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The Threat of Wildfire on Development in the West

August 26, 2015

I. Introduction

The threat of wildfire continues to grow across the western U.S. Fires are getting larger, causing more damage and cost more money to control and suppress. Several of the worst fire seasons in decades have occurred since 2000, with the problem growing each year. A number of fundamental factors contribute to the significant growth of wildfire threats. First and foremost, our western forest lands are characterized by a significant and growing biomass that provides the fuels that sustain catastrophic wildfires. Decades of fire suppression activities have eliminated the natural cycle of fires that have long kept the western landscape in balance. The historic pattern of small and frequent fire cycles has been disrupted, allowing dense undergrowth and the accumulation of forest debris. Historic forest management practices and overgrazing have worked to exacerbate the problem. The native grasses that have fueled normal and periodic low intensity surface fires have been replaced by densely packed trees and brush that sustain the hotter and more intense “canopy” fires that characterize recent fire seasons.

More than 15,000 wildfires burned in the continental U.S. between 2000 and 2013, threatening 127 different urban areas.[1] Western cities located adjacent to public landholdings have proved particularly vulnerable to wildfire threats because of increasing drought conditions, remote forested areas, steep terrain and limited opportunities for access. Wildfires frequently threaten homes, development and critical infrastructure. Public communication facilities, energy infrastructure, critical transportation routes, water supplies and air quality are routinely threatened by the spread of wildfire. The costs of fire suppression activities continue to grow at an accelerating pace.

The future growth of western population centers will create both challenges and opportunities in addressing the risk of wildfire. Development in what is characterized as the “Wildland-Urban Interface” (WUI) has sparked significant debate regarding the wisdom of allowing development in fire prone areas, the impact of fire suppression on governmental budgets and whether building codes, land use restrictions and other tools can effectively be utilized to minimize the impacts of continued growth. This article explores the tools being developed by different western communities to combat the ongoing threat of wildfire.

2. The Evolution of Fire Policy

The U.S. Forest Service (USFS) adopted a strong policy of fire suppression beginning as early as 1920.[2] The Clarke-McNary Act of 1924[3] tied federal appropriations to a requirement that each state adopt a strong fire suppression policy. As a practical matter, this resulted in a national policy of fire suppression. While early fire research (dating from the 1920’s) demonstrated the significant ecological benefits associated with a regular cycle of frequent and low intensity fires, such actions were contrary to state and federal fire policies for many decades. Fire suppression policies were initially effective in controlling the spread of wildfire. However, the excessive loading of forest fuels has resulted in larger, hotter and more intensive “stand- replacement” fires that are far more difficult and costly to control.

Federal fire policy has significantly changed since 1995 with a current recognition that fire plays a natural and essential role in the ecology of the west. A 2001 federal “Wildfire Management Policy” characterized fire as “as a critical natural process” to be “integrated into land and resource management plans and activities on a landscape scale, and across agency boundaries.”[4] Following this change in federal fire policy, the USFS began efforts to reduce fire hazards on public lands using a combination of mechanical treatments and prescribed fire. Both the USFS and the U.S. Bureau of Land Management (BLM) have initiated significant efforts to treat and control fire hazards on the western public lands- with specified goals for annual fire treatments. Unfortunately, agency progress towards stated fire treatment goals has been constrained by a number of factors. Federal agencies encounter a variety of legal and practical challenges in efforts to implement fuel production measures. Public opposition to smoke has made it increasingly difficult for land managers to implement prescribed burns, particularly in locations near urban centers where such treatments are critically necessary. In addition, regulatory review and court challenges related to the short term impact of fire on sensitive, threatened and endangered species have impeded progress towards agency treatment goals.[5] Budgetary constraints and liability concerns (discussed in more detail below) have also severely limited agency treatment efforts and objectives. While current fire policies recognize the need to implement aggressive forest fuels reduction measures, efforts are increasing derailed by the substantial costs of fire suppression. As a result, federal, state and local governments face significant roadblocks in their efforts to address, control and reduce forest fuels.

