I can’t remember if this is the third time; there was the “Mark Rey going to jail” case, and a more recent case (that maybe led to the NPDES permit requirement? Whatever happened to that?)
But maybe some went by when I wasn’t paying attention.
I first heard about this from The Hotshot Wakeup last weekend. According to his industry sources, the USC study (cited in the case, apparently) involved formulations that are no longer used.
I asked Andy why just the FS and not other wildfire agencies. Here’s his answer:
Contracting for all federal leases of aerial retardant aircraft is done by the FS. The FS also controls retardant formulation approvals through its Qualified Product List.
Here’s a copy of the complaint, thanks to Andy for sending!
That’s all I know..
Here’s a few related question for experts that I’ve never heard answered..
When Senator Sheehy wants only one federal agency (FAA, I guess) to check planes and not the FS, what does the FS check that’s different? It seems like that would be good to know, but I don’t see that in the stories. Also, I had heard that some new formulation, supposed to be more gentle to the environment, had negative impacts to the interior of aircraft, which raised questions about the FS adequately checking on that… but never heard the rest of the story.
I’d like to post a big thank-you, both to Kelly Martin and to Riva Duncan of Grassroots Wildland Firefighters. Some have accused this thinking as being a creature of the current Admin, which we know would be a death-knell for a policy position from the perspective of any person who has correct thinking (just kidding), but as with so many issues, it’s more complicated than that.
It seems to me that we live in a world where everything is connected, and yet organizations can’t handle everything. So there need to be divisions. Think NRCS and FS State and Private, both deal with private landowners, one with all plants, and one with trees. Plus there’s NIFA Forest Extension to give technical advice. So the agencies are kind of organized by topic (trees) and kind of organized by landowners (targets of policies). My point being that there will always be organizational hinges or links, that work better or worse, for individuals, inside and outside government, to negotiate. And folks interested in making government work better try to a) ensure that the hinges are not hindrances (by organizational design) and b) oil the hinges that squeak.
Just to back up, Megafire Action, which has ties to D’s, calls for one department and moving FS to Interior, from their report.
The Fit for Purpose Wildfire Readiness Act of 2025 marks the new beginning of a broad discussion among Congress, federal agencies, firefighters, land managers, Tribes, and forestry/wildfire policy groups on how to best modernize and streamline federal wildland fire mitigation and management. The bill directs the Secretaries of Agriculture and Interior submit a plan with three primary elements—
a budget for the National Wildland Firefighting Service;
a description of the qualifications required for an individual to be appointed to be the Director of the National Wildland Firefighting Service, who shall be appointed by the President, by and with the advice and consent of the Senate; and
a description of the resources and authorities necessary to consolidate Federal wildland fire response efforts of the Secretaries in the National Wildland Firefighting Service.
The plan that comes out of this process will require careful coordination and input from all stakeholders. For nearly a year, Megafire Action has been researching past proposals to reorganize and improve the federal wildland fire response. Our assessment has included proposals to relocate the Forest Service under DOI and the creation of a “National Wildland Firefighting Service’’ as envisioned by Senators Sheehy and Padilla.
Note also that the Fit for Purpose Wildfire Readiness Act is bipartisan. So the idea long predates this Admin.
Now let’s listen to what Riva is saying; I’m with her when she says “we (GWF) know we don’t have all the answers or necessarily the “right” answers, but we do believe the time is right for a real discussion” :
Grassroots Wildland Firefighters (GWF) has had a National Wildfire Service as one of our Four Pillars since the organizations establishment in 2019. We released our proposal shortly after the introduction of the Sheehy/Padilla Bill, but it was lost in a lot of the administration’s chaos at that time. Like the discussion about a NWFS in DOI, and several comments here, a separate agency doesn’t automatically divorce fire suppression from mitigation, ecosystem health, or the land management agencies, nor does it discard the collateral duty workforce (always hated the word “militia” to describe our non-primary fire employees). Ours certainly does not. Also, we (GWF) know we don’t have all the answers or necessarily the “right” answers, but we do believe the time is right for a real discussion. GWF exists in order to represent the boots on the ground and those that directly support them, and that will always be our priority — and something that has been absent in all the other discussions. Our argument has always been that the status quo no longer serves the firefighters. The agencies have failed to protect the workforce, and it’s time to not only think about how we must be able to serve our publics AND our public lands, but also how to serve the people doing the work in an ever riskier and more demanding profession. For those who care to read our proposal, you can do so here: https://static1.squarespace.com/static/5f6ced5b8d33bb20b5c97c0b/t/67a964eb7f17585b0fd3fdf5/1739154668441/GWF+National+Wildland+Fire+Service.pdf
Let’s dig into the GWF report a bit. I recommend reading the whole paper, because I’m not a fire person and what was interesting to me might not be to you and vice versa. Based on the citations, the report was developed since 2023, but Riva can tell us exactly when.
It is past time to build and implement a National Wildland Fire Service (NWFS). For decades, the US Forest Service and Department of Interior (DOI) have refused to do any kind of study or white paper to look at the pros and cons of removing wildland fire, fuels, and aviation response/management from the natural resource agencies. Any serious requests or suggestions have been met with disdain and refusal to even consider such an exercise. Now the FS and DOI struggle to retain experienced wildland firefighters, managers, and support staff such as dispatchers. While the rest of the non-fire workforce is faced with hiring “pauses” and plummeting program budgets, removing fire from these agencies is not only necessary to efficiently address the wildland fire situation, but it just may “save” the rest of the FS and DOI agencies.
Background
The current system of five federal agencies (US Forest Service, Bureau of Land Management, the National Park Service, the US Fish and Wildlife Service, and the Bureau of Indian Affairs) under two different departments (USDA and DOI) being tasked with responding to wildland fires on federal lands (and assist cooperators) is extremely inefficient. This is largely due to the fact that while the employees across the agencies essentially do the same jobs, the agencies have different budgets, position descriptions, training standards, payment processing systems, health support programs to only name a few. Even the four agencies within the DOI have numerous inefficiencies and redundancies between them. Wildland firefighters move between agencies regularly, and, when they do, they have to deal with discrepancies in position descriptions, training standards, background checks, HR issues, etc. After the passage of the Bipartisan Infrastructure Law and the mandate for the FS and DOI to change to a new federal job series, the DOI agencies re-graded Interagency Hotshot Crew (IHC) Superintendents at the GS-10 level, while the FS kept these critical positions at the GS-09 level. It is the exact same job. These inefficiencies and duplications are confusing even to those within the agencies and are costing the American taxpayers.
