Balancing Accountability and Risk in Program Implementation: The Case of National Fire Policy

Balancing Accountability and Riskin Program Implementation:

The Case of National Fire Policy

Charles R. Wise and Christian M. FreitagIndiana University

ABSTRACT

For most of the twentieth century, public land managers in theUnited States suppressed virtually all wildland fires. This suppres-sion philosophy contributed to unhealthy ecosystems and allowed adangerous buildup of burnable vegetation. As a result of genera-tions of fire suppression, recent years have seen an increasedincidence of catastrophic fires in American wildlands. Followingsome of the worst fire seasons in American history, representativesfrom several federal agencies promulgated the 1995 National FirePolicy, updated in 2001. The National Fire Policy, and the subse-quent National Fire Plan passed by Congress, acknowledged theimportance of fire in natural systems, replacing the suppressionphilosophy with directions that wildland fire should be used as atool by forest managers to restore and maintain ecosystem health.

Fueled by high profile incidents such as the prescribed burngone awry at Cerro Grande in 2000, critics have pointed to the lackof appropriate accountability mechanisms for agencies in charge ofimplementing the National Fire Policy and Plan. Fixing blame forcatastrophic events should not be the only goal of accountabilitysystems, however. Accountability systems interact with otherimportant variables in the management context, including risk. Riskperception and risk management issues significantly influencemanagerial decision making. Moreover, organizational incentivesand disincentives for risk taking can heavily influence managerialrisk propensity, which can have important consequences forprogram implementation. Accountability systems may affectmanagerial perception of risks and thus managerial risk propensity.This article examines the relationship between accountabilitysystems and risk management in the context of the National FirePolicy, arguing that accountability and risk should be treated as

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Accountability and Risk: The National Fire Policy

On May 4, 2000, officials of the National Park Service igniteda prescribed fire in an effort to reduce the accumulation of vegeta-tion in the park near Los Alamos to lessen the chances of a futurecatastrophic fire. The plan was to bum nine hundred acres. Unfortu-nately, the fire now known as Cerro Grande eventually burned48,000 acres, destroyed 235 homes, forced the evacuation of 18,000people, caused serious ecological damage, and cost approximatelyone billion dollars in damages. It was substantially contained onMay 19, 2000. On May 11, the Secretary of the Interior appointedan interagency fire investigation team, which reported on May 18,2000, and fixed accountability for the incident by concluding that"federal personnel failed to properly plan and implement the UpperFrijoles Prescribed Fire, which became known as the CerroGrande Prescribed Fire" (Board of Inquiry Final Report 2001, 1).The secretary suspended the use of all prescribed fires as well,which was a ban that lasted for a year. However, the subsequentboard of inquiry's report, which was released a year later, criticizedthe original investigation's report as not always consistent with thefacts, and in some cases inappropriately evaluated performance(Board of Inquiry Final Report, 2001, ii). It went on to concludethat while the personnel involved committed errors in judgment,their actions in light of the information they had prior to the burnwere in compliance with agency policies (p. 45).

However, fixing accountability for catastrophic incidents is notthe only or necessarily the most important function of accountabil-ity systems for public programs. Accountability in public organiza-tions is a multifaceted concept, and too much focus on any one goalof accountability incurs the danger of distorting managementdirection and effectiveness. Accountability for the degree ofprogram implementation and accountability for the results ofprogram implementation in achieving system change are other oft-sought goals of accountability. Accountability, however, cannot beconsidered in isolation. It affects and is affected by other importantvariables in the management context. One such significant variableis risk. That is, risk is a significant component of managerialdecision making, and organizational incentives and disincentivesfor risk taking can heavily influence managerial risk propensity,which in turn can have important consequences for programimplementation. Managers' risk propensity and behavior influencetheir choice of priorities among types of risks that will be engagedor avoided, which then affects priorities for program implementa-tion. Accountability potentially affects managerial perception ofrisks and thus managerial risk propensity. In short, accountabilityand risk need to be treated as systemic matters within publicprograms.

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The focus of this article is on the following managerialquestions:

• How does the nature of an accountability system affect theimplementation of public policies?

• How do the incentives for risk taking by managers affect theimplementation of public policies?

• How does the balance between accountability and risk affectthe implementation of public policies?

The questions will be explored in the context of the implementationof the Federal Wildland Fire Management Policy. Thus, the specificquestions are:

• How has the nature of the accountability system in federalagencies that are responsible for implementation of the FederalWildland Fire Management Policy affected implementation ofthe policy;

• How has risk been approached in federal fire programs, andwhat incentives for risk taking have been created by theaccountability system in agencies involved in the implementa-tion of the Federal Wildland Fire Management Policy;

• What is the balance between accountability and risk in federalfire programs, and what adjustments are needed to improveimplementation of the Federal Wildland Fire ManagementPolicy.

ACCOUNTABILITY IN FEDERAL FIRE PROGRAMS

Accountability has become a major focus in federal fire pro-grams. In 1995, following the severe fires of 1994, the Secretariesof Agriculture and Interior jointly promulgated the Federal Wild-land Fire Management Policy to fundamentally alter the federalgovernment's historical stance toward fire in federally ownedwildlands from the view that fire is bad and should always besuppressed, to the view that fire is often good and a necessary partof maintaining healthy and safe ecosystems (U.S. Department ofInterior and U.S. Department of Agriculture 1995). According tothis policy, fire is to be used by federal land managers as a tool topursue the goals of ecosystem management. When the fire policywas originally adopted, it did not require the involved agencies toconduct program evaluation. Following the severe fires in 2000,an interagency working group reviewed the 1995 Fire Policy andits implementation, and while they found the 1995 policy to beessentially sound, they developed a revised fire policy to improve





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implementation. The working group found that the implementationof the 1995 policy had been incomplete, and as a result of fireexclusion the condition of fire-adapted ecosystems was deteriorat-ing; the fire hazard situation in these areas was worse than had beenpreviously understood (U.S. Department of the Interior et al. 2001,ii-iii).

A major theme of the 2001 report was directed at programmanagement and oversight, and the report stated: "Agencies haveimplemented the policy recommendations unevenly, and there islittle evidence that managers have been held accountable for imple-mentation (U.S. Department of the Interior et al. 2001, 10). Further-more: "The Working Group found that there is no effective meansof overseeing and evaluating implementation of fire policy, espe-cially across agency and program lines. A new policy on evaluationis therefore included in the 2001 Federal Fire Policy" (p. iv). Thenew policy requires that agencies develop a systematic method toevaluate implementation of the Fire Policy to assure accountability,1and calls for clear performance measures to be developed on aninteragency basis.2

Accountability is clearly identified as one of the major reformsthat were needed to foster actual implementation of the NationalFire Policy and was recognized as such in the revised policy asapproved by the secretaries of the departments involved. The taskbefore the departments and agencies that are responsible for variousaspects of implementing the Fire Policy is how to devise anaccountability system that will foster actual policy implementationand produce results.

POLICY IMPLEMENTATIONIN AN INTERORGANIZATIONALAND INTERGOVERNMENTAL SETTING

'"Agencies will develop and implement asystematic method of evaluation to deter-mine effectiveness of projects throughimplementation of the 2001 Federal FirePolicy. The evaluation will assure account-ability, facilitate resolution of areas ofconflict, and identify resource shortagesand agency priorities (p. 24).

^Evaluation of the 2001 Federal FirePolicy and its implementation will requireclear performance measures, mechanismsfor collecting and analyzing data, and thetracking of accomplishments and that allof these should be developed and used onan interagency, interdisciplinary basis"(p. 30).

