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David Groves

March 2014
Wildfire Pay-for-Success
Feasibility Study
The Author
David Groves is Executive Director of Private Capital for Public
Good. PCPGs mission is to establish market mechanisms that
increase available resources for conservation programs by bringing
together stakeholders from the public, private, and nonprofit sectors.
Prior to PCPG, David earned his MBA from Presidio Graduate
School in San Francisco. From 2004 - 2008, David spearheaded a
campaign while at the Environmental Investigation Agency in Wash-
ington, DC that resulted in passage of a federal law to restrict the
flow of illegally-sourced wood products into the U.S. The law earned
the 2011 Future Policy Award as being the worlds best new forest
policy. David also has a passion for animal welfare and was the
Director of an animal shelter in Montreal from 2008 - 2010. He now
regularly volunteers at a local shelter in San Francisco, CA where he
currently resides. Contact David at
Copyright 2014, Private Capital for Public Good, a project of the Trust for Conservation
Innovation, all rights reserved. Any use of material in this work determined to be fair use
under Section 107 or that satisfies the conditions specified in Section 108 of the US Copyright
Law does not require PCPGs permission. Republication, systematic reproduction, posting in
electronic form on servers, or other uses of this material, except as exempted above, requires
PCPGs permission or license.

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

Introduction 4
Pay-for-Success (PFS) and its Application to Wildfire
Requirements of a PFS Project 5
Proven intervention
Intervention is replicable and scalable
Well defined metrics
Substantial cost savings that flow to a single entity
Funding that is inadequate or difficult to sustain
Unique Benefits of a Wildfire PFS 10
Fixed income
Broad investor base
Wildfire PFS Implementation 10
Conclusion & Key Findings 13
Private capital dwarfs public and philanthropic
resources by several orders of magnitude.
However, social and environmental programs
rarely create revenue and thus cannot attract
private investors by offering a return. Therefore,
they are shut out of this massive pool of poten-
tial resources.

However, many social and environmental
programs are preventative in nature, and enact-
ing them now reduces future remediation costs.
By determining the savings from a successful
preventative program generally based on
historical data one can structure an invest-
ment vehicle to monetize these savings.

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

Currently, the PFS model is being replicated
globally to address a number of social ills.
However, very few have proposed utilizing PFS
in a natural resources context, despite its
potential applicability.

Wildfire has historically played an important role
in maintaining healthy forest ecosystems. How-
ever, due to the past centurys forest manage-
ment strategy of total fire suppression, forests
particularly in the West are now unnaturally
blanketed in downed and small diameter trees,
as seen in the image below. These act as fuel
that can turn a low-intensity ground fire into a
devastating crown fire and are largely responsi-
ble for the catastrophic wildfires we see today,
according to the U.S. Forest Service (USFS).

The Government Accountability Office states
that the most extensive and serious problem
related to the health of national forests in the
interior West is the over-accumulation of vege-
tation, which has caused an increasing number
of large, intense, uncontrollable, and catastro-
phically destructive wildfires.

Introduction: Pay-for-Success and its Application to Wildfire
A forest blanketed in fuel wood in the Bob Marshall Wildness Area in Montana Jake Willits
The federal governments wildfire
fighting costs have been increasing.
Taxpayers spent $1.4 billion annually
from 1991 to 1999, but this figure
jumped to $3.5 billion from 2002 to
This trend is expected to
continue as scientists predict that
wildfire rates in the American West
will double by 2050 due to the effects
of climate change.

Congress has responded to this
problem by writing larger and larger
checks for fire suppression while
inadequately funding fire prevention.
Lowe (2006) stated that the area of
forestland being treated is miniscule
compared to the amount of forest
area that would benefit.
(2006) said that the policy of under-
funding hazard reduction treatments
does not represent rational economic
behavior, because funding hazard
reduction would pay for itself by low-
ering future fire suppression costs.

This report analyzes the feasibility of
using the PFS model to fund wildfire
prevention projects on public land.
The report finds that a Wildfire PFS
satisfies all of the basic requirements
of a PFS project and that there are
two additional benefits of a Wildfire
PFS over other PFS applications.
These include 1) the ability to create a
fixed income vehicle and 2) a broader
investor base because of firms carrying their
own wildfire risk. Finally, the report broadly out-
lines an implementation plan for a Wildfire PFS.

