An Initial Review of the Regional Forest and Fire Capacity Program

An Initial Review of the Regional Forest and Fire Capacity Program GABRIEL PETEK | LEGISLATIVE ANALYST DECEMBER 2021 AN LAO REPORT LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT Executive Summary State Established Regional Forest and Fire Capacity (RFFC) Program to Support Greater Regional Coordination Regional Coordination Is Important. Wildfires in California have become increasingly large and destructive over the past couple of decades. Implementing effective strategies to increase protection and resilience against these wildfires is complex, in part due to the wide range of entities responsible for managing lands across the state, including local, state, and federal agencies; tribes; small private landowners; and timber harvest companies. Successfully implementing forest health and wildfire mitigation projects often requires public and private entities to work together, particularly in order to complete larger, more complex and cross-jurisdictional projects than if they work independently. RFFC Grants Support Planning and Coordination. The state created RFFC in 2018 to support regional collaboration for forest health and wildfire resilience by providing block grants to various entities, each covering a different part of the state. (The program also provides some grants to entities that provide technical support throughout the state.) Regional grant recipients are engaged in a wide array of activities, including developing regional priority plans; permitting and developing projects; implementing demonstration projects; and conducting outreach, education, and training. In total, the program has received $130 million in one-time appropriations, including $60 million in the 2021-22 budget. To date, RFFC has awarded two rounds of funding totaling $70 million. The program is administered by the Department of Conservation (DOC). While Promising, RFFC Faces Some Challenges to Success RFFC Is a Promising State Effort to Support Regional Coordination. Based on our review of the activities undertaken to date, as well as our conversations with grantees, we find that the initial activities funded by RFFC have been consistent with the intended goals of the program— supporting regional collaboration for forest health and wildfire prevention activities. The program has supported valuable activities that would not have happened otherwise, including outreach to and collaboration efforts with regional partners. In addition, RFFC has provided technical assistance and support that have been important in facilitating learning, sharing best practices, and improving technical expertise among local entities. Lack of State Requirements on Regional Priority Plans Has Led to a Disjointed Approach. Although RFFC guidelines provide criteria that grant recipients must consider when prioritizing projects, the guidelines do not specify how these criteria should be weighed against one another, nor do they give direction on how projects should be assessed on these factors. Without a consistent set of criteria or requirements to guide the plans, it is difficult to assess whether the final plans developed will be aligned with state priorities in improving the pace and scale of forest management activities at the regional level, or will be the most effective at achieving state goals for forest health and wildfire prevention. Limited Data Collection and Reporting Make it Difficult to Evaluate Program. Currently, DOC is not required to nor does it plan to evaluate the effectiveness of the program. The absence of program evaluation makes it difficult for the Legislature to (1) hold DOC accountable www.lao.ca.gov 1 AN LAO REPORT for achieving programmatic goals that reflect legislative priorities and (2) make future funding and policy decisions for the program. In addition, the absence of data collection and regular reporting could affect how well DOC is able to administer the program, including how the department uses technical assistance, data, and information on best practices in the future to support the grantees. Unclear Whether Definition of Regions Is Optimal and Comprehensive. Regional grantees cover areas that vary in size by tens of millions of acres and it is unclear whether the resulting geographic regions are the most strategic in size—neither too large nor too small—to effectively meet program goals. In addition, not all areas in the high severity fire zones are currently covered by RFFC grants. Uncertain How Priority Plans Will Be Implemented. Once projects have been identified and prioritized by these regional collaboratives, it is unclear how these projects will acquire the necessary funding for implementation. At both the local and state levels, the available funding will likely not be sufficient to meet all project needs in the future. In addition, regional grantees reported two specific staffing challenges—a limited forestry workforce and insufficient staffing capacity dedicated to implementing regional coordination activities—that could further hinder the implementation of regional priority plans. Recommendations to Improve Program Outcomes and Oversight Short-Term Recommendations. We recommend a few more immediate actions for the Legislature to take to improve RFFC program outcomes and oversight. • Create State Requirements for Regional Priority Plans. To support greater alignment of regional priority plans with state priorities across regions, we recommend the Legislature adopt statutory language to (1) define which types of projects should be prioritized and (2) require DOC to set state standards for regional priority plans consistent with those priorities. • Adopt Evaluation and Reporting Requirements. To assess how well RFFC is meeting its objectives, we recommend the Legislature direct DOC to develop an evaluation of RFFC, culminating in a regularly published report assessing how well the program is meeting state priorities. More specifically, this evaluation should regularly assess RFFC in three aspects— processes, deliverables, and outcomes. Long-Term Recommendations. We recommend several actions that could be implemented in a few years after the program is more established and the Legislature knows more about the program’s outcomes. • Align Forest Health and Wildfire Prevention Funding With Regional Priority Plans. If grantees complete regional priority plans that consistently align with state priorities, the Legislature might want to consider either (1) requiring that state departments prioritize high-ranking projects from the plans when awarding grants in existing forest health and wildfire prevention programs or (2) creating a new program specifically to fund the implementation of high-priority projects identified in the regional plans. • Consider Ongoing Funding for RFFC. In the long term, the Legislature might want to consider ongoing funding for RFFC activities based on the value of the regional priority plans and the outcomes of future program evaluations. Ongoing funding could support regular updates to the plans, as well as coordination staffing, outreach, education, training, demonstration projects, project planning, and workforce development. 