Managing Cultural Resources During Wildfires

Unplanned wildfires, by their very nature, are difficult to anticipate and the severity and extent of such an event cannot be predicted. Parks can, and do, however, specify protocols for responding to wildfires, identifying resources to be considered when implementing responses, and identifying management goals. A comprehensive wildland fire management plan includes information about cultural resources, recommended treatments for their protection, use of fire to benefit cultural resources, and restoration treatments after fire.

Procedures for considering cultural resources during unplanned wildfires facilitate protection of resources at risk from fire and fire responses. Good communication between wildland fire management programs and cultural resource management programs is one of the best ways to protect cultural resources during a wildland fire.

This section of the Cultural Resources and Fire module provides guidance for park superintendents; cultural resource managers; NHPA Section 106 coordinators; and wildland fire program managers to ensure that cultural resources are fully considered when responding to unplanned fires and to ensure that response protocols and implementation comply with Federal cultural resource laws and policies and Executive Order 13175.

Cultural Resources Implications

The National Historic Preservation Act (NHPA) Section 110 requires that Federal agencies develop a program to inventory and evaluate cultural resources within a park. It is beneficial to complete the inventory before any fire occurs and make relevant information available to the fire program manager for planning purposes. Information sharing ensures full consideration of cultural resources while planning fire management activities. During a wildfire information about these resources is made available to cultural resource specialists (CRS) or resource advisors (READ) working with incident managers. 

Establishing Response Protocols During Planning

The park establishes a framework for responding to wildfires in the wildland fire management plan. The plan articulates parameters for controlling and containing fires within the park boundaries and outlines recommendations for treatment for known cultural resources. In cases where cultural resources have not been identified and assessed, protocols are specified for treatment or avoidance of cultural resources that may be encountered when responding to a wildfire. Objectives for managing or restoring cultural resources using fire are included in the plan.

Cultural Resources Implications

The cultural resource manager works closely with the wildland fire program manager and the NHPA Section 106 coordinator in planning protocols for responding to unplanned fires to ensure that cultural resource management concerns are included in the development of wildfire planning documents for the park.

Wildland Fire Planning and Cultural Resources provides more information about wildland fire management planning processes to ensure that cultural resources will be fully considered when developing planning documents.

Compliance with Federal CR Laws, Policies, and Executive Order 13175

Wildland fire management responses are Federal undertakings that have the potential to adversely affect important cultural resources of significance to a park or park. Because it is a Federal undertaking, wildland fire management response protocols must comply with Federal cultural resource laws policies, and Executive Order 13175. Implementation of response protocols is also considered a Federal undertaking. Wildland fire managers and cultural resource managers ensure that fire activities comply with laws, policies, and Executive Order 13175 at the planning and implementation stage.

Fire Management and Cultural Resource Laws provides information for complying with Federal cultural resource laws and policies, and Executive Order.

Cultural Resources Implications

Cultural resource managers are involved in the wildland fire management process to ensure that protocols for fire response comply with National Environmental Policy Act (NEPA) and National Historic Preservation Act (NHPA) Section 106, other Federal cultural resource laws, Executive Order 13175, and Department of the Interior (DOI) and NPS policies.

More information about consultation requirements during fires is available in Consultation for Compliance with Federal Cultural Resource Laws and Policies.

Unless this contingency is documented in an approved fire management plan or a park-specific programmatic agreement, the SHPO must be consulted about cultural resources potentially affected by fire management activities. Responses to wildfires that have been formally declared emergencies or disasters are not subject to NHPA Section 106 compliance at the time of response, however, the park must initiate compliance within 30 days following the fire.
 

Wildfire Typology

Wildfire classifications are based on size, severity, and complexity of the organization needed to respond. Each type of wildfire prompts structured responses from the park and agency. Unplanned wildfires on Federal lands are managed through the incident command system, which can expand or contract to accommodate the size and complexity of a fire. In order for cultural resource management staff to cooperate promptly and efficiently with the wildland fire management program, implications of the wildland fire classification system must be understood.

Type 5—Initial response. Local fire suppression resources assess and attempt to contain the fire in one operational period (usually 12 hours for wildfires, 4 hours for structural fires).

Type 4—Extended Response. Initial response exceeds first operational period. Additional resources are needed to manage increases in complexity of organization. Aerial resources may be needed or are enroute. The situation enters an extended response, exceeding one operation period.

Type 3— Extended Response. Local incident management team needed. Incident management organization expands as additional command positions are added.

Type 2— Extended Response. Regional incident management team needed. Delegation of authority by park superintendent to incident commander needed. Incident command organization complexity increases. Additional dispatch, logistical, planning, and operational support needed.

Type 1— Extended Response. National incident management team needed. Delegation of authority needed. Incident command organization complexity increases. Additional dispatch, logistical, planning, and operational support needed.

Initial Response to Wildfires

The first response to an unplanned wildfire generally involves relatively few fire-fighting resources because either the fire is small, or it takes time to assess and mobilize for an extended response. Small fires may be suppressed completely by an initial response.

Wildfire suppression typically includes three phases of activities: 1) Containment - the establishment of fire control lines around the entire fire perimeter; 2) Control - ensuring the fire is completely out within a defined buffer around the entire perimeter achieved through mop-up activities; and 3) Fire suppression repair - cleaning up activity areas, removing hazardous trees, and repairing fire control lines. All three phases of fire suppression may occur at one time during a single fire.

Depending on the park’s fire management objectives, land, location, timing and expected effects of a wildfire, the objective of the response may not be full suppression and containment. When the park has an approved wildland fire management plan, fire management policy allows for the use of wildfire to meet management objectives such as hazardous fuel reduction and ecosystem restoration.

