County considers 11th hour changes to Community Wildfire Protection Plan

The Ravalli County Commissioners held a meeting last week to consider some last minute changes to the Community Wildfire Protection Plan (CWPP) that would involve expanding the Wildland Urban Interface (WUI) from what was delineated in the current Draft Plan.

“We have a Core Team that spent a lot of time developing this map,” said Commissioner Jeff Burrows. “Originally we had a WUI layer and an infrastructure layer which was considerably more extensive than what this layer is now. We decided to go away from that due to litigation out of Carbon County where a judge smacked the county for getting too extensive, saying you can’t just blanket your county in a WUI without justification and the Core Team went back to the Healthy Forest Restoration Act (HFRA) definition of a WUI. Then Steve Kimble from DNRC sent an email talking about modeling to project the probability of ignitions reaching private property that he had seen from the Forest Service and that is what we are considering today.”

Commissioner Greg Chilcott stated that in years past there was a lot of discussion, debate and concern about what it would do to fire insurance rates, but  it has been determined that a CWPP does not have any impact on insurance rates because insurance companies rate themselves.

“But we do have to comply with the court decision which says you can’t just take a gallon of paint and cover the area saying that’s now the CWPP,” said Chilcott.

Bitterroot National Forest District Ranger Steve Brown told the commissioners that what DNRC’s Steve Kimble saw was a mapping layer that was developed as part of the analysis that has been done as part of the Forest Service’s Bitterroot Front Project, a high priority fuels reduction project.  

“We utilized this information to identify where the areas are that we really need to focus on doing treatment,” said Brown. “Where are the high risk areas?” He said Kimble felt that it should be incorporated or at least looked at as part of the CWPP defining the WUI. “If the WUI wants to identify high risk structures, then this layer does a good job of doing that,” said Brown.

Brown said that the colored layers on the Forest Service map surrounding the HFRA defined WUI in the Draft CWPP Plan are delineated based on 50,000 simulations under multiple weather scenarios with each pixel being a fire start area, basically simulating that the fire escaped initial attack and under the definition of different weather scenarios, it shows how many times that fire grew to impact private structures. Different colors show different probabilities ranging from 50-60%, 60-70%, 70-80%, 80-90% and 90-100%.

 Burrows said that it would involve getting the contractor who designed the map in the Draft Plan to amend it, but the contractor was at the end of his contract so it could mean some additional cost.

County Forester Andrew Amidon said that changing the map was one thing but if they are changing the definition of the WUI based on new data, a revision of the whole document might be needed.

Burrows wondered if expanding to the blue line in the Forest Service map representing the area with a 50-60% chance of a fire reaching a structure would really require a full rewrite of the Draft Plan or if they could consider that in the future and just extend the existing buffer zone on the Draft Plan map.

Amidon said that extending the buffer zone, currently set at about a half mile out, to a mile or two or three would have to be justified by using a different data set to show that it is not just an arbitrary choice.

Commission Chair Dan Huls said that he thought it should be the blue layer because it was the most reasonable.

Amidon said that initially a similar analysis was done in the Draft Plan using the CWPP Guidebook and DNRC’s Montana Wildlife Risk Assessment. But the guidebook does say to use the most recent, most valuable data. 

“We had not seen this data before a week ago,” said Amidon. “If we had been able to use this data we would have put it through the process. So now my concern is we are at the end of the process and incorporating information based on new data.”

“I guess for one, the process isn’t over, right?” said Chilcott. “Until the decision is made, it’s in process and this, granted it is late in the game, but this seems like pretty valuable data. It doesn’t change a whole lot. We want to do the best we can and we also want to give our partner agencies, DNRC and the Forest Service, the most tools available. I think this helps them, putting more tools in the toolbox.”

Burrows said he hadn’t seen this data, “but when you see it and hear the rationale for it, then how could you not incorporate that into the CWPP?” 

Huls said, “I’m in agreement. I just think that you would be remiss in not using the latest data even though it came late in the game.”

“I think you need to use the most accurate data,” said Burrows. “I don’t know why the Forest Service wasn’t involved all along. We all know that fire coming out of the canyons is a concern and this gives DNRC and the Forest Service tools to work on that.”

Forest Service fire manager Mark Wilson said, “I think the Forest Service was involved, but people just didn’t understand what they were hearing. I know this probably was talked about but I don’t know that it was fully understood by all how it could be incorporated. I think it was an inclusive process, just not fully understood.”

Kristin Mortenson from DNRC said, “We are definitely supportive of incorporating different data into the process but I do want to point out that this process is supposed to be collaborative and it has been collaborative. We would like it to continue to be collaborative. This is a change at the 11th hour that we are not opposed to, but the Core Team should be handling this. Ideally we should be looking at this and figuring out what we would recommend to you.”