3. Growth of Wildfire Protection Costs

The primary federal agencies responsible for fire protection are the USFS, BLM, the National Park Service (NPS), the U.S. Fish and Wild Life Service (FWS) and the Bureau of Indian Affairs (BIA). Federal appropriations for fire suppression activities have tripled since 1990. In the 1990’s, the average cost of federal wildfire protection and suppression was less than $1 billion annually.[6] Annual costs have grown substantially since 2012, now averaging over $3 billion per year.[7] Nearly half of the USFS annual budget and nearly ten percent of the budget for all Department of Interior agencies (including the BLM, NPS, FWS and BIA) is now devoted to wildfire suppression efforts. In addition, the Federal Emergency Management Agency (FEMA) has been required to pay substantial amounts in disaster relief related to large wildfires. FEMA responded to 19 major or emergency wildfire disaster declarations between 2000 and 2012.[8] FEMA’s fire management assistance grants have grown from $20.4 million annually in the 1990’s to more than $71.2 million annually between 2002 and 2011.[9] These figures do not include the substantial and growing expenditures made by state and local governments on fire suppression activities. State government expenditures on fire suppression measures have been estimated to exceed over $1 billion annually with no definitive tabulation of the significant expenditures of local governments.

Firefighting costs routinely exceed annual agency appropriations. The rising costs of fire suppression have strained agency budgets and diverted funds originally earmarked for forest fuel reduction programs, resource management programs, recreation and wildlife habitat. Federal agencies have been required to borrow unobligated funds from other agency accounts to fund emergency firefighting efforts to the detriment of other federal programs. In an effort to address these funding challenges, Congress enacted the Federal Land Assistance, Management and Enhancement Act (FLAME Act) of 2009.[10] The FLAME Act established reserve funding mechanisms for the USFS and Department of Interior that are intended to address the rising costs of forest fire suppression. In addition, Congress mandated the development of a national wildland fire management strategy to comprehensively address wildland fire management across all lands in the US. While FLAME Act funds were intended to insulate federal land management agencies from the financial impacts of fire suppression, agency budgets are impacted by the increasing costs of handling large wildfires.[11]

4. Issues/challenges associated with development within the Wildland-Urban Interface

Growth and development in Wildland-Urban Interface presents difficult challenges for governmental entities, land managers and property owners.[12] Fire protection in the WUI is largely the responsibility of state and local governments but the federal government provides oversight, assistance and funding to state and local governments. Federal wildfire suppression policies prioritize the protection of human lives, with the protection of private property and natural resources as a second priority. As a result of this priority scheme, federal fire- fighting resources are often allocated to combat large wildfires that threaten homes and other structures located on privately-owned property within the WUI. This priority scheme creates challenges for federal agencies which have no oversight or control over development on privately owned forest lands.

In 2003, Congress passed the Health Forests Restoration Act[13] which requires that half of the allocated federal fuel reduction funds be used in the WUI. Fuel reduction efforts are particularly difficult to implement in the developed WUI areas. The presence of homes constrains the ability to utilize prescribed burns as a tool to control forest fuels because land managers face potential liability concerns associated with the intentional introduction of fire. For example, in 2000 a prescribed burn in the Bandelier National Monument was impacted by shifting winds and burned into areas of Los Alamos, New Mexico. In Montana, the State Supreme Court upheld a $750,000 judgment against the State Department of Natural Resource and Conservation when an intentionally set “backfire” was determined to have unnecessarily harmed a privately owned ranch. As a result of these factors, less effective mechanical fire suppression tools, such a mowing, pruning and brush removal, are commonly utilized in WUI areas where prescribed burns are needed.

The challenges of fire protection in the WUI are expected to grow as population and development pressures increase in the west. It is estimated that only 16 percent of the western WUI areas are currently developed.[14] In order to reduce wildfire risk, federal, state and local governments must work cooperatively with developers and private property owners to plan for future developments in the WUI.

5. Tools for Future Development

Federal, state and local land managers have a variety of different tools that may be utilized to guide the future development of properties within the Wildland-Urban Interface. Public education, ongoing fuels treatment programs, building standards and zoning restrictions have all proved effective in minimizing fire risks in the WUI.

Beginning in 1986, the USFS and the U.S. Department of Interior partnered with the National Fire Protection Association (NFPA)[15] and the National Association of State Foresters to create a national project to address fire dangers and planning in the WUI. This collaborative effort has resulted in the creation of the “Firewise Communities Program,” with a mission to protect people and property in communities at risk from wildfire. The Firewise program includes public outreach, education, agency coordination efforts and the promulgation of specific building and development standards designed to minimize wildland fire risks.

The NFPA has developed specific standards intended to minimize wildfire risks in the WUI. NFPA 1141 provides the “Standard of Fire Protection Infrastructure for Land Development in Suburban and Rural Areas.” This standard recognizes that development in WUI areas often occurs in areas with inadequate public water supply, extended fire department response times, limited available access and areas of hazardous vegetation. The standard addresses the design of subdivisions and development in areas where the threat of fire has not previously been addressed in land use planning or applicable fire and building codes.

