Wildland Fire Suppression
Lack of Clear Guidance Raises Concerns about Cost Sharing between Federal and Nonfederal Entities Gao ID: GAO-06-570 May 30, 2006Wildland fires burn millions of acres each year, requiring substantial investments of firefighting assets. Since 2000, federal suppression costs alone have averaged more than $1 billion annually. Wildland fires can burn or threaten both federal and nonfederal lands and resources, including homes in or near wildlands, an area commonly called the wildland-urban interface. Cooperative agreements between federal and nonfederal firefighting entities provide the framework for working together and sharing costs. GAO was asked to (1) review how federal and nonfederal entities share the costs of suppressing wildland fires that burn or threaten both of their lands and resources and (2) identify any concerns that these entities may have with the existing cost-sharing framework.
Federal and nonfederal entities used a variety of methods to share the costs of fighting wildland fires affecting both of their lands and resources. Cooperative agreements between federal and nonfederal firefighting entities--which are developed and agreed to by the entities involved--provide the framework for cost sharing and typically list several cost-sharing methods available to the entities. The agreements GAO reviewed, however, often lacked clear guidance for federal and nonfederal officials to use in deciding which method to apply to a specific fire. As a result, cost-sharing methods were applied inconsistently within and among states, even for fires with similar characteristics. For example, GAO found that in one state, the costs for suppressing a large fire that threatened homes were shared solely according to the proportion of acres burned within each entity's area of fire protection responsibility. Yet, costs for a similar fire within the same state were shared differently. For this fire, the state agreed to pay for certain aircraft and fire engines used to protect the wildland-urban interface, while the remaining costs were shared on the basis of acres burned. In contrast to the two methods used in this state, officials in another state used yet a different cost-sharing method for two similar large fires that threatened homes, apportioning costs each day for personnel, aircraft, and equipment deployed on particular lands, such as the wildland-urban interface. The type of cost-sharing method ultimately used is important because it can have significant financial consequences for the entities involved, potentially amounting to millions of dollars. Both federal and nonfederal agency officials raised a number of concerns about the current cost-sharing framework. First, some federal officials were concerned that because guidance is unclear about which cost-sharing methods are most appropriate in particular circumstances, it can be difficult to reach agreement with nonfederal officials on a method that all parties believe distributes suppression costs equitably. Second, some nonfederal officials expressed concerns that the emergence of alternative cost-sharing methods is causing nonfederal entities to bear a greater share of fire suppression costs than in the past. In addition, both federal and nonfederal officials believed that the inconsistent application of these cost-sharing methods has led to inequities among states in the proportion of costs borne by federal and nonfederal entities. Finally, some federal officials also expressed concern that the current framework for sharing costs insulates state and local governments from the increasing costs of protecting the wildland-urban interface. Therefore, nonfederal entities may have a reduced incentive to take steps that could help mitigate fire risks, such as requiring homeowners to use fire-resistant materials and landscaping. On the basis of a review of previous federal reports and interviews with federal and nonfederal officials, GAO believes that these concerns may reflect a more fundamental issue--that federal and nonfederal entities have not clearly defined their financial responsibilities for wildland fire suppression, particularly those for protecting the wildland-urban interface.
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Director: Team: Phone:GAO-06-570, Wildland Fire Suppression: Lack of Clear Guidance Raises Concerns about Cost Sharing between Federal and Nonfederal Entities
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Report to the Chairman, Subcommittee on Public Lands and Forests,
Committee on Energy and Natural Resources, U.S. Senate:
United States Government Accountability Office:
GAO:
May 2006:
Wildland Fire Suppression:
Lack of Clear Guidance Raises Concerns about Cost Sharing between
Federal and Nonfederal Entities:
Wildland Fire Suppression Cost Sharing:
GAO-06-570:
GAO Highlights:
Highlights of GAO-06-570, a report to the Chairman, Subcommittee on
Public Lands and Forests, Committee on Energy and Natural Resources,
U.S. Senate.
Why GAO Did This Study:
Wildland fires burn millions of acres each year, requiring substantial
investments of firefighting assets. Since 2000, federal suppression
costs alone have averaged more than $1 billion annually. Wildland fires
can burn or threaten both federal and nonfederal lands and resources,
including homes in or near wildlands, an area commonly called the
wildland-urban interface. Cooperative agreements between federal and
nonfederal firefighting entities provide the framework for working
together and sharing costs. GAO was asked to (1) review how federal and
nonfederal entities share the costs of suppressing wildland fires that
burn or threaten both of their lands and resources and (2) identify any
concerns that these entities may have with the existing cost-sharing
framework.
What GAO Found:
Federal and nonfederal entities used a variety of methods to share the
costs of fighting wildland fires affecting both of their lands and
resources. Cooperative agreements between federal and nonfederal
firefighting entities”which are developed and agreed to by the entities
involved”provide the framework for cost sharing and typically list
several cost-sharing methods available to the entities. The agreements
GAO reviewed, however, often lacked clear guidance for federal and
nonfederal officials to use in deciding which method to apply to a
specific fire. As a result, cost-sharing methods were applied
inconsistently within and among states, even for fires with similar
characteristics. For example, GAO found that in one state, the costs
for suppressing a large fire that threatened homes were shared solely
according to the proportion of acres burned within each entity‘s area
of fire protection responsibility. Yet, costs for a similar fire within
the same state were shared differently. For this fire, the state agreed
to pay for certain aircraft and fire engines used to protect the
wildland-urban interface, while the remaining costs were shared on the
basis of acres burned. In contrast to the two methods used in this
state, officials in another state used yet a different cost-sharing
method for two similar large fires that threatened homes, apportioning
costs each day for personnel, aircraft, and equipment deployed on
particular lands, such as the wildland-urban interface. The type of
cost-sharing method ultimately used is important because it can have
significant financial consequences for the entities involved,
potentially amounting to millions of dollars.
Both federal and nonfederal agency officials raised a number of
concerns about the current cost-sharing framework. First, some federal
officials were concerned that because guidance is unclear about which
cost-sharing methods are most appropriate in particular circumstances,
it can be difficult to reach agreement with nonfederal officials on a
method that all parties believe distributes suppression costs
equitably. Second, some nonfederal officials expressed concerns that
the emergence of alternative cost-sharing methods is causing nonfederal
entities to bear a greater share of fire suppression costs than in the
past. In addition, both federal and nonfederal officials believed that
the inconsistent application of these cost-sharing methods has led to
inequities among states in the proportion of costs borne by federal and
nonfederal entities. Finally, some federal officials also expressed
concern that the current framework for sharing costs insulates state
and local governments from the increasing costs of protecting the
wildland-urban interface. Therefore, nonfederal entities may have a
reduced incentive to take steps that could help mitigate fire risks,
such as requiring homeowners to use fire-resistant materials and
landscaping. On the basis of a review of previous federal reports and
interviews with federal and nonfederal officials, GAO believes that
these concerns may reflect a more fundamental issue”that federal and
nonfederal entities have not clearly defined their financial
responsibilities for wildland fire suppression, particularly those for
protecting the wildland-urban interface.
What GAO Recommends:
GAO recommends that the Secretaries of Agriculture and the Interior,
working with relevant state entities, provide more specific guidance on
when to use particular cost-sharing methods and clarify the financial
responsibilities for fires that burn or threaten to burn across
multiple jurisdictions. The Forest Service and Interior generally
agreed with the findings and recommendations. The National Association
of State Foresters disagreed, stating that the recommendations would
not provide the flexibility needed to address the variability in local
circumstances and state laws.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-570].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Robin M. Nazzaro at (202)
512-3841 or nazzaror@gao.gov.
[End of Section]
Contents:
Letter:
Results in Brief:
Background:
Unclear Guidance and Inconsistent Application of Cost-Sharing Methods
Can Have Significant Financial Consequences for Entities Involved:
Current Cost-Sharing Framework Raises Several Concerns:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Characteristics of the Eight Fires That GAO Reviewed:
Appendix III: Comments from the USDA Forest Service:
GAO Comments:
Appendix IV: Comments from the Department of the Interior:
Appendix V: Comments from the National Association of State Foresters:
GAO Comments:
Appendix VI: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Master Agreements for 12 Western States Varied in the Cost-
Sharing Methods Specified:
Figures:
Figure 1: The Varied Cost-Sharing Methods Used for Eight Similar Fires
We Reviewed:
Figure 2: Distribution of Costs under the Actual Cost-Sharing Method
Used Compared with an Acres-Burned Method:
Abbreviations:
FEMA: Federal Emergency Management Agency:
IMT: incident management team:
NASF: National Association of State Foresters:
United States Government Accountability Office:
Washington, DC 20548:
May 30, 2006:
The Honorable Larry E. Craig:
Chairman, Subcommittee on Public Lands and Forests:
Committee on Energy and Natural Resources:
United States Senate:
Dear Mr. Chairman:
Wildland fires burn millions of acres of land each year. Although
wildland fires triggered by lightning are a natural, inevitable, and
necessary ecological process, past federal fire suppression policies
have led to an accumulation of fuels and contributed to larger and more
severe wildland fires. In addition, as human development continues to
expand in or near wildlands--an area commonly known as the wildland-
urban interface--wildland fires increasingly threaten not only federal
lands and public resources, such as forests and watersheds, but also
nonfederal lands and resources, including homes and other structures.
Fighting wildland fires--which can burn across federal, state, and
local jurisdictions--requires significant investments of firefighting
personnel, aircraft, equipment, and supplies, resulting in substantial
and increasing fire suppression expenditures. Since 2000, federal
suppression expenditures alone have averaged more than $1 billion
annually. In addition, nonfederal entities, such as state and local
governments, can spend hundreds of millions of dollars during severe
fire years. Firefighting efforts are mobilized through an interagency
incident management system, which depends on the close cooperation and
coordination of federal, state, tribal, and local fire protection
entities. At the federal level, five principal agencies are involved in
firefighting efforts--the Forest Service within the Department of
Agriculture and four agencies within the Department of the
Interior.[Footnote 1] Federal and nonfederal firefighting entities
share their personnel, equipment, and supplies and work together to
fight fires, regardless of which entity has jurisdiction over the
burning lands. Agreements between cooperating entities, commonly
referred to as master agreements, govern these cooperative fire
protection efforts and include general provisions for sharing
firefighting costs. According to federal officials, these provisions,
and the guidance on available cost-sharing methods, have been changing
over the years, in part, to address the continuing expansion of the
wildland-urban interface and the resulting increase in nonfederal
resources at risk from wildland fire.
