The National Fire Plan: Federal Agencies Are Not Organized to	 
Effectively and Efficiently Implement the Plan (31-JUL-01,	 
GAO-01-1022T).							 
								 
This testimony discusses how federal agencies conduct fire	 
management under the National Fire Plan. Effective fire 	 
management requires coordination, consistency, and agreement	 
among five federal land management agencies in two		 
departments--the National Park Service, the Fish and Wildlife	 
Service, the Bureau of Land Management, and the Bureau of Indian 
Affairs in the Department of the Interior and the Forest Service 
in the Department of Agriculture. Human activities, especially	 
the federal government's decades-old policy of suppressing all	 
wild fires, have led to dangerous accumulations of felled trees  
and other dead vegetation on federal lands. As a result,	 
conditions on 211 million acres continue to deteriorate. The	 
National Fire Plan represents the latest effort to address	 
wildland fire on federal lands. Two conditions set this effort	 
apart from earlier efforts. First, Congress has to recognize the 
need to sustain increased funding for wildland fire management in
future fiscal years. Second, Congress has issued direction to	 
reduce the risk of wildland fire in the wildland-urban interface.
However, many of the policy's guiding principles and		 
recommendations have not been implemented. The failure of the	 
five federal land management agencies to incorporate into the	 
National Fire Plan many of the federal wildland fire management  
policy's guiding principles and recommendations can be traced to 
their reluctance to change their traditional organizational	 
structures of federal wildland fire management. As a result, the 
five agencies continue to plan and manage wildland fire 	 
management activities primarily on an agency-by-agency and	 
unit-by-unit basis.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-01-1022T					        
    ACCNO:   A01499						        
  TITLE:     The National Fire Plan: Federal Agencies Are Not	      
             Organized to Effectively and Efficiently Implement the Plan      
     DATE:   07/31/2001 
  SUBJECT:   Environmental monitoring				 
	     Forest management					 
	     Interagency relations				 
	     Emergency preparedness				 

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GAO-01-1022T
     
Testimony Before the Subcommittee on Forests and Forest Health, Committee on
Resources, House of Representatives

United States General Accounting Office

GAO For Release on Delivery Expected at 3: 00 Tuesday, July 31, 2001 THE
NATIONAL FIRE

PLAN Federal Agencies Are Not Organized to Effectively and Efficiently
Implement the Plan

Statement of Barry T. Hill Director, Natural Resources and Environment

GAO- 01- 1022T

Page 1 GAO- 01- 1022T The National Fire Plan

Mr. Chairman and Members of the Subcommittee: We are here today to discuss
the results of our preliminary work for you on the implementation of the
National Fire Plan. The National Fire Plan is not a single, cohesive
document. Rather, it is composed of various documents, including (1) a
September 8, 2000, report 1 from the Secretaries of the Interior and of
Agriculture to the President of the United States in response to the
wildland fires in 2000; (2) congressional direction accompanying substantial
new appropriations for wildland fire management for fiscal year 2001; and
(3) several approved and draft strategies to implement all or parts of the
plan.

In addition, the 1995 federal wildland fire management policy, 2 updated in
2001, 3 provides the philosophical and policy foundation for federal
interagency fire management activities conducted under the National Fire
Plan. Incorporating the policy's guiding principles and recommendations into
the plan presents unusual, if not unique, challenges to traditional
organizational structures. Wildland fires do not recognize the
administrative boundaries of federal land units. Therefore, the policy
requires coordination, consistency, and agreement among five federal land
management agencies in two departments- the National Park Service, the Fish
and Wildlife Service, the Bureau of Land Management, and the Bureau of
Indian Affairs within the Department of the Interior and the Forest Service
within the Department of Agriculture. Moreover, an effective strategy to
reduce the risk of wildland fire requires a full range of fire management
activities, including management- ignited fires (prescribed fires) and other
fuel treatments, such as thinning. Therefore, the policy requires an
interdisciplinary approach in which federal fire managers must forge new
working relationships with other disciplines

1 Managing the Impact of Wildfires on Communities and the Environment, A
Report to the President In Response to the Wildfires of 2000, Secretaries of
the Interior and of Agriculture (Sept. 8, 2000).

