who participated in the previous managed fire discussions! If you haven’t read all the comments (some came in over the weekend) please take a look.
Folks are still talking about One Fire Agency even though House Appropriations seems to have a distaste for it. It’s a good sign but perhaps not the end of the road for people who don’t want it. We’ll keep you posted.
I’d like to try to draw out some potential zones of agreement, and some areas that haven’t been brought up yet.
1. Some people say “we will never get to where “we need to be” without MF.” I’m not so sure of that framing (have we really discussed “where we need to be”? Perhaps no combo of PF MF and MT will ever get us there, since we haven’t clarified where “there” is (and it’s possible that we don’t all agree).
I would go with “we need to keep all the tools in the toolkit.” Pragmatically, I’m not sure that it makes any difference. But that makes many of us “keep and improve” rather than “stop.” We actually don’t know how many folks out there (nor just here on TSW) are “stop entirely.” Are most of us here mostly variants of “keep and improve?” Is this like climate change, where most of the oxygen in the room is taken up by “believers” and “unbelievers” and there’s no space left for “let’s talk about what to do about it?” and “how can we make this work better for everyone?”.
2. Folks mentioned MF in the GCNP plan; I know the GMUG has a fire use plan amendment; I heard that some newer plans (Inyo?) incorporated fire use. The Santa Fe also has based on the news story about the Laguna Fire. Shouldn’t there be a more or less consistent approach?
3. Even without a new fire agency, some members of the public are going to paint all agencies with the same brush when things go wrong. Do the FS, BLM, USFWS, NPS, DOD have consistent approaches to planning for MF? Should they? Given their different missions, conceivably they could still do some kind of NEPA, and involve the public to lay some groundwork for the inevitable lightning strike.
4. There is talk of “blaming doesn’t help”. Of course, the wildfire organization is famous for being a learning organization. Are there ways we can broaden this to becoming more of a “learning society”? How do we balance accountability, learning, and keeping good people?
5. Some would argue that when litigation and money enter the discussion, learning becomes more difficult or goes out the window. I hope TSW folks in the legal world know of some ways to surmount this.
6. Same thing with partisan politics. Historic winds were caused by climate change..better decisions would have been made except the good decision-makers took early outs. Of course, if climate change causes historic winds, then maybe folks should be more careful with MF…
It’s interesting that both 5 and 6 (try to) take everyone’s eye off the ball of of “improving practices.” And the voices of practitioners- the only people who can fix it- are not heard except in service to various positions or narratives.
7. It seems to me that many of the escapes happen when the weather changes unexpectedly. Conceivably, that is one scenario that the team is considering. What if strong winds come up? From what direction are they likely to come up? Technology to detect and predict changes (as well as putting them out) will only get better over time. Maybe more resources need to be stationed and ready to go to- maybe held to support MFs? Certainly part of that is not having MF’s when other resources are drained, but maybe there are other ways of organizing resources as backup.
8. Perhaps the fact that the lodge has gotten so much attention has distracted us from other people, livestock and wildlife that can be hurt by uncontrolled wildfires. Structural protection only does so much. Only so many critters can get out of the way fast enough.
9. Second order effects of MF escapes (or possibly monitoring). If resources are tied up (either in monitoring or suppressing escapes) then they aren’t available for “real” wildfires, which could lead to more damage on those acres.
10. Costs and benefits. We hear that MF is cheaper than PF and MT, and no doubt it is, in some cases. Then there’s the environment. There’s more smoke potentially (for months) and possibly the use of more fire retardant, and more carbon released? I’m not sure we really know (and I’m not sure costs are considered in deciding 5K acre box vs. 15K acre box). See the SNF list of considerations below.
Now some here at TSW say “escapes happen but they’re necessary.” So if we were going to follow that line of thinking, we would analyze alternative ways of (doing what exactly, restoring all acres to historic conditions or managing for resource and community protection?) including MT PF, MT plus PF, MF and all possible combinations, I guess, and select a percentage for escapes and calculate the impacts.