What I hear is “the status quo is not working for us people doing the work.” We can imagine another solution.. “fix those interagency problems without reorganizing” and yet, no one, over all these years, has seemed to be very interested in oiling these particular hinges. So it is not surprising that the workers want to place the hinges elsewhere in the hope that someone else will have to deal with them.
There is a very interesting, and somewhat depressing, review of the National Fire Plan and associated history since the year 2000 starting on page 4. It even cites a report by Michael Rains (frequent TSW contributor) and Jim Hubbard.
Why was FPA never actually implemented? According to 2016 Denver Post interviews with original developers and the Chief of the Forest Service at the time, it came down to the fact that FPA showed that the most efficient way to manage resources and budgets was to shift resources, and therefore funds, from places with less wildfire activity to places with more. The team lead said that initial version took agencies’ objectives and then optimized them to determine how to best allocate resources for the greatest impact. The idea was to figure out how much money to devote to fire suppression and to reducing fuels to improve overall forest health, and where to do it. But when the tool was used for a preliminary analysis in 2006, not everyone liked what it found. The results showed which areas needed more resources and which needed less, throwing into uncertainty budgets used for staff programs and some administrative overhead. Forest Service officials began to publicly cast doubts about the efficacy of FPA, but Douglas Rideout, the CSU wildland-fire economist and researcher, defended the methodology behind the original FPA, noting it passed a peer review published in a scientific journal the year prior. The Former team leader on the project said FPA became a shadow of what it was supposed to be, the victim of forces opposed to a process that would take decisions about where to put resources out of their hands (Olinger and Gorski, 2016). To this date, no other fire planning analysis tool has been developed for implementation.
Neither department, USDA nor DOI, have any current data on the appropriate numbers, mix, and locations of federal wildland firefighting resources. They continue to cling to what has become an arbitrary number of approximately 14,000-16,000 firefighters. None of the federal agencies have developed a modern formula for determining how many wildland firefighters and support personnel are truly needed to address 21st century issues. It can be done. The California Department of Forestry and Fire Protection (CALFIRE) has one and bases its staffing and funding from it. Many municipal fire departments in California have similar formulas.
My experience was with a GAO review that suggested that beltway-bandit- generated models would be better at determining allocations. Peer review is great, but people have fears and if those fears are not dealt with directly, telling them that something about budget allocation is “scientific” is not particularly helpful. When resources don’t come, “the AI told us that optimal allocation was for someone else” will not make people feel better. And undersecretaries will probably still order air tankers to Long Island. Still, an interesting question.. how did CALFIRE successfully do it?
There’s a strong concern about background of people deciding about wildfires.
Historically, before promoting into these positions, people worked their way up through the agencies in forestry, engineering, biology, range, and wildland fire positions. They spent years as field-going employees and then mid-level managers before moving into positions such as District Ranger, District Manager, Park Superintendent, Refuge Manager, etc. Many had fought fire early in their careers. However, over the past 15 or so years there has been a significant push to hire people from non-traditional programs or even from outside the natural resource agencies. A by-product of this shift is that the average age of a District Ranger in the FS has dropped dramatically, which means people holding those positions are at earlier stages in their career instead of later. We can argue that most now don’t bring fire experience into these jobs, but what is also alarming is many bring little work experience of any kind as they come from special placement programs such as the Presidential Management Fellow program (very popular in the FS) after graduate school. The FS is placing numerous people from this program into line officer positions on national forests with large, complex fire programs.
What this really means is that individuals with no fire education or experience are being tasked with making extremely critical decisions about wildfire within their jurisdictions. Decisions that could have catastrophic results. The situation has gotten so dire that the federal agencies developed an accelerated fire management training program for people in these positions.
However, rather than competency, the goal seems to be rapid certification, which does nothing to resolve the issue. These agency administrators oversee wildfire incident commanders, which is unsettling. Much like if someone with only a basic first aid class were put in charge of a hospital’s emergency department.
My bold. That’s a pretty strong statement, but it’s very clear about their concerns.
What this has meant is individuals with the ultimate wildfire decision-making authority have put wildland firefighters, and often the public, in harm’s way, by making poor and/or uniformed decisions. These are not usually malicious actions, but typically come from places of ignorance, inexperience, incompetence, or fear of torpedoing their young careers. This also means that line officers can “hold” resources back from critical suppression needs. It is common for some line officers to cancel suppression resources’ availability to assist other regions when those requesting regions are experience high fire activity.
I first heard these concerns at the Retirees Roundup in Vail in 2012. When the retirees expressed concerns about the fire experience of line officers, I felt like the FS was saying “this is the way it’s got to be, so we’re doing the best we can with more training.” As to holding resources back, of course people are worried about how decisions are made to use resources. That’s why States like Colorado and California are buying their own.
Bob B. has obviously been doing a great deal of thinking about this.. it was originally a comment, but his ideas are extensive and worthy of discussion on their own.
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An opening thought to this post…“People don’t resist change. They resist being changed.” — Peter Senge
Maybe it’s time—because the status quo in federal wildfire management is unsustainable. As someone who’s worked at every national, regional, and forest levels of the U.S. Forest Service—I’ve seen firsthand how fragmentation, underfunding, and outdated models are limiting our ability to meet today’s megafire challenges.
Here are some thoughts to inform the conversation around a potential executive order or legislative reorganization:
If We’re Doing This—What Should the Organizational Model Be?
If we move forward with establishing a National Wildland Fire Agency, the organizational model will determine its success or failure. Two analogies offer insight:
• DHS Post-9/11 shows how consolidating multiple agencies under one mission can increase national focus—but also demonstrates the pitfalls of poor integration, such as clashing agency cultures, unclear roles, and persistent stovepipes.
• The U.S. Space Force, with a workforce similar in size (~10–12K), is a better analogy. It was built with clarity of mission, streamlined command, and intentional structure. A National Wildland Fire Agency should emulate Space Force’s lean, agile design while learning from DHS’s growing pains.
• Any other ones to copy?
Integrating Prescribed Fire and Suppression
Suppression and prescribed fire are typically executed by many of the same people—yet fire “years” make that untenable in the future. Consolidating these functions under the new agency would improve operational alignment and reduce risk. Land management agencies could contract back for prescribed fire work, but the staffing of resources and accountability would rest with the wildfire agency. This shift could finally address chronic under-resourcing and reduce the unacceptable rate of escaped prescribed burns.