2 Federal Wildland Fire Management Policy and Program Review, Report to the
Secretaries of the Interior and of Agriculture by an Interagency Federal
Wildland Fire Policy Review Working Group (Dec. 18, 1995).

3 Review and Update of the 1995 Federal Wildland Fire Management Policy,
Report to the Secretaries of the Interior, of Agriculture, of Energy, of
Defense, and of Commerce; the Administrator, Environmental Protection
Agency; and the Director, Federal Emergency Management Agency, by an
Interagency Federal Wildland Fire Policy Review Working Group (Jan. 2001).

Page 2 GAO- 01- 1022T The National Fire Plan

within the agencies, including those responsible for wildlife and fisheries
and vegetation and watershed management.

Federal and state officials estimate that $30 billion will be needed over
the next 10 years to implement the National Fire Plan. Toward this end, the
Congress appropriated almost $2.9 billion for Wildland Fire Management for
fiscal year 2001. At your request, we are reviewing whether the five federal
land management agencies are spending this money in an efficient, effective,
and timely manner. To date, we have focused our work primarily on efforts to
reduce dangerous accumulations of hazardous fuels and firefighting
management and preparedness.

In summary, the preliminary information we have gathered to date suggests
the following:

 Human activities, especially the federal government's decades- old policy
of suppressing all wildland fires, including naturally occurring ones, have
resulted in dangerous accumulations of hazardous fuels on federal lands. As
a result, conditions on 211 million acres, or almost one- third of all
federal lands, continue to deteriorate. According to the federal wildland
fire management policy, these conditions have increased the probability of
large, intense wildland fires beyond any scale yet witnessed. Coupled with
the explosive growth of people and structures in areas where human
development meets or intermingles with undeveloped wildland- the wildland-
urban interface- these fires will, in turn, increase the risk to
communities, watersheds, ecosystems, and species. They will also place in
jeopardy the lives of the public as well as the lives of the firefighters
charged with controlling or suppressing them.

 The National Fire Plan represents the latest effort to address wildland
fire on federal lands. Two conditions set this effort apart from prior
efforts to reduce the risk of wildland fire: (1) congressional committee
recognition of the need to sustain increased funding for wildland fire
management in future fiscal years and (2) congressional committee direction
to reduce the risk of wildland fire in the wildland- urban interface.
However, although the federal wildland fire management policy is intended to
provide the policy foundation for the National Fire Plan, many of the
policy's guiding principles and recommendations- especially those that
present challenges to traditional organizational structures- have not been
implemented. Lacking the coordination, consistency, and agreement called for
in the federal wildland fire management policy, the five federal land
management agencies cannot ensure, among other things, that they (1) are
allocating funds to the highest- risk communities and ecosystems, (2) are
adequately

Page 3 GAO- 01- 1022T The National Fire Plan

prepared to fight wildland fires in 2001, and (3) can account accurately for
how they spend the funds and what they accomplish with them.

 The failure of the five federal land management agencies to incorporate
into the National Fire Plan many of the federal wildland fire management
policy's guiding principles and recommendations can be traced to their
reluctance to change their traditional organizational structures of federal
wildland fire management. As a result, the five agencies continue to plan
and manage wildland fire management activities primarily on an agencyby-
agency and unit- by- unit basis. Moreover, although implementing the
National Fire Plan in an efficient, effective, and timely manner will
require an interdisciplinary approach, federal fire managers and managers in
other disciplines within the agencies- including those responsible for
wildlife and fisheries and vegetation and watershed management- have been
reluctant to forge the necessary new working relationships.

For a number of years, both the Congress and the administration have been
made aware of the increasingly grave risk of wildland fire posed by the
buildup of brush and other hazardous vegetation on federal lands.

