USFS Prescribed Fire Policy

Policy Documents

• FSM 5140

• FSH 5109.17

• Interagency Prescribed Fire Planning and Implementation Procedures Reference Guide

• Implementation Strategy for the Federal Wildland Fire Policy

• WO Letter dated October 27, 2008

FSM 5140

• Last update – April 18, 2008

• Next update – January 2009

FSM 5140 - 2008

FSM 5140 - 2008

• Incorporated “by reference” the Interagency Prescribed Fire Planning and Implementation Procedures Reference Guide

• Eliminated redundancies between 5140 and Interagency Guide

FSM 5140 - 2008

• Exempts “Administrative Burning” from requirements

• Requires reviews and timely reporting of escaped prescribed burns which are declared “wildfires”

FSM 5140 - 2008 Administrative Burning

5140.5 - Definitions

“Administrative burning is the burning of debris at Administrative sites or sites under special use permit or sites covered under formal agreements. The debris being burned is generated by routine administrative activities, such as fall leaf and needle raking, right-of-way clearing, and trimming or removal of trees and shrubs adjacent to structures for defensible space.”

FSM 5140 - 2008 Administrative Burning

5142 - PRESCRIBED FIREAdministrative Burning is exempted from the requirements of FSM 5140 (FSM 5140.5). This type of burning should adhere to local government debris burning requirements where applicable and follow additional requirements as determined by the Forest Supervisor or other delegated line officer.

FSM 5140 - 2008 Escapes

Newspaper Headlines2 prescribed fires set at just the wrong time

By Tom Beal

ARIZONA DAILY STAR

FSM 5140 - 2008 Escapes

Newspaper Headlines

"We strongly discouraged them from starting it," said Bill Turner, a meteorologist in the National Weather Service's Tucson office. "We had red-flag criteria everywhere."

By Tom Beal

ARIZONA DAILY STAR

FSM 5140 - 2008 Escapes RF Responsibility

• 5. Conducting administrative reviews (and reporting review results to the Chief within 90 days) of all prescribed fires that:– a. Result in serious or multiple personal

injuries; or– b. Are converted to wildfire status that burn

significant private or other agency lands.

FSM 5140 - 2008 Escapes For Supe Responsibility

7. Conducting reviews of all prescribed fires that are converted to wildfire status.

8. Reporting the review results to the Regional Forester within 60 days after the prescribed fire was declared a wildfire (FSM 5140.3, para. 5).

9. Reporting all wildfires resulting from prescribed fire actions to the Regional Forester within 24 hours of the wildfire declaration.

FSM 5140 - 2008 Escapes District Ranger

Responsibility

6. Reporting all wildfires resulting from fire use actions to the Forest Supervisor within 12 hours of the wildfire declaration.

FSH 5109.17

• Last Update - November 2007

• Next Update – January 2009

FSH 5109.17

• Fire Use Positions

• RXB1, 2, 3

• FIRB

• RXCM

• RXFM

FSH 5109.17

• RXB1, 2, 3– RXB3 quals included in Rx Fire

Implementation Guide

• RXFM– No change at this time– Is this position needed?

FSH 5109.17

• FIRB– Combined IGN1, IGN2, and FIRB into new

FIRB

• RXCM– No change

Implementation Procedures Reference Guide

• Last update – Summer 2008

• Key changes

Implementation Procedures Reference Guide

• Either Technical reviewer or Rx Fire Planner must be currently qualified less physical fitness requirements

• An RXB3 is allowed to function as a Prescribed Fire Plan Preparer for a low complexity plan, but not as a Technical Reviewer.

Implementation Procedures Reference Guide

• Agency Administrator responsibilities additional requirement (new bullet 12):

“Ensure that prescribed fires which receive a National Ambient Air Quality Standards (NAAQS) Notice of Violation (NOV) are reviewed according to established guidelines”

Implementation Procedures Reference Guide

• Technical review for amendments: “the need for additional technical review will be determined and justified by the agency administrator.”

Implementation Procedures Reference Guide

Mixed ownership burns:

• If an interagency mixed ownership Prescribed Fire Plan is being prepared, the development of all appropriate elements within the plan will be conducted in an interagency setting.

Implementation Procedures Reference Guide

Mixed ownership burns:

• For cooperative burns implemented by non-federal entities involving federal and non-federal lands, where only a small amount of federal lands will be treated, the local agency administrator has discretion to use either a federal or non-federal Prescribed Fire Plan.

Implementation Procedures Reference Guide

Mixed ownership burns:

• Interagency agreements and Memorandums of Understanding (MOU) and/or private land owner agreements are required to implement prescribed fire on multiple ownerships.

Implementation Procedures Reference Guide

• Element 5. Goals and ObjectivesDeleted requirement for a description of purpose of the prescribed fire, resource management goals from the supporting L/RMPs and/or NEPA documents, desired future conditions of the prescribed fire project, and discussion of future Fire Regime Condition Class (FRCC) post-treatment conditions.

