Fire Consolidation as Creative Destruction? Trump's Proposed U.S. Wildland Fire Service

Secretarial Orders from the DOI and USDA were released on September 15th announcing steps they will take to implement Trump's Executive Order #14308 that mandated consolidation of all federal fire management programs. Issued last June, Trump demanded that this radical restructuring of federal fire programs be accomplished within 90 days--essentially, during peak wildfire season in the west! The DOI and USDA have been scrambling largely in secret to develop something that will appease Trump's desire for command and control. 

A New Agency, A New Acronym

Consolidating the fire programs of the DOI's National Park Service (NPS), U.S. Fish and Wildlife Service (USFWS), Bureau of Indian Affairs (BIA), and Bureau of Land Management (BLM), along with USDA's U.S. Forest Service (USFS) will take the form of a new entity, possibly a separate new agency within the DOI called the U.S. Wildland Fire Service (USWFS). The exact architecture of the USWFS has yet to be defined, and both Secretarial Orders were thin on details while making grandiose promises to lead a bold transformation of the federal wildfire system. Standardizing a few contract templates and administrative procedures were the most concrete examples of consolidation offered, representing low-hanging fruit that did not require much deep thought or heavy lifting. The USWFS remains more of a concept or work-in-progress that prompts more questions than were answered in both SOs.

Congressional Courage?

Trump followed up his fire consolidation EO with a budget request to Congress that would basically defund each agency's existing fire management program, and then use those budget cuts to fund the new USWFS. Remarkably, funding for the USWFS is not included in either the House or Senate's proposed Interior Appropriations bills. The absence of appropriations for the USWFS at first glance appears as a rebuke of Trump's fire consolidation scheme. Such defiance displayed from a normally obedient Congress has been extremely rare, almost nonexistent in the age of Trumpism. But bolstering their bravery was the fact that the budget figures provided by the USFS to Congress were so bad that they could not be trusted and were simply ignored. The fact remains that Trump's EO and the Secretaries' SOs are essentially unfunded mandates. One wonders how soon and how hard will Trump and his Cabinet lackeys be bullying the Interior Appropriations committees to fund the creation of the USWFS? 

Consolidation or Demolition?

Complicating the proposed consolidation is that the fire services are split between two departments. Trump's draft EO admits that moving the USFS fire program into the DOI would require Congressional legislative approval. But what would be the impact of stripping fire out of the USFS given that the majority of the agency's workforce, budget, and mission are connected in some way to its fire program? This dismembering would have a devastating impact on the USFS, and as the largest federal fire management organization, its effects would ripple through the whole wildland fire community. To even a casual observer, fire consolidation seems more like a demolition plan for the USFS. But maybe that was the point: punish the agency for its chronic mismanagement and stubborn refusal to change its policies or practices. There are very few friends of the Forest Service on Capitol Hill--everyone wants to see significant change in the agency--but there are a few key members of Congress from both parties who value the votes of their constituents who work for the USFS or economically depend on the agency and they do not want to see the USFS defunded or disbanded. 

Creative Destruction or Just Destruction?

There are also many people who desperately desire fundamental change in the USFS, have been frustrated by the agency's inability or unwillingness to reform itself, and believe that Congress taking away fire funding from the USFS and putting it in the hands of a new professionalized fire management agency offers a pathway to transformation. This proposed act of "creative destruction" has the mark of Trump's trademark impulsiveness with the strong scent of vengeance in line with his crusade to dismantle the administrative state. But the speed and scale of this radical restructuring of federal fire management and likely demise of the USFS was apparently too extreme for Congress to abide by. So instead, members of Congress have proposed a three-year GAO study to research the costs and effects of consolidating federal fire programs. That's a rational decision to look before they leap that doesn't negate the need for a great leap in federal fire management. 

Given that transfer of USFS programs from the USDA into the DOI requires Congressional approval and Trump is unwilling to engage in the messy process of passing legislation, preferring instead to rule by Presidential decree, The USDA merely goes through the motions of a plan for consolidation. The SO reads like a bureaucratic nothingburger, resembling one of those "mystery meat" sandwiches fed to wildland firefighters. Where's the beef? The bulk of the Secretary's memo can be described as strategically vague. It does not reveal what the USWFS is going to look like and what will it do, nor does it talk about what the USFS will be or do after its fire program is consolidated with DOI agencies. It feels like the USDA Secretary was whistling past the graveyard, going through the motions for the sake of appeasing Trump but not really investing much in the project or its purpose.