Unified and Interoperable Data Systems
Current systems are fractured, especially between USDA and DOI. During my time, I saw how even basic functions—like syncing global address books—failed across agencies DOI and USFS in the same building. All dispatch centers and platforms (like IROC) should be unified under the new agency to ensure full interoperability and operational clarity.
Facilities Optimization
Many current agency facilities are obsolete or redundant. In Region 5, it was documented that the USFS had as many facilities as employees, most in poor condition. A BRAC-style review is needed to determine which facilities will transition to the new agency. Some former DOD sites (like March AFB) could be rehabilitated for training and housing, so long as they’re affordable and family-suitable.
National Performance Metrics and Procurement
A unified agency would allow for standardized staffing, equipment, and operational benchmarks. Dare I utter national “standard module configuration”. Right now, the same type of engine or crew is staffed and equipped differently depending on the forest or region. Using Defense Logistics Agency (DLA) procurement processes could streamline purchasing and improve readiness. Finally, just like DOD assigns mission sets, equipment, and training without units worrying about base budget funding.
Permanent Incident Management Teams (IMTs)
Permanent, nationally managed IMTs would ensure consistent training, readiness, and response capacity. Building on the USFS NIMO model, these teams would retain control of operations, finance, and intelligence throughout an incident. Supported agencies (e.g., USFS, NPS, BLM) would no longer pull the response in multiple directions, the new agency would own the mission, data, and accountability. This would also increase suppression cost analytics (why is that fire so expensive?), which is always asked the farther you are from the fireline.
Law Enforcement, Arson Investigators and Lawyers For Cost Recovery
LE personnel in USFS (maybe other agencies) operate using fire-funded systems (dispatch, radios, etc.), but without formal alignment. Under a new model, LE support shouldn’t be expected and should be contracted by an agency to the wildfire agency. Cause/origin investigations will roll to the new agency with a centralized investigative unit, modeled on CAL FIRE’s approach, could recover hundreds of millions annually through arson-related litigation, and ensure those cases hold up in court.
We must close the gap between local cause and origin and national arson tracking. The unified Wildland Fire service should participate in the Information Sharing Environment (ISE) via the National Network of Fusion Centers to look multi-jurisdictionally at arson. The ATF’s Bomb Arson Tracking System (BATS) should be the standard platform for all investigative reporting, enabling broader threat analysis and interagency response coordination.
“Change is disturbing when it is done to us, exhilarating when it is done by us.” Rosabeth Moss Kanter (Harvard Business School)
While the change may be hard, a unified National Wildland Fire Agency offers a rare opportunity to reset—this time, with clarity, coordination, and mission alignment.
This is my prep paragraph to Eric Horne’s post below of context for MegaFire Action’s paper on One Department for Wildfire Management (1) which includes (2) moving the Forest Service to Interior (what we might call “the whole enchilada” of moves).
If I recall correctly, Michael Rains mentioned that there was a Carter-era initiative to bring the agencies together. Larry Kurtz often mentions this as a good idea from his perspective, and we’ve discussed it here at TSW several times.
Then there was Service First, which many of us remember as successful but foundering on the shoals of individual agency budget accountability (or personal preference by State Directors or RFs? has a good history been written? Here’s a link to to GAO Report from 2000 called “Ongoing Initiative to Share Activities and Facilities Needs Management Attention. Well, I guess it got management attention.. but not in a good way. Like disappearing it.
So given those historic undercurrents that come to the surface from time to time (as included in the Megafire Action report, as far back as Reagan-er Interchange), it is not surprising that folks new to this space (Megafire Action) have surfaced the idea. Be sure to check out their “One Department for Wildfire Management” report in its entirety. Please remember to be hospitable and kind to new folks. As Eric says, we can expect much more discussion around this topic, so hopefully we can set a productive tone for further discussions.
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Thoughts on the Administration’s proposed Federal Wildland Fire Service
By Eric Horne, National Policy Director, Megafire Action
The Trump Administration’s newly released “skinny budget” proposes a wholesale restructuring of wildfire management. Acknowledging that the “dispersed nature of the Federal mission creates significant coordination and cost inefficiencies that result in sub-optimal performance”, the budget calls for “consolidating and unifying the Federal wildland fire responsibilities into a single new Federal Wildland Fire Service at DOI, including transferring USDA’s current wildland fire management responsibilities.” Coming on the heels of Senators Padilla and Sheehy’s “Fit for Purpose Wildfire Readiness Act of 2025” and the widely circulated draft executive order, this concept is clearly gaining momentum.
Back in February, Megafire Action laid out the extensive history and potential merits of this proposal—“One Department for Wildfire Management”. We found that unifying wildland fire management and land management under one department would greatly streamline preparedness and mitigation, enhance transparency, strengthen tribal partnerships, and improve resource allocation by leveraging DOI’s centralized budget structure and departmental leadership that has a strong history of managing wildland fire across its agencies.
The Administration’s proposal is currently light on details, though we expect the forthcoming Congressional Budget Justification to shed more light on how and when this consolidation will take place, what programs and functions will be moved from USDA to DOI, and what will be left behind at USDA. While we await further details, we want to be clear about one thing: improved wildfire outcomes and cost synergies will only materialize if land management responsibilities are consolidated into the Department of the Interior alongside wildfire suppression capabilities. Fragmentation between emergency response, prevention and mitigation has too often resulted in year-round disaster management, minimizing long-term risk reduction.
The Administration’s skinny budget references “risk mitigation efforts” for consolidation, potentially including fuels management currently under the Forest Service’s Wildfire Suppression Operations appropriations account, though its inclusion remains unclear. On the other hand, key Forest Service land management accounts appear to be left behind at USDA, with significant budget cuts: $392 million in cuts to National Forest System Management, including “vegetation and watershed management”; and $994 million in cuts to other programs. Moving wildfire suppression to DOI while leaving these critical functions underfunded at USDA would forgo cost synergies with DOI land management agencies, missing an opportunity to save taxpayer dollars while improving performance. Severing wildfire suppression from the Forest Service while underfunding land management agencies which are already in the throes of a workforce crisis would likely result in a significantly worse fire environment.
Kelly Martin, retired Chief of Fire and Aviation at Yosemite National Park, explains that “taking a unified approach to all aspects of fire management is intended to help eliminate duplication and overlap between the two main departments—Agriculture and Interior—over the next 50 years. However, without sustained public and political support for communities and individuals doing wildland fire and land management work, we risk perpetuating the wildfire crisis and facing even more severe fire seasons well into the future.”
