Biscuit Fire: Analysis of Fire Response, Resource Availability,  
and Personnel Certification Standards (12-APR-04, GAO-04-426).	 
                                                                 
In 2002, the United States experienced one of the worst wildland 
fire seasons in the past 50 years--almost 7 million acres burned.
These fires included the largest and costliest fire in Oregon in 
the past century--the Biscuit Fire. Following a lightning storm, 
five fires were discovered in the Siskiyou National Forest over a
3- day period beginning July 13. These fires eventually burned	 
together to form the Biscuit Fire, which burned nearly 500,000	 
acres in southern Oregon and Northern California and cost over	 
$150 million to extinguish. GAO evaluated (1) whether policies	 
and procedures were in place for acquiring needed firefighting	 
resources during the initial days of the Biscuit Fire, and the	 
extent to which these policies and procedures were followed when 
the fire was first identified; (2) what resource management	 
issues, if any, affected the ability of personnel to fight the	 
fire; and (3) what differences, if any, existed in key		 
certification standards for personnel among federal and state	 
agencies and whether these differences affected efforts to	 
respond to the fire. In commenting on a draft of this report, the
Forest Service stated that the report appears to be accurate and 
the agency generally agrees with its contents. The Department of 
the Interior did not provide comments.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-426 					        
    ACCNO:   A09731						        
  TITLE:     Biscuit Fire: Analysis of Fire Response, Resource	      
Availability, and Personnel Certification Standards		 
     DATE:   04/12/2004 
  SUBJECT:   Emergency preparedness				 
	     Environmental policies				 
	     Fire fighters					 
	     Forest management					 
	     Personnel management				 
	     Wilderness areas					 
	     Internal controls					 
	     Policy evaluation					 
	     Policies and procedures				 
	     Wildland fires					 
	     Oregon						 
	     Siskiyou National Forest (OR)			 

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GAO-04-426

United States General Accounting Office

                     GAO Report to Congressional Requesters

April 2004

BISCUIT FIRE

 Analysis of Fire Response, Resource Availability, and Personnel Certification
                                   Standards

                                       a

GAO-04-426

Highlights of GAO-04-426, a report to congressional requesters

In 2002, the United States experienced one of the worst wildland fire
seasons in the past 50 years-almost 7 million acres burned. These fires
included the largest and costliest fire in Oregon in the past century-the
Biscuit Fire. Following a lightning storm, five fires were discovered in
the Siskiyou National Forest over a 3day period beginning July 13. These
fires eventually burned together to form the Biscuit Fire, which burned
nearly 500,000 acres in southern Oregon and Northern California and cost
over $150 million to extinguish. GAO evaluated (1) whether policies and
procedures were in place for acquiring needed firefighting resources
during the initial days of the Biscuit Fire, and the extent to which these
policies and procedures were followed when the fire was first identified;
(2) what resource management issues, if any, affected the ability of
personnel to fight the fire; and (3) what differences, if any, existed in
key certification standards for personnel among federal and state agencies
and whether these differences affected efforts to respond to the fire.

In commenting on a draft of this report, the Forest Service stated that
the report appears to be accurate and the agency generally agrees with its
contents. The Department of the Interior did not provide comments.

April 2004

BISCUIT FIRE

Analysis of Fire Response, Resource Availability, and Personnel Certification
Standards

National policies and procedures were in place and provided the framework
to guide personnel in the local interagency dispatch center in Grants
Pass, Oregon, who were responsible for acquiring resources to fight the
Biscuit Fire. These policies and procedures provide for a multilevel
dispatching system where, if sufficient firefighting personnel and
equipment are not available locally, resource requests can be elevated to
other dispatch centers at the regional and, if necessary, national level.
To facilitate the swift suppression of new fires, local dispatch center
personnel can contact neighboring centers directly, including those in
adjacent regions, before elevating resource requests. When the first two
fires were found on July 13, the Grants Pass dispatch center did not have
sufficient firefighting resources available locally. Grants Pass personnel
requested resources from the responsible regional center in Portland, as
well as from a dispatch center in central Oregon, but no resources were
immediately available in the region due to other higher priority fires
that were threatening lives and property. Grants Pass personnel did not
request resources from a neighboring interagency dispatch center in
Fortuna, California, located in an adjoining dispatch region, because they
believed the center had no available resources due to fire activity there.
State officials working at the Fortuna dispatch center later said that a
Fortuna-based helicopter fighting fires in Northern California near the
first of the five Biscuit fires could have been made available to suppress
this fire. However, Forest Service officials working with Fortuna
personnel disagreed, saying that the helicopter had been needed to fight
fires in California. Because no request was made, there was no discussion
on that first day about whether the Biscuit Fire would have been the best
use of the helicopter, and it is unclear, in any case, what the outcome of
such a request would have been.

Following the initial days of the Biscuit Fire, delays in obtaining needed
personnel hampered efforts to fight the rapidly growing fire.
Specifically, officials faced problems obtaining (1) highly experienced
management teams to direct suppression strategies and crews to carry the
strategies out, (2) supervisors to manage crews and equipment, and (3)
support staff to monitor the training and experience of contracted crews.
An unusually severe fire season, with many other higher priority fires,
affected the availability of personnel needed to fight the Biscuit Fire.

Finally, while some differences exist in certification standards for
personnel between federal and state agencies responsible for fighting
wildland fires, these differences did not appear to affect efforts to
respond to the Biscuit Fire.

www.gao.gov/cgi-bin/getrpt?GAO-04-426.

To view the full product, including the scope and methodology, click on
the link above. For more information, contact Barry T. Hill at (202)
512-3841 or [email protected]

Contents

  Letter

Results in Brief
Background
National Policies and Procedures Were in Place to Guide theProcess

for Acquiring Firefighting Resources Reduced Availability of Key Personnel
Hampered the Ability to Effectively Fight the Biscuit Fire Some
Differences in Certification Standards Exist between State

and Federal Firefighting Agencies, but No Effect Was Identified
Conclusions Agency Comments and Our Evaluation

1 5 8

12

21

28 30 31

  Appendixes

Appendix I: Scope and Methodology 32

Appendix II: Comments from the Forest Service 34

Appendix III:GAO Contact and Staff Acknowledgments 35 GAO Contact 35 Staff
Acknowledgments 35

Table Table 1: The Five Types of Incidents

Figures Figure 1:

Figure 2: Figure 3:

Figure 4:

Figure 5: Figure 6: Figure 7:

Locations and Final Perimeter of the Five Fires That
Became the Biscuit Fire 3
Biscuit 1 Burning on Steep Terrain on July 14, 2002 9
Example of an Extended Attack Firefighting
Organization 10
Illustration of the Flow of Resource Requests between
the Local Dispatch Centers Involved in the Initial Attack
of the Biscuit Fire 14
Key Events on July 13 and 14, 2002, Related to the Biscuit
Fire 16
New Fire Starts Identified in the Vicinity of the Biscuit
Fire on July 13 and 14, 2002 18
Fire Size on Key Dates When Fire Management Teams
Were Requested and Received 23

Contents

Abbreviations

CDF California Department of Forestry and Fire Protection
NIFC National Interagency Fire Center
NWCG National Wildfire Coordinating Group
ODF Oregon Department of Forestry

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A

United States General Accounting Office Washington, D.C. 20548

April 12, 2004

The Honorable Greg Walden Chairman, Subcommittee on Forests and Forest
Health Committee on Resources House of Representatives

The Honorable Peter DeFazio House of Representatives

The Honorable Scott McInnis House of Representatives

In 2002, the United States experienced one of the worst wildland fire
seasons in the past 50 years. In total, the federal government spent more
than $1.6 billion to suppress fires that burned almost 7 million acres.
These
fires included the largest and costliest fire in Oregon in the past
century-
the Biscuit Fire.1 The fire season in 2002 began early, with major fires
in
Arizona, Colorado, and New Mexico draining many firefighting resources
out of the Pacific Northwest during early summer. As a result, when
lightning storms hit California and Oregon from July 12 to 15, there were
limited resources available to fight the hundreds of ongoing fires,
including
five fires that eventually burned together to form the Biscuit Fire. While
no
lives were lost, the Biscuit Fire burned almost 500,000 acres, including
much of the biologically diverse 180,000-acre Kalmiopsis Wilderness. The
Biscuit Fire was not declared extinguished until December 31, 2002, more
than 5 months after it began. In all, the Biscuit Fire destroyed 4 primary
residences and 10 other structures, resulted in about 15,000 residents
being
put on evacuation notice, required thousands of firefighters and other
resources, and cost over $150 million to fight.