In this context of both the increasing size and severity of wildland
fires and the rising costs of suppressing fires and protecting federal
and nonfederal lands and resources, you asked us to (1) review how
federal and nonfederal entities share the costs of suppressing wildland
fires that burn or threaten both of their lands and resources and (2)
identify any concerns federal and nonfederal entities may have with the
existing cost-sharing framework. To address these objectives, we
reviewed federal statutes governing cooperative fire protection
activities; federal and interagency wildland fire policies and
procedures; master agreements between federal and nonfederal entities
governing cooperative fire protection in 12 western states that
frequently experience wildland fires;[Footnote 2] and federal, state,
and nongovernmental entities' reviews of recent large fires or other
reports related to wildland fire suppression costs. We also interviewed
national, regional, and local firefighting officials from the Forest
Service and Department of the Interior agencies as well as state
officials from Arizona, California, Colorado, and Utah. In addition,
for two recent fires that burned or threatened both federal and
nonfederal lands and resources in the 4 states, we reviewed the records
listing the firefighting resources deployed, their costs, and the
methods chosen to share these costs.[Footnote 3] We determined that
these data were sufficiently reliable for the purposes of this report.
Appendix I contains a more detailed description of our scope and
methodology, and appendix II contains additional information on the
fires we reviewed. We performed our work in accordance with generally
accepted government auditing standards from May 2005 through May 2006.
Results in Brief:
Federal and nonfederal entities used a variety of methods to share the
costs of fighting wildland fires affecting both of their lands and
resources, but they applied these varied methods inconsistently to
fires with similar characteristics. Master agreements between
firefighting entities provide the framework for cost sharing and,
typically, list several cost-sharing methods available to the entities.
The agreements we reviewed, however, often lacked clear guidance for
federal and nonfederal officials to use in deciding which method to
apply to a specific fire. As a result, cost-sharing methods were
applied inconsistently within and among states, even for fires with
similar characteristics. For example, we found that in one state, the
costs for suppressing a large fire that threatened homes were shared
solely according to the proportion of acres burned within each entity's
area of fire protection responsibility. However, costs for a similar
fire within the same state were shared differently. For this fire, the
state paid for certain aircraft and fire engines used to protect the
wildland-urban interface, while the remaining costs were shared on the
basis of acres burned. In contrast to the two methods used in this
state, officials in another state used yet a different cost-sharing
method for two similar large fires that threatened homes, apportioning
costs each day for personnel, aircraft, and equipment deployed on
particular lands, such as the wildland-urban interface. The type of
cost-sharing method ultimately used is important because it can have
significant financial consequences for the entities involved,
potentially amounting to millions of dollars.
Federal and nonfederal agency officials we interviewed raised a number
of concerns about the current cost-sharing framework. First, some
federal officials were concerned that because guidance is unclear about
which cost-sharing methods are most appropriate in particular
circumstances, it can be difficult to reach agreement with nonfederal
officials on a method that all parties believe shares suppression costs
equitably between affected federal and nonfederal entities,
particularly for fires threatening the wildland-urban interface. For
example, different cost-sharing methods were used for two fires we
reviewed in one state, even though both fires required substantial
suppression effort to protect the wildland-urban interface. Nonfederal
officials agreed to pay a higher proportion of the suppression costs
for one fire--primarily because most of the nonfederal share of the
fire's costs were eligible for reimbursement by a Federal Emergency
Management Agency (FEMA) grant program--but they would not agree to do
so for the second fire. Second, nonfederal officials were concerned
that the emergence of alternative cost-sharing methods is causing state
and local entities to bear a greater share of suppression costs than in
the past. Moreover, both federal and nonfederal officials were
concerned that the inconsistent application of cost-sharing methods has
created inequities among states in the proportion of suppression costs
borne by federal and nonfederal entities. Finally, some federal
officials also expressed concern that the current framework for sharing
costs--combined with the availability of funds from FEMA to reimburse
nonfederal entities in certain cases--insulates state and local
governments from the increasing costs of protecting the wildland-urban
interface. Consequently, nonfederal entities may have a reduced
incentive for requiring the use of fire-resistant building materials
and landscaping, which can help mitigate fire risks in the wildland-
urban interface and thereby help reduce the costs of protecting it. On
the basis of our review of previous federal reports and interviews with
federal and nonfederal officials, we believe that these concerns may
reflect a more fundamental issue--that federal and nonfederal entities
have not clearly defined their financial responsibilities for wildland
fire suppression, particularly those for protecting the wildland-urban
interface.
To strengthen the framework for sharing wildland fire suppression
costs, we are recommending that the Secretaries of Agriculture and the
Interior, working in conjunction with relevant state entities, (1)
provide more specific guidance as to when particular cost-sharing
methods should be used and (2) clarify the financial responsibilities
for suppressing fires that burn or threaten to burn across multiple
jurisdictions. In commenting on a draft of this report, the Forest
Service and Interior generally agreed with our findings and
recommendations. The National Association of State Foresters (NASF)
also provided comments on the report and generally did not agree with
the recommendations. NASF stated that developing national guidance
specifying appropriate cost-sharing methods and clarifying financial
responsibility for fire suppression costs would not provide the
flexibility needed by local federal and nonfederal officials to address
the variability in local circumstances and state laws. We agree that a
certain amount of flexibility is needed, however, without more explicit
guidance to assist local federal and nonfederal officials responsible
for developing cost-sharing agreements for individual fires, the
inconsistencies in how suppression costs are shared within and among
states are likely to continue, along with concerns about perceived
inequities. Comments from the Forest Service, Interior, and NASF are
reprinted in appendixes III, IV, and V, respectively.
Background:
Wildland fires triggered by lightning are both natural and inevitable,
and they play an important role on our nation's lands. Many ecosystems
have adapted to periodic wildland fires, which help control vegetation
levels and stimulate seedling regeneration and growth. Past land
management practices, including effective fire suppression, have
disrupted the historic frequency of wildland fires. As a result, a
decrease in the number of acres burned nationwide during much of the
twentieth century has led to an accumulation of dense vegetation that
now fuels larger, more severe, and sometimes catastrophic wildland
fires.
In recent years, both the number of acres burned by wildland fires and
the costs to suppress fires have been increasing. From 1995 through
1999, wildland fires burned an average of 4.1 million acres each year;
from 2000 through 2004, the fires burned an average of 6.1 million
acres each year--an increase of almost 50 percent. During the same
periods, the costs incurred by federal firefighting entities to
suppress wildland fires more than doubled, from an average of $500
million annually to more than $1.3 billion annually.[Footnote 4]
Although efforts to fight these larger, more severe fires have
accounted for much of the increase in suppression costs, the continuing
development of homes and communities in areas at risk from wildland
fires and the efforts to protect these structures also contribute to
the increasing costs. Forest Service and university researchers
estimate that about 44 million homes in the lower 48 states are located
in areas that meet or intermingle with wildlands--commonly referred to
as the wildland-urban interface.[Footnote 5] When fire threatens the
wildland-urban interface, firefighting entities often need to use
substantial resources to fight the fire and protect homes, including
firefighters, fire engines, and aircraft to drop retardant. Although
firefighters are able to protect many homes threatened by wildland
fires, these fires have burned an average of about 850 homes each year
in the United States since 1984.
Because one firefighting entity alone cannot handle all wildland fires
that may occur in its jurisdiction, federal and nonfederal entities
work together to protect lands and resources and to fight fires. At the
federal level, five principal agencies are involved in fire
suppression--the Forest Service within the Department of Agriculture
and the Bureau of Indian Affairs, Bureau of Land Management, Fish and
Wildlife Service, and National Park Service within the Department of
the Interior. In addition, nonfederal entities--including state
forestry entities and tribal, county, city, and rural fire departments-
-play an important role in protecting resources and fighting fires.
Federal and nonfederal entities enter into master agreements that
govern their cooperative fire protection activities, including wildland
fire suppression, and provide for sharing the costs of these
efforts.[Footnote 6] To share suppression costs for a specific fire,
local representatives of federal and nonfederal firefighting entities
responsible for protecting lands and resources affected by the fire
decide which costs will be shared and for what period. They document
their decisions in a cost-sharing agreement for that fire. These local
representatives can include federal officials from a national forest, a
Bureau of Land Management district office, or a national park and
nonfederal officials from the state or other entities. In developing
the cost-sharing agreement for a specific fire, these officials are
guided by the terms of the master agreement.
As wildland fire suppression costs have continued to rise, increasing
attention has focused on how suppression costs for multijurisdictional
fires are shared. According to federal officials, in the past these
cooperating entities often shared suppression costs on the basis of the
proportion of acres burned in each entity's protection area. These
officials explained that this method is relatively easy to apply and
works well when the lands affected by a wildland fire are similar. In
2000, federal officials updated interagency policy to include, among
other things, additional information about alternative cost-sharing
methods. According to a federal official, the interagency policy was
updated, in part, in response to requests for additional guidance on
cost sharing.[Footnote 7] In addition to the acres-burned method, the
policy describes two alternative methods for sharing the costs of fire
suppression efforts.[Footnote 8] Under the first alternative--you
order, you pay--each entity pays for the firefighting personnel,
aircraft, and equipment it orders, regardless of where these resources
are deployed during a fire. Under the second alternative--cost
apportionment--entities share total fire costs according to the
assignment or actual use each day of firefighting personnel, aircraft,
and equipment in federal or nonfederal protection areas. Indirect costs
can then be shared in the same proportions as these direct
costs.[Footnote 9] According to the interagency policy, however, the
cost-sharing terms of the master agreements take precedence.
To facilitate an effective response to wildland fires--including those
affecting both federal and nonfederal jurisdictions--firefighting
entities in the United States use an interagency incident management
system. This system provides an organizational structure that expands
to meet a fire's complexity and demands and allows entities to share
firefighting personnel, aircraft, and equipment. When a fire is first
detected, firefighting entities normally follow a principle of "closest
available resource," whereby, regardless of jurisdiction, the closest
available firefighting personnel and equipment respond to the fire. The
firefighter managing the suppression efforts is called the incident
commander. Typically, when a fire is first detected, it is classified
as a type 5--the least complex--or type 4 fire, depending on the fire
and the number of firefighters needed to fight it. If additional
firefighting assets are needed, the incident commander orders them
through a three-tiered system of local, regional, and national dispatch
centers. Federal, state, tribal, and local entities and private
contractors supply the firefighting personnel, aircraft, equipment, and
supplies, which are coordinated and dispatched through these centers.
If the fire escapes initial suppression efforts, officials may request
a type 3 incident commander and additional firefighting assets. The
fire may grow in size or complexity into a type 2 or type 1 fire, the
latter being the most complex. For such fires, officials may request an
incident management team that includes not only an incident commander
but a cadre of personnel to handle command, planning, logistics,
operations, and finance functions. Nationally, there are 17 type 1
incident management teams available to manage the most complex fires.
An additional 38 type 2 teams are available to manage large fires that
are less complex.