2 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT INTRODUCTION In recent years, as wildfires have increased in grant recipients coordinate with and distribute severity and damage, the Legislature has shown funds to partnering entities within their regions. growing interest in state support of wildfire We prepared this report to provide an early prevention efforts, including regional planning for review of RFFC’s implementation. We begin by forest health activities. The Regional Forest and providing background on the purpose and intent Fire Capacity program (RFFC)—created in 2018— of RFFC, as well as how RFFC is funded. Next, provides non-competitive block grants to state we discuss both the promise and key limitations conservancies, resource conservation districts, of the program. We conclude by recommending and other entities to facilitate regional coordination short- and long-term steps the Legislature could for forest health and wildfire resilience. These take to improve RFFC outcomes and oversight grants are intended to support regional planning, to better ensure that the program successfully project development, demonstration projects, and achieves state objectives. community outreach. To implement these activities, BACKGROUND ON RFFC Regional Coordination Is Important for nearly 40,000 structures, took 148 lives, and charred millions of acres. Forest Health and Wildfire Resilience Forest Health and Wildfire Resilience Wildfires Are Increasingly Destructive. Is a Regional Issue. Management of these California consists of a wide range of landscapes, wildfire-prone landscapes generally involves from conifer forests to chaparral, that are activities, such as timber harvesting (specifically increasingly wildfire prone due to a variety of for forests), vegetation thinning (clearing out factors. Some of these factors include increasing heat and drought patterns influenced by climate change, Figure 1 greater development in Largest and Most Destructive wildlands, and past wildfire Wildfires Have Occurred in Recent Decades suppression practices that have led to excess vegetation. Such conditions have contributed 9 to more destructive wildfires 8 20 Largest in recent years. As shown 7 20 Most Destructive in Figure 1, the largest and 6 most destructive wildfires 5 in California’s recorded 4 history have occurred in 3 recent decades, and 13 of 2 the 20 most destructive 1 wildfires (as measured by the numbers of structures lost) 1930s 1940s 1950s 1960s 1970s 1980s 1990s 2000s 2010s 2020sa have occurred in the last four years. These 13 fires destroyed a Includes wildfires that occurred in 2020 and 2021 (through November). www.lao.ca.gov 3 AN LAO REPORT small trees and brush), and reforestation (planting centralized, coordinated approach to working on new trees). Management responsibility is often forest management and wildfire resilience across aligned with land ownership. As shown in jurisdictions. Because a centralized state structure Figure 2, a mix of entities own and manage these has not existed, regional collaboration has occurred lands throughout the state, including federal, on an ad hoc basis, and is further developed in state, and local governments, as well as private some parts of the state than others. For example, landowners, such as industrial timber harvesters, the Sierra Nevada Conservancy’s (SNC) Watershed individuals, conservation and natural resource Improvement Program brought together seven organizations, and tribes. partnering organizations and eight forest Due to the wide range of entities responsible collaboratives to found the Tahoe-Central Sierra for managing lands across the state, regional Initiative (TCSI) to scale up forest management collaboration is often necessary for effective projects in the region. To date, TCSI has secured protection and resilience against wildfire damages. $32 million for forest health projects in order to thin For example, unhealthy forest conditions, with fewer 20,000 acres, remove 164,000 tons of biomass, larger and older trees and more small trees and and implement 8,000 acres of prescribed fire brush, result in increased risk of severe forest fires across ownerships and jurisdictions. in not only the parcel of land with the poor forest However, not all parts of the state have these health conditions, but also the surrounding areas. regional collaboratives due to a variety of factors. Therefore, improvements on one parcel of land will Based on our conversations, some key barriers not significantly reduce the broader fire risk if the to regional coordination include the existence of surrounding parcels continue to have overly dense few natural resource organizations focused on and unhealthy conditions. In addition, collaboration forestry and wildfire issues in some parts of the has the potential of increasing the pace and scale state, limited funding dedicated to forest health of forest health projects. By working together, and wildfire resilience project development, and public and private entities can have greater capacity under-resourced planning and project development to work on larger, more complex projects than if staff dedicated to forestry projects. In particular, they work independently. regional coordination for forest health and wildfire Few Formalized State Governance Structures resilience historically has been less developed in for Regional Coordination. There are a few parts of Southern California compared to the North examples of collaborations between various entities Coast and the Sierra Nevada region. on forest health projects. For example, the state State Has an Interest in Effective Regional can fund and implement forest health projects on Coordination. Local entities share a common goal federally owned land under the “Good Neighbor in regional coordination for forest management Authority,” a policy that allows the U.S. Forest and wildfire resilience—healthier, more resilient Service to enter into agreements with state landscapes that can reduce the severity of future forestry agencies. However, there is no formalized wildfires and their damage to communities and state governance structure to support regional watersheds in their jurisdictions. The state also has collaboration on forest health and wildfire resilience an interest in the success of collaboration in these that include all the relevant actors, including but not local communities, as effective implementation limited to city and county governments, resource of regional scale forest health projects increases conservation districts, conservancies, fire safe public safety and lessens the demand for state councils, private landowners, as well as state services. The California Department of Forestry and and federal agencies. Instead, the existing efforts Fire Protection (CalFire) holds primary responsibility generally are either project-specific or limited to for wildfire response for about 13 million acres certain regions in the state. across the state. As wildfires have increasingly Historically, there has not been an entity become more destructive in recent years, the responsible at the state level to facilitate such state has concurrently incurred higher costs to regional coordination, and the state has lacked a respond to wildfires. For example, as shown in 4 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT Figure 2 Patchwork of Owners Across California Forestlands Federal government State and local governments Private industrial Private nonindustrial Hewes, Jaketon H.; Butler, Brett J.; Liknes, Greg C. 2017. Forest ownership in the conterminous United States circa 2014: distribution of seven ownership types - geospatial dataset. Fort Collins, CO: Forest Service Research Data Archive. https://doi.org/10.2737/RDS-2017-0007. www.lao.ca.gov 5 AN LAO REPORT Figure 3, CalFire’s cost of providing fire protection and initially funded RFFC with a one-time is estimated to be roughly $2.9 billion in 2020-21, appropriation to the California Natural Resources a significant increase from $750 million in 2005-06. Agency of $20 million from the Greenhouse Gas In addition, the state has paid billions of dollars in Reduction Fund. The agency then directed the recent years to assist in the cleanup and recovery Department of Conservation (DOC) to administer from devastating wildfires. To the extent that local the program. As discussed in more detail below, and regional efforts can effectively reduce wildfire DOC allocated this funding to grantees in six risks, the state is likely to spend less in the long run regions, as well as to two other grantees providing for wildfire response and recovery. technical assistance statewide. More recently, the program received General Fund augmentations of RFFC Established in 2018-19 Budget $50 million in 2020-21 (as a mid-year augmentation) Established to Support Regional Planning and $60 million in 2021-22. The additional and Coordination for Forest Health. RFFC was funding in 2020-21 was intended to expand the created in 2018 with the primary goal to restore program to areas that did not receive grants in health and resilience to forests at the regional the first round, as well as continue activities in scale. As described above, the emphasis on regions that received funding in the first round. regional activity is in recognition that wildfires and The administration has not yet specified how the forest health are by nature, a regional issue that funding