Andy brought up the long-term problematic question of fuels reporting, the old double-counting question and so on. I thought I’d post what’s in FOFA as I think that will take care of it. Perhaps this is the first entry in the Peoples’ Database, provided by Congress, who like us, would like to see where the bucks are going. I’m curious as to what folks think of this approach. Any formatting issues are mine, if you want the original formatting check out Sec.302 of FOFA.
It kind of makes me wonder why Int and Ag didn’t self-organize to do something like this on their own. Rather than moving the FS to Interior, I think much more doable would be to identify the top 20 interdepartmental annoyances and coordinate them, similar to what the Admin is doing in wildfire.
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(a) Definitions.—In this section:
(1) FEDERAL LAND.—The term “Federal land” means any land under the jurisdiction of—
(A) the Secretary; or
(B) the Secretary of the Interior.
(2) HAZARDOUS FUELS REDUCTION ACTIVITY.—
(A) IN GENERAL.—The term “hazardous fuels reduction activity” means any vegetation management activity to reduce the risk of wildfire, including mechanical treatments, grazing, and prescribed burning.
(B) EXCLUSION.—The term “hazardous fuels reduction activity” does not include the provision or execution of a contract to carry out an activity described in subparagraph (A).
(b) Materials submitted in support of President’s budget.—
(1) IN GENERAL.—Beginning with the first fiscal year that begins after the date of enactment of this Act, and annually thereafter, the Secretary concerned shall include in the materials submitted to Congress in support of the President’s budget pursuant to section 1105 of title 31, United States Code, a report describing the number of acres of Federal land on which the Secretary concerned carried out hazardous fuels reduction activities during the preceding fiscal year, as determined using—
(A) the methodology of the Secretary concerned in effect on the day before the date of enactment of this Act; and
(B) the methodology described in paragraph (2).
(2) REQUIREMENTS.—For purposes of a report required under paragraph (1), the Secretary concerned shall—
(A) in determining the number of acres of Federal land on which the Secretary concerned carried out hazardous fuels reduction activities during the period covered by the report—
(i) record acres of Federal land on which hazardous fuels reduction activities were completed during that period; and
(ii) record each acre described in clause (i) once in the report, regardless of whether multiple hazardous fuels reduction activities were carried out on that acre during the applicable period; and
(B) with respect to the acres of Federal land recorded in the report, include information relating to—
(i) which acres are located in the wildland-urban interface;
(ii) the level of wildfire risk (high, moderate, or low) of the acres on the first and last day of the period covered by the report;
(iii) the types of hazardous fuels reduction activities completed with respect to the acres, including a description of whether those hazardous fuels reduction activities were conducted—
(I) in a wildfire managed for resource benefits; or
(II) through a planned hazardous fuels reduction project;
(iv) the cost per-acre of the hazardous fuels reduction activities carried out during the period covered by the report;
(v) the region or System unit in which the acres are located; and
(vi) the effectiveness of the hazardous fuels reduction activities with respect to reducing the risk of wildfire.
(3) TRANSPARENCY.—The Secretary concerned shall make each report submitted under paragraph (1) publicly available on the website of the Department of Agriculture or the Department of the Interior, as applicable.
(c) Accurate data collection.—
(1) IN GENERAL.—Not later than 90 days after the date of enactment of this Act, the Secretary concerned shall implement standardized procedures for tracking data relating to hazardous fuels reduction activities carried out by the Secretary concerned.
(2) ELEMENTS.—The standardized procedures required under paragraph (1) shall include—
(A) regular, standardized data reviews of the accuracy and timely input of data used to track hazardous fuels reduction activities;
(B) verification methods that validate whether those data accurately correlate to the hazardous fuels reduction activities carried out by the Secretary concerned;
(C) an analysis of the short- and long-term effectiveness of the hazardous fuels reduction activities on reducing the risk of wildfire; and
(D) for hazardous fuels reduction activities that occur partially within the wildland-urban interface, methods to distinguish which acres are located within the wildland-urban interface and which acres are located outside the wildland-urban interface.