Structural reform on this scale comes with real risks and potential opportunities. Success will require that the entire land management and wildfire community engage Congress and the Administration to ensure any reform strengthens responsible land management alongside suppression. Stay tuned.
Views like these are not unusual here (like my wildfire plan amendments) but they are from a law professor at UC Berkeley School of Law, who used to work for Earthjustice so it comes from a person with a different background than many of us. It came from a regular newsletter called “Legal Planet.”
This is an excerpt, and the entire piece is here. It was written in January 2025, in the context of the House version of the Fix our Forests bill.
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What is a possible path forward? A key issue is that we spend too much time and effort on review, compliance, and litigation over individual projects, rather than focusing on the big picture. The scale and the urgency of the problem requires us to think about accomplishing management across large areas – but even examining individual projects at the size of 10,000 acres (as proposed in the bill) will still require hundreds and hundreds of projects to be reviewed and completed. And note agencies still have to accomplish review and compliance for land-use plans that they are legally required to prepare and maintain. Those plans do not generally turn directly into on the ground projects – they are usually too vague in their constraints and environmental analysis to do so. Thus, the agencies are stuck doing two levels of review for all projects. And it only takes a mistake on one of those two levels to set back the whole program.
Most recent proposals (including in this legislation) would reduce our scrutiny for individual projects. That perhaps solves one-half of the problem, but it also puts far more weight in terms of ensuring environmental review and compliance on the larger-scale planning process. Planning has the potential to provide important guardrails to ensure good outcomes – the Forest Service is legally prohibited from taking actions that are prohibited by its planning documents. But in general forest plans have imposed only limited constraints on individual, on-the-ground projects. And more generally, the plans have not overall been designed to allow individual projects proceed directly without more environmental review or compliance work.
A better approach might be to do what the agencies already often do with managing off-road vehicle use on their lands. Those travel management decisions can occur in the planning document itself, and can then be immediately implemented when the plan is approved. This reduces the number of steps – including the number of opportunities for litigation.
Agencies could enact forest plans (or more likely amendments to forest plans) that create a pathway that specifically identifies when and how active management will occur within the relevant National Forest. Analysis could draw on what is sometimes called “conditions-based management”, in which specific conditions in terms of forest status would trigger a range of possible responses by the agency. The plan would impose clear limits on the kinds of projects that could be pursued, such as restrictions around endangered species habitat or riparian areas. The plan might also put caps on the total acreage that could be treated within certain timeframes. NEPA review could be undertaken as part of the planning process, along with public participation and engagement. By doing review at a larger geographic scale, there can be economies of scale for analysis and public participation. And by focusing the discussion on the larger-scale problem, it might help refocus debates around the need to act, rather than simply just focusing on individual projects that will always have tradeoffs and risks. Projects that are consistent with the plan and its analysis would be exempt from NEPA, since the review had already been done.
Congress could facilitate this kind of approach. It could explicitly endorse it, or even mandate it – which might make agencies more comfortable taking a new approach. It could limit the amount of NEPA analysis for fire management at the plan level, perhaps by restricting the number of alternatives. It could require the NEPA analysis to consider the risks of inaction with no fire management, which may shape the debate to emphasize the need for action. It could provide limits on litigation – shorter statutes of limitation for NEPA challenges to fire management projects developed through the planning process, and a limitation on any supplemental NEPA claims for a specified timeframe after the planning process is completed. It could also mandate greater community outreach for the planning process, and assistance in developing community fire protection plans that are included in the agency’s own planning process.
A model here is what California did in 2019 for accelerating treatment in forests and other ecosystems at the state level – an overarching environmental review process for its Vegetation Treatment Program, which facilitated approvals for many projects on the ground. California has seen substantial increases in the levels of acres treated since the implementation of the VTP process.
An approach focused on planning decisions at the individual forest level, or at the regional level, allows for agencies to consider the varied ecological and social conditions for different forests and communities. What works for reducing fire risk in dry Sierra conifer forests will not necessarily work in chapparal in Southern California. Finally, by allowing for more active management while still maintaining public participation and some accountability through judicial review, this approach may reduce the distrust that has swirled around forest management for the past few decades. Because at the heart of our challenges in addressing fire risk in our forests is a deep distrust. Without addressing that distrust, any solutions will be contested and less effective.
It looks like a condition-based management EA for wildfire risk reduction activities. It’s 75 pages with many appendices.
The LPNF proposes two general categories of treatments: (1) Fuelbreaks and Defense Zones (Zones) and (2) Forest Health Treatment Units (Units). The objective in Units is to promote healthy forests that are resilient to natural disturbance, enhance opportunities to suppress wildfire, and increase protection of the urban interface. Zone treatments would occur along ridgelines, existing roads, motorized trails, and property lines and adjacent to Forest Service administrative sites (including developed recreation sites, fire stations, and ranger district offices), communication sites, and other structures. Zone treatments would involve the establishment and maintenance of strategic fuelbreaks along ridgelines to slow the rate of spread of wildfire for the purposes of aiding wildfire management efforts and protecting infrastructure, communities, and natural and cultural resources. Zone treatments would also involve reducing fuels along roads and motorized trails to support ingress/egress and evacuation and reducing fuels along property lines and adjacent to United States Forest Service (USFS) administrative sites to help protect life and structures and limit economic damage associated with wildfires. Treatment methods could include mechanical thinning, hand thinning, chipping and grinding, piling and burning, mastication, mowing and weed-whipping, prescribed fire, targeted grazing, and planting and seeding.
The project is designed with a management approach that supports responsiveness and flexibility prior to treatment implementation. This approach allows for proposed treatments to be aligned post-decision but prior to implementation with ground conditions at the time of implementation. This will maximize the efficacy and efficiency of project planning and implementation by reducing the time and funding currently spent per project, increasing flexibility to choose treatment areas and methods, and taking advantage of time-sensitive opportunities and conditions. It also allows for continued coordination with local agencies, tribes, and others to focus treatments on shared priorities and include cultural approaches consistent with the project.
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One of the questions many people have on these projects is “how is the public involved in the site-specific decisions?”