provided in the 2021-22 budget will be crosses jurisdictional boundaries. Because there utilized, but it expects to allocate the funds over the is no formalized approach to regional coordination next several years. across the state, this program is intended to RFFC Recently Set in Statute. Chapter 225 support and expand regional collaboratives in the of 2021 (AB 9, Wood) establishes RFFC in statute, few places where they already exist, as well as to primarily maintaining the existing program. (While develop new regional collaboration in areas where the program was funded in the budget prior to the it is missing. To do so, the program provides block enactment of this legislation, it was not previously grants to a few local entities to coordinate and established in statute.) The new law reiterates facilitate collaboration within their region. Under the purpose of the program to increase regional the program guidelines, each grant recipient is leadership and capacity to identify, prioritize, and expected to develop—in collaboration with regional implement projects to increase wildfire resilience partners—regional priority plans for forestry, fire and improve forest health. It also expands some protection, and forested watershed improvements. of the program’s objectives, guidelines, and These regional priority plans will be public documents intended to Figure 3 identify and prioritize projects at the landscape or watershed-level Spending on Wildfire Response to address forest health and (In Millions) wildfire risks within their region. In addition, grantees are expected to $4,000 complete permitting for projects 3,500 that address regional forest and 3,000 fire protection priorities; implement 2,500 demonstration projects; and 2,000 Emergency conduct outreach, education, and Fire Suppression 1,500 training necessary to facilitate 1,000 regional coordination and planning. 500 Base Fire Protection Program Funded by One-Time Appropriations. In the 2018-19 2005-06 2007-08 2009-10 2011-12 2013-14 2015-16 2017-18 2019-20 2020-21 budget, the Legislature established 6 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT requirements. For example, a recently added federal grants, legal support for Prescribed Burn objective of the program is to create fire adaptive Associations (PBAs), and facilitation of regional communities by prioritizing projects that maximize learning and collaboration. risk reductions to people and property, especially In the second round of funding, DOC plans to in the most vulnerable communities. In addition, utilize $2 million to augment the amount provided DOC is now directed to provide RFFC block grants to the Watershed Research and Training Center to regional entities to cover every part of the state for statewide technical assistance and a total that contains or is adjacent to a very high or high of $5 million for three new statewide efforts. fire hazard severity zone. Chapter 225 also includes This includes funding for (1) training for PBAs some new program reporting requirements, and developing the prescribed burn workforce including for DOC to report on its website the list across the state; (2) supporting the Intertribal of grant recipients, outcomes of the grants, and a Indigenous Stewardship Project, a tribal-led description of progress towards ensuring all very organization to support tribal capacity building high or high fire hazard severity zone areas are and demonstration fire resilience projects; and covered by the program. (3) providing direct grants to smaller, financially disadvantaged communities. In addition, DOC Initial Grants Support has set aside $5 million for “opportunity funding” Statewide and Regional Activities that it will allocate at a later date, depending on Initial Funding Allocated in Two Rounds. To identified needs, as well as $2.5 million for program date, RFFC has awarded two rounds of grants. administration. Figure 4 on the next page provides In the first round of funding, DOC provided a more information on all of the statewide initiatives. total of $20 million, including $14.3 million to six Regional Grant Recipients. As shown in regional grantees—each covering a different part Figure 5 on the next page, DOC has awarded of the state—with the remainder supporting two a total of $49.8 million in grants to ten regional statewide grant recipients, DOC administration entities. Six of the grantees received funding in both costs, and forest and watershed restoration rounds of RFFC grants, while the other four have projects targeted at the drainages that supply the received only second round grants. Oroville, Shasta, and Trinity Reservoirs consistent Regions Differ in Size, Ecology, and with Chapter 638 of 2018 (AB 2551, Wood). More Existing Capacity. Figure 6 on page 9 shows the recently, DOC announced that of the $50 million geographic boundaries of the ten regional grant provided in 2020-21, $26.3 million will augment recipients. As shown in the figure, these grantees the funding provided to the six previous regional are responsible for implementing RFFC activities grant recipients, and $9.3 million will support in regions of varying size across the state with four new regional grant recipients. The remaining some regions being much larger than others. $14.5 million is going towards statewide initiatives For example, the region that SNC covers includes as well as program administration. about 25 million acres, whereas the Lake Tahoe Statewide Initiatives. In the first round of Conservancy covers about 320,000 acres. Besides funding, DOC provided $3.6 million for grants to size, regions also differ in the types of ecological two statewide entities—the California Fire Safe landscapes they encompass. Across the state, Council and the Watershed Research and Training landscapes vary from chaparral and woodlands, Center—as well as for DOC administrative costs. consisting of smaller shrubs and scrub oak The California Fire Safe Council provides technical trees, to mixed confiner forests, which include assistance to local fire safe councils, supporting the a variety of taller pine, cedar, and fir trees with development of fire safe councils where they are shrubs in the understory. Grant recipients in the absent and facilitating learning between fire safe northern parts of the state tend to have a larger councils across the state. The Watershed Research concentration of conifer forests and other types of and Training Center supports the regional grantees forestlands, whereas grant recipients in Southern and subgrantees with technical assistance, California cover regions with more chaparral including assistance applying for state and and woodlands landscapes. www.lao.ca.gov 7 AN LAO REPORT Figure 4 Statewide RFFC Initiatives (In Millions) First Round Second Round Purpose Description Grant Grant Total Fire Safe Council California Fire Safe Council provides technical assistance to $1.6 — $1.6 Support local fire safe councils, as well as support development of fire safe councils and facilitate learning between fire safe councils across the state. 1.3 $2.0 3.3 Statewide Technical Watershed Research and Training Center supports regional Assistance grantees and subgrantees with technical assistance, including grant writing assistance, legal support for prescribed burn associations, and facilitation of regional learning and collaboration. 0.7 2.5 3.2 DOC Administration Program administration. — 5.0 5.0 Opportunity Funding Funds available to allocate at a later date, depending on identified needs. — 3.0 3.0 Prescribed Burn Watershed Research and Training Center provides training, Association technical support, and funding opportunities for Prescribed Support Burn Association development across the state. — 1.0 1.0 Intertribal Indigenous Supports tribal-led organization for tribal capacity building and Stewardship fire resilience demonstration projects. Project — 1.0 1.0 Disadvantaged Direct grants to smaller, disadvantaged communities. Communities Direct Grants Totals $3.6 $14.5 $18.1 RFFC = Regional Forest and Fire Capacity program and DOC = Department of Conservation. Figure 5 Regional RFFC Grantees (Dollars in Millions) Size of Region First Round Second Round Organization (Acres) Granta Grant Total State Coastal Conservancy 11,726,089 $4.0 $8.9 $12.9 Sierra Nevada Conservancy 25,000,000 1.9 7.8 9.7 North Coast Resource Partnership 12,160,000 4.0 3.0 7.0 Santa Monica Mountains Conservancy 887,124 1.4 2.2 3.6 Inland Empire Resource Conservation District 823,390 1.4 2.2 3.6 Resource Conservation District of San Diego County 1,847,300 1.4 2.2 3.6 Napa County Resource Conservation District Coalition 850,672 — 3.0 3.0 Tehama County Resource Conservation District Coalition 4,166,000 — 3.0 3.0 Irvine Ranch Conservancy 470,000 — 2.2 2.2 Lake Tahoe Conservancy 320,640 — 1.1 1.1 Totals 58,251,215 $14.3 $35.5 $49.8 a In addition to these amounts, $2.1 million is dedicated for forest and watershed restoration investments for the drainages that supply the Oroville, Shasta, and Trinity reservoirs in accordance with Chapter 638 of 2018 (AB 2551, Wood). RFFC = Regional Forest and Fire Capacity Program. 