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1 Chapter 17 2 Prescribed Fire 3 4 Introduction 5 TheAn updated version of the 2006 Interagency Prescribed Fire Planning and 6 Implementation Procedures Reference Guide (IA RX Fire Guide) was 7 signedissued by the National Wildland Fire and Aviation Executive Board 8 (NFAEBCoordinating Group (NWCG) on September 1, 2006.August 6, 2008. 9 The IA RX Fire guide provides consistent interagency policy, establishes 10 common terms and definitions, and identifies planning and implementation 11 processes for prescribed fire. These procedures meet all policy requirements 12 described in the 2003 Interagency Strategy for the Implementation of Federal 13 Wildland Fire Management Policy. The 2006 guide provides unified direction 14 and guidance for prescribed fire planning and implementation for the 15 Department of the Interior’s Bureau of Indian Affairs (BIA), Bureau of Land 16 Management (BLM), the National Park Service (NPS), the United States Fish 17 and Wildlife Service (USFWS), and the United States Department of 18 Agriculture Forest Service (USDA FS). The guide and prescribed fire plan 19 template can be accessed electronically at http://www.nifc.gov/fire_policy. 20 21 The guide can be obtained electronically at the National Fire and Aviation 22 Executive Boards (NFAEB) website: http://www.nifc.gov/fire_policy/ and at the 23 National Interagency Fuels Management Website: 24 http://www.nifc.gov/fuels/index.html. Access the ‘Direction and Guidance’ 25 link. 26 27 The IA RX Fire Guide describes what is minimally acceptable for prescribed 28 fire planning and implementation. Agencies may choose to provide more 29 restrictive standards and policy direction, but must adhere to these minimums. 30 All personnel involved in the prescribed fire planning and implementation 31 process must ensure that specific agency additional standards and or 32 supplemental guidance are followed. Please see agency specific additional 33 guidance: 34 35 Purpose 36 The purpose of this guide is to provide consistent interagency policy, establish 37 common terms and definitions, and identify planning and implementation 38 processes for prescribed fire. 39 40 The guide describes what is minimally acceptable for prescribed fire planning 41 and implementation. Agencies may choose to provide more restrictive standards 42 and policy direction, but must adhere to these minimums. 43 44 Scope 45 This guide provides policy and direction to implement existing federal policy 46 and has been developed with tribal, state, county, and local cooperators in mind. 2 Release Date: January 20082009 17-1 1 CHAPTER 17 PRESCRIBED FIRE

1 While some of these guidelines will not fit all non-federal cooperators, the intent 2 is to include everyone by establishing a planning and implementation guide that 3 might result in that outcome. 4 5 6 Prescribed Fire Program Goals 7 Interagency Prescribed Fire Program goals are to: 8  Provide for firefighter and public safety as the first priority. 9  Ensure that risk management is incorporated into all prescribed fire 10 planning and implementation. 11  Use prescribed fire in a safe, carefully planned, and cost-efficient manner. 12  Reduce wildfire risk to communities, municipal watersheds and other 13 values and to benefit, protect, maintain, sustain, and enhance natural and 14 cultural resources. 15  Utilize prescribed fire to restore natural ecological processes and functions, 16 and to achieve land management objectives. 17 18 Authorities 19 All use of prescribed fire will be supported by a Land/Resource Management 20 Plan (L/RMP) and/or Fire Management Plan (FMP). Prescribed fire projects 21 can only be implemented through an approved Prescribed Fire Plan. Specific 22 authorities exist for each agency to utilize prescribed fire (See Appendix A of 23 the Interagency Prescribed Fire Planning and Implementation Procedures 24 Reference Guide). All project decisions to use prescribed fire are subject to the 25 agency’s analysis, documentation, and disclosure requirements for complying 26 with the National Environmental Policy Act (NEPA). 27 28 During prescribed fire planning and operations, all federal agencies will accept 29 each other’s standards for qualifications. The minimum qualifications standard 30 is the National Wildland Fire Coordinating Group (NWCG) Wildland and 31 Prescribed Fire Qualifications System Guide, 2000 (PMS 310-1). State, local 32 cooperators, and contractors working on federal agency prescribed fires must 33 meet the NWCG PMS 310-1 standards unless local agreements specify 34 otherwise. 35 36 The main reference glossary for this guide is the NWCG glossary, which is 37 updated periodically: http://www.nwcg.gov/. 38 39 This guide is not intended to address interagency business rules. Reference 40 individual agency’s business rules for direction. 41 42 Prescribed Fire Planning Process 43 Common planning documents to ensure quality prescribed fire plans include: 44  Land/Resource Management Plan (L/RMP)

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1  Overall direction is provided to the Wildland Fire Management Program 2 by L/RMP. These plans serve as the document to initiate, analyze, and 3 provide the basis for using prescribed fire to meet resource management 4 objectives. 5 6 7 8 Fire Management Plan (FMP) 9 All burnable acres will be covered by a Fire Management Plan (FMP). The FMP 10 is the cornerstone plan for managing a Wildland Fire Management Program and 11 should flow directly from the L/RMP. FMPs may be developed for a Fire 12 Planning Unit (FPU) that crosses jurisdictional boundaries. Where the Wildland 13 Fire Management Program crosses jurisdictional boundaries, or where program 14 coordination is essential, the FMP will require interagency coordination. Most 15 FMPs are anticipated to fall into this category. 16 17 National Environmental Policy Act (NEPA) 18 Resource and prescribed fire objectives for specific prescribed fire projects are 19 derived from the NEPA analysis. The entire prescribed fire project area must be 20 analyzed under NEPA. NEPA documents that identify and analyze the effects 21 of using or not using prescribed fire treatment projects may include 22 Environmental Impact Statements (EIS), Environmental Assessments (EA), and 23 Categorical Exclusion (CE). 24 25 Other authorities that may be utilized to guide analysis and determination of 26 NEPA compliance are the Healthy Forest Restoration Act (HFRA), the Healthy 27 Forest Initiative (HFI), and the Tribal Forest Protection Act (TFPA). 28 29 Prescribed fire planning and related NEPA analysis should always occur at the 30 largest possible spatial and temporal scales. 31 32 Implementation Organization and Qualifications 33 During prescribed fire planning and operations, all federal agencies will accept 34 each other’s standards for qualifications. The minimum qualifications standard 35 is the National Wildland Fire Coordinating Group (NWCG) Wildland and 36 Prescribed Fire Qualifications System Guide, 2000 (PMS 310-1). State, local 37 cooperators, and contractors working on federal agency prescribed fires must 38 meet the NWCG PMS 310-1 standards unless local agreements specify 39 otherwise. No less than the organization described in the approved Prescribed 40 Fire Plan may be used for implementation. The complexity of each prescribed 41 fire or phase of fire(s) determines the organization(s) needed to safely achieve 42 the objectives specified in the Prescribed Fire Plan. 43 44 Minimum Supervisory Qualifications Determined By Prescribed Fire 45 Complexity: Complexity 2 Release Date: January 20082009 17-3 1 CHAPTER 17 PRESCRIBED FIRE Position High Moderate-low Low RXM1 Optional Optional Optional RXM2 Not Allowed Optional Optional RXB1 Required Optional Optional RXB2 Not Allowed Required Optional RXB3 Not Allowed Not Allowed Required FIRB Optional Optional Optional 1 Holding Specialist 2 Holding functions will be managed by personnel qualified at the appropriate ICS 3 wildland fire operations position as required by complexity, assigned resources 4 and operational span of control. For some projects, there may be no holding 5 requirements or the holding duties are assumed by the Burn Boss. 6 7 High, Moderate, and Low complexity prescribed fires are determined through 8 the required NWCG Prescribed Fire Complexity Rating System Guide. 9 10 Prescribed Fire Burn Boss Type 3 (RXB3) 11 Adoption of the RXB3 position is up to each agency. Non-federal RXB3s must 12 meet the qualifications as listed in the table below unless local agreements 13 specify otherwise. 14 15 An RXB3 will only be allowed to implement low complexity prescribed fires 16 where the possibility of spread or spotting outside the project area is negligible 17 to non-existent; multiple fuel models are not involved; and aerial operations are 18 not involved. 19 20 Requirements for Prescribed Fire Burn Boss Type 3 Training Required: S-290 Intermediate Wildland Fire Behavior Suggested: S-234 Ignition Operations Prerequisite Experience Incident Commander, Type 5 OR Advanced Firefighter/Squad Boss AND Satisfactory position performance as a Prescribed Fire Burn Boss Type 3 Physical Fitness Moderate Other Position Assignments that will Prescribed Fire Burn Boss Type 2 Maintain Currency Prescribed Fire Burn Boss Type 1 Fire Use Manager Prescribed Fire Manager Type 1 Prescribed Fire Manager Type 2 21 22 Responsibilities