(3) REPORT.—Not later than 14 days after implementing the standardized procedures required under paragraph (1), the Secretary concerned shall submit to Congress a report that describes—
(A) the standardized procedures; and
(B) any programmatic or policy recommendations to Congress to address limitations in tracking data relating to hazardous fuels reduction activities under this subsection.
(d) GAO study.—Not later than 2 years after the date of enactment of this Act, the Comptroller General of the United States shall—
(1) conduct a study regarding the implementation of this section, including any limitations with respect to—
(A) reporting hazardous fuels reduction activities under subsection (b); or
(B) tracking data relating to hazardous fuels reduction activities under subsection (c); and
(2) submit to Congress a report that describes the results of the study under paragraph (1).
(e) No additional funds authorized.—
(1) IN GENERAL.—No additional funds are authorized to carry out this section.
(2) SUBJECT TO APPROPRIATIONS.—The activities authorized by this section are subject to the availability of appropriations made in advance for those purposes.
Sharon said:
“It kind of makes me wonder why Int and Ag didn’t self-organize to do something like this on their own.”
I’m guessing the answer is money. The agencies tend to resist gathering new data, or gathering itin different ways, unless they have a very clear and direct need for it. This is because these activities cost money that the agencies would have to shift from other activities, which in turn could alienate the citizens who benefit from those activities (and therefore, at least potentially, their congressional representatives). This is also why the agencies tend not to ask for additional funds to carry out such activities; they believe (reasonably, in my view) that Congress might simply take that money from programs and acitivities that are higher agency priorities.
Note the language of subsection (e). This is probably there at the agencies’ request, so they can say to Congress “sure we’ll be happy to do this if you provide the funding,” while also being able to say to any aggrieved members of the public whose favorite programs are cut “blame the Hill, not us.”
It will be interesting to see if Congress does in fact fund these activities. This data, properly assembled, could go a long way toward overcoming OMB’s traditional objections to authorizing agency budget requests for increased hazardous fuel reduction funding.
Sharon also said:
“Rather than moving the FS to Interior, I think much more doable would be to identify the top 20 interdepartmental annoyances and coordinate them, similar to what the Admin is doing in wildfire.”
Couldn’t agree more!
Well, the FS did come up with this more analytical and complicated way to track accomplishments, which conceivably would cost more $.. https://forestpolicypub.com/2024/03/01/outcome-based-performance-measures-report-2020/
Which of course, might make a person wonder whether BLM and the FS, both being multiple use agencies under the same Approps committee, might want to work together to come up with the same measures?
You might also want to share a link to the House version of the bill (HR 471), as there are some nuanced differences between the two bills.
One difference that just out is under Requirements Sec. 2, B(iii)(II) – the Senate version is “through a planned hazardous fuels reduction project”. The House version is more broad “through a planned project:”.
Great idea, maybe someone will do a side by side.
How do you report out on “the effectiveness of the hazardous fuels reduction activities on reducing the risk of wildfire.”
If no wildfire passes through the treatment area, does that mean it treatment was effective!? If an extreme weather event creates a extreme fire situation and the fire torches out the treatment area, does that mean it was ineffective? How many years following treatment must the FS assess for ‘effectiveness’, until the next treatment, 5 years, 10 years, 1 year?
I think this needs to be removed from both versions of the bill. The evaluation of this metric is too subjective and ambiguous.
A, I’m glad you brought this up. I think there’s a great deal of confusion about what Congress and others are funding in terms of “treatment evaluation of success and feedback to the fuels community,” vs. simply “telling Congress what agencies did with the funds on the ground.”
As far as I can tell, Congress is already funding SWERI in the BIL via the TWIG project https://cfri.colostate.edu/2024/07/24/sweri-reshape-project/
“The Southwest Ecological Restoration Institutes (SWERI) were identified in the BIL to undertake a national wildfire and treatment effectiveness mapping and assessment project. Policymakers, land management agencies and the research community identified the following needs:
(1) To compile and display existing information on fuels treatment projects and wildfires at the national level.
(2) To coordinate and facilitate the use of these data for assessing planning and monitoring fuel treatment interactions with wildfires across boundaries.
(3) To analyze and report on fuel treatment effects.
https://reshapewildfire.org/twig/layers”
I agree that if the point of agency reporting is to tell Congress what it did with the bucks, anything more abstractifying, calculational, and subjective just muddies the water.
