Project Activity Level

The Sale Activity Level (SAL) system has been utilized to regulate industrial fire precautions on Region 5 projects since the early 1980’s. Prior to the implementation of SAL, the Burning Index (BI) from the 1972 version of National Fire Danger Rating System was utilized in the administration of timber sales and public works administration contracts, and prior to that, the Fire Load Index from (FLI) the California Wildland Fire Danger Rating System was the guiding factor for the regulation of industrial operations.

SAL used a limited set of factors, a manually weighed 10-hour fuel stick, and a 10 minute average wind speed measured 20 feet above the vegetation, and one of two fire precaution matrices based on groups of fuel models. A manager would determine the fire precautions for a particular day by locating the predicted wind speed and fuel stick readings in the matrix for a given fuel model which could represent a single project or a large geographic area. The matrix was broken into 5 classes for which instructions were written guiding restrictions and fire precaution activities within each class.

There are several deficiencies associated with SAL. First, the 10-hour fuel stick and wind speed are more subject to daily weather variations and are more difficult to predict in complex terrain. Second, the SAL matrix has proved incapable for evaluating the effects of extended drought or seasonality. Drought reduces fuel moistures resulting in increasing available fuel. The fuel loading helps define how the fire will behave and its ability to grow. Live fuel moisture and larger woody fuel moistures generally decline as the fire season progresses into late summer and early fall. Forest’s fuel structure has also changed as a consequence of fire exclusion practices and changing climate. Fuel loadings have increased and fuels have become spatially arranged such that they foster greater fire intensity and severity, resulting in an increased potential for large, costly, damaging fires. Lastly, equipment used to operate around smaller size trees, such as “hot saws” and masticators, have a greater propensity to ignite fires.

The Crystal Fire of 1994 on the Tahoe National Forest was started by masticating equipment and consumed over 7300 acres as it advanced toward the community of Verdi along the I-80 corridor near Reno, Nevada. The fire cost over $4 million to suppress and resulted in forest and other resource value loses of $33 million dollars. Litigation over the recovery of a portion of the suppression costs revealed that there were some weaknesses associated with SAL. As a result of this event and issues raised on a number of other National Forests, a team of specialists was convened to assess alternatives to SAL. The present Project Activity Level (PAL) process is the culmination of these efforts.

PAL has the advantage of using a scientifically based fire danger rating system that calculates indices and components using weather data from remote automatic weathers stations and danger rating algorithms. The National Fire Danger Rating System (NFDRS) system has been thoroughly tested and provides for reliable results. The NFDRS process is described in greater detail in "What is NFDRS?".

PAL uses the National Fire Danger Rating System (NFDRS) Energy Release Component (ERC) and Ignition Component (IC) in a matrix structure to compute the PAL values. The matrix has undergone a number of enhancements as a result of field input.

The National Fire Danger Rating System (NFDRS) is a scientifically based process that integrates the effects of existing and expected states of selected fire danger factors into one or more qualitative or numerical indicators of an area's wildland fire management workload. The climatology-based system considers the current and antecedent weather, how the weather has affected the fuels, and topography. NFDRS provides a modern system to use for making rational and defensible activity level determinations.

Features of the total system include:

• Data is collected from the Remote Area Weather Stations (RAWS) network via satellite telemetry and data can always be accessed from the danger rating processor (WIMS) when individuals aren’t available to take readings. This automation corrects for the past loss of data when individuals have been unavailable to collect the weather data on a particular day. Reliance on the collection of the manual data by individuals who can make errors in reading, calculating and reporting is reduced.
• The Ignition Component (IC) and Energy Release Components (ERC) from NFDRS are acknowledged as more accurate indicators and factors for fire risk determinations. The IC has a wind component and the ERC is a fuels component independent of the wind component, so it holds steady. These components use trends in fuel moisture instead of spot indicators so they are more stable and do not give the drastic up and downs that the fuel stick and wind do under the current system.
• The IC and ERC are standard NFDRS outputs available from with the Weather Information Management System (WIMS) and are utilized in daily fire management decision processes.
• Records are readily accessed, application is more consistent, and the potential for human error is reduced.