8 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT Figure 6 Map of RFFC Grantees North Coast Resource Partnership Tehama County RCD Coalition Napa Lake Tahoe Conservancy County RCD Coalition Sierra Nevada Conservancy State Coastal Conservancy Inland Empire RCD Santa Monica Mountains Conservancy Irvine Ranch Conservancy RCD of San Diego County RFFC = Regional Forest and Fire Capacity program and RCD = Resource Conservation District. www.lao.ca.gov 9 AN LAO REPORT Regions additionally differ in existing capacity Each Region Has Taken Different Approach for regional coordination around forest health and to Regional Planning and Coordination. As wildfire resilience. For example, some grantees— shown in Figure 7, grant recipients are spending most notably, SNC and North Coast Resource RFFC funding for a wide array of activities. Funding Partnership (NCRP)—had existing regional is generally being used for the following categories collaboration programs prior to RFFC. Therefore, of activities: developing regional priority plans; these grantees already have more experienced permitting and developing projects; implementing staff, further developed coordination governance demonstration projects; and conducting outreach, structures, and greater expertise implementing education, and training. Even within the same regional forest management and wildfire prevention category of activities, regions are taking different projects. Other regions are in the beginning stages approaches. For example, grant recipients need of coordination and collaboration related to regional different types of resources and support in wildfire resilience. For example, the Inland Empire developing their regional priority plans. Santa Resource Conservation District (IERCD) has done Monica Mountains Conservancy is spending significant collaborative work in other aspects of some of its block grant towards hiring an external natural resources, such as land conservation, but consultant to help develop its regional priority their work in facilitating regional collaboration on fire plan, collecting projects from existing plans, and prevention is still nascent. Grantees that have not compiling best management practices for the historically coordinated regionally for fire prevention region. Alternatively, IERCD is acquiring geospatial and preparedness work typically have less staff data and aerial imagery of its region to help assess with expertise in forestry and wildfire issues, and plan fuel reduction projects more efficiently. fewer resources for planning and implementing As another example, project development forest health projects, and less developed existing and permitting activities varies across grantees, governance structures for broader regional ranging from developing a template for permitting coordination. fuel management projects to providing technical assistance for environmental impact analyses for Grantees Undertaking Varied forest health projects. Grantees further diverge on Activities With Initial RFFC Funds the number and types of demonstration projects Program Provides Flexible Funding to implemented, depending on the need for and Address Regional Needs. Recognizing the capacity to implement demonstration projects. All different needs of grantees, DOC has intentionally grantees are implementing some demonstration made the RFFC block grants flexible in how projects—mainly for vegetation management, forest they can be used. There are some minimum restoration, and prescribed burns—to test newer requirements that all grant recipients must fulfill, techniques and methods that could potentially be such as developing a regional priority plan. scaled up. In total, RFFC block grants have funded Otherwise, there are few restrictions on how the 32 demonstration projects across the first six funding can be used. As a result, grant recipients funded regions. Additionally, grantees are using have been able to use the funding to target the their funding to implement different outreach, highest priority staffing, planning, education, education, and training activities, such as training workforce, or other needs of their regions. programs for cultural burning and community outreach events related to home hardening and wildfire safety. 10 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT Figure 7 Types of Activities Funded by RFFC (In Millionsa) Developing Permitting and Implementing Conducting Outreach, Regional Priority Plans Developing Projects Demonstration Projects Education, and Training State Coastal Conservancy $11,729,749 Sierra Nevada Conservancy $7,520,000 North Coast Resource Partnership $6,225,400 Inland Empire RCD $3,625,000 Santa Monica Mountains Conservancy $3,625,000 RCD of San Diego County $3,550,000 Napa County RCD Coalition $2,507,041 Tehama County RCD Coalition $2,020,000 Irvine Ranch Conservancy $2,000,000 Lake Tahoe Conservancy $1,090,000 1 2 3 4 $5 1 2 3 4 $5 1 2 3 4 $5 1 2 3 4 $5 a These amounts do not include program administration and overhead costs. RFFC = Regional Forest and Fire Capacity and RCD = Resource Conservation District. FINDINGS In this section, we discuss the findings from our making it difficult to assess whether the resulting review of RFFC. Notably, we find that the initial activities plans will be aligned with state goals and priorities. In funded by RFFC have been consistent with the intended addition, we find that RFFC has limited data collection goals of the program—supporting regional collaboration and reporting, making it difficult to evaluate the for forest health and wildfire prevention activities. program. Finally, there is uncertainty about whether the However, we find that regional priority planning—one of boundaries of the regions are optimal and how projects the primary RFFC activities—varies significantly across prioritized through the regional collaboration efforts grantees due to a lack of specific state standards, funded by RFFC will be implemented. www.lao.ca.gov 11 AN LAO REPORT RFFC Is a Promising State Effort to Lack of State Requirements on Support Regional Coordination Regional Priority Plans Has Led As mentioned earlier, regional collaboration to a Disjointed Approach and planning is important for effective forest DOC Provides Prioritization Criteria, but management. Coordination across jurisdictions Limited Direction. As noted above, all RFFC grant helps ensure forest management activities are recipients are expected to develop regional priority occurring region-wide, and collaboration has plans intended to identify high-priority forest health the potential to increase the pace and scale of and wildfire prevention projects within the region. implementing forest health and wildfire prevention As shown in Figure 8, RFFC guidelines provide projects in the state. By working together, ten key criteria that grant recipients must consider local entities can increase their capacity to when prioritizing projects, such as high wildfire risk implement larger, more complex projects than to neighboring communities. While these criteria would be possible working alone. Based on our provide some guidance to grantees, the guidelines conversations with grant recipients, the program do not specify how these criteria should be weighed is helping to facilitate regional coordination in against one another, nor do they give direction on forest management and wildfire prevention. For how projects should be assessed on these factors. example, in interviews, every organization that For example, the criteria prioritize