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1 Prior to prescribed fire implementation, thorough planning and review processes 2 must be conducted. All prescribed fire actions must be developed from 3 resource/fire management objectives carried forward from FMP’s and L/RMP’s. 4 A specific implementation plan for each prescribed fire must be completed, 5 reviewed, and approved before ignition can begin. 6 7 The agency administrator has final approval authority for all Prescribed Fire 8 Plans, unless special circumstances warrant higher review and concurrence 9 (such as may occur during higher Preparedness Levels or for extremely large, 10 complex projects). Although the agency administrator has final approval 11 authority for the Prescribed Fire Plan and the Agency Administrator Pre-Ignition 12 Approval Checklist, the Prescribed Fire Burn Boss has the responsibility to 13 make the on-site tactical "GO/NO-GO" decision. The Prescribed Fire Burn 14 Boss ensures that all prescription, staffing, equipment, and other plan 15 specifications are met before, during, and after the prescribed fire. 16 17 Every Prescribed Fire Plan must receive a technical review. The Technical 18 Reviewer and Prescribed Fire Plan Preparer must be qualified or have been 19 previously qualified as a Prescribed Fire Burn Boss at an experience level equal 20 to or higher than the complexity being reviewed. Either the Prescribed Fire Plan 21 Preparer or Technical Reviewer must be currently qualified. 22 23 Only a RXB1 can review plans at high complexity. An RXB2 can review plans 24 of moderate to low complexity. An RXB3 is not allowed to function as a 25 Prescribed Fire Plan Preparer (see Chapter 3, section C of the Interagency 26 Prescribed Fire Planning and Implementation Procedures Reference Guide) or 27 Technical Reviewer. 28 29 Agency or individual unit policy may dictate additional reviews. Interagency 30 Prescribed Fire Plans require approval from all appropriate agency 31 administrators and a technical review. Listed below are the prescribed fire and 32 implementation position roles and responsibilities. 33 34 Agency Administrator 35 For the purposes of this document, the agency administrator is defined as the 36 Line Officer (or designee) of the agency or jurisdiction that has responsibility 37 for the prescribed fire. These usually include the: NPS Park Superintendent, 38 BIA Agency Superintendent, USFS Forest Supervisor, BLM District/Field 39 Office Manager, FWS Project Leader, State Forest Officer, and/or Fire Chief. 40 41 The agency administrator is responsible to: 42  Approve Prescribed Fire Plans. When approving a plan, understand the 43 risks associated with it. Ensure that the plan has been reviewed and 44 recommended for approval by the Technical Reviewer who was not the 45 primary preparer of the plan.

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1  Ensure that only trained and qualified personnel participate in the 2 implementation portion of the prescribed fire. 3  Ensure that projects are monitored, evaluated, and documented in the 4 project file. 5  Sign, date, and provide an expiration date for the approval to burn on the 6 agency administrator Pre-Ignition Approval Checklist (Reference Burn 7 Plan Template, Appendix B of the Interagency Prescribed Fire Planning 8 and Implementation Procedures Reference Guide). 9  Understand and approve the Complexity Analysis (PMS 424 January 10 2004). 11  Ensure that all prescribed fires are conducted in accordance with the 12 approved implementation plan and established standards and guidelines. 13  Ensure that periodic reviews and inspections of the Prescribed Fire 14 Program are completed. 15  Determine if and when the agency administrator is to be notified that 16 contingency actions are being taken. 17  Report all wildfires resulting from prescribed fires through the chain of 18 command. 19  Declare an escaped prescribed fire a wildfire (if responsibility is assigned 20 in the plan). 21  Ensure that escaped prescribed fires are reviewed according to established 22 guidelines. 23 24 Technical Reviewer 25 The Technical Reviewer is responsible for reviewing each Prescribed Fire Plan 26 element for content, evaluating the risk, and completing a Complexity Analysis 27 to ensure that the stated goals and objectives can be safely and successfully 28 achieved when properly implemented. The Technical Reviewer shall be 29 qualified or previously qualified as a Burn Boss at or above the level of project 30 complexity. At a minimum, NWCG qualifications will be accepted. The 31 Technical Reviewer should have local knowledge of the area, experience 32 burning in similar fuel types, and/or conduct an on-site review. The Technical 33 Reviewer must be someone other than the primary preparer of the plan. An off- 34 unit technical review is encouraged to provide an additional independent 35 perspective. It is acceptable for other specialists to review certain portions of 36 the plan however; a primary Technical Reviewer must be designated as 37 technical review signatory. For example, a fire behavior analyst may review the 38 fire behavior calculations; the aviation manager may review the air operations 39 plan; and/or a resource specialist may review impacts to their resource of 40 interests. It is recommended that at least once every year, each unit should send 41 a moderate or high complexity Prescribed Fire Plan off-unit for technical 42 review. The Technical Reviewer is responsible to: 43  Ensure that Prescribed Fire Plans meet agency policy and direction. 44  Ensure that the Complexity Analysis accurately represents the project, so 45 the agency administrator understands the identified risks and the mitigating

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1 measures enacted. This may require on-site review in Wildland Urban 2 Interface (WUI) or high complexity situations by the Technical Reviewer. 3  Check the prescription parameters against the fuel types to ensure that the 4 project as planned has a reasonable chance of meeting the resource 5 management objectives. 6  Ensure that the fire behavior calculations and/or prescription parameters 7 are appropriate and within the acceptable range. 8  Ensure that the ignition, holding and contingency plans are consistent with 9 the predicted fire behavior. 10  Complete and sign the Technical Review Checklist (See Burn Plan 11 Template, Appendix B of the Interagency Prescribed Fire Planning and 12 Implementation Procedures Reference Guide) and the Prescribed Fire Plan 13 signature page. 14 15 Prescribed Fire Plan Preparer 16 For the purpose of this document, the Prescribed Fire Plan Preparer is defined as 17 the individual responsible for the preparation of the Prescribed Fire Plan. 18 Several people may be involved in the preparation of the Prescribed Fire Plan, 19 but the Prescribed Fire Plan Preparer is responsible for the final plan content. 20 The primary preparer of the Prescribed Fire Plan will sign the signature page. 21 The preparer is responsible to: 22  Prepare the Prescribed Fire Plan in accordance with this guide’s policy and 23 direction. 24  Coordinate with the resource management and/or technical specialists to 25 ensure that the plan meets management and operational objectives. 26  Interact with the Technical Reviewer to ensure that all plan elements are 27 adequately addressed. 28  Complete and sign the Complexity Analysis. 29 30 Prescribed Fire Burn Boss (RXB1/RXB2/RXB3) 31 The Prescribed Fire Burn Boss is responsible to the agency administrator, 32 Prescribed Fire Manager, or FMO/local fire management organization for 33 implementing the Prescribed Fire Plan. The Prescribed Fire Burn Boss is 34 responsible to: 35  Review the Prescribed Fire Plan prior to implementation and ensure all 36 required elements and objectives are addressed. 37  Inspect the burn unit to validate Prescribed Fire Plan elements including 38 areas of special concern as well ensuring that holding/contingency plans 39 adequately address expected fire behavior outside the unit(s). 40  Obtain current weather and smoke management forecasts, updates, and 41 special advisories from a meteorologist. 42  Maintain communication with the agency administrator, Prescribed Fire 43 Manager, or FMO/local fire management organization.