The PAL process was designed with the intent of managing industrial fire precaution measures on a landscape scale, with the Fire Danger Rating Area(s) (FDRA) being the common denominator. The number of weather stations located within a FDRA may range from one to several; using all available stations within the fire danger rating area is the preferred approach. The Forests may choose to aggregate the weather stations within several Fire Danger Rating Areas to streamline their local process after appropriate analysis. Managing the PAL using a “weather station to project” relationship does remain an option to the Forests; however it is not the preferred approach.

Each Forest’s management philosophy and operational procedures with respect to the Project Activity Level will be fully explained in the appropriate section of their Fire Management Plan. The Regional Predictive Service units located at the North Zone and South Zone Geographic Coordinating Centers (GACC’s) can provide help in validating the proper location of weather stations. They are also available for consultation and interpretation of historic weather and NFDRS component responses and the validation of Special Interest Groups (SIG). The definition and explanation of the development of a weather station Special Interest Group (SIG) may found in “What is SIG?”

Following are the basic steps that a Forest should follow to evaluate and select the fire danger rating area(s), or weather station(s) for a project area.

• Review weather station locations and fire danger rating areas on the Forest. This information should be documented in the Fire Danger Rating Operating Plan and or the Fire Management Plan. It is important to understand what weather stations are in each fire danger rating area, and how the fire danger rating areas relate to the various portions of the Forest. An understanding of how PAL values relate to traditional percentiles in each fire danger rating area and the thresholds utilized in the Pocket Card is also valuable.
• Review the PAL seasonal climatology for each of the weather station on the Forest to understand the expected frequency of occurrence of the different PAL levels across the Forest. This information has been provided to the Forests several times over the past several years. Copies are available from the North Ops Predictive Service Unit.
• Evaluate the three typical scenarios for issuing PAL values on a daily basis; (1) by fire danger rating area, (2) by a group of fire danger rating areas, and (3) by individual weather station using the seasonal PAL climatologies. Are the station climatologies similar within each of the fire danger rating areas? Are there significant differences when comparing stations over the same period of time? What might be causing this? Discuss your concerns with the Predictive Services Units.
• Select the most preferred option from a Forest perspective for issuing daily PAL values. PAL was designed to operate on a landscape (fire danger rating area) scale and this approach or the grouped fire danger rating areas approach should blend best with the existing daily fire danger rating based decisions already made at the Forest level.
• Generate the PAL days per month for each individual weather station and for the approach the Forest selected to issue PAL values on a daily basis. The steps in the analysis process using Fire Family Plus and the PAL days per month spreadsheet are outlined in the “PAL Analysis- How to” document.
• Review the monthly PAL day trends and compare the stations to each other and to the Forest’s selected approach to issuing the daily PAL values. Do the relationships still seem to be logical? No significant differences that cannot be explained? The Predictive Service Units at North Ops and South Ops can provide advice and counsel at this point.
• Establish the necessary Special Interest Groups (SIGs) in the Weather Information Management Systems (WIMS) to deal with PAL. See the information on the CD that was provided to each Forest at the July 2003 BOD meeting. (This will only be necessary if the Forest is using a different group of stations for PAL values verses what it uses for daily fire danger rating based fire management decisions.)
• Utilize the functionality of WIMS to compare the Observed PAL values to the Forecast PAL values as generated by the National Fire Danger rating System (NFDRS) processor for the 2005 season using the capabilities of a spreadsheet. The review should look at May through the period of time the National Weather Service was providing forecast (early November). Is there a good relationship between what was forecast and what actually happened? If consistent anomalies are present, they need to be reviewed and discussed with the Predictive Service Units to better understand what may be going on. Are the anomalies forecast issues, station issues, management of the model in WIMS issues?

The group(s) of weather stations may contain Forest Service as well as other agency’s weather stations within the same fire danger rating area. The key is that they meet NFDRS weather station location and operational standards. This guidance is provided in the Weather Station Handbook an Interagency Guide for Wildland Managers (PMS-426-2) and NWCG National Fire Danger Rating System Weather Station Standards (PMS 426-3).