And if that seems unduly esoteric, welcome to what I call “NEPA for might could” as in forest planning and Roadless, which is not analyzing actual projects, but analyzing what projects might happen under various scenarios.
The problem with these kinds of analyses is that people and organizations usually have predilections, and depending on what they consider and what values they assume.. they tend to get answers favoring their predilection. So these analyses don’t really solve any problems. Plus they can get held up in court making the agency reanalyze, when we all know that they are made-up numbers in “NEPA for might-could.” If the problem is escapes, which I think it is, the answer is to reduce the risk of escapes and all this other stuff is more or less a distraction.
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Two more stories of interest:
These appear to be from intentionally set backburns and according to the Santa Fe, the plan to MF 13K acres was in their forest plan and the result of collaboration. According to the SF, they did communicate with permittees about their plans.
Here’s their process:
As required by our Santa Fe National Forest Land Management Plan, when a natural ignition occurs, specifically, a wildfire caused by lightning, our SFNF team analyzes various fire management strategies. The decision-making process involves assessing risks to people and property, current weather conditions and forecasts, existing drought conditions, firefighter health and safety, and the methods available for safely engaging with and fighting the fire. We also consider the potential smoke impacts on communities and the duration of those effects, as well as impacts on grazing allotments, wildlife habitats and species, timber, and watersheds. After collaborating with federal, state, and local leaders, as well as Land Grants, Tribes, permittees, and community members, the SFNF identified a planned perimeter of 13,000 acres around the lightning-caused wildfire. Our primary objectives were to prioritize the safety of firefighters and the public, while also protecting water quality in watersheds, water systems, and springs by minimizing fire intensity and the potential for severe fire effects.
This is interesting because that’s a lot of collaborating, and other folks are saying that there isn’t enough time after an ignition to do that kind of collaboration. But the whole story is interesting.
8. Some Retired Fire Folks on Dragon Bravo:
“This ongoing fire has displaced over 250 NPS employees and an additional 230 private concessions staff from their homes and continues to pose a devastating ecological and economic burden on the State of Arizona,” Gosar wrote to Interior Secretary Doug Burgum. “Who made the decision to treat the Dragon Bravo Wildfire as a controlled burn versus deploying the assets to immediately extinguish it?”
A retired U.S. Forest Service official familiar with the terrain of the North Rim tells 12News an investigation should determine who made those decisions.
“I’m disturbed why the park would make a management decision to allow it to burn. Normally you wouldn’t let a fire burn in late June and early July in a region with a history of fires escaping,” said Jim Page, who managed wildfires as an officer in other forests during his career. “You also have to consider how many fires were burning in the western United States and how many air tankers were committed elsewhere at the time.”
The National Park Service said human life and safety were the priority, and no lives were lost.
I’m sure this person didn’t mean that the way it sounds.. “it worked the way we wanted, we just have different priorities..”
“Firefighters had constructed containment lines and were prepared to conduct a defensive firing operation before conditions rapidly changed,” said NPS spokesperson Rachel Pawlitz in a written statement Tuesday. “The winds shifted unexpectedly during the firefight, pushing historic wind gusts.”
I recommend taking a look at this video, starting at about the 30-minute mark. Zeke discusses the FSPro model managers used prior to managing it for resource benefits, which suggested there was a 0.2 percent chance the fire would have reached the lodge. https://the-lookout.org/2025/07/15/norcal-fire-effects-and-the-grand-canyon-fiasco-7-15-2025/
Zeke also points out that the lodge and its neighboring cabins failed Firewise 101.
Thanks for linking to this! And thanks for telling us where exactly to look on the video.
It’s interesting how we work with models. Doing 200 runs with the same parameters or whatever. Maybe a different approach would be “what could we do if the following things happened even if they’re rare?” and work backwards to a strategy that is robust to a wide variety of potential scenarios. I’d ask local experienced fire folks for “what are the unexpected things that could happen” and work backwards from there. Not to get rid of other kinds of modeling, but as an approach to compare.
