Our analysis found three different ways of framing the barriers to scaling up mitigation, each emphasizing certain aspects of the problem and prioritizing certain types of solutions. Most of the people we interviewed emphasized only one of these three frames, but there were a handful of interviewees who focused on more than one.
The Usual Suspects: commonly cited barriers to scaling up mitigation
The Usual Suspects is a framing that tends to dominate the discussion in both the Crosswalk and our interviews. This framing focuses on the following barriers: (1) lack of resources, especially funding; (2) cumbersome and time-consuming policy and procedural requirements; (3) litigation that halts or delays implementation; and (4) lack of a shared understanding of the problem and solutions among the public.
Not surprisingly, lack of resources (particularly funding) emerged as a significant barrier. The Crosswalk states that “funding for fuels treatments is scarce among all entities” (Appendix F6). Interviewees in both Washington and Utah frequently discussed lack of funding and lack of capacity, stating that existing resources are “not enough to keep pace” with wildfire risk and that lack of funding “is always a real challenge…a significant challenge.” And despite an interest in sharing resources to build capacity, the current system for sharing resources for mitigation work, particularly for prescribed burning, was described by the Crosswalk as “inefficient and cumbersome” in comparison with the system for sharing resources for wildfire response and suppression (Appendix F2-F3). Interviewees agreed, saying that the mechanisms for billing across agencies that exist for incident response do not exist for mitigation. They explained that “there’s capacity in one place that another organization could use,” but these barriers often stymie efforts to share those resources. For example, as a tribal member explained, it can be difficult to compensate tribal employees for conducting cultural resource surveys on federal land in advance of prescribed burning. Further, while the recently expanded Good Neighbor Authority (GNA) includes mechanisms for sharing capacity across agencies, challenges to using GNA remain (Crosswalk Appendix F5). For example, one Forest Service employee pointed out that the federal agencies could not, at the time, turn prescribed burning over to Oregon and Washington state agencies because state employees lacked the required training. Where barriers were framed as lack of capacity for implementation, the solutions cited included increased funding to treat more acres and better mechanisms for sharing resources and building capacity across agencies.
Policy was also regarded as a significant barrier. The Crosswalk states that “landscape scale restoration is often difficult to achieve due to the complex procedural requirements of federal laws, rules, and policies” (Appendix E5) and that:
Years can pass before collaboratively developed and approved projects can be implemented due to the various planning requirements and processes, and allocation of resources necessary to allow the projects to move forward. Ability to implement such projects on the ground in a timely manner should be increased. (Appendix F7-F8)
A local Fire Chief from Utah echoed this concern, suggesting that federal regulations do not allow for some types of mitigation work, saying “so many people would love to harvest those dead trees or just at least get rid of them but I know federal regulations, they don’t allow that. They have a lot of other red tape that they have to cut through.” Similarly, a Forest Service employee cited the planning processes as “one of the largest barriers” because of “competing values” and the challenges of getting “buy-in from the biologists and other specialists.”
Interviewees talked extensively about the lengthy environmental impact assessments required by the regulations that implement the National Environmental Policy Act (NEPA), arguing that the NEPA process is expensive and delays implementation of fuel reduction projects. Interviewees described NEPA as a “headache,” “one of our bigger frustrations,” and an impediment to collaboration between state and federal agencies. A Utah state agency employee described how federal policy requirements made it difficult to collaborate with federal agencies on large-scale treatments, saying:
We’re ready to go. And we can really implement something in a matter of months. And we’ve got to wait two years for the Forest Service to figure it out. Definitely a big headache, right? So, you move at the speed of your slowest person. So you have to shelf that idea, maybe, if we really want to collaborate.
One County employee complained that NEPA is a “pretty open door on objections” that “encourages too much engagement, too much participation.”
While NEPA was characterized as the primary policy barrier, air quality rules were seen as restricting prescribed fire in both the Crosswalk (appendix E3) and among our interviewees, who explained that exceeding “parameters on particulate matter” was a “real challenge” and meant shutting down prescribed fires. Interviewees also perceived the Endangered Species Act as a barrier to doing fuels work in areas with threatened or endangered species.
When policy was highlighted as the barrier, interviewees and the Crosswalk converged on a similar solution, to streamline policy requirements, in particular NEPA. The Crosswalk focuses specifically on the need for “actions that break down identified regulatory, process, and other administrative barriers and address critical success factors” (p 18) and calls for federal agencies “to expedite the planning/collaboration process to treat large landscapes” (CSF14-2) and to “seek relief from impediments in the Forest Service Planning Rule for fuels management” (CSF14-5). According to the Crosswalk, “Alternative federal processes must allow more efficient and less costly processes that decrease the time needed for the necessary planning, and aid in the development of solutions promoting large scale active management and fuels treatments” (Appendix F7-F8). Interviewees, including a Utah state employee, argued that the federal government should “speed up that process.”