SIG (a special interest group) is the term used in the fire danger rating arena to identify a number of stations that have been grouped together for a specific purpose, such as creating industrial fire precautions levels or dispatch response levels. Simply stated, a SIG is a tool, which helps fire managers process operational and historic weather observations for NFDRS purposes in an efficient manner.

In the PAL process, a SIG will be the group of stations utilized by the Forests to represent each of the specific landscapes (areas) that they have delineated for the purposes of managing the project activity level. The individual SIG will then facilitate the calculation of the current day’s PAL value and the forecast PAL value for the next day.

The SIG name is unique to the individual process and area for which it is being utilized.

A SIG must be created in the Weather Information Management System (WIMS) to generate a PAL value. Even if the PAL is determined off data from one station a SIG must be created. The Display Average (DAVG) function in WIMS is where the PAL value is generated. You must have a SIG for DAVG. The Edit Average (EAVG) function allows the users to set fuel model and weighting for the SIG. All fuel models in a SIG must be identical for the DAVG to generate IC and ERC, which drive the PAL matrix. Without a SIG set up for fuel model G no PAL will be generated. Meteorologists, NFDRS, WIMS, and RAWS Subject Matter Experts in the North Ops and South Ops Predictive Service Units are available to provide technical support.

The Forest Service has over 140 automated fire weather stations (RAWS) in California. Cooperating agencies such as the BLM, NPS, BIA, FWS and several counties also have extensive weather station networks that can be utilized in the generation of daily PAL values. There should be very few instances where a Forest has a need to establish additional RAWS to support the PAL process.

Forests should review their existing weather station network for strategic gaps as part of the PAL implementation process (see How does a unit select a process for generating PAL values for a unit or project area?).

The assessment of the needs for a new station(s) should be completed during project planning (NEPA) stages or during the development of a fire danger rating operating plan (FSM 5120.45).

Short term mitigating actions could include the establishment of a temporary weather station(s) if there is truly a need, or the use of non-tradition weather data sources.

Meteorologists, NFDRS, WIMS, and RAWS Subject Matter Experts in the North Ops and South Ops Predictive Service Units are available to provide technical analysis and support if a Forest establishes the need for an additional RAWS. “Loaner” RAWS may be available for site evaluations.

The historical occurrence of PAL values by month for a fire danger rating area, a group of fire danger rating area(s) station or individual stations can be determined using the historical weather observations for the site(s) stored in the National Interagency Fire Management Integrated Database (NIFMID) and recent operational outputs available in WIMS. The FireFamily Plus program and an Excel spreadsheet are utilized in the analysis. The FireFamily Plus is a suite of Windows-based computer programs that combine fire climatology and fire occurrence data and provide several analysis capabilities.

Technical support is available from NFDRS Subject Matter Experts in the Predicative Services Unit at North Ops.

FireFamily Plus training should be provided to those who have not completed the S-491 training, where skills using this software are typically developed.

The Region has conducted several field visits to projects operating under the new PAL provisions. A team of specialists representing Fire, Fuels and Aviation Management; Forest Management and Acquisition programs; and an industry representative has conducted onsite reviews to determine the operational and cost effectiveness of PAL. In addition to doing the field visits, the Region sent out a query to all Forests who have implemented the new PAL provisions seeking their assessment of how well PAL provisions and its implementation are functioning.

The variance concept was developed to provide industry with an “opportunity to operate” once conditions reached the “shutdown threshold” (a PAL value of “E”) provided site specific mitigation measures were in place and external risk factors were “acceptable”. It is an effort to balance the risk and consequences of a large fire with the need to get work done to meet other resource management objectives at specific sites.

The variance process provides the local line officer discretion to manage industrial operations to minimize fire risk for those activities that are normally restricted by contract provisions and determine the fire precautions listed in the fire plan or Emergency Precautions stated in C7.22. This level was named “Ev”. It was later expanded to include the B, C, and D levels of PAL. A variance may be enacted when appropriate criteria are met and mitigations are in place. The Contracting Officer/FSR, in consultation with the assigned Line Officer and Fire Management Officer, may authorize continued specified operations when variance requirements have been fulfilled for an assigned site. Variances may be developed for Activity Levels A through Ev (1300 hours). A Project Activity Level Variance checklist has been designed to lead a local manager and Contracting Officer/FSR through areas of consideration as they prepare a variance and associated mitigations.

