Richard Manning: Forest Service is fighting every fire, but at what cost?

Read the entire article here.  A little intro snip is below:

On July 12, lightning sparked a forest fire in western Montana’s Bob Marshall Wilderness Complex — a place where wildfires are common this time of year. Usually, if they’re small and don’t threaten to get out of control, the U.S. Forest Service will let them burn. Small fires are good for the forest ecosystem, burning off dead timber and creating habitat for many woodland species; because of that, all U.S. agencies adopted a policy in 1995 to reintroduce fire on federal land.

So what happened last month was unusual: the U.S. Forest Service, which manages the 1.5 million-acre Bob Marshall Wilderness Complex and an additional 35 million acres of federally designated wilderness land nationwide, ordered a full-on attack of the fire by smokejumpers, bucket-bearing helicopters, and four lumbering slurry bombers that each dumped more than 2,000 gallons of red chemical fire retardant on an ecosystem that is otherwise treated as pristine.

This has been happening all across the West this summer, as the Forest Service throws its already-thin firefighting resources at blazes that in previous years would have been allowed to spread naturally and burn out on their own. The stated reason is cost: the Forest Service is so worried that the hot, dry conditions will cause one or more of those small fires to burn out of control — consuming not just acres of forest, but also the agency’s strapped budget — that it’s willing to pour money and resources into fighting blazes that threaten little and are usually considered healthy for the forests.

Compensating North Fork Fire Victims

Photo from Jefferson County

Here is a link to today’s article in the Denver Post, and below is an excerpt.

The commission also may make “compensatory recommendations” after hearing from victims of the fire, who were expected to testify in Conifer on Monday night.

“Realistically, we’re talking about many months, if not over years” before victims see special compensation from the state, said commission chairwoman state Sen. Ellen Roberts, R-Durango .

Mike Babler, fire programs manager for the Colorado chapter of the Nature Conservancy , said wildfires are becoming more frequent and more intense.

Babler said prescribed burns, which the state put an indefinite ban on after the Lower North Fork fire, are still important for fire management. But he listed a variety of other strategies, including defensive techniques such as cleaning up pine needles and other fuel around homes.

Another major factor has been the collapse of the timber industry, Babler said. With a depressed construction industry and foreign competition, mills have been shuttered, leaving forests thicker with fuel.

He also pointed to the growth of those living in the “urban wilderness interface,” where development creeps into forests. Two million people in Colorado now live in these areas, and studies say that could double in 20 years, he said.

In California on Monday, more than 825,000 rural residents received bills from the state of up to $150 for fire protection costs.

The controversial new fees are expected to raise $84 million to help balance the state budget.

Sharon’s questions: Does someone have a link to the California policy? Also, it’s still not clear to me why the taxpayers of Colorado (say, the person working at the 7-11) should be compensating these folks. Is it for something their insurance does not cover? Does the policy of “no prescribed burns” really make any practical sense? Is there really such a policy in the State (I haven’t been following this)? Finally, I wonder if the studies of the doubling of populations in the WUI takes into account the economy, and the distribution of wealth. If we can’t predict that, what can we predict? Sensitivity analysis might be useful.

Study of Reasons for Increased Suppression Costs

JZ sent this as a comment to another thread, but in the interest of using the “best available science” here is a link to a Journal of Forestry article from 2008. The full title is “External Human Factors in Incident Management Team Decisionmaking and their Effect on Large Fire Expenditures.”

It’s interesting to get a perspective from the people involved. It sounds like the next piece of research was to interview the agency administrators. Does anyone know if the authors finished this, and if so, where the paper might be found?

Smoke from the NW Visits Denver- It’s a Small World

good photos included in the CBS story here.

Have you noticed the hazy skies we have had around the Mile High City the last few days?

The current wind patterns are to blame.

At the moment there are over a dozen wildfires burning in the Pacific Northwest. There’s also a fire that has put out a bit of smoke in Western Colorado — the Wolf Fire.

The high pressure ridge over Colorado and a Jet Stream passing over the northern Rockies is pumping smoke right into our state from the northwest.

This along with the higher ozone levels has made for poor air quality that has created unhealthy conditions for people with breathing difficulty, according to Colorado Department of Public Health and Environment.

Firefighting Policy Time Out or “Reversal”.. You Read the Memo and Decide

I’ve seen a couple of articles about a new fire policy with regard to “letting it burn”. Haven’t seen the text of the actual policy.