Litigation was also regarded as a major barrier. According to the Crosswalk (Appendix F7-F8):
Federal laws and regulations, particularly the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), and the Equal Access to Justice Act (EAJA), have been used by groups…to limit or delay the implementation of these projects…This will likely require new legislation or the modification of current legislation in order to allow collaborative, outcome-based solutions to withstand judicial challenges.
In addition, fear of litigation was believed to influence the types of projects that are proposed. One timber industry representative argued that the Forest Service is “afraid to sneeze without getting litigated, and they’ve had most of their tools taken away from them, or tied up so heavily in litigation that they just can't get business back.” One federal wildfire leader suggested that it is more fear of lawsuits than actual lawsuits, saying “you get this fear of lawsuits, and I think what they found is, yes in certain areas it’s very well founded, but in most areas it’s somewhat unfounded, and there’s not, percentage wise, as many of those plans that get challenged as we often would think.” The Crosswalk suggests that “new interpretation and engagement with key partners can take advantage of flexibility that currently exists, but may not be exercised for fear of litigation” (Appendix E5). In short, litigation was characterized as both delaying implementation and influencing the types of projects proposed. Thus, limiting litigation was seen as a way to address that barrier.
The fourth commonly discussed “usual suspects” barrier was lack of public understanding. A state agency employee summed up a sentiment echoed by many interviewees, saying that “increasing public awareness and understanding” was “critical.” According to a Forest Service employee:
We have a lot of members of our publics, people who live in our communities who have a very good, very nuanced understanding of fire’s role on landscapes. And we have a lot of other people that don’t have any context for it at all. And all they see is fire is bad…So, now we have conflict, this difference in the worldview about what the challenges are, and what reasonable solutions are.
This NGO employee described “misunderstandings,” saying:
I’ve heard crazy statements of people who really don’t understand the science of forest management…like, “You’ve got to be kidding me, you're going to harvest and right after harvest you're going to light it on fire? I mean, what more can you do to the land to punish it?” They just don’t understand how mechanical treatment followed up by prescribed fire is probably going to get you the best results for the fuel reduction…it takes patience to allow people at different stages in their understanding to develop a better awareness of what we’re all trying to accomplish.
Interviewees suggested that residents “don’t understand” agency goals, believed that mitigation meant cutting down all of the trees, and worried that projects would reduce privacy. Both state and federal agency employees also argued that the public is not “accepting of smoke in the air” and described the challenge of “getting the public to understand, yes, it’s smoke now, but to prevent catastrophe later.” In response to these challenges, the Crosswalk proposes increasing public acceptance of prescribed fire and improving public understanding of the role of fire (Appendix C-4) and timely educational messages to communities.
Agency-Agency Relationships: inadequate organizational capacity to work across boundaries
While The Usual Suspects focuses on barriers that are external to the agencies, including lack of funding, policy requirements, litigation, and lack of public understanding, Agency-Agency Relationships emphasizes barriers that are internal, including agency structure and culture, and relationships between agencies. According to this framing, the key barriers to scaling up mitigation are associated with working across organizational and jurisdictional boundaries, including the following: (1) different agencies have different missions and approaches, which can make it difficult to work together across boundaries; (2) agencies need to invest time to navigate these differences and build partnerships and trust, but they often do not have the capacity to do so; and (3) staff turnover limits agency ability to build the relationships necessary to work at larger scales across jurisdictional boundaries.
According to this Washington state agency employee, agencies “work differently…because of our missions” and not because of different policies or procedures. A Forest Service employee in Utah similarly argued that “different agencies have different missions” which leads to different approaches to wildland fire. For example, both the Crosswalk (Appendix E5) and our interviewees characterized the Forest Service as more focused on reducing risk in the wildland-urban interface as compared with the Department of Interior agencies. Interviewees also suggested that, in some regions, the Bureau of Land Management is more focused on protecting sage grouse habitat as compared with other agencies. Diverging missions and the locations of public lands influence these different approaches to wildfire.