This is precisely the issue that OMB hones in on every fiscal year. It is why administrations of both parties routinely underfund (imho) fuel reduction activities. In the aggregate, a dollar spent on fuel reduction might well yield $10 in avoided costs. But the specific treatments that yield most of those benefits cannot be known in advance, so OMB throttles the funding requests for those activities. The federal budget development process is set up to be penny wise and pound foolish, and nowhere is this more apparent than in fire management.
I yield to none in my criticism of the current Congress. But this issue has much deeper roots.
“methods to distinguish which acres are located within the wildland-urban interface”
I’m kind of puzzled that they don’t seem to know where the WUI is. Such a fundamental land management decision that affects future projects should already be Identified and should be in forest plans, ideally based on standardized criteria. But dream on.
I’m also curious about how incentives for management would change if they can no longer count each treatment – will they deprioritize burning areas they’ve thinned, which I’ve understood is important for the thinning to be effective.
That’s a very interesting question .. is there a standard def for WUI? I think there was one in HFRA maybe.. Is it mapped? How does it show up in Forest Plans?
I would think they couldn’t count acres as accomplished unless the burning was done, which makes sense as if fuels are laying around you just have the same fuel redistributed and possibly drier
Fri9n HFRA 2003:
(16) WILDLAND-URBAN INTERFACE.—The term ‘‘wildland- urban interface’’ means— (A) an area within or adjacent to an at-risk community that is identified in recommendations to the Secretary in a community wildfire protection plan; or (B) in the case of any area for which a community wildfire protection plan is not in effect— (i) an area extending 1⁄2-mile from the boundary of an at-risk community; (ii) an area within 11⁄2 miles of the boundary of an at-risk community, including any land that— (I) has a sustained steep slope that creates the potential for wildfire behavior endangering the at-risk community; (II) has a geographic feature that aids in creating an effective fire break, such as a road or ridge top; or (III) is in condition class 3, as documented by the Secretary in the project-specific environmental analysis; and (iii) an area that is adjacent to an evacuation route for an at-risk community that the Secretary determines, in cooperation with the at-risk community, requires hazardous fuel reduction to provide safer evacuation from the at-risk community.
Since that 2003, there have been lots of different defintions used for WUI. An example is the NIST table: https://www.nist.gov/el/fire-research-division-73300/resources/hazard-mitigation-methodology-hmm.
To get everyone on the same page, our take on the Forest was to use WUI boundaries designated in each of our County CWPPs. The 3,000 acre CE in the HFRA definitely encouraged liberal use of the definition for everyone involved.
The other consdiration now is that the increaed frequency of larger and more robust fire behavior has made some of the older WUI boundaries challenging.
Thanks, Andy! I had a vague memory of HFRA, that’s what we used in the discussions during Colorado Roadless. And folks haven’t necessarily kept up their CWPPs.. and like you said, different fire behavior would affect what people put in their CWPPs if they updated them.
I had forgotten that HFRA had evacuation routes included. I have a friend who works on evacuation routes (on mostly private land0 and our CDOT doesn’t seem to think this is their bailiwick.
At least in Colorado, some places seem to have done minimalist CWPPs to access grant funds and then never kept them up.
It’s interesting how much the current dialogue is similar to HFRA.
A recent draft CWPP that I reviewed defined WUI as ” and area where structures and other human development meets or intermingles with wildland or vegetative fuels” citing the International Wildland Urban Interface code of 2021 and uses 1/2 mile, 1 mile and 3 mile buffers.
One discussion we had during Colorado Roadless had to do with the concentration of structures and kind of structures necessary to produce a WUI designation… one cabin? five houses? a powerline? IF it’s decided locally it seems random to some; if decided nationally it would be subject to national political forces and possibly not make sense anywhere. And so it goes..
Thanks for providing that. HFRA defines WUI for the purpose of expedited review based on objectives to reduce fire risk, which seems like that same idea being pursued in FOFA. So I’ll just repeat myself: “Such a fundamental land management decision that affects future projects should already be Identified and should be in forest plans, ideally based on (these) standardized criteria.” If someone wants to use a different definition for a different purpose, they should use a different term.