By contrast, NFPA 1144 contains “Standards for Reducing Structure Ignition Hazards from Wildfire Risk.” This standard provides a methodology for assessing wildland fire ignition hazards around existing structures, residential developments and subdivisions that will be located in WUI areas. The standard contains minimum requirements for new construction to reduce potential of structural ignition from wild land fires. NFPA 1144 references specific standards for building design, building locations and construction. The rules require a wildland fire assessment of each structure in a development zone to determine relative fire risks and applicable mitigation measures. The standards are based on the extensive study of the risk of structural ignition in connection with wild land crown fires. Crown fire experiments conducted in both forest and shrub land areas have indicated the temperature, flame length and flaming duration associated with major wildland fire events. Research has demonstrated that wildland fires do not spread to homes unless the homes meet the fuel and heat requirements sufficient for ignition and continued combustion.[16] Flammable materials adjacent to a home can be managed with the home’s materials and design to minimize the potential for ignition. Structural ignition modelling has been utilized to calculate the amount of radiative and convective heat transferred to a structure in connection with major wild land “crown fire.” The NFPA standards contain requirements for fuel breaks and brush clearing that will reduce the heat and intensity of fire around the site of a structure. NFPA building material and construction standards are designed to insure a structure can survive a wildland fire event. Case studies have demonstrated that the application of building and development standards are effective in reducing structural damage in WUI areas impacted by wildfire.

The International Code Council (ICC) has also promulgated independent standards governing building and development in the WUI. The ICC’s Wildland-Urban Interface Code (WUI Code) is designed to apply to the construction, alteration, movement, repair and maintenance of any structure located in the Wildland-Urban Interface. The code contains science based regulations intended to mitigate the risk to life and structures from wildland fire exposure. The WUI Code contains standards governing defensible space, vegetation management and ignition resistant construction. In addition, the WUI Code references minimum standards for access roadways, water supplies and other land use and development considerations in the WUI. The specific construction and development standards of the WUI Code will differ, depending on vegetation type, topography and the degree of fire hazard. Implementation of this code requires mapping of the WUI boundary and designated fire hazards.

Many individual western cities and counties have incorporated provisions from the NFPA standards and WUI Code into their local fire and building codes. The scope and degree of local implementation has varied in individual jurisdictions based on topography, climatic conditions, the degree of fire risk and specific vegetation types. Political and budgetary constraints have impacted the ability to implement fire related building and development standards in some locales.

6. Case Studies

Case studies conducted in the aftermath of large fire events have highlighted standards and practices that can be implemented to control fire risks in connection with future development in WUI areas. A comprehensive assessment of fire strategies was conducted after the Waldo Canyon Fire near Colorado Springs, Colorado in 2012.[17] The Waldo Canyon Fire was the worst in Colorado state history. Two residents were killed, 346 homes were lost and more than 30,000 acres were evacuated. In the end, it took firefighters 18 days to fully contain the blaze.

The Waldo Canyon fire provides lessons that apply throughout the west, as the fire burned through a variety of different forested areas and vegetation types (pine, fir, spruce, shrubs, grass, oak and juniper/pinyon). Assessment of the fire demonstrated that adopted building codes and ordinances were effective in reducing fire risk. In fact, following the assessment, the City Council worked with the Fire Marshall, local builders’ associations and residents to amend applicable fire codes to provide more guidance on exterior building materials and other factors intended to reduce fire risk. The fire also demonstrated that fire mitigation work conducted in high risk areas was effective in saving 82 percent of the structures threatened by fire. Analysis demonstrated a significant cost/benefit ratio associated with fire fuels mitigation efforts. In one neighborhood (Cedar Heights) the study identifies a cost/benefit ratio of 1/257 ($300,000 spent on mitigation work avoided $77,248,301 in losses). For all neighborhoods affected by the fire, each dollar spent on pre-fire mitigation efforts prevented $517 in losses.

The Waldo Canyon assessment determined that mitigation efforts must be conducted at both the individual and community level. In addition, mitigation efforts must be ongoing because the threat of wildfire will continue in fire prone areas. The study concluded that individual property owners can significantly reduce potential losses by ongoing and regular mitigation efforts. Creating and maintaining areas of defensible space and the removal of debris from areas surrounding home sites was critical to ongoing fire protection efforts. The study noted the importance of utilizing non-combustible building materials and specifying construction standards in high risk areas. The continuing importance of prescribed fire was also noted.

