Cultural Resources and Fire Planning

Wildland fire is one of the most prevalent, rapid and dramatic forces that affect park resources. To protect against the ravages of fire, wildland fire management programs require careful, methodical planning far in advance of any fire event. Planning can mitigate adverse effects of fire and effects of management of fire on cultural resources and requires involvement by cultural resource specialists. Deferring involvement until fire is on the ground increases the chance of unacceptable outcomes for cultural resources.

NPS Management Policies (reference, 2006) directs each park with burnable vegetation to have an approved wildland fire management plan. The plan defines and documents a program to manage wildland fire within a specific park and is the cornerstone of a park’s wildland fire management program. Wildland fire management plans and associated compliance documents provide flexible programmatic multi-year coverage for wildland fire management activities and can accelerate compliance with Federal laws, policies, and Executive Order 13175.

This section of the Cultural Resource and Fire Chapter of RM #28A: Archeology provides guidance for wildland fire managers; cultural resource managers; NHPA Section 106 coordinators; and park superintendents for integrating cultural resource information into wildland fire planning.

Employee and public safety is the first priority in every management activity. All planning and implementation activities must reflect this commitment. A job hazard analysis should be prepared for each incident activity.

For a downloadable checklist of activities to ensure that cultural resources are included in wildland fire planning, go to the Wildland Fire Planning and Cultural Resources Checklist (.docx).

Wildland Fire Management Planning and Cultural Resource Law Compliance

NPS DO #18: Wildland Fire Management requires that wildland fire management plans comply with the National Environmental Policy Act (NEPA) and National Historic Preservation Act (NHPA) Section 106. In addition to consultation for NEPA and NHPA compliance, Executive Order 13175 and DOI Policy on Consultation with Indian Tribes require that the NPS conduct government-to-government consultations with federally-recognized Indian tribes when undertaking any Federal action that may have a direct impact on tribes or tribal lands. Tribes may have concerns about cultural resources that may not necessarily be addressed during the NHPA Section 106 process.

Key elements of compliance include compilation of information in order to consider the effects of fire planning and project implementation on cultural resources; to allow individuals, associated groups, and federally-recognized Indian tribes to comment on the planning documents and implementation actions; and documentation of the consultations.

Consultation with groups associated with the park, Indian tribes, State and Tribal Historic Preservation Officers, and the public is an important component of compliance with Federal cultural resource laws and policies and Executive Order 13175. Consultation occurs when planning documents are developed (fire management plans, burn plans, etc.) and again when the plans are implemented.

Cultural Resources Implications

Cultural resource managers participate in the wildland fire management plan NEPA Environmental Assessment or Environmental Impact Statement planning process to ensure that fire program alternatives adequately consider and assess effects on cultural resources. Cultural resource managers should coordinate NEPA and NHPA public involvement for the purpose of developing Environmental Impact Statements and Environmental Assessments. Cultural resource managers can anticipate cultural resource assessment needs for compliance with NHPA Section 106 by initiation of cultural resource inventory under NHPA 110. An active park NHPA Section 110 program to identify and assess cultural resources aids in their protection during fires.

The cultural resource manager coordinates with the park or regional Section 106 coordinator. Appropriate tribal officials are contacted at the earliest possible point in the wildland fire planning process so that tribal input can be incorporated into wildland fire planning documents in compliance with Executive Order 13175 and DOI policy.
Fire Management and Cultural Resource Laws contains more information about Federal cultural resource laws, policies, and Executive Order 13175.

Wildland fire management plans and associated compliance documents are structured to provide flexible programmatic multi-year coverage for a range of wildland fire management activities while minimizing the amount of additional compliance efforts required for each individual fire event or project. Fire management planning has three distinct levels:

• Strategic planning;

• Annual planning; and

• Project/event planning.

Cultural resource managers’ involvement in all three levels of planning is critical to stewardship responsibilities.

Strategic Wildland Fire Management Planning

Strategic wildland fire planning considers short and long term benefits and damage from wildland fire to the landscape. The overall objective is to reduce damage to natural and cultural resources and to increase beneficial effects of fire for those same resources. Planning may include scheduling fuel reduction projects (prescribed burns and mechanical fuel reductions), and protocols for responding to unplanned fires (wildfires) that range from full suppression to monitoring from a distance. Land, resources, and incident objectives guide the incident manager in choosing the appropriate responses and tactics for each wildland fire.

Strategic planning for wildland fire begins with the park’s general management plan (GMP) and/or foundation statement (FS). The GMP/FS establishes the overall direction for the role of wildland fire within the park. The park’s cultural resource management plans (or resource stewardship strategy) further describes how wildland fire is managed to fulfill park objectives, as well as to establish resource-related objectives for wildland fire management activities.

The wildland fire management plan implements guidance and objectives described in higher-level park planning documents (GMP/FS and resource plans), and ensures that wildland fire management is integrated into other activities and furthers park stewardship goals. It provides specific operational guidance to the wildland fire management staff, including:

• Demonstrating that wildland fire management is derived from and consistent with park-wide goals and objectives put forth in other management plans;

• Describing where, how and why wildland fire will be managed in the park;

• Defining roles and responsibilities of park staff and cooperators in wildland fire management;

• Describing how wildland fire will be safely employed to best meet park objectives and how detrimental effects of fire will be managed; and

• Listing the consultation schedule, to ensure compliance with Federal cultural resource laws, policies, and Executive Order 13175.