Transition to an Extended Response

If a wildland fire event spans multiple days, it is no longer classified as a Type 5. A daily operational plan is developed by the wildland fire’s incident manager that incorporates site specific activities, equipment use, staffing, firefighting tactics, and constraints on operations among other information. Modeling of fire spread days or weeks into the future may be conducted by the incident fire manager to anticipate potential effects and to plan needed actions.

A Type 2 fire is the first level at which most or all of the command and general staff positions of the incident command system (ICS) are activated, and park staff prepare a delegation of authority. The delegation of authority transfers responsibility for management of the park from the superintendent to an incident manager. The delegation includes descriptions of the preferred management strategies, the operational parameters associated with those strategies, and the human and other resources necessary to carry out the strategies, including cultural resource staffing. The fire suppression strategies that are chosen are consistent with the delegation of authority. It identifies resources to protect, including cultural resources.

When the ICS General Staff positions are activated, cultural resource considerations become the responsibility of the appropriate staff position. Cultural Resource Advisors (CR READs) are needed on wildfire management teams where there may be ongoing damage to cultural resources from the effects of the fire or the effects of efforts to control the fire. READs listed in the dispatch list or in the wildland fire management plan are contacted first.

A cultural READ needs to be involved when the delegation of authority is being drafted. The READ needs to be present during all planning meetings and able to contribute to planning discussions and offer solutions to operational problems. Cultural resource managers and cultural resource specialists in a park in which a fire is occurring coordinate with the incident command team or with the cultural READ about cultural resource issues. The cultural resource manager gathers as much information as possible regarding known cultural resources and their locations within the wildfire area, and works with the cultural technical specialist (THSP) or READ assigned to the fire and the incident command team to protect the resources.

Cultural resource managers ensure that significant cultural resources are identified in the delegation of authority, and that CR READs are notified of cultural resources at risk. In the early stages of extended responses there is a significant potential to protect cultural resources by informing the incident command team of conflicts between the proposed locations of fire management facilities (such as fire camps, helispots) and cultural resources. Avoidance of such locations may not always be possible if there are no suitable alternatives, but damage to these locations may be minimized if the conflict is identified and facilities are prudently put into place.

Protecting Cultural Resources During a Wildfire

The protection of known important resources is a high priority when protection is possible without endangering life, property, or the efficacy of the fire management effort. Such protection occurs within the context of the incident command structure. Management decisions about historic preservation priorities often must be made immediately in order to protect important resources. This includes decisions regarding which resources to protect as well as decisions regarding the type of protective measures that can be practically and effectively applied during wildfires. Parks often consider unevaluated cultural resources as potentially eligible for the National Register of Historic Places (National Register) and treat them as such for the purposes of the Federal undertaking that is the fire response.

Fire behavior modeling may estimate the amount of time that is available before a fire reaches certain areas, especially for large fires. There may be opportunities to carry out reconnaissance activities in advance of the fire if the daily situation analysis indicates that it is safe to travel to a particular area, and there is sufficient time without exposure to danger from the advancing fire, or without hindering fire management activities. Field reconnaissance and investigations are coordinated through the incident command structure. Unauthorized movements near the fire can result in removal from the fire lane.

Cultural Resources Implications

Even in large fires, there can be opportunities to carry out cultural resource survey and to protect known resources in areas that are predicted to burn. Information about protecting cultural resources from fire is available in Fire Treatment Measures for Archeological Resource Protection (.pdf). The highest priority for cultural resource survey is to identify new resources that may be subject to the most immediate threat of damage. Sources of damage usually consist of ground disturbance and threats to standing structures. Field survey before fire camps and staging areas, helispots, new access roads, road widening, and fire breaks created by bulldozers and hand lines are constructed, or as soon as possible after they are established, can help to protect cultural resources.

Survey results are communicated to the incident command team and may prompt relocation of facility or treatment to protect cultural resources. Immediate post-construction survey may prevent or minimize further resource damage. Always coordinate cultural resource survey and reconnaissance activities through the chain of command at the fire. The incident response team includes sufficient fire-line archeologists and CR READs to provide guidance to fire suppression staff for all such activities.
 

Transition to Burned Area Emergency Response (BAER)

After the fire is contained, the Incident Command team begins the process of mopping up and fire suppression repair, and returning control of the incident back to the local unit. The park may initiate burned area emergency response (BAER) actions to identify emergency stabilization and rehabilitation (ESR) needs. Efforts to assess fire suppression damage and prevent further damage to cultural resources from fire management activities, however, are initiated by the Incident Command team.

A report of supression activity effects on cultural resources is critical to appropriate post-fire treatment. Information reported will be used by cultural resource managers, as well as by the BAER team, in the weeks after the fire. Records of immediate post-fire cultural resource conditions are valuable in monitoring changes during BAER assessments and rehabilitation efforts. The report should also include recommendations for protection or rehabilitation. Recommendations for resource treatment should relate to either damage caused by fire or fire management activities, or threats posed by fire damage to the environment. Recommendations that are prohibitively expensive or which do not relate to fire effects are unlikely to be funded. Timeliness is essential in completing a report.

Cultural Resources Implications

The park cultural resource manager works with the incident command team or cultural READ to ensure that the cultural resources report is complete and submitted prior to demobilization. The report should be submitted to the incident command team before demobilization and provided to the park cultural resource manager so that it is available when BAER assessments begin.

Post-Wildland Fire Programs provides guidance for ensuring that post-fire assessments and rehabilitation consider needs to protect cultural resources.