Here’s
a link to a fairly long piece about it, including an interview with Jim Hubbard, excerpted below.
Here’s a link to the memo.

In fact, Hubbard and everyone else agree that allowing wildfire in wilderness makes long-term financial sense. “It does. It absolutely does,” said Hubbard. “This is not a good position to be in.”

Niel Lawrence, director of the forestry project at the Natural Resources Defense Council (which publishes OnEarth), argues that the agency is suppressing wilderness fires today as a way of generating future revenue for itself. He said the agency has been deprived of the income it once drew from timber sales (because of greatly decreased demand for lumber and pulp), and so has learned to maximize its income in the fire suppression business. When forests and homes are burning, and the images of slurry bombers are dominating cable news, it’s an opportune moment to pry money loose from Congress. Fire suppression today guarantees there will be more fire in the future to make that gambit sustainable, Lawrence argues.

Regardless of motives, the whole situation takes on an added urgency in light of global warming. Given the prospect of more hot, dry weather and more catastrophic fires in the future, it seems prudent to burn what is burnable now, Lawrence says, again to defuse the future bomb. “We’ve got a window here that’s closing,” he says. “If we don’t get fire back in now, it’s going to be impossible to control it later.”

There’s been overwhelming agreement with that idea in the past from Forest Service fire managers, but sticking to that principle means the bureaucracy needs to accept some short-term risk — including some political risks — for long-term gains. Hubbard made it clear in his conversation with me that the agency, at least at this point, is not willing to do that.

The two other major federal agencies charged with managing public lands — the Bureau of Land Management and the National Park Service — have not followed the Forest Service’s lead. After Hubbard’s memo, they restated that they will continue to follow the 1995 policy. In the mountainous West, however, the Forest Service carries the most weight on this issue; it manages about 60 percent of the total designated wilderness acreage in the 11 contiguous Western states.

Hubbard’s letter containing the new directive cites “unique circumstances,” and in our conversation, he acknowledged that those circumstances are global warming. But in terms of the future, those circumstances are not at all unique — hotter, drier, more fire-prone conditions across the West are the new normal. So does this mean, I asked him, that the keystone of wildfire science and policy for nearly two decades is a first casualty of global warming?

“I would agree with that,” Hubbard said. “And this is not a policy shift because we thought we were headed in the wrong direction. It is a financial shift.”

But tight budgets and a hot climate aren’t going away anytime soon. So the Forest Service’s new policy continues to shift the burden of global warming to future generations: their forest fires will be bigger and more costly because we refused to confront the new realities facing us now.

Note from Sharon:
Oh, for heaven’s sake! Does Mr. Laurence really think this is a conscious effort to get more money for the FS in the future? And why would that matter to a current employee such as Mr. Hubbard?

Another hypothesis might be (and I have no reason to think that that is the case), that this is an election year and the Executive Branch folks told the FS to be conservative on fires that might get out of control and provide campaign fodder.

Or maybe Congress or even OMB told the FS to pick the lowest cost solution, if they want to get funding.

Just sayin’ FS fire folks don’t work in a vacuum.

I also thought that it was entertaining that someone wrote by the side of the memo:

James E. Hubbard, deputy chief for state and private forestry, orders an “aggressive initial attack” on fires sparked in wilderness area managed by the U.S. Forest Service — even though he acknowledges that this reverses a long-standing federal policy designed to create healthier forest ecosystems is undesirable from both a scientific and long-term financial standpoint

Hubbard never said it was undesirable from “a scientific standpoint”. Science doesn’t give us an endpoint, it gives us a path forward. Having “restoration” as an objective is no more scientific than having increased exports as an objective. IHMO.

More on The Price Tag for Wildfire Suppression and Recovery

This could be helpful for our discussion of costs of fires, except for the lack of dollar figures. We may have to stay tuned.

from the Denver Post here:

Colorado needs more federal help than earlier anticipated to recover from this summer’s devastating wildfires, according to a letter Gov. John Hickenlooper sent President Obama this week.

“While we are appreciative of the current declaration, as it exists today, only a select handful of local governments and private non-profits will receive (the) benefit of reimbursement and only in limited amounts,” the governor’s letter to the president states.

“Most of the identified needs remain unmet, and Colorado communities will be unable to fully recover without additional federal assistance.”