All five fires began in the Siskiyou National Forest in southwest Oregon
over a 3-day period, beginning July 13, 2002. On the first day, two fires
were
found-one approximately 4 miles north of the California-Oregon border,
named Biscuit 1, and another, the Carter Fire, 16 miles north of the state
border within the Kalmiopsis Wilderness (see fig. 1). The Carter Fire was
the first fire Siskiyou Forest officials took action to suppress, and it
was
contained within a few days. On July 14, the third fire-Biscuit 2-was

1Federal agencies select names for wildfires based upon nearby geographic
features. For example, the Biscuit Fire started near Biscuit Creek in
southern Oregon.

found near Biscuit 1, and on July 15, the last two fires-Florence and
Sourdough-were found (see fig. 1). The Florence Fire was located almost 30
miles north of Biscuit 1 and 2, and by early August it had burned 244,000
acres, about one-half of the total acreage ultimately burned by the entire
Biscuit Fire. The Sourdough Fire was located near Biscuit 1 and 2, and by
July 22, the three had burned together to form one fire. By August 7, the
Florence Fire had burned south and merged with the other fires to form
what was later called the Biscuit Fire.

Figure 1: Locations and Final Perimeter of the Five Fires That Became the
Biscuit Fire

Source: GAO analysis of Forest Service data.

Note: The names of the fires changed as they progressed. Initially, each
of the fire starts was named individually. As these fires burned together,
the names were modified. Ultimately, the fires merged to become one-the
Biscuit Fire.

Since no one agency alone can handle all wildfires that may occur in its
jurisdiction, especially when large fires like the Biscuit Fire occur, the
United States uses an interagency incident management system that depends
upon the close cooperation and coordination of federal, state, tribal, and
local fire protection agencies. At the federal level, there are five

agencies involved in firefighting efforts-the Forest Service, within the
Department of Agriculture; and the Bureau of Indian Affairs, the Bureau of
Land Management, the Fish and Wildlife Service, and the National Park
Service, all within the Department of the Interior. The Forest Service is
the predominant firefighting agency among these in terms of the amount of
resources devoted to firefighting. In addition to the federal agencies,
state, tribal, and local firefighting agencies also play an important role
in fighting wildland fires and share firefighting personnel, equipment,
and supplies to facilitate cost-effective firefighting. Private companies
are increasingly providing contracted crews and equipment to supplement
those of federal, state, and local agencies.

To coordinate the firefighting efforts of these agencies, the National
Wildfire Coordinating Group (NWCG) was established. This group adopted an
interagency incident management system and firefighting standards for
responding to wildland fires. This system provides an organizational
structure that includes command, planning, logistics, operations, and
finance functions to meet the complexity and demands of wildland fires.
Needed personnel, aircraft, equipment, and supplies for wildland fires are
ordered through a system of local, regional, and national dispatch
centers. These dispatch centers are staffed or funded by federal or state
agencies, or a combination of those agencies. Federal, state, local, or
tribal agencies or private contractors supply the firefighting resources
dispatched at these centers. If resources in the local dispatch area close
to a wildland fire are insufficient, dispatch center personnel forward the
requests to the responsible regional dispatch center2 that locates and
sends additional firefighting resources from within the region. If
necessary, the regional dispatch center can forward the request to the
National Interagency Coordination Center in Boise, Idaho, which locates
and assigns the closest available resources to the fire. This center is
staffed jointly by Bureau of Land Management and Forest Service personnel.
This incident management system was used to respond to the Biscuit Fire.

Concerns about the response to the Biscuit Fire surfaced as the fire
rapidly grew and began to threaten lives, homes, and businesses. These
concerns included whether firefighting resources were available across the
border in California, which could have been used during the critical early
days of the fires, and whether better management of firefighting resources
could have

2There are 11 regional dispatch centers nationwide, called geographic area
coordination centers, each of which serve a specific geographic portion of
the United States.

improved suppression efforts. In this context, we reviewed (1) whether
policies and procedures were in place for acquiring needed firefighting
resources during the initial days of the Biscuit Fire, and the extent to
which these policies and procedures were followed when the fire was first
identified; (2) what resource management issues, if any, affected the
ability of firefighting personnel to effectively fight the Biscuit Fire;
and (3) what differences, if any, existed in key personnel certification
standards at federal and state agencies involved in fighting wildland
fires-particularly in Oregon-and whether any such differences affected
efforts to respond to the Biscuit Fire.

To address these questions, we reviewed firefighting policies and
procedures that included interagency standards for fire and fire-aviation
operations, interagency personnel certification standards, the national
mobilization guide, and the local mobilization guide and mutual aid
agreement for the dispatch center in Grants Pass, Oregon,3 which was
responsible for acquiring resources to respond to the Biscuit Fire. We
interviewed headquarters, regional, and local firefighting officials from
the Forest Service and Department of the Interior agencies, as well as
state officials from California, Oregon, and five other Western states. We
reviewed Biscuit Fire records, including daily fire reports, resource
orders, and transcripts of key radio transmissions during the initial days
of the Biscuit Fire. We conducted our work in accordance with generally
accepted government auditing standards.

Results in Brief 	National policies and procedures were in place and
provided the framework to guide personnel in the local dispatch center in
Grants Pass, Oregon, responsible for acquiring firefighting resources for
the Biscuit Fire. Guided by these policies and procedures, dispatch
centers use a threetiered dispatching system-local, regional, and
national-to locate and send resources to wildland fires. If sufficient
resources are not available locally, a dispatch center requests additional
resources from its regional dispatch center. If sufficient resources are
not available within the region,

3In the case of the Biscuit Fire, the local dispatch center was the Grants
Pass Interagency Fire Center in Grants Pass, Oregon. The Siskiyou National
Forest has contracted with the Oregon Department of Forestry (ODF) to
operate this center. ODF personnel staff the center, but the operating
costs are shared between ODF and the Forest Service. The regional dispatch
center responsible for the Biscuit Fire was the Northwest Interagency
Coordination Center in Portland, Oregon.

the request is then elevated to the national level. However, to facilitate
the swift suppression of new fires-called the initial attack phase of a
fire- these policies also permit dispatch centers to contact neighboring
centers directly for resources, including those in adjacent regions,
before elevating resource requests to a higher level. For the Biscuit
Fire, the Grants Pass dispatch center did not have sufficient resources
available and took steps to locate resources to fight what began as five
separate fires in the Siskiyou National Forest, found over a 3-day period
beginning July 13, 2002. Grants Pass dispatchers contacted their regional
dispatch center in Portland about the availability of resources, including
helicopters, on the first day of the Biscuit Fire. There were no resources
immediately available due to other higher priority fires burning in the
region. In making these inquiries, Grants Pass personnel did not request
resources from the Fortuna dispatch center,4 a neighboring center located
in the adjoining dispatch region in Northern California. Grants Pass
personnel believed that Fortuna had no available resources, based on daily
fire situation reports, because Northern California was also fighting
numerous fires. Concerns were later expressed by state and local officials
in California that a helicopter, under the control of the Fortuna dispatch
center, was fighting fires in Northern California near one of the five
fires in the Siskiyou National Forest-Biscuit 1-and could have been made
available to fight it. However, Forest Service and California state
officials working in the Fortuna dispatch center expressed differing
viewpoints on whether they could have provided the helicopter for the
Biscuit Fire, had Grants Pass requested it. State officials at the
dispatch center said that the helicopter could have been sent to Oregon.
However, Forest Service dispatchers disagreed, stating that the helicopter
was needed to fight fires in Northern California. Because no request was
made, there was no discussion on that first day about whether the Biscuit
Fire would have been the best use of the helicopter, and it is unclear, in
any case, what the outcome of such a request would have been.

