Fire Management Requirements

This section presents the requirements that must be met before a wildland fire management program can be implemented. Requirements apply to all burns and can only be exempted by the Fire Management Coordinator. All exemptions of requirements must be requested and granted in writing. See also Fire Management Guidelines.

If you have an unusual situation which does not conform to any of the typical fire management scenarios in which TNC becomes involved, contact the Fire Management Coordinator for individual consideration of the circumstances.

There are nine Fire Management Requirements.

#1:	All wildfires, regardless of origin, must be reported to the appropriate fire control agency. Responsibility for a wildfire must be turned over to fire control authorities, unless a mutual aid or other cooperative agreements have been established in writing.

A wildfire is defined as a fire, regardless of ignition source, which is unplanned, has escaped control, or is not authorized under state law or local ordinances. Your Review of Laws and Regulations should list appropriate fire control authorities and explain the authorization process. Under no circumstances should TNC make the decision to allow a wildfire to run its course.

On large remote landscapes, naturally ignited fire may be an important means of accomplishing resource management goals. There may be instances where naturally ignited fires can be managed for benefit on TNC lands, as long as they are burning within a pre-approved fire use or prescribed fire plan. These fires are subject to all TNC guidelines and requirements. This is most likely to be appropriate when TNC owns land near or within a large federal landholding. State laws governing prescribed burning will determine whether naturally-ignited fires on private land can be managed to meet ecological management goals on our property. In almost all instances, arson-ignited fires can not be managed for resource benefit and must be suppressed.

It is important to recognize TNC's responsibilities on different types of wildfires. Naturally-ignited wildfires are generally considered "acts of God," and the landowner of the property where the fire starts is usually not held responsible for any damage the fire may do to a neighbor's property. However, if the fire is not immediately reported, it may be claimed that failure to report aggravated the damages.

#2:	A Review of Laws and Regulations must be completed before any prescribed burns are conducted on Nature Conservancy property or led by Conservancy Representatives on non-Conservancy property.

The purpose of the Review of Laws and Regulations is to investigate and understand all the laws and statutes controlling wildland fire practices in the state and county in which burns are conducted. The Review is meant to ensure that Conservancy Representatives adhere to all applicable laws and regulations when engaged in wildland fire activities. See Fire Planning for specific guidance on this requirement. Documentation that the review has been completed is made through confirmation in the Prescribed Burn Unit Plan.

#3:	All prescribed burns must be conducted according to a written approved plan. Broadcast burns must have a written approaved Prescribed Burn Unit Plan. Use of daily Incident Action Plan (IAP) is encouraged, but the IAP may not replace the use of a Prescribed Burn Unit Plan for a broadcast burn.

All Plans must be signed and dated by the preparer and by the Burn Boss before the burn is conducted. The signature of the Burn Boss signifies his/her approval and agreement to abide by its content in conducting the burn. Final approval for the Prescribed Burn Unit Plan is given by the designated Fire Manager for the site. Those approving the plan are responsible for its content.

The person who authors a Prescribed Burn Unit Plan cannot be the sole person to review it. If the Fire Manager is the author of the plan, it must receive a technical review by an RxB2 familiar in the fuel type. The Technical Reviewer does not have to be a Conservancy Burn Boss; staff from other agencies are acceptable as long as they are qualified as an RxB2. The Technical Reviewer must sign the signature page of the plan. The Fire Manager is still the final approver for the plan.

The Standard Prescribed Burn Unit Plan form is available here. The form may be customized, but it must contain the following burn plan elements:

• Signature Page
• Geographic location
• Sources of emergency assistance
• Description of the prescribed burn unit area (vegetation type and fuel models by percent of unit; narrative description of unit)
• Goals and objectives
• Fuel and weather prescription
• Desired fire behavior to meet objectives (narrative description)
• Smoke management
• Crew (number and organization)
• Equipment
• Day of burn operations (firebreak prep, ignition plan, holding plan, communications, mop-up standards, public relations)
• Contingency plan (predicted fire behavior for free-running fire, both inside and outside the unit; location, type and response time of emergency resources; secondary control lines)
• Backup source of water supply
• Safety and medical information
• Documentation (confirmation of required planning, consequence analysis, exemptions and justifications for any TNC guidelines)
• Consequence Analysis (Required for all plans after January 1, 2010)
• Go/No Go Checklist
• Post-burn activities
• Maps

The use of aviation resources, helicopters or other aircraft, on Conservancy burns must be included in the Prescribed Burn Unit Plan. Note of resources will be made in the crew organizational chart or text, and in day of burn operations plan element. Potential use of aircraft should be taken into account in burn plan complexity and consequence analysis. Go/No Go checklists must be appended to include briefings for both ground and air safety (e.g. Interagency Aviation User Pocket Guide, NFES 1373).

Non-broadcast burning includes activities such as burning brush piles, old structures and spot burning invasives. All non-broadcast burns must meet state and local regulations and burn permit requirements. All non-broadcast burns must have a plan and a Consequence Analysis must be conducted as part of Fire Manager review and approval of plans. Plan formats vary considerably. See the Guidelines #3 for more details. All burns must be preceded by completion of the Non-broadcast Burn Go/No-go Checklist.

