Fire Safe California Grants Clearinghouse

The Fire Safe California Grants Clearinghouse was created by the members of the California Fire Alliance in order to facilitate the process of applying for Federal grants to do wildfire prevention projects on private lands in California and Nevada. This process is also referred to as "one-stop shopping."

The Clearinghouse is administered by the California Fire Safe Council, Inc. (CFSCI) on behalf of the members of the Fire Alliance. For these services, the CFSCI receives reimbursement or direct and indirect expenses related to grant administration. The CFSCI is a 501(c)(3) California non-profit corporation headquartered in Glendora, California.

Reasons for development of the Grants Clearinghouse

New funding

In response to the wildland fires of 2000, President Bill Clinton requested, and the Secretaries of the Department of the Interior and Department of Agriculture submitted, a September 8, 2000, report, Managing the Impact of Wildfires on Communities and the Environment, A Report to the President In Response to the Wildfires of 2000. This report, its accompanying budget request, Congressional direction for substantial new appropriations for wildland fire management, resulting action plans and agency strategies and the Western Governors Association's A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment - A 10-Year Comprehensive Strategy - Implementation Plan have collectively become known as the National Fire Plan.

The National Fire Plan, and the subsequent Healthy Forests Initiative (HFI), significantly increased Federal funding for projects on private lands, both "on the ground" and educational, that would reduce the wildfire risk to Federal lands.

For the first time, the Bureau of Land Management (BLM), National Park Service (NPS), U.S. Fish and Wildlife Service (FWS), and Bureau of Indian Affairs (BIA) had funds available for grants to organizations for use on non-Federal lands. Unlike the U.S. Forest Service, (USFS), these four agencies did not have any internal structure in place to administer grants to the private sector, so some process needed to be established to administer these grant funds. As the Clearinghouse got established, the USFS also came on board.

Different requirements by different agencies

Another factor was that every agency had different timeframes and formats for submittal of Concept Papers. The agencies also had different requirements for environmental compliance, such as NEPA and other regulations. These factors made it very difficult for applicants to submit funding requests to different agencies.

The Fire Safe California Grants Clearinghouse is created

So in 2002, the members of the Fire Alliance, including the CFSCI, developed a standard application, with one timeframe.^[1] It was based on the very successful Community-Based Wildfire Prevention Grants Program established in 2001 to administer funds on behalf of BLM. This is discussed in detail in the article on the California Fire Safe Council.

The members of the Fire Alliance designated the CFSCI as the administrator of the Clearinghouse without a competitive bidding process.

Two independent aspects of the Clearinghouse

The Clearinghouse consists of two aspects: project selection and funding administration. Historically, both parts have been overseen by the CFSCI; however, they are actually independent functions.

Project selection

"FSC [i.e., the CFSCI] convenes a grant review and brokering session that includes all agencies with funding in the clearinghouse and a volunteer-based review committee of grant experts, for example, from state and local government and the private sector. For grants that pass through the FSC, the FSC board of directors also will have to have a procedural vote to approve the grants at a regularly scheduled quarterly meeting to ensure the FSC complies with its policies in the area of subgranting."^[2]

Grant Administration

"FSC [i.e., the CFSCI] funds and monitors programs. FSC plans to advance funding to subrecipients on a quarterly basis. Monitoring includes reviewing quarterly reports, checking in with subrecipients via phone and doing monitoring visits as needed."^[2]

Grant administration also includes the authority of the CFSCI to cancel previously approved grants.

Summary of funding from 2001-2009

From 2001 through 2009, a total of at least $74.3 Million has been passed though the Fire Safe California Grants Clearinghouse.^[3][4][5] Since these funds were administered by a different entity, the Sacramento Regional Foundation, they are identified separately from those funds administered by the CFSCI after it became a 5010(c)(3) non-profit in mid-2002.

The following table provides a summary of funding, for 2001-2009. The totals by agency are:

BLM: $24.55 Million

USFS: 44.38 Million

NPS: 1.45 Million

F&W: 0.72 Million

In addition, CAL FIRE ran $3.19 Million of Proposition 40 funding through the Clearinghouse in 2005.^[6]

This analysis does NOT include funds from the USFS Western States Wildland Urban Interface (WS WUI) Grants. Prior to 2008, these grants were administered by CAL FIRE, and to include them now would skew the analysis. Also, the projects to be funded are selected by CAL FIRE using a different set of criteria than those selected by the Clearinghouse Grants Review Committee and CFSCI Board and staff members are part of the selection committee. The CFSCI is administering the WS WUI grants in California on behalf of CAL FIRE for the convenience of CAL FIRE for a flat fee of 15%.^[7]

Nor does the analysis include the earmark which the CFSCI lobbied from U.S. Senator Dianne Feinstein for $3.9 million, which was included in the budget for fiscal year 2006,^[8] and another $3.9 million earmark from Senator Feinstein in 2008, as there is no public information available as to what projects were funded by these dollars.^[9]

California Fire Safe Council, Inc. overhead

The California Fire Safe Council, Inc. receives reimbursement for direct and indirect expenses for administering the block grants that go through the Clearinghouse. In addition, the CFSCI has received direct grants, both for Clearinghouse operation and for other projects. Some, but not all, of these grants are listed on the "Federal Assistance" tab of the fedspending.org database.