The loss of the North Rim Lodge in a wildfire the was in Managed Fire Use was preventable and no less than a travesty. Theoretical policies and decision by those who either are not qualified or do not listen to qualified staff…those folks should be removed. Prescribed Fire has a legitimate place in management of OUR natural resources, as does Managed Fire Use. Both should be limited by analysis of fuels, topography, fire weather forecasts, availability of suppression resources and legitimate plans for suppression action if the fire exceeds the prescription and move past trigger boundaries. This loss was not a learning experience! It was a failure of both management and leadership. I maintain that we cannot achieve forest and wildland health by arbitrarily allowing wildfires to burn unabated!
Historic winds? I laugh at even the mention; Wallow had days of 70 mph winds. Springerville airport normally has winds in excess of 100 mph gusts. This is the Southwest, in May, June and early July, don’t pee down my leg and say it is raining….
As for MF, if the consequences of escape are seemingly happening more often, plan for the effect! MF plans should address loss of private property, loss of life, etc! If that’s an outcome (and it is) plan for it! Then, I want to shake hands with that Line Officers that approves such plan; he, or she is about to be toast!!!!!
I will comment on the “zones of agreement” presented by TSW, with the usual caveat that I am not an expert. I will address each of the 10 points:
1. “Where we need to be”. Neither agency performance measures nor the GAO are asking that question. The agencies could take a WAG at it, but it is fraught with issues and is dynamic from year to year. Instead, the feds have all embraced the National Cohesive Wildland Fire Management Strategy (which has not been rescinded or discarded) with three goals:
Resilient Landscapes
Fire Adapted Communities
Safe and Effective Wildfire Response
Vision: To safely and effectively extinguish fire when needed; use fire where allowable; manage our natural resources; and as a nation, to live with wildland fire.
I support MF, especially in wilderness. However, whether wilderness or non-wilderness, it is all about quantifying “benefits” or objectives; and after the fire, monitor to determine if the objective were met. Many land and fire management plans only loosely define those objectives….such as “let fire play it’s natural role” (even if there has been 100+ years of fire suppression). We can do better, if you know what I mean.
Lastly, I suggest that federal fire policy be reviewed (again) and clarified/updated. The current policy (Guidance for Implementation….) was launched in 2009…after a few prior versions went down in flames.
2. Consistent approach? The feds do have a (mostly) consistent approach, essentially using their local plan (that is based on the 2009 fed fire policy and related policies), as well as NextGen WFDSS to develop the strategy and course of action for each incident However, this is an area of needed improvement and education. I will also add that (currently) the NPS will allow human-caused wildfires to be managed for resource objectives, IF “the initial action is not successful and an updated decision is made to manage the fire, that decision will be documented as part of the official record. The updated strategy will be commensurate with firefighter and public safety, risk management, and values to be protected, with consideration for cost efficiency”. This is not the policy of the FS.
3. Consistent approaches in planning for MF? Yes, but loosely consistent. All currently require NEPA, but approaches vary. I will add that PODs are FS policy requirement, but not DOI Policy requirement. There are other emerging tools that (ISAP, RMA) that have mixed acceptance and capacity by the federal agencies.
4. Good question about “balance accountability, learning, and keeping good people”. We have a structure in place for lessons learned and incident reviews. We can probably all agree that we could and should do better with that information.
5. I do not offer any observation on the role of litigation and money, other than it will be with us forever.
6. Agree with TSW on partisan politics and expect we will be dealing with this topic in the future.
7. Point of clarification…feds do not declare an “escape” of a MF. They just develop a new decision in WFDSS. Escape is used only for Rx Fire.