The 1988 wildland fires that burned Yellowstone National Park and millions
of acres of other public and private land resulted in a 1994 report by the
statutorily established National Commission on Wildfire Disasters. 4 The
Commission stated:

"The vegetative conditions that have resulted from past management policies
have created a fire environment so disaster- prone in many areas that it
will periodically and tragically overwhelm our best efforts at fire
prevention and suppression. The resulting loss of life and property, damage
to natural resources, and enormous costs to the public treasury, are
preventable. If the warning in this report is not heeded, and preventative
actions are not aggressively pursued, the costs will, in our opinion,
continue to escalate."

The Commission observed: "The question is no longer if policy- makers will
face disastrous wildfires and their enormous costs, but when." The when came
that very year. The 1994 fire season resulted in 34 fatalities, including 14
firefighters on Storm King Mountain in Colorado. These deaths, coupled with
a growing recognition of the fire problems caused by the

4 Report of the National Commission on Wildfire Disasters (1994). The
National Commission on Wildfire Disasters was established on May 9, 1990, by
the Wildfire Disaster Recovery Act of 1989 (Pub. L. No. 101- 286).
Conditions on Federal

Lands Continue to Deteriorate

Page 4 GAO- 01- 1022T The National Fire Plan

accumulation of hazardous fuels, resulted in the first comprehensive federal
wildland fire management policy for the departments of the Interior and of
Agriculture. The December 1995 policy stated:

"The challenge of managing wildland fire in the United States is increasing
in complexity and magnitude. Catastrophic wildfire now threatens millions of
wildland acres, particularly where vegetation patterns have been altered by
past land- use practices and a century of fire suppression. Serious and
potentially permanent ecological deterioration is possible where fuel loads
exceed historical conditions. Enormous public and private values are at high
risk, and our nation's capability to respond to this threat is becoming
overextended."

In the aftermath of the escape of a prescribed fire at Cerro Grande, New
Mexico, in May 2000, the Secretaries of the Interior and of Agriculture
requested a review of the 1995 federal wildland fire management policy and
its implementation. According to the 2001 update, as a result of excluding
fire from federal lands, conditions on these lands continue to deteriorate.
The update observed that the fire hazard situation is worse than previously
understood and stated:

"The task before us- reintroducing fire- is both urgent and enormous.
Conditions on millions of acres of wildland increase the probability of
large, intense fires beyond any scale yet witnessed. These severe fires will
in turn increase the risk to humans, to property, and to the land upon which
our social and economic well being is so intimately intertwined."

The 2001 policy update also observed that the fire hazard situation in the
wildland- urban interface is more complex and extensive than was understood
in 1995. According to the update, the explosive growth in the wildland-
urban interface now puts entire communities and associated infrastructure,
as well as the socioeconomic fabric that holds communities together, at risk
from wildland fire. The update concluded that the fire problem in the
wildland- urban interface would continue to escalate as people continue to
move from urban to wildland areas in the twenty- first Century.

Page 5 GAO- 01- 1022T The National Fire Plan

The National Fire Plan represents the latest effort to address wildland fire
on federal lands. Two conditions set this effort apart from prior efforts to
reduce the risk of wildland fire: (1) congressional committee recognition of
the need to sustain increased funding for wildland fire management in future
fiscal years and (2) congressional committee direction to reduce the risk of
wildland fire in the wildland- urban interface. However, although the
federal wildland fire management policy is intended to provide the policy
foundation for the National Fire Plan, many of the policy's guiding
principles and recommendations- especially those that present challenges to
traditional organizational structures- have not been implemented. Lacking
the coordination, consistency, and agreement called for in the federal
wildland fire management policy, the five federal land management agencies
cannot ensure, among other things, that they (1) are allocating funds to the
highest- risk communities and ecosystems, (2) are adequately prepared to
fight wildland fires in 2001, and (3) can account accurately for how they
spend the funds and what they accomplish with them.