“I wasn’t aware of any timeline,” added Mortenson. “The door has been opened to addressing this and the door is still open, but I strongly believe that the Core Team should be aware of this. There will be public backlash to any expansion of the WUI, so there is a concern there. We do have members that don’t want to see any significant changes between the draft and what they expected to happen and the signature on the final document. I feel there is potential for a credibility issue if what they saw was an extended WUI. This should be a transparent process.”

Burrows said, “The only counter I would have to that is we’ve already had consensus on an expanded WUI. We are moving forward with that expanded WUI from the beginning. It wasn’t until that court ruling came out that we fully reversed gears. But that was the only problem I heard was that threat of litigation. I never heard anyone say that this is too expansive. The only objection I heard was that we don’t want to get litigated.”

Amidon disagreed, stating, “We did get a lot of feedback on that and we haven’t gone to public comment on this. I guarantee 100% that we will get feedback.”

Burrows said they need to talk to the contractor and see how changes might fit into the time frame because he would still like to keep this thing on track. “I think we need to shoot for the beginning of the year as close as we can, but we need to ask how much of the plan would need to be changed and how much can be incorporated in this WUI map. To be fair, maybe we should schedule a public meeting but I don’t see any of the public here.” He said if people have concerns they could have commented at this meeting and could comment at the next meeting scheduled for adoption on January 2nd. If you just assume that there will be no changes made at this meeting, I think that’s a dangerous assumption and there are zero public here to make comment today.”

Amidon stated that this wasn’t really a publicized meeting, it was just a meeting scheduled by commissioners. He said it was presented to the public as the final draft plan. This [new map] only came up in the last week.

District Ranger Steve Brown said, “To be fair, the same people who said they don’t want to see any changes also voted against the adoption of the CWP plan.”

“I think we need to reach out to the contractor and see what the revision entails and present it to the collaborative group before final adoption, but it’s a process and sometimes the data, we get it when we get it. I don’t want to say that it should come in by such and such a date,” said Chilcott. “I don’t think that’s a good process.” 

Huls wondered what it would do to the timeline and Burrows responded, saying, “It depends on the contractor. If we could schedule a Core Team meeting before the end of the year, we could see if there is any major objection to this and if the contractor says he can import this into the mapping layer and get that done then it just goes back to that question of how much more do we need to involve the public. Do we need to advertise that January 2nd meeting as a public comment meeting? We have a lot of meetings where people show up and we’ll make changes and adopt something at the same meeting. We could put it out there that we are reopening the public comment and to show up for the adoption of the amended plan.”

Amidon said that, given it’s the holiday season, a January 2nd meeting seemed unrealistic.

Burrows said, “I think it’s realistic for the public comment piece of it. Our requirement is 48 hours notice. If the contractor could change the maps we could put them on the web page and start advertising it. It’s already on the agenda and the public knows they can come to any one of our meetings and make public comment.”

Huls asked if the deadline could be extended and the County Administrator said that Tuesday the 16th was open. She also noted that there was no official timeline, but that the current County Forester would not be available after January 2nd. 

“At the end of the day we want to have the best product we can get and I would really like to do everything we can to meet that January 2nd time frame,” said Chilcott. “If we can’t, we can extend it, but I’d like to keep that on the table.”

All three commissioners agreed they were in favor of extending the WUI to cover the blue layer.

Chilcott asked if it was really going to give DNRC and the Forest Service more tools.

Mortensen said, “As long as it is scientifically justified. To put it in context, the initial reduction in the WUI was due to litigation concerning over-reach and that was the consideration. It should conform to HFRA as close as possible, but counties are allowed to determine their WUI however they want to, so this document is the County’s decision as to what you want your WUI to be delineated. But the projects that other agencies pursue using that WUI need to be scientifically justified to have good standing in court.”

“I think the comments I saw, whether you opposed or supported the WUI, were to use the best available science,” said Burrows. “And if what we’re hearing today is the best available science, then let’s put the cards on the table.” He said he hoped the contractor would say he can do it and will help to expedite it and that they can get it to the Core Team and tell them “there’s been a little bit of change.”

Brown said he would be glad to talk to them and explain the layers that he believes capture the risks, saying, “I believe it’s justifiable.”

Commissioner Huls said, “I believe it’s defensible.”

Over a dozen written comments were submitted to the Commissioners following their last meeting on the Draft Plan but none were discussed at the latest meeting.