work both in received block grants in the first round of funding areas with high habitat values at risk and to address reported that RFFC funding has supported valuable reforestation needs after high mortality events, activities that would not have happened otherwise, but the guidance does not specify how projects including outreach to and collaboration efforts with targeted towards these different criteria should be regional partners, as well as the planning for and compared. Moreover, the guidance does not define development of new regional forest health projects. what constitutes vulnerable habitats. According to In addition, several grant recipients reported the administration, this flexibility is intentional, given in interviews that the technical assistance and that grant recipients are all operating with different support provided by the statewide grant recipients expertise, capacity, and experience, as well as have been important in facilitating learning, sharing varying local and regional needs. For example, best practices, and improving technical expertise. the guidelines state that each grant recipient In particular, RFFC’s work in supporting regional should incorporate the criteria “into their plans as coordination in areas where it historically has not appropriate for their region.” occurred is valuable, in that it helps develop a structure for regional Figure 8 coordination in more fire-prone Current Regional Priority Plan Considerations areas of the state, not just in the areas with existing regional • Areas that contribute to high wildfire risk faced by adjacent or nearby communities. • Forests projected to be at risk due to climatically driven stressors. collaboratives. For example, the • Forests at greatest risk to high-severity mortality events (for example, fire or insect latest funding allocation from outbreak). RFFC has accelerated regional • Forests at high risk of type conversion (for example, forest to shrub or grass vegetation). coordination in Napa, Tehama, • Areas with high habitat values at risk, such as spotted owl activity centers. and Orange Counties, supporting • Headwater areas that provide significant water supply. local Resource Conservation • Areas that need to be reforested after high mortality events. Districts with funding and technical • Forests at risk of conversion to other uses, including development and agriculture. • Opportunities for follow-up “maintenance” treatments via prescribed fire or other fuels assistance to start partnerships reduction techniques. with other local entities. • Availability of adequate workforce and infrastructure to complete projects. 12 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT DOC is currently working on creating a more approaches can be more complex. For instance, specific framework for the regional priority plans, NCRP is first developing a comprehensive list of called the Resilience Pillars. This is based on a forest health and fuel reduction projects in their framework developed by the TCSI, which assesses, entire region, from existing plans, interviews with prioritizes, and evaluates forest health projects partnering agencies, and request for proposals. in the Tahoe-Sierra region. According to DOC, Then, NCRP is evaluating projects using a the Resilience Pillars is expected to set desired data-driven tool incorporating geospatial data outcomes in various ecological areas, such as analysis and modeling. forest health, fire adaptation of communities, Third, grantees differ in their use of priority wetland integrity, among other categories. There ranking. Some partner agencies within regions would be a central state framework, with slight ranked all of their identified priority projects regional adaptations. However, the work is still numerically or in tiers. In other cases, neither the early in development, and many details are not RFFC grantee nor their partner agencies identified yet available, including when it will be completed, any prioritization of the projects in their regional what additional guidance will be provided, and how priority plan. This is in part due to the challenges stringent the guidance will be. of coordinating with many entities with different With Limited State Direction, Regions Are priorities. Without specific authority or state Taking Different Approaches. Most grantees that direction on how to prioritize projects, some grant received funding in the first round have reported recipients reported that it is difficult to come into they are well underway in developing regional agreement with all involved partner agencies on priority plans. However, our review finds that they how to rank or prioritize some projects over others all differ in a few important ways regarding their in their regional priority plans. approach to developing the plans and prioritizing Fourth, grantees vary in when they expect projects. First, grantees differ in how they are to complete their regional priority plans—those identifying priority projects to include in their plans. receiving grants in the first round reported their In interviews, some grantees reported that their expected completion dates range from the end regional priority plans are simply compilations of of 2021 to 2024. RFFC does not have a required project lists provided by their partner agencies deadline for completed regional priority plans. within the region, which include state and Different Approaches Could Result in Plans federal agencies, special districts, tribes, and Inconsistent With State Priorities. As a result private landowners. Other grantees are using a of the different approaches being used by RFFC more centralized prioritization process. In these regional grantees, priority plans could vary in cases, grantees assess and prioritize projects usefulness from the state’s perspective. Without submitted by partner agencies for inclusion in the a consistent set of criteria or requirements to regional priority plans. guide the plans, it is difficult to assess whether Second, grantees range in the complexity the final plans will be aligned with state priorities in of their prioritization approaches. In cases improving the pace and scale of forest management where prioritization is decentralized, the partner activities at the regional level, or will be the most agencies identified and prioritized projects effective at achieving state goals for forest health independently before submitting them for inclusion and wildfire prevention. In particular, the absence in the regional plans, using different factors to of clearer direction on how to prioritize projects and determine which projects should be a priority. differing regional approaches create the possibility For example, grantees reported some partner that some of these plans will mainly consist of agencies prioritize projects based on their projects with smaller scale benefits, instead of readiness for implementation, whereas others larger, cross-jurisdictional projects that are more prioritize based on risk to communities. Other likely to yield the greatest regional benefits. www.lao.ca.gov 13 AN LAO REPORT Limited Data Collection and Reporting in nature. More recently, Chapter 225 added a Make it Difficult to Evaluate Program requirement that DOC report a list of the program’s grantees, a summary of funding outcomes, and Regional Coordination Is Difficult to Assess. progress towards covering all high or very high The intended goals of RFFC—as administered severity fire zones in the state. While this will be by DOC and articulated in Chapter 225—are to helpful and add information useful for legislative support regional coordination for the development, oversight, it does not require the inclusion of prioritization, and implementation of strategies specific data to show program effectiveness. to improve ecosystem health, community wildfire Lack of Robust Program Oversight Presents preparedness, and fire resilience. It is difficult to Multiple Problems. The absence of program assess whether the activities currently funded by evaluation makes it difficult for the Legislature to the program are meeting such goals for a couple hold DOC accountable for achieving programmatic of reasons. First, RFFC is still in early stages of goals that reflect legislative priorities. In particular, implementation making it