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1  Ensure that the Agency Administrator Pre-Ignition Approval Checklist is 2 valid (See Burn Plan Template, Appendix B of the Interagency Prescribed 3 Fire Planning and Implementation Procedures Reference Guide) 4  Take to the field those portions of the Prescribed Fire Plan necessary for 5 completing the briefing and safe project implementation. 6  Complete and sign the Prescribed Fire GO/NO-GO Checklist (See Burn 7 Plan Template, Appendix B of the Interagency Prescribed Fire Planning 8 and Implementation Procedures Reference Guide). 9  Ensure availability of any contingency resources and management of those 10 resources if deployed. 11  Ensure that all operations are conducted in a safe manner and in 12 accordance with the approved plan and established standards and 13 guidelines. 14  Verify qualifications of all assigned personnel. Conduct the personnel 15 /safety briefing to ensure a safe operation. 16  Conduct the test fire and document the results. 17  Supervise assigned personnel and direct the ignition, holding and 18 monitoring operations. The Prescribed Fire Burn Boss will be responsible 19 for implementation including mop-up and patrol unless otherwise assigned 20 to other qualified personnel. 21  Declare the prescribed fire out unless the responsibility for it is formally 22 passed to another Prescribed Fire Burn Boss, Prescribed Fire Manager or 23 the local fire management organization. 24  Determine when the prescribed fire is not within prescription parameters 25 (both short and long term) or is not meeting objectives. 26  Declare an escaped prescribed fire a wildfire (if responsibility is assigned 27 in the plan). 28  Manage the incident or oversee the transition to another Incident 29 Commander if an escape occurs. 30  Ensure that reports are completed. 31  Coordinate with adjacent landowners, cooperators and permittees as 32 designated in the Prescribed Fire Plan. 33 34 Fire Management Officer (FMO)/ Fire Program Manager 35 The Fire Management Officer (FMO)/Fire Program Manager is responsible to 36 the agency administrator for planning, implementing and monitoring of the 37 Prescribed Fire Program in accordance with policy and direction. The 38 FMO/Fire Program Manager is responsible to: 39  Ensure compliance with national, regional, tribal and local fire policy and 40 direction, as well as applicable state and local laws. 41  Ensure that Preparedness Level Restrictions are adhered to. At National 42 Preparedness Levels Four and Five, prescribed fire implementation is 43 restricted. See the National Interagency Mobilization Guide for details.

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1  Ensure that both the Prescribed Fire Plan Preparer and the Technical 2 Reviewer are qualified or qualified less currency at the level of complexity 3 or higher. 4  Ensure that trained and qualified personnel are available to participate in 5 the Prescribed Fire Program. 6  Assign the Prescribed Fire Burn Boss. 7  Ensure a Prescribed Fire Plan with written approval exists for each 8 prescribed fire project. 9  Review the Prescribed Fire Plan to assess the impact of the project on the 10 unit’s workload; include the project in the unit’s Annual Work Plan; assess 11 the unit’s ability to implement the project; and assess the need for 12 additional implementation resources. 13  Ensure that all prescribed fires are conducted in accordance with the 14 approved Prescribed Fire Plan and established standards and guidelines. 15  Declare an escaped prescribed fire a wildfire (if responsibility is assigned 16 in the plan). 17  Act as liaison/coordinator to the agency administrator, Prescribed Fire 18 Manager and/or Prescribed Fire Burn Boss, local dispatch office, other 19 units, other agencies, air quality authorities, news media, transportation 20 agencies, and safety officials. 21  Ensure that projects are reported through the local office and comply with 22 national reporting guidelines. 23  Ensure that fuels management projects and interagency support actions are 24 reported through the proper reporting systems. 25  Ensure that periodic reviews and inspections of the Prescribed Fire 26 Program are completed. 27  Update agency administrator on the progress of the prescribed fire (as 28 necessary). 29  Ensure that projects are monitored, evaluated and documented as a part of 30 the project file. 31 32 Prescribed Fire Manager (RXM1/RXM2) 33 The Prescribed Fire Manager is responsible for implementing and coordinating 34 assigned prescribed fire activities. A Prescribed Fire Manager may be assigned 35 during periods when multiple simultaneous prescribed fires are being conducted; 36 when multiple prescribed fires will be conducted within a short time frame; or 37 where there is complex interagency involvement. The Prescribed Fire Manager 38 is responsible to: 39  Review Prescribed Fire Plans prior to implementation. 40  Monitor all prescribed fire operations. 41  Ensure that all operations are conducted in a safe manner and in 42 accordance with the approved plan(s) and established standards and 43 guidelines.

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1  Act as coordinator/liaison between the burn organization(s) and other 2 offices, agencies, air quality authorities, news media, transportation 3 agencies, safety officials, and interested public. 4  Declare an escaped prescribed fire a wildfire (if responsibility is assigned 5 in the plan). 6  Obtain and interpret long-term weather information. 7  Brief the Burn Bosses and direct operational assignments according to 8 policies, priorities, and standards. 9  Set priorities for allocation of resources. 10  Ensure the completion of all required documentation including the 11 evaluation and documentation of accomplishments, fire behavior and fire 12 effects, operation procedures, and cost summaries. 13 Firing Boss (FIRB) 14 The Firing Boss reports to the Prescribed Fire Burn Boss and is responsible for 15 supervising and directing ground and/or aerial ignition operations according to 16 established standards in the Prescribed Fire Plan. The Firing Boss is responsible 17 to: 18  Review the Prescribed Fire Plan and the burn unit prior to implementation. 19  Brief personnel on project objectives and ignition operations. 20  Complete the test fire according to the ignition plan at the direction of the 21 Prescribed Fire Burn Boss. 22  Conduct ignition operations in a safe manner according to the ignition 23 plan. 24  Identify the impacts of ignition on the control and desired fire effects. 25  Coordinate ignition operations with the Holding Specialist. 26 27 Holding Specialist 28 The supervisory position in charge of the holding forces reports to the 29 Prescribed Fire Burn Boss. There is no specific NWCG approved prescribed 30 fire position for this function. This position is assigned by name and title using 31 PMS 310-1 mnemonics. Holding functions will be managed by personnel 32 qualified at the appropriate Incident Command System (ICS) wildland fire 33 operations standard and as required by the prescribed fire complexity, assigned 34 resources, and operational span of control. The Holding Specialist is 35 responsible to: 36  Review the Prescribed Fire Plan and the burn unit prior to implementation. 37  Brief holding personnel on project objectives and holding operations. 38  Conduct holding operations in a safe manner according to the holding plan. 39  Coordinate holding operations with the Firing Boss. 40  Confine the fire to a predetermined area, mop up, and patrol. 41  Maintain communication with Burn Boss on holding progress and/or 42 problems. 43  For some prescribed fires, there may be no holding requirements or the 44 holding duties are assumed by the Prescribed Fire Burn Boss. 45 2 17-10 Release Date: January 20082009 1 PRESCRIBED FIRE CHAPTER 17

