EWP working paper

Changes in land use and management practices throughout the past century–in addition to drought and other stressors exacerbated by climate change–have degraded the nation’s forests and led to overgrowth and accumulation of hazardous fuels (GAO 2015). Because of these fuels, some forests now see high-severity fires that threaten communities as well as important natural and cultural resources. Restoring desired vegetation conditions, which can often be accomplished through mechanical thinning or prescribed burning, are central objectives of restoration and fuel reduction projects carried out by federal land management agencies. However, prior to implementing restoration projects or any other major action that may result in a significant impact on the environment, the National Environmental Policy Act (NEPA) of 1969 requires federal land management agencies to conduct an environmental analysis to consider and fully disclose potential impacts (42 USC § 4332(C)). Rather than enforcing or prohibiting any specific action on the landscape, NEPA prescribes a general process designed to educate decision-makers, relevant agencies, and the general public about the environmental consequences of actions planned on federally-administered public lands. This decision-making process of receiving, documenting, and evaluating public comment on potential impacts of proposed actions is commonly referred to as the NEPA process. Historically, NEPA compliance has posed numerous hurdles for public land managers.Since early 2013, administrative challenges to Forest Service land management decisions take the form of a pre-decisional administrative review process involving the filing of written “objections” to proposed agency decisions (Brown 2015). Prior to early 2013, administrative challenges generally took the form of a post-decisional administrative review process. The agency’s resolution of an administrative challenge can in turn be judicially challenged via a lawsuit in U.S. District Court (Jones and Taylor 1995; Keele et al. 2006; Portuese et al. 2009), and district court decisions can be challenged in the appropriate U.S. Court of Appeals (Jones and Taylor 1995; Malmsheimer et al. 2004). The Court of Appeals is usually the final level of review for Forest Service land management decisions because very few Court of Appeals cases are selected for discretionary review by the U.S. Supreme Court. Note that the term “legal challenge,” used throughout this synthesis, is an encompassing term that includes both primary types of legal challenges: administrative (agency-level) and judicial (in the courts).

Over the past century, wildland fire management has been core to the mission of federal land management agencies. In recent decades, however, federal spending on wildfire suppression has increased dramatically; suppression spending that on average accounted for less than 20 percent of the USFS’s discretionary funds prior to 2000 had grown to 43 percent of discretionary funds by 2008 (USDA 2009), and 51 percent in 2014 (USDA 2014). Rising suppression costs have created budgetary shortfalls and conflict as money “borrowed” from other budgets often cannot be paid back in full, and resources for other program areas and missions are subsumed by suppression expenditures (Thompson et al. 2013). Significant policy making over the past 15 years has been designed, at least in part, to address these issues and temper wildfire costs. Effective political efforts and strategies to control public spending on suppression rely on a thorough and comprehensive understanding of the drivers of suppression costs and recent trends. Currently, scholars and policymakers have little understanding or agreement on the diversity of drivers behind wildfire suppression costs, how drivers vary in different situations, or what specific tactics or approaches might best reign in rising costs. There is great variability in costs between comparable wildfires in the same season, as well as between comparable fire seasons. Problematically, much of this variation is unexplained by frequently noted drivers. As speculation and scrutiny around potential drivers has increased, so too has a growing body of scholarly literature investigating the correlates and influences driving suppression costs. A more comprehensive understanding of the full suite of factors affecting suppression costs can inform how land management agencies can best leverage limited resources for wildfire management, and how budget allocations could more accurately accommodate annual suppression costs. This working paper gathers together existing scholarly literature on wildfire suppression cost drivers. The purpose of the paper is to provide an overview of the diversity of drivers examined in scholarly literature that may influence suppression costs; be a resource for documenting the growth, parameters, and directions in this field of research; and serve as a central collection annotating this literature to date.