Observations conducted after Arizona’s Wallow Fire provide additional insight into fuels reduction and the preservation of wildlife habitat. The Wallow Fire was one of the largest in Arizona history and burned more than 539,000 acres in May-June 2011. Observations conducted after the Wallow Fire showed the effectiveness of previously treated areas in containing and reducing fire impacts.[18] Treated areas of ground cover reduced the intensity of the fire and eliminated the need for active fire suppression efforts in many areas. Analysis showed treatment methods were effective in both intensively treated areas that had been cleared for fire protection and less intensively cleared areas where land managers had preserved limited areas of dense forest cover for wildlife habitat. Where habitat considerations were applied to the treatment regime, the study demonstrated the need for larger treatment areas to reduce fire severity.

A case study of fires in Monterey County, Nevada County and Tuolumne County, California demonstrate the importance of land use planning to protect against wild land fire events.[19] This assessment recommended that land planners recognize that extreme fire hazard may limit development in some areas based on water scarcity and environmental conditions (slope, fuels, weather, access). Planning rules should require that any development creates and maintains defensible space for structures. Regulations are needed for all aspects of development work, including roads, water supply, density, setbacks, turnarounds and the position of a house on its lot. In addition, fire protection agencies should be involved in the land use planning, with an equitable sharing of planning costs between developers, local governments and fire protection agencies. The study also documented the importance of adopting and adhering to fire resistant building codes and development standards.


Land planners, local governments and private developers have a wide variety of available tools to address fire danger in the Wildland-Urban Interface. The implementation of appropriate mitigation and planning measures can provide an additional degree of protection in areas of current fire danger. Current expenditures for fire suppression have proved inadequate to fund much needed fire fuels reduction efforts. Studies have indicated the cost-effectiveness of fuel treatment regimes, including the use of prescribed fire. State and local governments can adopt existing science-based fire treatment and building standards to further reduce fire risks.

[1] The Rising Cost of Wildfire Protection, Ross Gorte, Headwaters Economics, June 2013

[2] Federal Forest Policy in the United States, Scott L. Stephens and Lawrence W. Ruth, Fire Management, Volume 22, Number 4, (2005).

[3] 43 Stat 653 (1924)

[4] Federal Forest Fire Policy in the United States, Scott Stephens and Lawrence Ruth, Fire Management, Volume 22, Number 4 (2005).

[5]In many cases, specific resource management strategies designed to protect the viability of threatened and endangered species have worked to exclude fire from otherwise fire-dependent habitat. While such management prescriptions may provide a short term benefit to sensitive wildlife and habitat, the long term consequence is the build-up of forest fuels that will eventually burn under severe and catastrophic conditions. See Federal Forest Fire Policy in the United States, Stephens and Ruth (2005).

[6] Gorte, The Rising Cost of Wildfire Protection, Headwaters Economics, June 2013.

[7] Id.

[8] Id.

[9] Id.

[10] 43 USC 1748a (2009)

[11] See discussion of federal fire suppression funding, “Local Responses to Wildfire Risks and Costs, Case Studies and Lessons Learned,” Ray Rasker, Headwaters Economics, Spring 2014.

[12] The term “WUI” is commonly used as a short-hand reference to all forested areas and wild lands that abut more intensive urban development. There is, however, no precise definition of a specific WUI boundary. From a technical perspective, the WUI is intended to encompass areas where the fuel feeding a wildfire changes from natural (wild land) fuels to man-made fuels (from structures or development). Essentially, the term WUI is intended to encompass all areas surrounding urban development where there is a danger wild land fires will ignite homes or other developed structures. See Jack D. Cohen, What is the Wildland Fire Threat to Homes, April 10, 2000, USFS.

[13] 16 USC Chapter 84 (2003).

[14] Gorte, Ross, The Rising Costs of Wildfire Protection, Headwaters Economics, 2013

[15] The NFPA is a global non-profit life- safety organization that was formed in 1896 with a mission to eliminate death, injury and property damage associated with fire. The organization has developed over 300 sets of consensus code standards that are designed to minimize the possibility and effects of fire and other hazards.

[16] What is the Wildlland Fire Threat to Homes, Jack D. Cohen , Research Scientist, USFS, April 2000

[17] Lessons Learned from Waldo Canyon, Fire Adapted Communities, Mitigation Assessment Team Findings.

[18] Science Daily,USFS Pacific Northwest Research Station, May 30, 2014.

[19] Land Use Planning May Reduce Fire Damage in the Urban-Wildland Intermix USFS, General Technical Report PSW-127 Carol Rice, James Davis, March 1991.

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