Randy Moore, Regional Forester, R5
RE: Addressing Barriers to Increasing the Use of Prescribed Fire on the
Six Rivers and Klamath National Forests
Dear Mr. Moore,
The Western Klamath Restoration Partnership (WKRP), since its inception in 2014, has
brought diverse parties together in the wake of the protracted Timber Wars to create a
plan for restoring fire process on our 1.2 million acre landscape. We are in Tier 1 for CFLRP
funding in this next round, and have leveraged nearly $10 million in non-Federal funding
for projects on federally administered lands in the past five years. We are actively building
our local capacity to increase the scope and scale of our work to make a difference in
the face of the most catastrophic wildfires ever recorded for our region.
The 2020 Slater Fire burned over 90,000 acres in 24 hours, killing two people and
destroying nearly 200 homes in the Happy Camp community. While arcing powerlines
may have been the proximal cause for the Slater Fire, the history of industrial logging and
fire suppression/exclusion in the Indian Creek drainage, exacerbated by climate change,
is primarily responsible for the unprecedented fire behavior and historic fire damages.
These impacts to human and natural systems are made worse by the fact WKRP
proposed a pilot project to the Klamath NF in 2015 that aimed to treat approximately
30,000 acres in the Indian Creek drainage around Happy Camp, and would likely have
saved at least half of these homes from burning. The Klamath rejected this proposal, and
instead chose a landscape to the south for their next project, which has not progressed.
We, the non-FS co-leads of the WKRP, are writing you because without a significant shift in
engagement and collaboration from FS leadership both on the Klamath and Six Rivers
National Forests we have serious concerns for the future of our Partnership.
While the Karuk Tribe and other WKRP partners are actively building capacity for
implementing prescribed fire at a larger scale, it does not appear that prescribed fire
capacity development within our KNF and SRNF partners is a priority. Possibly more
disturbing, existing agreements that allow for active participation in an All Hands All Lands
approach to increasing the scope and scale of prescribed burning are being
underutilized, or not being utilized, by our FS partners.
Prescribed Burning: Six Rivers NF - Somes Bar Integrated Fire Management Project
Currently, we have a 700+ acre backlog of untreated piles on the Somes Bar Integrated
Fire Management Project, the first WKRP landscape scale demonstration project, which is
projected to grow as more manual thinning is accomplished. These piles are located
directly around private inholdings and along critical access and egress routes. Six Rivers
NF Supervisor Ted MacArthur has made the determination, with input from National Park
Service FMO Rick Young, that federally qualified burn bosses with the Karuk Tribe cannot
boss pile burns in the Somes Project without a FS burn boss present. This has significantly
delayed our ability to get piles burned during available burn windows as FS employees
are taking use or lose vacation time, are not authorized for overtime or holiday pay, or
are unwilling to burn during inclement weather.
The Karuk Tribe has a cooperative interagency burn agreement in place with the Six
Rivers National Forest and believes this should be enough to empower tribal burn bosses
to ensure this backlog of piles is burned by next summer. We believe that interagency
agreements do not fall under the section of the Red Book titled: Use of Contractors for
Prescribed Fire Implementation (page 361 line 34) as we are not contractors, but rather
BIA sponsored interagency resources. Instead, the following sections of the Red Book
(p.361) should be employed:
Federal Agencies Assistance
Reference Section VI of the Interagency Agreement for Wildland Fire Management
among the Bureau of Land Management, Bureau of Indian Affairs, National Park Service,
Fish and Wildlife Service of the United States Department of The Interior, and the Forest
Service of the United States Department of Agriculture, effective 2016-2021.
Agencies will enter into separate agreements for personnel and other resources provided
for planning and implementation of fuels management treatments and activities. This may
or may not result in an exchange of funds subject to the applicable statutory authority
• FS – USFS units will make every attempt to establish agreements in advance when
planning to utilize resources from cooperating agencies to implement or respond as
contingency resources for prescribed fire. However, for prescribed fire activities and
exigent circumstances, where an agreement was not executed and funds were not
obligated prior to commencing work, a ratification may not be necessary if an approved
agreement is executed and funds obligated on I-web within 30 calendar days of the
start of work. See FSH 1509.11 Chapter 10, Section 15.81.
• BIA – Refer to Bureau of Indian Affairs Fuels Management Business Rules,
July 2008, pages 23-24.
We are requesting the Forest and Region reconsider the current limitations being unjustly
imposed so qualified tribal burn bosses can implement pile burns, at the very least,
through this winter. Proper notifications and protocols will be followed as any sending unit
would in response to an ordering unit request to assign personnel.
WKRP partners brought our community along with us as we developed the Somes Project.
The main concern from the community was that past projects on public lands left activity
fuels that were not treated in a timely manner. Several times, unburned piles were lit midsummer by arson, or contributed to wildfires jumping containment lines as seen most
recently during the 2020 Slater Fire, leading to homes being threatened or lost. We
assured the community this project would be different, as the goal is to restore fire
process and function across the entire 5,500 acre project footprint. Now is the time for us
to collectively deliver on our promise and maintain the trust we have built for future
projects. We are requesting the Region work with both the SRNF and KNF to ensure
federally qualified tribal burn bosses can lead both pile burns and broadcast burns on FS
lands through existing interagency agreements, even if FS burn bosses are not available
on site. The project has a federal signature on the NEPA documents, the burn plans, and
the interagency agreement that says the Karuk Tribe will provide fully qualified burn
bosses when needed.