An Implementation Plan (IP) was developed as part of this proposed action to help ensure resource conditions at the time of implementation are appropriately considered prior to implementation. The IP provides an implementation framework and process that the Forest Service will apply at the stand level prior to entry. The IP includes three forms to be filled out at different stages of implementation planning, and one form to be filled out upon treatment completion:
• Form A: Phase Initiation Form
• Form B: Phase Treatment Form
• Form C: Environmental and Permitting Requirements and NEPA Consistency Determination
• Form D: Treatment Completion Tracking Form
Each form is described in detail in Appendix D – Implementation Plan, including templates for each. Work will be prioritized each year based upon an assessment of the dynamic conditions, addressing areas of highest priority for the upcoming phase with the input of the Forest’s fire, fuels, silviculture and/or other specialists as applicable. A key component of this step would be to identify the areas and types of surveys that need to be performed, including (but not limited to) special-status species and their habitats,
invasive plant species, riparian conservation areas, and cultural resources. Many of these studies are time-sensitive and surveys, when necessary, would be performed in the appropriate season before the work. Applicable RPMs and Best Management Practices (BMPs) would be listed based on the assessment of resources to ensure that any constraints are included in the planning of the work for the year and to ensure that crews performing the work are also aware of the requirements.
For the WRRP, it is anticipated that up to 10,000 acres of treatments would be implemented each year, with a maximum implementation scenario, including re-entry treatments, not to exceed 20,000 acres per year. This is based on a review and average of work over the last 10 years. Including all types of treatments, the LPNF currently averages 3,500 acres per year, with higher totals over 9,000 acres of annual treatment.
Appendix D has a very detailed description of the implementation steps. I selected this section to describe public outreach at the site-specific implementation level.
Each phase of work would be disclosed to cooperating agencies, tribes, and the public (e.g., posted to the Forest website, social media, and/or other method(s)), to the extent practicable. No additional NEPA decisions are needed unless proposed work falls outside the scope of the EA. A detailed plan for the phase of work that includes elements such as the location of treatment areas, the surveys completed and areas of modified treatments based on RPMs and other measures, identification as to whether material would be sold, chipped or masticated, piled and burned, or removed would be provided as well as a more precise schedule of activities. Outreach to the public, particularly in areas where treatment is located near residences or prescribed fire is planned, would be undertaken. Regulations requiring formal public engagement opportunities (e.g., comment or objection periods (36 CFR 218)) during project implementation do not exist.
So there is a chance for the public to make its wishes known at each site, but no regulatory requirements for formal comment periods. What do you think?
Obviously there are many interesting things going on right now, not all of which can be covered here.
We’ll start with my favorite quote of last week, from Andy Stahl in an E&E News article about the Timber EO. Extra points for the Kohelet reference!
Stahl said he thinks the emergency designation is overblown.
“There’s nothing new under the sun happening out in the woods,” Stahl said. “Forests burn, insects thrive.”
What I’ve Heard is Happening with FS
Purchase cards continuing to be a problem.
Reports are that positions are being reviewed for contribution to recreation and veg management capacity in some Regions. No new info on RIFs, same discussion about R&D, S&PF, WO and ROs.
Fixing Broken Links:
Last week I mentioned that the links to the projects websites from the SOPAs seemed to be broken. I contacted the Press Office (not knowing the address of the Tech Office) and they said
“Our system nationwide switched to a new platform this week, and we’re working on broken links. If you check back next week and they are still not working, please send us the links.” So please let me know of any broken links in the comments, probably best after Wednesday or so, to give them a chance to fix.
Wildfire Insurance
The Hotshot Wakeup interviewed Michael Wara of Stanford, an expert in the wildfire/insurance space. Interesting interview, and Wara explains that that plethora of wildfire risk maps have to do with what exactly they are used for.
Scott Fitzwilliams, White River National Forest Supervisor Resigns
These stories reminded me of when Scott first came to the Region from California. He was shocked by how little funding his forest got for their work, compared to California forests. I’ve always wondered about that, and whether national cuts are always cutting from the Big Timber days, so Regions with formerly Big Timber programs still get relatively more bucks. I wonder if anyone has ever taken the current roads, trails, campgrounds, ski areas, and dispersed use and looked across the country and seen the differences in funding (and wondered why that was so).
Happy Retirement, Scott!
There were many articles, but I thought I’d pick this one from the Colorado Sun:
The White River National Forest — with its 11 major ski areas, eight wilderness areas and four reservoirs — regularly hosts more than 17 million visitors a year. The forest supports more than 22,000 jobs, with forest-dependent workers in its communities — like Aspen, Breckenridge, Carbondale, Eagle, Glenwood Springs, Meeker, Rifle and Vail — earning $960 million a year, according to the Forest Service’s economic analysis of its top 111 properties. The forest’s annual impact of $1.6 billion in its communities ranks as the highest in the agency.
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He recently began speaking up about the need to better fund a forest that produces so much for its communities, calling on federal lawmakers to pass the Ski Hills Resources for Economic Development Act — or the SHRED Act — which would allow forests to retain as much as 75% of the fees paid by ski areas in their boundaries.
The White River’s ski areas — like Beaver Creek, Breckenridge, Copper Mountain, Keystone, Snowmass and Vail — send the federal treasury more than $20 million a year as revenue-based rent for public lands. The SHRED Act would allow the White River to keep as much as $17 million of that, which would almost return the forest’s annual budget to where it was in the late 2000s, before wildfire costs ravaged the agency’s disbursements to individual forests.
“We see all this economic activity and money flowing out of the forest but none is flowing back in. This forest, it’s a machine and it’s a producer for us,” Fitzwilliams told The Sun in 2022. “It’s really taking care of us and it’s really giving us a lot. Maybe it’s time to give back.”
**********
This is a very interesting interview by Zeke Lunder of the Lookout, with Tanya Torst, who was a partnership coordinator apparently hired to help with partnerships for fuel treatment projects. She has a fairly unusual background for a new hire, so it’s interesting to get her perspective.
Tanya brought a unique perspective to her new job, trying to get things done within a large bureaucracy staffed largely by people without a business background.
Tanya has a MBA from Chico State, a Master’s Degree in Organizational Leadership from Gonzaga University, and a Bachelor of Science Degree in Business Management from Marylhurst University.
Here’s a sample:
Zeke Lunder
Why is that? Why is why is the Forest Service lost so much capacity? Why is it so hard for them to get work done?
