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Differential Pay for Prescribed Wildland Fire Activities

Public comments on 91 FR 19081, docket OPM-2026-0199. Analyzed 2026-10-04.

Comments: 92
Unique texts: 89
Form-letter groups: 1
Issue clusters: 10
Substantive arguments: 11

Proposed rule: Differential Pay for Prescribed Wildland Fire Activities (91 FR 19081)

Checked against OPM's final rule

OPM's final rule (91 FR 52479) answers 11 comment topics, 8 of them by engaging a particular argument and the rest by answering general views together.

Recall: 88%; 7 of 8 topics OPM answered specifically match an argument rated substantive here.
Precision: 91%; 10 of 11 arguments rated substantive were answered specifically in the final rule. OPM does not answer every argument separately, so this is a floor, not an error rate.

Coverage of GW pay plan employeesAnswered specifically2 arguments · group "Requests to Expressly Cover GW Pay System Employees" (covered)
Hazard pay for GW-0456 employees as double compensationAnswered specifically2 arguments · group "Hazard Pay Eligibility for GW Versus GS/FWS Firefighters" (covered)
Prior pay increases already compensate GW firefightersAnswered specifically2 arguments · group "Hazard Pay Eligibility for GW Versus GS/FWS Firefighters" (covered)
Prescribed fire is not hazardous enough to warrant differentialAnswered specifically4 arguments (covered)
Payment for staging and waiting time / pre-ignition activitiesAnswered specifically2 arguments · group "Scope of Covered Prescribed Fire Hazardous Activities" (covered)
Cost and incentive to prolong operationsAnswered specifically1 argument (covered)
Comparison to other hazardous Forest Service dutiesAnswered specifically3 arguments (covered)
Expand coverage to smokejumper training jumps and aviation/air tanker personnelAnswered specifically2 arguments (covered)
Fossil fuel industry should bear wildfire costsAnswered with general views1 argument (covered)
Guidance on endangered species affected by prescribed burnsAnswered with general views1 argument (covered)
General support for the prescribed fire differentialAnswered with general views9 arguments · group "Adequacy of the 25 Percent Differential Rate" (covered)

Read the final rule: Differential Pay for Prescribed Wildland Fire Activities

Issues raised

Each group splits into arguments (statements that make a legal argument, give evidence, or propose an alternative) and general views. An argument is substantive if, true, it would require a change to the rule or its analysis; the APA requires the final rule to respond to significant comments. Select a group to review its arguments and draft responses.

Showing 11 of 11

Support for Hazard Pay Based on Comparable Prescribed Fire RisksWhole rule · Background and need for the rule

Support 75, Oppose 2

None substantive1 argument · 62 general statements

Scope of Covered Prescribed Fire Hazardous ActivitiesCovered activities (fireline implementation and control) · Covered activities: prescribed wildland fire duties (5 CFR 532, 550 appendices) · Covered prescribed fire activities · Covered activities: fireline implementation and control of prescribed fires

Support 11, Suggest change 2, Mixed 1, Oppose 1, Question 1

1 substantive1 argument · 10 general statements

Hazard Pay Eligibility for GW Versus GS/FWS FirefightersWhole rule · § 550.904 · Coverage of wildland firefighter (0456/GW) employees · Eligibility / coverage of GW wildland firefighters

Support 7, Suggest change 7, Oppose 2

1 substantive1 argument · 1 general statement

Adequacy of the 25 Percent Differential Rate25 percent differential rate · Differential rate (25 percent)

Support 6, Suggest change 1

None substantive0 arguments · 7 general statements

Differential Pay Supports Wildland Fire Workforce Recruitment and RetentionRecruitment and retention · Need for the rule / workforce retention · Workforce recruitment and retention · Recruitment and retention rationale

Support 6

None substantive0 arguments · 6 general statements

Prescribed fire hazards comparable to wildfire suppressionHazard justification · Hazard justification for prescribed fire coverage · Justification for hazard differential · Hazard justification for prescribed fire differential

Support 6

None substantive1 argument · 3 general statements

Prescribed Fire Hazards Comparable to Wildfire OperationsWhole rule

Support 5

None substantive1 argument · 4 general statements

Requests to Expressly Cover GW Pay System EmployeesCoverage of pay systems · Coverage of employees / pay systems

Suggest change 3

1 substantive1 argument · 0 general statements

Support for differential to aid recruitment and prescribed fireWhole rule · Benefits of the rule

Support 3

None substantive0 arguments · 3 general statements

Timing and Duration of Covered Prescribed Fire ActivitiesCovered activities (§ 550 Appendix A / § 532 Appendix A) · Covered activities (§ 550 Appendix A / § 532 Appendix J)

Suggest change 2, Support 1

1 substantive1 argument · 2 general statements

Other issues raised by few commentersWhole rule · Costs and burden · Need for the rule · Scope of covered activities

Support 40, Suggest change 18, Oppose 3, Question 2, Mixed 1

7 substantive19 arguments · 37 general statements

Form-letter campaigns

Comments submitted three or more times with the same or nearly the same text.

3 copies · OPM-2026-0199-0031
Strongly support Hazard pay for prescribed fire, but I would like to see coverage of the GW pay scale expressly stated in the policy change.…

Grouping and summaries generated by claude-opus-5-5 (analysis cost: approximately $1.54). Commenters are not identified by name; each excerpt links to the comment on regulations.gov.