Colorado has been hit by 19 fires in 15 counties this year, Colorado’s worst season in a decade.

Obama approved aid for the state June 28.That federal money was to help local governments and non-profits recover from the 87,284-acre High Park fire in Larimer County, which claimed 259 homes and one life, and the Waldo Canyon fire in El Paso County, where flames consumed 18,247 acres and 347 homes while claiming two lives .

The president’s declaration did not come with a dollar amount, and the state’s new request does not affix a price tag for recovery.

Post Fire Flooding on the Front Range

In this Monday evening, July 30, 2012 photo provided by the Colorado Department of Transportation, a pickup truck is engulfed by a mudslide on U.S. 24 west of Cascade, Colo. The brown area visible on the mountain at left, behind a row of trees, was burned in the Waldo Canyon wildfire. Authorities are warning people who live in and around the area burned by the Waldo Canyon wildfire to watch out for possible flooding and mudslides triggered by rain which started on Monday.


Here’s
a link to a story from the Denver Post, and below is an excerpt.

Typical monsoon-season rainfall in the High Park area for the month ranges from 2 to 2½ inches, but this year, the amount more than doubled to nearly 6 inches in some spots, bringing an increased chance of mud, ash and debris
Piles of mud, rocks and other debris washed across U.S. 24 near Cascade on Tuesday after heavy rain Monday. The highway was closed for several hours. (Mark Reis, Colorado Springs Gazette)
slides.

“July and August typically have thunderstorm activity, so it would not have been a total fluke to have some locally heavy rains,” said Nolan Doesken, the state climatologist based at Colorado State University’s Department of Atmospheric Science. “But 5 inches in one month in Colorado’s dry climate is a lot.”

Most of the rain fell July 6-9, washing ash into the Cache la Poudre Canyon and coating many of the river banks with black sludge. Although much of the ash had cleared by the next week, erosion and mudslides continue to be a concern.

The area near Colorado Springs, where the Waldo Canyon fire ripped through 18,247 acres and destroyed 346 homes, is experiencing similar conditions, with 10 flood advisories issued for the month of July already.

“We hardly ever issue flood advisories up there, probably just one or two,” said Tom Magnuson, warning coordination meteorologist for the weather center’s Pueblo office. “Typically they don’t get big rainfalls up there, and they don’t do much.”

Five of the 10 advisories were issued Monday night, Magnuson said, with heavy rains causing gravel to slide from the burn area onto U.S. 24 west of Cascade.

“I went out there this morning to take pictures, and the pile of granite, just the pebble size, was probably 8 feet deep to the side of the road and 5 feet deep in the middle of the road,” he said.

Emergency management and U.S. Forest Service officials began creating barriers of sandbags last week around homes that survived the Waldo Canyon blaze and were able to prevent floodwater from reaching them.

More on the Historic Vegetation Ecology Dust-up

Emily Guerin posted this on the High Country News Goat Blog. Here is an excerpt.

The team from Wyoming rounded out their studies by criticizing common forest management practices. Except where necessary to protect homes, they believe widespread culling of small trees and understory shrubs to thin forests, the doctrine behind projects like Arizona’s ambitious 4 Forest Restoration Initiative, is a bad idea. This strategy, they say, will “move dry forests outside their historical range of variability, rather than restore them, probably with negative consequences for biological diversity.”

I can hardly believe that they are still attached to the concept of HRV; however, I understand if you’re a historic vegetation ecologist, it is difficult to let go of that concept. Why do they care so much (being from Wyoming.. about intervening in Arizona?).

Baker doesn’t disagree with Swetnam’s argument that current climate conditions are likely to make modern fires worse. He and Williams just hope to place the current rash of wildfire in its historic context. Big, severe wildfires are “a natural part of our forest ecosystems; we maybe didn’t know that until recently. But now that we do we just have to figure out how to live with that.”

I agree we have to live with current conditions, but also think we need to be clear in our logic as to exactly why we think the past is relevant. It seems like they are saying “we need to do things that are like the past.”

There were a couple of interesting comments also. like this..