In 2000, in response to a decade of severe wildland fires, the
Departments of Agriculture and the Interior developed a National Fire
Plan. This plan comprises several strategic documents that together
address how to respond to wildland fires, reduce the impacts of these
fires on communities and the environment, and ensure sufficient
firefighting resources for the future.[Footnote 10] The National Fire
Plan encourages collaboration and cooperation among a variety of
stakeholders, including federal, state, and local firefighting and
other government entities; nongovernmental entities; and property
owners. The plan includes a 10-year comprehensive strategy and an
associated implementation plan that outline a collaborative approach
for reducing wildland fire risks to communities and the environment.
The implementation plan includes steps addressing four key areas--
improving fire prevention and suppression, reducing hazardous fuels,
restoring fire-adapted ecosystems, and promoting community assistance-
-and identifies parties to help carry out these steps. For example, to
help protect structures and communities, state and local entities are
encouraged to develop and adopt local land-use plans and ordinances to
help reduce the wildland fire risks to homes and other structures. To
help meet National Fire Plan goals, Congress provided funding for
programs to assist not only federal firefighting entities but also
nonfederal entities and communities. For fiscal years 2001 through
2005, assistance to nonfederal entities and communities totaled $436
million ($462 million adjusted for inflation). These funds--in the form
of grants or other assistance administered by the Departments of
Agriculture and the Interior--were used to train state and local
firefighters and acquire firefighting equipment, carry out hazardous
fuel treatments, conduct hazard assessments and assist communities in
developing community wildland fire protection plans, and educate
homeowners and others on preventive steps to help reduce their risk
from wildland fires.
Unclear Guidance and Inconsistent Application of Cost-Sharing Methods
Can Have Significant Financial Consequences for Entities Involved:
Federal and nonfederal entities included in our review used a variety
of methods to share the costs of fighting fires that burned or
threatened both federal and nonfederal lands and resources. Although
master agreements between federal and nonfederal entities provided the
framework for cost sharing and, typically, listed several cost-sharing
methods, the agreements often lacked clear guidance for officials to
follow in deciding which cost-sharing method to apply to a specific
fire. Consequently, for eight fires we reviewed in four states, we
found varied cost-sharing methods used and an inconsistent application
of these methods within and among states, although the fires had
similar characteristics. The type of cost-sharing method chosen is
important because it can have significant financial consequences for
the federal and nonfederal entities involved.
Master Agreements Provided Cost-Sharing Framework, but Those We
Reviewed Lacked Clear Guidance:
Master agreements provide the framework for federal and nonfederal
entities to work together and share the costs of fighting wildland
fires. The master agreements we reviewed for 12 western states all
directed federal and nonfederal entities to develop a separate
agreement, documenting how costs were to be shared for each fire that
burned--or, in some cases, threatened to burn--across multiple
jurisdictions. The master agreements also listed one or more methods
that could be used for sharing costs (see table 1). The master
agreement for Idaho was the only one of the agreements reviewed that
did not cite any specific methods for sharing multijurisdictional fire
suppression costs. Three other master agreements--for Alaska, Arizona,
and New Mexico--provided that firefighting entities should distribute
suppression costs exclusively or primarily on the basis of the
percentage of acres burned in each entity's jurisdiction, although two
of the agreements permitted another method if all parties agreed to use
it. The master agreements for the remaining 8 states listed a variety
of methods that could be used to share suppression costs. Although, the
specific methods varied from agreement to agreement, they included
acres burned, cost apportionment, or variations of these or other
methods.
Table 1: Master Agreements for 12 Western States Varied in the Cost-
Sharing Methods Specified:
State: Alaska;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: Checked;
Cost-sharing method specified in master agreement: Multiple methods:
[Empty];
State: Arizona;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: Checked;
Cost-sharing method specified in master agreement: Multiple methods:
[Empty];
State: California;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
Checked;
State: Colorado;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
Checked;
State: Idaho;
Cost-sharing method specified in master agreement: No Specific Method:
Checked;
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
[Empty];
State: Montana;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
Checked;
State: Nevada;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
Checked;
State: New Mexico;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: Checked;
Cost-sharing method specified in master agreement: Multiple methods:
[Empty];
State: Oregon;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
Checked;
State: Utah;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
Checked;
State: Washington;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
Checked;
State: Wyoming;
Cost-sharing method specified in master agreement: No Specific Method:
[Empty];
Cost-sharing method specified in master agreement: Acres burned was the
primary or only method: [Empty];
Cost-sharing method specified in master agreement: Multiple methods:
Checked;
Source: GAO analysis of data provided by the Forest Service.
[End of table]
The master agreements we reviewed provided a framework for cost
sharing, but they did not provide clear guidance for federal and
nonfederal officials to follow in deciding which method to use for a
specific fire. Only one master agreement, the agreement for Alaska,
clearly stated that an acres-burned method should always be used. The
agreement noted, however, that this method may distribute suppression
costs disproportionately to the cost of protecting lands and resources
in a particular jurisdiction. The acres-burned method spreads fire
suppression costs evenly across the affected landscape, a distribution
that may not recognize extra fire suppression costs incurred to protect
lands and resources in one entity's jurisdiction. Most of the master
agreements we reviewed for the remaining 11 states listed multiple,
alternative cost-sharing methods but did not provide clear guidance on
when each method should be used. For example, master agreements for
several states defined three cost-sharing methods, including cost
apportionment. These master agreements noted that the cost-
apportionment method was "the most equitable method and should be used
when a type 1 team is assigned" to manage a wildland fire, but they
provided no further guidance about when the other methods should be
used. Similarly, the master agreement for another state, Montana,
suggested that an acres-burned method be used when entities'
responsibilities, objectives, and suppression costs are similar, but
the agreement did not describe when the other three listed methods
should be used. Finally, the joint master agreement for Oregon and
Washington[Footnote 11] listed five possible cost-sharing methods. The
agreement stated that some of the cost-sharing methods described were
typically used on "smaller, less complex" fires and others were
typically applied to "larger, more complex" fires. It did not define,
however, at what point a fire crosses the threshold from smaller and
less complex to larger and more complex.
Two other master agreements prescribed a primary cost-sharing method
but allowed the use of alternative methods without explicitly stating
under what circumstances an alternative method would be appropriate.
The master agreements for these states--Arizona and New Mexico--
stipulated that firefighting entities share suppression costs on an
acres-burned basis unless federal and nonfederal officials jointly
agreed to use an alternative method. But the agreements for these
states did not clearly delineate the circumstances that would warrant
use of such an alternative. The master agreement for New Mexico, for
example, cited "extra suppression effort," and the agreement for
Arizona referred to "an unusually high amount" of suppression activity
as prerequisites for distributing suppression costs on a basis other
than acres burned. The agreements did not define what constitutes
"extra suppression effort" or an "unusually high amount" of suppression
activity.
In addition to providing limited guidance on cost-sharing methods, the
master agreements we reviewed also provided unclear guidance on whether
estimated or actual costs should be shared between federal and
nonfederal entities. Although estimated costs can be more quickly
determined than actual costs--often by the end of a fire--estimated
costs can be incomplete or inaccurate. For example, federal and
nonfederal officials with whom we spoke in California said that in
their experience, estimated costs could differ from actual costs by as
much as 30 percent. Such discrepancies can occur because not all costs
are available and entered into the accounting system at the time of a
fire. In addition, some costs entered into the accounting system at the
time of a fire, such as federal personnel costs, are in fact estimated
costs. According to federal officials, actual cost data may take from
several weeks to several months to become available.
For several of the fires we reviewed, total actual fire costs were much
higher than the costs estimated immediately after the fire. For one
fire we reviewed in Colorado, for example, total estimated fire costs
increased from $5.4 million at the end of the fire to $7 million as of
February 2006--an increase of 29 percent. Federal and state officials
have been using actual costs to finalize federal and nonfederal
entities' shares. In another example, for a fire we reviewed in
Arizona, total costs increased from an estimated $17.3 million at the
end of the fire to $19.4 million as of February 2006--an increase of
more than 12 percent. In this case, nonfederal entities' share of costs
was agreed to on the basis of estimated costs. As a result, federal
entities will bear the total increase.
Cost-Sharing Methods Were Inconsistently Applied for the Eight Fires We
Reviewed:
Federal and nonfederal entities used varied cost-sharing methods for
the eight fires we reviewed, although the fires had similar
characteristics. As shown in figure 1, the cost-sharing methods used
sometimes varied within a state or from state to state.
Figure 1: The Varied Cost-Sharing Methods Used for Eight Similar Fires
We Reviewed:
[See PDF for image]
[A] A complex consists of two or more individual fires located in the
same general area and managed by a single incident commander.
[End of figure]
The costs for the two fires that we reviewed in Utah were shared using
two different methods, although both fires had similar characteristics.
For the Blue Springs Fire, federal and nonfederal officials agreed that
aircraft and engine costs of protecting an area in the wildland-urban
interface during a 2-day period would be assigned to the state and that
the remaining costs would be shared on the basis of acres burned.
Federal and state officials explained that, because the Blue Springs
Fire qualified for assistance from FEMA, state officials agreed to bear
a larger portion of the total fire suppression costs.[Footnote 12] In
contrast, state officials were reluctant to share costs in the same
manner on the Sunrise Complex of fires. Although these fires also
threatened the wildland-urban interface, they did not meet the
eligibility requirements for FEMA reimbursement of nonfederal costs.
Consequently, federal and nonfederal officials agreed to share costs
for the Sunrise Complex on the basis of acres burned.
The costs for the two fires we reviewed in Arizona were also treated
differently from each other. For the Cave Creek Complex, federal and
state officials agreed to share suppression costs using an acres-burned
method for the southern portion of the fire, which encompassed federal,
state, and city lands and required substantial efforts to protect the
wildland-urban interface. The federal government paid the full costs
for the northern portion of the fire, which burned almost exclusively
on federal land although some efforts had also been taken on federal
lands to protect an area of wildland-urban interface northeast of the
fire. Forest Service regional officials who conducted a postfire review
expressed concern about the method chosen for the Cave Creek Complex
because they believed that it did not equitably share the fire
suppression costs among the affected entities, especially the costs of
protecting the wildland-urban interface. The Arizona state forester
explained, in contrast, that he and local forest officials agreed to
use an acres-burned method because they did not believe that an
unusually high amount of suppression effort had gone toward protecting
nonfederal lands and resources.
Unlike the Cave Creek Complex, federal and nonfederal officials were
unable to reach any agreement on how to share costs for the Florida
Fire in Arizona. Officials from the affected national forest had
proposed a cost-sharing agreement, whereby the state would pay the
costs of firefighting personnel, equipment, and aircraft used to
protect the wildland-urban interface, and all other fire suppression
costs would be paid by the federal government. The state forester,
however, did not agree with this proposal. He explained that he
believed that the Forest Service, not the state, was responsible for
protecting areas of the wildland-urban interface threatened by the
Florida Fire and that he was not authorized to agree to the terms of
the proposed agreement.[Footnote 13] Federal and state officials were
not able to reach agreement, and, according to federal officials, no
further discussions were planned.