In Washington, a local fire chief suggested they “just don’t have the same vision” as the Forest Service. They argued that local fire departments are more focused on protecting infrastructure and think about their management in terms of a “circle that radiates from the structures out.” In contrast, they characterized the Forest Service as focusing on “a plot of land that’s maybe four or five miles from a structure.” A Utah Forest Service official contrasted a state agency’s mission to “put the fire out as quick as possible” with the Forest Service desire “to manage the fire to achieve an outcome.” These examples illustrate that while the agencies may share a goal of reducing wildfire risk, how that translates to specific actions on the landscape can look very different.
Even within an agency, differences across units can challenge efforts to work together. As this interviewee points out:
There’s a different mindset to first responders, and that kind of preparedness and response mindset or mantra doesn’t always jive with what the rest of the organization in the Forest Service has going, who are, perhaps biologists who are managing a piece of ground for that particular interest, that particular program.
Thus, agency-agency partnerships may need to navigate differences within as well as across agencies.
Different terminology can also inhibit collaboration. As this County Fire Marshall from Washington described:
Mid-summer, they [USFS] put out bulletins about going to stage two for fire designation. It just threw a lot of us for a loop because we just didn’t have a clue what they were talking about initially…It was done without any consultation of any of the folks here. It was like the gorilla in the room got their way right away.
This individual also references the power dynamic when large federal agencies are perceived as calling the shots and county agencies have to catch up.
In addition to different missions, different approaches to wildland fire, and different terminology, agency staff indicated that they were focused on their own lands and jurisdictions and reluctant to tell each other how to operate. One Forest Service employee in Washington suggested that one of the “biggest” barriers was the “attitude” of the Forest Service, which they claimed has a myopic focus on their own lands. They stated:
You can imagine that over many years now the Forest Service [is] used to doing things themselves, right? We rarely go ask people for help or work across boundaries. We just have a long history of taking care of the land that we’re responsible to manage and I would say that’s generally true for states as well…That’s just the way we’ve always done it…And it’s time to try something new. A different way of working together and that just overcoming [what] I refer to as having an attitude.
This emphasis on autonomy was echoed by states and tribes as well. One interviewee who works on interagency efforts at the national-level explained that “our intent is not to tell one another how we're going to operate.” A tribal forest manager described the tribe as “individual autonomous land owners” with “sovereignty” that means that federal and state agencies cannot dictate how fire is managed on tribal lands.
Because the Agency-Agency Relationships framing defined the problem in terms of barriers to agencies working together, this framing also emphasized the need to build relationships across different agencies and approaches. One community wildfire leader in Washington argued that “it’s less even a matter of the policy and the mandates…it’s about relationships too.” They suggested that to “work together more effectively…that’s a relationship issue, not necessarily always a policy or goal issue.” According to this Fire Chief from Washington:
When we have our meetings, BLM comes to the meetings, Forest Service comes to the
meeting, Parks comes to the meetings. So we do face time when there’s not an emergency. When an emergency breaks out there’s a little bit more of a comfort feeling…with somebody you break bread with. You know who they are…You establish a trust with that person and that’s really how we make things work here.
While this comment focuses on responding to a fire, many interviewees pointed out that these kinds of relationships would benefit mitigation work as well. Interviewees also indicated that the incident command structure that makes collaboration work for fire response can impede collaboration on mitigation, because the “operational mindset of follow the rules, do what you're told, don’t ask questions” can limit the innovation required for scaling up mitigation.
Given the need to build relationships that enable agencies to work together, some interviewees focused on increased capacity and resources. But rather than capacity and resources to expand fuel treatment to additional areas, they argued for capacity to build relationships and collaborate, again in order to work across different agency missions and approaches. As one interviewee put it, “collaboration moves at the speed of trust.” According to an interviewee from the local government in Washington:
Probably one of the biggest barriers is just time. In coordinating our communications so that we’re on the same page…it takes a lot of time to go and build a relationship with someone else. I could work in complete isolation, and stay busy every day of the week, working just within my jurisdiction, just for my residents, without any partnerships whatsoever. And so it takes us being proactive, and making time for partnerships. And a lot of people just don’t have it. I think capacity is a big issue. People’s plates are full, and they have to prioritize their jurisdiction, and their work.
A Utah Fire Chief confirmed this challenge, describing that building relationships with the Forest Service was “not my number one focus” due to lack of capacity. Some interviewees, including this Utah state agency employee, suggested that they needed “more consistent participation” and a “firmer commitment” by federal agencies as well as “federal agency leadership” “at the table” and “engaged in discussions to help prioritize where we want to allocate resources.” A local agency employee from Washington echoed this sentiment, sharing that some federal agencies do not “engage local practitioners” and do not show up to planning meetings, saying “we just don’t see it” and “when asked, we often get no response.” This interviewee went on to suggest that a lack of alignment between agency goals might contribute to this lack of engagement, wondering if perhaps “our priorities and [our] objectives [do not] meet theirs to where they should be at the table.” In other words, key partners need to invest time to develop shared priorities, which requires navigating the different missions and approaches described above.
