Biography

My name is Frank Carroll. I'm a wildfire consultant and a veteran of the Forest Service. For the last decade or so I've been deeply engaged in wildfire policy, and in looking at the overarching picture of wildfire management, forest management, and active management in the United States on both public and private lands.

I've concluded that there needs to be a dramatic change at the top of the of the Forest Service that includes a new Chief and new principal officers and the national leadership team, because there are three immediate reforms that are necessary, and those reforms need to happen within the next 24 months.

The Forest Service and its wildfire management policies aimed at sustainable outputs and outcomes in perpetuity -- meaning living, functional forests -- have been replaced by alternate fire suppression strategies, like "monitoring," which means "let burn."

The new leaders must quickly pivot to a regulated, transparent, and accountable fire suppression policy that prioritizes public safety, agency accountability, and environmental protection. There is currently no legal basis for intentional wildfire use, and no adequate or comprehensive effort to document and disclose cumulative effects.

Alternative arrangements from CEQ [Council on Environmental Quality] have now fallen away, along with the [1984] Chevron Deference -- both of which provided cover for current policies previously, and now they have no effect in law.

The second reform is in the fire suppression methods that we need to reconsider, Common fire retardant chemistries pose, environmental and health concerns due to their compositions, which contribute to nutrient pollution, threaten water quality, inhibit plant growth, and pose potential risks to the public and firefighters.

Phosphorus and magnesium chloride are famously ill-suited to use the safe, as effective ground and aerial retardants. Continuing lawsuits over the past 15 years increasingly threaten the viability of what should be one of our most effective suppression and prevention tools.

The Environmental Protection Agency's "safer choice" program has identified newchemistries that are more effective and much safer, and that require less handling and maintenance than current products. They can be sprayed or dropped in advance and work bone dry until washed away in fall rains.

The third reform I think we need to emphasize in the relatively short time that the Administration may have to make real change, is that an otherwise promising agency contracting system called VIPR, the "Virtual Incident Procurement" system has been preempted and neutralized.

The agency organization in charge of VIPR insists on forcing a potentially effective computer-based system that would quickly order equipment and services for emergencies, into a 1960s-style review and authorization maze of old school, Soviet-style bureaucracy.

Urgent reform of the incident management system for wildfire response is needed by separating emergency and non-emergency operations, promoting district level contracting, and increasing efficiency through proactive planning and resource management within the next 24 months.