premature to determine without adequate reporting, the Legislature has whether the program is effective. Only two rounds insufficient information to determine how well the of grants have been awarded to date, with the funded activities are meeting—or not meeting— latest round allocated in the summer of 2021. Also, the program’s objectives to promote and support coronavirus disease 2019 has disrupted some regional collaboration and planning. collaboration activities, such as education and outreach events, and delayed implementation of In addition, having only limited information demonstration projects. Consequently, regions on program outcomes makes it more difficult to are not as far along as they might otherwise be in make future funding and policy decisions for the implementing the program. Second, it is difficult to program. For example, additional information on evaluate whether the program has been effective program efficacy would be helpful in determining in meeting its goals because regional coordination any additional or ongoing funding for the program, is inherently difficult to quantify and measure. as the Legislature weighs the merits and costs of Performance measures typically used in state level the program compared to other potential policies to forestry and wildfire resilience programs, such as support forest health and wildfire resilience in the acres treated, are not as relevant to RFFC, because state. If the program is shown to be successful in the program is primarily supporting planning facilitating regional coordination, it strengthens the and coordination activities, not implementation rationale to continue or expand funding for RFFC. of projects. Instead, alternative performance Alternatively, if the program is not meeting its goals, measures, data collection, and reporting would be the Legislature might consider altering components necessary to assess the effectiveness of RFFC. of RFFC to improve outcomes. No Evaluation Plan or Reporting Requirement In addition, the absence of regular reporting for RFFC. Currently, DOC is not required to nor could affect how well DOC is able to administer does it plan to evaluate the effectiveness of the the program, including how the department program. DOC has published summary reports uses technical assistance, data, and information on funded activities through one of its statewide on best practices to support the grantees to grantees, the Watershed Research and Training reach the program objectives. For example, if Center. Although these reports provide descriptive grantees are struggling with achieving meaningful summaries of activities, they do not assess the participation from a wide range of stakeholders— degree to which activities are tied to program such as smaller, more financially disadvantaged objectives or whether the program is effective in communities—in their collaborative planning meeting its goals. For example, these reports do process, DOC could provide best practices for not include objective and measurable data showing governance structures that are inclusive in their how the program is improving regional capacity decision-making processes or technical assistance to prioritize, develop, and implement forest health to help facilitate more proactive engagement of projects. Instead, the reports are more narrative targeted communities. In this way, this reporting 14 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT would help inform and improve DOC’s program the organizational and administrative capacity to administration, as well as ensure the funded administer the block grant and to facilitate regional activities are aligned with the program’s objectives. collaboration in their areas. As mentioned in the previous section, Chapter 225 has directed DOC to Unclear Whether Definition of Regions prioritize expanding the program to every area that Is Optimal and Comprehensive contains or is adjacent to high or very high severity Uncertain Whether RFFC Regions Are fire zones. The department is required to report Most Strategic. As previously discussed, the progress on expanding to such areas in the future. grantees cover regions that vary in size by tens of Uncertain How Priority Plans millions of acres. This is in part due to the nature Will Be Implemented of the RFFC block grant allocation process. DOC selected grantees based on prior experience in Limited Funding Available to Implement regional coordination and organizational capacity Projects. Once projects have been identified to administer the block grant. Although relying on and prioritized by these regional collaboratives, grantees with a history of coordinating regional it is unclear how these projects will acquire the efforts might be helpful in getting new regional necessary funding for implementation. At the collaboratives up and running, it is unclear whether local level, there is limited funding dedicated to the resulting geographic regions are the most implementing forest health projects. Although strategic in size. On the one hand, it is possible that local governments invest in some preventative large regions might be able to take advantage of forest health activities, such as developing forest economies of scale by consolidating staffing and fuel reduction priorities in Community Wildfire resources from a larger number of local jurisdictions Protection Plans, local spending on forest and partners. In so doing, these regions might have management programs can be significantly limited greater capacity to plan, develop, and implement in many rural areas with wildfire prone landscapes projects. On the other hand, it is possible that due to small tax bases and in many cases, if regions are too large, they might find it more economically disadvantaged residents. difficult to include the needs of the many small, At the state level, CalFire has several grant more disadvantaged communities within their programs to support local or regional forest regions. Moreover, without a program evaluation, health and wildfire prevention projects. Most it might be difficult for DOC or policymakers in the notably, the Fire Prevention Program—which future to determine the extent to which variations funds fuel reduction projects and fire prevention in region size affect how well coordination education—and Forest Health Program—which and collaboration occurs. funds restoration and reforestation projects—have Some Wildfire Prone Areas Remain received a total of about $200 million annually in Uncovered by Program. Although the most recent recent years. The 2020-21 and 2021-22 budgets round of grants expanded RFFC to additional provided significant one-time augmentations wildfire-prone areas, not all areas in the high for these and other programs as part of forest severity fire zones are covered by RFFC grants. health and wildfire resilience budget packages. More specifically, as shown in Figure 9 on the next Specifically, the Legislature approved a mid-year page, some areas of high risk that are not covered augmentation of $536 million for various forest by the first two rounds of regional grants include health and wildfire resilience programs, and the much of Riverside County, South Eastern Sonoma 2021-22 budget includes an additional $988 million County, Upper Salinas Las Tablas, San Gabriel for these activities. These budget augmentations River Watershed, San Bernardino County, and included several programs that provide forest Inyo County. This is in part due to DOC’s approach restoration grants to local entities, including the in selecting the grant recipients. According to Forest Health Program and the Forest Improvement DOC, these uncovered regions generally do not Program, which received a combined total of have the type of natural resources entity with $464 million over the two years. In addition, www.lao.ca.gov 15 AN LAO REPORT 16 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT CalFire’s Fire Prevention Program received a total Ongoing Staffing Challenges Could Hamper of $243 million in augmentations in the budget Implementation. In interviews, we heard about packages. The budget augmentations also funded two specific staffing challenges faced by regional a new Tribal Program with a total of $20 million grantees. First, some grantees reported that a to provide grants for forest health projects