While the PFS model holds promise, it is not a
panacea for attracting private capital to
nonmarket problems. There are several key
requirements a project must satisfy to justify
employing PFS over traditional financing. The
following is a list of these requirements and
how they are satisfied with a Wildfire PFS.

1) Proven intervention

Investors will view a Wildfire PFS as being
high-risk due to its newness and corresponding
lack of historical success. To minimize model
risk so that the project only carries execution
risk investors will limit capital deployment
toward interventions with proven track records
of success. This is particularly important for the
first PFS application of a natural resources
project, since it will attract more attention and
Requirements of a PFS Project
Before and after thinning treatment in the Blacks Mountain
Experimental Forest in California John Ahnstead, USFS
scrutiny than future projects.

Reducing hazardous fuel loads can significantly
decrease the risk of severe wildfire.
can even determine the specific amount of
wood to remove for a given site based on local
conditions. Forest managers also have criteria
for determining areas to prioritize, based on the
likelihood of project effectiveness, cost per
acre, proximity to high-value resources (e.g.
surface water, endangered species habitat, the
wildland-urban interface), proximity to mill
capacity, vegetation type, precipitation rate,
prevalence of invasive species, etc.
data show that when taken, preventative
measures controlled wildfires in 87% of cases
in 2011.

To illustrate the granular level of understand-
ing that forest managers have, Mason, et al.
(2003) simulated various treatments in two
national forests in the Pacific Northwest, from
removing all trees above or below a threshold
size to removing various percentages of
basal area per acre. The most effective treat-
ment to reduce fire risk in these forests set a
target of leaving 45 feet
of basal area per
acre (BA-45) by thinning trees from smallest-
to-largest in size. This moved 71% of stands
into a low-risk category and eliminated high-
risk stands.

2) Intervention is replicable and scalable

Since establishing a PFS project requires
significant resources, interventions should be
replicable and scalable so that the first PFS
can be a template for subsequent interven-
tions. A successful PFS project should create
the political will for government to then scale
the intervention outright. If not, success
should at least lead to similar PFS projects
that cumulatively create that political will.

There is nothing particularly unique or complex
about any hazardous fuel wood removal treat-
ment. The process involves a determination of
the best treatment type for a given area accom-
plished via a literature review and site visit. A
team goes into the forest to identify and mark
the fuel wood to be removed. A crew then
removes the marked fuel wood and brings the
marketable material to a processing facility. It
then may conduct a prescribed burn if condi-
tions are appropriate.
The relative simplicity
at least compared to
many of the social inter-
ventions employed using
existing PFS makes
the intervention easily

The Healthy Forests
Restoration Act of 2003
streamlined the process
for implementing hazard
fuel reduction projects in
national forests. An envi-
ronmental impact
assessment must still be
performed under the
National Environmental
Protection Act, but all
other permitting has
been simplified. A
project could be scaled
to treat as many acres
Lower Joseph Creek Restoration Project USFS
in the Wallowa-Whitman National Forest
as there is available funding, whether a Wildfire
PFS receives $10 million or $100 million in

3) Well defined metrics

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

Wildfire experts have done extensive fire
modeling to predict local wildfire trends and
behavior based on large historical datasets.
They consider a range of variables, including
fuels, wind, terrain, slope, and moisture.
Experts have also produced a number of well-
defined metrics to determine wildfire intensity,
risk, and probability. Parties to a Wildfire PFS
can use these models and metrics to mitigate
their own risk and clearly define project suc-
cess. Some examples are described below.

Since PFS is fundamentally outcomes-
based, the most appropriate metric to
determine success is the rate of catastro-
phic wildfire in the treated area
compared to a control area.
Catastrophic wildfire is qualita-
tively defined, so a PFS contract
could refer to the various types
of fire regimes as defined by
Brown & Smith (2000).

Contract language could define
Understory Fire Regime versus
Stand-Replacement Fire Regime
versus Mixed Severity Fire
Regime and define acceptable
levels of each over the length of
the contract. A third-party auditor
would evaluate the treated land
and a control area after any fires
occur and compare them to
ensure that contract goals are
being met.

An outcomes-based metric could be defined
in varying ways. For example, since an
initial Wildfire PFS will be a pilot project, it
will only be large enough to treat a small
portion of any particular national forest.
Instead of the project treating a consoli-
dated area of forest, treatment could
instead be applied to a contiguous line,
strategically placed to prevent a wildfire
passing from one area into another as
seen in the image below. Thus the contract
could define success such that no fire
regime of a certain type shall pass through
from one side of the treated area to the
other side over the life of the contract.