A Glimmer of Positive Reform

To its credit, however, two of the USDA Secretary's Orders do enjoy widespread support within the wildland fire community: his directive to modernize Personal Protective Equipment to ensure the long-term health and safety of wildland firefighters and collaborate with the Environmental Protection Agency to eliminate regulatory barriers to prescribe fire. Those two issues do not require consolidation with all other federal fire management agencies, and the USFS should begin implementing those directives immediately.

Consolidation or Coordination?

The DOI Secretary's Order is a much more developed response to Trump's EO. It begins by touting the coordination that is already occurring in the DOI through its Office of Wildland Fire (fun fact: the OWF used to include the word, Coordination, in its name), and the National Wildfire Coordinating Group (NWCG). The DOI Secretary could have also added NIFC (National Interagency Fire Center) and JFSP (Joint Fire Science Program) as additional examples of current interagency coordination and collaboration within the DOI. This begs the question: if the DOI moves forward on its own to consolidate its fire programs, how will future consolidation be different or better than the existing coordination that is occurring within the DOI through its Office of Wildland Fire, NIFC, NWCG, NICC, JFSP, and numerous others?

Consolidation as Unification

DOI Secretary Burgum made a clear distinction in his Secretarial Order between the words consolidation and "unification," and emphasized that the two were not synonymous. The SO was about unifying--not consolidating--DOI fire programs, and defined unification as the "strategic alignment of resources" that includes "consistent application of firefighting strategies" (italics original). Burgum's redefinition of the word consolidation was a deft form of defiance, a slick way of appeasing Trump without fully acquiescing to his impossible demand. Unification defined as strategic alignment implies that fire programs will be retained within separate DOI agencies, but how does this relate to the USWFS? There are fundamental differences in the land management missions and subsequent fire management strategies among the different DOI agencies. For example, the NPS's strategy of fire reintroduction to promote ecosystem restoration differs dramatically from the BLMs strategy of fire exclusion to protect resource extraction. If they all remain separate agencies how will their diverse strategies become "consistent," and if they become unified within the single agency of the USWFS, which mission and strategy will dominate and define it?

A Political Appointee as USWFS Fire Chief

Neither SO explains what the architecture or extent of authority of the USWFS will be, how it will operate in the field and how its workers will interact with other DOI agencies and employees, especially during wildfire responses. One thing that is clearly announced, however, is that a new "Fire Chief" will be appointed to lead the USWFS, and this Fire Chief will report directly to (or receive orders from) Secretary Burgum or his designee. Thus, another federal agency will be headed by a Trump political appointee. Given the track record of other Trump appointees, this does not engender a lot of confidence that this person to head the USWFS will be experienced, competent, or committed to the best interests of the wildland fire community, the American people, or their public lands. However, rumor has it that, at least for now, an experienced and capable fire manager from NIFC is first in line for the new USWFS Fire Chief position.

USWFS a Professionalized or Politicized Agency?

The DOI's SO declares that agency unification will come through "elevation and streamlining." Translated: power will be centralized and concentrated in the hands of political appointees at the highest levels of the Administration, and streamlining will come through cutting environmental regulations, agency budgets, and the wildland fire workforce. A short and steep chain of command from the highest levels of Trump's cabinet officials directly down to field personnel will be structured in a USWFS. How will this all unfold? Will a USWFS result in a professionalized fire management workforce that utilizes the best available fire ecology science and progressive fire policy, with its own chain of command that will enable fire managers to escape the grip of risk-averse, careerist line officers who only want to put fires out, never put fires in? Or will the USWFS become a politicized supersized suppression army that serves at the whim of Trump and his officials? 

Given Trump's repeated threats to withhold wildfire disaster relief funds from Blue states, would he also dare to withhold suppression resources, refusing to dispatch the USWFS to places like California? And if the USWFS becomes subject to Trump's intrusions in operations, will it spend its time doing performative firefighting such as turning the spigots of canals to release water from distant reservoirs instead of directly managing fire? Again, the nature of fire consolidation conceived as creation of a new agency, the USWFS, has yet to be fully defined or described. 

Consolidation Cutting Budgets and Workers

Trump's fire consolidation E.O. came on the heels of his Department of Government Efficiency (DOGE) slashing budgets and workforces to shrink the size of government. The DOGE dudes' downsizing debacle resulted in the termination or early retirement of hundreds of red-carded Forest Service employees who staff the "fire militia." It didn't take much to suspect that fire consolidation was another DOGE-driven downsizing scheme intended to further shrink the federal workforce and cut agency budgets. That is the belief held by the terminated USFS workers who got "DOGEd" last spring. And that is the fear of workers who managed to keep their jobs in fire management until now but stand to lose a lot if their program and budget are terminated, and their positions get transferred over to the USWFS. There is no guarantee that career fire workers will be transferred to the new agency. Some may lose their jobs, lose their pensions, or lose other benefits. Thus, the rank-and-file of the wildland fire workforce feels quite suspicious if not guarded about the proposed fire consolidation. The DOI and USDA Secretaries have their work cut out for them trying to convince their employees that the USWFS does not ultimately mean the elimination of jobs and ending of careers. But then the opposite could happen and the USWFS could launch a hiring spree with many excellent job candidates among the hundreds of displaced DOGE'd fire workers. Either way, change is coming but the nature and direction of this change is uncertain.