The Regional Forester’s 2430/5100/6320 letter of Project Activity Level (PAL) implementation and monitoring enabled contractors to continue to operate at the Ev level without further discussions with the agency, provided the minimum contract requirements for specific equipment, and any additional mitigation actions specified by the Forest were in place. This means that the variance mitigations will need to be well thought out during project development and included in the contract, C7.22#. The Agency now must communicate to the contractor if they are not going to be allowed to continue to operate once the Ev level is reached. Situational awareness on the part of the District Ranger, Fire Management Officer and Contracting Officer/FSR is critical.

The variance checklist will provide a baseline for mitigation actions, but site specific analysis should be conducted during the project planning phase to determine actual fuel conditions, response times for fire suppression resources and other specific site and operational information that would affect variance procedures.

The District Ranger has line officer responsibilities for the conduct of activities on their particular unit. They provide leadership and oversight for the proper use of variances and establish local procedures and assign roles and responsibilities for the implementation of additional or special mitigations. The District Ranger will advise the Contracting Officer or FSR when the execution of a variance is appropriate and determine when a PAL level of “E” should be set.

The Contracting Officer (CO) will provide the District Ranger information on contractual obligations, a purchaser’s/contractor’s past performance with fire precautions, a determination of the readiness of the purchaser’s fire suppression equipment, and will execute legal documents as appropriate. The CO/FSR will work with the Contractor/Purchasers to develop Variance options.

The District Fire Management Officer and staff are responsible for providing the District Ranger and CO/FSR with the conduct of fire risk assessment and analysis of variance mitigations. Fire management may be asked to develop mitigation measures and organization support in variance implementation such as locating engines or other fire suppression resources near a project area during certain activity levels.

The special precautions and site-specific mitigation actions will be spelled out in the contract. These should be reviewed at the pre-ops meeting. Of key importance during this discussion would be the process the Forest will utilize to administratively move from the Ev level to a complete shutdown; the E level.

The Forest Service can modify or exercise unilateral withdrawal of the approval based on non-compliance of the variance or extraordinary circumstances encountered during the field season such as the loss of local fire suppression resources due to increased fire activity within the Region or nationally, or the advent of north wind conditions.

The values in the matrix are intended to be a guide to aid local line officers, fire managers, and contracting authorities in establishing the PAL value for contract administration and other purposes for the coming day. It is appropriate to make minor adjustments to the forecasted PAL for the coming day based on the current PAL values, short-range and longer-range forecasts, and other local knowledge and considerations, at the “Ev” level and below. Situational awareness is important.

Some business rules include:

• The forecasted PAL should not be adjusted to a level below what has been observed for the previous three days.
• If a Forest receives no forecast for the next day, the Forest should use the observed PAL for the current day as the forecast PAL for the next day.
• If a Forest receives overnight precipitation that is not reflected in the forecast PAL, the Forest may roll back the PAL to one level below what was observed on the previous day.
• No adjustments are appropriate once the actual PAL has reached “E” - the shut down level, except for an overnight, on site, precipitation event that was not included in the forecast.
• If predictions made after 6:00 PM are significantly different than originally estimated, Forest Service will inform Purchaser when changes in restrictions or industrial precautions occur.

Forests will include the “how to” of their local adjustment process in their Fire Management Plans, and thoroughly document the rationale for any daily adjustments as they are made. Meteorologists and NFDRS/PAL Subject Matter Experts in the North Ops and South Ops Predictive Service Units are available to provide technical assistance and recommendations.

PAL may increase the number of shut down days over the days that would have been shutdown under SAL. Contract preparers need to account for this as the additional shutdown days may result in added seasons being needed to complete the terms of the contract over what SAL would have required. Additional appraisal allowances for additional move-in and move-out costs may become necessary in the R5 appraisal system.

