Introduction In the Western United States, thehistory of natural areas has been a historyof proﬁtable natural resource exploitation.The ponderosa pine forests have provideda stable supply of consumer products fortwo centuries. Management techniqueshave been geared toward the preservationand production of this resource. However,these ecosystems have been historicallyﬁre-adapted, depending on frequent,small surface ﬁres for natural thinning andregeneration (Swetnam and Baisan, 1996). Well over a century of ﬁre-supressionmanagement strategies have depletedforests of necessary biological processes tomaintain health (Savage and Mast, 2005).Analagous to a child’s fever as an immuneresponse to illness, ﬁre acts to ﬂush andcleanse the system—slightly detrimentalin the short-term but essential for overallhealth. A constant suppression of feverwith medicine only deters the symptomwithout addressing the cause, and will actto weaken the immune system over time.Long-term suppression leads to treatment-immune super-viruses (large crown ﬁres),increased ﬁre frequency and intensity, andstand mortality. Recognizing this, forest management professionals h f i l have endorsed a f d d d fundamental shift t l hiftin strategy from ﬁre suppression to controlled burning, manual thinning, and laissez-faire smallﬁreﬁghting. (Savage and Mast, 2005; Miyahishi and Johnson, 2001; Wier et al, 2000). The speciﬁctechniques that are most effective or cost-efﬁcient are still debated, yet the overall adoption of aﬁre-supported management technique is well-documented as a BMP. Currently, the targeted critical area for forest management is also one of the fastestchanging—the Wildland-urban interface (WUI). The WUI is commonly described as “the zonewhere structures and other human development meet and intermingle with undeveloped Wildlandor vegetative fuels. This WUI zone poses tremendous risks to life, property, and infrastructure inassociated communities and is one of the most dangerous and complicated situations ﬁreﬁghtersface” (CWPP Handbook 2004).
Urban planners, developers, and academics have not neglected this situation. Policies havecome into effect since the ‘drastic’ wildﬁre seasons of 2002-2003, and several communities havereﬁned their policies prior to that. Some communities have adopted shelter-in-place constructionstandards, development limits, ingress/egress models, mandated fuel mitigation at the property andthe community level (Cova, 2005; Cova & Church, 2000; RSF, 2007; PPMD, 2005; USFS 2007; Fienstien,2007) . Such a brief review of such a broad subject matter will obviously not yield any deﬁnitiveconclusions, this study simply intends to publicly inform about the current discussions within theprofession. The ultimate goal of this analysis is to assess the effectiveness of certain speciﬁc pointsstill contended within the WUI planning sphere. Concepts of ecological sustainability, public andproperty preservation, and effectiveness of policy implementation will be discussed. Within thesecriteria, identiﬁcation whether benchmarks are met can be viewed as those which support forests’natural restoration (including natural ﬁre patterns), protect the life-safety of human populations withinthe WUI, and promote an economically viable resource cycle.Background Figure 1. GIS Data of Fire Ignitions Annually. (Black is natural ignition, red is human ignition)History of Forest Management/Fire Supression GEOMAC, 2007 Even though human-ignited ﬁre has been a partof western American forests since the beginning ofrecord, the past century has been marked by a steadyand exponential increase in the annual acerageburned (see Figure 1)(GEOMAC, 2007; Farnsworth etal, 2002; ). Native Americans utilized prescribed burnsto clear ground for agriculture, to assist in hunting, andto thin overgrown areas. Arid climates and lightningignitions have undoubtedly instituted the prehistoricadaptation to ﬁre in which forests now rely. The year1910, however, appears to begin the current epoch inWildland ﬁre behavior. During that year, 1700 ignitions 2002burned 3.1 million acres throughout the western UnitedStates. This tragedy laid the foundation for aggressiveﬁre suppression and ﬁreﬁghting strategies that haveonly recently been called to question (Ricklefs, 1987;Graham, 2003). Traditional ﬁreﬁghting strategies were effective atreducing acres burned until the early 1960’s, but fromthat point until now, ﬁres have increased annually inintensity and spatial area. The age of uncontrollableWildland ﬁres began with Yellowstone in 1988,progressed to the Colorado Haymen ﬁre in 2002, andmore recently the Southern California ﬁres of 2007. Ofcourse, there have been several other catastrophic ﬁre 2003
events in the past 20 years, but these are most familiardue to the national media attention (Graham, 2003).Natural Ecology of Ponderosa Forests The natural state of Ponderosa forests areclumped in broadly spaced stands. As suppressionand artiﬁcial restoration efforts have progressed, thecurrent state of many forest systems is that of large-caliper individuals evenly and densely spaced. Smallercaliper individuals and ‘ladder fuel’ species abundantly 2004distributed within the stands generally result fromovergrazing activity (). Further, shrubs, detrium, grassesand smaller species are more abundantly and uniformlydispersed at the surface level. This even stratiﬁcationof the forest allows ﬁres to start, spread, and increaseintensity well beyond natural levels. And, with regard tothe WUI, ﬁres have radically increased in frequency dueto an increased point of ignition—humans. Referring toignitions within the last decade, the substantial majorityof large ﬁres were human-ignited.Development of the WUI 2005 Within the past three decades, development atthe WUI has progressed exponentially. The prospectof access to natural surroundings, larger plots of land,refuge from urban intensity, and increased privacymake a sound argument for living in the WUI. Theseattractions, however, usually overshadow the realityof increased responsibilities and costs associated withthis environment. Looking out the kitchen windowat a mule deer is certainly endearing, but lookingout to a black bear, mountain lion, or coyote aren’tgenerally met with such romanticized ideas. Severalstate agencies including those in Colorado have spentconsiderable resources on public education andoutreach programs to increase community awareness 2006and involvement concerning private fuel mitigation,slash pick-up programs, land management, andoverall ﬁre preparedness (CWPP, 2007; Firewise, 2007;douglascounty.gov; nifc.gov). The Healthy ForestsRestoration Act of 2003 enabled a new tool for WUIcommunities in the Community Wildﬁre ProtectionPlan. This interagency collaborative charge allotscommunities active in wildland mitigation access to
