Jerry Williams, former National Director of Fire and Aviation for the U.S. Forest Service, was one of the keynote speakers at the Large Fire Conference that is wrapping up Friday in Missoula, Montana. I was so impressed with Mr. Williams’ talk that I asked him if I could put a portion of it here on Wildfire Today.
He knows what he is talking about when it comes to wildland fire. He started his career in the USFS as a firefighter, became a smokejumper, and worked his way up through the position of Director of Fire and Aviation for the agency’s Northern Region before migrating east to D.C.
Below is an excerpt from Mr. William’s talk, which was titled, Between a Rock and a Hard Place; a Growing Wildfire Threat and the Urgency to Adapt Protection Strategies:
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“…Let me come back to these five areas that I believe need attention if we are to get out from between this “rock and this hard place.” They might be the elements of a next generation wildfire protection strategy:
- Analysis at the program level (fire management and land management)
- The regulatory exemption for wildfires
- Accounting for total wildfire impacts
- Linking land management direction to wildfire risks
- Firefighting’s limitations
Analysis at the program level:
Last August (2013), the GAO issued a fire-related report that expressed concern over,
…a firefighting culture that values experience and history over data and scientific analysis.
The Fire Services can be proud of their “can-do” attitude and their traditions, but GAO has a point.
In many areas, we have done a good job with project-level or implementation analysis, but many of the larger program-level or strategic questions are left unanswered. Many of us are familiar with the National Fire Management Analysis System (NFMAS), Aerial Delivered Firefighter Studies, Aerial Platform Studies, engine studies, firefighter qualification studies, mobilization reports and a host of other analyses to determine the mix, positioning, and numbers of “the most efficient level” of firefighting assets.
We do very, very well at suppression almost all of the time, but – given the enormity of consequences involved when we fall short – we have to ask if we might be fine tuning the tactical applications of a flawed strategy; a presumed strategy; one we adopted without benefit of rigorous analysis. If a suppression-centric strategy has clear limits of effectiveness at the highest level of threat…and the highest level of threat is becoming more common…, what strategy might be more effective under these conditions?
What would a rigorous analysis show, if we evaluated the short- and long-term social, economic, and ecological costs, risks, and benefits among alternative protection strategies? How does suppression “pencil-out” if we continue to emphasize it in the future? What are the risks to public values like water, wildlife, air quality and other values if we choose to protect private property and houses over public lands? What does it mean if we accept that large fires are inevitable and “let nature take its course?” What are the pros and cons if we accelerate fuels reduction work to more meaningful scales?
Of the alternatives we might have, which one (or combinations of several) best meets our wildfire protection objective? Over the long-term, which is economically feasible and ecologically appropriate?
This need for program-level or strategic analysis is not confined to the Fire Services.
In land management activities, we are required to evaluate proposed actions at the project level, but – again – at the program level it is a different story. If, for example, there is a need to reduce wildfire threats on…say 1,000 acres…we will enlist a number of interdisciplinary specialists and pull together an Environmental Assessment (EA) to navigate the selective logging, thinning and prescribed burning impacts that are likely to effect the project area. Before it is completed, we will have probably spent most of the project’s allocation. The project plan will probably take a couple of years to complete and gain internal approval. Chances are better than even that the project will get appealed or scaled-down. It may stall altogether for the weight of its costs and constraints.
On the other hand, in the absence of action, the wildfire threat will continue to incubate. When the wildfire takes off, many will be surprised or, even, outraged. This wildfire may grow to many times the size of our proposed project, cost many times more than the size of our project, and result in many times greater impacts than our project. Before the smoke clears, intense scrutiny will be brought to bear in how the incident was managed. Operational performance will be reviewed and, maybe, investigated. It may be litigated. An Incident Commander may get sued.
For all of the scrutiny that will be brought to bear after-the-fact, not much attention will be directed to the causal and contributory factors that fueled this disaster. There are no regulatory requirements to evaluate the factors that predispose wildfires. In fact, wildfires are exempt from the kind of analysis that that is required for the proposed actions that would prevent them.
When it comes to the best way to protect against high-consequence wildfires, whether it’s Biswell’s balanced 1/3-1/3-1/3 formula or…
- Double-down on suppression,
- Protect houses, let the rest burn,
- Accept that large fires are inevitable and “let nature take its course,” or,
- Accelerate fuel reduction work in high-hazard, high-risk forests,
- Or, any other option we might have.
Evidence- and science-based analysis helps us find…or, at least, document…the optimal, most sustainable alternative and avoid settling on the most expedient – but socially, economically and ecologically wrong solution over the long-term. Credible analysis helps us understand what problems our “solutions” may bring over time. Analysis done right helps us avoid unintended consequences.
The regulatory exemption for wildfires:
Many of the laws, regulations, and policies that govern the management of federal lands were enacted in a cooler, wetter climate cycle; before the onset of drought. In the 1950’s, 1960’s and 1970’s, the science of fire ecology was in its infancy and not many plans addressed the disturbance dynamics of fire. With the exception of the 1964 Wilderness Act, most legislation has been silent on fire’s ecological role. Instead, while the regulatory framework acknowledges wildfire’s negative impacts, it also tends to regulate fire-use through a negative-impact prism. In the laws’ interpretation, fire’s long-term, less discernable benefits must “compete” against its short-term, obvious impacts. This disparity…this bias…begs attention in fire-dependent ecosystems.