There are also treatment-based metrics the
parties could use to define success. For
example, success could be defined by how
much forest has been converted from
moderate & high fire risk to low risk, as
determined by the auditor. Several factors
are used to determine fire risk, including the
amount of non-fire-resistant biomass per
acre, how altered the vegetation composi-
tion and structure is compared to its historic
state, the amount of ladder fuels present,
etc. A treatment-based metric versus an
outcomes-based metric could resolve
potential conflicts during contract negotia-
A fire line across a ridge on Orleans Mountain in CA Kimberly Baker
tions. For example, there will be tension
between the government wanting the con-
tract length to follow natural fire intervals
and investors wanting to keep their capital
illiquid for the shortest length of time possi-
ble. A treatment-based metric also reduces
investors execution risk, since performance
would be measured by what the forest
restoration crews control (amount of acres
treated) versus what they do not (wildfire).

4) Substantial cost savings that flow to a
single entity

PFS can only work where an ounce of preven-
tion is worth a pound of cure. In addition to
covering the costs of the intervention itself, PFS
savings must also yield enough to 1) provide
investors a return that approaches a market
rate for the amount of risk, 2) cover the admin-
istrative costs of executing the PFS, and 3)
provide enough of a savings to taxpayers to
incentivize policymakers to scale the project in
the future. Furthermore, savings must be
captured by a single entity, since distributing
them across the budgets of several government
agencies and private sector actors would
significantly complicate PFS administration.

The USFS is the federal governments primary
wildfire fighting agency, receiving 73% of the
overall federal wildfire budget in FY 2013 and
77% of the fire suppression budget, specifically.
To determine if a Wildfire PFS is justifiable, one
must compare USFS wildfire suppression costs
to the costs of implementing preventative treat-

Using conservative cost estimates, a Western
Forestry Leadership Coalition (WFLC) report
(2010) found that direct suppression costs for
the wildfires it studied were $262 per acre.

Note that this figure does not include pre-
suppression fixed costs, rehabilitation costs, or
any indirect costs including property damage,
public health costs, or environmental costs.
Snider, et al (2006) supported this figure when
calculating that avoided future costs justifies
spending between $238 and $601 per acre for
fire prevention measures.

Compare this to the costs of implementing fire
risk reduction treatments. Using conservative
estimates assuming highest costs and lowest
benefits Mason, et al (2003) found that net
costs of a BA-45 treatment, for example, are
$168 per acre. Note that BA-45 treatment could
actually result in positive revenue of $529 per
acre (through the sale of removed timber) if
low-cost estimates are used.

With direct suppression costs of $262 per acre
and the net cost of an example fire prevention
treatment at $168 per acre, a $10 million pilot
Wildfire PFS could have $1 million in adminis-
trative costs, offer investors a 10% return, and
reduce fire risk on 48,000 treated acres, saving
taxpayers $4.5M in future fire suppression
costs. Even if PFS administrative costs soared
to $2 million and investors demanded a 15%
return, taxpayers would still save $3.6 million
via the treatment of 38,000 acres.

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

It is worth noting that this analysis only incorpo-
rates a small percentage of the actual benefits
society reaps from the treatment of high-risk
forests. Table 1 on page 9 compares the full
societal costs of wildfire remediation versus
prevention. Only the top lines of Suppression
Costs and Operational Costs are incorporated
into this analysis.

The 2010 WFLC report analyzed indirect costs
of wildfires including property damage, public
health costs, and environmental costs and
found that they can range from 2 to 30 times
the reported suppression costs, increasing true
wildfire costs to $520 - $7,800 per acre. These
savings would be in addition to the figures
stated above and should be considered bonus
benefits of a Wildfire PFS.
Furthermore, forest treatments result in a
higher rate of carbon sequestration, since they
protect the remaining trees and send some
harvested wood to be made into durable goods.
Many treatments also improve habitat for
certain species over a forest blanketed in
downed and small diameter trees, and they
improve habitat for virtually all species over an
area that recently experienced a large crown
These nonmarket benefits are also not
included in the analysis above.

5) Funding that is inadequate or difficult to

Given their complexity and cost, PFS projects
should not be employed when traditional fund-
ing mechanisms are adequate. The PFS model
is best utilized when it is difficult to scale a
proven intervention due to a lack of political will.

Currently, the USFS is forced to focus almost
all of its fire-related resources on suppression
and only a trivial amount on prevention. Accord-
ing to a 2008 statement to Congress by five
former USFS Chiefs
and a 2012 Department
of Interior (DOI) literature review,
the reasons
for this include budget cuts, a flawed formula
for determining USFS budgetary needs, a
blank check approach to funding fire
suppression, and increased development in the
wildland-urban interface. Keiter (2006) went so
far as to say that this fiscal arrangement has
been more destructive to our forests than
wildfire itself.
A capital infusion from the
private sector could break this cycle of
misallocated wildfire appropriations.

In the short term, Congress and the USFS are
incentivized to implement a Wildfire PFS
because of the way it eliminates operational
risk for the USFS. If services do not meet the
standards described in the contract, the USFS
does not pay for them. If the work is successful,
opportunity costs are clearly understood and
demonstrate that the USFS has still saved
money even after paying investors principle and
interest. It is a win-win proposition for the
federal government.

A long term implication is how a Wildfire PFS
will shine a light on the costs of wildfire
suppression versus prevention. As a result,
policymakers should develop a better under-
Costs of Wildfire Remediation
Suppression Costs wages, transportation, equipment & supplies, evacuations
Property Damage
structures; timber & agricultural products; cultural & historic sites;
transportation, communication & energy infrastructure
Public Health Costs hospitalizations, fatalities, medical equipment, long-term health effects
Environmental Costs
loss of wildlife & habitat, surface water damage & erosion, carbon emissions,
soil degradation, loss of recreational opportunities, air pollution & visibility,
land rehabilitation
Additional Economic Costs lost tax revenue, lost business revenue, lost earnings by evacuees
Costs of Wildfire Prevention
Operational Costs wages, transportation, equipment & supplies, project planning
Environmental Costs
smoke from prescribed burns, impacts from treatment (habitat loss, soil
compaction, damage to standing trees, road sediments) which can all be
minimized with due care
Table 1
standing of the savings accrued when the
USFS prioritizes wildfire prevention. This could
motivate Congress to fund fire prevention
outright, without the need of employing a
Wildfire PFS.

Unique Benefits of a Wildfire PFS

Fixed Income

With the emerging PFS contracts addressing
social problems recidivism, chronic homeless-
ness, early childcare the source of revenue is
solely from monetizing the cost savings. The
interventions themselves do not directly gener-
ate revenue. Thus investors have no opportu-
nity for regular payments on their investment,
like what a traditional bond offers.

In addition to being the first to address a natural
resources problem, a Wildfire PFS can also be
the first fixed income PFS, where the sale of
wood products from forest treatments
generates revenue that can be passed on to
investors. A fixed income PFS would have the
same effect of reducing risk to investors as any
fixed income instrument, as investors would not
have to wait the length of the contract to collect

Mason, et al (2003) determined that the net
revenue (i.e. the market value of board
feet extracted minus logging and hauling
costs) from a BA-45 treatment, for
example, could be as high as $6,240 per
It is worth noting that there is
considerable range to potential revenue
streams, based on treatment type and
other factors.

Broad Investor Base

Current PFS projects have to rely on investors
that are either interested in building a PFS
market or have compassion for those individu-
als benefitting from the intervention. While a
Wildfire PFS can draw upon these kinds of
investors, it can also attract firms with a finan-
cial motivation to reduce local wildfire rates.
For example:
an insurance company that holds claims on
property near a treatment site;
a firm that relies on a substantial supply of
clean water from a forested watershed;
a firm with large private timber holdings
adjacent to forested public lands. (Given the
amount of wildfire risk it carries, the latter
type of firm might be inclined to fund an
entire Wildfire PFS.)

Instead of taking on an entirely new form of
financial risk, as would be the case for compas-
sionate investors, these firms already carry
wildfire risk. Investing in a Wildfire PFS might
simply be a transfer of risk from property
and/or forest resources to financial risk and
thus would be more justifiable to executives.

Wildfire PFS Implementation

A Wildfire PFS requires five key stakeholders:

Use capital for forest
Provides project
management support
Provides payment
only if wildfire
rates decrease
Audits wildfire rates
to provide credibility
Provide capital for projects
Receive principle & interest
if wildfire rates decrease
To attract capital from more risk averse inves-
tors, some PFS structures have also included
philanthropic agents to either guarantee a
portion of the investment or be subordinate
investors. The first natural resources focused
PFS might also require a similar structure to
adequately reduce risk for some investors.

Table 2 identifies specific organizations that
could be party to a Wildfire PFS and includes
rationale for why they would be involved. Note
that this table is a hypothetical exercise to
illustrate the kinds of organizations that could
be interested in this kind of project.


Potential Actors Note
State Farm largest home insurer in the U.S. with 21% of market share
Swire Coca-Cola
Coca-Cola bottling subsidiary serving 11 western states; has several
large bottling plants in CO, ID, & UT that rely on surrounding forested
watersheds for clean water
Plum Creek Timber largest private land owner in the U.S.; manages 7.8M acres of forests
Rockefeller Foundation
invested in the first-ever PFS project in the UK; has spent millions
funding work to promote a PFS market in the U.S. (could either be an
investor or guaranteer)
Goldman Sachs
invested in the first two PFS projects in the US, in New York City and
Salt Lake City
(or subordinate
Tom Steyer
billionaire former hedge fund manager who has spent millions of his
own money on political and market initiatives to reduce carbon
emissions (could either be an investor or guaranteer)
National Forest
nonprofit partner of the USFS; runs a National Conservation Campaign
that focuses on large-scale forest restoration projects
Service Providers
USFS and state
forest services
federal and state forest services manage their own forest restoration
West Range Reclamation
CO-based firm that has restored 90K acres of forest on public and
private lands
Campbell Group
vertically integrated forest management firm; manages 3.2M acres of
forestland (could be an investor or service provider)
Ecological Restoration
independent research branch of Northern Arizona University; conducts
research on forest health, unnatural wildfire, and restoration treat-
ment strategies and techniques
Global Institute of
Sustainable Forestry
institute that directs the Yale School of Forestrys research
U.S. Forest Service
receives 73% of the overall federal wildfire budget and 77% of the fire
suppression budget
Third Sector
Capital Partners
conducts PFS feasibility studies; has overseen PFS deal construction
and financing; is acting as the intermediary for several U.S.-based PFS
Social Finance
UK office was the intermediary for the first-ever PFS and is managing
several other PFS projects in the UK; U.S. office is managing a PFS in CA
and has done feasibility work for other projects
Rural Technology
could act as a forestry-specific project manager to oversee the forest
restoration crews
Table 2
Creating a Wildfire PFS will take several years,
from inception to launch. (It took Social Finance
-UK more than three years to develop the
Recidivism PFS in Peterborough, UK.) The
discovery phase is in process by Private Capital
for Public Good (PCPG). This phase includes:
conducting a thorough literature review,
primarily to find data on direct costs of
wildfires, costs of various forest treatments,
and their level of fire risk reduction;
interviewing potential parties that could be
involved in a Wildfire PFS to determine their
respective levels of interest and compe-
tency and, in the case of the USFS,
lobbying decision-makers in the administra-
tion and Congress to support this effort;
completing a risk assessment analysis, by
creating a financial model and running it
against a range of scenarios; and
helping to establish informal partnerships
among the diverse public and private sector
stakeholders to ease future negotiations.

Once the discovery phase is complete, a
project managing intermediary will take the lead
on PFS administration. This work will include:
formal financial structuring and cash flow
raising capital from investors and donors;
overseeing the public procurement process
(if required);
overseeing the hiring of forest restoration
firm(s) and auditor(s);
overseeing the multiparty contract negotia-
overseeing the work of the forest restoration
ensuring the auditing process is following
the terms of the contract;
overseeing financial transactions

Below is a rough timeline of task implementa-

Literature Review; Interviews
Risk Assessment Analysis
Stakeholder Vetting
Lobbying USFS & Congress
Partnership Formations
Financial Structuring
Capital Raising
Public Procurement Process
Contract Negotiations
Wildfire PFS Launch
Forest Restoration & Auditing
2014 2015 2016 Thru at
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 least 2021
Conclusion and Key Findings

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

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

Furthermore, a Wildfire PFS has two additional benefits that PFS programs addressing social
problems do not:
Hazardous fuel reduction treatments can create a stream of revenue to create a fixed income (i.e.
lower risk) instrument for investors.
Raising capital for a Wildfire PFS could be easier than for a socially-based PFS project as many
firms carry their own wildfire risk.

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


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