Methods used to share suppression costs for fires with similar
characteristics also varied among states. For example, costs for the
fires we reviewed in California and Colorado were shared using methods
different from those used for similar fires we reviewed in Arizona and
Utah. In California, federal and nonfederal officials agreed to share
the costs of two fires using the cost-apportionment method--that is,
costs were apportioned on the basis of where firefighting personnel and
equipment were deployed. Officials said that they had often used this
method since the mid-1980s because they believed that the benefit it
provides in more equitable cost sharing among affected firefighting
entities outweighs the additional time required to apportion the costs.
In contrast, federal and state officials in Colorado shared suppression
costs for both of the fires we reviewed in that state using guidance
they had developed and officially adopted in 2005, called "fire cost
share principles."[Footnote 14] Under these principles, aviation costs
for fires burning in the wildland-urban interface are shared equally
for 72 hours,[Footnote 15] and other fire suppression costs, such as
firefighting personnel and equipment, are shared on the basis of acres
burned. State officials said that they developed the principles because
they did not want firefighting officials to be reluctant to order
needed resources due to concerns about which entity would pay for them.
They added that using the principles is less labor-intensive than cost
apportionment and better distributes the cost of expensive aviation
assets than an acres-burned method alone. In addition, for the Mason
Gulch Fire, Colorado officials agreed to pay for some fire engines that
were used to protect homes in the wildland-urban interface during one
operational period.
The Cost-Sharing Method Used Can Lead to Significantly Different
Financial Outcomes:
Having clear guidance as to when particular cost-sharing methods should
be used is important because the type of method ultimately agreed upon
for any particular fire can have significant financial consequences for
the firefighting entities involved. To illustrate the effect of the
method chosen, we compared the distribution of federal and nonfederal
costs for the five fires we reviewed in which the actual cost-sharing
method used was not acres burned with what the distribution would have
been if the method used had been acres burned (see fig. 2).
Figure 2: Distribution of Costs under the Actual Cost-Sharing Method
Used Compared with an Acres-Burned Method:
[See PDF for image]
Note: For each illustrated fire, we estimated costs under an acres-
burned method by multiplying the total costs for each fire by the
percentage of affected acres under nonfederal and federal protection,
respectively. Dollars were not adjusted for inflation.
[A] Data for these California fires, which occurred in 2004, reflect
total actual suppression costs.
[B] Data for these Colorado and Utah fires--which, according to the
fire officials involved, were the best available as of March 2006--
reflect a combination of actual suppression costs and estimated costs,
when actual costs were not available. Because final actual shares of
the costs had not been determined for the Mason Gulch Fire at the time
of our review, we worked with federal officials to estimate the federal
and nonfederal shares on the basis of the fire's actual cost-sharing
agreement. The federal and nonfederal shares of total costs calculated
at final settlement by firefighting entities involved in the Mason
Gulch Fire may differ from these estimates.
[End of figure]
We found that the distribution of costs between federal and nonfederal
entities differed, sometimes substantially, depending on the cost-
sharing method used. Of the five fires included in our review, the
largest differences occurred for the two fires in California. Officials
shared the costs for each of these fires using a cost-apportionment
method. For the Deep Fire, federal entities paid $6.2 million, and
nonfederal entities paid $2.2 million. Had the costs been shared on the
basis of acres burned, federal entities would have paid an additional
$1.7 million, and nonfederal entities would have paid that much less
because most of the acres burned were on federal lands. According to
federal and state officials, the nonfederal entities bore a larger
share of the cost than they would have under an acres-burned method
because (1) substantial aircraft, fire engines, and personnel were used
to protect nonfederal lands and resources, primarily in the wildland-
urban interface, and (2) the costs for protecting these nonfederal
lands and resources were assigned to the nonfederal entities. In
contrast, for the other California fire we reviewed, the Pine Fire,
federal firefighting entities would have paid about $2 million less,
and nonfederal entities would have paid that much more under an acres-
burned method. Under the cost-apportionment method, federal entities
paid $5.2 million, and nonfederal entities paid $8.1 million. According
to a federal official who worked on apportioning costs for that fire,
the higher costs that the federal entities paid under cost
apportionment were largely due to extensive firefighting efforts on
federal land to ensure that the fire was extinguished.
In Colorado and Utah, which for three fires used cost-sharing methods
other than cost apportionment and acres burned, the differences in
federal and state entities' shares between the methods used and the
acres-burned method were less pronounced. This is likely because the
cost-sharing methods used still relied heavily on acres burned. In each
case, federal entities' shares would have been more and nonfederal
shares less had an acres-burned method been used, due to the efforts to
protect the wildland-urban interface. For example, the federal share of
costs for the Blue Springs Fire in Utah would have been about $400,000
more and the nonfederal share that much less if an acres-burned method
had been used for the whole fire. In Colorado, we estimated that the
federal share of costs for the Mason Gulch Fire would have been about
$200,000 more and the nonfederal share that much less under an acres-
burned method. For the McGruder Fire, where the number of federal and
nonfederal acres burned were nearly identical and the total fire cost
of about $800,000 was much less than the cost of other fires we
reviewed, the change in the distribution of costs between the method
used and acres burned--about $30,000--was much less than for the other
fires.
For two other fires we reviewed in which federal and nonfederal
entities had agreed to use the acres-burned method, nonfederal entities
might have borne a greater proportion of the costs had a different cost-
sharing method been used. For these two fires, in Arizona and Utah,
federal and state officials we interviewed had identified many aviation
and ground firefighting assets that went toward protecting nonfederal
lands and resources. Although we were unable to fully estimate a
distribution of costs using an alternative method due to limitations in
the data available, our analysis suggested, and many of the officials
we interviewed acknowledged, that the nonfederal entities would have
borne a larger share of the costs.
Current Cost-Sharing Framework Raises Several Concerns:
Federal and nonfederal agency officials we interviewed raised a number
of concerns about the current cost-sharing framework. First, some
federal officials said that because master agreements and other
policies do not provide clear guidance about which cost-sharing methods
to use, it has sometimes been difficult to obtain a cost-sharing
agreement that they believe shares suppression costs equitably. Second,
nonfederal officials were concerned that the emergence of alternative
cost-sharing methods has caused nonfederal entities to bear a greater
share of fire suppression costs than in the past. Finally, some federal
officials expressed concern that the current framework for sharing
costs insulates state and local governments from the cost of protecting
the wildland-urban interface, thereby reducing their incentive to take
steps that could help mitigate fire risks and reduce suppression costs
in the wildland-urban interface. On the basis of our review of previous
federal reports and interviews with federal and nonfederal officials,
we believe these concerns may reflect a more fundamental issue--that
federal and nonfederal entities have not clearly defined their
financial responsibilities for wildland fire suppression, particularly
for the wildland-urban interface.
Lack of Clear Guidance Can Lead to Difficulties in Sharing Costs:
Some federal officials said that the lack of clear guidance can make it
difficult to agree to use a cost-sharing method that they believe
equitably distributes suppression costs between federal and nonfederal
entities, particularly for fires that threaten the wildland-urban
interface. For example, different cost-sharing methods were used for
the two fires we reviewed in Utah, even though both fires required
substantial suppression efforts to protect the wildland-urban
interface. For the Blue Springs Fire, nonfederal officials agreed to
pay a higher proportion of the suppression costs than they would have
paid had an acres-burned method been used, because they recognized the
substantial effort undertaken to protect the wildland-urban interface
and because most of the state's costs for that fire were eligible for
FEMA reimbursement. For the Sunrise Complex, the federal official who
negotiated the cost-sharing agreement said that using a method other
than acres burned might have better recognized and distributed the
costs of the suppression effort necessary to protect the wildland-urban
interface. Nonfederal officials, however, said they were not willing to
pay a higher proportion of costs for the Sunrise Complex because for
that fire, the state was ineligible for financial assistance from FEMA.
The federal official said that because of the state officials'
unwillingness to use a method other than acres burned, and because of
the lack of clear guidance about which cost-sharing method should be
used, he agreed to use an acres-burned method and did not seek a cost-
sharing agreement that would have assigned more of the Sunrise
Complex's costs to the nonfederal entities. Some federal officials in
Arizona expressed similar views, saying that the lack of clear guidance
on sharing costs can make it difficult to reach agreement with
nonfederal officials. For example, federal and state officials in
Arizona did not agree on whether to share costs for the Florida Fire in
that state.
Officials from NASF and the Utah Division of Forestry, Fire and State
Lands raised a related issue--that existing guidance does not specify
how costs should be shared when one entity's management goals alter
fire suppression strategies and increase costs. For example, these
officials said that federal agencies may restrict the use of mechanized
equipment in wilderness areas or in sensitive wildlife habitat and
increase the use of aircraft instead. The officials did not believe
that nonfederal entities should have to pay for the resulting higher
costs. Utah officials said that although they have been able to reach
cost-sharing agreements they believe are appropriate in such cases,
guidance should be improved to recognize these situations.
Officials from the Forest Service's and the Department of the
Interior's national offices agreed that interagency policies for cost
sharing could be clarified to indicate under what circumstances
particular cost-sharing methods are most appropriate. They said that
the acres-burned method, for example, is likely not the most equitable
method to share costs in cases where fires threaten the wildland-urban
interface. But they also said that it would be difficult to develop
universal guidance requiring a particular cost-sharing method for fires
with certain characteristics. They explained that the organization,
responsibilities, and funding of state and local firefighting entities
vary from state to state, and flexibility is therefore needed. The
National Fire and Aviation Executive Board was developing a template
for both master and cost-sharing agreements.[Footnote 16] As of May
2006, this template had not been finalized, but our review of a draft
version indicated that the template might not provide additional
clarity about when each cost-sharing method should be used.[Footnote
17]
Nonfederal Officials Were Concerned about Increased Costs and Equity
among States:
While federal officials expressed the need for further guidance on how
to share costs, nonfederal officials were concerned that the emergence
of alternative cost-sharing methods was leading state and local
entities to bear a greater share of suppression costs than in the past,
and they questioned whether such an increase was appropriate.
Nonfederal officials also said that wildland fire suppression costs
already posed budgetary challenges for state and local entities and
that using alternative cost-sharing methods more often could exacerbate
the situation. State officials said that if a state's suppression costs
in a given year exceed the funds budgeted, they must seek additional
state funds, which can be difficult. Moreover, they said, in many
states, protecting structures is primarily a local responsibility, and
many local entities are unable to pay the costs of fighting a large
fire that threatens the wildland-urban interface.[Footnote 18] Although
clarifying guidance about which cost-sharing methods are most
appropriate for particular circumstances could cause nonfederal
entities to bear more wildland fire suppression costs, over the long
term, such clarification would also allow each entity to better
determine its budgetary needs and take steps to meet them.