Rather than surveyors’ reports, I would put more trust in photographic studies such as Yellow Ore, Yellow Hair, Yellow Pine, which compared multiple photos of the Black Hills taken from the same spots in 1874 and 1974. You can really see how much thicker those ponderosa pine forests became over 100 years

And this exchange between Baker and

We appreciate HCN covering this topic, which obviously is controversial, but there is certainly a need for more research and more public discussion. There is much at stake, as these forests are among our most beautiful western forests, they are near many of our communities, fires are burning out of them into our communities, and there is no doubt that they are in need of ecological restoration after a century of intense logging and livestock grazing. Our research differs, however, in providing distinct messages that we hope will be carefully considered by scientists and the public. The evidence we have published shows that these forests historically burned at high-severity, meaning a large fraction of trees were killed. This occurred when fuels were at natural levels, before any of the widespread EuroAmerican land uses altered these forests. The implication is that today’s fuel-reduction programs that promise to restore fuels to their natural levels likely may not work, since severe fires were common when fuels were at these natural levels. Inside or near ponderosa pine forests or dry mixed-conifer forests thus are really bad places to live, even if fuel-reduction has been undertaken. Alternative approaches for western communities to protect themselves are in my book: Baker, W.L. 2009. Fire ecology in Rocky Mountain forests. Island Press, Washington, D.C.

Dr. Brown’s comment about creationists is just sour grapes, probably because he does not like the findings of our research. He knows very well that our research is published in top, peer-reviewed scientific journals, the same kinds of scientific journals where he publishes. These scientific journals do not publish creationism. The journals are well-respected, including Ecological Monographs and Ecosphere, published by the Ecological Society of America. Our research was funded by the National Science Foundation and the U.S. Department of Agriculture, which have extremely competitive peer-reviewed grant programs. Dr. Brown’s comment is unfounded and also denigrating to the scientific enterprise in general and the many scientists who contribute to these programs and scientific journals.

Also, the dataset is not tiny, as Dr. Brown implied. There are >13,000 records from the surveyors across about 4 million acres of land in three states in the central study, which is published in Global Ecology and Biogeography (see below). Moreover, the records are as good or better than the kinds of data Dr. Brown and Swetnam rely upon. Even in the most heavily sampled area in Northern Arizona (Abella and Denton 2009), the tree-ring data that form the basis for our study (75 trees/ha) are more abundant than in tree-ring studies (69 trees/ha) and much more abundant than government weather data and government forest-monitoring (FIA) data that are considered a sound basis for scientific understanding of climate and forests. Also, the accuracy and validity of the survey data were validated in an extensive scientific trial, which was published in 2011 in Ecological Monographs, one of the top ecological science journals in the world. Moreover, the tree-ring data that Drs. Brown and Swetnam rely upon are very spatially limited, generally from small, isolated studies totally at most thousands of acres, not millions of acres as in our study.

Dr. Swetnam is incorrect. We published new evidence that the size of high-severity fire patches and the rate of high-severity fire is no different now than it was in a comparable period before EuroAmerican settlement, in natural forests. This study is in Ecosystems (see below).

Readers interested in seeing the actual evidence in these published studies can find them using the citations and links below, but may have to access them via subscriptions, or can email me at [email protected]. Bill Baker

and Peter Brown

I would like to briefly follow up on my comments to Ms. Guerin with first an apology concerning my ill-chosen comparison of this recent work from Drs. Williams and Baker to creationists’ efforts: Certainly W&B are publishing their research in peer-reviewed journal articles and are obviously following scientific methods and ethics, in very strong contrast to the creationists. I sincerely apologize to both Drs. Williams and Baker for that comparison.

However, my point was that we have been here before. This new data set is, in my opinion, just one more in a series of approaches that appears from the outside to be part of an agenda to tear down any efforts – however well-meant, however well-documented – at ecological restoration of surface fire regimes in ponderosa pine ecosystems around the western US. So to my follow-up question about the data presented in their work: Even if their model of forest structure based on the GLO data is correct, there is still a grand leap from there to fire behavior. Current fires in ponderosa have contained large portions of active crown fire, with complete tree mortality over 1000s or even 10000s of acres. Tree recruitment into recent fires on the Front Range (e.g, Black Tiger, Buffalo Ck, Bobcat Gulch, Hayman, etc) as well as many other areas around the SW in particular has been either very slow or nonexistent. Considering the lack of seed sources that have occurred across some very extensive landscapes and the relatively large size and lack of mobility of ponderosa seed, how does the lack of recruitment after recent fires fit with their model of past fire behavior, if the current fires are within the HRV according to this model? Most certainly current forests are not coming back as dense stands of even-aged trees. Right there something is incomplete in the model, and strongly suggests that their interpretations of the GLO data – and hence implications contained in these data for ecological restoration efforts – are flawed.

and of course I enjoy a fellow bringing up evolutionary characteristics of forest trees (after all “ecosystems” don’t evolve; species do)

It is in the best practice of science that widely accepted paradigms are challenged from time to time if for no other reason that it forces us to step back and really examine what we think we know. I think the research mentioned here certainly falls into that category as we work to expand our understanding of fire processes in western ecosystems.