Tanya Torst
Yeah, that’s a good question. Part of it is because Congress does not give them enough money to to hire and even pay our people last year because of the continuing resolution last fiscal year, fiscal year 24 there was, it was very it was a big struggle. We had to stop expense, any expenses. I. Um, we couldn’t do travel to do our work done. I’m not talking about fun travel. I’m talking about travel to get work done. We it. We just couldn’t pay our own bills. And with the continuing resolution of this year, we couldn’t even buy toilet paper. I mean, it’s ridiculous. And you know, we’re talking about forest supervisors, and everyone’s like, Well, looks like, you know, office folks are going to be doing cleaning toilets, and that’s okay, you know what? I think all of us are fine with doing that. We don’t have an issue with that. I, I was on a call with one of the forests, and the question was, how do we keep track of everything when we have four to five different jobs to do where one person is doing the work of four to five people or trying to they’re honestly, some of them are not getting paid over time. No one’s getting paid overtime. It’s like it’s so hard to get anything done. And then I’m gonna just bring it up. NEPA is challenging…
At the time, it sounds like the federal funding was stopped. But various partners are now hiring for positions formerly done by employees, so perhaps the taps are back on? For some but not all? What do folks know about this?
In Oregon, they are still battling over their wildfire risk map and associated policy interventions. Colorado has taken an interesting approach focused on transparency and landowners getting discounts for their mitigation work, which has the support of both homeowners and the insurance industry. It’s always interesting how the state “laboratories of democracy” work out. Nice article by Robert Tann of the Glenwood Springs Post Independent.
House Bill 1182 passed the Senate on Friday after being approved in the House last month. The bill is now poised to head to Gov. Jared Polis’ desk.
Polis has mentioned tackling the rising cost of homeowners insurance as a top legislative priority, calling for lawmakers to pass reform measures in his State of the State address.
Colorado has seen a dramatic increase in insurance costs in recent years as weather events, intensified by climate change, drive up homeowners’ risk.
According to a study by the state-run Division of Insurance, premiums for single-family homes jumped 52% between January 2019 and October 2022. In the High Country, where wildfire is an even more present threat, some homeowners have reported premium increases upwards of 1,000%.
At the heart of House Bill 1182 is an effort to give homeowners more credit for steps they take to protect their homes and reduce their risk.
“People are doing different kinds of mitigation work thinking that the insurance company will be impressed and give them a discount,” said Rep. Brianna Titione, D-Arvada, during debate on the House floor last month, “and a lot of times what they’re doing is irrelevant to what the insurance company thinks is best for the property.”
Under the bill, insurance carriers would be required to consider mitigation efforts when assessing a homeowner’s wildfire risk. Companies would also need to share information on their risk models with the state’s insurance division, explain to homeowners how their risk is calculated and what they can do to lower it, and allow homeowners to appeal their risk score.
Titione, a bill sponsor, said the measure “is about promoting transparency and accountability in the wildfire risk scoring and the models and empowering Coloradans to make informed decisions about mitigation.”
Bill sponsors agreed to several amendments brought forward by the insurance industry.
That includes holding homeowners’ mitigation efforts to an industry-recognized standard, such as the Insurance Institute for Business and Home Safety’s Wildfire Prepared Home program.
The program certifies homes that meet a set of criteria as being “wildlife-resilient” and is currently recognized by insurance carriers in California and Oregon as a way to lower premiums.
Carole Walker, executive director for the Rocky Mountain Insurance Association, said that having standards for mitigation work in House Bill 1182 could open the door to having the program recognized by insurers in Colorado.
“We all believe in mitigation, but just mowing the grass is not enough,” Walker said.”What we’ve found is there needs to be actionable mitigation that people are doing, and this helps us verify it, and once it’s verified, that’s something that the models can consider.”
Other amendments allow insurance companies to directly lower a homeowner’s premium rather than adjusting their models to account for new mitigation work. Walker said this gives carriers more flexibility to adhere to the bill since not all models work the same.
The bill also narrows what information must be shared between carriers and the state when it comes to modeling software and ensures that a company’s intellectual property is kept confidential. Changes were also made to exempt nonresidential commercial properties from the bill and to push out the bill’s implementation date from January to July 2026.
Walker stressed to lawmakers to be mindful of not passing policies that would drive insurers out of the state due to overregulation. She said the bill’s amendments “come to what I think is a good opportunity for education around what the models do and meaningful mitigation steps that are verifiable.”
House Bill 1182 received broad bipartisan appeal, passing the House by a vote of 45-18 and the Senate by 33-1. House lawmakers must still approve changes made in the Senate before the bill can go to Polis’ desk.
I’ve been thinking about how much the current FOFA is a this decade’s version of HFRA and the Healthy Forest Initiative. It’s actually surprising how similar the ideas are “delineate an area”, “use special authorities”. Been there, done that.
I asked “what worked and what didn’t?” and “what can we learn?” If you were around then, please add your own observations. I did find this 2007 review of HFRA implementation.
INTRODUCTION
Following the exceptionally severe wildfire seasons that punctuated the past decade, the Administration and Congress authorized a suite of administrative and legislative tools to expedite the reduction of hazardous fuels and restoration forest health. These Healthy Forests authorities include the Healthy Forests Initiative (HFI), the Healthy Forests Restoration Act (HFRA) and expanded authority for stewardship contracting and agreements. These authorities call for increased collaboration with stakeholders and provide streamlined administrative processes. The goal is to increase the acreage treated annually and to reduce overall treatment costs.
Although the Forest Service has strongly encouraged the use of Healthy Forests authorities over the past three years, Forest Service personnel and stakeholders have voiced frustration over their implementation. In response, the Forest Service conducted an internal review of its use of Healthy Forests authorities during the 2006 field season.
The purpose of the review was to 1) gauge Forest Service employees’ understanding of Healthy Forests tools, 2) identify opportunities to improve the tools, and 3) determine how Forest Service leadership can better support the use of Healthy Forests authorities. The review noted both significant barriers and challenges to Healthy Forests implementation and elements of successful Healthy Forests implementation. This report includes recommendations to address the barriers and improve Healthy Forests implementation.
Overall, the review team found few major problems with the use of Healthy Forests authorities. While some region-specific issues exist with the use of Healthy Forests tools, there are also several common trends that are applicable more broadly. This report documents the review findings and recommends actions to improve the implementation of Healthy Forests authorities nationwide.
The Executive Summary highlights the major findings and recommendations. These and some additional findings and recommendations are detailed in the Discussion section that follows. The Appendices include regional summaries, briefing papers on the threat assessment centers, coordinated resource offering protocols, strategic placement of treatments, and numerous useful references for field personnel wanting to improve the efficiency of their fuels reduction and forest health programs.