An approved burn plan is in effect for five years, or until conditions stated within the plan have changed. All burns must be conducted according to the parameters outlined in the approved plan. In rare instances, there may be justification for minor modifications in the field on the day of the burn. The Burn Boss and the Fire Manager must come to an agreement in advance on what changes may be made to a burn unit plan on the day of burn and whether or not the Fire Manager needs to be consulted. All changes made to a plan by a Burn Boss must be documented and justified in writing either on the plan or on the pre-burn checklist.

#4:	Only qualified personnel may participate in wildland fire management for the Conservancy. All wildland fire personnel must maintain written documentation of their training, experience and performance qualifications.

All individuals participating in wildland fire activities for the Conservancy must be at least 18 years of age and meet stated qualification criteria. All personnel must maintain documentation related to their training and experience, including copies of their training certificates, a log of their fire experience, and completed task books. When an individual is designated as a TNC Burn Boss, a copy of the signed letter of designation, along with copies of all certificates, logs, and task books should be sent to the Fire Management Coordinator for archiving. Further logs should then be kept by the individual.

See Personnel for complete information on qualification standards, training and other administrative issues related to personnel.

#5:

All fire management personnel actively involved on a burn must wear Nomex clothing, hard hat, leather gloves, fire/heat resistant boots, and eye protection. Personnel should be trained in the uses, advantages and drawbacks of their personal safety equipment. A first aid kit must be available on all burns. See Prescribed Burn Guidelines regarding fire shelters and headlamps.

A number of different boot types may meet this requirement, including those with leather or leather/kevlar uppers and soles made of some heat-resistant material such as Vibram. In some instances, such as when burning wetlands, fire-resistant rubber boots are permissible. This should be noted in the Prescribed Burn Unit Plan.

#6:	All fire management personnel actively involved on a burn must be screened annually for physical fitness. All personnel must take part in annual fireline safety refresher training.

It is the responsibility of the Burn Boss and Fire Manager to screen staff and volunteers annually for physical fitness using accepted testing methods. The Conservancy standard for wildland fire is moderate, however the Fire Manager may require a fitness level of arduous on specific burns or sites, depending on factors such as topography, fuels, or climate. The arduous fitness level may also be required for personnel in Interagency wildland fire positions or assignments with other organizations. See Physical Fitness Testing for a full discussion.

All Conservancy fire management personnel must attend an annual safety refresher. It is the responsibility of the Fire Manager and Burn Boss to be sure this refresher takes place and that all personnel participating in fire management have attended. See Annual Safety Refresher Guidelines for specific instructions.

#7:

All incidents on burns must be reported by phone as soon as possible, typically within 12-24 hours or less, to the Fire Manager, Fire Management Coordinator, program or project director, and assigned TNC attorney. A written report must be filed within four weeks of the incident, unless directed otherwise by the Fire Management Coordinator or TNC attorney.

A review must take place following any injury requiring professional medical attention. The extent of the review is dependent on the seriousness of the events and partners involved in the burn. It must be sufficient to identify the cause of the injury and whether steps must be taken to correct training or equipment procedures to prevent a similar accident from occurring.

Incidents include:

• escapes that require outside suppression assistance
• escapes or spot-overs that leave managed property
• any burn with estimated property or equipment damage greater than $5,000
• any burn with an injury requiring professional medical attention
• any burn where smoke damages could potentially result in an insurance claim

See Fire incident Response Protocol (Intranet) for guidance on dealing with Serious Incidents. Examples of Serious Incidents include: an injury resulting in admission to a hospital for something more than observation; suspected fatality; Fire Shelter deployment; property damage and/or operating loss initially estimated at $50,000 or more (damage value may be difficult to determine at the scene); situations which may receive significant negative attention by the public or media.

#8:	At the end of each fiscal year, each state is required to submit an Annual Fire Management Summary to the Fire Management Coordinator for insurance reporting and tracking purposes.

This summary must list each individual fire by preserve or site, date of fire, name of the Burn Boss, name of the burn unit, size, type, and location (rural vs. urban) of the fire. Summaries should include all prescribed burns (broadcast and non-broadcast) conducted on TNC-owned lands or burns conducted by TNC on lands of others, and all wildfires occurring on TNC-owned lands. This information is essential for tracking, planning, and training purposes, and is required by our insurance carrier to determine our premium for smoke insurance. A reporting spreadsheet is emailed to each program for the fiscal year that ends June 30 of each year.

Before burning on third-party land, our insurance carrier requires that we, at minimum, obtain in writing both permission to enter the property and permission to burn it. This must be accompanied by a map defining the burn unit boundaries. This written permission may take the form of a document signed by the landowner, or it may be included in an MOU or other management agreement developed with a government entity. It is often advisable to seek other waivers of liability. See the Administration for Special Situations section of this Manual and the Intranet Fire Manual (Special Situations, Section-A) for more information on burning on non-TNC land, and permission to burn forms and waivers on the Intranet Fire Management Legal Resource page.

Last updated May 20, 2011.