In practice, the regulations typically subject proposed actions to series of requirements and a long, costly planning process, but the wildfire outcome…in the absence of treatment…gets a “pass.” In the language of the law, wildfire impacts are considered an “act of God” or an “accident of nature.” Their impacts fall under emergency exemptions; they don’t “count” against air quality, greenhouse gas emissions, endangered species habitat, watershed integrity or other objectives. In regulation, there is no consequence for “no action.” The West’s large fire problem in dry forests is being abetted by a regulatory framework that makes the high-severity wildfire outcome all but certain. This bias in the law is almost certainly perpetuating the large fire problem in the West’s dry, fire-dependent ecosystems.
Are safer, more cost-effective wildfire protection strategies unattainable in fire-prone ecosystems because the selective logging, under-story thinning and prescribed burning projects that they might require perceived as too contentious, too costly or too risky? What are the tradeoffs? Are healthy, resilient and diverse fire-adapted ecosystems realistic if the treatments that get them there are constrained by a regulatory bent for stasis?
Dismissing these wildfires as an “act of God” or an “accident of nature” does not hold when we consider the effects of one-hundred years of man-induced changes…especially in the West’s interior dry forests. These changes have predisposed these forests to severe burning and large fire potential. Removing the wildfire exemption in altered dry forests strikes the perception that “no-action” equates to no-consequence. In fire-prone ecosystems, it forces the realization that significant social, economic and ecological effects can and do result from “no-action.”
Full accounting for total wildfire impacts:
Over the years, Agency Administrators, Comptrollers and Budget Examiners have been critical of federal spending on wildfires. Some believe that there is a lot of waste in firefighting, that the Fire Services spend money recklessly or that Incident Management Teams spend so much simply because they can.
We are between a rock and a hard place because many of the highest cost wildfires involve threats to high values (e.g. houses and private property). Any opportunity to rein in spending on these kinds of fires is invariably met with public and political demands to do (and spend) more, regardless of effectiveness. It doesn’t matter that fuel build-ups went un-addressed for years before the incident. It is never a good time to broker savings in the middle of an emergency.
A full accounting of wildfire costs includes much more than the suppression component. Private property and infrastructure losses, natural resource damages, burned area emergency re-habilitation costs, human health impacts, post-fire impacts (e.g. mudslides and flooding), and settlement costs related to lawsuits are all a part of large fires “true costs.” Some high-consequence wildfires have control costs that represent less than 15% of the true, total costs. For example, the Rodeo-Chediski Fire cost $46 million to control, but another $308 million to cover losses and damages. It is not unusual for property losses and natural resource damages to exceed three-quarters of total wildfire costs (Western Forestry Leadership Coalition, 2010).
The costs of reacting to an emergency, rather than proactively preventing a disaster are where the real costs lay. The costs of “no-action” are enormous…and getting bigger.
When Administration Budget Examiners and Congressional Appropriators confront the full costs of these wildfires, they might better support fuel reduction strategies that, before, were dismissed as too costly.
Linking land management direction to wildfire risks:
Modern large wildfires are often blamed on yesterday’s practices (e.g. a century of fire exclusion, high-grade logging and over-grazing). But, the mega-fire assessment revealed a number of examples where many of today’s land management plans call for maintaining dense, late-successional conditions un-interrupted over broad landscapes for a number of resource aims (watershed protection, endangered species habitat, roadless natural areas, and others).
Perhaps after decades of over-exploitation, our notions of protection became aligned with an emphasis on preservation and maintaining undisturbed conditions. In fire-dependent forests, this is proving a costly and unsustainable approach. In fact, we may actually be imperiling the very values we hope to sustain by insisting that altered fire-dependent forests can be held in stasis by relying on suppression.
A policy requirement that connects the long-term risks of land management decisions to likely wildfire outcomes needs to be put in place in the post-fire review process. This linkage is seen as critical in order that there be a more defensible basis to revise land management plan objectives as the means to reduce wildfire impacts. Unless we better manage expectations in dry, fire-dependent ecosystems, we run the risk of “piling on” more fuel and adding more complexity onto an already-dangerous situation.
Firefighting’s limitations:
There is another issue that waits on the Fire Services; maybe the most difficult, but a most important one. The Fire Services need to acknowledge the limits of suppression. It is time to make clear the need to confront the high-hazard forest conditions that predispose or set the stage for many of these disastrous wildfires. The structural fire services did something similar nearly a century ago, when they turned to managing for safer, more fire-resistant conditions in our cities instead of only building bigger fire departments.
As long as public and political perceptions hold that bigger and better firefighting assets can solve the large wildfire problem, real solutions will remain elusive. Public and political perceptions are easily seduced into thinking that more and larger assets will promise solutions. We sometimes encourage that perception. When bigger budgets, bigger aircraft, bigger engines and bigger organizations don’t solve the large wildfire problem, public and political scrutiny will turn to failures in operational performance. As you are perhaps already seeing, the Fire Services will – increasingly — find themselves being blamed or sued for wildfire outcomes.”