DISCUSSION Barriers and challenges to successful Healthy Forest implementation
Aside from environmental challenges such as continuous drought, insect and disease outbreaks and overly dense vegetation, many units nationwide are also experiencing social, economic, institutional and cultural challenges.
Social
The Healthy Forests authorities strongly emphasize collaboration. While some units have successfully engaged in collaboration with local communities, others are having trouble establishing collaborative relationships for a host of reasons. For example, some communities are engaged in collaborative planning, but are unable to fully realize their goals due to challenges from outside the local area or the collaborative group. In other locations community collaboration groups have expanded their collaboration, broadening the geographic area from which to draw partners while focusing on activities on a smaller geographic area.
This seems like it may have been fixed since 2007?
Economic
The declining forest products industry presents a continual challenge to the implementation of Healthy Forests activities, particularly with biomass utilization and stewardship contracting. In many regions, the milling infrastructure necessary to process biomass from hazardous fuels treatments or merchantable timber from stewardship contracts is absent or inadequate.
The shrinking availability of infrastructure has coincided in some areas with a loss of individuals with the necessary skills to perform forest restoration work. For example, the Rocky Mountain region has recently experienced a surge in the oil and gas industry; as these industries have increased their wages and workloads, individuals who once worked in the forest products industry have transitioned into the more lucrative oil and gas business.
Further, the low value of timber removed reduces economical treatment options, forcing many national forests into expensive service contracts to remove the hazardous fuels. Continuously rising fuel and transportation costs are often cited as contributing factors to the increasing costs of service contracts and as impediments to economically viable biomass utilization and stewardship contracting.
Seems like, except for the O&G industry, this has possibly gotten worse (Montana mills).
Institutional
Although external factors such as the economics and politics of a particular area affect Healthy Forests implementation, review participants also noted that procedural obstacles to the use of Healthy Forests authorities exist within the Forest Service itself. With continuously expanding workloads, many units expressed frustration with their inability to provide adequate staff and expertise to all of the projects in their program of work. In effect, Healthy Forests projects are sometimes given lower priority for staffing than forest plan revisions, major EISs for fire recovery, other large scale projects and high priority planning work.
Further, Forest Service personnel cited the lack of integration between staff areas as a major challenge to Healthy Forests implementation. Without clear communication between resource program managers, it has been difficult for units to incorporate Healthy Forests projects within their larger program of work. Many units requested strong, clear, consistent guidance from all levels of Forest Service leadership on how to integrate Healthy Forests authorities into existing policies and procedures.
I would guess the FS Implementation memo is designed to get at this, but perhaps only for the areas with existing (or should I say remaining) infrastructure.
Cultural
While the barriers mentioned above do not hinder Forest Service personnel from specifically using or attempting to use Healthy Forests authorities and tools, they do create a climate of frustration when Healthy Forests projects do not come to fruition, whether designed specifically with the newer authorities or with traditional ones. This is where the corporate culture of the Forest Service or of an individual can affect use of Healthy Forests authorities. In the face of this frustration, personnel who tend to take a conservative approach to accomplishing their work are reluctant to adopt new techniques and prefer to stick with tools with which they are familiar. On the other hand, the “early adopters” recognize the benefits of the newer tools and aggressively use them even if their initial attempts are not fully successful.
Again, the FS implementation memo appears to seek to abjure conservatism in using authorities and technologies. The below part of the Secretary’s memorandum has a bit of a “continuous improvement” ring to it, so perhaps attention will be paid regularly to progress and impediments? I really, really hope that the FS will make these reports public and we won’t have to FOIA them.
e. REPORTING
Each calendar year, the Forest Service shall report to Natural Resources and Environment on the use of emergency authorities that will include those actions taken pursuant to this Forest Health and Fuels Reduction Emergency Situation Determination detailing:
• Status of any ongoing environmental analysis or compliance actions;
• Listing of completed (signed decision) or future compliance actions;
• Status of any ongoing consultation, including the National Historic Preservation Act and Endangered Species Act;
• Status of any ongoing coordination with local or state emergency management offices or other federal agencies;
• Status of coordination and consultation with federally recognized Tribal governments and/or Alaska Native Corporations; and
• Listing of any completed (implemented on the ground) or future mitigating emergency actions, to include number of acres treated or anticipated to be treated
Back to the 2007 Review..the Biomass section is good, but also depressing. If you’re interested, check it out.
Note: Bob Zybach and I posted these at almost the identical time yesterday, so I changed the time on this to today, so it would be more visible to folks. Also since then, Tom Erb of Senator Hick’s office posted on X that FOFA is an “abundance bill.” If you’re not familiar with the Abundance idea promoted in this book according to Wikipedia it’s generally about “better managing the trade-offs between regulations and social advancement.” It’s always interesting to see what larger movements have to contribute (or not) to forest policy, so if someone would like to read and review the Klein and Thompson book for TSW, that would be great!
When I first ran into Matt Weiner of Megafire Action, I wondered “who are these people?”, “why are they in our space?” and “why is he talking about wildfire and I am moderating the panel?”. I felt challenged to gracefully accept new people interested in our policy arena, and not be suspicious. They are big fans of the Wildfire Center, and I have some reservations about it. Nevertheless, this group, working with others, has been successful at moving FOFA along- likely in a way that the traditional groups would not have been, so “by their fruits” and all that.
Folks I have spoken with in the past have had trouble getting through to various D staffs about this bill because to some any changes affecting litigation possibilities are a non-starter. Thanks to a dedicated effort by many groups, FOFA has arrived as a bipartisan bill to the Senate. People have been asking me about changes between the House and Senate Bills, and it looks like this is a nice summary by Megafire Action. So many thanks to them, both for helping shepherd the bill through and providing this handy section by section analysis. Changes are noted in red in the document.