In 2009 and 2010, an attempt was made to obtain details on the various Federal grants the CFSCI has received so that an analysis could be done of how much Federal money has gone to the CFSCI itself, versus the funding that went to "on-the-ground" projects. This effort was only moderately successful. Three of the four agencies provided partial information: the Bureau of Land Management only provided information about indirect expense reimbursement; the US Forest Service and the National Park Service provided both direct and indirect reimbursement data, but not about all of their grants. Fish & Wildlife, alone among the four agencies, refused to grant a fee waiver. As of June 2010, an appeal is pending.

An analysis of the grants where full data was available on both direct and indirect expenses, about three-quarters of total Clearinghouse funding through 2010, showed that nearly 15% of the Federal funding went to the CFSCI rather than to "on-the-ground" projects.^[10] This included a previously unannounced total of $370,000 in grants, including indirect expenses, to the CFSCI by the USFS ‘’in addition to’’ reimbursement for direct and indirect expenses in the 2005 and 2006 Clearinghouse cycles. Further, the USFS gave the CFSCI a direct grant in the 2003 cycle to set up the Clearinghouse in the amount of $60,000 in direct and indirect dollars. The existence of these grants, which came directly from the block grant funds intended for subgrants, only became known when the final list of recipients was received under the FOIA request.

This 15% overhead contrasts with claims by the CFSCI that administration is only 6 or 7%.^[8][11] While it's true that most expenses go to programs, which is how they're reported to the Internal Revenue Service on the Form 990, every dollar that is spent on running programs is one dollar less that is available for actual on-the-ground fire prevention and should be considered overhead, regardless of how the cost is recorded on the Form 990.

Concerns about consistency of operation

Overall

No public oversight

Even though it administers millions of public funds on behalf of Federal agencies, the CFSCI operates the Clearinghouse without any public oversight.^[12] Even its own Board of Directors is kept out of the loop; for example, in 2003 the Board was asked to vote to accept the list of approved projects even though the list was not yet available for them to see^[13] and in 2005 questions by the Board about the selection process were brushed aside by Chairman Turbeville.^[11]

Potential irregularities

There are several points in the process where irregularities could occur with little or no risk of detection. The following discussion corresponds to the numbered areas of the Fire Safe California Grants Clearinghouse diagram above.

• One of the screening criteria is "Project type is eligible for funding according to grant programs’ eligibility requirements." As the gatekeeper, the CFSCI can exclude an application from consideration simply by not connecting it to a potential funding source.
• The scoring criteria are fuzzy and subject to interpretation and there are unanswered questions about the Review Committee (see below for details on each of these topics)
• Project selection and grant administration are separate activities, as discussed above. Having the same organization manage project selection as does the grant administration makes applicants nervous about asking questions since their future, or even current, funding could be put at risk. Some have had their funding directly threatened by CFSCI Board and/or staff members.^[14]
• An unknown number of approved grants have been revoked by the CFSCI. The only one that is publicly known is that of the Big Tujunga Fire Safe Council.^[12] There is no independent arbitration process for when this happens, even though the CFSCI Board voted unanimously to establish such a process.^[15]

Project Selection Process

Questions about the Review Committee

The projects to be funded are chosen by a Review Committee consisting of representatives from a variety of organizations. Specifics are known only for the first round of funding in 2001.^[16] Since the CFSCI assumed the responsibility for the Review Committee, it has been operated in secret. Nothing is known publicly about how potential Review Committee members are identified, what criteria are used for selection, how members are trained, or what process they follow to choose projects, and the CFSC refuses to answer questions.

Theoretically, neither the CFSCI or the agencies have input into which projects are chosen, but there is no assurance of this since the Review Committee operates in secret. CFSCI Board Members have served on at least one Review Committee. The April 16, 2003 Board Meeting minutes state "There was discussion about the makeup of the committee, which included Mr. Davies, Mr. Turbeville, …^[13]

Some major questions about the operation of the Review Committee are:

• What process ensures that the scoring criteria, which are rather imprecise, are applied equally across all applications?
• Are the Concept Papers spread out among the members to be scored individually, or do all of the members examine each application together to arrive at a consensus on the score?
• How is the Field personnel project prioritization score arrived at? This score accounts for 16th of the total score. See below for an in-depth discussion of this topic.

Concept paper scoring

Review Committee scoring criteria are imprecise

On January 18, 2007, after four funding cycles of operation, the CFSCI announced a list of criteria that would be used by the Review Committee to score concept papers prior to project selection.^[17] For the 2010 funding cycle, an updated list of criteria was posted to the Clearinghouse web site and copied in the binders handed out at the Grant Writing Workshops, but the criteria were not discussed in the workshops nor were they announced to the CFSCI e-mail list as the 2007 criteria were.

Many of the "criteria" used by the Review Committee are imprecise and how they might be consistently applied across all concept papers is unclear. It is not known if all members of the Review Committee collaborate on scoring each Concept Paper, or if each reviewer scores several papers on his or her own. The latter case could result in increased disparity in the application of the criteria. The answers to most questions appear to simply be taken from the applicant's statements in the Concept Paper being evaluated, with no verification of accuracy. Further, the answers to some criteria seem like they should result in the disqualification of a Concept Paper, rather than just being part of its overall score.

An analysis of each criterion follows, based on the list of scoring criteria posted as of January 26, 2010, with notes as to what has changed from the criteria posted in 2007. The criteria list has two parts: "An initial screening will determine if a project can be considered for funding based on the following criteria" and "Proposals passing initial screening will be scored by the grant review committee ... based on the below criteria."

Initial Screening Criteria

These criteria are pass/fail, and are assessed by CFSCI staff. If a Concept Paper fails any one of the criteria, it is not eligible for funding and is not passed on to the Review Committee.

1. Application received on time
2. Applicant is an eligible organization
3. Applicant submitted only 1-5 applications (more than 5 will not be accepted) (new in 2010)
4. Application is complete
5. All Letters of Commitment received on time
6. Total match amount in Letters of Commitment equals match amount in Application
7. Applicant included themselves in the match table if they are contributing matching funds (new in 2010)
8. If the applicant has a fiscal sponsor, they submitted a fiscal sponsor agreement letter (new in 2010)

Gone from 2010 list:

• Project type is eligible for funding according to grant programs’ eligibility requirements

Review Committee Criteria

Each criterion has a possible score range as indicated.

1. The organization/fiscal sponsor has a history of similar successful projects and/or demonstrates the capability to successfully complete this project either with qualified current staff or through the addition of qualified staff. Consideration should be given to ensuring new programs do not overburden the organization’s/fiscal sponsor’s resources given current workload. (0-5 points)
   • How is this determined and by whom? This is too subjective as stated.
   • How is the score determined? What rates a 0 versus what rates a 5? Or should this be a yes/no question? The evaluation criteria should be shared with the applicants in advance so they can adhere to them; and not to spend the time and effort it takes to apply if they don't meet the criteria.
2. The project will create, or be linked to a completed or draft, interagency community wildfire protection plan (CWPP), collaborative community fire plan or an equivalent. (0-5 points)
   • This should be a yes or no question, not one that varies from 0 to 5 points.
3. The project/area’s priority in an interagency community wildfire protection plan (CWPP), collaborative community fire plan or equivalent is in the top 5. (0-5 points)
   • Another yes/no question.
4. The proposed project will improve wildfire survivability in one or more communities at-risk. (0-5 points)
   • Another yes/no question.
5. Costs are reasonable in proportion to the projected deliverables. (0-5 points)
   • How is this evaluated? Costs vary by region of the state and by technique used. One project might have to use a more expensive treatment method than another due to factors beyond the control of the applicant. Might a better criteria be a return-on-investment evaluation such as the Benefit-Cost Ratio (BCR) used by the Federal Emergency Management Agency (FEMA) Pre-Disaster Mitigation Program (PDM)?
   • How is the score determined? What rates a 0 versus what rates a 5?
6. The detailed budget is clearly defined, demonstrates involvement of key partners and identifies unit costs. (0-5 points)
   • What determines a "clearly defined" budget that "supports the project"? The evaluation criteria should be shared with the applicants in advance so they can adhere to them.
7. The project addresses long-term sustainability by creating community capacity to make itself fire safe after the grant ends. (0-5 points)
   • How is this evaluated? What criteria are used?
   • How is the score determined? What rates a 0 versus what rates a 5? Or should this be a yes/no question?
8. The area impacted by the project is at risk to fire originating on federal land. (0-5 points)
   • This should be a yes or no question, not one that varies from 0 to 5 points. Also, the reverse should be asked—is federal land at risk from a fire in the project area? (These are not the same question, as fuel load and topography vary.)
9. The area impacted by the project is in the wildland urban interface. (0-5 points)
   • Again, a yes/no question.
10. The project will reduce hazardous fuels by treating acres in wildland urban interface (WUI) areas, or areas designated in a CWPP or CALFIRE map. (0-5 points)
    • Another yes/no question.
11. Field personnel project prioritization. (0-10 points - was 0-5 points previously)
    • This is calculated by the CFSCI based on input from the Federal agencies. See below for a discussion of concerns and questions about how this score is arrived at.

Gone from 2010 list:

• The project is located in Condition Class 2 or 3
• The project is located in Fire Regime III, IV or V
• The workplan is clearly defined, demonstrates involvement of key partners and identifies unit costs of each task shown.
• Project complements others selected to achieve a geographical distribution of projects that support grant program objectives.

Federal Agency scoring process is ill-defined

The last score in the list of criteria, Field personnel project prioritization, accounts for 10 points, or 1/6 (17%) of the total score. No explanation was available about how these points are awarded until a clandestine copy was obtained of the scoring instructions from the CFSCI to the agencies for the 2010 cycle,^[18][19] (2010 refers to the year that Concept Papers were submitted; it is actually the 2011-2012 cycle of the agency budgets). There are several issues and questions about how this crucial score is calculated:

• The agency reviewers assign a ranking, but are given no guidelines about how to do this so there is no guarantee of consistency from one reviewer to the next or even for the same reviewer across different projects.
• The agency reviewers are asked to evaluate the "performance ranking" of the applicant, but how do they know this? They aren't involved in actual grant management. And this evaluation is too subject to the reviewer taking an opportunity to "get back" at someone personally. Reviewers should be required to justify their ranking, not just give a number. And how is this number used?
• Federal reviewers can comment on and rate any concept paper, even those outside of their area—who decides if those comments are appropriate and based on actual knowledge? What’s to prevent one area from downranking the projects in another area in order to improve the chances of funding their own area?
• Comments made by the Federal reviewers are not available to the applicants so the applicants have no ability to counter false or misleading information even though the comments are visible to the Grant Review Committee to use in their selection process.
• How is the final ranking arrived at—is it an average, or what? And how does this number translate into the score that is used by the Review Committee?

Scoring results are not shared with applicants

Unsuccessful applicants are not given the results of their scoring, so they are unable to use the information to improve their chances of future success. While "organizations can resubmit unfunded projects for two additional funding cycles" what good is this if they are not given a chance to alter their project proposal based on its score? It will just fail again.

Selection process produces skewed results

The same counties and organizations receive funding year after year, to the detriment of other applicants. For example:

• For the 2009 USFS funding that was designated for selected northern California counties:^[20]
  • Siskiyou County was the top recipient, with $2.6 million, or over 25%.
  • Over 15% of the funds went to counties that were not on the USFS list of qualified recipients
  • Of the three northern California Congressional Districts, 02 received 47%, 04 got 37%, and 13% went to 01 [the Nevada (state) FSC got the remaining 3%]
  • Mendocino County was unfunded—the only county that received no funding at all
• For the 2010 statewide funding:^[21]
  • Siskiyou County was the top recipient again, with $747,751, or 10% of all funds statewide
  • Six Counties accounted for 50% of the funding
  • Congressional District 02 garnered 21% of all funds statewide
• For 2001-2009 overall (does not include 2010 funding):^[3]
  • 50% of all funding went to just 10 counties. San Diego, at 11%, was almost double the second highest recipient, Siskiyou County, which received just over 6%. 38 counties received a total of 1% or less each. (See tabs "by County" and "Chart County %")
  • The number of recipients as a percent of total funding has declined from 0.0016% in 2001 to 0.0006% in 2009. (See "Chart Recipients as % of $") This means that, over time, the number of different organizations (vs counties) receiving funding each year is not expanding in proportion to the amount of funding. For example, from 2008 to 2009, the amount of funds increased by 54% but the number of organizations funded went up by only 23%. Since 2001, annual funding has increased by a factor of 4, but the annual number of recipients has barely doubled.

Since the Review Committee scores are not made public, it is impossible to know if the funded applicants actually scored higher consistently or whether favoritism/black balling is involved.

Grant administration process

THIS SECTION IS UNDER DEVELOPMENT

Potential topics to be included:

• Payments not distributed in a timely fashion
• Monitoring activities not being performed
• Cancellation of previously approved grants
• Lack of independent appeals process
• Administration could be done by any qualified non-profit, or even multiple non-profits
• The CFSCI has passed audits every year, but that is irrelevant

An alternative proposal: "Sunshine"

THIS SECTION IS UNDER DEVELOPMENT

References

External links

• Office of Inspector General U.S.DOI: Evaluation of Wildland Urban Interface Community Assistance Function Report July 2010
• CAL FIRE also called CDF or California Department of Forestry and Fire Protection
• California Fire Alliance
• California Fire Safe Council
• Fire Safe California Grants Clearinghouse