The biggest difficulty I’m having with the conclusions of Drs. Baker and Williams is that it seems counter-intuitive to the evolutionary selection of traits in ponderosa pine — thick bark, fast juvenile growth, and good self-pruning — which seem tailor made for a low-intensity fire regime. As opposed to lodgepole pine — thin bark, early maturation, serotinous cones, poor stem exclusion — which would benefit from an infrequent high-intesity regime. And with mixed-conifer stands the story is more complicated of course, hence mixed-severity regimes being thought of as common in them (with the true firs in areas mostly devoid of fire).

It’s this incongruity that I’m trying to reconcile with the idea that infrequent high-severity fires were the historic norm across a wide array of western forests.

And this historical comment from Clark Stoner:

Although clearly a clever use of GLO notes, I think the GLO survey notes should be read from the point of view of the surveyors who wrote them and in the context of the times.

The GLO surveyors weren’t exactly welcomed guests in those days. The U.S. Government was at war with various indian tribes at various times across the west. There is little doubt that the indians understood the surveyors preceded the western movement of the white man, which they likely considered threatening. The survey parties weren’t exactly all that well paid, and they likely often feared for their safety. So, I would have taken a rather tongue in cheek approach to the reliance of the GLO notes when they were describing the landscape (they most often served future boundary retracement surveyors needs quite well). In my experience with reading GLO notes in California and Nevada, dating back from the 1860s through the 1880s, I find that they weren’t exactly describing forested land in terms of any measurable density. Their descriptions of forested land were actually quite general and subjective. You were taking a gamble if you were a speculator in the GLO office trying to decide whether or not you wanted to buy the land described. So in the study it appears they found quite a number of bearing trees (which is cool), but their existence is no testament to the density of the forest at the time the GLO surveyors marked them.

Also, why is reliance on data from the 1880s so relevant? I seem to recall Lewis and Clark witnessing the indians setting fire to the landscape in 1804, which I believe it is now accepted that the indians were performing their own forestry management practices prior to the arrival of the Europeans, and most agree their practices were to promote fertile hunting grounds. So, as the indians got wrapped up in wars with the U.S. Government, it might be safe to say that their normal forestry management practices were disrupted and in various cases the forests appeared quite different by the time the GLO surveyors arrived. The GLO surveyors in many cases might not have been witnessing the forests in their centuries prior “pre-existing” state (saving the term “natural state”).

There are other interesting comments as well.

Bottom line, many people have interesting perspectives on this and scientific journals and the general press only give us a piece of the story, if left to their own devices. Further, many people’s disciplines and experiences can be relevant from understanding surveyors to tree evolution.

Thanks to Emily for taking this on!

Some Excerpts from Rand Study

Rand report here.. thought I’d excerpt some of this on topics (economic analysis of fires) we have discussed on this blog…
from pages 27-30.

Analysis
There are several important costs and resource value changes that we
did not include in our analysis because the data did not exist or because
the data or methods required to estimate the values were not yet sufficiently
well developed to justify including them. These included nonmarket
values, federal disaster assistance, timber losses, and public
health effects.

Nonmarket Values
There is a growing literature on how fires affect nonmarket resources,
such as wildlife habitats, watersheds, public health, cultural heritage,
and recreational services. But the data and methods required to quantify
these resource changes are not yet adequate to generate compelling
estimates of these nonmarket values (Abt, Prestemon, and Gebert,
2008; Hesseln and Rideout, 1999; Venn and Calkin, 2007).