1 Fire Effects Monitor (FEMO) 2 The Fire Effects Monitor (FEMO) is responsible for collecting the onsite 3 weather, fire behavior, and fire effects information needed to assess whether the 4 fire is achieving established resource management objectives. The FEMO is 5 responsible to: 6  Review the monitoring plan prior to implementation. 7  Monitor, obtain, and record weather data. 8  Monitor and record fire behavior data throughout the burn operations. 9  Recon the burn unit/area assigned. 10  Plot the burn area and perimeter on a map. 11  Monitor and record smoke management information. 12  Monitor first order fire effects. 13  Provide monitoring summary of the fire. 14  Provide fire behavior and weather information to burn personnel as 15 appropriate. 16 17 Helitorch Manager (HTMG) 18 The Helitorch Manager is responsible to manage the helitorch operation, 19 supervise the mixing operation, and provide technical assistance to the 20 Prescribed Fire Burn Boss/Ignition Specialist. The HTMG may also serve as 21 Helicopter Manager and Helitorch Manager or Helicopter Parking Tender (but 22 not both). 23 24 Plastic Sphere Dispenser Operator (PLDO) 25 The Plastic Sphere Dispenser Operator (PLDO) is responsible for the 26 preparation, operation, maintenance, and care of the dispenser. The PLDO 27 reports to the Ignition Specialist. 28 29 Helitorch Mixmaster (HTMM) 30 The Helitorch Mixmaster (HTMM) is responsible for supervising the 31 mixing/filling operations. The HTMM may also serve as Helitorch Manager or 32 Helicopter Manager. 33 34 Resource Specialist or Resource Advisor (READ) 35 The Resource Specialist/READ is responsible for ensuring the prescribed fire 36 project is planned and implemented in a manner supporting the unit’s resource 37 management goals and objectives. The Resource Specialist/READ is 38 responsible to the agency administrator. The Resource Specialist/READ is 39 responsible to: 40  Ensure resource management representation in the preparation of the 41 Prescribed Fire Plan. 42  Ensure a review of Prescribed Fire Plans is conducted before each plan is 43 submitted for approval. 44  Evaluate the prescribed fire project in terms of meeting objectives.

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1  Provide resource information and direction to the Prescribed Fire Burn 2 Boss. 3  Present information at briefings on resources, priorities, and issues of 4 concern. 5  Coordinate with adjacent landowners, cooperators and permittees as 6 designated in the Prescribed Fire plan or by the Burn Boss. 7 8 Amendments 9 There may be a need to make amendments to the Prescribed Fire Plan. These 10 are changes to the Prescribed Fire Plan that require an agency administrator 11 signature. When changes are necessary, plans must be amended to identify the 12 affected sections; the reason for the change(s); and have the changes clearly 13 identified. For amendments, the same standards for Prescribed Fire Plan 14 preparation, review, and approval apply. Common reasons for amending the 15 Prescribed Fire Plan may include: 16  Changes to objectives. 17  Changes to complexity. 18  Changes to fire behavior prescription parameters. 19  Changes to project area boundaries resulting in either an increase or 20 decrease in area. 21  Reduction in resource capabilities identified as required in the plan. 22  Major changes to ignition methods including ground ignition to aerial 23 ignition; aerial ignition to hand ignition; hand drip torch ignition to use of 24 terra torch ignition (includes ATV mounted ignition devices); and/or hand 25 ignition from roadways to hand ignition from boats or other watercraft. 26 27 To avoid having to amend the Prescribed Fire Plan, flexibility should be built 28 into the plan that will allow for a range of adjustments during the prescribed fire. 29 When building flexibility, the range of identified options must remain within the 30 scope of the Complexity Analysis. Examples of flexibility that can be built into 31 a prescribed fire plan: 32  The Prescribed Fire Plan may state that on burn day and subsequent days 33 of the prescribed fire, a mix of the number and kinds of hand crews and 34 engines may be modified as long as stated production capabilities are not 35 compromised. 36  As the prescribed fire progresses from ignition to holding to mop up and 37 patrol, specified capabilities and/or types of resources may be adjusted. If 38 these flexibilities are built into the Prescribed Fire Plan, there must be a 39 clear statement as to the work capability requirements of the resources at 40 the various stages of the prescribed fire. 41  Minor changes in burn unit boundaries to facilitate holding and/or ignition, 42 as long as the area in question has been in the NEPA document, requires 43 no change in holding or ignition resources and is within the project 44 boundaries.

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1  Additional resources may be assigned to the project without amending the 2 burn plan if the addition of these resources does not change the complexity 3 of the burn or require additional supervisory positions. These changes 4 must be documented in the daily briefing. 5 6 Safety 7 The Federal Wildland Fire Policy states that firefighter and public safety is first 8 priority. Prescribed Fire Plans and activities must reflect this commitment. 9 Every person involved in a prescribed fire is responsible for identifying safety 10 issues and concerns. It is the responsibility of each individual participating in 11 prescribed fire activities to notify immediate supervisor of any possible 12 misunderstanding of assigned tasks or safety concerns related to the assignment. 13 14 NWCG established Work/Rest Guidelines and span of control apply equally to 15 wildland and prescribed fire operations. The management of crew, overhead, 16 and support personnel rest to assure safe, productive fire operations is the 17 responsibility of all supervisory fire management personnel (refer to NWCG 18 Interagency Incident Business Management Handbook, PMS 902, NFES 3139). 19 20 Exposure to smoke during prescribed fire operations can be a significant safety 21 concern. Research has shown that exposure to smoke on prescribed fires, 22 especially in holding and ignition positions, often exceeds that on wildfire. At a 23 minimum, smoke exposure must be addressed in the Job Hazard Analysis (JHA) 24 and smoke management element. Public safety impacts from smoke should be 25 addressed in the Smoke Management and Air Quality Element as well as the 26 Public, Personnel Safety, and Medical Element. 27 28 Transportation and use of any product containing chemicals (drip torch fuel, 29 aviation gas, sphere dispensers, fusees, fuel thickener, etc.) must be in 30 compliance with the Occupational Safety and Health Administration’s (OSHA) 31 Hazard Communication Standard (29 CFR 1910.1200) and Department of 32 Transportation Regulations (49 CFR Part 171), and agency specific guidance. 33 Material Safety Data Sheets (MSDS) for hazardous materials used on projects 34 should be consulted in developing the JHA. 35 36 The SAFENET form and process is designed for reporting and correcting unsafe 37 situations and is applicable to prescribed fire applications. 38 39 The risk management process identified in the NWCG Incident Response Pocket 40 Guide (IRPG, PMS 410-1) helps ensure that critical factors and risks associated 41 with prescribed fire operations are considered during decision making. This 42 process should be applied to all prescribed fire planning and operations. 43 44 Consider using a Safety Officer on high complexity prescribed fires and others 45 where the complexity analysis shows the need or indicates a higher than normal 46 hazard. 2 Release Date: January 20082009 17-13 1 CHAPTER 17 PRESCRIBED FIRE

1 2 A qualified Safety Officer is defined as a currently qualified Safety Officer, at 3 any Type level (Types 1, 2 or Line), as defined by the NWCG, Wildland and 4 Prescribed Fire Qualification System Guide (PMS 310-1). 5 6 Prescribed Fire Plan 7 The Prescribed Fire Plan is the site-specific implementation document. It is a 8 legal document that provides the agency administrator the information needed to 9 approve the plan and the Prescribed Fire Burn Boss with all the information 10 needed to implement the prescribed fire. Prescribed fire projects must be 11 implemented in compliance with the written plan. 12 13 Prescribed Fire Plans will vary in their degree of detail. The size and 14 complexity of the prescribed fire project will determine the level of detail 15 required. The Prescribed Fire Plan Template (Appendix B of the Interagency 16 Prescribed Fire Planning and Implementation Procedures Reference Guide) 17 must be utilized. Each element must be addressed and then assembled in the 18 sequence identified in the template. Should an element not apply to a specific 19 prescribed fire plan, not applicable (N/A) may be utilized. Programmatic plans 20 for multiple units under like conditions may be appropriate. Additional 21 information may be added as appendices. 22 23 If an interagency mixed ownership Prescribed Fire Plan is being prepared, the 24 development of all appropriate elements within the plan will be conducted in an 25 interagency setting. Interagency agreements and Memorandums of 26 Understanding (MOU) and/or private land owner agreements are required to 27 implement prescribed fire on multiple ownerships. 28 29 Listed below are the planning explanations of each individual element required 30 as part of a complete Prescribed Fire Plan and implementation policy related to 31 the element. 32 33 Prescribed Fire Plan Elements 34 35 1. Signature Page 36 The following information must be included on the signature page: 37  Administrative unit name. 38  Prescribed Fire Unit (burn unit)/Project name. 39  At a minimum, three dated signatures are required: a Prescribed Fire Plan 40 Preparer, a Technical Reviewer, and an agency administrator. Additional 41 signatures may be included as required by the individual unit. 42  Final determined complexity rating(s). 43  If the plan needs to be amended, the signed and dated amendments must be 44 attached to the Prescribed Fire Plan (see Chapter 4 of the Interagency

