Fuel Reduction and Cultural Resources

National parks conduct prescribed burns and mechanical fuel reductions to reduce the amount of combustible material within park boundaries. Prescribed burns are fires intentionally set and allowed to burn within a designated area. Mechanical fuel reductions refer to the manual or machine removal of fuels from a designated area. Prescribed burns and mechanical fuel reductions intentionally reduce the fuel load to prevent or minimize the effects of wildfires.

Careful planning can result in a fuel reduction project that mutually benefits the wildland fire program and cultural resource program. This section of Cultural Resources and Fire provides guidance to ensure that planning and implementation of fuel reduction projects comply with Federal cultural resource laws and policies, and Executive Order 13175. The guidance is aimed at wildland fire program managers; cultural resource managers; park superintendents; and Section 106 coordinators.

For a downloadable checklist of activities to facilitate consideration of cultural resources in planning and implementing fuels reduction projects, go to the Fuel Reduction Projects and Cultural Resource Checklist (.docx).

Planning Fuel Reduction Projects

Planning for fuel reduction projects begins with the park’s wildland fire management plan. Parks schedule fuel reduction activities 5-10 years in advance and include them in the plan. The list of proposed fuel reduction projects is updated as projects are completed and new ones are added. Each year, the park prioritizes the fuel reduction activities for that year. The national program coordinates fuel reduction activities between agencies and distributes a list of targeted activities for that year. Depending on weather and other local conditions, this list may change. Wildland fire management plans must address management of cultural resources at risk during the prescribed burn or mechanical fuel reduction activity.

Cultural Resources Implications

Information about cultural resources in the area of potential effect (APE) is crucial to the burn plan or mechanical fuel reduction plan in order to ensure full consideration of the resource. Cultural resource managers review the wildland fire management plan and fuel reduction plans each year and update cultural resource information. As soon as a fuel reduction project is proposed and it is determined that the cultural resource inventory is incomplete, the cultural resource manager should formulate the project in PMIS for funding.

Funding for cultural resource assessment activities within the targeted areas may be available through the wildland fire management program, but coordination will be necessary to request and obtain funds. Useful information for obtaining funding for cultural resource inventories for fuels management projects is found in the Toolbox tool Fire Funding Sources for Cultural Resources (.pdf).
 

Fuel Reduction and Compliance with Federal Laws, Policies, and Executive Orders

Wildland fire management plans for fuel reductions are Federal undertakings and, as such, must comply with Federal cultural resource laws and policies, and Executive Order 13175.

Essential elements of compliance for fuel reductions include:

• Completion of an inventory of significant cultural resources at risk of adverse effects from the fuel reduction activity;

• Sharing information with stakeholders in consultation; and

• Documentation that stakeholders’ comments and concerns have been taken into consideration before implementing the proposed project.

Compliance with Federal cultural resource laws and policies, and Executive Order 13175 includes consultation to share and elicit cultural resource information and demonstration that comments and concerns have been taken into consideration when planning and implementing fuel reduction projects.

Consultations take place when the fuel reduction project is proposed, and may be held again just prior to implementation. Consultations with federally-recognized Indian tribes are conducted on a government-to-government basis and cannot be delegated to any nonfederal entity.

More information is available in Fire Management and Cultural Resource Laws.
Assistance for planning and implementing consultations is available in Consultation for Compliance with Federal Laws.

Cultural Resources Implications

Cultural resource managers work with the park NHPA Section 106 coordinator to ensure that all research, consultations, and documentation are completed before fuel reduction projects take place. Even if the fuel reduction activity is considered a Categorical Exclusion under NEPA, consultation under NHPA Section 106 still is required, including consultation with the State Historic Preservation Officer (SHPO), federally recognized Indian tribes, groups associated with the park, and the public.

On a case-by-case basis and for individual parks, the NHPA Section 106 coordinator may determine that all cultural resources within the APE of a fuels reduction project are accounted for and that the proposed project will have no adverse effect on historic properties. In these instances, the NHPA nationwide programmatic agreement or a park-specific programmatic agreement can provide an alternative process to streamline consultation.

More information about programmatic agreements is available in NHPA Programmatic Agreements and Fire.
 

Developing Cultural Resource Inventories for Fuel Reduction Projects

NHPA and NEPA compliance stipulates that all significant cultural resources that may be adversely affected by the proposed fuel reduction project be identified and assessed prior to initiation of the project. The effects of a fuel reduction activity on cultural resources depend on characteristics of the resources and of the method used to remove the burnable fuel. Mechanical fuel reductions may have little effect on historic structures but may have an effect on archeological resources. Proposed burns may have little effect on archeological resources, but have the potential for effects on historic structures. The direct and indirect effects of burning fuel depend on the size and height of the fuel, the moisture content, and other factors.

Cultural Resources Implications

Cultural resource managers work with the park wildland fire management program to identify the anticipated effects of the planned fuel reduction activities on cultural resources. For fuel reduction purposes, significant cultural resources include, but are not synonymous with, historic properties as defined in the National Historic Preservation Act. Cultural resources at risk are those that are significant to the park, and that are vulnerable to adverse effects of the project. If needed, the cultural resource manager proposes treatments to mitigate the anticipated adverse effects of the proposed fuel reduction activity.

More information about completing cultural resource inventories, identifying significant resources that may be adversely affected by fire, and planning treatments may be found in Cultural Resources Data for Fire Management.

More information about fire effects may be found in the Toolbox resource Direct Effects of Wildland Fire on Cultural Resources (.pdf).

More information about protecting cultural resources may be found in the Toolbox resource Fire Treatment Measures for Archeological Resource Protection (.pdf).
 

Implementing the Fuel Reduction Plan

The wildland fire program manager notifies the cultural resource manager of the dates of any fuel reduction activity. The wildland fire program manager and the cultural resource manager coordinate to ensure that all cultural resource avoidance or treatment measures are in place. Care is taken to ensure that the project does not exceed the APE.

Cultural Resources Implications

The cultural resource manager ensures that treatment measures are carried out to mitigate any adverse effects of fuel reduction activities on cultural resources. The manager also ensures that a knowledgeable cultural resource advisor (CR READ) is present to monitor the fuel reduction project.

Safety

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.

After Completion of Fuel Reduction Projects

Mechanical fuel reductions and prescribed burns protect cultural resources by removing burnable fuels from the vicinities of historic properties. These fuel reduction projects may also remove ground cover, and make the ground surface more vulnerable to looting and erosion, which affects the integrity of cultural resources. Periodic inspection of the affected APE is carried out to determine whether looting or erosion is occurring.

Cultural Resources Implications

The area of the fuel reduction project is inspected and monitored after the event, to ensure that no unidentified cultural resources are present and that no cultural resources are harmed by erosion or other disturbance. Documentation of the effects of the activity on cultural resources is important for understanding the efficacy of fuel reduction treatments. If, despite the efforts made to protect cultural resources, the fuel reduction project adversely affects cultural resources, additional actions are needed. The park superintendent may request that a BAER team provide assistance. The cultural resource manager works with the BAER team to determine the needs for cultural resource protection.

For more information about post-fire programs, consult Post-Wildland Fire Programs.