In addition to their concerns about increased costs, nonfederal as well
as federal officials were concerned that the federal government was
treating nonfederal entities in different states differently, thereby
creating inequities. Federal and nonfederal officials said that because
some states use particular cost-sharing methods more often than other
states, the proportion of costs borne by federal and nonfederal
entities likely varies from state to state, resulting in nonfederal
entities' paying a higher proportion of costs in some states and a
lower proportion in other states. For example, nonfederal officials in
Utah said that even though they agreed to pay certain aircraft and fire
engine costs to protect the wildland-urban interface on the Blue
Springs Fire, they were uncertain if this method was equitable,
particularly if nonfederal entities were not paying for similar costs
in other states. Clarifying which cost-sharing methods should be used
in particular situations could increase nonfederal officials' assurance
that the federal government is treating them equitably relative to
other states.
Cost-Sharing Framework May Reduce Incentives to Mitigate Fire Risks in
the Wildland-Urban Interface:
In addition to the concerns raised about obtaining equitable cost-
sharing agreements and about the increased costs to nonfederal
entities, federal officials said that the current cost-sharing
framework insulates state and local governments from the cost of
protecting the wildland-urban interface. A variety of protective
measures are available to help protect structures from wildland fire,
although they are not consistently used in areas at risk. Some federal
and nonfederal officials noted that the current framework for sharing
costs--combined with the availability of funds from FEMA for some
emergency fire suppression costs--may reduce the incentive for state
and local governments to require that such measures be taken.
Measures Are Available to Mitigate Fire Risks in the Wildland-Urban
Interface, but They Are Not Consistently Used:
Firefighting officials and researchers have identified a variety of
measures that can mitigate the risk to structures from wildland fire.
As we have previously reported, key among these measures are (1)
reducing vegetation and flammable objects within an area of 30 to 100
feet around a structure, often called creating a defensible space, and
(2) using fire-resistant roofing materials and covering attic vents
with mesh screens.[Footnote 19] In addition, fire-resistant windows and
building materials can help prevent structures from igniting. Other
measures, such as designing communities to ensure an adequate water
supply for fighting fires and access for emergency vehicles, can assist
fire suppression efforts and further reduce the risk to structures.
Taken together, these measures can help reduce the likelihood that a
wildland fire will damage a structure.
Increasing the use of protective measures to mitigate the risk to
structures from wildland fire is a key goal of the National Fire Plan.
This plan--developed by federal wildland fire agencies and state
governors--encourages, but does not mandate, state or local governments
to adopt laws requiring homeowners and homebuilders to take measures to
help protect structures from wildland fires. Because these measures
rely on the actions of individual homeowners or on laws and land-use
planning affecting private lands, achieving this goal is primarily a
state and local government responsibility. The National Association of
Counties supports this goal.
Federal and nonfederal officials told us that the use of measures to
help protect structures from wildland fires has become more common, but
that such measures are not consistently used in areas at risk. The
increased use of these measures in recent years is due in part to
continuing federal and nonfederal efforts to educate homeowners in the
wildland-urban interface and to state and local governments' adopting
laws requiring that such measures be used. Education efforts, such as
the Firewise Communities program,[Footnote 20] seek to increase the
voluntary use of such measures by working with community leaders and
individual homeowners. As wildland fires have become more severe and
the number of damaged homes has grown, more state and local governments
have adopted laws requiring homeowners or homebuilders to use measures
to reduce the risk to structures from wildland fires. Nevertheless,
federal and nonfederal fire officials told us that protective measures
are not used consistently in many areas at risk from wildland fire.
Some homeowners and homebuilders, for example, resist using fire-
resistant landscaping and roofing because they are concerned about
aesthetics, time, or cost. As a result, federal and nonfederal
officials said, it can be politically difficult for state and local
governments to adopt--and enforce--laws requiring such measures, and
many at-risk areas have not done so. In 2004, the Western Governors'
Association reported that greater use of protective measures was
urgent, but the progress made was unknown.[Footnote 21]
The states and communities we visited exhibited various degrees of
progress in adopting laws requiring protective measures. Since 1965,
for example, California has required homeowners in the wildland-urban
interface to maintain 30 feet of defensible space around their homes, a
requirement that was increased to 100 feet in 2005. This law applies to
existing homes as well as to new construction and specifically allows
local jurisdictions to adopt stricter standards. In areas at
particularly high risk from wildland fires, California regulations also
require new structures to be constructed with fire-resistant roofing
materials and vents. The other states we visited do not have such
statewide requirements, but they are taking a variety of steps to
require or encourage protective measures. Utah, for example, passed a
law in 2004 requiring its counties to adopt standards for landscaping
and building materials if they want to be eligible to receive state
funds to assist with fire suppression costs. According to state
officials, exactly what will be required under these standards was
still being determined, but once final, the standards will apply only
to new construction, not existing structures. Similarly, Arizona did
not have any statewide requirements, although it adopted a law in 2004
explicitly granting local governments the authority to establish codes
to mitigate wildland fire risk in the wildland-urban interface.
Finally, in Colorado, laws requiring protective measures have been
adopted primarily at the local, not state, level. Although some
counties, such as Larimer County, required owners of new structures in
the wildland-urban interface to use measures to help mitigate fire
risk, others--including the three counties affected by the wildfires we
reviewed--were educating homeowners about measures they can use to
reduce their risk, without requiring that such measures be used.
Cost-Sharing Framework and Federal Assistance May Reduce the Incentive
to Require the Use of Protective Measures:
Although measures are available to help protect structures in the
wildland-urban interface from wildland fires, federal officials
expressed concern--and some nonfederal officials acknowledged--that the
use of cost-sharing methods that assign more costs to federal entities,
and the availability of federal emergency assistance, insulate state
and local governments from the cost of providing wildland fire
protection. These federal officials pointed out that wildland fires
threatening structures often require added suppression effort, such as
an increased number of aircraft and fire engines or firefighters to
remove vegetation around individual structures. Under some cost-sharing
methods, such as acres burned, federal entities often end up paying a
large proportion of the costs for these efforts. Some federal and
nonfederal officials also noted that the availability of FEMA
assistance to nonfederal entities--which can amount to 75 percent of
allowable fire suppression costs for eligible fires--further insulates
state and local governments from the cost of protecting the wildland-
urban interface. Of the eight fires included in our review, nonfederal
officials were seeking reimbursement for the allowable costs of the
five fires that FEMA determined met eligibility requirements.
Federal officials suggested that to the extent that state and local
governments are insulated from the cost of protecting the wildland-
urban interface, these governments may have a reduced incentive to
adopt laws requiring homeowners and homebuilders to use protective
measures that could help mitigate fire risks. Homeowner and homebuilder
resistance make it politically difficult to adopt and enforce such
laws. Both federal and nonfederal officials noted, however, that
greater use of fire-resistant building materials and landscaping could
help reduce the cost of protecting the wildland-urban interface. Some
officials also said that by requiring homeowners and homebuilders to
take such measures, more of the cost of protecting the wildland-urban
interface would then be borne by those who chose to live there. The
Colorado State Forest Service, for example, has reported that the
expansion of the wildland-urban interface has increased wildland fire
suppression costs, but that these costs have not been equitably divided
because all taxpayers--not just those who live in areas threatened by
wildland fire--fund the cost of suppression.[Footnote 22]
Officials' Concerns May Reflect Ambiguity over Financial
Responsibilities:
On the basis of our review of previous federal reports and interviews
with federal and nonfederal officials, we believe that the concerns we
identified may reflect a more fundamental issue--that federal and
nonfederal firefighting entities have not clearly defined their
financial responsibilities for wildland fire suppression, particularly
those for protecting the wildland-urban interface. Federal officials
said that the continuing expansion of the wildland-urban interface and
rising fire suppression costs for protecting these areas have increased
the importance of resolving these issues. First, federal wildland fire
management policy states that protecting structures is the
responsibility of state, tribal, and local entities; but the policy
also says that, under a formal fire protection agreement specifying the
financial responsibilities of each entity, federal agencies can assist
nonfederal entities in protecting the exterior of structures threatened
by wildland fire.[Footnote 23] Forest Service guidance defines actions
to protect the exterior of structures to include removing fuels in the
vicinity of structures and spraying water or retardant on structures or
surrounding vegetation. Federal and nonfederal officials agreed that
federal agencies can assist with such actions, but they did not agree
on which entities are responsible for bearing the costs of these
actions. Federal officials told us that the purpose of this policy is
to allow federal agencies to use their personnel and equipment to help
protect homes but not to bear the financial responsibility of providing
that protection. Nonfederal officials, however, said that these actions
are intended to keep a wildland fire from reaching structures, and
financial responsibility should therefore be shared between both
federal and nonfederal entities.
Second, the presence of structures adjacent to federal lands can
substantially alter fire suppression strategies and raise costs. A
previous federal report and federal officials have questioned which
entities are financially responsible for suppression actions taken on
federal lands but intended primarily or exclusively to protect adjacent
wildland-urban interface. Fire managers typically use existing roads
and geographic features, such as rivers and ridgelines, as firebreaks
to help contain wildland fires. If, however, homes and other structures
are located between a fire and such natural firebreaks, firefighters
may have to construct other firebreaks and rely more than they
otherwise would on aircraft to drop fire retardant to protect the
structures, thereby increasing suppression costs. For example, for the
Sunrise Complex fires in Utah, federal and nonfederal officials agreed
that if structures had not been present, they could have used easily
accessible roads to contain the fire and would not have used as many
aircraft. Nonfederal officials in several states, however, questioned
the appropriateness of assigning to nonfederal entities the costs for
suppression actions taken on federal lands. These officials, as well as
NASF officials, also said that accumulated fuels on federal lands is
resulting in more severe wildland fires and contributing to the
increased cost of fire suppression.[Footnote 24] They also said that
federal agencies are responsible for keeping wildland fires from
burning off federal land and should, therefore, bear the costs of doing
so. Federal officials in the states we visited recognized this
responsibility, but some also said that with the growing awareness that
wildland fires are inevitable in many parts of the country, policy
should recognize that wildland fires will occur and are likely to burn
across jurisdictional boundaries. In their view, those who own property
in areas at risk of wildland fires share a portion of the financial
responsibility for protecting it. Previous federal agency reports have
also recognized this issue and have called for clarifying financial
responsibility for such actions.[Footnote 25]
Conclusions:
Wildland fires are an enduring part of the landscape, and they will
continue to affect both federal and nonfederal lands and resources.
Federal, state, and local firefighting entities have taken great
strides to develop a cooperative fire protection system so that these
entities can effectively work together to respond to these fires.