Most of the comments submitted were critical of the buffer zone extending about a mile into national forest land which the commissioners are now considering expanding. Almost all the comments emphasized what they call the latest available science concerning the “Home Ignition Zone.” 

Most of the critics rely heavily on the work of Jack Cohen, a recently retired research scientist at the U.S.D.A. Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory in Missoula. In a 2020 article titled “Preventing Disaster – Home Ignitability in the Wildland-Urban Interface,” Cohen notes that “Wildland fire and home ignition research indicates that a home’s exterior and site characteristics significantly influence its ignitability and thus its chances for survival. Considering home and site characteristics when designing, building, siting, and maintaining a home can reduce W-UI fire losses.”

Cohen concludes, “The key to reducing W-UI home fire losses is to reduce home ignitability. SIAM modeling, crown fire experiments, and case studies indicate that a home’s structural characteristics and its immediate surroundings determine a home’s ignition potential in a W-UI fire. Using the model results as guidance with the concurrence of experiments and case studies, we can conclude that home ignitions are not likely unless flames and firebrand ignitions occur within 40 meters of the structure. This finding indicates that the spatial scale determining home ignitions corresponds more to specific home and community sites than to the landscape scales of wildland fire management. Thus, the W-UI fire loss problem primarily depends on the home and its immediate site.

“Because home ignitions depend on home ignitability, the behavior of wildland fires beyond the home or community site does not necessarily correspond to W-UI home fire loss potential. Homes with low ignitability can survive high- intensity wildland fires, whereas highly ignitable homes can be destroyed during lower-intensity fires.

“This conclusion has implications for identifying and mapping W-UI fire problem areas. Applying the term wildland-urban interface to fire losses might suggest that residential fire threat occurs according to a geographic location. In fact, the wildland fire threat to homes is not a function of where it happens related to wildlands, but rather to how it happens in terms of home ignitability. Therefore, to reliably map the potential for home losses during wildland fires, home ignitability must be the principal mapping characteristic.”

In September of 2016, just two months after the Roaring Lion Fire destroyed 16 homes in and on the edge of the Bitterroot National Forest, the Montana Department of Natural Resources and Conservation (DNRC) contracted Cohen to conduct an examination of the home destruction there.

He was charged with examining both the destroyed and surviving homes associated with the Roaring Lion Fire; identifying the fire behavior characteristics presented to each home; and determining, to the best of his ability, the mechanism of ignition at lost or damaged homes. DNRC also wanted to know how the Roaring Lion Fire experience related to previous research findings that home ignitions during extreme wildfires are primarily determined locally by a home’s ignition potential and the fire behavior in the immediate surroundings of the house.The post-fire examination of home destruction and survival along with the degree of burning vegetation immediately surrounding homes revealed that the causes of destruction were firebrand ignitions and flame contact from surface fires and not crown fires.

What Cohen found after an intensive study of the Roaring Lion Fire conforms to what he found in much broader research around the nation.

“Research and analyses of WU fires, of which the Roaring Lion Fire examination is a part, have shown that home ignitions during extreme wildfires are primarily determined locally by a home’s ignition characteristics in relation to the size and duration of flames within 100 feet of the home – the HIZ (Howard et al. 1973; Foote 1994; Cohen 2000a, b; Cohen and Stratton 2003; Cohen 2004; Cohen and Stratton 2008; Graham et al. 2012). Understanding how homes ignite along with the HIZ concept defines WU fire as a home ignition problem, not a wildfire problem; and thus, home ignition potential and WU fire can be addressed separately from wildfire.”

Some of the public comment submitted also questions the make-up of the Core Team that was established to advise the commissioners.

“Most have ties to the timber industry,” wrote Jeff Lonn. “Where are the wildfire scientists? There are several nationally known ones living in the area. Where are the interested citizens who live in the ‘WUI’? Where are the forest ecologists? CWPPs are required to include collaboration that ‘engages a broad diversity of stakeholders to ensure the CWPP reflects the best local knowledge, receives broad community buy-in, and accounts for ongoing and planned future projects’ (p.2). That diversity of stakeholders is sorely lacking in the CWPPs core team.”

Laura Jackson states, “The inclusion of the Lost Horse corridor and the Rye-Skalkaho cross road do not seem to fit under the name ‘Wildland URBAN Interface,’  nor could they be reasonably listed as ingress/egress essential routes.”

Richard Donovan notes that, “The executive summary references the notion of a living document but does not describe any process through which the CWPP is updated and/or reauthorized. The executive summary references the successful development of a comprehensive CWPP. The current draft of the CWPP is far from comprehensive and lacks very fundamental features that are required for it to be functional such as describing SMART (specific, measurable, achievable, relevant and time-bound) goals and objectives.”