limited forestry workforce can hinder project specifically for tribes. implementation. Across many regions, grantees While recent budgets have provided substantially reported a need for increased workforce more funding to implement projects, available state development efforts, especially for professionals funding will not be sufficient to meet all project experienced and trained in vegetation management needs in the future. While no comprehensive practices, including cultural burning practices and assessment of the costs of forest health projects oversight of prescribed burns. As a result, grantees has been completed, the Forest Carbon plan have dedicated some of their block grant dollars for estimated 20 million acres of forestlands are at workforce development programs in this area, but it high risk of wildfire damage and could benefit from is unclear if such initiatives are sufficient to meet the forest treatments. The cost to treat these areas can workforce needs of regions. range significantly, but can exceed $1,000 per acre. Second, many grantees reported limited Therefore, the total costs to improve forest health staffing capacity dedicated to implement regional across the state would be substantial for private coordination activities, such as facilitating meetings and public entities involved in forest management. between partner agencies, developing the regional Moreover, because the state’s grant programs are priority plan, and overseeing grant administration. competitive, not all eligible projects submitted by Some organizations have been able to add staff jurisdictions for inclusion in regional priority plans with RFFC funding, but without ongoing and will receive funding. With local and state funding dedicated funding source, they might find it difficult for projects limited, it is not clear how high-priority to continue the same level of regional coordination projects will be implemented in the future efforts in the future. Consequently, there is after the regional priority plans are completed. uncertainty about how regional priority plans Consequently, it is unclear how useful these will be updated or revised in the future, as forest plans will be in the long run if there is not a clearer conditions change and regional priorities evolve. strategy for implementation of identified projects. RECOMMENDATIONS TO IMPROVE PROGRAM OUTCOMES AND OVERSIGHT In order to address the challenges described SHORT-TERM RECOMMENDATIONS above, we recommend several steps the Legislature could take to improve RFFC program outcomes Create State Requirements for and oversight. Our recommendations are in two Regional Priority Plans parts. First, we recommend a few more immediate State Standards Could Help Align Plans With actions for the Legislature to take, such as creating State Priorities. The main purpose of regional state requirements for regional priority plans and planning is to identify and target efforts towards adopting evaluation and reporting requirements. projects that are broad, interconnected, and Second, we recommend several actions that could cross-jurisdictional—ones that are beyond the be implemented in a few years after the program scope and capacity of a single entity. As described is more established and the Legislature knows above, however, it appears that some of the more about the program’s outcomes. These regional priority plans currently under development potential longer-term actions include aligning state are compilations of small, unrelated projects, rather grants with regional priority plans and considering than larger-scale projects with cross-jurisdictional ongoing funding for RFFC. www.lao.ca.gov 17 AN LAO REPORT importance and multiple regional benefits, such • Multiple Regional Benefits. Projects that as forest health, public safety, water supply, provide not only wildfire risk reduction but and biodiversity. In part, this is because DOC also address interrelated issues, such as has not established specific standards for the protection of key watersheds and restoration development of regional priority plans. Setting of wildlife habitat for a focal species standards across all of the regional priority plans could provide greater public benefits in would help to identify and prioritize projects with forests and watersheds. the largest potential to make a significant difference • Benefits Disadvantaged Communities. in forest health and wildfire prevention, among Not all areas are equally equipped to do other state goals. forest management projects due to limited In addition, setting clearer standards for priority financial resources, local workforce, or plans could help grant recipients and their partner organizational capacity. Prioritizing projects agencies come into agreement on how projects in the most financially disadvantaged should be prioritized in their regional priority plans. communities is important because they It can be challenging to coordinate across several are the ones least able to implement local entities with varying and competing priorities. high-priority projects on their own, and it As a result, without specific state direction, regional is of regional interest that all areas make priority plans may not rank or prioritize projects progress in improving forest health. This at all. Therefore, it might be even more important focus would be similar to many other state that the state sets some prioritization principles programs that provide priority to projects that to ensure projects included in the regional priority benefit disadvantaged communities. plans are all supporting the same goals statewide. DOC Should Develop Standards Based on Statute Should Define State’s Primary Legislative Priorities. Based on these legislatively Priorities for Plans. To support greater alignment established priorities, DOC would develop of regional priority plans with state priorities standards for the regional priority plans that include across regions, we recommend the Legislature more specific directions to grantees on how these adopt statutory language to (1) define which types statewide priorities are defined, measured, and of projects should be prioritized and (2) require assessed for projects included in the plans. For DOC to set state standards for regional priority example, the DOC standards would determine how plans consistent with those priorities. At minimum, risk to people and property is defined, what metrics we find that the following types of projects are are used to quantify such risk, and how individual ones that should be prioritized in statute to yield projects are assessed using those metrics. maximum regional benefits: Importantly, each project included in the • Risk Reduction to People and Property. regional priority plans should be required to be Consistent with the intent of Chapter 225 to assessed against each of the priorities consistent use RFFC to create fire adapted communities, with the DOC standards, similar to the centralized regional priority projects should be ones that assessment process that NCRP uses for their maximize public safety by targeting areas of regional priority planning. Projects could then highest wildfire risk to people and property. be ranked more systematically based on the • Cross-Jurisdictional. Projects that span outcomes of these assessments. More systematic multiple entities’ boundaries and go beyond assessment of projects would provide more the scope and capacity of a single entity could transparency to local stakeholders and state policy provide significant regional benefits and be makers about how projects are being prioritized. As difficult to plan and implement without some we discuss below, it could also provide additional regional collaboration and coordination. information that would be useful in selecting projects for state grant funding. 