Implementation Procedures Reference Guide

• Element 7. Prescription “If the prescription limits are exceeded, the

Prescribed Fire Burn Boss must evaluate fire controllability and whether fire effects will meet objectives. The Prescribed Fire Burn Boss must take action to ensure objectives are being met, or take appropriate actions to maintain control of or secure the fire.”

Implementation Procedures Reference Guide

• Element 13. Public & Personnel Safety, Medical

“A job hazard analysis (JHA) or other agency-specific risk analysis is required for each prescribed fire.”

Implementation Procedures Reference Guide

• Element 15. Ignition Plan

“Describe planned ignition operations. Examples could include firing methods, devices, techniques, sequences, patterns, and ignition staffing for single or multiple unit operations.”

Implementation Procedures Reference Guide

• Element 17. Contingency Plan

“Contingency resources are those resources or capabilities required to meet contingency actions. These resources may be on or off site as required by the Prescribed Fire Plan. For purposes of this element, the terms capabilities and resources are interchangeable.”

Implementation Procedures Reference Guide

• Element 17. Contingency Plan

“Resource needs should be based on fire behavior outputs tied to the hottest, driest, windiest fire behavior scenario as identified in Element 7: Prescription.”

Replaces “worst case”

Implementation Procedures Reference Guide

• Element 18. Pre-Burn Considerations

“A prescribed fire must be declared a wildfire by those identified in the plan when that person(s) determines that the contingency actions have failed or are likely to fail and cannot be mitigated by the end of the next burning period.”

Deletes “by on-site or preplanned holding forces”

Implementation Procedures Reference Guide

• Element 18. Wildfire Conversion

“After a wildfire declaration, an escaped prescribed fire cannot be returned to prescribed fire status. A WFSA will define appropriate future management actions.”

New wording eliminates the requirement to conduct a WFSA

Implementation Procedures Reference Guide

• Element 19. Smoke Management & Air Quality

“If a Notice of Violation (NOV) is issued by an air quality regulatory agency for a prescribed fire, a formal review of the incident must be conducted, following the guidance provided under the ‘Reviews’ chapter.

Implementation Procedures Reference Guide

• Element 19. Smoke Management & Air Quality

If an air quality regulatory agency notifies a land management agency that their prescribed fire may have contributed to an exceedance of a NAAQS then a review is highly recommended. Use of Guidance for After Action Review of Smoke Impacts, available at http://www.nifc.gov/smoke or other review approaches are recommended to the extent feasible in order meet information needs stipulated by the Final Rule on the Treatment of Data Influenced by Exceptional Events (40 CFR Parts 50 1nd 51).”

Implementation Procedures Reference Guide

• Other deletions of unnecessary text such as:

“Since all prescribed fires are planned management actions, an escape may lead to a Tort Claim and liability issues. Special attention to documentation is critical.”

Implementation Procedures Reference Guide

• Burn plan template– 21 elements– Not all elements must be filled out

• Allowance for labeling any “NA” for not applicable

• More discretion for the agency administrator and the burn boss

• Clarification of terms

• Reduced redundant text

Implementation Strategy for the Federal Wildland Fire Policy - 2003• Three Types of Wildland Fire

– Wildfire– Wildland Fire Use– Prescribed Fire

• Only one objective for any wildland fire

• Once designated wildfire cannot be managed for resource benefit

Implementation Strategy for the Federal Wildland Fire Policy - 2009• Two Types of Wildland Fire

– Wildfire– Prescribed Fire

• Multiple objectives allowed for wildfires

• Allows objectives to be changed from resource benefit to protection and back again

Implementation Strategy for the Federal Wildland Fire Policy - 2009• Allows prescribed fire to be converted to

wildfire and then back to prescribed fire

• Allows simultaneous management of portions as a prescribed fire and as a wildfire

WO Letter - October 27, 2008

WO Letter - October 27, 2008

• Released updated Implementation Guide

• Listed additional requirements:– Spot weather forecasts– Annual line officer approval/recertification of

burn plans

WO Letter - October 27, 2008 Spot Weather Forecasts

1. Obtain a project-specific spot weather forecast prior to ignition and for each day that ignition continues and any days the fire is actively spreading. An exemption from the spot weather forecast requirement may be made by the authorizing Line Officer when adhering to the following:

WO Letter - October 27, 2008 Spot Weather Forecasts

Completion of a weather/climate analyses if the analysis indicates that:

a. The general fire weather forecast for the Fire Management Unit (FMU) is usually

accurate and well documented.

b. There is no threat of escape due to seasonal weather.

WO Letter - October 27, 2008 Spot Weather Forecasts

• When spot weather forecasts are exempted, the general weather forecast must be reviewed daily until the prescribed burn is declared “out” to:

• a. Prevent the burn from escaping the burn unit.

• b. Ensure smoke management requirements are met.

WO Letter - October 27, 2008 Line Officer Approval/Recertification

• All burn plans must be reviewed and updated if necessary to comply with new policy or procedures, and re-authorized if more than one year has elapsed since initial approval.

Questions