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1 Prescribed Fire Planning and Implementation Procedures Reference 2 Guide). 3 4 2. GO/NO-GO Checklists 5  Agency Administrator Pre-Ignition Approval Checklist 6 The Agency Administrator’s Pre-Ignition Approval Checklist (Burn Plan 7 Template, Appendix B of the Interagency Prescribed Fire Planning and 8 Implementation Procedures Reference Guide) is required to be completed. 9 The Agency Administrator’s Pre-Ignition Approval Checklist evaluates 10 whether compliance requirements, Prescribed Fire Plan’s elements, and 11 internal and external notification(s) have been completed and expresses the 12 agency administrator’s intent to implement the Prescribed Fire Plan. The 13 checklist establishes the expiration date for the implementation of the 14 Prescribed Fire Plan. If ignition of the prescribed fire is not initiated prior 15 to expiration date determined by the agency administrator, a new approval 16 is required. An ‘acting’ agency administrator may sign the Agency 17 Administrator Pre-Ignition Approval Checklist if authority to do so has 18 been delegated. If the Prescribed Fire Plan is amended, a review and re- 19 validation of the Agency Administrator Pre-Ignition Approval Checklist 20 would be required and included in the Project File. 21  Prescribed Fire GO/NO-GO Checklist 22 Prior to all ignition operations, the assigned Prescribed Fire Burn Boss will 23 complete and sign the Prescribed Fire GO/NO-GO Checklist (Burn Plan 24 Template, Appendix B of the Interagency Prescribed Fire Planning and 25 Implementation Procedures Reference Guide). This checklist is a 26 minimum standard and agencies may elect to add questions and/or 27 approval signatures. For each day of active ignition on a prescribed fire, a 28 separate daily GO/NO-GO Checklist is required. 29 30 3. Complexity Analysis 31 Risk management is a foundation for all prescribed fire activities. Risks and 32 uncertainties relating to prescribed fire activities must be understood, analyzed, 33 communicated, and managed as they relate to the cost of either doing or not 34 doing an activity. At a minimum, those risks from the Complexity Analysis that 35 are rated high and can not be mitigated will be identified with a discussion of the 36 risks associated in the Summary Complexity Rating Rationale. This discussion 37 will also be included in the Complexity Analysis Summary page (Burn Plan 38 Template, Appendix B of the Interagency Prescribed Fire Planning and 39 Implementation Procedures Reference Guide). 40 41 The Prescribed Fire Complexity Rating must be completed utilizing the 42 Prescribed Fire Complexity Rating System Guide, NWCG, January, 2004 (or 43 current version). The purpose of the complexity rating process is to provide: 44  Assignment of a complexity rating of high, moderate, or low to the 45 prescribed fire.

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1  Management and implementation personnel a relative ranking as to the 2 overall complexity of a specific prescribed fire project. 3  A process that can be used to identify Prescribed Fire Plan elements or 4 characteristics that may pose special problems or concerns. 5  A process that identifies mitigation activities needed to reduce the 6 risk/hazard to the implementation personnel and public as well as 7 mitigating potential resource damage. 8  A preliminary rating will be completed early in the Prescribed Fire Plan 9 development stage. This will identify potential concerns that may be 10 mitigated during the plan preparation process. Once the Prescribed Fire 11 Plan is near completion, the final complexity rating is made. The final 12 complexity rating will be used as a basis for determining prescribed fire 13 organization, Prescribed Fire Burn Boss level, and mitigation measures. 14 15 The Summary Complexity Rating Rationale will clearly justify the summary 16 rating for prescribed fire organization and Prescribed Fire Burn Boss level. It 17 must also identify those risks from the Complexity Analysis that are rated high 18 and can not be mitigated and will provide a discussion of the risks associated. 19 The Complexity Analysis must be signed by the Prescribed Fire Plan Preparer 20 and the agency administrator and attached as an appendix to the Prescribed Fire 21 Plan. The Complexity Analysis Summary will be attached to the Prescribed Fire 22 Plan following the GO/NO-GO Checklists. 23 24 Separate prescriptions and/or burn organizations for different stages of 25 implementation may result in multiple Complexity Analyses and ratings. For 26 example, a plan may have separate prescriptions for spring and fall burning 27 which may require different organizations and constitute the need for additional 28 complexity analyses. 29 30 If a prescribed fire complexity changes which results in different Prescribed Fire 31 Burn Boss qualifications, a separate complexity analysis is required. For 32 example, for certain prescribed fires conducted over time, progressive or 33 sequential actions may reduce complexity, organization, and Prescribed Fire 34 Burn Boss qualifications (e.g. a large scale, high complexity prescribed fire has 35 been black-lined, portions burned and operations suspended for a period of time 36 then resumed to continue or finish the prescribed fire). In this case, a separate 37 Complexity Analysis will be developed to reflect the reduced complexity rating 38 and will be included in the appendix of the Prescribed Fire Plan. 39 40 4. Description of the Prescribed Fire Area 41 42 Physical Description 43 This section of the plan will describe the physical features of the prescribed fire 44 area.

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1  Location - Narrative description of the location of the prescribed fire 2 project including a legal description, UTM and/or latitude/longitude 3 (decimal degrees; NAD83 preferred), county, and state. 4  Size - Area, in acres, of the prescribed fire project with a breakdown by 5 prescribed fire unit and/or ownership if applicable. 6  Topography - Identify the upper and lower range of elevation, slope(s) – 7 maximum/minimum and average, and aspect(s) of the prescribed fire 8 project. 9  Project Boundary - The project boundary defines that area where fire will 10 be ignited and may be allowed to burn (some agencies previously called 11 this Maximum Management Area or Allowable Area). Describe the 12 physical, natural and/or human made boundaries (including multiple units) 13 of the prescribed fire project. This will be done through maps and may 14 include narratives. The entire prescribed fire project area must be analyzed 15 under NEPA. 16 17 Vegetation/Fuels Description 18 This is a description of current vegetation and fuels in the project area and 19 should discuss history including past environmental effects or land management 20 practices and how they have impacted the fuel characteristics. Identify any 21 reference material used. 22  Describe the structure and composition of the vegetation type(s) and fuel 23 characteristics. This description may include natural or activity fuels, total 24 fuel load (both live and dead) in tons/acre, dead fuel load by time-lag size 25 classes, live fuel load (woody/herbaceous), fuel bed depth, and vertical and 26 horizontal arrangement within the project boundary. 27  Describe the percent of the unit composed of each vegetative type and the 28 corresponding fuel model(s). 29  Identify conditions (fuels, slope, and aspect) in and adjacent to boundaries 30 that may be a potential threat for escaped fire. 31  Identify any abiotic conditions like airshed, climate, soils, etc. as 32 appropriate. 33 34 Description of Unique Features and Resources 35 List and discuss special features, hazards, regulations, issues, constraints, etc. 36 Examples may include: fences to protect, power poles, historical/cultural sites, 37 threatened and endangered species or habitat, etc. 38 39 Maps 40 Maps will be developed and included in the Prescribed Fire Plan. At a 41 minimum, the plan will include a vicinity and project map. The number of 42 maps, map size and scale, legend and level of detail should be appropriate for 43 the complexity of the project. All maps will include the standard mapping 44 elements: title, name of preparer(s), date, north arrow, scale, and legend.