Following the initial efforts to suppress the Biscuit Fire, fire officials
faced delays obtaining (1) highly experienced management teams to direct
fire suppression strategies, along with sufficient crews to carry out fire
plans; (2) supervisors to manage crews and equipment; and (3) support
staff to monitor the training and experience of contracted crews. These
delays

4The Fortuna Interagency Emergency Command Center, which we will refer to
as the Fortuna dispatch center, is an interagency center staffed by Forest
Service and California Department of Forestry and Fire Protection (CDF)
personnel. The center serves Six Rivers National Forest, Redwood National
Park, the CDF Humboldt-Del Norte Unit, and the Hoopa Indian Reservation.

were primarily due to the severe fire season-there were many higher
priority fires within and outside the region. By the time the most highly
experienced type of management team had arrived at the fire, the fire had
grown from a few hundred acres to almost 200,000 acres. Difficulties in
filling supervisory positions for managing firefighting crews hindered the
effectiveness of firefighting efforts. Insufficient personnel to supervise
crews and equipment resulted in the inability to use crews to carry out
planned actions, and as a result, fire suppression progress was delayed.
Insufficient support personnel meant that thousands of contracted
personnel could not be adequately monitored to determine if they met
applicable training and experience requirements. As a result, some
insufficiently trained or inexperienced contractor crews were not always
able to carry out planned operations, resulting in the need to postpone or
alter some tactical firefighting operations.

Finally, while some differences exist in certification standards for
personnel between federal land management agencies and state agencies
responsible for fighting wildland fires, these differences did not appear
to have affected efforts to respond to the Biscuit Fire. In 1993, the
National Wildfire Coordinating Group-an interagency group comprising
federal and state representatives-established minimum training and
experience standards for personnel assigned to fight interagency wildland
fires outside their home region. Federal land management agencies, as well
as firefighting agencies in five of the seven states we contacted in and
around the Northwest Region, have adopted these standards as the minimum
requirements for all of their fire personnel. The state firefighting
agency in Oregon-the Oregon Department of Forestry-uses these standards
for firefighting personnel assigned to fight interagency fires outside
their home region, although the state maintains its own certification
standards for personnel assigned to state fires or interagency fires
within the Northwest Region. Finally, the California state firefighting
agency-the California Department of Forestry and Fire Protection-has
maintained its own requirements and certification system for fire
personnel, but state officials said that these standards meet or exceed
those established by the National Wildfire Coordinating Group. We did not
find any evidence of problems at the Biscuit Fire that stemmed from these
differing standards, based on our review of relevant documents and
interviews with knowledgeable officials.

We provided a draft of this report to the Secretaries of Agriculture and
of the Interior for review and comment. The Forest Service commented that
the report appears to be accurate and the agency generally agrees with its

contents. The Forest Service's comment letter is presented in appendix II.
The Department of the Interior did not provide comments.

Background	A severe drought in many Western states set the stage for an
early and intense fire season. By mid-June, several major fires were
burning, including the Rodeo-Chediski Fire in Arizona and the Hayman Fire
in Colorado. These fires siphoned both aerial and ground firefighting
resources from the Pacific Northwest, including helicopters, air tankers,
agency and contract fire engines, smoke jumpers, highly trained agency
crews (called "hot shot" crews), and contract firefighting crews. By June
21, the National Interagency Fire Center (NIFC) in Boise, Idaho, was
reporting a preparedness level of 5, the highest level, indicating that
the nation had the potential to exhaust all agency firefighting resources.
When lightning storms passed through California and Oregon on July 12 and
13, igniting hundreds of fires, including the Biscuit Fire, more than 30
large fires were already burning across the nation and firefighting
resources available for initial attack were limited.

The Biscuit Fire began as five separate fires in the Siskiyou National
Forest5 in southwest Oregon. The Siskiyou Forest, encompassing more than 1
million acres, contains diverse topography, including the Siskiyou
Mountains, the Klamath Mountains, the Coast Ranges, and the 180,000-acre
Kalmiopsis Wilderness. Steep terrain, together with many roadless areas,
presented accessibility and logistical challenges for managers directing
fire suppression efforts at the Biscuit Fire. To complicate the situation,
the fires were also located almost 30 miles apart. As the fires rapidly
grew during late July and early August, the southern fire burned south and
crossed the state border into the Six Rivers National Forest in Northern
California. While the Biscuit Fire burned primarily federal forestland, by
early August, it threatened a number of communities in Oregon and
California. Figure 2 shows Biscuit 1 burning on a steep hill on July 14,
2002.

5The Siskiyou National Forest and the Rogue River National Forest are
separate forests but are administered jointly. However, because the
Biscuit Fire burned only in the Siskiyou Forest, we will only refer to the
Siskiyou National Forest.

2: Biscuit 1 Burning oFi n Steep Terrain on Jgure uly 14, 2002

Source: Forest Service.

To understand the response to the Biscuit Fire, it is important to
understand the phases of fire suppression efforts and the nature of
interagency wildland firefighting. On a large wildland fire, such as the
Biscuit Fire, fire suppression efforts generally fall into two phases. The
initial attack phase is defined as efforts to control a fire during the
first operational period, usually within 24 hours. Local fire managers
direct these initial firefighting efforts. In fiscal year 2002,
firefighters were successful in suppressing about 99 percent of wildland
fires in federal, state, and local jurisdictions during the initial attack
phase. If a fire has not been contained or will not be contained during
this period or additional firefighting resources are ordered, firefighting
efforts move into the extended attack phase.6 In this phase, key fire
management officials

6Fire managers may order more experienced leadership immediately based on
the initial assessment if it appears that the fire will become a more
complex incident.

firefighting resources assigned. There are five types of incidents-type 1
being the most complex (see table 1). For example, to manage a type 5
incident, the incident commander may be a local district employee with
adequate experience to direct initial attack efforts on a small fire with
two to six firefighters. In contrast, for a type 1 incident, such as the
Biscuit Fire, the incident commander is just one member of a highly
qualified management team. While both type 1 and type 2 incident
management teams have a standard composition of 28 members, type 1 team
members receive additional training and experience in handling the most
complex incidents.

Table 1: The Five Types of Incidents

                Source of incident 
           Type   commander/team                                  Description 
                             Local                      Up to 10 firefighters 
                             Local                      Up to 50 firefighters 
                             Local                     Up to 100 firefighters 
                                         Operations personnel normally do not 
                          Regional                                     exceed 
                                                          200 at any one time 
                          National   Operations personnel often exceed 500 at 
                                                                          any 
                                                                     one time 

Source: GAO analysis of National Interagency Fire Center and National
Academy of Public Administration data.