Implementation research has pointed out several dynamics thatpotentially condition the success of a public policy. Among theseare objectives that are precise and clearly ranked in importance toserve as an aid in program evaluation and in the provision ofunambiguous directives to implementing officials (Mazmanian andSabatier 1989, 25). Implementation studies, however, have sug-gested that even with clear directives, compliance is related to indi-viduals' assessments of the relative costs and benefits of followingthe legal directives, and that the cost/benefit calculus is influencedby the probability that noncompliance will be detected and sanc-tions are available to penalize noncompliance (Mazmanian andSabatier 1989; Rodgers and Bullock 1976; Rosenbaum and Fix1977). In turn, the probability that significant sanctions will follow

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noncompliance is affected by such factors as the resources availableto agency officials to monitor noncompliance and the number ofveto points involved in penalizing noncompliance (Mazmanian andSabatier 1989, 37).

Several of these compliance inducing factors are potentiallyproblematic in the interorganizational and intergovernmentalcontext of fire policy. Lands that constitute potential catastrophicfire dangers are intermingled. U.S. Forest Service forests adjoinstate forests and private forests as well as Bureau of Land Manage-ment and Park Service forests. Joint action is required to achievethe goals of the Fire Policy in many areas. Therefore, effectiveimplementation of fire policy is inherently interorganizational andintergovernmental. Where such joint action is required by severalparties—federal, state, and nongovernmental—actors can be in aposition to deny what is needed for successful resolution (Churchand Nakamura 1993, 147). Thus strict compliance to open defianceto many behaviors in between are all possible on the part of actorsin potential collaborative programs (Agranoff 2001, 22). In addi-tion, if a paucity of inducements to cooperation exists, interorgani-zational implementation will be difficult (O'Toole and Montjoy1984, 495). As a result, compliance cannot be assumed for nationalpolicy that requires interorganizational action.

Accountability, therefore, becomes a priority managementissue in interorganizational policy implementation in order to assurecompliance with policy goals. As Goggin et al. point out, "A feed-back loop is an essential component of an implementation model"(1990, 40). Nonetheless, just because it is essential does not meanthat particular accountability arrangements will be in place andsufficient for implementation of a given policy. Numerous factorscan condition the effect of accountability arrangements. In theinterorganizational implementation setting if mandates are not veryspecific, monitoring, even when it is required, will frequently beweak (O'Toole and Montjoy 1984,495). This is exactly whatoccurred in the context of implementing fire policy. Mandates forimplementation were not specific and monitoring suffered. Unfortu-nately, beyond this, little implementation research has focused onthe role of accountability mechanisms in the achievement ofsuccessful policy implementation, nor has much research revealedhow accountability mechanisms or configurations of accountabilitymechanisms affect policy implementation.

In addition, policy implementation research has not focused onthe role that risk plays in inducing compliance by program partici-pants. The implementation of public policies often involves factorsthat possess unknown qualities and may have impacts on implemen-tation success or unintended side effects that are difficult to project.





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Also, unanticipated factors may emerge that have significant effects(Ingram and Mann 1980, 25-27). It is reasonable to project thatthose who are responsible for policy implementation factor the risksof compliance and noncompliance into their decisions about imple-menting policy and about the priority they place on particular poli-cies versus other management priorities. Nonetheless, implemen-tation research has not delineated the role that assessments of riskcan play in decisions about policy implementation or in the impactthat other components in the management context have on such riskcalculations. The public management literature has articulatedseveral reasons for accountability and risk to play important roles inmanagement reform.

MANAGEMENT REFORM:FOCUS ON ACCOUNTABILITY AND RISKTO IMPROVE PROGRAM IMPLEMENTATION

Fire programs are hardly unique in experiencing concertedrequirements for the establishment of accountability systems tosystematically demonstrate program results. The new publicmanagement paradigm clearly presses managers toward resultsmanagement with a focus on outcomes and demands that suchoutcomes be readily demonstrable (Behn 1999; Durant 1999). Thedemand for demonstrated accountability is presented both in thepursuit of greater program effectiveness and in the pursuit ofgreater democratic control of government institutional performance(Romzek and Dubnick 1994). This thrust is far more than a theo-retical preoccupation. These demands have found policy embodi-ment in the United States national government in such majorinitiatives as the National Performance Review (1993) and theGovernment Performance and Results Act. The latter applies tofederal agencies across the board. The thrust for demonstratedresults has also been embodied in reform initiatives at the state level(Brudney, Hebert, and Wright 1999; Government PerformanceProject 1999).

Another thrust of the new public management paradigm is thatmanagers are supposed to be more entrepreneurial. A central com-ponent of this orientation has long been stressed by advocates ofpublic management reform: to encourage public managers toengage in more risk taking. While there are some dissenters to theview that risk taking is important to entrepreneurship and effectivepublic management, the pervasive view is that risk aversion is aproblem and that it impedes entrepreneurial behavior (Bozeman andKingsley 1998, 109). One argument in favor of greater risk taking isthat public organizations need to encourage risk-taking behaviorbecause their policy environment is never predictable and stable





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(Ford Foundation 1996). Another is that government needs topromote prudent risk taking by providing room for failure, in orderto pull public officials out of routines and encourage proactivenessto solve problems (Dilulio, Garvey, and Kettl 1993, 76).

We see, then, that one major thrust of administrative reformstresses increased demonstrated accountability by public managers,and another stresses increased risk taking by public managers.These questions arise: How does each affect the implementation ofpublic programs? Does the relationship between them affectprogram implementation?

The relationships between accountability and risk and howsuch relationships affect policy implementation have not beenextensively researched in public administration. Nevertheless,managers confront several problems in any attempt to incorporatethe reform prescriptions of increased managerial accountability andincreased managerial risk taking. In the first place, various concep-tions of accountability exist, and proponents of specific conceptionsassert them as the solution to policy implementation. These differ-ing conceptions must be sorted through, and their potential forenhancing or diminishing policy implementation must be assessed.

The relationships between accountability and risk must beexplicated. Measures that promote accountability and those thatpromote risk taking potentially could be complementary, but thepotential does exist for them to conflict. Complementarity cannotbe assumed. Accountability systems, for example, are potentiallyconstraining of risk-taking behavior, particularly if the emphasis isplaced on penalizing personnel who do take risks for mistakes orinsufficient achievement of objectives. With regard to the imple-mentation of new policies, the leadership that sets the goals setsthem without knowing all the factors that might affect their achieve-ment. The leadership is dependent on lower-level personnel to takeinitiatives that involve risks to explore what can be achieved and tomake adjustments. Risk taking is inherent in this activity, and itinevitably involves mistakes. If the accountability system isdesigned to incorporate the notion that feedback loops are presentto facilitate managerial and organizational learning, then the resultsof risk taking may potentially be incorporated into the accountabil-ity system in a way that facilitates policy implementation. However,for this to occur, organizational leadership needs to identify whichkinds of risk-taking behavior facilitate learning and policy imple-mentation and which kinds are detrimental.

The integration of accountability and risk-taking objectives isby no means assured. Management must conceptualize what types





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of accountability will be emphasized to promote policy implementa-tion and how existing accountability systems are or are not alignedwith what is needed. In addition, management needs to conceptual-ize how various risk elements affect policy implementation, whattypes of risk-taking behavior are appropriate, and what guidance isneeded to encourage appropriate risk-taking behavior. Managementmust then decide how the choices among accountability approacheswill affect risk taking and other factors that impact policy imple-mentation. This sorting-out process begins with conceptualizingaccountability and risk.

ACCOUNTABILITY

In a fairly short time, the field has gone from a situation inwhich "[accountability is a fundamental but underdevelopedconcept in American public administration" (Romzek and Dubnick1987, 228) to one in which "[t]he scope and meaning of'account-ability' has been extended in a number of directions well beyond itscore sense of being called to account for one's actions" (Mulgan2000, 555). There is not space here to review all the senses andcontexts that accountability has been asserted to come into play,including notions of responsibility and dialog (for such review, seeMulgan 2000). Suffice it to say that there has been considerableconceptual creep associated with the term in the literature. Onesense of accountability, though, termed as accountability in its coresense is that it embraces the notion of being called into account tosome authority for one's actions (Jones 1992; Mulgan 2000).Within this sense of accountability, a broad definition applicable toadministrators embedded in multiple actor relationships in manage-ment and policy making is "the means by which public agenciesand their workers manage the diverse expectations generated withinand outside the organization" (Romzek and Dubnick 1987, 228).This definition suggests multiple and varied sources of accountabil-ity to which a public organization and its managers respond.Romzek and Dubnick (1987) derive four types of accountabilitysystems in the public sector, including organizational, legal, profes-sional, and political (Dubnick and Romzek 1991). To these four, Josand Tomkins add market exchanges, informal network exchanges,and personal values (1994, 48).

Romzek and Dubnick (1994, 271) assert that different types ofaccountability mechanisms are equally legitimate and, while all maybe present simultaneously, an agency or individual will typicallyoperate in a context where at least two types of accountabilitymechanisms actively compete for the agency's or individual'sattention. Rosen (1998, 209) describes accountability in the federalgovernment and points to multiple accountability mechanisms that





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constitute "[a]n awesome armada of policies, mechanisms, andprocesses for overseeing government bureaucracies" and provide agreat deal of redundancy.

Given the demands from the political branches responding tothe public, accountability demands are likely to be increasinglynumerous, sporadic, and unpredictable. More is not necessarilybetter. Multiplication does not necessarily produce an effectiveaccountability system. Multiple and contradictory demands mayproduce responses that undermine rather than promote an account-able public service (Jos and Tompkins 1994, 53) and may provedetrimental to policy implementation. Too often in the past, perfor-mance failures or ethical lapses have spurred increased calls foraccountability that have resulted in policy makers adding yetanother accountability mechanism to those already applicable to agiven agency or program. These additional mechanisms have beenadded without analyzing what the existing panoply of mechanismsis already doing to either the attainment or nonattainment ofaccountability goals or to providing incentives or disincentives tomanagers for various aspects of program implementation. The resulttoo often is a layering of accountability mechanisms that, takentogether, create disincentives for managerial initiative. As Rosenpoints out, "If all accountability mechanisms worked as they could,they would probably hobble bureaucracies in their essential work"(1998, 210).

To introduce administrative reforms, including new account-ability mechanisms, into an organizational environment with exist-ing accountability systems runs the risk—if the reforms are contraryto the dominant accountability systems and if no adjustments aremade—that long-term success is doubtful (Romzek and Dubnick1994, 88). If this result is to be avoided, the task will be to align thereforms and the accountability mechanisms to create incentives toensure that managers and workers will direct their efforts towarddesired policy goals.

RISK

As we have discussed, an oft-repeated theme in administrativereform is for organizations to encourage managers to take risks.While this is often advocated both in public and in private manage-ment, it is more common in public management. However, littleempirical evidence exists that public and private managers differ intheir propensity to take risks. Bozeman and Kingsley (1998, 113)found, for example, that sector had little influence on perception ofrisk-taking behavior in organizations. While there may be littledifference between sectors, this does not mean that either sector, or

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a given organization, has achieved the optimal level of risk propen-sity among its managers. Nor does it indicate achievement ofspecific risks that can impact goal attainment positively. It is per-fectly possible for a given public organization's managers to exhibitsuboptimal risk-taking behavior in terms of goal attainment.

The issue of risk in public management, however, cannot beusefully approached as if the goal were to automatically increasethe level of risk taking by public managers. In fact, it is logical toconsider that task and decision areas exist within certain publicorganizations where the needed objective would be to decrease riskpropensity among public managers. In addition, even where greaterrisk taking is desirable, it is unlikely that a given public organiza-tion would be well served by increasing risk taking across theboard. The organizational goal for impacting risk taking by manag-ers needs to be directed not only to the desired level of risk takingin general, but to focusing managers' propensity for risk takingtoward those activities and areas where more risk taking is specifi-cally needed.

Public organizations also have responsibilities beyond theencouragement of appropriate levels of risk taking. These responsi-bilities extend to providing methods for managers to use in assess-ing risks and to making decisions based on those assessments. Inaddition, organizations provide information that aids managers ingauging the nature and potential magnitude of risks; they also pro-vide feedback regarding the consequences of the decisions manag-ers have made based on the information they received. Organiza-tions also provide resources that managers can use for risk mitiga-tion if they have made faulty projections. Finally, organizationalofficials as well as policy makers external to the organization areinvolved in the assessment of risk-based decisions and their conse-quences for purposes of performance appraisal, program adjust-ments, and policy reappraisal.

Public organization policies and practices can have a signifi-cant effect on managers' risk-taking behavior. For example, topmanagers and organizational leaders can influence perceptions thatrisk is or is not legitimate and what behavior is acceptable concern-ing risk (Bozeman and Kingsley 1998, 111; Sitkin and Pablo 1992,22). Specifically, empirical research demonstrates that perceptionsof trust in employees that is exhibited by top managers affectsemployee perceptions of risk propensity in the organization (Moon1999, 38; Bozeman and Kingsley 1998, 115). In addition, goalclarity is linked to risk taking, in that managers who work insettings where the organization's mission is clear are likely toperceive their organization's culture as more favorable to risk





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taking (Bozeman and Kingsley 1998, 115; Moon 1999, 38). Organi-zations reward some types of behavior and penalize other types.Organizations that are perceived by managers to encourage promo-tion based on performance are more likely to be perceived by suchmanagers as having risk-oriented cultures (Bozeman and Kingsleyp. 115). Several of the findings that are reported here demonstratethe impact of organizational factors on managers' perceptions ofrisk. Nonetheless, risk perception has been shown to have crucialinfluence on individual risk-taking behavior (Sitkin and Weingart1995; Tamuz and Sitkin 1992; Van de Ven and Polley 1992).Several of these influences on risk are present in national fire pro-grams, and they affect the implementation of the Federal WildlandFire Management Policy.

THE NATIONAL FIRE POLICY

Smokey Bear and his famous slogan, "Only you can preventforest fires," represented the fundamentally suppression-orientedattitude of federal land managers for the greater part of the twenti-eth century. In recent years, that suppression policy has beenreplaced by a policy that acknowledges the role of fire in healthyecosystem management.

The current National Fire Plan and its counterpart, the 2001update of the Federal Wildland Fire Management Policy, requiremanagers to consider the important role fire plays in ecosystemmanagement. The federal government has not always taken such awelcoming view of fire in their management scheme. Historically,fire policy in America involved a debate between advocates of fireuse and advocates of fire suppression. Amidst this debate, federalland managers have suffered from the perception by some that "theAmerican fire establishment could neither adequately fight fires norlight fires" (Pyne 2001, 8). As noted biologist and fire historianStephen Pyne commented, our public lands have suffered ninetyyears of federal protection (p. 8). The current federal policy towardfire management has arisen over many years.

Both Native Americans, prior to European settlement, andearly European settlers used the equivalent of prescribed fires toincrease wildland resources such as game; they simply consideredoccasional wildfires to be part of the natural world (Williams 2000;Pyne 2001).The creation of the National Forest system and the U.S.Forest Service (FS) changed this orientation, and for over a centurychief foresters saw a policy of suppression of all fires as the key toforest health, although critics of the Forest Service policy continuedto advocate light burning or the Indian way (sometimes derided asPauite forestry) to improve forest health and decrease the risk oflarger blazes (Pyne p. 9; Williams p. 16).





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Advocates of the use of fire for wildland management receiveda new call to arms after the 1994 fire season, when thirty-four fire-fighters died, including fourteen in one fire alone. At the request ofthe Secretaries of the Interior and Agriculture, agencies chargedwith managing fire reevaluated their programs to ensure uniformityof federal policies and cohesive interagency and intergovernmentalfire management programs (NAPA 2001,3). An interagency steer-ing group guided the process; it consisted of representatives fromthe Departments of the Interior and Agriculture (DOI and DOA),the U.S. Fire Administration, the National Weather Service (NWS),the Federal Emergency Management Agency (FEMA), and theEnvironmental Protection Agency (EPA). In late 1995, the groupproduced the first interagency policy of its kind, the FederalWildland Fire Management Policy.

The 1995 policy officially supplanted the existing fire suppres-sion policy, replacing it with directions that "[w]ildland fire will beused to protect, maintain, and enhance resources and, as nearly aspossible, be allowed to function in its natural ecological role." Thepolicy included nine guiding principles, thirteen policy statements,and no less than eighty-three action items. In order for fire to beused as a resource management tool, the policy acknowledged theneed for a large-scale assessment of existing fire conditions andrequired all units with burnable vegetation to create fire manage-ment plans (FMPs) using the data collected from the assessments(NAPA 2001, 4). Until they completed FMPs, managers had tocontinue suppressing all fires. The 1995 policy also stressed theimportance of implementing the policy on a landscape scale, thusplacing great emphasis on interagency—and in fact intergovern-mental—coordination and collaboration.

In the wake of the Cerro Grande fire in 2000 all use of pre-scribed fire by federal managers temporarily ceased. An interagencyinvestigative team almost immediately began to review the 1995policy and its implementation. The working group that reviewed the1995 policy consisted of representatives from the Departments ofCommerce (DOC), Defense (DOD), Energy (DOE), EPA, FEMA,and the National Association of State Foresters (NASF). The groupconcluded that the principles and guidelines in the 1995 policy werefundamentally sound but needed clarification and updating. In Jan-uary 2001 the working group produced a review and update of the1995 Federal Wildland Fire Management Policy (NAPA 2001, 6).

The 2001 policy update retained, with little modification, thenine guiding principles of the 1995 policy, added five additionalpolicy statements and modified several others, deleted a policystatement that discussed economic efficiency, and proposed eleven





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implementation actions. Like the 1995 policy, the 2001 policy pro-moted the role of fire in resource management by addressing: therole of fire in ensuring ecosystem sustainability; the need for restor-ation and rehabilitation of fire-damaged lands and ecosystems; therole of science in developing and implementing fire managementprograms; the importance of communication and education inter-nally and externally; and the critical need for regular, ongoingevaluation of policies and procedures (NAPA 2001, 7).

Cerro Grande was not the only major fire outbreak in 2000,the worst fire season in fifty years. In August 2000, PresidentClinton asked the Secretaries of Interior and Agriculture to makerecommendations on how to respond to the severe 2000 fire season.The secretaries were also to consider both short- and long-termactions that could be put into effect at all levels of government,including tribal. In September 2000, the secretaries released theirrecommendations, Managing the Impact of Wildfires on Communi-ties and the Environment, also known now as the National Fire Plan(NFP). The key components of the report addressed ensuringadequate firefighting preparedness for coming fire seasons; restor-ing landscapes and rebuilding communities damaged by wildfire;investing in projects to reduce fire risk; working directly with localcommunities to ensure adequate protection; and becoming account-able and establishing adequate oversight and monitoring for results(NAPA 2001,10).

Congress appropriated almost 2.9 billion dollars for the imple-mentation of the NFP and imposed the requirement that the Secre-taries of Interior and Agriculture produce both a plan for meetingthe goals of the NFP and a budget for any allocated funds. Congressalso asked the departments to produce a list of communities cur-rently at high risk of wildfire and a performance report, both withinninety days of the end of fiscal year 2001. The report would identifyfinal expenditures and an updated action report detailing the depart-ments' final accomplishments. To date, each department has pro-duced its own action and financial plans, with special attentiongiven to the number of new hires planned as well as any plannedefforts to reduce hazardous fuels (NAPA 2001, 10).

In every respect, the 2001 policy was intended to be an inter-agency document. The policy was signed by representatives fromtwelve federal agencies, including some from five federal depart-ments (Agriculture, Interior, Commerce, Defense, and Energy) andtwo independent agencies (EPA and FEMA). Since it was alsosigned by the National Association of State Foresters, it wasintended to be an intergovernmental document. The 2001 policyemphasized the need for agencies to unify their own approach to





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implementing the Fire Management Policy and then effectivelyinterface with nonfederal parties (NAPA 2001, 73). Primary respon-sibility for implementing the policy falls on two federal depart-ments, Interior and Agriculture, and on the five land managementagencies within them. The Interior Department contains (listed frommost acres managed to least) the Bureau of Land Management(BLM), the Fish and Wildlife Service (FWS), the National ParkService (NPS), and the Bureau of Indian Affairs (BIA). The Depart-ment of Agriculture, by historical anomaly, contains the ForestService (FS). Each of these agencies has a unique mission statementand approach to fire management, creating a complex web thataffects coordination efforts for the explicitly interagency policy.

The fundamental mission of each federal land managementagency may be summarized briefly as follows:

• FS: sustainable, multiuse land management to meet diverseneeds;

• BLM: sustain health, diversity, and productivity of publiclands;

• NPS: preserve natural and cultural resources and allow forpublic education and enjoyment;

• FWS: conserve, protect, and enhance wildlife habitat;• BIA: enhance Indian quality of life and promote economic

opportunity (NAPA 2001, 20).

In short, the Forest Service and BLM have multiple use missions,the NPS and FWS have dominant use missions, and the BIA has theunique responsibility of dealing with multiple sovereigns.

As their diverse missions would suggest, each agency alsoapproaches wildland fire management differently. Their approachesto fire may be summarized as follows:

• FS: reduce hazardous fuel, restore ecology, suppress whereappropriate;

• BLM: manage fuel loads, respond to wildland fire appropri-ately;

• NPS: meet specific land-use and restoration objectives;• FWS: habitat management;• BIA: effective wildland fire protection, public safety, fire use,

and hazardous fuels treatment (NAPA 2001, 21-22).

To summarize, the Fish and Wildlife Service uses fire to promotehabitat objectives. The National Park Service uses fire to restoreland to its historical condition before human alteration, though theNPS resists mechanical thinning and the use of heavy machinery.





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The Forest Service has been the most actively engaged in suppres-sion activities and does not resist mechanical thinning. The BLMuses fire to reduce fuel loads. The BIA uses fire for public safety,ecosystem health, and hazardous fuel treatment. Not surprisingly,these divergent missions and approaches have implications for theimplementation of the interagency policy.

Though Congress adopted the NFP and the 2001 policy almostconcurrently, most attention has been paid to the NFP, given themassive appropriation it received. Perhaps because of the brighterspotlight placed on the NFP, the federal land management agencieshave tended to focus on meeting objectives set by the NFP, asopposed to other action items set forth in the policy. Althoughconsistent with the policy, the NFP has a narrower focus.

IMPLEMENTATION OF NATIONAL FIRE POLICY:PROBLEMS AND ISSUES OF ACCOUNTABILITY

While there are many issues concerning implementation of theNational Fire Policy, our analysis will be confined to the account-ability and risk issues, which are major components of the imple-mentation issue.

The treatment of accountability will be within the organiza-tional, legal, professional, and political framework we have dis-cussed. The legal aspect has not been a major influence, in that theNational Fire Policy is essentially a policy declared by the heads ofthe participating agencies; it has not been passed by Congress. Thatis significant, in that the policy lacks the force of a congressionallyenacted statute.

Several organizational issues are pertinent. Bozeman stressesthe need to assess whether and under what conditions structuralconfigurations of organizations and their environments, internalresources, and technological complexity provide buffers againstaccountability demands (Bozeman 1987). And, as Jos andTompkins (1994, 47) point out, organization structures significantlyaffect accountability demands and responses. Attempts to monitoror control administrative agencies can be undermined because theyconstitute separate, bounded systems that make gathering andinterpreting information difficult.

Three features of the organizational configuration responsiblefor implementing the National Fire Policy are pertinent to policyimplementation: multiorganizational responsibility (multiple depart-ments and multiple bureaus within departments); decentralizedmanagement structure of regionalized field units that control policy





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initiation and execution (e.g., National Parks and National Forests);and functional separation of managers responsible for differentaspects of policy implementation (land managers and fire programmanagers). With twelve agencies and one national association assignatories for the 2001 fire policy update, accountability is condi-tioned by the separate history, mission, and culture that affectagency capacity and commitment to implementing a uniformfederal policy promulgated by secretarial order that is superimposedon the separate laws that define each organization's responsibilitiesand funding. A considerable portion of implementation research(based on the top-down perspective) has noted that implementationproceeds most expeditiously when only a few organizations areinvolved and the administrative structure is well integrated fromabove rather than dispersed and fragmented into numerous officesand bureaus (O'Toole 1986; Mazmanian and Sabatier 1983). Thiswould seem to be particularly applicable with respect to determin-ing accountability for policy implementation of the Federal Wild-land Fire Management Policy. Five agencies actually manage 90percent of all federal lands and their operations are overwhelminglyplace based (NAPA 2001, 16). The focal point for operations for theNPS is the parks, for the FS it is the national forests, for FWS it isthe refuges, and for the BIA it is the reservations. The responsibilityand control rest primarily with the senior line official (e.g., forestsupervisor, park superintendent), and while they are held account-able within their operational chain of command they have substan-tial autonomy in managing their organizations, including the firemanagement program (NAPA 2001, 39-40). Thus primary opera-tions are highly decentralized and regionalized.

In addition, the headquarters operations for the fire manage-ment programs are staff offices, and they do not have line authorityover program operations in field units. Fire use activities (pre-scribed fire) and fire suppression activities are often managed bydifferent offices within the land units, as well. In the NPS, fire sup-pression activities, for the most part, fall under the visitor/resourceprotection services (the park rangers), and prescribed fire fallsunder the jurisdiction of the resource managers. Frequent conflictbetween the two sets of managers stems from fundamental differ-ences of opinion over how to use and manage fire. For one hundredyears, the focus has been on suppression, and that emphasis hasburrowed deeply into the culture of many professionals who haveseen their roles as protecting the resource. In 2001, the Departmentof Interior and the Forest Service did establish the National Inter-agency Steering Group to oversee implementation of the NationalFire Plan, but field units continue to receive directions and guid-ance from their agencies, and they implement some aspects of thefire plan on a single agency basis rather than collaboratively. For





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example, the joint Forest Service-BLM Service First offices prepareseparate reports for FS and BLM on the status of National Fire Planimplementation (NAPA 2001, 58).

Organizational accountability has many facets, includingaccountability for policy implementation, program outputs, programoutcomes, and program efficiency. Fire policy accountability hasbeen lacking for all facets. With regard to policy implementationaccountability, the 2001 policy review and update concluded:

There is no systematic method or program for evaluating federal fire policy andits implementation, especially across agency and program or discipline boun-daries. No performance measures or other means exist to determine the statusof implementation or the effectiveness of the policies. The review of the 1995Federal Fire Policy found substantial actions that were not completed. There isno ongoing or established process for tracking status of policy implementationwithin or among agencies. (U.S. Dept. of Interior 2001, 40).

The land management agencies do perform various reviews of theirland management programs, but for the most part these are prepar-edness reviews that are meant to determine whether field units areadequately prepared for the fire fighting season, not reviews of firepolicy implementation (NAPA 2001, 40). The land managementagencies did not have mechanisms in place either to assess whetherthe policy was being implemented or to hold staff accountable fordoing so. While in a few instances fire policy implementation maybe assessed as part of normal performance reviews for field staff,the bulk of the field staff do not have this as part of their perfor-mance reviews (NAPA 2001, 46).

With respect to accountability for outputs, major agencyattention is devoted to output tracking for their National Fire Planaction targets by the Department of Interior and the Forest Service,with both departments developing automated systems to track andreport data related to NFP targets. One input factor—number ofnew hires—and one output factor—number of acres that receivefuels reduction treatments—are primarily being monitored. Thelatter does not provide data about whether overall hazard or risk arereduced, and without such additional information there is an incen-tive to treat the acres of forest that are easiest to treat but that do notconstitute the greatest hazards. Thus tracking such an output pro-vides no accountability for outcome targets included in the NationalFire Policy such as risk mitigation, healthy ecosystems, and com-munity priorities in the urban interface (NAPA 2001,45).

With respect to tracking outcomes relevant to the National FirePolicy, not much has been accomplished on an overall multiagencybasis. One problem has been the unavailability of criteria, measures,





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'Researchers have documented the bene-fits of fire as a resource management tool.The benefits of fire use include reductionof ground fuel loading; disposal of slash;preparation for replanting (by reducingdowned timber and natural litter); thin-ning of overstocked or diseased stands;increase of plant growth; improvement ofwildlife and fish habitat; maintenance offorest openness; and protection of peopleand property from catastrophic wildlandfire (Williams 2000).

and data within and across agencies. The 2001 review, for example,found that criteria have not been developed for evaluating ecosys-tem conditions by ecosystem type and for prioritizing areas forreintroduction of fire to meet resource objectives and reducehazards (U.S. Department of Interior et al. 2001, 49). Individualagencies have begun to make some decisions about trackingoutcomes. The Forest Service has decided to measure both thepercent of wildland-urban interface areas with completed fuelstreatment and the percent of all acres with fuel levels that meetrelatively fire safe condition class I criteria3 (General AccountingOffice 2001, 8-9). Nonetheless, that represents the decision of oneagency and will not provide data for assessing the multiagencyNational Fire Policy effort. Developing useable measures ofoutcomes is important for the interorganizational implementation offire policy. For one thing, the rationale of the policy—to producehealthier ecosystems—inherently requires multiagency action.Second, as Bardach and Lesser (1996, 203) have pointed out,because collaborative organizational efforts are adopted in order toachieve some sort of synergy in a joint production process, theyought to produce a better or more valued outcome than wouldotherwise be expected. Properly conceived outcome measures, then,can become part of the larger managerial strategy for makinginteragency collaboration effective.

With regard to accountability in the professional category,there is a clear and universally embraced goal in the fire commu-nity—safety in fire suppression. This embraces safety for all firefighting personnel and for communities threatened by fire. The landmanagement agencies do perform reviews of their land manage-ment programs, but for the most part these are preparednessreviews, which are meant to determine whether field units areadequately prepared for the fire fighting season, not reviews of firepolicy implementation.

With regard to accountability in the political category, as aresult of increased congressional appropriations, increased agencyattention is directed at providing information to Congress about theimplementation of the National Fire Plan—not the National FirePolicy, which has a broader set of goals. In addition, accountabilityin the political sphere can periodically become most salient whenthere is a major fire-related incident, as the events after the CerroGrande fire illustrate. In fact, episodic accountability demands inthis arena have the potential to condition behavior that affects majoraspects of Fire Policy implementation.

Individual agencies have some guidelines for the investigationof major fire-related incidents. For example, the National Park





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Service has now established reviews at park level, regional level,and national level. A park-level review provides the park superin-tendent with information to take corrective actions and to recognizecommendable actions; it is conducted by the park's fire manage-ment officer and other qualified officials appointed by the superin-tendent. A regional-level review may be conducted if a fire crossesa park's boundary into another jurisdiction without the approval ofan interagency agreement, if it results in adverse media attention, ifit involves serious injury to fewer than three personnel, if it causessignificant property damage or is an incident with such potential, orif it results in controversy with another agency. Qualified individu-als for the review team are appointed by the regional director andthe park's superintendent and serve along with the park's manage-ment officer and the fire incident commander. A national-levelreview may be conducted for any fire that involves service-wide ornational issues. These could include adverse media or politicalinterest, substantial loss of equipment or property, or a fatality ormultiple injuries. The national fire management officer convenes anational-level review that includes the park superintendent, the parkfire management officer, the incident commander, and other quali-fied individuals.

The Fire Policy itself lacks the guidelines to ensure standard,systematic review procedures for investigating major fire incidents.While each agency has its own procedures for conducting incidentreviews, without a formal process organized on an'interagencybasis, these reviews can become quickly politicized (NAPA 2001,xxix). For example, in the Cerro Grande fire situation, the investi-gation team appointed by the Secretary of Interior conducted inter-views for only two days while the fire was still burning and pre-sented a final report to the secretary within a week (NAPA 2001,114). Because the fire destroyed houses and buildings in LosAlamos, because people were evacuated, and because the fire drewnational attention the investigation took place in a highly chargedatmosphere. Top officials of the Department of Interior placedblame on personnel who were said to not have followed procedures.A year later they were found to have followed agency policies.Many agency staff have indicated that the manner in which the firstinvestigation was conducted has made land managers more riskaverse and less willing to pursue the Fire Management Policy's goalof using fire to restore ecosystems (NAPA 2001, 161).

IMPLEMENTATION OF NATIONAL FIRE POLICY:PROBLEMS AND ISSUES OF MANAGING RISK

Managing fire carries risks. Risks cannot be eliminated fromthe fire management process. From this premise, federal land

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managers who deal with wildland fire seek to understand the risksand act accordingly. Previously, land managers sought to controlrisks by suppressing all fires, and in doing so they actuallyincreased the risks they would later face. The 2001 policy and theNFP, understanding the importance of fire in maintaining safe andhealthy wildlands, require land managers to consider fire as morethan just a destructive force. In doing so, the policy acknowledgedthat, given the benefits of fire, some risks may be justified and notall risks can be controlled. Learning to manage risks under a policythat requires them to manage fire has been a difficult task for manyland managers. According to some analysts who reviewed the CerroGrande fire, managers there fell short on several points in their riskassessment (Board of Inquiry Report 2001). After Cerro Grande,some land management agencies revised their risk assessmentprocedures to emulate more closely those used in the aerospace anddefense arenas. Still, not all agencies use improved techniques. Thedifferences in techniques among agencies make landscape scaleplanning across agency, intergovernmental, and private ownershipboundaries complex and difficult to achieve (NAPA 2001, 93-96).

Before we proceed with a discussion of risk assessmentconflicts and difficulties, we will define several concepts. Riskassessment involves the process of characterizing risks. Risk maybe defined as the chance of hazards or negative consequences (HotTopics 2001, 6). In order to properly characterize risk, managersmust consider three related concepts: the intensity of the hazard ordanger, the probability of an occurrence, and the value of potentiallosses or consequences that may result from an occurrence (NAPA2001, 90). Hazards include any existing or potential condition thatcan cause injury, illness, or death, or damage to equipment or prop-erty (Hot Topics 2001, 6; Committee on Risk Perception and Com-munication 1989,321). In the context of fire, this includes an area'sfuel load and condition. Probability is defined as the expression ofconfidence that an event will occur (NAPA 2001, 87). In this con-text, probability addresses the likelihood of ignition or of fireescaping predefined boundaries (NAPA 2001, 123). Values encom-pass ecological, physical, social, and economic costs of potentialdamage (NAPA 2001, 90). Firefighter and other human life isalways the first priority (U.S. Dept. of Interior et al. 2001, 22; U.S.National Park Service, 2001, chap. 3, p. 1) Other primary consider-ations generally include safety, economic factors, environmentalfactors, public health, geographic factors, administrative factors,and social or legal considerations (U.S. National Park Service,2001, chap. 2, p. 3).

Risk management, then, is the process of deciding what to doabout the risk. Managers may reduce risk by reducing the hazard

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itself; by reducing the probability of occurrence of the hazardousevent (ignition or escape); or by reducing the value of the potentiallosses at risk (NAPA 2001, 88). Reducing the value of potentiallosses, for example, could involve a reduction of the number ofhomes at risk from wildland fire. Not surprisingly, proper riskassessment presents a difficult calculus for land managers. Riskassessment in the federal agencies has generally been pursued onthe following bases:

• risks are generally assessed for small areas as part of opera-tional fire plans;

• assessment tools typically used are qualitative and basedlargely on the personal experience of fire planners;

• quantitative models are seldom used because of inadequatedata, technology, and personnel in the field;

• consultation with adjoining property owners is often lacking orinadequate;

• preparation of joint fire management plans is rare;• mitigation measures are more often aimed at tactical concerns

relating to managing the risks of controlling the fire withinspecified boundaries than at reducing longer term risks; and

• mitigation costs sometimes may be unrealistically budgetconstrained (NAPA 2001, 94).

Organizations affect appropriate managerial risk propensity inseveral ways, including provision of risk assessment methods,information, risk mitigation resources, and assessment of risk-baseddecisions. Implementation of the Fire Management Policy has beenimpaired by deficiencies in several of these.

With regard to the provision of appropriate methods forassessing risks and making decisions, wildland fire programs havelacked a comprehensive definition of risk. Across all agencies,current risk assessment techniques focus on only one of the threecomponents we have described as necessary for proper risk assess-ment—typically hazard—and they tend to neglect probability andvalue considerations (NAPA 2001, 90). To better manage risk,assessment needs to consider each of the fundamental concepts—hazard, probability, and value.

A second component, provision of information that aidsmanagers in gauging the nature and potential magnitude of risks,has been insufficient to support implementation of the Fire Manage-ment Policy. While a large number of wildland fire models havebeen developed to assist with assessments, many of these computermodeling programs and decision support tools focus only onhazards. Moreover, although software exists that could help





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managers estimate hazards resulting from existing fuel loads,predict fire behavior, quantify risks, estimate potential losses, anddetermine ecological restoration needs, data necessary for runningthe models is often unavailable to managers. Furthermore, manyfire managers lack the training and resources necessary to fullyutilize the decision support tools. Decision support tools are helpfulonly to the extent that they are valid and reliable, and this requiresthat such tools are continually updated based on current nationwideexperience. The board of inquiry that reviewed the activities in theCerro Grande fire found that "the complexity rating processcompleted for the Upper Frijoles 1 and 5 prescribed fire plan didnot follow the National Park Service rating system. However, thiswas not due to an oversight by the Bandalier staff but due to thefact that the version of the Wildland and Prescribed Fire Complex-ity Rating Worksheet Numeric Rating Guide posted on the internetat the National Park Service Fire Management Program Centerhome page was incorrect at the time of the Cerro Grande PrescribedFire" (Board of Inquiry Final Report 2001, 14). Even if the correctrating guide had been used, there is little assurance of reliability inthat no process exists to feed back data on actual interagency fireexperience to continually update the guide.

Thus, the current problem is that there is no systematic methodthat generates and aggregates information about decision outcomesand feeds that information back into risk planning and decisionmaking. If a field unit conducts a review of a wildland fire in itsarea of responsibility, the data gathered in the review are notentered into a central data base (NAPA 2001, 113-14). Thus theexperience cannot be shared with others in the agency nor can it beused to improve risk methodologies. Department of Interior agen-cies are required to complete a form for each wildfire that occursnaturally within a park or for each prescribed fire that escapes itsplanned boundary. By not gathering data on fires that proceed asplanned, even if the data collected were aggregated, an incompletepicture of total risk experience would be generated. Too often,inadequately validated decision support tools result in decisionmaking that is based solely on experiential data and in a lack ofinformational resources for mitigating erroneous decisions.

Another problem in the current risk assessment, management,and mitigation arena is a lack of information coordination andconsultation. For example, although Congress in 2001 mandatedthat the Secretaries of Interior and Agriculture jointly compile a listof communities in the wildland-urban interface (WUI) currently athigh risk from wildfire, to date there is no such list. Rather thanworking jointly on this list as directed, DOI and DOA have createdtheir own lists (NAPA 2001, 96).

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A third component of potential organizational assistance is theassessment of risk-based decisions and their consequences for thepurposes of program adjustments, policy reappraisal, and perfor-mance appraisal. This may prove to be the most problematic.Comprehensive incident reporting has been missing, and assess-ment cannot proceed for the fire management policy without a clearmission. Mission clarity is a key component in encouraging appro-priate managerial risk propensity, and each agency tasked withimplementation of the 2001 policy operates under a differentcharge. The mission of each agency affects the manner by which itbalances short-term versus long-term risks. Ignition of prescribedburns obviously carries with it some short-term risks, but a strictfocus on these short-term risks may allow fuels to accumulate to alevel such that the longer-term risk of catastrophic fire increases. Agood example of such a conflict of missions may be seen in theForest Service and the Fish and Wildlife Service.

Because the FWS has primary enforcement responsibility forthe federal Endangered Species Act (ESA), it operates at least inpart as a regulatory agency in addition to its independent landmanagement responsibilities. The FWS and the National MarineFisheries Service (NMFS) share responsibility for administration ofthe Endangered Species Act. Section 7 of the ESA requires that allthe land management agencies consult with the FWS or the NMFS4

on any proposed action on their land that might impact any endan-gered species. These Section 7 consultations are often time consum-ing and costly. Regulatory concern over negative short-term effectscan delay or stop projects altogether, even those that would result inlong-term benefits to the particular species or ecosystem. Thefundamental mission differences lead these agencies to differentconclusions about the appropriate balance between short- and long-term risks. One regional forester with the Forest Service summedup the nature of the conflict succinctly:

The Forest Service's multiple-use mission . . . provides for management actionsthat allow acceptance of short-term risk, within acceptable limits, to achievelong-term benefits. Regulatory agencies view recovery of species as requiring arisk averse policy in evaluating human induced proposals. This leads to strictlyminimizing, or avoiding altogether, short-term risks, in spite of the degree ofshort or long term threats to the species or habitat, or the overall long-termproject benefits. This basic policy difference creates additional informationaldemands equivalent to high-risk projects, causes long delays, and in the end itis difficult to see any benefits from the additional burdens all agencies endure(official correspondence, Jack A. Blackwell, regional forester, April 30,2001).

In short, the regulatory agency's short-term risk aversion mayThe NMFS is in charge of saltwater prevent the land management agency from using fire to manage formarine species, while the FWS is \ c ^. . ' b . . . ,• .• c • igenerally in charge of freshwater marine long-term forest health. Moreover, the application of environmentalspecies, terrestrial species, and birds. regulations may discourage fire in the effort to minimize immediate





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risks to certain species, but in doing so may cause accumulation offuels that spawn catastrophic fires that hurt the very species theregulations seek to protect. This fundamental mission conflict alsohas implications for accountability. If land management agenciesfind themselves unable to use fire projects to reduce ignitable fuelbuildup due to regulatory prohibition or delay, measuring theiraccountability may be unfair at best, and impossible at worst.

Although the federal agencies that are charged with imple-menting the 2001 policy and managing the risks inherent in wild-land fire suffer from problems associated with proper assessment,resources, information, and methods, wildland fire risk assessmentis still improving. However, because of these systemic problems,appropriate and necessary risk assessment sometimes simply is notcompleted. Ultimately, the individual land unit managers areresponsible for wildland fire risk assessment and management intheir units. Because these unit managers often possess a great dealof programmatic discretion, the complications associated with wild-land fire risk assessment and management may cause them to focustheir attention and resources on less problematic programs. Itshould be understood that land and forest managers are not neces-sarily oriented toward change in management approach or objec-tives. Hodges and Durant found that neither changes in forest con-ditions nor changes in employers were cited by foresters as reasonsfor a shift in management philosophy. Also, foresters in risk-aversesectors were less likely to change their management approachesthan were those employed in less risk-averse organizations (Hodgesand Durant 1989, 479). Thus the land management agencies willhave to work to create a risk environment that creates conditionsthat will change managerial orientation toward taking risks onbehalf of the objectives stated in the Fire Management Policy.

BALANCING ACCOUNTABILITY AND RISKIN THE IMPLEMENTATION OF THEFEDERAL FIRE MANAGEMENT POLICY

Deficiencies in several key types or categories of the account-ability system in the interagency organizational configurationresponsible for federal fire management policy create inadequateincentives for risk taking and otherwise have detrimental impactson policy implementation. Prospective remedies may potentiallyreinforce appropriate incentives that would bolster implementationefforts.

Accountability in the organizational category has been largelyneglected. With regard to accountability for program implementa-tion, a dearth of mechanisms specifically address implementation





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responsibilities for the Fire Management Policy, particularly forthose resource managers who control decisions over the land areasfor which risks must be taken in order to fulfill the goals of thepolicy. On a national level there is little information aggregated thatpinpoints the degree of program implementation. Some data hasbeen collected pursuant to the National Fire Plan (NFP), such asnew hires, but this is plainly inadequate for tracking Federal FireManagement Policy implementation.

With regard to tracking outputs, the system on a national levelat the current time is too narrowly focused, and as a result it ispotentially distorting as it relates to important risk attributes. Datacollected pursuant to the National Fire Plan on number of acrestreated provide an incentive to treat the land parcels that are theleast difficult to treat, and that are not necessarily either those thatpose the greatest hazard for catastrophic fire, or those that are themost important for sustaining healthy ecosystems—major goals ofthe Fire Management Policy. Accountability for outcomes related tothese important goals is virtually nonexistent. The vacuum in track-ing outcomes creates an incentive to minimize short-term risks—such as either the risk of a planned fire escaping its boundaries, orthe risk of incurring regulatory problems from environmental regu-latory agencies—by avoiding planned burns, which increases thepotential long-term risks.

It would seem to be imperative for the top leadership to focusits attention on clarifying the responsibilities that land managershave to pursue the goals of the Fire Management Policy and toimprove managerial accountability systems that, in particular, trackpolicy implementation and program outcomes. The latter will nodoubt take longer to develop and perfect. It should not be surprisingthat goal clarity is problematic in that goal multiplicity is anubiquitous part of an interorganizational setting (O'Toole 1993,241). Nevertheless, by clarifying outcome goals and placing apriority on their attainment as a first step in the development of anoutcome tracking system, benefits can be expected in managerialrisk propensity. Research has found that managers who work insettings where the mission is clear are likely to perceive the organi-zation's culture as favorable to risk taking. Improvement in thetracking of policy implementation and the clarification of goals canmore readily take place. An integrated managerial accountabilitysystem is best developed on an incremental basis so that lessonslearned in early system development stages can be used in the per-fecting of later stages. In addition, proceeding on a phased basiswill help to avoid premature implementation of measures of indeter-minate validity and reliability, which if used for performance orprogram evaluation might make managers question their utility in

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decision making. Such premature implementation might then alsomake managers more risk averse and lead them to emphasize otheragency responsibilities.

Accountability in the political category, on the other hand, hasbeen salient and as a result has created potential disincentives forrisk taking in pursuit of Federal Fire Management Policy goals.Two aspects of political accountability are pertinent here. Con-gress, having authorized and funded the National Fire Plan, hasfocused the attention of the participating agencies on demonstrat-ing accountability for the expenditure of the appropriated funds,and this creates incentives to emphasize shorter-term goals such astracking the number of new hires and the number of acres treated,thus reducing incentives to pursue more difficult Fire ManagementPolicy goals. Some top political leaders have interceded in theinvestigation of major fires and this has created public attention,which in turn has created disincentives to take risks. After all,given the current accountability system, there is little penalty fornot igniting a prescribed fire. An accumulation of fuels thatincrease hazards will most likely not be noticed until after a par-ticular land manager has moved on to the next assignment. Ignitinga prescribed fire that crosses boundaries and draws the attention oftop leadership, on the other hand, carries with it the risk of repri-mand or worse.

The current alignment between the types of accountabilitywould seem to be less than optimal in supporting policy implemen-tation. This is not unusual in government, in that the existence ofmultiple, overlapping accountability relationships means that thelikelihood of facing at least one less-than-ideal alignment in publicmanagement is the norm rather than the exception. A multimethodapproach to accountability, given several legitimate sources ofauthority and multiple diverse expectations, is appropriate, but it isnecessary to align the methods or the long-term success of thereform is at risk (Romzek 2000, 37).

In order to encourage appropriate risk taking in pursuit ofFederal Fire Management Policy goals, improvements in account-ability systems for tracking policy implementation and policy out-comes are in order. However, if adjustments are not made in theaccountability approach used in the political sphere, the likelihoodexists that accountability activities in the political category willovershadow improvements in the managerial sphere.

Two actions in the political sphere could avoid the reinforce-ment of undesirable disincentives for risk taking. First, Congresscould take steps to diminish the distortions in the operation of

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current policy. Congress could either legislate the Federal WildlandFire Management Policy or it could be responsible for greater over-sight of the 2001 policy. Legislating the policy could activateaccountability in the legal sphere, which could offset the incentivefor managers to ignore activities for which they do not have specificlegal responsibility in an effort to insure they are fulfilling the tasksfor which they do have such responsibility. A statute would createownership for the policy by congressional committees, which thencould undertake regular legislative supervision in the form ofoversight or reauthorization hearings. Alternatively, Congress couldundertake more intensive oversight of the Federal Fire ManagementPolicy as it now stands. This might provide the opportunity for therelevant committees to explore the relationships between theNational Fire Plan and the Fire Management Policy and placeemphasis on the broader agenda embraced by the Policy.

Whichever course Congress chooses to follow, it would beimportant for the relevant committee members to address the rela-tionships between the Fire Plan and the Fire Management Policy inan effort to assist the agencies' top leadership in clarifying goalsand setting priorities. Such improvement in goal clarity could serveto increase the propensity of operational managers to take appro-priate risks.

A second measure would be to put in place a systematicinteragency procedure for investigation and review of major fires.This would be aimed at reducing the potential for politicizing thereview process in future major incidents, especially those that arisefrom planned fires. A National Academy of Public Administrationpanel, studying implementation of the Fire Management Policy,recommended that the Secretaries of Agriculture and the Interiorestablish an interagency fire incident review and reporting process.The regulations for such a process would establish the criteria formembership on and appointment to the investigating committee; thecriteria to be used in the review; the fact-finding procedures to beused; the due process protections to be afforded to those underreview; and the procedures for reviewing report findings andrecommendations (NAPA 2001, 118). The idea is to assure man-agers that in case a fire burns out of control they will be treatedfairly according to a standard process established long before theincident and to assure the public that major incidents will be inves-tigated thoroughly. The measure would decrease the potential forad hoc politicization and the disincentive to risk taking that poses,and would increase the measure of professional accountability inthe review of major incidents. Previous research has found thatperceptions of trust exhibited by top managers in their employeesaffect perceptions of risk propensity in the organization. The move





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to systematize and assure professional input in the review processcould serve to increase the trust perceived by operational managers.

These measures could diminish the existing disincentives forland managers to pursue the goals of the Fire Management Policyby realigning the emphases among the types of accountability thataffect the implementation of the policy. As perceived by managers,a decrease in the potential for ad hoc political intervention and anincrease in congressional oversight of Federal Fire ManagementPolicy implementation, coupled with an increase in managementaccountability systems designed to support such goals, could pro-vide a better balance between accountability and risk. This couldincrease incentives for managerial appropriate risk propensity thatis directed at supporting implementation of the Fire ManagementPolicy.

CONCLUSION

The experience with the implementation of fire managementpolicy demonstrates how the nature of accountability systems andtheir interaction with risk factors affect policy implementation. Inthe first place, it illustrates the key role that neglect of accountabil-ity systems can have in providing needed incentives to implementpublic policies on a national basis. Accountability systems createincentives that may or may not be supportive of new policy imple-mentation. Existing accountability systems and practices will condi-tion the context of policy implementation and, as the experiencewith the Fire Management Policy illustrates, preexisting account-ability expectations may be ill-suited to the implementation of anew policy.

In addition, the fire policy experience to date illustrates thatmultiple accountability expectations will operate within a givenpolicy, and will interact with other accountability expectations thatoperate within proximate competing policies. With respect to thislast point, the accountability expectations with respect to the imple-mentation of the Federal Wildland Fire Management Policy cannotbe analyzed and optimized without reference to the accountabilitydemands of the National Fire Plan and its potentially competingexpectations.

Thus it is important, when one analyzes the effects of account-ability systems on policy implementation, to scrutinize the influ-ences of such systems from two focal points—that of the policy andthat of the implementing organizations. The first is necessary inorder to align the incentives to support the attainment of policygoals and the second is necessary in order to align the potentially





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competing accountability expectations that arise from proximatepolicies and dominant organizational accountability practices. Ifplanned accountability changes are contrary to dominant account-ability systems and no adjustments are made, the likelihood is poorfor long-term success.

The fire management policy experience also illustrates howimportant it is to align the types of accountability systems and themechanisms used within the types so that the accountability systemas a whole will support policy implementation. Both are important.More appropriate alignment between political, organizational, andprofessional accountability systems within the context of firemanagement policy can remove some of the disincentives that havebeen created to this point. Concomitantly, the choice of mechanismswithin the organizational context could go a long way in sendingsignals that would reinforce the goals of the Fire ManagementPolicy.

The experience we have discussed also illustrates how incen-tives for taking risks that support policy implementation are influ-enced by accountability systems and how design and alignment ofaccountability systems are significant for managerial risk propen-sity. Organizations have responsibilities that can significantly affectmanagerial risk propensity in support of policy implementation,including the responsibility to methods for risk assessment, infor-mation to support decisions about risks, resources for risk mitiga-tion, and assessment of risk-based decisions. Organizationalactions, including those involved in the design and operation ofaccountability systems, are important for the creation of managerialincentives for taking appropriate risks. Top organizational leader-ship potentially can provide incentives in support of policy imple-mentation by providing goal clarity, trust, and rewards and penaltiesbased on policy goal attainment. We have shown that failure toaddress such incentives undermines the attainment of the goalscontained in a new policy.

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Documents

Balancing Accountability and Risk in Program Implementation: The Case of National Fire Policy