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1  Vicinity Map - Shows prominent features including roads, streams, water 2 sources, towns, structures, and the proximity of the burn unit(s) to these 3 features. Transportation route(s) will be identified. Map scale will be such 4 that the burn units can be located on the ground and in sufficient detail to 5 guide implementation. 6  Project Map(s) - The project map(s) identify features in sufficient detail to 7 guide and assist in operational implementation of the prescribed fire. 8 Topographic, vegetative, or aerial photo maps should be used as the base 9 map. ICS map display symbols, identified in the Fireline Handbook PMS 10 410-1 will be used as appropriate. Examples of features that should be 11 included on the project map(s) are: project boundary, individual unit 12 boundaries, ownership, fireline locations, natural barriers, fuel model 13 locations, proposed ignition patterns and sequence, critical holding points, 14 hazards, safety zones, escape routes, helispots, areas of special concern, 15 smoke management issues (predicted plume dispersion, sensitive receptors, 16 etc), escaped fire contingency actions (primary and secondary control 17 lines, trigger points, etc), water sources, location of treatment monitoring 18 plots, etc., if these are significant in communicating project 19 implementation. 20 5. Goals and Objectives 21 A short summary description will be developed that identifies the purpose of the 22 prescribed fire and the resource management goals from the supporting L/RMPs 23 and/or NEPA documents. The summary will identify desired future conditions 24 of the prescribed fire project. This should be consistent with the appropriate 25 land management goals. Include a discussion of future Fire Regime Condition 26 Class (FRCC) post-treatment conditions if applicable. 27 28 Describe in clear, concise statements the specific measurable resource and fire 29 objectives for this prescribed fire. Objectives will be measurable and 30 quantifiable so prescription elements can be developed to meet those objectives 31 and the success of the project can be determined following implementation. 32 33 6. Funding 34 Identify the funding source(s) and estimated cost(s) of the prescribed fire. 35 Itemize by phase if desired. 36 37 7. Prescription 38 Prescription is defined as the measurable criteria that define a range of 39 conditions during which a prescribed fire may be ignited and held as a 40 prescribed fire. 41 42 The plan prescription will describe a range of low to high limits for the 43 environmental (weather, topography, fuels, etc.) and fire behavior (flame 44 lengths, rate of spread, spotting distance, etc.) parameters required to meet 45 Prescribed Fire Plan objectives while meeting smoke management and control

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1 objectives. Parameters are quantitative variables expressed as a range that result 2 in acceptable fire behavior and smoke management. 3 4 The range of prescribed fire behavior characteristics (outputs such as: flame 5 lengths, rates of spread, scorch heights, mortality, spotting, etc.) identified in the 6 plan will help determine the acceptable combination of environmental 7 parameters (inputs such as: weather, topography and fuels) under which the 8 prescribed fire can be conducted. In many cases, burning under the extremes of 9 all prescriptive parameters would not meet or possibly exceed the desired 10 prescribed fire behavior characteristics and are therefore out of prescription. 11 The Prescribed Fire Burn Boss must ensure that the prescriptive parameters and 12 fire behavior characteristics as identified in the Prescribed Fire Plan are not 13 exceeded. Empirical evidence (historical evidence or researched data) and 14 judgment may be utilized to identify or calibrate prescriptions. Weaknesses in 15 modeling can be overridden, but must be justified with empirical evidence 16 and/or verified actual fire behavior. 17 18 Separate prescriptions may be needed for multiple fuel model conditions to 19 address seasonal differences and/or types of ignition (black lining, aerial 20 ignition, etc). Separate prescriptions may result in multiple complexity ratings 21 and burn organizations. For example, a separate prescription is needed for 22 black-lining operations if conditions will be significantly different from the 23 primary prescription or if the holding resources differ from those identified for 24 ignition and holding phases. Separate prescriptions may result in the need to 25 identify multiple levels of management, organizational structures, 26 implementation measures, and pre-burn considerations. 27 28 Holding and contingency plans must be developed with the consideration of the 29 predicted fire behavior outside the project boundary(s). Fire behavior 30 characteristics for fuel models within the maximum spotting distance and/or 31 adjacent to the project boundaries must be considered and modeled using worst- 32 case fire behavior predictions. These predictions will be identified from fire 33 behavior model runs or empirical evidence of the hottest, driest, and windiest 34 prescription limits identified in the Prescribed Fire Plan, along with the most 35 extreme environmental conditions (slope, aspect) identified. 36 37 A short fire behavior narrative that summarizes the fire behavior identified in the 38 prescription and discusses how it will achieve the desired treatment objectives 39 may be included. 40 41 When used, fire behavior calculations must be developed using an appropriate 42 fire behavior modeling program. Include modeling and/or empirical evidence 43 documentation as an appendix or in the fire behavior narrative. 44 45 8. Scheduling

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1 Identify the general ignition time frame(s) (i.e. time of day, duration of ignition) 2 or season(s) and note any dates when the project may not be conducted. For 3 prescribed fires with multiple ignitions or burn days, list projected duration. 4 5 At National Preparedness Levels Four and Five, prescribed fire implementation 6 is restricted. See National Interagency Mobilization Guide for details. 7 8 9. Pre-burn Considerations 9 Describe on and off-site actions and considerations that need to be conducted 10 prior to implementation. Examples include clearances; line to be built; 11 preparation of critical holding points; snags to be felled or protected; equipment 12 to be pre-positioned; special features to be protected; warning signs to be placed; 13 weather recording; fuels condition sampling; monitoring needs; responsibility; 14 and timeframes. 15 16 Describe any fuel sampling and weather data that may need to be obtained (See 17 Element 14: Test Fire). This data should be taken at the project site. If this is 18 not possible, use the closest representative site. 19 20 The plan will include a list of organizations (including media) and individuals 21 that are to be notified prior to ignition, with information necessary to make the 22 contacts. Reasonable efforts will be made to notify adjacent land owners (or 23 their agents) and other potentially impacted publics. Attempts and/or actual 24 notifications will be documented with date and method and placed in the Project 25 File. 26 27 Identify in the burn plan the method and frequency for obtaining weather and 28 smoke management forecast(s). 29 30 Spot weather or local area forecasts are required prior to ignition, on all ignition 31 days and any days the fire is actively spreading. A copy of the forecast will be 32 included in the Project File. The Prescribed Fire Burn Boss or other person in 33 charge of mop-up and patrol will also obtain and review the spot weather or area 34 forecast to determine if mop up and patrol resources are adequate. 35 36 10. Briefing 37 All assigned personnel must be briefed at the beginning of each operational 38 period to ensure personnel safety considerations (including the JHA) and 39 prescribed fire objectives and operations are clearly defined and understood. 40 Briefing checklists are required to be included in the Prescribed Fire Plan and 41 will include the following elements: 42  Burn Organization and Assignments 43  Burn Objectives and Prescription 44  Description of the Prescribed Fire Area 45  Expected Weather & Fire Behavior

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1  Communications 2  Ignition Plan 3  Holding Plan 4  Contingency Plan and Assignments 5  Wildfire Conversion 6  Safety and Medical Plan 7 8 The briefing checklist should list briefing topics only, not re-state what is listed 9 in the Prescribed Fire Plan for that element. 10 11 The Prescribed Fire Burn Boss will ensure that any new personnel arriving to 12 the prescribed fire receives a briefing prior to assignment. 13 14 An Incident Action Plan (IAP) is optional, it is recommended for large multi- 15 day or high complexity prescribed fires. 16 17 If aerial ignition devices will be used, include an Aerial Ignition Briefing. 18 19 11. Organization & Equipment 20 The complexity of each prescribed fire determines the organization capabilities 21 needed to safely achieve the objectives specified in the Prescribed Fire Plan. 22 Specify the minimum required implementation organization to meet the 23 capabilities (line production rates, etc.) by position, equipment, and the supplies 24 needed for all phases of the prescribed fire until declared out. At a minimum, a 25 Prescribed Fire Burn Boss will be assigned to every prescribed fire. Positions 26 that may not be filled as collateral duty will be identified in the organization 27 chart of the Prescribed Fire Plan. 28 29 Standard ICS fire management principles for span of control and length of 30 assignments will be adhered to when developing burn implementation 31 organization(s) and used in managing prescribed fires. On prescribed fires with 32 large organizations, use the ICS organization and staffing commensurate with 33 the level of complexity. Consider the use of a Prescribed Fire Manager in 34 conducting multiple prescribed fires. 35 36 Before implementation (all phases) of the prescribed fire, documentation in the 37 form of an organization chart must be completed. Any changes to the 38 organization during implementation must be documented. Any changes that 39 reflect modification of the capabilities, equipment or supplies will require an 40 amendment. Different organizations may be identified for different phases of 41 implementation (i.e. holding v. mop-up and patrol, different ignition operations, 42 different prescriptions). 43