That being said, the level of detail and sophistication that is used during the management and suppression of wildfires varies significantly, as it should. Those who have worked with IMTs are familiar with PACE; Primary, Alternate, Contingency, and Emergency for fire containment. Something like this might need to be defined for MF. When there were a handful of Wildland Fire Management Teams (Type 2 command and general staff with LTAN, SOPL, and others) there has been a wide range of approaches. WFDSS wasn’t the preferred “go-to” tool (just a formality), so most of those teams developed Long-Term Implementation Plans and related sorts of documents. It might be time to revisit this, in coordination with the NextGen WFDSS folks at WFMRDA.
8. A consistent approach to identifying and protecting HVRA is essential for any response and strategy for a wildfire.
9. Remember that there is currently no use of the term “escape” for MF. They just develop a new decision in WFDSS. Escape is used only for Rx Fire. The issue of resource allocation from incident to incident, draw-down, preparedness, and related is complex and in theory, dealt with at the local and GACC level.
10. The cost question seems to be frequently mentioned. However, when it comes to firefighter and public safety (life or death) is cost an issue? I remember once a high-ranking FS official (Regional FMO) told me once that the FS “practically had a gag-order” on cost-containment issues. Yes, cost accountability is important. But I do not believe there is any economic model in-place that accurate describes the “return on investment” for Rx Fire or wildfire. Not sure we (feds) would want to take that on.
Thanks for this thoughtful reply.. two questions and a concern.
Concern:
I want MF to be accepted and I want management to get better, and I think not being able to use the word “escape” nor to track them (apparently very easily) is helpful to building public trust. To me, to the extent that MF has aspects of PF, if they have planned a box and it goes outside the box, there needs to be a word for that… It’s kind of like when I was told not to use the term managed fire because “all fires are managed.” My recollection is that the Wildfire Commission talked about lumping PF and MF under “beneficial fire.” It seems to me that all this word-shifting does little to clarify anything. Now I know that Fire Folks have many acronyms.. and that’s a necessary part of the work- but when you’re trying to communicate with the public on sensitive issues maybe being more clear would help.
If for MF folks can just shift boxes and make a new decision.. maybe PF folks should be able to do that also? Then there’s never going to be an escape. What’s the value in making PF and MF more consistent when possible?
Questions:
2.
See, that’s the idea (perhaps inaccurately) I got from the Coconino.. that they had more or less of a prescription in mind for each acre.. Now I don’t know if that level of detail was in the forest plan (nor could it be because conditions change.. like fires..). But like you said, it should be more specific than “fires are good” or “any burning reduces fuels” or even “all the big trees shouldn’t die.” So there seems to be an intermediate layer of decision making that happens about benefits and achieving those or not could be a part of monitoring (is there a post-MF monitoring report?).
for the NPS
“I will also add that (currently) the NPS will allow human-caused wildfires to be managed for resource objectives, IF “the initial action is not successful and an updated decision is made to manage the fire, that decision will be documented as part of the official record.”
Are you saying that one of all these agencies (but not others) have a policy to have MF from human-caused ignitions?
Also what does it mean if “the initial action is not successful”? “We tried to put it out but couldn’t?”
3. “All currently require NEPA, but approaches vary.” I’m kind of surprised that none of the vast knowledge infrastructure in the Forest/NEPA world has been directed at comparing the approaches to MF across forests and agencies. For a reasonable sum of money, I’d be willing to do it and maybe it could be a training opportunity for new NEPA folks.
The “newspeak” is managed fire (mf) Big Brother is proud! No human can manage fire successfully over time. The weather systems are in control and dominate the puny humans with their hubris capes.
But all of this MF is not authorized or appropriated under the system of laws. Organic Acts do not authorize MF and appropriations law labels wildfire an emergency and requires suppression.
I’m not sure what language you are referring to in the Forest Service Organic Act, but “protecting” the forest may mean letting it burn at some times and places.
Yes John – – that is the Viet Nam Conflict interpretation of the Organic Act where the general receiving report from the colonel says; “son how did you do today? And the colonel responded; “sir in order to save the village, I had to destroy it!”
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.!