Incident management teams manage a variety of firefighting resources.
These include highly trained "hot shot" crews, agency and contracted
crews, air tankers, helicopters, fire engines, and bulldozers. Federal
agencies, such as the Forest Service, provide a large number of the
personnel that work on fires. These federal agencies rely on a "militia"
strategy to fight wildland fires whereby personnel within each agency are
trained to serve in fire suppression or support roles, when needed and
requested, in addition to performing their normal day-to-day work
responsibilities. However, many factors, including past downsizing within
the federal government, have reduced the pool of employees qualified to
work on fires. Increasingly, private contractors provide crews and
firefighting equipment, including engines and helicopters.

National Policies and Procedures Were in Place to Guide the Process for
Acquiring Firefighting Resources

National policies and procedures7 were in place and provided the framework
to guide personnel in the local dispatch center in Grants Pass, Oregon,
who were responsible for acquiring firefighting resources for the Biscuit
Fire. Guided by these policies and procedures, dispatch centers use a
three-tiered dispatching system-local, regional, and national-to locate
and send resources to wildland fires. During the initial attack phase of a
fire, these policies also permit dispatch centers to contact neighboring
dispatch centers directly for resources, including resources in adjacent
regions, before elevating resource requests to a higher level. For the
Biscuit Fire, the Grants Pass dispatch center did not have sufficient
resources available and took steps to locate needed resources to fight
what began as five separate fires in the Siskiyou National Forest. Grants
Pass dispatchers contacted their regional dispatch center in Portland
about the availability of resources, including helicopters, on the first
day of the Biscuit Fire. In making resource inquiries, Grants Pass
personnel did not request resources from the Fortuna dispatch center, a
neighboring center located in the adjoining dispatch region in Northern
California. Grants Pass personnel believed that Fortuna had no available
resources, based on daily fire situation reports, because Northern
California was also fighting numerous fires. Concerns were later expressed
by state and local officials in California that a helicopter, under the
control of the Fortuna dispatch center, was fighting fires in Northern
California, just across the border from the first of the five Biscuit
fires, and could have been provided to fight it. Forest Service and state
dispatchers working in the Fortuna dispatch center expressed differing
viewpoints on whether they could have provided a helicopter for the
Biscuit Fire, had Grants Pass requested it.

National Policies and Procedures Provide the Framework for Acquiring
Firefighting Resources

The National Interagency Mobilization Guide includes policies and
procedures to help ensure the timely and cost effective mobilization of
firefighting resources. Federal, state, tribal, and local firefighting
agencies share their firefighting personnel, equipment, and supplies,
following a standardized process to coordinate responses to fires and
mobilize resources. When local dispatch center personnel are notified of a
fire, they send available firefighting resources based on a preplanned
response. If fire managers need additional resources, they send a request
to the local dispatch center identifying the type and amount of resources
needed. If the dispatch center personnel cannot fill a request locally,
they can forward the

7National Interagency Mobilization Guide (Feb. 1, 2002).

request to the responsible regional dispatch center. If the regional
center cannot fill the request with resources from within the region, the
request is sent to the National Interagency Coordination Center in Boise,
Idaho, the primary support center for coordinating and mobilizing wildland
firefighting resources nationally. When requests exceed available
resources, the fires are prioritized, with those threatening lives and
property receiving higher priority for resources. To facilitate the swift
suppression of new fires-called the "initial attack" phase of a fire-local
dispatch center personnel can first contact neighboring dispatch centers
directly, including those in adjacent regions, before elevating resource
requests to the regional or national level. For resource sharing between
neighboring dispatch centers in adjoining regions, a formalized agreement,
such as a mutual aid agreement and local operating plan, is needed.

Existing policies and procedures encourage the sharing of resources
between local dispatch centers. The national guidance states that local
dispatch centers should use mutual aid agreements whenever possible to
obtain resources directly from neighboring units. In the case of the
Biscuit Fire, a regional mutual aid agreement between the state of
California and federal agencies in California, Nevada, and Oregon
establishes the protocols for interagency coordination and cooperation for
wildland fire protection in California, which includes the areas along the
Nevada and Oregon borders.8 Local, state, and federal agencies jointly
develop local operating plans that identify the specific resources that
can be shared under the mutual aid agreement and the provisions for cost
sharing. One of these plans allows the Grants Pass dispatch center in
Oregon and the Fortuna dispatch center, located in the neighboring region
in Northern California, to request resources directly from each other.
(See fig. 4.) The Grants Pass dispatch center operates under a contract
between the Siskiyou National Forest and the Oregon Department of Forestry
(ODF). ODF operates and staffs the center, and the Forest Service
reimburses the department for a portion of the center's operating costs,
according to a Siskiyou official. The Fortuna dispatch center is operated
by the Six Rivers National Forest and the California Department of
Forestry and Fire Protection (CDF) and is staffed by personnel from both
agencies.

8This mutual aid agreement, the Cooperative Fire Protection Agreement,
involved the Bureau of Land Management, California and Nevada; National
Park Service, Pacific West Region; Forest Service, Regions 4, 5, and 6;
and California Department of Forestry and Fire Protection.

Figure 4: Illustration of the Flow of Resource Requests between the Local
Dispatch Centers Involved in the Initial Attack of the Biscuit Fire

         Source: GAO analysis of National Interagency Fire Center data.

Grants Pass Dispatch Center Personnel Sought a Variety of Firefighting
Resources for the Initial Attack of the Biscuit Fire

When the first two fires were found on the afternoon of July 13, 2002, the
Grants Pass dispatch center did not have the firefighting resources needed
locally to fight the fires. Many resources, including the helicopter
normally stationed at Grants Pass, had been sent to other higher priority
fires that were threatening lives and property. The fires, located in the
Siskiyou National Forest, were initially small-two trees and 1 acre.
Biscuit 1 was a few miles north of the California-Oregon border, and the
Carter Fire was about 12 miles north of Biscuit 1. Figure 5 provides
information about the initial attack on the fires.

Figure 5: Key Events on July 13 and 14, 2002, Related to the Biscuit Fire

Note: For the Oregon air reconnaissance, ODF personnel used a Siskiyou
National Forest reconnaissance aircraft.

Biscuit 1 was the first fire found. At 3:17 p.m. on July 13, a Siskiyou
Forest Service aircraft being used by ODF personnel to perform
reconnaissance spotted Biscuit 1. The aerial observer reported the fire to
Grants Pass dispatch. At 3:53 p.m., air reconnaissance spotted the Carter
Fire 12 miles north of Biscuit 1.

Soon after Grants Pass and Siskiyou officials became aware of the first
fire, firefighting personnel in California also spotted the fires. At 3:51
p.m., a CDF reconnaissance airplane, assisting the Six Rivers National
Forest, spotted smoke columns to the north while circling a fire in
Northern California. The airplane was directing the activity of a CDF
helicopter and crew of six firefighters assigned to a fire in the Six
Rivers National Forest in Northern California, just south of the
California-Oregon border. At the request of a Six Rivers National Forest
official, the CDF airplane flew north to investigate the smoke in Oregon.
Reconnaissance personnel reported Biscuit 1 and the Carter Fire to the Six
Rivers official and to the Fortuna dispatch center-an interagency center
staffed by CDF and Six Rivers National Forest personnel. Since the
helicopter and crew were close to finishing up their assignment in
California, the CDF reconnaissance personnel suggested to Fortuna dispatch
that the helicopter and crew could next take action on the fire in Oregon.
The Forest Service dispatcher at Fortuna informed the reconnaissance
airplane to continue patrolling while, in accordance with normal
dispatching protocol, Fortuna notified the Grants Pass dispatch center
about the fire. Grants Pass told Fortuna that it already had
reconnaissance aircraft in the area. Because of the lack of communications
between the CDF and Oregon aircraft, the Fortuna dispatch center advised
the CDF airplane to leave the area to ensure air safety. At 4:15 p.m., CDF
air reconnaissance reported another three lightning-caused fires in
Northern California, and at 4:36 p.m., the CDF helicopter and crew were
sent to fight these fires. Figure 6 shows the new fires found in southern
Oregon and Northern California on July 13 and 14.