The Department of the Interior and Related Agencies Appropriations Act for
Fiscal Year 2001 required the Secretaries of the Interior and of
Agriculture, after consultation with state and local firefighting agencies,
to publish jointly in the Federal Register a list of all urban- wildland
interface communities, as defined by the Secretaries, within the vicinity of
federal lands that are at high risk from wildfire, as defined by the
Secretaries. Despite this directive, the five federal land management
agencies currently do not know how many communities are at high risk of
wildland fire, where they are located, or what it will cost to lower the
risk. Therefore, they cannot set priorities for treatment or inform the
Congress about how many will remain at high risk after appropriated funds
are expended.

Prior to publishing an initial list of communities, the Secretaries of the
Interior and of Agriculture did not define either "urban- wildland interface
communities" or "within the vicinity of federal lands that are at high risk
from wildfire." On January 4, 2001, the Secretaries published an initial
list in the Federal Register of 4,395 communities. However, as stated in the
notice, (1) 11 states did not respond or did not have lists of communities
available, (2) 5 states indicated that they did not have any at- risk
communities, and (3) each of the 34 states that did identify communities
used "criteria it determined appropriate for selecting communities at risk."

In February 2001, Interior and the Forest Service issued guidance intended
to refine and narrow the initial list of communities. The guidance defined
wildland- urban interface. It also identified three criteria for evaluating
the Implementation of the

National Fire Plan Lacks the Coordination, Consistency, and Agreement Called
for in the Federal Wildland Fire Management Policy

Highest- Risk Communities Have Not Been Identified

Here is what we have learned to date.

Page 6 GAO- 01- 1022T The National Fire Plan

risk to wildland- urban interface communities (fire behavior potential; risk
to social, cultural, and community resources; and fire protection
capability) and risk factors relating to each criterion. In addition, the
guidance included a discussion of fire behavior potential that provided some
general information on identifying fire risk. However, the guidance did not
specifically identify federal lands that are at high risk from wildland fire
rendering it difficult to identify urban- wildland interface communities
within the vicinity of such lands. Without this definition and with the
criteria and risk factors subject to broad interpretation by the states, the
list of at- risk communities ballooned to over 22,000 in May 2001. In
addition, two states with lands in the fire- prone interior West- California
and Idaho- did not revise their initial lists of communities on the basis of
the February guidance, stating that all of their communities on the initial
list should be considered high- risk.

At that time, the Secretaries of the Interior and of Agriculture said they
intended to continue to work collaboratively with states, tribes, local
leaders, and other interested parties to identify and set priorities for
specific treatment projects. However, rather than continue to work toward a
jointly published list of communities, Interior and the Forest Service went
their separate ways.

From the list of over 22,000 communities, Interior has identified 545
communities near its lands that it determined to be at "highest risk" by
assigning numeric values to the risk factors in the February 2001 guidance.
However, 278- or over half- of the communities are in three southeastern
states- Georgia, North Carolina, and Tennessee- that are not prone to severe
wildland fires. Conversely, since California and Idaho did not revise their
initial lists of communities on the basis of the February guidance, Interior
did not include any communities in these two fire- prone states. (See app. I
and II.)

Meanwhile, by October 2001, the Forest Service plans to develop its own
separate list of highest- risk communities from the list of over 22,000.
However, it plans to allow its nine regional offices to work individually
with states within their boundaries to develop nine separate lists of
highest- risk communities.

Page 7 GAO- 01- 1022T The National Fire Plan

In the interim, a group of federal, state, and private individuals has
prepared a draft 10- year strategy to implement the National Fire Plan. 5
This draft strategy emphasizes not only locally driven priority- setting but
also locally driven budget development, project planning and implementation,
monitoring, and reporting. However, without nationwide criteria to
differentiate risks among wildland- urban interface communities in different
states and geographical regions, the National Fire Plan will become little
more than a funding source that will not allow for accountability at the
national level and will not ensure that federally appropriated funds are
being spent in those wildland- urban interface communities at the highest
risk of wildland fire.

The coordination, consistency, and agreement required by the federal
wildland fire management policy is also missing from efforts by Interior and
the Forest Service to ensure that the nation is fully prepared to fight
future wildland fires.

For instance, the five federal land management agencies cannot agree on the
priority to be given to preparing fire management plans. Since 1995, federal
wildland fire management policy has required that every federally managed
area with burnable vegetation must have an approved fire management plan.
These plans are critical to determining preparedness needs for fighting
wildland fires because they identify, among other things, which wildland
fires should be suppressed and which should be allowed to burn. However, 6
years later, only the 60 units managed by the Bureau of Land Management have
fully complied with the policy. Of the remaining 1,323 units managed by the
other four federal land management agencies, 768- or 58 percent- still do
not have a plan that complies with the policy. These 768 units encompass
about 121 million acres- or 31 percent- of all the acres with burnable
vegetation managed by the four agencies. (See app. III.) Moreover, although
wildland fire does not recognize the administrative boundaries of federal
land units, federal fire management plans have been, and continue to be,
prepared on a unit- by- unit basis.

Similarly, rather than using one computer model to identify their
firepreparedness needs, the five federal land management agencies use three
different models. The Forest Service, the Bureau of Land Management,

5 A Collaborative Approach for Reducing Wildfire Risks To Communities and
the Environment: Ten- Year Comprehensive Strategy (Draft for Signature)( May
2001). Neither the Forest Service

Nor Interior Is Fully Prepared to Fight Future Wildland Fires

Page 8 GAO- 01- 1022T The National Fire Plan

and the Bureau of Indian Affairs use one model to determine their
preparedness needs, the National Park Service uses another, and the Fish and
Wildlife Service uses a third. Moreover, we have concerns about all three
models because they (1) do not consider conditions on non- federal lands in
the wildland- urban interface and elsewhere, and (2) stop at the
administrative boundaries of land units as opposed to providing the broader-
scale planning embraced in the federal wildland fire management policy.

Further, using the existing fire preparedness models, all five of the
federal land management agencies requested funds to hire, develop, and
support additional fire managers and firefighters, and all five have made
substantial progress in hiring the additional personnel. (See app. IV.)
However, in addressing firefighting equipment needs, it is a different
story. Even though the Congress gave the agencies the opportunity to request
the equipment needed to be fully prepared to fight future wildland fires,
the agencies did not identify their funding needs in a coordinated or
consistent fashion. Instead, each agency identified its own equipment needs.
Two of the agencies- the Forest Service and the Fish and Wildlife Service-
did not request the funding needed to procure the firefighting equipment
called for in their existing fire preparedness models. So for these two
agencies it is not clear when they will reach the firefighting capacity
envisioned with the funding provided for fiscal year 2001. The Forest
Service failed to ask for about $44 million that it needs to procure
hundreds of pieces of equipment, including fire engines, bulldozers, water
tenders, and trucks, as well as associated supplies. According to the Fish
and Wildlife Service, it was not aware that it was supposed to request about
$8 million that it needs to procure about 90 pieces of firefighting
equipment.

Lack of coordination, consistency, and agreement among the five federal land
management agencies extends to how they plan to measure accomplishments and
how they account for funds.

For instance, to ensure that the National Fire Plan accomplishes its
intended goals and objectives, the federal wildland fire management policy
requires federal agencies to establish and implement a clear, concise system
of accountability. However, Interior has not established any quantifiable
long- term or annual performance measures to gauge its progress in reducing
hazardous fuels. Conversely, the Forest Service plans to measure and report
on (1) the percent of wildland- urban interface areas with completed fuels
treatments and (2) the percent of all acres with fuel Lack of Coordination,

Consistency, and Agreement Extends to How Accomplishments Are Measured and
How Funds Are Accounted For

Page 9 GAO- 01- 1022T The National Fire Plan

levels meeting "condition class 1;" that is, where human activities have not
significantly altered historical fire regimes or where management activities
have successfully maintained or restored ecological integrity.

