In your letter of 12/22/2005, I received directions to implement a decision on an appeal of the classification of a Supervisory Forestry Technician (Engine Module Supervisor/Engine Captain), GS-462-7 position in this region.  I respectfully disagree with this decision and request reconsideration based upon what I believe to be incorrect assumptions presented in the evaluation statement.  The effects of this decision have enormous impact on this region and the Forest Service.  In this region alone, we have over 25 positions that face downgrading if this decision is implemented.  I have requested and received support from all other Regional Foresters to act on their behalf in my request.

The national standard position descriptions approved in 1997 could not be supported at the time in Region 3.  Guidance issued by the Regional Human Resources Office concerning the National Standard Position Descriptions for Supervisory Fire Engine Operators, G8-462-8, N8017, was based upon the assumption that the position description did not accurately describe the work performed by engine supervisors in Region 3.  During the 2001 implementation of the National Fire Plan, regional and national field reviews resulted in Line Officers questioning the guidance due to changed position expectations and increasing complexity of the wildland fire environment in the Southwest.  With the concurrence of Line Officers and Unit Fire Management Officers and Region Fire Management, it was determined that many locations in Region 3 met the criteria of the GS-8 because of changed management and fire environment conditions since 1997.  As per your letter of March 13, 2001 which stated “the Appropriateness of the GS-8 Fire Engine Captain and Fire Engine Operator would need to be determined by classification specialists at the regional level and most likely verified by desk audit.”  A regional classification field review in 2002 of the Prescott National Forest resulted in the approved use of the GS-8 position description in the Region where the criteria was met.  Forests proceeded with the GS-8 positions where applicable. 

In 2004 the Chief directed implementation of the Interagency Fire Program Management Qualifications Standards (IFPM).  This action created fire program management standards on a service-wide basis for those that have direct fire safety responsibilities. Fourteen key positions were identified to be implemented, two of which were Engine Module Supervisor and Supervisory Fire Engine Operator.  The direction identifies these two positions to have no complexity variability recognizing that some positions will not vary in their responsibilities regardless of the complexity of the program assigned to it.  Standard key performance elements, competencies, and training required is the same service-wide whether in Region 5 or not.  It was understood the intent was to standardize positions and minimum grade levels across the wildland fire agencies nationally much as Helicopter Managers and IHC Superintendents had been years previously.  The guide assigned the grade level to be GS-7/8 for the Engine Module Supervisor.  In March 2005 additional guidance was issued without field input that arbitrarily included the addition that the GS-462-8 position was again for R-5 forests only.        

We understand that the GS-8 Standard Position Description was based on supervising at least seven crew members to provide five-person staffing for seven days per week through the field season and crediting of physical dispersion as a special situation.  We strongly disagree that the use of the Standard Position Description is only appropriate in California and we submit that the Southwestern Region has comparable complexities.  We also disagree on segments of the decision where our regional evaluation was downgraded for program scope and effect and base level determination affecting supervisory duties and responsibilities.

The decision evaluation of Program Scope and Effect is capriciously conservative.  An engine is assigned to a Ranger District for administrative management, but responds to incidents within an interagency fire zone which is a greater geographic area.    It has a response service area that includes public lands of multiple federal agencies, State of Arizona, and municipalities.  They service an area more complex and diverse than a single Ranger District.  We have neither the funding nor the numbers of engines today to be afforded the luxury on an engine servicing “an area smaller than a district office”.

The decision only credits our Engine Captain with supervising work that is routine in nature and states that the majority of the work is at the GS-4 level.  The position supervises one permanent Forestry Technician (Assistant Fire Engine Operator, Type III), GS-0462-07 one permanent seasonal Forestry Technician, GS-462-5, a seasonal FS-462-5, two seasonal GS-462-4, and two seasonal GS-3s.  The determination that the difficulty of work supervised (factor 5) is at the GS-4 was based on “assumptions” that each subordinate non-supervisory position performs grade controlling work 100 percent of the time.  This assumption is not only unrealistic but totally ignores the intent of Factor 5 which is to determine the highest grade which best characterized the nature of the basic (mission oriented) non supervisory work performed and constitutes 25 % or more of the workload (not positions or employees) of the organization.  The configuration of the crew, engine, and training standards are nationally set and identical to Region 5.

The decision also fails to give credit for the complexity of the work.  This work typically ranges from operating a large, complex fire engine while supervising the crew, to becoming an incident commander responsible for supervising multiple interagency resources.  Supervision of operation of the engine is not routine and varies from incident to incident depending upon the location of the incident, forest or wildland urban interface.  The engine supports the work of the crew, which must be trained to operate in hazardous environments, extreme weather conditions, to build hand lines or deploy hose packs for long periods.  The Engine Captain under time critical decision situations,  is constantly evaluating, identifying, and analyzing strategy and tactics for a variety of forest, range, and interface mix, often in a unified command with other agencies and municipal fire districts.  The challenges that face our Engine Captains in the wildland urban interface have increased in the last decade due to the encroachment of residential, commercial and human activities within and adjacent to our National Forest boundaries.  They are dealing today with directing suppression actions on incidents with resource and structure values measured in the millions and not uncommonly billions of dollars. 

In addition the decision goes on to say “This factor is a critical difference in the GS-8 national SPD because the GS-8 position was designed for a fire program with the complexities found in southern California.  The fire program in southern California is the most complex program in the agency.  The fire seasons are longer than other parts of the country.  The GS-8 position description is appropriate for use for positions supervising Type III engines with a crew comprised of at least seven individuals, the intent being to provide five person staffing seven days per week throughout the field season.”  The critical difference in classification centers around the concept that only southern California, Region 5, has the fire complexities that justified the GS-8 grade in 1997.   This concept appears to remain locked in time and fails to recognize the fire management, social, and environmental changes that have occurred service-wide across the nation since 1997.  Much as the southern California complexities are considered applicable across all of California the same complexities now exist nation-wide.  The Southwestern Region also has fourteen different fuel types, urban interface, multiple cooperators responding to each incident, multiple agreements, significant fuels reduction plans and projects a longer fire season than many other parts of the country; it is not unusual to have wildland fires occur in every month of the year.  The general social and political environment affecting the complexity of incidents our fire management personnel respond to is as complex as Region 5.  In addition the IFPM now sets the same expectations for performance standards, competencies, and training requirements service-wide for the Engine Module Supervisor.  There is no difference in the expectation of performance of management for the Engine Module Supervisor in Southern California and Northern Arizona. 

Given credit for the above factors, we feel that our position is properly classified at the GS-8 level.  Based on potential negative ramifications to all Forest Service Regions, I request that this decision be reexamined and that it be reviewed openly and fairly. 

/s/ Lucia Turner for

HARV FORSGREN

Regional Forester

cc: 

Regional Foresters

Director, Fire & Aviation

Director, Human Capital Management