The normal operating season is typically May 15 to October 31, a period of time the purchaser could reasonably be expected to work on the sale area and earn CTA in accordance with B8.21. The working operating season may equal the normal operating season, or it maybe a portion thereof. The working operating season is the season that the FS estimates the purchaser can conduct operations, exclusive of limited operating periods. The PAL appraisal allowance calculation is based on the estimated months (i.e., working operating season) that the purchaser should actually conduct operations.

To determine the cost of implementing the new Region 5 Project Activity Levels (PAL) requirements, the contract preparer needs to estimate the number of days during the project’s working operating season in each of the Project Activity Levels. The contract preparer should use the actual number of PAL days from past years to estimate the levels for the project’s working operating season.

The number of days in the project’s working operating season should only be those days where a purchaser or contractor can be expected to work. Sundays or the whole weekend should be deleted from the total days if you do not expect the purchaser or contractor to work on those days. Also any limited operating seasons that shutdown the operations should be deleted. In determining the cost of the PAL implementation, only estimated operating days are to be used.

The Regional Transaction Evidence Appraisal (TEA) and R5 TEARV spreadsheets will calculate this fire precaution cost for timber sale contracts. The appraiser will supply the spreadsheet with needed information as number of days needed to complete logging, cost of a fireperson, number of days in each of the activity levels, etc; and the spreadsheet will calculate the fire precaution cost. The spreadsheet estimates the fire precaution cost by calculating an average cost per day and multiplies it by the number of operating days needed to complete the sale or project. The total shutdown days will be accounted for by subtracting them out of the operating season. This will mean fewer days during the season for the purchaser or contractor to work, thus this could lead to higher logging cost, more operating seasons and more move-in and move-out costs for the sale or project. Also, the cost of idle equipment and crew under an “E” day is calculated in the fire precaution average cost per day.

For service contracts, the contract preparer must take into account the cost of the PAL requirements in determining contractor cost for contract estimates. The number of potential shutdown days also needs to taken into account as a cost against the contract costs as well as contract length in preparation for advertising the contract.

The sale or project prospectus shall announce that the sale or project will be using the Project Activity Level system and then state the fire danger rating area, a grouping of fire danger rating areas, or the individual weather station that will be used to generate PAL values for the sale or project. State the number of historical Project Activity Levels (i.e., A, B, C, D, Ev, & E) days for the “working operating season”. Also, state the dates of the Normal Operating Season.

Use the Project Activity Level Variance Check list. Variances can be determined in advance (i.e., at the time of developing the fire plan). The Line Officer or their representative in consultation with the District Fire Management Officer will evaluate the items in the variance check list as they relate to the existing and planned activities, add any mitigation measures as needed and the Line Officer will advise the Contracting Officer they may execute the variance. The name of the Fire Management Representative and the Line Officer involved must be filled in but a signature is not required.

The delegated authority to approve or disapprove the variance or modifications to the variance can occur at the FSR/COR level since they would usually have more knowledge of the ground and have access to the District Ranger.

The project area should be evaluated for differences in potential fire activity should a fire occur. This could necessitate the use of multiple forms. Examples of this would be units on a north slope near riparian areas versus those units located on south slopes that are generally dryer and would be expected to have more severe fire conditions or there is a significant difference from the predicted PAL and the actual conditions.

Consult with the Purchaser/Contractor or their representative when determining types of variances that are being considered. They might be able to come up with other options.

Yes, under PAL, this scenario would be possible. One operator could agree to a set of variances, which allows him to operate while the adjacent operator would not agree to same set of variances or be incapable of performing the necessary mitigations, thus shutting him down. Also, if the two operators are operating on two different Ranger Districts or two different National Forests, those respective line officers may impose different variances thus causing one operator to decide not to operate or vice versa. To avoid this situation from happening or to be able explain why its happening it will be imperative that adjacent Districts/Forests communicate with one another frequently enough during the course of the season to anticipate this situation and hopefully avoid it.