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1 Multiple prescriptions for one Prescribed Fire Plan are permissible and in some 2 cases required (Element 7). Multiple prescriptions may require identifying and 3 developing multiple organizations. 4 5 The Prescribed Fire Burn Boss is responsible for implementation including mop- 6 up and patrol until the responsibility is formally passed to a Prescribed Fire Burn 7 Boss, Prescribed Fire Manager or the local fire management organization. 8 9 12. Communication 10 Develop communications plan specific to the project’s implementation to 11 address safety and tactical resource management needs. Identify and assign 12 command, tactical, and air operations frequencies as needed. Also include any 13 required telephone numbers. Cover under an Incident Action Plan, if utilized. 14 15 13. Public & Personnel Safety, Medical 16 Describe provisions to be made for public and personnel safety. All personnel 17 who are within the active burn area are required to wear personal protective 18 equipment. Identify and analyze the safety hazards unique to the individual 19 prescribed fire project and specify personnel safety and emergency procedures. 20 Include safety hazards (including smoke exposure and impacts) and measures 21 taken to reduce those hazards. Specify emergency medical procedures, 22 evacuation methods, and emergency facilities to be used. A JHA is required for 23 each prescribed fire project and will be attached to the Prescribed Fire Plan as an 24 appendix. 25 14. Test Fire 26 Provisions for a test fire are required and results must be recorded. The test fire 27 must be ignited in a representative location and in an area that can be easily 28 controlled. The purpose of the test fire is to verify that the prescribed fire 29 behavior characteristics will meet management objectives and to verify 30 predicted smoke dispersion. In many applications, analysis of the initial 31 ignitions may provide adequate test fire results. On multiple-day projects, 32 evaluation of current active fire behavior, in lieu of a test fire, may provide a 33 comparative basis for continuing and must be documented. If in doubt however, 34 initiate a separate test fire and evaluate results. 35 36 Prior to ignition of both the test fire and ignition operations, compare the 37 Prescribed Fire Plan prescription elements, both individually and collectively, 38 against local area or spot weather forecasts, other predicted conditions, and the 39 actual conditions onsite (See element 9: Pre-Burn Considerations) to ensure that 40 predicted fire behavior will take place and/or weather parameters will not 41 change to the point of the burn going out of prescription. 42 43 15. Ignition Plan 44 Describe planned ignition operations including firing methods, devices, 45 techniques, sequences, patterns, and ignition staffing for single or multiple unit 46 operations. Maps showing proposed firing patterns may be included. If aerial 2 17-22 Release Date: January 20082009 1 PRESCRIBED FIRE CHAPTER 17

1 ignition (or other aerial operations) is planned, cover aviation operations, 2 organization, and safety within the Prescribed Fire Plan, Aerial Ignition Plan, or 3 in an agency specific Aviation Operating Plan (Refer to the Interagency 4 Helicopter Operations Guide, {NFES #1885} and the Interagency Aerial 5 Ignition Guide {NFES #1080}for more detailed information on this topic). 6 Multiple prescriptions and ignition operations (blackline, primary, aerial, etc.) 7 may require identifying and developing multiple ignition organizations. 8 9 16. Holding Plan 10 Describe general procedures to be used for operations to maintain the fire within 11 the project area and meet project objectives until the fire is declared out. This 12 may include mop-up and/or patrol procedures. Describe critical holding points 13 (if any) and mitigation actions. Critical holding points will be identified on the 14 project map. Describe minimum capabilities needed for all phases of 15 implementation (see Element 11: Organization and Equipment). If used, attach 16 or reference modeling outputs or worksheets (i.e. Fireline Handbook production 17 rates, BEHAVE, etc.) and/or documented empirical evidence to justify 18 minimum holding resources required. 19 20 Different organizations may be identified for different phases of implementation 21 (i.e. holding, mop-up and patrol, different ignition operations, different 22 prescriptions). Multiple prescriptions may require identifying multiple 23 complexity ratings and developing multiple holding organizations. 24 25 If onsite resources are insufficient to meet the prescribed fire plan objectives, 26 then the Burn Boss should implement the Contingency Plan or Wildfire 27 Conversion. 28 29 17. Contingency Plan 30 “…If the objectives are not being met the Contingency Plan, a required 31 component of the Prescribed Fire Burn Plan, is implemented. If the 32 Contingency Plan is successful at bringing the project back within the scope of 33 the Prescribed Fire Burn Plan the project continues. If contingency objectives 34 are not met the prescribed fire is converted to a wildfire and Extended Attack is 35 undertaken.” 36 Interagency Strategy for the Implementation of Federal Wildland Fire 37 Management Policy, June 20, 2003, page 12. 38 39 Contingency planning is intended for more than just a response to an escaped 40 fire. The contingency plan is the portion of the Prescribed Fire Plan that 41 considers possible but unlikely events and the contingency resources and actions 42 needed to mitigate those events. 43 44 Contingency planning is the determination of initial actions and additional 45 resources needed if the prescribed fire is not meeting, exceeds, or threatens to 46 exceed: 2 Release Date: January 20082009 17-23 1 CHAPTER 17 PRESCRIBED FIRE

1  Project or unit boundary 2  Objectives 3  Prescription parameters 4  Minimum implementation organization 5  Smoke impacts 6  Other Prescribed Fire Plan elements 7 8 The contingency plan will establish trigger points or limits that indicate when 9 additional holding resources and actions are needed. 10 11 Contingency planning includes the additional resources required, and the 12 maximum acceptable response time for those resources. Resource needs should 13 be based on fire behavior outputs tied to the worst case fire behavior scenario (as 14 modeled in Element 7: Prescription). Separate contingency plans may be 15 necessary and appropriate to address seasonal differences, types of ignitions or 16 phases of the burn implementation as described in the prescriptions and ignition 17 and holding plans developed for the burn. 18 19 Verify and document availability of identified contingency resources and 20 response time on day of implementation. If contingency resources availability 21 falls below plan levels, actions must be taken to secure operations until 22 identified contingency resources are replaced. 23 24 The same contingency resource can be identified for multiple prescribed fire 25 projects. When specific contingency resources are identified for more than one 26 prescribed fire, the local fire management organization(s) must evaluate and 27 document adequacy of all contingency resources within the area. This evaluation 28 must consider: 29  Local, current, and predicted fire danger 30  Local and regional wildland fire activities. 31 32 Once a contingency resource is committed to a specific wildland fire action 33 (wildfire, wildland fire use or prescribed fire), it can no longer be considered a 34 contingency resource for another prescribed fire project and a suitable 35 replacement contingency resource must be identified or the ignition halted. 36 37 The agency administrator will determine if and when they are to be notified that 38 contingency actions are being taken. 39 40 If the contingency actions are successful at bringing the project back within the 41 scope of the Prescribed Fire Plan, the project may continue. If contingency 42 actions are not successful by the end of the next burning period, then the 43 prescribed fire will be converted to a wildfire. 44 45 18. Wildfire Conversion