Figure 6: New Fire Starts Identified in the Vicinity of the Biscuit Fire
on July 13 and 14, 2002

                  Source: GAO analysis of Forest Service data.

At the request of Siskiyou National Forest officials, Grants Pass dispatch
personnel began to try to locate needed firefighting resources. At 4:30
p.m., Grants Pass dispatch personnel requested a helicopter (with a bucket
for water drops) from the dispatch center in Portland, Oregon. Shortly
after 5 p.m., Siskiyou officials asked the Grants Pass dispatch center to
check on the availability of smoke jumpers, rappellers, helicopters, and
air tankers. Dispatchers checked with the regional dispatch center in
Portland and were told that no helicopters or air tankers were available.
Dispatchers contacted the Central Oregon dispatch center and were told
that no smoke jumpers or rappellers were available for the Biscuit Fire
for 48 to 72 hours because of higher priority fires elsewhere. Grants Pass
personnel relayed this information to Siskiyou officials.

By the next morning, July 14, the fires had grown. Shortly after 10:10
a.m., Siskiyou Forest officials directing firefighting efforts departed on
a reconnaissance flight. They flew over the Carter Fire and decided to
staff this fire as soon as possible because of its proximity to a trail
that would allow access to the fire and because there were natural safety
zones for firefighters. A type 2 crew began to hike to the Carter Fire
later that afternoon. Siskiyou officials next flew over Biscuit 1 and
found it was about 7 acres. They also spotted a third fire, named Biscuit
2, which was about 20 acres and located about one-half mile from Biscuit
1. Siskiyou Forest officials believed that the Biscuit 1 and 2 fires would
burn together in the afternoon and had a high probability of getting
significantly larger. Due to safety concerns, limited accessibility, wind
and fire behavior, and insufficient firefighting resources, forest
officials decided not to staff Biscuit 1 and Biscuit 2 at that time.
Siskiyou officials requested that Grants Pass dispatch personnel order
additional firefighting resources, including a type 2 incident management
team, air tankers, and other equipment for the fires. However, due to
higher priority fires elsewhere, many of these resource orders could not
be filled by the regional dispatch center in Portland for several days or
longer, and the request for air tankers was never filled.

Shortly before noon, a CDF helicopter and crew were on duty in Northern
California performing reconnaissance and responding to reported fires. A
Six Rivers Forest official helping to direct the helicopter crew's
activities requested that the crew check the fire in Northern California
they had worked the previous day to ensure it was out. She also requested
that the crew, on the way, fly by a campground near the Biscuit 1 and
Biscuit 2 fires to ensure no campers were there. None were seen. The
helicopter then landed near the site of the fire they had worked the
previous day in

Northern California, and the crew hiked to the fire to ensure it was
extinguished. At 2:17 p.m., the CDF helicopter reported the fire was cold,
and the helicopter was assigned to another incident in California.

At 6:40 p.m., in response to the July 13 request for a helicopter, a
regional dispatch official in Portland working with officials in the
Northern California regional dispatch center in Redding, the Fortuna
dispatch center, and the Grants Pass dispatch center arranged for a CDF
helicopter with a water bucket to respond to the Biscuit fires, as allowed
under the provisions of the mutual aid agreement. The helicopter had been
working on fires in Northern California. However, a few minutes later, as
the helicopter was en route to Oregon, Siskiyou officials canceled the
request because at that point the fires had spread to more than 300 acres,
and officials stated that the helicopter would have been of limited use on
a fire that size. Officials explained that without ground resources
available to fight the fire, water drops alone are usually of limited
value.

On July 15, the last two fires that would make up the Biscuit Fire-
Sourdough and Florence-were discovered. The Sourdough Fire was found near
Biscuit 1 and Biscuit 2. The Florence Fire was located almost 30 miles
north of these fires. Siskiyou officials requested the Grants Pass
dispatch center to order numerous resources on July 15, including
helicopters, engines, and crews. Most of these requests were not able to
be filled for several days or longer. By July 16, the Northwest's
Multi-Agency Coordination Group in Portland, Oregon, which is responsible
for prioritizing fires and allocating firefighting resources in the
region, ranked the Biscuit Fires as priority 12 out of 18 large fires in
the region. The Florence Fire went on to burn almost 250,000 acres before
merging with the other fires on August 7.

Concerns were later expressed by state and local officials in California
that a CDF helicopter, fighting fires in Six Rivers National Forest on
July 13, just across the state border from Biscuit 1, could have been
provided earlier to assist on the Biscuit Fire. Grants Pass personnel
explained that they did not request assistance from the Fortuna dispatch
center on July 13 because, based on the daily fire situation reports, they
believed no resources would be available due to the fires in Northern
California. California was also fighting numerous fires ignited by the
same lightning storm that passed through Oregon. When we asked the Fortuna
dispatch center about this issue, the Forest Service and state of
California dispatchers working there expressed differing viewpoints on
whether they could have provided a helicopter on the first day of the
Biscuit Fire if such a request had been

made. A CDF dispatcher working at the Fortuna dispatch center said that if
the Grants Pass dispatcher had requested the helicopter at that time to
launch an initial attack on the Biscuit Fire, he believed he would have
provided it to them. However, a Forest Service official also working at
Fortuna to dispatch firefighting resources had a differing opinion, saying
that even if Fortuna had sent the helicopter to Oregon, he believes that
it likely would have been diverted back to California to suppress other
higher priority fires in Fortuna's direct protection area. Because Grants
Pass dispatch did not request assistance from Fortuna on the first day of
the Biscuit Fire, there was no discussion at that time about whether this
would have been the best use of the helicopter. In the final analysis, it
is unclear what the outcome of such a request would have been.

Reduced Availability of Key Personnel Hampered the Ability to Effectively
Fight the Biscuit Fire

Following the initial attack of the Biscuit Fire, delays in obtaining
needed personnel hampered efforts to effectively fight the Biscuit Fire in
three key ways. First, neither a management team with adequate experience
to strategically plan and manage firefighting efforts nor sufficient
highly trained crews to carry out the plans were initially available for
the Biscuit Fire due to their need on higher priority fires. By the time a
highly experienced management team became available and was assigned to
the Biscuit Fire in late July, the fire had increased from a few hundred
acres to almost 200,000 acres. Second, key supervisors needed to direct
the tactical efforts of firefighting crews and equipment were unavailable
at critical points in July and August as the fire was growing in size and
intensity. As a result, the ability to implement aggressive fire
suppression tactics was compromised due to concerns about the safety of
fire crews. Finally, some fire support positions, such as contracting
technical representatives, also were unavailable to play a key role in
monitoring contracted crews.

Delayed Availability of a Top Management Team Affected Initial
Firefighting Efforts

Siskiyou Forest officials directing the firefighting effort had difficulty
obtaining both a highly trained incident management team with the
necessary level of experience to plan and direct firefighting efforts on
the Biscuit Fire, as well as needed crews to carry out such plans. Within
one day after the initial fires were discovered, Siskiyou district fire
managers determined that the fire would likely grow larger and require a
more experienced incident management team to direct the firefighting
effort than was currently available at the forest. They requested a type 2
team and numerous type 1 crews and other firefighting resources during the
initial days. However, because of the high level of fire activity both in
the Pacific

Northwest, as well as in other Western states, higher priority fires meant
that no type 2 incident management teams or highly experienced crews were
immediately available for assignment to the Biscuit Fire. Siskiyou
officials' request for a team was not filled for 7 days, by which time the
acres burned had grown from about 700 to more than 5,000.