Nevertheless, where federal and nonfederal lands and resources are
adjacent or intermingled, particularly in the wildland-urban interface,
different views prevail about which entity is responsible for the costs
of protecting these lands and resources. Without explicit delineation
of each entity's firefighting financial responsibilities, federal and
nonfederal entities' concerns about how these costs are shared are
likely to continue. In addition, lack of clarity about respective
financial responsibilities can also make it more difficult for both
federal and nonfederal entities to accurately forecast and plan for
future budget needs. As the wildland-urban interface continues to
become a more prominent feature of the fire suppression landscape,
contributing to rising suppression costs, the need for clarity is
becoming more acute. Improved guidance that clearly delineates federal
and nonfederal entities' financial responsibilities for suppressing
wildland fires could assist all entities in better planning for, and
during, a fire season.
Recommendations for Executive Action:
To strengthen the framework for sharing wildland fire suppression
costs, we recommend that the Secretaries of Agriculture and the
Interior, working in conjunction with relevant state entities, take the
following two actions:
* provide more specific guidance as to when particular cost-sharing
methods should be used and:
* clarify the financial responsibilities for suppressing fires that
burn, or threaten to burn, across multiple jurisdictions.
Agency Comments and Our Evaluation:
We received written comments on a draft of this report from the Forest
Service and Interior. Both agencies generally concurred with our
findings and recommendations. The Forest Service stated that it will
clarify the guidance to the field regarding the most appropriate cost-
share method to use in a given situation, which will serve as a place
to begin negotiations with its partners. We recommended, however, that
the Secretaries of Agriculture and the Interior work in conjunction
with relevant state entities to develop more specific guidance. If the
Forest Service independently clarifies guidance without engaging state
entities that also will be affected by any changes, there is no
assurance that these state entities will agree to the changes in cost-
sharing methods. Interior stated, however, that it would work closely
with the Forest Service and state agencies to clarify such guidance to
the field.
The Forest Service also stated that its financial responsibilities are
clearly defined in policy. Several federal officials with whom we spoke
during our study disagreed, however, stating that these policies do not
clearly delineate federal entities' financial responsibility for fire
protection, especially in regards to the wildland-urban interface.
Although Forest Service policy states that structural fire suppression
is the responsibility of tribal, state, or local governments and the
Forest Service's primary responsibility and objective for structure
protection is to suppress wildland fire before it reaches structures,
it does not clearly define what this would constitute. Officials told
us that such actions could include efforts on Forest Service lands to
keep fire from crossing jurisdictional boundaries or suppression
actions in closer proximity to a structure, such as removing vegetation
or other flammable objects. Without a clear definition of each entity's
protection and related financial responsibilities, it will be difficult
to determine how to appropriately share the costs of the efforts. The
Forest Service also provided additional comments that we have
incorporated in this report where appropriate. The Forest Service's and
Interior's letters are reprinted in appendixes III and IV,
respectively, along with our evaluation of specific Forest Service
comments in appendix III.
In addition to these federal agencies, we also sought comments from
NASF because of our report's potential financial implications for
states and other nonfederal entities. NASF provided both oral comments
and a written response to our report. NASF did not agree with our
recommendations, stating that developing national guidance specifying
appropriate cost-sharing methods and clarifying financial
responsibility for fire suppression costs would not provide the
flexibility needed by local federal and nonfederal officials to address
the variability in local circumstances and state laws. We agree that a
certain amount of flexibility is needed. However, without more specific
guidance to assist federal and nonfederal officials when developing
cost-sharing agreements for particular fires, inconsistencies in the
methods used--as well as perceived inequities in how costs are shared
between federal and nonfederal entities, as expressed by many officials
with whom we spoke--are likely to continue. A copy of NASF's letter and
our evaluation of its specific comments are included in appendix V.
As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies of this report
to interested congressional committees, the Secretaries of Agriculture
and the Interior, the Chief of the Forest Service, the Director of the
Bureau of Land Management, and other interested parties. We will also
make copies available to others upon request. In addition, this report
will be available at no charge on the GAO Web site at [Hyperlink,
http://www.gao.gov].
If you or your staff have questions about this report, please contact
me at (202) 512-3841 or nazzaror@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report are
listed in appendix VI.
Sincerely yours,
Signed by:
Robin M. Nazzaro:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Scope and Methodology:
To determine the general framework for how federal and nonfederal
entities share suppression costs when fires burn or threaten both their
lands and resources, we reviewed federal laws and interagency policies
governing cost sharing for cooperative fire protection efforts. To
identify similarities and differences in the cost-sharing framework and
available methods from state to state, we obtained and reviewed master
agreements between federal and nonfederal entities for 12 western
states.[Footnote 26] Although wildland fires can affect all states, we
focused our review on these western states, which have substantial
federal lands and often experience wildland fires.
To identify how cost-sharing methods are applied in different states,
we selected a nonprobability sample of four states--Arizona,
California, Colorado, and Utah--that used a variety of different
methods to share wildland fire suppression costs between federal and
nonfederal entities. In each of the four states, we selected a
nonprobability sample of two fires that occurred in 2004 or 2005 and
were managed by either the Forest Service or the Bureau of Land
Management.[Footnote 27] The eight fires all burned or threatened to
burn both federal and nonfederal lands, burned or threatened both
natural resources and wildland-urban interface areas, and were of
sufficient size and complexity to require type 1 or type 2 incident
management teams for a portion of the fire. For each of the eight
fires, we reviewed available records on firefighting personnel,
aircraft, and equipment used for fire suppression efforts; reviewed
fire cost data; reviewed the cost-sharing agreement that federal and
nonfederal officials negotiated, if any; interviewed federal and
nonfederal officials to identify the process used to select the cost-
sharing method; and obtained agency estimates of total suppression
costs that were based on data collected by federal agencies for each
fire. Using this information and working with federal and nonfederal
officials, we estimated the federal and nonfederal shares of the
suppression costs. To determine the effect of the cost-sharing method
selected on the relative proportion of costs borne by federal and
nonfederal entities--for the five fires that used a cost-sharing method
other than acres burned--we compared the estimated federal and
nonfederal shares of costs resulting from the cost-sharing agreement to
our estimate of what the federal and nonfederal shares of costs would
have been if an acres-burned method had been used. We used estimates of
suppression costs for some of the fires because the entities had not
yet determined the actual total cost for all eight fires we reviewed.
To determine the reliability of the data used, we reviewed previous
audits of the federal financial systems used for the accounting of fire
costs; interviewed federal officials knowledgeable about these systems
to identify how data are entered into the system and what steps are
taken to help ensure accuracy; and, working with federal and nonfederal
officials, reviewed data on the specific firefighting assets used and
the related costs for the eight fires. Because we were primarily
interested in the relative proportions of fire costs borne by federal
and nonfederal entities using different cost-sharing methods, we
determined that these data were sufficiently reliable for the purposes
of this study. The 12 master agreements reviewed, the four states
visited, and the two fires we reviewed within each state are all
nonprobability samples. The results of these samples, therefore, cannot
be used to make inferences about all master agreements, states, or
wildland fires.
To identify concerns that federal and nonfederal entities may have
about the existing cost-sharing framework, we reviewed previous reports
on wildland fire suppression, including large fire cost reviews
conducted by the Departments of Agriculture or the Interior, a series
of reports by the National Academy of Public Administration, and
reports by state entities. We interviewed federal officials from the
Department of the Interior's and Forest Service's national offices and
the National Interagency Fire Center in Boise, Idaho; Forest Service
officials from the four regional offices and other Forest Service
officials involved with the fires we reviewed; and Bureau of Land
Management officials from the two state offices and several district
offices involved with the fires we reviewed. We also interviewed
additional federal officials in other regions and states to obtain a
broader perspective on any concerns with the cost-sharing framework.
Nonfederal officials that we interviewed included state--and, in some
cases, local--officials from the four states we visited, as well as
officials from Montana, Oregon, and Washington. We also reviewed
reports by or interviewed officials from the National Association of
State Foresters (NASF), the Western Governors' Association, and the
National Association of Counties. To better understand the concern
officials raised about the cost-sharing framework and incentives to
increase the use of protective measures, we reviewed federal policies
and reports on protecting the wildland-urban interface, including the
National Fire Plan and the federal wildland fire management policy;
federal laws and regulations governing Federal Emergency Management
Agency (FEMA) assistance; and reports by GAO,[Footnote 28] the American
Planning Association,[Footnote 29] and state audit entities.
We performed our work in accordance with generally accepted government
auditing standards from May 2005 through May 2006.
[End of section]
Appendix II: Characteristics of the Eight Fires That GAO Reviewed:
State: Arizona;
Fire: Cave Creek Complex;
Date: June-July 2005;
IMT type[A]: 1;
Number of acres burned (percentage of total): Federal: 231,171 (94%);
Number of acres burned (percentage of total): Nonfederal: 15,543 (6%);
Total acres burned: 246,714;
Total cost: $19,413,000.
Fire: Florida Fire;
Date: July 2005;
IMT type[A]: 1;
Number of acres burned (percentage of total): Federal: 22,549 (97);
Number of acres burned (percentage of total): Nonfederal: 634 (3);
Total acres burned: 23,183;
Total cost: 6,217,000.
State: California;
Fire: Deep Fire;
Date: August 2004;
IMT type[A]: 1;
Number of acres burned (percentage of total): Federal: 2,928 (93);
Number of acres burned (percentage of total): Nonfederal: 220 (7);
Total acres burned: 3,148;
Total cost: 8,412,000.
Fire: Pine Fire;
Date: July 2004;
IMT type[A]: 1;
Number of acres burned (percentage of total): Federal: 4,180 (24);
Number of acres burned (percentage of total): Nonfederal: 13,238 (76);
Total acres burned: 17,418;
Total cost: 13,311,000.
State/: Colorado;
Fire: Mason Gulch Fire;
Date: July 2005;
IMT type[A]: 1;
Number of acres burned (percentage of total): Federal: 9,124 (80);
Number of acres burned (percentage of total): Nonfederal: 2,233 (20);
Total acres burned: 11,357;
Total cost: 7,054,000.
Fire: McGruder Fire;
Date: July 2004;
IMT type[A]: 2;
Number of acres burned (percentage of total): Federal: 1,404 (50);
Number of acres burned (percentage of total): Nonfederal: 1,402 (50);
Total acres burned: 2,806;
Total cost: 805,000.
State: Utah;
Fire: Blue Springs Fire;
Date: June-July 2005;
IMT type[A]: 2;
Number of acres burned (percentage of total): Federal: 10,331 (84);
Number of acres burned (percentage of total): Nonfederal: 1,955 (16);
Total acres burned: 12,286;
Total cost: 3,497,000.
Fire: Sunrise Complex;
Date: July 2005;
IMT type[A]: 2;
Number of acres burned (percentage of total): Federal: 18,186 (85);
Number of acres burned (percentage of total): Nonfederal: 3,272 (15);
Total acres burned: 21,458;
Total cost: 2,043,000.
Source: GAO analysis of data from the Forest Service and the Department
of the Interior.