Results from the small number of studies that have attempted
such valuations reveal complex effects of wildfires that may correspond
to large positive or negative value changes and to changes that
evolve dynamically over time. For instance, Englin, Holmes, and Lutz
(2008) reported complex time-varying effects from fires on recreational
demand, with demand increasing in the years immediately following a
fire but significantly decreasing in later decades.
Similarly, some fire effects result in both positive and negative
changes, such as the effects of fire on watersheds. Typically, fires
increase water yield, but they also increase sedimentation in the water.
Potts, Peterson, and Zurring (1985) attempted to value these positive
and negative outcomes, finding that the benefits of additional water
availability exceeded the costs of additional sedimentation by a factor
of more than 1,000 in some regions.

Other studies have suggested that the social value of preventing
large fires may be extremely high. For instance, using a contingent
valuation approach to estimating willingness to pay, Loomis and
Gonzales-Caban (1998) found that the societal value of protecting
the first 1,000 acres of northern spotted owl habitat in California and
Oregon amounted to $25 per household, a figure that Venn and Calkin
(2007) note is “greater than the annual national fire suppression expenditure
by the Forest Service in recent high cost firefighting years.”

The uncertainties in nonmarket values have led recent Forest Service
guidance on cost-risk analyses to suggest estimating the minimum
value of nonmarket effects that would be implied by available interventions,
rather than trying to estimate the nonmarket effects themselves
(Calkin, Hyde, et al., 2007).

Federal Disaster Assistance

In principle, federal disaster assistance funding to states, localities, and
individuals affected by wildfires should be known to the federal government.
However, a recent Congressional Research Service report on
wildfires reported that public data on Federal Emergency Management
Agency fire disaster assistance were not available (Gorte, 2006).
A portion of this funding goes to reimbursing states and local
governments for the costs they incur in suppressing wildfires. Because
we have already estimated state and local suppression costs, including
the costs of federal reimbursements in our calculations would result in
double-counting of some suppression costs. Therefore, this portion of
the federal disaster assistance budget is omitted from the analysis.
Timber Losses
While past studies have attributed considerable financial value to lost
timber (e.g., 20 percent of total losses for four large fires reviewed by
Abt, Prestemon, and Gebert, 2008), such estimates reveal widely varying
assumptions about the commercial viability of the lost timber, the
proportion of existing timber lost in burned areas, and the value of salvageable
burned timber. Some estimates of timber losses consider only
Forest Service timber lease values or lost Forest Service timber sales,
while others have considered the likely wealth transfers resulting from
the market effects of shocks to the timber supply.
Butry et al. (2001), for instance, examined the welfare effects of
the timber price reductions resulting from a short-term glut of salvaged
timber and later price increases resulting from local shortages of timber,
which they hypothesized would follow the 1998 wildfires in northeast
Florida. Their analysis suggested that short-term gains to consumers
are roughly matched by long-term gains to producers, with a net loss
resulting from the effects on owners of damaged timber.
We adopted a social cost perspective for our analyses, as opposed
to considering just the cost to the Forest Service. As such, to include
timber losses in our analysis, we would have required an estimate of the
welfare changes resulting from timber losses that are net of the types
of wealth transfers described by Butry et al. (2001). While that study
produced such an estimate for one fire in 1998, we do not believe that
these results can be generalized to timber losses nationally, and other,
more general estimates of timber resource value changes of this kind
were not available for us to incorporate into our analysis.

Public Health Effects
Fires degrade air quality in ways that are harmful and can exacerbate
asthma and bronchitis, reducing quality of life, increasing hospital
admissions, and contributing to deaths. But attributing the prevention of morbidity and mortality to fire suppression is complicated by uncertainties and great variation in the numbers of people affected by
individual fires, the severity of harms they might be expected to suffer,
and the valuation of those harms.

Sorenson et al. (1999) noted that, during the 1998 Florida wildfires,
admissions at some regional hospitals increased 91 percent for
asthma and 132 percent for bronchitis over the same period in the
prior year, though the atmospheric conditions that contributed to fire
risk in 1998 could have affected respiratory conditions as well. Butry
et al. (2001) used treatment costs as a proxy for the societal costs of
smoke from the same Florida fires, concluding that they represented
a small cost relative to other costs of the fires. Similarly, Rittmaster et
al. (2006) evaluated the health effects of a large fire in Canada. Unfortunately,
the results of each of these studies are likely unique to the fires
they investigated. We know of no analyses offering national or peracre-
burned estimates of the public health costs of smoke, so we could
not include these values in our analysis.
Next, we discuss the estimated costs of prospective aircraft. Ultimately,
it is these aircraft costs against which we compared the estimated
costs of large fires.