18 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT Adopt Evaluation and demonstration projects, and conduct Reporting Requirements outreach, education, and training. In this case, the department could evaluate Direct DOC to Conduct an Evaluation. To whether the regional priority plans meet assess how well RFFC is meeting its objectives, the state’s expectations, and whether we recommend the Legislature direct DOC to they align with state standards developed develop an evaluation of RFFC, culminating in a by DOC. The department could also set regularly published report assessing how well the a goal for the number of demonstration program is meeting state priorities. This would projects, outreach events, collaboration build on the requirements in Chapter 225 to meetings, and project development that each provide regular information on the outcomes and grantee should achieve. benefits that RFFC grants provide in wildfire risk • Outcomes. A main impetus of RFFC is to mitigation ecosystem, public health and safety, increase the pace and scale of forest health climate resilience, and biodiversity. Costs to provide projects across the state. Therefore, the such reporting are likely minimal. To the extent department could assess the extent to which there are additional reporting costs, DOC should RFFC helped to increase the number or scale have sufficient funds in the recent appropriations of landscape-level forest health projects to develop and implement an evaluation over the compared to before the program existed. next few years. For each aspect of the evaluation, DOC should determine the desired outcomes, as Require Initial Report to Address Whether well as objective and measurable criteria to assess Regions Are Strategic. To address our finding whether the program is resulting in such outcomes. on the uncertainty regarding whether the existing More specifically, this evaluation should regularly definition of regions is optimal, we recommend the assess RFFC in three aspects—processes, Legislature require that DOC assess the current deliverables, and outcomes. geographic definitions of regions as part of the first evaluation report. For example, DOC could report • Processes. Successful regional coordination on whether RFFC should expand to new regions requires the engagement and participation with areas of high risk of wildfire or in areas where of a wide range of stakeholders, including that risk is growing because of other factors, such state and federal agencies, tribes, local as climate change. As another example, DOC can governments, conservancies, nonprofits, consider whether certain regions are too large or as well as private landowners. Within this too small to coordinate most effectively to achieve aspect of the evaluation, DOC should aim to the benefits of landscape planning. evaluate how inclusive and comprehensive the grantees’ planning processes are. As an LONG-TERM RECOMMENDATIONS example, the department could evaluate how inclusive the regional collaboration process Align Forest Health and Wildfire is by assessing how many organizations Prevention Funding With Regional contributed to the plans, what types of entities (such as tribes, local governments, nonprofits, Priority Plans and private landowners) participated in If grantees complete regional priority plans that outreach, education, and coordination align with state priorities, the state could have events, as well as the level of participation an interest in financially supporting many of the by financially disadvantaged communities identified projects in partnership with local and (for example, their participation in events and regional entities. The priority projects included in leadership in regional coordination). these plans should be those that are expected to • Deliverables. Each grantee is expected to yield the greatest regional and statewide benefits. develop a regional priority plan, complete State departments that administer grant permitting for projects, implement programs for forest health and wildfire prevention www.lao.ca.gov 19 AN LAO REPORT projects—such as the Forest Health Program, in implementing the state’s forest health and Forest Improvement Program, Fire Prevention wildfire resilience strategy and targeting financial Program, and Tribal Program—potentially could use resources, it could consider ongoing funding to the information provided in regional priority plans regularly review, revise, and update the plans on in a couple of ways. First, high-ranking projects an ongoing basis in the future. Absent future state in regional priority plans could receive higher funding, local entities might not have sufficient prioritization for funding in existing state programs. resources to do this regional coordination and Second, the Legislature could create a new planning themselves, similar to what was occurring program specifically to fund the implementation in most parts of the state prior to RFFC. of high-priority projects in the regional plans, Ongoing funding for RFFC could also be used to particularly if the Legislature finds that the level address the other types of activities funded by the of funding provided or purpose of existing state program, such as supporting coordination staffing, grant programs are insufficient to support the outreach, education, training, demonstration projects identified in the regional plans. Under such projects, project planning, and workforce a program, the Legislature could, for example, development. For example, the Legislature could budget a certain level of funding to ensure that consider targeting funding or implementing the highest-priority projects in every region are other changes to address specific workforce implemented each year. It is too early to determine development challenges that are identified by how much funding the state should budget for regions as part of the RFFC process. such a program. Instead, the Legislature will want It is too early to know what level of ongoing RFFC to wait until regional priority plans are completed funding would be appropriate. However, given and recently appropriated funding is committed to the current expenditure levels, ongoing annual projects to determine what gaps remain. funding for regional coordination might reasonably be expected to be in the range of the low tens Consider Ongoing Funding for RFFC of millions of dollars. Ultimately, the amount of In the longer run, the Legislature may want future funding to provide for RFFC will depend on to consider ongoing funding for RFFC activities what activities the Legislature wants to prioritize— based on the value of the regional priority plans which could be informed by future reporting from and future program evaluations. If, for example, the DOC—and the number and size of RFFC regions Legislature finds that the priority plans are valuable in the future. CONCLUSION As wildfires have become larger and more and technical assistance. Though promising, RFFC destructive in recent years, there is a need to is currently limited by a lack of consistent standards increase the pace and scale of wildfire prevention for regional priority planning, insufficient evaluation work, such as vegetation management, forest and reporting requirements, and the absence restoration, and fuel breaks. Regional collaboration of an ongoing planning and implementation is often needed to plan, develop, and implement strategy. As RFFC continues to develop, we larger, more complex projects that cross recommend the Legislature take steps to modify jurisdictional boundaries. RFFC is an important the program in order to better align the program mechanism through which the state can support with legislative priorities, increase oversight, and such regional coordination. Although the program improve outcomes. In particular, we recommend is still in early phases of implementation, RFFC creating state requirements for the regional has already supported and initiated regional priority plans, adopting evaluation and reporting collaboratives, helping facilitate collaboration, requirements, and considering long-term alignment outreach, and education, as well as increased local of state funding. capacity through workforce development, training, 20 LEGISLATIVE ANALYST’S OFFICE AN LAO REPORT www.lao.ca.gov 21 AN LAO REPORT LAO PUBLICATIONS This report was prepared by Eunice Roh, and reviewed by Brian Brown and Anthony Simbol. The Legislative Analyst’s Office (LAO) is a nonpartisan office that provides fiscal and policy information and advice to the Legislature. To request publications call (916) 445-4656. This report and others, as well as an e-mail subscription service, are available on the LAO’s website at www.lao.ca.gov. The LAO is located at 925 L Street, Suite 1000, Sacramento, California 95814. 22 LEGISLATIVE ANALYST’S OFFICE