[A] Incident management teams (IMT) are assigned to manage wildland
fire suppression efforts on the basis of fire size and complexity. Type
1 IMTs typically handle the most complex fires. The IMTs listed in the
table represent the IMT type on each fire during its peak size and
complexity.
[End of table]
[End of section]
Appendix III: Comments from the USDA Forest Service:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
USDA:
United States Department of Agriculture:
Forest Service
Washington Office:
1400 Independence Avenue, SW:
Washington, DC 20250:
File Code: 1420/1310/1930:
Date: APR 18 2006:
Ms. Robin Nazzaro:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, N. W.
Washington, DC 20548:
Dear Ms. Nazzaro:
Thank you for the opportunity to review and comment on the draft
Government Accountability Office (GAO) report, GAO-06-570, "Wildland
Fire Suppression: Lack of Clear Guidance Raises Concerns about Cost
Sharing among Federal and Nonfederal Entities." The Forest Service
generally agrees with the findings and recommendations in the report
and believes that GAO accurately highlighted some of the complexities
associated with large, multi jurisdictional wildland fires.
There are a few points that the Forest Service would like to see
clarified.
* The heading "Unclear Guidance and Inconsistent Application of Cost-
Sharing Method Can Be Costly for Entities Involved" seems to imply that
clearer guidance and consistent application of cost share methods would
result in reduced wildland fire costs. However, the question is reduced
costs for whom? Wildland fires in the urban interface are expensive
regardless of the cost sharing methods used. We suggest the following
modification "Unclear Guidance and Inconsistent Applications of Cost-
Sharing Method Can Lead to an Inequitable Apportionment of Costs."
* Under the heading "Cost-Sharing Method Used Could Lead to
Significantly Different Financial Outcomes", the report states that
"For two other fires we reviewed in which federal and nonfederal
entities had agreed to use the acres-burned method, nonfederal entities
might have borne a greater proportion of the costs had a different cost-
sharing method been used". This statement seems to imply that the
Forest Service should choose the cost-sharing method that results in
the states paying a greater share.
The report recommends that the Secretaries, working with relevant state
agencies, provide more specific guidance as to when particular cost-
sharing methods should be used and clarify the financial
responsibilities for fires that burn or threaten to burn across
multiple jurisdictions. The Forest Service will clarify the guidance to
the field regarding the most appropriate cost-share method to use in a
given situation. This guidance will serve as a place to begin
negotiations with our partners. The final cost-sharing method chosen
will take into account a multitude of factors that will be determined
at the incident. The Forest Service's financial responsibilities are
clearly defined in our policy. Reiteration of these financial
responsibilities will occur as Master Fire Agreements with states are
updated.
If you have any additional questions or concerns, please contact the
Forest Service audit lead, Sandra Cantler, Fire and Aviation
Management, at 202-205-1438, or Sandy T. Coleman, Assistant Director
for GAO/OIG Audit Liaison staff, at 703-605-4699.
Sincerely,
Signed by:
Dale N. Bosworth:
Chief:
cc: Sandra Cantler, Jesse L King, Sandy T Coleman, Clarice Wesley:
The following are GAO's comments on the USDA Forest Service's letter
dated April 18, 2006.
GAO Comments:
1. We modified the language of our report to clarify that the cost-
sharing method chosen can have significant financial consequences for
the entities responsible for providing fire protection to the lands
involved. Although we agree that fires affecting the wildland-urban
interface may be costly, regardless of the method used, it is precisely
these high costs that make it critical for federal and nonfederal
entities to agree on appropriate cost-sharing methods.
2. We modified the language of our report to clarify that for the two
fires discussed, nonfederal entities would likely have borne a greater
proportion of the costs if another cost-sharing method had been used
that better recognized the many aviation and ground firefighting assets
that went toward protecting nonfederal lands and resources. We are not
implying that costs should be shifted to the state or nonfederal
entities without any basis. Rather, federal and nonfederal partners
need to agree on cost-sharing methods that appropriately distribute
wildland fire suppression costs on the basis of the federal and
nonfederal lands and resources requiring fire protection and the extent
of firefighting assets used to protect each.
[End of section]
Appendix IV: Comments from the Department of the Interior:
United States Department of the Interior:
Office Of The Assistant Secretary:
Policy, Management And Budget:
Washington, D.C. 20240:
Ms. Robin Nazzaro:
Natural Resources and Environment:
United States General Accounting Office:
441 G Street, N.W.
Washington, DC 20548:
April 27, 2006:
Dear Ms. Nazarro:
Thank you for giving us the opportunity to review the draft report,
Wildland Fire Suppression: Lack of Clear Guidance Raises Concerns about
Cost Sharing among Federal and Nonfederal Entities (GAO-06-570). We
agree with the fundamental premise of the report that there is a need
for more guidance as to when particular cost sharing methods should be
used to clarify an entity's financial responsibilities.
The report recommends that the Secretaries of Interior and Agriculture,
working with relevant state agencies, provide more specific guidance as
to when particular cost-sharing methods should be used and clarify the
financial responsibilities for fires that burn or threaten to burn
across multiple jurisdictions. The Department of the Interior will work
closely with the Forest Service and state agencies to clarify guidance
to the field regarding the most appropriate cost-share method to use in
a given situation.
In addition, as pointed out in the report, the capacity to correctly
share wildland fire suppression cost incurred by the Federal Government
(Forest Service, Department of the Interior, and Federal Emergency
Management Agency (FEMA)) with nonfederal entities may be challenged by
the competing Federal statutes and policies, such as FEMA's
reimbursement of nonfederal entities in certain cases. We have seen
this issue arise several times already this year when states, affected
by the early fire season, requested and then released Federal
firefighting resources seemingly based solely on whether or not a
Federal reimbursement was available.
In closing, I would like to express my appreciation for a balanced and
thorough examination of the issues surrounding cost sharing among
Federal and nonfederal entities. The Department of the Interior will
use this report as a point of reference as we deal with cost sharing
issues in the future.
Sincerely,
Signed by:
R. Thomas Weimer:
Assistant Secretary:
[End of section]
Appendix V: Comments from the National Association of State Foresters:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
2006 Executive Committee:
President James B. Hull Texas:
Vice President E. Austin Short Delaware:
Treasurer Kirk Rowdabaugh Arizona:
Northeastern Representative John Dorka Ohio:
Western Representative David T. Limtiaco Guam:
Southern Representative Steven G. Scott Tennessee:
Immediate Past President Pat McElroy Washington:
Executive Director: Anne E. Heissenbuttel:
National Association Of State Foresters:
444 North Capitol Street, NW, Suite 540, Washington, DC 20001:
May 5, 2006:
Robin M. Nazzaro:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW Room 2T43:
Washington, DC 20548:
Dear Ms. Nazzaro:
On behalf of the National Association of State Foresters (NASF), I
would like to thank you very much for providing us the opportunity to
meet with you and other GAO staff earlier this week. Our delegation
greatly appreciated the chance to review and offer our views on the
findings and recommendations in your draft report, "Wildland Fire
Suppression: Lack of Clear Guidance Raises Concerns about Cost Sharing
among Federal and Nonfederal Entities". We recognize that this
opportunity was unusual for a nonfederal organization. The cooperative
federal-state partnership is essential to effective and efficient
wildland fire suppression, and we took our assignment very seriously.
During the discussion our delegation offered a number of suggestions
and observations regarding the report. They included identifying minor
factual errors, suggestions for clarifying certain points, and
providing additional background on others. We hope that you found our
suggestions to be both informative and helpful, and that they will lead
to adjustments in your final report. I will not repeat them in this
correspondence.
As our delegation indicated during their meeting with you, NASF also
wishes to formally respond to your recommendation for executive action,
which reads: "To strengthen the framework for sharing wildland fire
suppression costs, GAO recommends that the Secretaries of Agriculture
and the Interior, working in conjunction with relevant state entities,
provide more specific guidance as to when particular cost-sharing
methods should be used and clarify the financial responsibilities for
suppressing fires that burn or threaten to burn across multiple
jurisdictions." (Emphasis added.)
First, in regard to providing more specific guidance on using cost-
share methods, Anne E. Heissenbuttel we believe that the national
template for Master Cooperative Agreements currently being developed by
the National Fire and Aviation Executive Board will provide appropriate
guidance for cost-share agreements. As your report notes, this draft
template identifies the requirement for a cost-share agreement and
defines the various options available to Line Officers. Although the
guidance in the template is not definitive regarding which option to
use under any specific set of circumstances, it provides the necessary
flexibility needed by Line Officers to effectively address local
variability in terms of terrain, fuels, values at risk, and local
protection responsibilities. We believe that further efforts to define
the specific circumstances that would warrant the selection of one cost-
share method over another, or identify the point at which a fire
crosses some arbitrary threshold, will neither be productive nor
helpful. Federal and state Line Officers need the flexibility to
jointly craft cost-share agreements appropriate to the complexity of
the incident, not attempt to apply rigid, national guidelines that may
not fit their local circumstances.
Second, we strongly believe that it is not the responsibility of the
Secretaries of Agriculture and the Interior to "clarify financial
responsibilities for suppressing fires that burn or threaten to burn
across multiple jurisdictions". The Secretaries clearly have the
responsibility to clarify federal responsibilities on federal lands
which, in fact, they have done. The 1995 Federal Wildland Fire Policy,
as revised in 2001, accurately defines federal fire protection
responsibilities, including operations in the wildland-urban interface.
We believe that federal responsibilities on federal lands are clear:
federal agencies have an obligation to keep fires originating on their
lands from spreading off federal lands to other ownerships. On the
other hand, it is the responsibility of state and local government to
define their financial obligations through state law and local
ordinances and codes. And, as states are independent entities, their
laws, ordinances and codes are frequently different from state to
state. Therefore, we believe that it is neither feasible nor
appropriate to attempt to define at the national level the financial
responsibilities for suppressing wildfires that burn across
federal/nonfederal jurisdictional boundaries. Federal agencies must
recognize that differences in state laws require that financial
decisions on sharing suppression costs must be determined on a state-
by-state basis.
Thank you again for the opportunity to review the draft and provide our
comments for your consideration prior to completion of the final
report. Our delegation members express their appreciation for your
patience and courtesy. Please contact Jeff Jahnke, chair of our Forest
Fire Protection Committee, if you have any questions on our comments or
need any clarification. Jeff can be reached at the Colorado Forest
Service at 970/491-6303, or by email at jjahnke@lamar.colostate.edu.
Sincerely,
Signed by:
James B. Hull:
President:
CC: Jeff Jahnke (CO), Chair, NASF Fire Committee:
Kirk Rowdabaugh (AZ), Treasurer, NASF:
Don Artley, NASF Fire Director:
Anne Heissenbuttel, NASF Executive Director:
The following are GAO's comments on NASF's letter dated May 5, 2006.