Getting the “right people at these conversations” was seen as a priority by many interviewees. At the same time, a tribal forest manager wondered if participation was worth the “time and effort,” especially if they are “seeing a lack of results or maybe things are moving too slowly” and there are things they “could be doing back home that would make more of an impact.” Some interviewees suggested that different agency priorities made it difficult to turn collaboration into on-the-ground projects. A local fire district employee explained that, “we collaborate really well on these ideas, but it’s getting the work on the ground that’s the disconnect.”
In this context, personnel practices and position descriptions were regarded as part of the solution. In some cases, local Fire Chiefs could not identify a particular person within the relevant federal agency whose job included working with local fire districts. As this Utah Fire Chief describes:
Our areas border one another yet we don’t have that discussion between our local jurisdiction and the federal level…we don’t have the working relationship…or even the contact… to get on the same page necessarily, or to understand one another’s goals and the barriers that do stand in the way to achieve the goals. I would love to understand better why the Forest Service has the rules they do in place…we could try to figure out a way around that, a way to address the problem in a different way.
One Utah state agency employee described the Shared Stewardship Strategy, a Forest Service initiative to partner with the states on wildfire, by saying that “it’s kind of forced collaboration that I don’t think they [the Forest Service] have time for right now.” In a time and resource-limited environment, individuals and agencies might understandably focus on what they perceive to be their core areas of responsibility. When this occurs, “partnerships and collaborations outside, that kind of takes a second seat,” according to a local fire district employee.
Many interviewees argued that one of the key barriers to building effective partnerships between agencies was staff turnover. As one interviewee explained, “the challenges we have with retention, keeping trained, qualified people here…[we’re] losing institutional knowledge at every level.” Frequent employee reassignment and turnover in federal agencies, particularly in the Forest Service, has been recognized as problematic (Davenport et al. 2007). While routine reassignment can create a workforce with broad experience in a variety of contexts, interviewees argued that turnover can also compromise relationships with partners. A tribal land manager explained how they “struggle” with staff turnover in the federal agencies, saying:
It seems like it’s a new face every year. So I have to build up that working relationship…We have some agreements in place. But it is a bit of a learning process…people that you’re used to working with, you built a working relationship, there’s some comfort there, there’s some confidence there, some trust. And you have to rebuild that with someone new every 18 months or so. That becomes problematic. And I just don’t think we move as fast as we could…But it’s places that you have a long tenured ranger or a long tenured forest supervisor who has a good working relationship with the tribe. And they’ve done some good things when those occurrences exist.
According to this interviewee, long-term working relationships enable on-the-ground, landscape-scale mitigation. A state agency employee in Utah talked about the “cyclical” nature of these relationships, saying that “all it takes is one line officer, somebody in leadership, the next FMO [Fire Management Officer] forester who doesn't buy into these types of cooperative partnership approaches. And it could make things really difficult again.”
A local-level wildfire professional in Washington also talked about the problem of building trust with “migratory staff within the agency,” drawing a direct link between turnover and challenges in managing risk. According to this interviewee, “in terms of co-managing risk on the landscape, if you think you’re getting to know the person, you’re trying to collectively come to some understandings about how to work on the landscape. Then the person leaves.” Similar to the tribal land manager above, this interviewee connects the ability to do on-the-ground work with relationships that are enabled by long-term tenure in particular positions. Interviewees in Utah described identical challenges, explaining that “a lot of turnover” and “churning” meant “constantly” rebuilding relationships and also directly connected these barriers to “this question of shared risk.” This framing illustrates the ways in which agencies themselves are creating barriers through the formal institutional structures that move staff frequently, and through a culture that de-prioritizes the time-consuming activities of engaging in collaborative work.
Engaging the Public: barriers to meaningful public engagement
According to The Usual Suspects, policy requirements and public engagement are regarded as barriers that needed to be streamlined and limited. However, in the Engaging the Public framing, litigation and lengthy NEPA processes are regarded as a symptom of the problem, which is viewed as a lack of meaningful public engagement. Thus, more robust public engagement and collaboration are advanced as the solution.
Interviewees who focused on this framing emphasized the need for multi-stakeholder collaboration. According to this Utah state agency employee:
Having these work groups in place, having it be a safe place where people can talk about fire, and wildfire risk reduction, making sure that the broader partners know one another, so it’s not just Forest Service, BLM, and state fire staff talking to one another. There’s more participation and input.