When a type 2 management team assumed command of the Biscuit Fire on July
21, they quickly realized that the fire had grown beyond the scope of a
type 2 team and that a more experienced type 1 team was needed to handle
the increasingly complex situation. A type 1 team was ordered on July 22,
but the Northwest's Multi-Agency Coordination Group in Portland
prioritized the Biscuit Fire, on this day, as priority 6 of 15 fires
burning in the region. This was largely because the Biscuit fires were not
threatening lives and property. As a result, most requests for management,
crews, and equipment for the Biscuit Fire went unfilled.

In the case of the management team, rather than assigning the type 1 team
requested, two other type 2 management teams were assigned in late July to
assist in managing firefighting efforts on the southern fire,9 including
the portion that had crossed into California. As these teams tried to
direct the firefighting efforts of crews and equipment, the
fires-especially the Florence Fire in the north-grew rapidly. Winds and
low humidity contributed to the fires' intensity. Between July 27 and
August 1, the size of the Florence Fire grew from 18,000 acres to 164,000
acres, and the size of the southern fire-the Sour Biscuit Fire-grew from
7,000 acres to 38,000 acres. Finally, on July 31, 9 days after first
requested, two type 1 management teams arrived and assumed command of
fighting the Biscuit Fire. Type 1 firefighting crews and many other
resources continued to be listed as critical resource needs throughout
August. Figure 7 shows the dates management teams were requested or
assumed command, the personnel and equipment assigned to the fire, and the
growth of the fires.

9The southern fire resulted from the merging of the Biscuit 1, Biscuit 2,
and Sourdough Fires. The southern fire was named the Sour Biscuit Fire.

 Figure 7: Fire Size on Key Dates When Fire Management Teams Were Requested and
                                    Received

                  Source: GAO analysis of Forest Service data.

Note: The fire size information was not available for July 14.

The first type 2 incident commander assigned to the Biscuit Fire said that
not having a type 1 management team and other needed resources slowed the
progress of the firefighting effort. He said that while he understood the
Portland group's decision not to assign a type 1 team at that time, it
nonetheless was difficult to effectively fight fires located almost 30
miles apart with the limited resources available. The available management
and other resources were split between the fires. He added that the type 2
team's firefighting strategies were the same as those of a type 1 team-
initially to improve access to the site of the fires. However, without
needed resources, tactics had to be modified, and progress was slower. His
operations section chief said that the complexity of the fire, coupled
with

the lack of a type 1 management team, type 1 crews,10 and equipment, meant
that firefighters could not attack the fire directly and had to use more
indirect methods, such as using bulldozers to build a firebreak, in an
effort to slow the spread of the fire. The incident commander and
operations section chief said that generally, when a fire is a high
priority and qualifies for a type 1 management team, it is also more
likely to be assigned other needed firefighting resources. In the case of
the Biscuit Fire, a type 1 team and additional type 1 crews and other
resources might have improved the chances of stopping the fire before it
burned southeast to an area called Oak Flat, according to the incident
commander. However, Forest Service headquarters officials said that in a
severe fire season such as 2002, difficult decisions have to be made about
where to assign limited resources. Fires are prioritized, and those
presenting the greatest threat to life and property receive firefighting
resources first.

Reduced Availability of Supervisors Slowed Biscuit Fire Suppression
Efforts

Even as top management teams and increasing numbers of crews and equipment
were assigned to the Biscuit Fire, some critical supervisory positions
were not filled as quickly as needed or remained unfilled at the end of
the fire. In all, over 200 requests for supervisory positions were never
filled. The primary cause for reduced availability of supervisory
personnel was the demand for these staff to work more than 30 other large
fires throughout the nation, including other fires in Oregon. Fire
managers and a Forest Service review11 of the Biscuit Fire stated that
delays in obtaining needed supervisors affected their ability to implement
aggressive fire suppression tactics or use equipment until sufficient
supervision became available. Federal officials, however, did take some
action to mitigate these problems, including obtaining personnel from
Australia and New Zealand to fill certain supervisory positions. Officials
emphasized that the difficulties in obtaining personnel to serve as
supervisors was not a problem unique to the Biscuit Fire and that such
issues have affected numerous fires in recent years.

Biscuit Fire managers identified a number of key supervisory positions
that went unfilled for a period of time in July or August when the fire
was rapidly growing and that were critical for effective fire suppression
efforts. These included government managers of contracted helicopters and

10A crew normally consists of 20 persons.
11Final Draft Biscuit Fire Review, USDA Forest Service, PNW Region (Jan.
31, 2003).

bulldozers (known as helicopter managers and dozer bosses); government
supervisors directing tactical operations for a division or segment of
crews (known as strike team leaders); and government supervisors (known as
division supervisors) directing the activities of strike team leaders.

Although it was not possible to measure the specific effect on fire
suppression efforts, such as the number of additional acres burned, from
unfilled supervisory positions, Biscuit Fire managers provided a number of
examples to illustrate the difficulty they faced in carrying out plans
without sufficient supervisors for aircraft or for equipment and
firefighting personnel. For example, an incident commander and an incident
business advisor working at the fire said that some bulldozers sat idle
for a few days and could not be used on fire suppression efforts because
of the lack of a dozer boss to manage and direct the equipments' use.
Interagency requirements state that one dozer boss is required to safely
manage the operations of each dozer. However, dozers and dozer bosses are
ordered separately and may arrive at a fire at different times. If a dozer
arrives first, it may sit idle until a dozer boss is available to
supervise its operation. According to an interagency Fire and Aviation
Safety Team Review,12 it was appropriate to not use all available
resources, including dozers, if safety would have been compromised because
of insufficient supervision.

In the case of helicopters, fire officials told us that for one or two
days several helicopters may have sat idle due to insufficient helicopter
managers. However, fire records indicate, and agency officials agreed,
that the major reason helicopters did not fly was due to poor visibility
as a result of weather or smoke. To minimize the impact of helicopter
manager shortages, fire officials used a waiver system so that, under
certain circumstances, one helicopter manager could manage two type 1 or
type 2 helicopters rather than only one, as permitted by interagency
policy.13 Using this waiver process, six waivers were granted for
helicopter managers working at the Biscuit Fire. In addition, National
Interagency

12Final Report: Fire & Aviation Safety Team Review of Northwest Geographic
Area (July 19 through Aug. 1, 2002).

13According to the Interagency Helicopter Operations Guide (January 2002),
two type 1 or type 2 helicopters may be designated as "limited use" and
managed by one qualified helicopter manager when (1) a second qualified
helicopter manager is on order, and there are active efforts to fill the
position; (2) both helicopters are physically side-by-side at the same
helibase; (3) a helibase manager is assigned; (4) aerial supervision is
provided; and (5) approval has been granted by the appropriate agency
aviation manager.

Fire Center officials requested and received numerous supervisors from
Australia and New Zealand, including eight helicopter managers.

The inability to fill government strike team leader positions also
resulted in delays in fire suppression actions, according to a Biscuit
Fire operations manager. In one effort to mitigate this shortage, three
qualified staff were transferred from a hot shot crew to work as strike
team leaders supervising contracted crews, according to the division
supervisor. The supervisor said, however, this move lowered the
firefighting effectiveness of the hot shot crew. In another case, a
shortage of division supervisors resulted in the inability to provide
adequate supervision in two of the four fire zones for about one week,
according to an operations section chief. The lack of needed supervision
resulted in the inability to use crews to carry out planned actions, and
as a result, fire suppression progress was delayed.