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1 The Prescribed Fire Plan will specify who has the authority to declare a wildfire. 2 A prescribed fire must be declared a wildfire by those identified in the plan 3 when that person(s) determines that the contingency actions have failed or are 4 likely to fail and cannot be mitigated by the end of the next burning period by 5 on-site holding forces and any listed contingency resources. In addition, an 6 escaped prescribed fire must be declared a wildfire when the fire has spread 7 outside the project boundary, or is likely to do so, and cannot be contained by 8 the end of the next burning period. A prescribed fire can be converted to a 9 wildfire for reasons other than an escape. 10 11 Describe the actions to be taken when a prescribed fire is declared a wildfire 12 (refer to Wildland Fire and Aviation Program Management and Operations 13 Guide {BIA--Blue Book} and Interagency Standards for Fire and Fire Aviation 14 [Red Book]). Description will include: 15  Wildfire declaration (by whom) 16  IC assignment 17  Notifications: dispatch, agency administrator, adjacent land owners, etc. 18  Extended attack actions and opportunities to aid in suppression efforts. 19  After a wildfire declaration, an escaped prescribed fire cannot be returned 20 to prescribed fire status. A WFSA will define appropriate future 21 management actions. 22 23 24 25 19. Smoke Management & Air Quality 26 Describe how the project will comply with local community, county, state, 27 tribal, and federal air quality regulations. Identify what permits, if any, need to 28 be obtained. Identify smoke sensitive areas including population centers, 29 recreation areas, hospitals, airports, transportation corridors, schools, non- 30 attainment areas, Class I air sheds, and restricted areas that may be impacted. 31 Include modeling outputs and mitigation strategies and techniques to reduce the 32 impacts of smoke production, if required by State Implementation Plans (SIPs) 33 and/or State or local regulations. Reference the Smoke Management Guide for 34 Prescribed and Wildland Fire 2001 Edition for other smoke management 35 planning suggestions and smoke management techniques for reducing or 36 redistributing emissions. 37 38 Special considerations must be taken to address smoke when the project is in a 39 non-attainment area for a National Ambient Air Quality Standards including 40 insuring compliance with SIP/TIP provisions and addressing Conformity. 41 Projects which will potentially impact Class I areas should address any efforts to 42 minimize smoke impacts on visibility. Comply with all local, state, tribal and 43 federal pre-burn and post-burn data reporting requirements. 44 45 20. Monitoring

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1 Prescribed fire monitoring is defined as the collection and analysis of repeated 2 observations or measurements to evaluate changes in condition and progress 3 toward meeting a management objective. Describe the monitoring that will be 4 required to ensure that Prescribed Fire Plan objectives are met. For the 5 prescribed fire, at a minimum specify the weather, fire behavior and fuels 6 information (forecast and observed) and smoke dispersal monitoring required 7 during all phases of the project and the procedures for acquiring it, including 8 who and when. 9 10 21. Post-burn Activities 11 Describe the post-burn activities that must be completed. This may include a 12 post-burn report, safety mitigation measures, and rehabilitation needs including 13 those as a result of pre-burn activities undertaken. 14 15 Appendices 16 Include all the required appendices. 17  Maps 18  Technical Review Checklist 19  Complexity Analysis 20  Job Hazard Analysis 21  Fire Behavior Modeling Documentation or Empirical Documentation 22 23 Project File 24 All prescribed fire project files will contain the following information. Agencies 25 and/or administrative units may require additional information. 26  Prescribed Fire Plan 27  Monitoring data including weather, fire behavior, fire effects and smoke 28 dispersal observations 29  Weather forecasts 30  Notifications 31  Documented prescribed fire organization(s) 32  Any agreements related to implementation 33  Multiple day GO/NO-GO checklist(s), if applicable 34  Re-validation of the Agency Administrator Pre-Ignition Approval 35 Checklist 36 37 Depending on the scope and complexity of the prescribed fire, optional 38 information and/or further documentation that may be included in the Project 39 File include: 40  After Action Review (see Chapter 8 of the Interagency Prescribed Fire 41 Planning and Implementation Procedures Reference Guide) 42  Incident Action Plans, Unit Logs 43  Press releases, etc 44  Implementation costs 45  Actual ignition patterns and sequences used 2 17-26 Release Date: January 20082009 1 PRESCRIBED FIRE CHAPTER 17

1  Smoke management information 2  Agency individual fire occurrence form 3  Detailed Post Burn Report 4  NEPA documentation 5  Permits 6 7 After Action Review (AAR) 8 Each operational shift on a prescribed fire should have an informal After Action 9 Review (AAR). Certain events or a culmination of events that may affect future 10 prescribed fire implementation and/or policy should be submitted via the Roll- 11 up documentation (Found at http://www.wildfirelessons.net). The questions to 12 answer in conducting an AAR are: 13  What did we set out to do (what was planned)? 14  What actually happened? 15  Why did it happen that way? 16  What should be sustained? What can be improved? 17 18 Escaped Fire Reviews 19 The agency administrator will be notified of an escaped fire. The agency 20 administrator is required to make the proper notifications. All prescribed fires 21 declared a wildfire will have an investigative review initiated by the agency 22 administrator. The level and scope of the review will be determined by policy 23 and procedures in Wildland Fire and Aviation Program Management and 24 Operations Guide (BIA--Blue Book) or Interagency Standards for Fire and Fire 25 Aviation (Red Book). 26 The goal of the escaped prescribed fire review process is to guide future 27 program actions by minimizing future resource damage and/or preventing future 28 escapes from occurring by gathering knowledge and insight for incorporation 29 into future resource management and prescribed fire planning. The objectives of 30 the review are to: 31  Determine if the Prescribed Fire Plan was adequate for the project and 32 complied with policy and guidance related to prescribe fire planning and 33 implementation. 34  Determine if the prescription, actions, and procedures set forth in the 35 Prescribed Fire Plan were followed. 36  Describe and document factual information pertaining to the review. 37  Determine if overall policy, guidance, and procedures relating to 38 prescribed fire operations are adequate. 39  Determine the level of awareness and the understanding of the personnel 40 involved, in regard to procedures and guidance. 41 42 At a minimum, the escaped fire review report will include the following 43 elements: 44  An analysis of seasonal severity, weather events, and on-site conditions 45 leading up to the wildfire declaration. 2 Release Date: January 20082009 17-27 1 CHAPTER 17 PRESCRIBED FIRE

1  An analysis of the actions taken leading up to the wildfire declaration for 2 consistency with the Prescribed Fire Plan. 3  An analysis of the Prescribed Fire Plan for consistency with policy. 4  An analysis of the prescribed fire prescription and associated 5 environmental parameters. 6  A review of the approving line officer’s qualifications, experience, and 7 involvement. 8  A review of the qualifications and experience of key personnel involved. 9  A summary of causal agents contributing to the wildfire declaration. 10 11 Document the incident, including all actions prior to and after the escape. Set up 12 a file that includes all pertinent information, i.e., the Prescribed Fire Plan; a 13 chronology of events including the prescribed fire report; unit logs and 14 individual statements; weather forecasts including any spot forecasts; weather 15 information taken on site and Remote Automated Weather Station (RAWS) and 16 National Fire Danger Rating System (NFDRS) data for the day of the escape 17 from the nearest station(s); photos; and all other pertinent information. Since all 18 prescribed fires are planned management actions, an escape may lead to a Tort 19 Claim and liability issues. Special attention to documentation is critical. 20 21 An independent review team is recommended for conducting escaped fire 22 reviews. The number of individuals assigned to the team and their functional 23 expertise should be commensurate with the scope and focus of the review. 24 Interagency participation is highly recommended for all prescribed fire reviews. 25

26  BLM - IM OF&A 2008 - 026 27  FWS - Fire Management Handbook 28  FS - FSM 5140 for direction 29  NPS - RM-18 30 31 Use of Pay Plan for Hazardous Fuel Reduction 32 Refer to the Department of the Interior (DOI) Pay Plan for Emergency Workers 33 for information regarding the use of emergency workers for hazardous fuel 34 reduction projects on Departmental lands. Refer to the Forest Service Pay Plan 35 for Emergency Workers for information regarding the use of emergency workers 36 for hazardous fuel reduction projects on Forest Service Lands.national forests.

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