If this was winning argument I would expect it to have been raised in some of the lawsuits for damages to private property – that the managed or prescribed fire was not authorized – illegal. But I would have no trouble arguing that the best available science shows that “destruction” by fire can be prevented by good fire.
There is only fire and science is not law.
The science argument was used by the United States in Isaak Walton v Butz, where Isaak Walton sued the Forest Service over illegal at the time clear cutting of trees, under the Organic Administration Act in the Monongahela NF. A Nationwide injunction followed. The injunction was lifted when the National Forest Management Act amended the Organic Administration Act and made clear cutting legal.
The science argument put forward by the United States was that science and economics had advanced and the practice was adopted, by the agency in keeping up with the “best available science.” The Court wasn’t buying that argument and admonished the government about the Organic Act’s plain language that prevailed in the Courts review of the act and the actions by the Forest Service.
As for a winning legal argument, we will see…
The Organic Act had specific limitations on timber removal, and I don’t think there is a counterpart that restricts fire management. From the Monongahela case:
Turning to that part of Section 476 which requires that the timber “before being sold, shall be marked and designated”, we find the statutory language to be simple and unambiguous. The term “marked” in the context of forestry is well defined and means “selection and indication by a blaze, paint * * * or marking hammer on the stem of trees to be felled or retained”.[9] “Designate”, on the other hand, is a much broader term and merely means to “indicate”.[10] The two words are not synonymous or interchangeable and in using them conjunctively it is evident that Congress intended that the Forest Service designate the area from which the timber was to be sold and, additionally, placed upon the Service the obligation to mark each individual tree which was authorized to be cut.
“The Organic Act had specific limitations on timber removal” which the Forest Service did not follow, because it was clear cutting and shelterwood cutting without marking each tree for harvest.
Just as the court found in Isaak Walton v Butz “the statutory language to be simple and unambiguous” so too is the statute’s requirement upon the Secretary [who] “SHALL make provisions for the protection against destruction by fire and depredations upon the public forests and forest reservations…”
As agreed, the statutory language is clear, simple and unambiguous. Shall is a mandatory action, a requirement meaning the Secretary is required to suppress fire as a form of protection. Protection in legislation means to shield from harm or to preserve something and in the case of this act it is the preservation of forests from fire and depredations. Depredations means pillaging, robbing, plundering which happened all too frequently to the timber of the forest reserves.
The drafters of the Act reasoned that fire and depredation (timber theft) were impacts on the purpose of forest reserve establishment. “No public forest reservation shall be established, except to improve and protect the forest within the reservation, or for the purpose of securing favorable conditions of water flows, and to furnish a continuous supply of timber for the use and necessities of citizens of the United States;…”
Wildfire and timber theft were seen by the Congress as bearing upon the improvement and protection, water quality and quantity consequences and a diminution of the continuous supply of timber envisioned by the Act.
This is important because the drafters of the Act in non-discretionary terms made this provision in the third paragraph which sets out the regulations for managing and protecting the nascent forest reserves.
Therefore, fire suppression is required and its use as a management action – is a tool which compromises the legislative intent and statutory controls of the Organic Act.
I think here is where your logic is weak – “Shall is a mandatory action, a requirement meaning the Secretary is required to suppress fire as a form of protection.” I think “shall make provisions” actually leaves the details on how to protect the forests up to the agency. But feel free to find yourself a court to tell you what it thinks.
1. “Where we need to be.” Do you mean something other than forest plan desired conditions? And getting away from stating those as generic platitudes to instead describing actual conditions on the ground would seem especially helpful here.
I think when fire folks talk about “where we need to me” they are not talking about forest plan DCs. I think some people want to reduce “the fire deficit” generically.
Sharon. Folks review. 1988 Yellow Stone Fire recomendations as they are foundational in any approach. Secondly. Where”s is analysis of area burned vs area reforestation as the Intermountain area is the only USA region where forests are net emitters not in a carbon storage status.