As an elderly wonk, FOFA reminds me a great deal of HFRA (pick certain areas and change the generic rules for projects for fuel treatments) and so I would have liked a more formal review of “why HFRA didn’t work” before starting FOFA, but that’s just me. Here’s the FS summary of HFRA (2003):
Healthy Forests Restoration Act
The Healthy Forests Restoration Act of 2003 (P.L. 108-148) contains a variety of provisions to expedite hazardous-fuel reduction and forest-restoration projects on specific types of Federal land that are at risk of wildland fire or insect and disease epidemics. The act helps rural communities, States, Tribes, and landowners restore healthy forest and rangeland conditions on State, Tribal, and private lands. It also:
Encourages biomass removal from public and private lands
Provides technical, educational, and financial assistance to improve water quality and address watershed issues on non-Federal lands
Authorizes large-scale silvicultural research
Authorizes acquisition of Healthy Forest Reserves on private land to promote recovery of threatened and endangered species, and improve biodiversity and carbon sequestration
Directs the establishment of monitoring and early warning systems for insect or disease outbreaks
Title I provides authorities for expedited vegetation treatments on certain types of NFS and BLM lands that are at risk of wildland fire; have experienced wind throw, blowdown, or ice-storm damage; are currently experiencing disease or insect epidemics; or are at imminent risk of such epidemics because of conditions on adjacent land. This title:
Provides expedited environmental analysis of HFRA projects
Provides administrative review before decisions are issued on proposed HFRA projects on NFS lands
Contains requirements governing the maintenance and restoration of old-growth forest stands when the USDA Forest Service and DOI BLM carry out HFRA projects in such stands
Requires HFRA projects on NFS and BLM land to maximize retention of larger trees in areas other than old-growth stands, consistent with the objective of restoring fire-resilient stands and protecting at-risk communities and Federal lands
Requires collaboration between Federal agencies and local communities, particularly when Community Wildfire Protection Plans are prepared
Requires using at least 50 percent of the dollars allocated to HFRA projects to protect communities at risk of wildland fire
Requires performance to be monitored when agencies conduct hazardous-fuel reduction projects and encourages multiparty monitoring that includes communities and other diverse stakeholders (including interested citizens and Tribes)
Encourages courts to expedite judicial review of legal challenges to HFRA projects
Directs courts that consider a request for an injunction on an HFRA-authorized project to balance the short- and long-term environmental effects of undertaking the project against the effects of taking no action
So it’s been 22 years and here we are with FOFA.
I am REALLY glad that Megafire Action did this analysis, as it’s very difficult for many of us to follow “remove section Xof HFRA and replace it with…”
The Senate version updates standards for judicial review of fireshed management projects and limits injunctions to defined conditions. It codifies the existing balancing test for injunctions and removes the “proximate and substantial environmental harm” threshold included in the House version. It introduces separate four-part tests for preliminary and permanent injunctions and establishes clear criteria for when courts may vacate agency actions—explicitly considering wildfire risk and ecosystem health. It also extends the statute of limitations from 120 to 150 days, removes the requirement that plaintiffs must have participated in the agency comment process, and requires agencies to act on court remands within 180 days. In all, this represents a balanced compromise between preserving process and preventing obstruction of badly needed projects.
I wonder about “removes the requirement that plaintiffs must have participated in the agency comment process.” I thought that was already a thing somewhere. It seems like if folks had concerns about a project they would want to participate so the agency would have a chance to do what they wanted. Maybe this has to do with increased use of CE’s, and maybe some groups would miss scoping? Would like to hear more about the rationale for this.
Here’s the NEPA xection: FYI Kelly Martin is on the Board of Megafire Action.
Under FOFA, forest management projects receiving up to a 10,000 acre CE must first be identified by a fireshed assessment. FOFA mandates that fireshed assessments comply with
applicable forest plans which are developed with community input, incorporate the best available science and traditional ecological knowledge from Indian Tribes, and allow for local government participation in their formulation. These added guardrails ensure that CEs will not be used for projects that harm our forests.
While sensitivities around changes to NEPA are justified, it is important to note that FOFA does not amend, alter, or rollback NEPA or the Endangered Species Act (ESA). Agencies must still adhere to all rules and regulations governing the use of categorical exclusions and CEs must only be used in appropriate areas and not used in areas where work is prohibited. It is also important to note that while the original draft eliminated acreage limitations for the utilization of categorical exclusions, the current version sets the acreage limitation to 10,000 acres. FOFA would not enable agencies to “stack” CEs any more than they are able to under the current 3,000 acre limitation.
To further understand the practitioner perspective on categorical exclusions, Megafire Action interviewed Kelly Martin, Ret. Chief of Fire and Aviation at Yosemite National Park, and Type 1 Incident Management Team member in Operations and Fire Behavior, who provided important insights on CEs:
“Categorical exclusions (CE) are a key tool for forest resilience and wildfire mitigation. Currently, there is an over-allocation of funding and human capital dedicated to
planning and revising existing NEPA Environmental Impact Statement (EIS) or Environmental Assessment (EA) documents sometimes 5 to 10 years in the making.
This favors what seems like endless and duplicative planning efforts compared to implementing beneficial actions on the ground that we know are based on solid science and research. CEs help us streamline the public review process and start putting meaningful projects on the ground faster to meet existential wildfire threats. Unfortunately, projects done under the current 3,000 acre CEs fall woefully short of what is needed to meet the ever increasing size of contemporary wildfires. Smaller CEs often don’t provide the buffer or resiliency needed to change conditions on the ground at a meaningful scale. In contrast, the value of a 10,000 acre CE is that you’re not just looking at small sections, you’re starting to look at the entire landscape and how it can withstand future challenges to watersheds, biodiversity, and key ecosystem services we deeply care about.
A common mindset around CEs is that they represent a rollback of environmental protections, but CEs are really about accelerating the implementation process for projects that have already been vetted and approved in existing land management plans backed by an EIS or EA. CEs are nothing new, they’ve been an important part of public engagement and meaningful land management actions for years. The CE reduces planning and analysis tiered to existing EISs and EAs and reduces the need for a redundant round of review for each specific project. This is not about returning to clear cut logging, going into sensitive areas, or removing mature growth old timber. We’re talking about targeting areas that are accessible, where intervention can make a meaningful difference to landscape resilience. While forestry in the past, particularly in the early 1900s, often led to negative outcomes, those earlier mistakes should not cloud the judgment of today’s forest management strategies, which are vastly more informed by modern science. We’re not going back to those days.”
The Senate version keeps the core of this provision while making a few tweaks to ensure that the CEs apply to fireshed management areas that are properly selected with the best science, and adds some new guardrails on the use of emergency authorities. The Senate version adds riparian and wet meadow restoration and more detailed descriptions of the types of treatments intended, to further signal that clearcutting is not a desired management activity.”
The Megafire Analysis is comprehensive, so if you find any other topics of interest, please feel free to comment. I just selected these because I heard that these were sticking points to some offices.