The Crosswalk also envisions collaborative groups as an effective mechanism to build broad support for mitigation work, stating that “collaborative groups have proven to be extremely successful in developing consensus in regard to federal fuel reduction projects” (Appendix F7-F8). Some interviewees suggested that collaboration could reduce litigation and the delays that often accompany lawsuits. As this Regional-level Forest Service employee suggests, “collaboration builds a common understanding and builds relationships that increase social license and social capacity…successful collaboration in some places means less litigation.” A senior Forest Service employee in Washington concurred, saying:
I think the risk is not collaborating…it’s the hardest form of decision making you can have. It’s very time consuming…if we design into a project, it’s going to take some work and discussion to try to get our collaborative to support it…The alternative is not collaborating, and buzzing through the early part real fast, and then bogging it down in objections in court at the end. It’s one or the other.
In other words, they are suggesting that streamlining the initial planning process could increase the risk of litigation.
Interviewees also suggested that earlier public engagement might reduce lawsuits. According to a Regional-level Forest Service employee, the “agency needs to do a lot more work pre-NEPA to work with public and stakeholders to figure out what you agree on, so that by the time you do NEPA you don’t get sued.” Interviewees also argued that fear of litigation meant that federal agencies spent more time on NEPA than required. These interviewees contested the claim that NEPA needs to be streamlined, suggesting instead that NEPA is “not broken” and “not the barrier they think it is,” but that “fear of lawsuits” was motivating lengthy and cumbersome NEPA processes.
Collaboration was seen as a way for agencies to better understand the needs of the public as well as a way to change public attitudes. This Washington state employee explained the connection between policy, public attitudes toward mitigation, and collaboration in this way:
So in order to make that change you’re going to have to change rules and regulations. But primarily, you’re going to have to change the attitude of the public. And the only way you’re going to do that is to get a collaboration of different organizations and individuals that are advocating for the same thing.
They are suggesting that collaboration can build a shared understanding of the problem and solutions, such that public views shift and policy change is possible. A Forest Service employee made the point that collaboration can also help agencies understand local community concerns, using this example:
This community has a very low tolerance for smoke, and the reason they have a low tolerance for smoke is that when there is smoke in the air, tourists from the west side [of the state] do not come here… the entire tourist economy grinds to almost a halt, and [in] the short period of time that these businesses have to make money, that really makes them mad.
The two-way dialogue inherent in these kinds of engagements provided opportunities to share these types of concerns and to build shared priorities.
Interviewees also acknowledged that multi-stakeholder collaboratives require substantial investments to succeed. As one NGO employee who works across the West pointed out:
It takes 10 years to develop a group of trusted stakeholders who can effectively co-manage programs, projects, multi-jurisdictional goals and objectives…you have to start by creating a group of stakeholders that form into a collaborative, that have a couple of leaders who can back each other up, and have a sustainable model, where these folks achieve incremental accomplishments annually, and develop momentum.
These investments were believed to pay off in the long-term as collaboratives built momentum through successful projects and expanded the scale of their mitigation work.
Similar to Agency-Agency Relationships, this framing also emphasizes the lack of agency capacity to engage, but in this case the focus was on the need for engagement with multi-stakeholder collaboratives and with the public more broadly. One community leader described the impact of this lack of capacity, saying “I don’t think they have enough money to do a damn thing…there’s not enough people to do the work that they need to do. I have reached out to the Forest Service on a number of occasions and I've not even got a phone call back.” A local NGO-employee shared a similar sentiment, suggesting that “they are under water here. On the National Forest there is no capacity remaining to engage in the community…Their budgets are small. They’re overworked and understaffed.” This interviewee also explicitly connected a lack of engagement with job descriptions and capacity, saying “It’s nobody’s job and nobody has time…There’s just no one around this table because they don’t think they have the time or the capacity.” They went on to suggest that agencies invest in collaborative capacity and specifically positions that focus on coordination, suggesting that “Other ways would be to actually invest in our people, our collaborative and coordinating capacity. Jobs like…don't exist because they are hard to fund, and they are even harder to convince an agency that it's worthwhile.” Thus, lack of capacity does not simply hinder the ability of the agencies to plan and implement fuel reduction projects, it also limits the ability of the agencies to effectively engage the public. Again, echoing the Agency-Agency Relationships frame, high rates of agency staff turnover were believed to compromise collaboration, especially given how long it takes to develop a successful collaboration.