Our findings on the reduced availability of personnel to fill critical
staff positions were confirmed by an internal Forest Service review of the
Biscuit Fire as well as Forest Service reviews of other wildland
firefighting efforts. The Forest Service review of the Biscuit Fire
concluded that opportunities to halt the spread of the fire had to be
abandoned because of limited resources, and as a result, the fire grew
larger and threatened more communities on both the western and eastern
perimeters. The Forest Service's January 2000 report, An Agency Strategy
for Fire Management, highlighted the shortage of federal staff for both
fire suppression and fire support positions. Also, during July 2002, the
Northwest Multi-Agency Coordination Group in Portland, Oregon, reviewed
ongoing fires in the Pacific Northwest, including the Biscuit Fire, and
the effects of the reduced availability of personnel to fill critical
supervisory positions for fire suppression. The group noted that some
crews and equipment had been suspended from fire suppression efforts
because of a lack of appropriate supervision.

Shortage of Personnel to Effectively Monitor Contractors Working on the
Biscuit Fire

Contracted resources played a key role in the Biscuit Fire-at its peak
over 1,600 contracted firefighters and over 400 pieces of contracted
equipment and helicopters were assigned to the fire. Interagency fire
managers acknowledged, however, that there was little, if any, monitoring
of private contractors to ensure that contracted crews assigned to the
Biscuit Fire met established training and experience requirements.
Instead, fire managers generally relied on contractors to certify that
their crews met these requirements, as stated in their contract. Despite
contractors' assurances that their crew met all requirements, Biscuit Fire
officials told

us that some insufficiently trained or inexperienced contracted crews
negatively impacted firefighting efforts because these crews were not
always able to carry out planned operations. In contrast, contracted
engines and other equipment had fewer problems.

Fire managers participating on the Biscuit Fire said that poorly trained
and inexperienced contracted crews presented significant operational
concerns. They cited examples of contracted crews that were unable to
carry out planned firefighting operations. Managers said that they
postponed or changed some tactical firefighting operations because it was
not safe using these crews in more aggressive fire operations. Crews that
could not be used as planned were assigned minimal firefighting
responsibilities, such as "mop up" activities at a considerable distance
from intensive fire activity. Although the limitations on how the crews
could safely be used likely affected progress of firefighting, the actual
effect cannot be measured.

Communication to and between crews also adversely impacted the use of
contracted crews on the Biscuit Fire. There were instances where crew and
squad bosses for contracted crews were unable to communicate in English
with government supervisors, as required in the interagency crew
agreement. The lack of fluency in English caused safety concerns and
resulted in crews being assigned to far less technical tasks than planned.
Fire managers told us that, even when assigned minimal fire tasks, some
private crews required above normal supervision, which in turn resulted in
supervisors having less time available to plan and implement higher
priority fire suppression tasks.

Under a cooperative arrangement between the federal government and the
states of Oregon and Washington, ODF has oversight responsibility for
private crew contractors in the Northwest. Typically, the monitoring of
crew qualifications should take place before the start of the fire season.
An ODF official, however, said that insufficient funding and personnel
have resulted in few, if any, evaluations of crews' qualifications prior
to the start of the fire season. Alternatively, interagency support
personnel, such as contracting officers or their technical
representatives, can perform contract crew qualification assessments. We
found that during the Biscuit Fire, however, these key support positions
were identified as a critical, but unfilled, resource need. According to
federal firefighting managers, about 90 individuals have been trained as
technical representatives to work with firefighting management teams, but
at any given time during recent fire seasons, only about 10 percent of
these trained technical representatives

were available to serve on incident management teams. The ODF official
having oversight responsibility for contracted crews in the Northwest
concluded that because of these shortages and the significant numbers of
contracted crews, it is likely that there was minimal monitoring of
contract crews at the fire. Finally, we noted that these shortcomings in
the monitoring of contracted crews were not limited to the Biscuit Fire.
The importance of monitoring crew training and experience was also cited
in an interagency fire and aviation safety report issued in 2002.14 The
review stated that deficiencies in the physical fitness and job skills of
crews raised concerns about the validity of qualifications of some
contracted resources.

Some Differences in Certification Standards Exist between State and
Federal Firefighting Agencies, but No Effect Was Identified

There are some differences in certification standards for personnel
between state and federal wildland firefighting agencies, but these
differences did not appear to have affected efforts to respond to the
Biscuit Fire.

In 1993, the National Wildfire Coordinating Group (NWCG)-an interagency
group comprising federal and state representatives- established minimum
training and experience standards15 for personnel assigned to fight
interagency wildland fires outside their home region. These standards,
which were updated in 2000, have been adopted by five federal land
management agencies, including the Forest Service.16 Five of the seven
states that we contacted in and around the Northwest Region have also
adopted these standards as the minimum requirements for all their
firefighting personnel.17 The Oregon Department of Forestry (ODF) meets
these standards for personnel on interagency wildland fires outside the
Northwest Region. For fires under state management and for

14Final Report: Fire & Aviation Safety Team Review of Northwest Geographic
Area (July 19 through Aug. 1, 2002).

15This system is the Wildland and Prescribed Fire Qualifications System,
commonly referred to as 310-1.

16The Forest Service has supplemented NWCG (310-1) standards with
additional requirements that apply only to Forest Service personnel.

17We spoke with wildland firefighting officials in California, Idaho,
Montana, Nevada, Oregon, Utah, and Washington.

interagency fires within the region,18 ODF has maintained its own
certification standards. These standards are nearly identical to the 1993
version of NWCG standards.19 In 2000, NWCG added some course and
experience requirements. ODF officials are currently working to
incorporate many, but not all, of these changes into state standards. For
example, ODF requirements for many positions rated type 2 or below will
meet NWCG standards. For type 1 positions, including incident commander,
some of the most advanced courses will not be required. An ODF official
explained that he believed, for state-managed fires, these additional
courses were not necessary. The California Department of Forestry and Fire
Protection (CDF) has maintained its own firefighting certification system
for its firefighting personnel. CDF shares many of the same standards as
those established by NWCG, including the combination of coursework and
experience requirements for firefighting certification,20 but requires
state-specific courses for some positions. Under an agreement with federal
land management agencies, California state personnel assigned to
interagency fires in supervisory roles within the state are required to be
certified to a level equivalent to NWCG standards.21 For national
mobilization, NWCG requires that participating agencies certify that their
personnel meet the established interagency qualification standards. In the
case of California, CDF officials stated that state certification
requirements meet or exceed the standards established by NWCG. In
addition, National Interagency Fire Center officials said they have no
concerns about the adequacy of the standards used by CDF.

18A 1998 agreement between Oregon, Washington, and federal land management
agencies recognizes each agency's standards as reasonable, prudent, and
acceptable for firefighting on lands under private, state, or federal
protection.

19Although Oregon standards differ from those set by NWCG, approximately
70 percent of the state's roughly 600 permanent firefighting personnel are
certified in one or more interagency incident command positions, according
to an ODF official. In addition, another roughly 300 seasonal employees
are brought in each year that, by their job duties, must be interagency
certified.

20California's Office of Emergency Services coordinates the sharing of
local emergency personnel, including wildland firefighters, through the
state's municipal aid program. The standards used are based on NWCG
standards, and these personnel are shared with interagency efforts.

21A May 2002 agreement between California and federal land management
agencies specifies that supervisory personnel responding to interagency
fires in the state and some adjacent areas shall meet either NWCG training
requirements or those of the California Incident Command Certification
System, which is based on NWCG standards. The agreement also provides
recommended qualifications for engine crews.