Six Rivers and Klamath NF Participation in Cooperative Prescribed Burning Through the
Prescribed Fire Training Exchange (TREX) And Other Agreements
Since 2014, a master participating agreement with R5 (and now the WO) and forest-level
supplemental project agreements between the Nature Conservancy, the Klamath and
Six Rivers National Forests, and partners have been in place to allow for cooperative
burning on public and private lands. Unfortunately, as this excerpt from a final report for
this KNF SPA agreement prepared by TNC to the Klamath NF describes, there has been
minimal use of this agreement by KNF fire staff:
It appears that KNF district fire staff are not familiar with or are not interested in implementing the
cooperative burning facilitated by this agreement and outlined in the Master Participating
Agreement (MPA) with USFS Region 5 that this agreement tiers to. In the section of the MPA
entitled “Social and Operational Capacity for Planning and Implementing Prescribed Fire,” it
describes how these TREX events are intended to be mutually beneficial to USFS staff, TNC and
Host collaborative restoration-related training events in an interagency/ interorganizational environment to facilitate shared learning on important topics such as fire
ecology, prescribed fire, smoke, and fire restoration-related community outreach and
communications to build skills and advance key strategies. By working and training
together, both the U.S. Forest Service and TNC will benefit from the increased skills,
strategies, capacity and professional networks to work more effectively across
organizations and jurisdictional boundaries. Shared work and training opportunities will
better prepare the organizations, their local partners, and local communities for future
success implementing prescribed fire and living in a fire-adapted ecosystem.
Instead, district FMO’s appear to see this as a distraction from their internal efforts to conduct
prescribed burns with USFS staff, and do not see a benefit to the USFS to actively participate in the
TREX Program. Until this is addressed, there will likely be minimal use of these agreements. TNC
would like to coordinate with KNF fire leadership at an appropriate time to better understand how
we can increase the amount of prescribed burning and training accomplished with this tool.
As of the date this letter was drafted, we have heard that there has been little or no
outreach from the Klamath NF to increase the use of this agreement. While there has
been more involvement by the Six Rivers NF, the agreement has been significantly
underutilized on that forest as well. In fact, there have been far more FS participants from
Forests other than the KNF or SRNF in the Klamath TREX program, including the
Mendocino, Lassen, Inyo, Humboldt-Toiyabe, etc). We request that regional fire
management staff work with these Forests to understand why their fire leadership are
choosing not to engage in the TREX program, and work to increase substantive future FS
engagement, including prioritized cross-boundary burns.
Regional and Forest-Wide Burn Suspensions
The frequency of burn suspensions on FS lands in Region 5 has been increasing at an
alarming rate. Nearly every burn season for the past five years, our KNF and SRNF partners
have had to stand down from implementing prescribed burns even though local
conditions on the ground are suitable for burning. During these periods, we have been
able to implement critical burns in the wildland urban interface on private and tribal
lands. We can only imagine that this has been demoralizing for local FS fire staff to stand
down when ideal local burn windows are foregone due to regional burn suspensions and
regional resource drawdown. Local non-Forest Service resources are available as
contingency resources should drawdown to wildfire events elsewhere be the reason for
The current risk tolerance of KNF and SRNF line officers and burn bosses for prescribed fire
is very low. There appears to be no perceived negative consequences for not burning
and high potential negative consequences for implementing prescribed burns. To be
clear, we are not advocating for burning regardless of risk, but are asking the region to
evaluate their current low risk tolerance, which has resulted in minimal application of
prescribed fire to reduce impacts from catastrophic wildfires rapidly increasing is size and
severity. Through the TREX program and other private lands cooperative burning, we
have implemented hundreds of prescribed burns on thousands of acres over the past 15
years with minimal resources and no declared wildfires. We are requesting that the region
seek to create incentives for prescribed burning, mitigate disincentives, and minimize the
frequency and duration of burn suspensions based on factors other than burn conditions
at the unit level.
We were just notified on December 3, 2020, by Orleans/Ukonom RD Fire Management
Officer Gordon Meyers that all prescribed burning has once again been suspended due
to fires in southern California. Piles here are barely starting to creep with our recent drying
trend, and may actually broadcast enough to complete some desired Type 2 burns in
the coming weeks. Conditions will never be safer for this to restore fire process on our
landscape that has been severely impacted from wildfires over the past 40 years. Now is
the time for Region 5 to collaboratively lead a transition from fire management strategies
primarily based on limiting ignitions to one that focus on creating fuel limited ecosystems
through restoring landscape scale fire processes. We respectfully submit this as Western
Klamath Restoration Partnership Co-Leads, and ask that these artificial barriers be
remedied so we can progress the shared values we all agreed to in our collaborative
process. We are available to work with Region and Forest fire staff to address these issues
in a timely manner.
WKRP Co-Leads Tripp, Harling, and Greenberg
Wouldn’t expect anything less from the Forest Service. The whole FS program is a sinking ship and no upper level management will do anything about it. This is just one classic example of the mismanagement of our federal lands. But even if people speak up, nothing will change.
A lot of them left and went to different agencies.
This is a very persuasive argument, the USFS needs to look hard at why the delays happened and continue to occur. I suspect the Lewiston Fire is still in the memory of Federal Fire Officials, but learn from the past and move forward.
Update from one of the authors of the letter: