Wildfire Pay-for-Success Feasibility Study

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David Groves

March 2014

Wildfire Pay-for-SuccessFeasibility Study


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The Author David Groves is Executive Director of Private Capital for PublicGood. PCPGs mission is to establish market mechanisms thatincrease available resources for conservation programs by bringingtogether stakeholders from the public, private, and nonprofit sectors.Prior to PCPG, David earned his MBA from Presidio GraduateSchool in San Francisco. From 2004 - 2008, David spearheaded acampaign while at the Environmental Investigation Agency in Wash-ington, DC that resulted in passage of a federal law to restrict theflow of illegally-sourced wood products into the U.S. The law earned

the 2011 Future Policy Award as being the worlds best new forestpolicy. David also has a passion for animal welfare and was theDirector of an animal shelter in Montreal from 2008 - 2010. He nowregularly volunteers at a local shelter in San Francisco, CA where hecurrently resides. Contact David at [email protected]

Copyright 2014, Private Capital for Public Good, a project of the Trust for ConservationInnovation, all rights reserved. Any use of material in this work determined to be fair useunder Section 107 or that satisfies the conditions specified in Section 108 of the US CopyrightLaw does not require PCPGs permission. Republication, systematic reproduction, posting inelectronic form on servers, or other uses of this material, except as exempted above, requiresPCPGs permission or license.

Cover image and image on the following page both Copyright, U.S. Forest Service


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Table of Contents

Introduction 4Pay-for-Success (PFS) and its Application to Wildfire

Requirements of a PFS Project 5

Proven intervention

Intervention is replicable and scalable

Well defined metrics

Substantial cost savings that flow to a single entity

Funding that is inadequate or difficult to sustain

Unique Benefits of a Wildfire PFS 10

Fixed income

Broad investor base

Wildfire PFS Implementation 10

Conclusion & Key Findings 13


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Private capital dwarfs public and philanthropicresources by several orders of magnitude.However, social and environmental programsrarely create revenue and thus cannot attractprivate investors by offering a return. Therefore,they are shut out of this massive pool of poten-tial resources.

However, many social and environmentalprograms are preventative in nature, and enact-ing them now reduces future remediation costs.By determining the savings from a successfulpreventative programgenerally based onhistorical dataone can structure an invest-ment vehicle to monetize these savings.

This is what the Pay-for-Success (PFS) modelis designed to do. Project savings become therevenue that is needed to offer investors areturn, making private capital available to pre-ventative social and environmental programs.

Currently, the PFS model is being replicated

globally to address a number of social ills.However, very few have proposed utilizing PFSin a natural resources context, despite itspotential applicability.

Wildfire has historically played an important rolein maintaining healthy forest ecosystems. How-ever, due to the past centurys forest manage-ment strategy of total fire suppression, forestsparticularly in the Westare now unnaturallyblanketed in downed and small diameter trees,as seen in the image below. These act as fuelthat can turn a low-intensity ground fire into adevastating crown fire and are largely responsi-ble for the catastrophic wildfires we see today,according to the U.S. Forest Service (USFS).1The Government Accountability Office statesthat the most extensive and serious problemrelated to the health of national forests in theinterior West is the over-accumulation of vege-tation, which has caused an increasing numberof large, intense, uncontrollable, and catastro-phically destructive wildfires.2

Introduction: Pay-for-Success and its Application to Wildfire

A forest blanketed in fuel wood in the Bob Marshall Wildness Area in Montana Jake Willits

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The federal governments wildfirefighting costs have been increasing.Taxpayers spent $1.4 billion annuallyfrom 1991 to 1999, but this figure

jumped to $3.5 billion from 2002 to2012.3This trend is expected tocontinue as scientists predict thatwildfire rates in the American Westwill double by 2050 due to the effectsof climate change.4

Congress has responded to thisproblem by writing larger and largerchecks for fire suppression whileinadequately funding fire prevention.Lowe (2006) stated that the area offorestland being treated is minisculecompared to the amount of forestarea that would benefit.5Snider(2006) said that the policy of under-funding hazard reduction treatmentsdoes not represent rational economicbehavior, because funding hazardreduction would pay for itself by low-ering future fire suppression costs.6

This report analyzes the feasibility ofusing the PFS model to fund wildfireprevention projects on public land.

The report finds that a Wildfire PFSsatisfies all of the basic requirementsof a PFS project and that there aretwo additional benefits of a WildfirePFS over other PFS applications.These include 1) the ability to create afixed income vehicle and 2) a broaderinvestor base because of firms carrying theirown wildfire risk. Finally, the report broadly out-lines an implementation plan for a Wildfire PFS.

While the PFS model holds promise, it is not apanacea for attracting private capital tononmarket problems. There are several keyrequirements a project must satisfy to justifyemploying PFS over traditional financing. Thefollowing is a list of these requirements andhow they are satisfied with a Wildfire PFS.

1) Proven intervention

Investors will view a Wildfire PFS as beinghigh-risk due to its newness and correspondinglack of historical success. To minimize modelriskso that the project only carries executionriskinvestors will limit capital deploymenttoward interventions with proven track recordsof success. This is particularly important for thefirst PFS application of a natural resourcesproject, since it will attract more attention and

Requirements of a PFS Project

Before and after thinning treatment in the Blacks MountExperimental Forest in California John Ahnstead, US

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scrutiny than future projects.

Reducing hazardous fuel loads can significantlydecrease the risk of severe wildfire.7Modelscan even determine the specific amount ofwood to remove for a given site based on localconditions. Forest managers also have criteriafor determining areas to prioritize, based on thelikelihood of project effectiveness, cost peracre, proximity to high-value resources (e.g.surface water, endangered species habitat, thewildland-urban interface), proximity to millcapacity, vegetation type, precipitation rate,prevalence of invasive species, etc.8USFSdata show that when taken, preventativemeasures controlled wildfires in 87% of casesin 2011.9

To illustrate the granular level of understand-ing that forest managers have, Mason, et al.(2003) simulated various treatments in twonational forests in the Pacific Northwest, fromremoving all trees above or below a thresholdsize to removing various percentages ofbasal area per acre. The most effective treat-ment to reduce fire risk in these forests set atarget of leaving 45 feet2of basal area per

acre (BA-45) by thinning trees from smallest-to-largest in size. This moved 71% of standsinto a low-risk category and eliminated high-risk stands.10

2) Intervention is replicable and scalable

Since establishing a PFS project requiressignificant resources, interventions should bereplicable and scalable so that the first PFScan be a template for subsequent interven-tions. A successful PFS project should createthe political will for government to then scalethe intervention outright. If not, successshould at least lead to similar PFS projectsthat cumulatively create that political will.

There is nothing particularly unique or complexabout any hazardous fuel wood removal treat-ment. The process involves a determination ofthe best treatment type for a given area accom-plished via a literature review and site visit. Ateam goes into the forest to identify and markthe fuel wood to be removed. A crew thenremoves the marked fuel wood and brings themarketable material to a processing facility. Itthen may conduct a prescribed burn if condi-

tions are appropriate.The relative simplicityat least compared tomany of the social inter-ventions employed usingexisting PFSmakesthe intervention easilyreplicable.

The Healthy ForestsRestoration Act of 2003streamlined the processfor implementing hazardfuel reduction projects in

national forests. An envi-ronmental impactassessment must still beperformed under theNational EnvironmentalProtection Act, but allother permitting hasbeen simplified. Aproject could be scaledto treat as many acres

Lower Joseph Creek Restoration Project USFSin the Wallowa-Whitman National Forest

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as there is available funding, whether a WildfirePFS receives $10 million or $100 million incapital.

3) Well defined metrics

All parties must have an explicit understandingof what is being measured and the methodol-ogy used. There can be no ambiguity surround-ing what is needed to satisfy the terms of thecontract. There also needs to be sufficienthistorical data to place any metrics in context,and the intervention must be compared to acontrol to know if progress has been achieved.

Wildfire experts have done extensive firemodeling to predict local wildfire trends andbehavior based on large historical datasets.They consider a range of variables, includingfuels, wind, terrain, slope, and moisture.Experts have also produced a number of well-defined metrics to determine wildfire intensity,risk, and probability. Parties to a Wildfire PFScan use these models and metrics to mitigatetheir own risk and clearly define project suc-cess. Some examples are described below.

Since PFS is fundamentally outcomes-based, the most appropriate metric todetermine success is the rate of catastro-phic wildfire in the treated areacompared to a control area.Catastrophic wildfire is qualita-tively defined, so a PFS contractcould refer to the various typesof fire regimes as defined byBrown & Smith (2000).11Contract language could defineUnderstory Fire RegimeversusStand-Replacement Fire Regimeversus Mixed Severity FireRegimeand define acceptable

levels of each over the length ofthe contract. A third-party auditorwould evaluate the treated landand a control area after any firesoccur and compare them toensure that contract goals arebeing met.

An outcomes-based metric could be definedin varying ways. For example, since aninitial Wildfire PFS will be a pilot project, itwill only be large enough to treat a smallportion of any particular national forest.Instead of the project treating a consoli-dated area of forest, treatment couldinstead be applied to a contiguous line,strategically placed to prevent a wildfirepassing from one area into another asseen in the image below. Thus the contractcould define success such that no fireregime of a certain type shall pass throughfrom one side of the treated area to theother side over the life of the contract.

There are also treatment-based metrics theparties could use to define success. Forexample, success could be defined by howmuch forest has been converted frommoderate & high fire risk to low risk, asdetermined by the auditor. Several factorsare used to determine fire risk, including theamount of non-fire-resistant biomass peracre, how altered the vegetation composi-tion and structure is compared to its historicstate, the amount of ladder fuels present,etc. A treatment-based metric versus anoutcomes-based metric could resolvepotential conflicts during contract negotia-

A fire line across a ridge on Orleans Mountain in CA Kimberly Ba

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tions. For example, there will be tensionbetween the government wanting the con-tract length to follow natural fire intervalsand investors wanting to keep their capitalilliquid for the shortest length of time possi-ble. A treatment-based metric also reducesinvestors execution risk, since performancewould be measured by what the forestrestoration crews control (amount of acrestreated) versus what they do not (wildfire).

4) Substantial cost savings that flow to asingle entity

PFS can only work where an ounce of preven-tion is worth a pound of cure. In addition tocovering the costs of the intervention itself, PFSsavings must also yield enough to 1) provideinvestors a return that approaches a marketrate for the amount of risk, 2) cover the admin-istrative costs of executing the PFS, and 3)provide enough of a savings to taxpayers toincentivize policymakers to scale the project inthe future. Furthermore, savings must becaptured by a single entity, since distributingthem across the budgets of several governmentagencies and private sector actors wouldsignificantly complicate PFS administration.

The USFS is the federal governments primary

wildfire fighting agency, receiving 73% of theoverall federal wildfire budget in FY 2013 and77% of the fire suppression budget, specifically.To determine if a Wildfire PFS is justifiable, onemust compare USFS wildfire suppression coststo the costs of implementing preventative treat-ments.

Using conservative cost estimates, a WesternForestry Leadership Coalition (WFLC) report(2010) found that direct suppression costs forthe wildfires it studied were $262 per acre.12

Note that this figure does not include pre-suppression fixed costs, rehabilitation costs, orany indirect costs including property damage,public health costs, or environmental costs.Snider, et al (2006) supported this figure whencalculating that avoided future costs justifiesspending between $238 and $601 per acre forfire prevention measures.13

Compare this to the costs of implementing firerisk reduction treatments. Using conservativeestimatesassuming highest costs and lowestbenefitsMason, et al (2003) found that netcosts of a BA-45 treatment, for example, are$168 per acre. Note that BA-45 treatment couldactually result in positive revenue of $529 peracre (through the sale of removed timber) iflow-cost estimates are used.14

With direct suppression costs of $262 per acreand the net cost of an example fire preventiontreatment at $168 per acre, a $10 million pilotWildfire PFS could have $1 million in adminis-trative costs, offer investors a 10% return, andreduce fire risk on 48,000 treated acres, savingtaxpayers $4.5M in future fire suppressioncosts. Even if PFS administrative costs soaredto $2 million and investors demanded a 15%return, taxpayers would still save $3.6 millionvia the treatment of 38,000 acres.

The above is obviously a crude estimate, as itdoes not incorporate a risk analysis ordiscounted cash flows; however, it demon-strates that even when using conservative cost-benefit assumptions, a very high rate of return,and a considerable administrative cost, aWildfire PFS is still able to treat a sizeableamount of forestland that results in significantcost savings for taxpayers.

It is worth noting that this analysis only incorpo-rates a small percentage of the actual benefitssociety reaps from the treatment of high-riskforests. Table 1 on page 9 compares the fullsocietal costs of wildfire remediation versusprevention. Only the top lines of SuppressionCosts and Operational Costs are incorporatedinto this analysis.

The 2010 WFLC report analyzed indirect costs

of wildfiresincluding property damage, publichealth costs, and environmental costsandfound that they can range from 2 to 30 timesthe reported suppression costs, increasing truewildfire costs to $520 - $7,800 per acre. Thesesavings would be in addition to the figuresstated above and should be considered bonusbenefits of a Wildfire PFS.

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Furthermore, forest treatments result in ahigher rate of carbon sequestration, since theyprotect the remaining trees and send someharvested wood to be made into durable goods.Many treatments also improve habitat forcertain species over a forest blanketed indowned and small diameter trees, and theyimprove habitat for virtually all species over anarea that recently experienced a large crownfire.15These nonmarket benefits are also notincluded in the analysis above.

5) Funding that is inadequate or difficult tosustain

Given their complexity and cost, PFS projectsshould not be employed when traditional fund-ing mechanisms are adequate. The PFS model

is best utilized when it is difficult to scale aproven intervention due to a lack of political will.

Currently, the USFS is forced to focus almostall of its fire-related resources on suppressionand only a trivial amount on prevention. Accord-ing to a 2008 statement to Congress by fiveformer USFS Chiefs16and a 2012 Departmentof Interior (DOI) literature review,17 the reasons

for this include budget cuts, a flawed formulafor determining USFS budgetary needs, ablank check approach to funding firesuppression, and increased development in thewildland-urban interface. Keiter (2006) went sofar as to say that this fiscal arrangement hasbeen more destructive to our forests thanwildfire itself.18A capital infusion from theprivate sector could break this cycle ofmisallocated wildfire appropriations.

In the short term, Congress and the USFS areincentivized to implement a Wildfire PFSbecause of the way it eliminates operationalrisk for the USFS. If services do not meet thestandards described in the contract, the USFSdoes not pay for them. If the work is successful,opportunity costs are clearly understood anddemonstrate that the USFS has still savedmoney even after paying investors principle andinterest. It is a win-win proposition for thefederal government.

A long term implication is how a Wildfire PFSwill shine a light on the costs of wildfiresuppression versus prevention. As a result,policymakers should develop a better under-

Costs of Wildfire Remediation

Suppression Costs wages, transportation, equipment & supplies, evacuations

Property Damage structures; timber & agricultural products; cultural & historic sites;transportation, communication & energy infrastructure

Public Health Costs hospitalizations, fatalities, medical equipment, long-term health effects

Environmental Costsloss of wildlife & habitat, surface water damage & erosion, carbon emissions

soil degradation, loss of recreational opportunities, air pollution & visibility,

land rehabilitation

Additional Economic Costs lost tax revenue, lost business revenue, lost earnings by evacuees

Costs of Wildfire Prevention

Operational Costs wages, transportation, equipment & supplies, project planning

Environmental Costssmoke from prescribed burns, impacts from treatment (habitat loss, soil

compaction, damage to standing trees, road sediments) which can all be

minimized with due care

Tabl

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standing of the savings accrued when theUSFS prioritizes wildfire prevention. This couldmotivate Congress to fund fire preventionoutright, without the need of employing aWildfire PFS.

Unique Benefits of a Wildfire PFS

Fixed Income

With the emerging PFS contracts addressingsocial problemsrecidivism, chronic homeless-ness, early childcarethe source of revenue issolely from monetizing the cost savings. Theinterventions themselves do not directly gener-ate revenue. Thus investors have no opportu-

nity for regular payments on their investment,like what a traditional bond offers.

In addition to being the first to address a naturalresources problem, a Wildfire PFS can also bethe first fixed income PFS, where the sale ofwood products from forest treatmentsgenerates revenue that can be passed on toinvestors. A fixed income PFS would have thesame effect of reducing risk to investors as anyfixed income instrument, as investors would nothave to wait the length of the contract to collect

interest.

Mason, et al (2003) determined that the netrevenue (i.e. the market value of boardfeet extracted minus logging and haulingcosts) from a BA-45 treatment, forexample, could be as high as $6,240 peracre.19It is worth noting that there isconsiderable range to potential revenuestreams, based on treatment type andother factors.

Broad Investor Base

Current PFS projects have to rely on investorsthat are either interested in building a PFSmarket or have compassion for those individu-als benefitting from the intervention. While aWildfire PFS can draw upon these kinds ofinvestors, it can also attract firms with a finan-cial motivation to reduce local wildfire rates.

For example:an insurance company that holds claims onproperty near a treatment site;a firm that relies on a substantial supply ofclean water from a forested watershed;a firm with large private timber holdingsadjacent to forested public lands. (Given theamount of wildfire risk it carries, the lattertype of firm might be inclined to fund anentire Wildfire PFS.)

Instead of taking on an entirely new form offinancial risk, as would be the case for compas-sionate investors, these firms already carrywildfire risk. Investing in a Wildfire PFS mightsimply be a transfer of risk from propertyand/or forest resources to financial risk andthus would be more justifiable to executives.

Wildfire PFS Implementation

A Wildfire PFS requires five key stakeholders:

FOREST

RESTORATIOCREWS

Use capital for fo

treatments

INTERMEDIARYProvides project

management support

U.S. FOREST

SERVICEProvides payment

only if wildfire

rates decrease

3rd-PARTY AUDITORAudits wildfire rates

to provide credibility

INVESTORS

Providecapital for projects

Receive principle & interest

if wildfire rates decrease

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To attract capital from more risk averse inves-tors, some PFS structures have also includedphilanthropic agents to either guarantee aportion of the investment or be subordinateinvestors. The first natural resources focusedPFS might also require a similar structure to

adequately reduce risk for some investors.

Table 2 identifies specific organizations thatcould be party to a Wildfire PFS and includesrationale for why they would be involved. Notethat this table is a hypothetical exercise toillustrate the kinds of organizations that couldbe interested in this kind of project.

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Potential Actors Note

Investors

State Farm largest home insurer in the U.S. with 21% of market share

Swire Coca-ColaCoca-Cola bottling subsidiary serving 11 western states; has several

large bottling plants in CO, ID, & UT that rely on surrounding foreste

watersheds for clean waterPlum Creek Timber largest private land owner in the U.S.; manages 7.8M acres of forest

Rockefeller Foundationinvested in the first-ever PFS project in the UK; has spent millions

funding work to promote a PFS market in the U.S. (could either be a

investor or guaranteer)Goldman Sachs invested in the first two PFS projects in the US, in New York City and

Salt Lake City

Guaranteers

(or subordinate

investors)

Tom Steyerbillionaire former hedge fund manager who has spent millions of his

own money on political and market initiatives to reduce carbon

emissions (could either be an investor or guaranteer)National Forest

Foundationnonprofit partner of the USFS; runs a National Conservation Campai

that focuses on large-scale forest restoration projects

Service Providers

USFS and state

forest services

federal and state forest services manage their own forest restoratio

crewsWest Range Reclamation CO-based firm that has restored 90K acres of forest on public and

private landsCampbell Group vertically integrated forest management firm; manages 3.2M acres o

forestland (could be an investor or service provider)

Auditors

Ecological Restoration

Instituteindependent research branch of Northern Arizona University; condu

research on forest health, unnatural wildfire, and restoration treat-

ment strategies and techniquesGlobal Institute of

Sustainable Forestry institute that directs the Yale School of Forestrys research

GovernmentAgency U.S. Forest Service

receives 73% of the overall federal wildfire budget and 77% of the fisuppression budget

Intermediaries

Third Sector

Capital Partnersconducts PFS feasibility studies; has overseen PFS deal construction

and financing; is acting as the intermediary for several U.S.-based PF

projects

Social FinanceUK office was the intermediary for the first-ever PFS and is managing

several other PFS projects in the UK; U.S. office is managing a PFS in

and has done feasibility work for other projectsRural Technology

Initiativecould act as a forestry-specific project manager to oversee the fores

restoration crews

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Creating a Wildfire PFS will take several years,from inception to launch. (It took Social Finance-UK more than three years to develop theRecidivism PFS in Peterborough, UK.) The

discovery phase is in process by Private Capitalfor Public Good (PCPG). This phase includes:

conducting a thorough literature review,primarily to find data on direct costs ofwildfires, costs of various forest treatments,and their level of fire risk reduction;interviewing potential parties that could beinvolved in a Wildfire PFS to determine theirrespective levels of interest and compe-tency and, in the case of the USFS,lobbying decision-makers in the administra-tion and Congress to support this effort;

completing a risk assessment analysis, bycreating a financial model and running itagainst a range of scenarios; andhelping to establish informal partnershipsamong the diverse public and private sectorstakeholders to ease future negotiations.

Once the discovery phase is complete, aproject managing intermediary will take the leadon PFS administration. This work will include:

formal financial structuring and cash flow

modeling;raising capital from investors and donors;overseeing the public procurement process(if required);overseeing the hiring of forest restorationfirm(s) and auditor(s);overseeing the multiparty contract negotia-tions;overseeing the work of the forest restorationcrews;ensuring the auditing process is followingthe terms of the contract;

overseeing financial transactions

Below is a rough timeline of task implementa-tion.

Literature Review; Interviews

Risk Assessment Analysis

Stakeholder Vetting

Lobbying USFS & Congress

Partnership Formations

Financial Structuring

Capital Raising

Public Procurement Process

Contract Negotiations

Wildfire PFS Launch

Forest Restoration & Auditing

2014 2015 2016 Thru

Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 least

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Conclusion and Key Findings

We should utilize the PFS model wherever it is appropriate and not confine it to only address socialills. This study demonstrates that PFS can be used to address a natural resources-based problem:the irrational underfunding of fire prevention on public lands.

A Wildfire PFS satisfies all of the requirements to be a successful PFS project:A number of fuel wood removal treatments are proven to reduce wildfire risk, where the specifictreatment type varies based on local conditions.The treatments are both replicable and scalable.There are a number of unambiguous metrics that parties to a Wildfire PFS can use to definesuccess.Treatments result in substantial enough cost savings to the USFS to pay for the intervention, PFSadministration, a return for investors, and provide enough additional savings to taxpayers to justifyscaling future projects.The lack of political will for scaling wildfire prevention treatments justifies implementing a WildfirePFS over traditional funding mechanisms.

Furthermore, a Wildfire PFS has two additional benefits that PFS programs addressing socialproblems do not:

Hazardous fuel reduction treatments can create a stream of revenue to create a fixed income (i.e.lower risk) instrument for investors.Raising capital for a Wildfire PFS could be easier than for a socially-based PFS project as manyfirms carry their own wildfire risk.

For questions regarding this report or how the PFS model can be applied to wildfire prevention,please contact David Groves at [email protected].

Endnotes

1 U.S. Forest Service. (n.d.) Fire and Fuels Buildup position paper.2 U.S. Government Accountability Office. (2000). Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wild-

fire Threats.3 Gorte, R. (2013). The Rising Cost of Wildfire Protection. Headwaters Economics.4 Liu, Y. et al. (2013). Wildland Fire Emissions, Carbon, and Climate: WildfireClimate Interactions. Forest Ecology and Management.5 Lowe, K. (2006). Effects of forest thinning treatments on fire behavior. Northern Arizona University, Ecological Restoration Institute.6 Snider, G. et al. (2006). The Irrationality of Continued Fire Suppression: An Avoided Cost Analysis of Fire Hazard Reduction Treatments

Versus No Treatment. Journal of Forestry.7 Lowe, K. (2006). Effects of forest thinning treatments on fire behavior. Northern Arizona University, Ecological Restoration Institute.8 U.S. Dept. of the Interior, Office of Policy Analysis. (2012). Wildland Fire Management Program Benefit-Cost Analysis: A Review of Rele-

vant Literature.9 Healy, J. (2013). Cost of Battling Wildfires Cuts into Prevention Efforts. The New York Times.10 Mason, L. et al. (2003). Investigation of alternative strategies for design, layout and administration of fuel wood removal projects. Rural

Technology Initiative, University of Washington.11 Brown, J. & Smith, J. (2000). Wildland fire in ecosystems: effects of fire on flora. General Technical Report. Rocky Mountain ResearchStation, USFS.

12 Western Forestry Leadership Coalition. (2010). The True Cost of Wildfire in the Western U.S.13 Snider, G. et al. (2006). The Irrationality of Continued Fire Suppression: An Avoided Cost Analysis of Fire Hazard Reduction Treatments

Versus No Treatment. Journal of Forestry.14 Mason, L. et al. (2003). Investigation of alternative strategies for design, layout and administration of fuel wood removal projects. Rural

Technology Initiative, University of Washington.15 ibid.16 Peterson, R. et al. 2008. Statement of Five Retired Chiefs of the Forest Service, On the FY2008

Appropriation for the U.S. Forest Service.17 U.S. Dept. of the Interior, Office of Policy Analysis. (2012). Wildland Fire Management Program Benefit

-Cost Analysis: A Review of Relevant Literature.18 Keiter, R. (2006). The Law of Fire: Reshaping public land policy in an era of ecology and litigation.

Environmental Law.19 Mason, L. et al. (2003). Investigation of alternative strategies for design, layout and administration of

fuel wood removal projects. Rural Technology Initiative, University of Washington.
mailto:[email protected]:[email protected]:[email protected]

Wildfire Pay-for-Success Feasibility Study

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