There was no apparent impact on the response to the Biscuit Fire as a
result of different agency firefighting certification standards. As with
other interagency fires, personnel that were dispatched to fight on
interagency fires outside their home region were required to meet these
standards. Within the Northwest Region, ODF maintains its own standards
for state fires and interagency fires, although only NWCG-qualified
personnel were dispatched to the Biscuit Fire, according to an ODF
official. While CDF utilizes an independent set of requirements, NIFC
officials said they had no concerns about the adequacy of the
certification system used by CDF. In addition, for the portion of the
Biscuit Fire that was located in California, CDF supervisory personnel
assigned to the fire were required by agreement to be certified to a level
equivalent with NWCG standards. Finally, our review of relevant documents
and discussions with knowledgeable federal, state, and local officials did
not identify any evidence that the differences between these systems
created difficulties during the response to the Biscuit Fire.

Conclusions	The cornerstone of wildland fire policy is interagency
cooperation and coordination among federal, state, tribal, and local
firefighting agencies. Central to that cooperation and coordination is a
system that includes managers and personnel from many different agencies
and that crosses jurisdictional boundaries. Such a system is facilitated
by good communication between personnel at all levels to help ensure
clarity of firefighting goals, strategies, and tactics. Communication is
also important for those working in various dispatch centers to obtain
firefighting resources. These personnel must communicate in a
timely-sometimes immediate-fashion to other dispatch centers the resources
they need to fight new or ongoing fires in their area. In the case of the
Biscuit Fire, Grants Pass dispatch personnel did communicate resource
needs to their regional dispatch center in Portland, but no resources were
immediately available due to other higher priority fires in the region.
However, personnel did not communicate the need for initial attack
resources to a neighboring dispatch center in Fortuna, California,
although this was an option available to Grants Pass personnel. Whether
this would have resulted in any resources being provided for the initial
attack of the Biscuit Fire is unclear because personnel in the Fortuna
dispatch center disagree on whether any resources could have been spared,
given that fires were also burning in Northern California at the time.
Since no request was made, the priority of the Biscuit Fire relative to
other ongoing fires within the Fortuna dispatch center's direct protection
area was not discussed on the

first day of the Biscuit Fire, and the outcome of such a request, had it
been made, remains unclear.

Agency Comments and 	We provided a draft of this report to the Secretaries
of Agriculture and of the Interior for review and comment. The Forest
Service commented that

Our Evaluation	the report appears to be accurate and the agency generally
agrees with its contents. The Forest Service's comments are presented in
appendix II. The Department of the Interior did not provide comments.

As arranged with your offices, unless you publicly announce the contents
earlier, we plan no further distribution of this report until 30 days
after the date of this letter. At that time, we will send copies of this
report to other interested congressional committees. We will also send
copies to the Secretary of Agriculture; the Secretary of the Interior; the
Chief of the Forest Service; the Directors of the Bureau of Land
Management, the National Park Service, the Fish and Wildlife Service, and
the Bureau of Indian Affairs; and other interested parties. We will make
copies available to others upon request. In addition, this report will be
available at no charge on the GAO Web site at http://www.gao.gov.

If you or your staff have any questions about his report, please contact
me at (202) 512-3841. Key contributors to this report are listed in
appendix III.

Barry T. Hill Director, Natural Resources and Environment

Appendix I

Scope and Methodology

To determine whether policies and procedures were in place for acquiring
needed firefighting resources during the initial days of the Biscuit Fire,
and the extent to which these policies and procedures were followed when
the fire was first identified, we reviewed national policies and
procedures that included the National Interagency Standards for Fire and
Fire Aviation Operations and the National Interagency Mobilization Guide.
We reviewed the interagency mobilization guides in 9 of the 11 regions.1
We also reviewed the local mobilization guide covering the Grants Pass
dispatch center and the mobilization guides for three other local dispatch
centers.2 We reviewed the mutual aid agreements governing resource sharing
for the Siskiyou National Forest. We spoke with officials at the National
Interagency Fire Center (NIFC) in Boise, Idaho; Forest Service
headquarters in Washington, D.C.; Forest Service Regions 5 and 6 regional
offices; Bureau of Land Management, Oregon State Office and the Medford
District Office; the Siskiyou and Six Rivers National Forests; the Oregon
Department of Forestry (ODF); and the California Department of Forestry
and Fire Protection (CDF). We visited three dispatch centers in Oregon
(the Grants Pass Interagency Fire Center, the Medford Interagency Fire
Center, and the Northwest Interagency Coordination Center in Portland) and
one in California (the Fortuna Interagency Emergency Command Center) to
discuss dispatch center operations. We also reviewed Biscuit Fire records
stored at Siskiyou National Forest headquarters in Medford, Oregon, and
records kept at Fortuna, including resource orders and transcripts of key
radio transmissions during the initial days of the Biscuit Fire. The
Forest Service provided the data used to generate the fire progression
maps. We took steps to assess the reliability of the mapping data and
determined that it was sufficiently accurate for our purposes.

To determine what resource management issues, if any, affected the ability
of firefighting personnel to effectively fight the Biscuit Fire, we
reviewed a variety of information, including resource orders and daily
incident reports showing firefighting resources requested and obtained,
incident action plans showing firefighting strategies and tactics,
close-out reports discussing firefighting progress and problems, and
Forest Service reviews of the Biscuit Fire. We interviewed a number of
federal and state personnel knowledgeable about the Biscuit Fire,
including officials from the Siskiyou

1These were the Northwest, Northern California, Southern California,
Western Great Basin, Eastern Great Basin, Southwest, Northern Rockies,
Rocky Mountain, and Eastern regions.

2These dispatch centers were the Central Washington Interagency
Communications Center, the Casper Interagency Dispatch Center, and the
North Dakota Interagency Dispatch Center.

Appendix I Scope and Methodology

and Six Rivers National Forests, ODF, and CDF, and the management teams
and other key support staff that were assigned to the Biscuit Fire. We
discussed resource management issues, their effect on the fighting of the
Biscuit Fire, and the reasons for these issues or problems. We also
reviewed assessments of other wildland fires to determine if the issues
identified were limited to the Biscuit Fire or were more widespread.

To determine what differences, if any, existed in key personnel
certification standards at federal and state agencies involved in fighting
wildland fires- particularly in Oregon-we reviewed the interagency
qualification standards established by NWCG. We also contacted officials
from Oregon and California, where the Biscuit Fire burned, and five other
states-Idaho, Montana, Nevada, Utah, and Washington-to discuss the
certification standards they use, and whether they differ from those
established by NWCG. In addition, we reviewed state firefighting standards
for ODF and CDF and compared them with those established by NWCG. To
determine what effect any differences may have had on the response to the
Biscuit Fire, we spoke with federal officials with NIFC, the Forest
Service, the Bureau of Land Management, and the National Park Service;
officials with the National Association of State Foresters; and state and
local officials in Oregon and California, including officials from ODF,
CDF, and the California Office of Emergency Services.

We conducted our work from April 2003 through February 2004 in accordance
with generally accepted government auditing standards.

                                  Appendix II

                        Comments from the Forest Service

Appendix III

                     GAO Contact and Staff Acknowledgments

GAO Contact Barry T. Hill, (202) 512-3841 or [email protected]

Staff 	Andrea W. Brown, John Delicath, Cliff Fowler (retired), Janet
Frisch, Molly Laster, Paul E. Staley, Stanley G. Stenersen, Amy Webbink,
and Arvin Wu

Acknowledgments made key contributions to this report.

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