Cultural resource information provided to the wildland fire management program may include analysis of the positive and negative effects of the proposed actions on specified resources or classes of resources, as well as a preferred alternative. It may also contain descriptions of mitigation actions that become requirements for wildland fire managers when implementing the preferred alternative.

Cultural Resources Implications

Cultural resource managers must become familiar with the contents of their park’s wildland fire management plan and be proactively involved in its development and periodic updates, ensuring that relevant cultural resource information is included in planning documents. Close collaboration between the cultural resource program and the wildland fire program is the most important aspect of planning for cultural resource protection in the event of a wildland fire. The collaboration ensures that information about cultural resources at risk is incorporated into the wildland fire management plan.

Cultural resource managers work with the wildland fire program managers to plan fuels treatment projects that improve conditions of cultural resources. The goal is outlined in strategic plans and recognized as mutually beneficial for both cultural resources and wildland fire programs.

For more information about wildland fire management plans, see Chapter 4—Fire Management Plans of RM 18—Wildland Fire Management (.pdf).

Annual Wildland Fire Management Planning

Parks conduct an annual review of their wildland fire management program and assess the adequacy of the wildland fire management plan and related compliance documents. Cultural resource managers and wildland fire managers work closely to ensure that annual planning is in compliance with Federal cultural resource laws and policies and Executive Order 13175. Many parks have a standing wildland fire management committee that helps to review wildland fire management planning and implementation documents.

The annual planning cycle incorporates updates to the multi-year fuels project plan, including projects that may have been deferred, altered, added, or deleted since the last update. The multi-year fuels project plan gives fire and cultural resource managers an opportunity to anticipate planning, funding, and survey needs well in advance of project implementation.

The park NHPA Section 106 coordinator works to ensure that NHPA requirements are met and coordinates consultations for compliance with NHPA and NEPA. Cultural resource managers ensure that private and sensitive information about the locations of cultural resources are protected but accessible to wildland fire program managers and incident managers.

Cultural resource managers develop and update the park cultural READ manual to ensure that cultural resources will be considered when responding to fires and implementing fuel reduction projects.

Wildland Fire Project/Event Planning

Each fuels reduction project and unplanned ignition has distinct planning and decision processes that guides its implementation. Consultation about cultural resources for compliance with Federal cultural resource laws and policies and Executive Order 13175 is an important component of the project planning and implementation process. Consultation takes place when finalizing the planning documents, implementing the planned activities, responding to wildfires, and planning and implementing post-fire recovery activities.

Planning for Wildfires (unplanned ignitions)

Though this seems contradictory, wildland fire managers do in fact ‘plan for the unexpected.’ Initial response to an unplanned ignition is normally guided by the park’s wildland fire management plan and is influenced by the origin and location of the ignition and the weather and fuel conditions at the time of the response. Responses may be immediate and aggressive, or delayed and reserved, depending on the individual situation and requirements contained in the management plan. For ignitions whose wildland fire management is expected to extend beyond a single day, the interagency Wildland Fire Decision Support System (WFDSS) is engaged. Decision criteria and factors important to the park (identified during the park’s preplanning efforts) are often preloaded into WFDSS, and information about the unfolding event, including decisions on management strategies and tactics, are recorded.

Cultural Resources Implications

It is critical that issues and concerns regarding cultural resources are incorporated into the wildland fire management plan and WFDSS decision criteria. Including cultural resources information in the plan increases the probability that the incident manager will take cultural resources into account when implementing wildfire management activities.

Cultural resources at risk for adverse effects of wildland fire are identified and mitigation measures are described in the wildland fire management plan and/or EA/EIS. Cultural resources rehabilitation and restoration should be identified as a specific objective in wildland fire planning documents.

Fuels Treatment Planning (planned ignitions and mechanical fuel reductions)

Fuels treatments proactively meet a variety of wildland fire management and cultural resource management objectives, including reducing the probability of damaging fires through removal of biomass; increasing defensible space around structures and other resources subject to fire damage; restoring and maintaining fire-dependent ecosystems; and maintaining vistas or cultural landscapes.

Fuels management treatments are planned several years in advance in order to secure funding for implementation and to allow time for detailed planning and preparation of the site for treatment. Planning includes survey of cultural resources and evaluation for eligibility for the National Register of Historic Places. Since the actual implementation of a given fuels project depends on a large number of variables including weather, funding, and staff availability, the exact fuels treatments planned at the beginning of a season may vary considerably from the those that are implemented as conditions change.

Each fuels treatment—whether using fire, chemical or mechanical methods—requires a separate plan. Individual treatment plans include a detailed description of objectives, operational details (including the type of tactics and equipment to be used), description of constraints and mitigations, evaluation criteria, other information required for safe implementation, and documentation of cultural resource consultation.

Cultural Resources Implications

Cultural resource managers are closely involved in fuels treatment planning to insure that requirements, mitigation, and protection contained in the park’s wildland fire management plan and compliance documents are included and implemented. They stay current with annual fuels treatment project planning to stay current with potential changes and project substitutions. Cultural resource managers also ensure that post-project monitoring is included in fuels planning documents to ensure that mitigation measures to protect cultural resources were effective.

Implementation of Planning Documents

Cultural resource and wildland fire managers continue cooperation and coordination to ensure that cultural resources are considered during the implementation of wildland fire management plans, and that both plans and projects comply with Federal cultural resource laws and policies and Executive Order 13175.