Similarly, Interior and the Forest Service are using different measures to
gauge their progress toward being fully prepared to fight future wildland
fires. Interior measures the percent of wildland fires contained during
initial attack while the Forest Service measures the amount of firefighting
resources that it can make available to fight a wildland fire.

Interior and the Forest Service also do not consistently account for how
they spend funds appropriated for wildland fire preparedness and
suppression. Prior to fiscal year 2001, both Interior and Forest Service
personnel normally assigned to managerial, administrative, and other staff
positions in their wildland fire management programs charged the first 8
hours of every workday to funds allocated for firefighting preparedness,
even when they were assigned to fighting wildland fires. However, beginning
with fiscal year 2001, all Forest Service personnel assigned to fighting
wildland fires now charge their entire time to funds allocated for
firefighting suppression. Although our ongoing work has not determined which
is more appropriate, the Forest Service's accounting change will reduce
funds charged to preparedness and increase funds charged to suppression, in
comparison with prior years and Interior's accounting for its funds
allocated for similar activities. As a result, the Congress has no
consistent basis for holding Interior and the Forest Service accountable.

According to the 2001 update, the failure to fully implement the 1995
federal wildland fire management policy resulted, in part, from the lack of
an entity with the authority to provide the necessary strategic direction,
leadership, coordination, conflict resolution, and oversight and evaluation
to the full range of affected agencies and disciplines. Although it is early
in the implementation of the National Fire Plan, it is clear that its
implementation also suffers from the lack of such an entity.

The five federal land management agencies have been reluctant to change
their traditional organizational structures of federal wildland fire
management. Because of this reluctance, they have failed to incorporate into
the National Fire Plan many of the federal wildland fire management policy's
guiding principles and recommendations. As a result, the five agencies
continue to plan and manage wildland fire management activities primarily on
an agency- by- agency and unit- by- unit basis. Moreover, although
implementing the National Fire Plan in an efficient, effective, and
Effective

Implementation of the National Fire Plan May Require Changes to Interior's
and the Forest Service's Existing Organizational Structures

Page 10 GAO- 01- 1022T The National Fire Plan

timely manner will require an interdisciplinary approach, federal fire
managers and managers in other disciplines within the agencies- including
those responsible for wildlife and fisheries and vegetation and watershed
management- have been reluctant to forge the necessary new working
relationships.

From a budgetary perspective, this continuation of a narrowly focused,
stovepipe approach will mean that funds appropriated for wildland fire
management may not be used in an efficient, effective, and timely manner.
There may be human consequences as well. For instance, the failure to
allocate funds for fuels reduction to the highest- risk communities and
ecosystems increases future risks not only to those communities and
ecosystems, but also to firefighters charged with controlling and
suppressing wildland fires.

We are continuing our review of the implementation of the National Fire
Plan. However, we agree with the federal wildland fire management policy
that the federal land management agencies must take action now to resolve
the wildland- urban interface problem. We would encourage the administration
and the Congress to consider all of the alternative organizational
structures identified in the policy, including establishing a single federal
wildland fire management entity with the authority to provide the necessary
strategic direction, leadership, coordination, conflict resolution, and
oversight and evaluation to the full range of affected agencies and
disciplines.

Mr. Chairman, this concludes my formal statement. I will be pleased to
respond to any questions that you or other Members of the Subcommittee may
have.

For future contacts regarding this statement, please contact Barry T. Hill
on (202) 512- 3841. Individuals making key contributions to this testimony
were Ron Belak, Paul Bollea, Charlie Cotton, Alan Dominicci, Cliff Fowler,
Ches Joy, Paul Lacey, and John Murphy. Contacts and

Acknowledgment

Page 11 GAO- 01- 1022T The National Fire Plan

Appendix I

Page 12 GAO- 01- 1022T The National Fire Plan

Appendix II

Page 13 GAO- 01- 1022T The National Fire Plan

Appendix III

Page 14 GAO- 01- 1022T The National Fire Plan

Appendix IV

(360019)( 360036)

Appendix IV
*** End of document. ***