GAO Comments:
1. NASF stated that it believes that the national template currently
being developed for master cooperative agreements will provide
appropriate guidance for cost-sharing agreements. As NASF noted, the
draft template lists several options for sharing suppression costs but
does not provide definitive guidance as to when each cost-sharing
method should be used. NASF stated that it does not believe that
further efforts to define the specific circumstances that would warrant
the selection of one cost-sharing method over another would be either
productive or helpful. We continue to believe that more specific
guidance--which could consider local characteristics and conditions--
would assist local federal and nonfederal officials in negotiating cost-
sharing agreements for individual fires. Without such guidance,
inconsistencies in how costs are shared are likely to continue, along
with perceived inequities within and among states.
2. NASF strongly believes that it is not the responsibility of the
Secretaries of Agriculture and the Interior to clarify the financial
responsibilities for suppressing fires that burn or threaten to burn
across multiple jurisdictions. We agree with NASF that the Secretaries
alone cannot clarify these responsibilities, and for that reason, we
recommended that the Secretaries do so in conjunction with relevant
state entities. Further, NASF stated that it is neither feasible nor
appropriate to attempt to define at the national level the financial
responsibilities for these fires. Ultimately, however, one or more
entities will end up paying for the costs of fighting a particular
fire, whether by explicit agreement beforehand or by negotiation
afterward. To avert decision making after the fact, we maintain that
federal and nonfederal entities--which have developed an effective
cooperative firefighting relationship--need to further clarify their
respective financial responsibilities in guidance articulated in
advance of the fire season.
In addition to written comments, NASF also commented orally about two
other issues discussed in our report. First, NASF officials expressed
concern about our example illustrating the influence of FEMA assistance
on the selection of a cost-sharing method for a particular fire. They
said that, in their experience, the availability of FEMA assistance
does not influence a state's willingness to use certain cost-sharing
methods, some of which may lead states to pay higher costs. Although we
did not attempt to determine how often the availability of FEMA
assistance affected a state's choice of cost-sharing method, we believe
that our example illustrates how, without specific guidance, costs for
similar fires have been shared in different ways. In its written
comments, Interior also raised a related concern about federal
assistance such as FEMA's. Interior commented that it has already seen
the issue arise several times this year, when states have requested,
then canceled, federal firefighting resources seemingly on the sole
basis of whether federal reimbursement was available. Second, with
regard to state and local governments' incentives for protecting the
wildland-urban interface, NASF officials said that reducing the
potential loss of life and property provides sufficient incentive for
state and local governments to adopt laws requiring the use of
protective measures against wildland fire. As we noted here and in a
previous report, however, many jurisdictions at risk from wildland fire
have not yet adopted such laws. We have incorporated other NASF
comments into our report as appropriate.
[End of section]
Appendix VI: GAO Contact and Staff Acknowledgments:
GAO Contact:
Robin M. Nazzaro (202) 512-3841 or nazzaror@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, David P. Bixler, Assistant
Director; Ellen W. Chu; Jonathan Dent; Janet Frisch; Timothy Guinane;
Kevin Jackson; Richard Johnson; Chester Joy; Winchee Lin; Tom
Moscovitch; and Jena Sinkfield made key contributions to this report.
FOOTNOTES
[1] The four agencies within the Department of the Interior responsible
for wildland firefighting are the Bureau of Indian Affairs, Bureau of
Land Management, Fish and Wildlife Service, and National Park Service.
[2] These 12 states were Alaska, Arizona, California, Colorado, Idaho,
Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming.
Although wildland fires can affect all states, we selected these
western states because they have substantial federal lands and often
experience wildland fires.
[3] The 12 master agreements reviewed, 4 states visited, and two
wildland fires reviewed within each visited state are all
nonprobability samples. Therefore, the results from these samples
cannot be used to make inferences about all master agreements, states,
or wildland fires.
[4] These dollars have been adjusted for inflation using the gross
domestic product price index, with fiscal year 2005 as the base year.
[5] Susan Stewart et al., Mapping the Wildland Urban Interface and
Projecting Its Growth to 2030: Summary Statistics, January 2005,
http://www.silvis.forest.wisc.edu/Library/Stats/uswuistats.pdf
(downloaded May 5, 2006).
[6] Cooperative fire protection agreements for the Forest Service are
executed principally under the following five laws: The Granger-Thye
Act of 1950, the Reciprocal Fire Protection Act of 1955, the
Cooperative Funds and Deposits Act of 1975, the Cooperative Funds Act
of 1914, and the Cooperative Forestry Assistance Act of 1978, as
amended. Cooperative fire protection agreements involving Department of
the Interior agencies are executed, among other authorities, under the
Reciprocal Fire Protection Act of 1955.
[7] National Wildfire Coordinating Group, Interagency Incident Business
Management Handbook (Boise, Id.: 2004).
[8] According to the Interagency Incident Business Management Handbook,
an acres-burned method should be used when entities‘ responsibilities,
objectives, and suppression costs are similar. The handbook also lists
a fourth method, which addresses sharing costs for a fire controlled
during initial fire suppression efforts. This fourth method did not
apply to our study because none of the fires we reviewed were
controlled during the initial ’attack“ period.
[9] Direct costs include the costs for firefighters, aircraft, and
equipment deployed to fight the fire. Indirect costs include the costs
for fire managers, fire camps, and other support services.
[10] The various documents making up the National Fire Plan include (1)
a September 2000 report from the Secretaries of Agriculture and the
Interior to the President in response to the wildland fires of 2000,
(2) congressional direction accompanying substantial new appropriations
in fiscal year 2001, and (3) several strategies to implement all or
parts of the plan. For a description of these strategy documents,
including the National Fire Plan, and their contents, goals, and
relationships to one another, see GAO, Severe Wildland Fires:
Leadership and Accountability Needed to Reduce Risks to Communities and
Resources, GAO 02 259 (Washington, D.C.: Jan. 31, 2002).
[11] Instead of having a separate master agreement for each state,
federal and state officials in Oregon and Washington developed a joint
master agreement for fire protection in both states.
[12] Under its Fire Management Assistance Grant Program, FEMA provides
financial assistance to nonfederal entities for the mitigation,
management, and control of any fire on public or private forest land or
grassland that would constitute a major disaster. Under this program,
nonfederal entities can be reimbursed for 75 percent of the allowable
fire suppression costs. FEMA evaluates the threat posed by a fire or
fire complex according to the following criteria: (1) threat to lives
and improved property, including threats to critical
facilities/infrastructure, and critical watershed areas; (2)
availability of state and local firefighting resources; (3) high fire
danger conditions, as indicated by nationally accepted indexes such as
the national fire danger ratings system; and (4) potential major
economic impact.
[13] Specifically, the state forester said that under Arizona law, the
state had no responsibility to protect the private lands and resources
in the wildland-urban interface threatened by the Florida Fire because
the fire did not threaten state lands, and the private properties that
the fire threatened were not covered by cooperative fire agreements
with the state.
[14] These principles were adopted in 2005, but the basic framework
contained in the principles was also used for the McGruder Fire in
2004. For the McGruder Fire, however, equal sharing of aviation costs
was not limited to 72 hours.
[15] The 72-hour count generally begins after a fire escapes initial
suppression efforts, or initial attack.
[16] The National Fire and Aviation Executive Board is made up of the
fire directors from the five federal land management agencies and a
representative from NASF. The board reports to the Wildland Fire
Leadership Council, which is a group established to support the
implementation and coordination of the National Fire Plan and the
federal wildland fire management policy.
[17] The draft template was very similar to the joint master agreement
for Oregon and Washington. The template described several cost-sharing
methods that can be used, but it did not specify that certain methods
be used for certain types of fires.
[18] Some states have provisions whereby wildland fires exceeding the
logistic and financial capabilities of local entities can be managed
and paid for by the state, but officials said that state funds to do so
are also limited.
[19] GAO, Technology Assessment: Protecting Structures and Improving
Communications during Wildland Fires, GAO 05 380 (Washington, D.C.:
Apr. 26, 2005).
[20] The Firewise Communities program is the primary national effort to
educate homeowners about wildland fire risks. The program is jointly
sponsored by the International Association of Fire Chiefs, National
Emergency Management Association, National Association of State Fire
Marshals, NASF, National Fire Protection Association, FEMA, U.S. Fire
Administration, Forest Service, Bureau of Indian Affairs, Bureau of
Land Management, Fish and Wildlife Service, and National Park Service.
Numerous state and local fire and forestry officials also participate
in this program. See http://www.firewise.org/ for more information.
[21] Western Governors‘ Association, ’Letter to the Secretary of
Agriculture and Secretary of the Interior,“ December 16, 2004,
[Hyperlink, http://www.westgov.org/wga/initiatives/fire/tempe-
report04.pdf] (downloaded May 8, 2006).
[22] Colorado State Forest Service, State of Colorado Wildfire Hazard
Mitigation Plan, Colorado Multi-Hazards Mitigation Plan (Denver, Colo.:
July 2002).
[23] Department of the Interior, Department of Agriculture, Department
of Energy, Department of Defense, Department of Commerce, Environmental
Protection Agency, Federal Emergency Management Agency, and the
National Association of State Foresters, Review and Update of the 1995
Federal Wildland Fire Management Policy (Washington, D.C.: January
2001).
[24] GAO has previously reported on fuel conditions on federal lands.
See GAO, Wildland Fire Management: Update on Federal Agency Efforts to
Develop a Cohesive Strategy to Address Wildland Fire Threats, GAO 06
671R (Washington, D.C.: May 1, 2006); Wildland Fire Management:
Important Progress Has Been Made, but Challenges Remain to Completing a
Cohesive Strategy, GAO 05 147 (Washington, D.C.: Jan. 14, 2005); and
Western National Forests: A Cohesive Strategy Is Needed to Address
Catastrophic Wildfire Threats, GAO/RCED 99 65 (Washington, D.C.: Apr.
2, 1999).
[25] Department of Agriculture, Secretary of Agriculture Independent
Cost-Control Review Panel: FY 2004 Large Cost Wildfires Report
(Washington, D.C.: Mar. 23, 2005); and Department of Agriculture and
Department of the Interior, Consolidation of the 2003 National and
Regional Large Incident Strategic Assessment and Oversight Review Key
Findings (Washington, D.C.: Sept. 22, 2003).
[26] These states were Alaska, Arizona, California, Colorado, Idaho,
Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming.
[27] Of the federal firefighting agencies, the Forest Service and the
Bureau of Land Management spend the most funds each year on wildland
fire suppression.
[28] GAO, Technology Assessment: Protecting Structures and Improving
Communications during Wildland Fires, GAO 05 380 (Washington, D.C.:
Apr. 26, 2005).
[29] James Schwab et al., Planning for Wildfires (Washington, D.C.:
American Planning Association, 2005).
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