SAL has under represented the actual fire danger in the past; consequently the purchaser incurred minimal fire mitigation expenses and the Forest Service has assumed a greater measure of the liability due to resulting fires. PAL provides a better assessment of fire danger. A limited analysis has demonstrated that there were a greater number of days of greater restrictions associated with PAL than with SAL. This shift to more days of higher industrial fire precaution levels and the imposition of stronger mitigation/prevention measures has resulted in increased expenses to the Government, purchaser and contractors.

PAL evaluates the level of industrial restriction differently than SAL. PAL uses the Energy Release Component and Ignition Component outputs from NFDRS in determining the activity level rather than the independently observed wind speed and 10-hour time lag fuel moisture used by SAL.

The Energy Release Component tracks seasonal changes in live fuel moisture and large dead fuel moisture as well as the fine dead fuel moisture. ERC describes the dryness of the fuels. The Ignition Component rates the probability that a firebrand will cause a fire requiring suppression action. The IC component factors the ability of fuel to ignite and the resulting spread characteristics through the fuelbed.

SAL variables do not provide the necessary information to properly evaluate the effects of seasonal and long-term drought as is accomplished by the NFDRS components. Additionally, majorities of the current operating periods have been compressed into the heart of the fire season when fire danger is most acute and fire precaution shutdowns are most likely to occur. SAL fire precautions were weighted more strongly by the wind speed and fine dead fuel moisture and thus reacted more to daily weather fluctuations, but did not identify the increasing hazardous fuel conditions evolving in the live fuels, duff, and large fuels as the summer drought progressed. Most of California lies under the influence of a strong high pressure air mass during the months of June, July and August. Wind gradients are generally less intense during this period because of the persistence of this air mass, but the wind gradients tend to intensify during the seasonal transitions as air mass patterns restructure.

Therefore, SAL has historically understated the fire danger during a typical fire season, especially during the critical late fire season patterns. Due to the differences in how the two systems process fire danger, PAL would be expected to post a greater number of higher fire precaution activity levels than SAL given the same weather conditions.

Fire researchers and NFDRS practitioners have found that the fuel model parameters, which comprise the 1978 version of the NFDRS fuel model “G”, correspond well to the relationship between fire occurrence and fire danger outputs and produce replicable results irrespective of local vegetation types.

The “G” fuel model is characterized by a good distribution of live and dead fuel classes. This distribution is especially true in the larger dead fuel classes and contributes to the good stability and seasonality of the ERC.

The use of a single fuel model for Project Activity Level (PAL) determination throughout the Region reduces variables in the calculation of the PAL to that of antecedent, observed, and forecast weather at each fire weather station utilized by the local fire manager for PAL and enhances comparability between stations.

Forests need to utilize the agency owned and operated weather network to manage the day-to-day determination of PAL values. This would include BLM, BIA, CDF, NPS, FWS, and local government stations. The agency stations are readily available in WIMS have the necessary history to support the PAL days by month analysis for the appraisal process.

When an operator/contractor has reliable NFDRS values available for specific project sites we should endeavor to include that information in our decision processes at the E level thresholds. The operator’s/contractor’s station should be a point of reference for the decision maker, not the key PAL driver or the sole source of information for the decision process.

Forests must continue to evaluate their existing network for strategic holes and implement appropriate mitigations. Validating that any new site will result in significant differences in the daily PAL values can only be determined thru a season of comparative analysis. This can be completed as part of the development of the Fire Danger Rating Operating Plan (FSM 5124.45).

There is nothing prohibiting a Forest from installing a temporary agency station in an area today and including it in the daily PAL values. The big disadvantage of that approach is that there is no history for that site, but it would provide a point of reference for the local decision maker. You will not know what to expect in the way of outputs over the season. There is no day-to-day PAL climatology for the timber sale appraisal process. It will also require the NWS forecaster to spend more time forecasting for that site, as it is new to them also. Any decision to set up a temporary station needs good staff work and should be discussed with the supporting Predictive Service Unit.

Yes. PAL is in the infant stage of full implementation. The system will be monitored to discover any limitations or needed modifications. Variance procedures and contract requirements may also need adjustments as issues arise.