Hope vs Fear of Changes to Come

The wildland fire community is split between those who hold hope and those who have fear of the changes that fire consolidation and the creation of the USWFS will bring under the Trump administration. Fire consolidation as a concept has many positive changes as a possibility, but so far confidence is lacking that the Trump administration has the best interests of the wildland fire community or American people and their public lands in mind. Consolidation might be a good idea, but this is the wrong time and the worst administration to pull it off. The Secretarial Orders lacked clarity and vision, and their words seemed more about conciliation than consolidation--appeasing the audience of The One in a task to radically restructure fire management agencies and wildfire governance during peak wildfire season. 

The fact that fire consolidation was largely developed in secret, refusing to engage or even inform essential partners and stakeholders including the States and Tribes and even Congress is a major reveal that likely this whole exercise was an unserious gesture at solving the wildfire crisis. In the near term, the process for implementing the Secretarial Orders falls on the Deputy Secretary of DOI, Kate MacGregor, and the Assistant Secretary of Policy, Management, and Budget, Michael Boren. That does not instill much confidence that fire consolidation will lead to anything but further sabotage of government agencies' abilities to provide goods and services to the American people. It may in the end be little more than a made-for-TV spectacle of Trump posturing as a leader, reflecting his personal desires to be Incident Commander-in-Chief in the war on wildfire. The DOI Secretary pledges to finalize a plan on October 31st for consolidation or unification or strategic alignment or whatever he chooses to call the USWFS. Released on Halloween, the final question remains: will the plan for the USWFS be a trick or a treat? 

Afterthoughts

The idea of consolidating federal fire management is not a new idea. It's been discussed among ecologically-minded fire practitioners for many years who have been suffering under the thumb of risk-averse careers line officers who only agree to aggressive suppression, rarely permit prescribed burning, and never allow ecological fire use. The idea of having a separate agency with its own chain of command offered some hope for getting more good fire on the ground. So there are several good points and possibilities that favor fire consolidation, and it's understandable that some members of the wildland fire community have come out in favor of the concept. But while the concept of consolidation may be good, this proposal comes out at the wrong time--during peak western wildfire season!--and worst administration to implement it. 

From the very beginning Trump's fire consolidation decree was tainted by ill intentions to further downsize the federal workforce, cut agency budgets, and sabotage the ability of federal agencies to manage public lands with the best interests of the American people foremost in mind. So there are valid reasons that other members of the wildland fire community have fear that corruption and incompetency will plague the USWFS from its outset, leading to further chaos and catastrophes. There are arguments on both sides articulating hope and fear, and a healthy debate within the wildland fire community should proceed. Unfortunately, the fire community has been excluded while these executive and secretarial orders have been crafted largely in secret.

Congress has yet to appropriate any funds for establishing the USWFS, but with each step that the Administration invests more energy and issues more directives into the effort, federal fire consolidation seems more like a fait accompli. If fire consolidation cannot be stopped, then it must be steered in a direction that maximizes benefits and minimizes harms. The USFWFS cannot become exclusively a supersized all-suppression-all-the-time federal firefighting force. Nor can it become the plaything of Trump and his top officials commanding and controlling field operations in made-for-TV-ratings performative firefighting spectacles that will put crews needlessly in extra danger, as happened when Trump ordered the turning of spigots of canals from distant reservoirs to put out the L.A. firestorms last January.   

The wildland fire community writ large must demand that the USWFS be led by dedicated public servants who are competent and committed to managing public lands in the public's interest. And USWFS policies and practices must be based on truly modernizing fire management with the best available ecological fire science and progressive fire policies (e.g. the 2001 Federal Wildland Fire Management Policy2023 National Cohesive Wildland Fire Management Policy, and policy proposals in the Wildland Fire Mitigation and Management Commission's "On Fire" report). Secretary Burgum has directed the DOI to coordinate with the USFS to employ a "broad, formal process for soliciting input from key stakeholders" and that's exactly what should happen. Time for the wildland fire community at all levels from all entities to raise their voices and engage in the unfolding development of the USWFS. It's the best if only opportunity we will have to ensure that this act of creative destruction is potentially creative and not purely destructive.

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