funds and resources necessary for the maintenenceof defensible space within the community. It alsoaids active communities with collaboration of federalland managment activity (Worley, 2006; CWPP 2004;USFS 2007; PPMD, 2005). While implementation ofcollaborative efforts created by the CWPP is notalways successful, several case studies show increasedefﬁciency in managing conﬂageration events,evacuation protocols, and emergency managmentstrategies (Worley, 2006; Carson, 2004). 2007Current Trends in Fuel MitigationPost-ﬁre logging: recycling or reinforcing the problem Currently, the debate surrounding salvage logging within burned areas remains relativelypolarized. The concept of harvesting an economically viable product after conﬂageration eventssuperﬁcially appears prudent and resourceful. However, recent testing suggests that this activityhinders forest restoration, contributes to erosion as well as riparian contamination, increases theprobability of repeat ﬁres, and could act to accelerate drastic ecosystem shift (Savage and Mast,2005; Elson et al,2007; Levy, 2007; Donato, 2007; Robbins, 2006; Lindenmayer et al, 2004). In fact,Donato et al. released data earlier this year advancing that post-ﬁre logging acts to reduce standregeneration up to 70% and increases overall fuel load in the form of surface slash (Donato et al,
2007). While the results of this study were initially contended in the peer review process, the datapresented has been validated. Others have analyzed soil restoration after ﬁre events, and foundreduced organic deposits, higher rates of erosion, compaction and dramatically reduced nutrientloads, which support the theory of hindered restorative growth (Dumroese et al, 2006; Poff, 1996).Dumroese’s work suggests that harvesting activity in the winter months could diminish erosion,compaction and possibly minimize disturbance to nutrient loads within post-ﬁre soils. The current U. S. Forest Service policy on post-event logging allows commencement withoutthe existing bureaucratic controls in events of emergency economic loss. While the economicviability of burned timber is not debatable, the expedited process by which access is granted forharvest prior to decay is a point of contention. Several have argued that this policy is antagonisticto the protection of wildlife populations already threatened or displaced (Nappi et al, 2004). Inextrapolation of the Dumroese’s work, up to a year’s delay in order to harvest appropriately shouldallow ample time for an environmental assessment to occur prior to total stand decay.Slash: community burden or entrepreneurial windfall With forest thinning and the substantial slash created resulting from fuel reduction policies, theproblem of surface fuel density arose. Research has shown that thinning without burning or total slashremoval will actually increase the likelihood of ﬁre as well as inhibit healthy growth and regeneration(Robbins, 2006; Donato et al, 2007). Recently, cottage industries dedicated to processing low-valuetimber have appeared--utilizing small diameter trees and slash for several marketable products.The largest processor currently is Forest Energy Products, a manufacturer of wood pellets for homeheating. One amicable partnership is retrieving enough biomass to supply 25% of the fuel for a localenergy plant (Neary and Zieroth, 2007). The bulk of the responsibility for the bulk of the detrium,however, still falls on the community (Farnsworth et al, 2002; Iverson and Demarck, 2005; GAO, 2006;Vogt et al, 2005; Reams et al, 2005). In Perry Park, Colorado, residents log 2000 hours annually in slashmanagement on their small residential properties alone. The metropolitan district contracts mitigationin public lands and rights-of-way, and the community is consistently engaged with local agencies tomanage the perimeters of State and National forest lands abutting the community (Threewitt andWagonlander, 2006).Contracting: sound business or old-school business Currently, approximately 30% of timber managment is contracted either through the BLM orthe Forest Service. According to the 1Q 2007 Healthy Forests and Rangelands report: “Stewardshipcontracting...shift[s] the focus of federal forest and rangeland management towards a desired futureresource condition. They are also a means for federal agencies to contribute to the development
of sustainable rural communities, maintain healthy forest ecosystems, and provide a continuingsource of local income and employment” (HFR, 2007). Table 3 shows the number of contractsawarded and subsequent acres treated per the HFR report. The treatment sizes range from 150 to650 acres averaged per contract, with an overall average of 512 acres treated per contract. Thereis currently no report available of the company sizes or locations for these stewardship contracts, noris there assembled data of the number of companies awarded these contracts. The nature of thesecontracts are such that the value of the slash harvested is deducted from the fair market value forcollection labor. The difference, if any, is then renumerated.Healthy Forests Restoration Act Analysis: Is W really an environmentalist?The Healthy forests initiative and the HFRA summary The Healthy Forests Restoration Act of 2003 (HFRA) came under the Bush Administration as afederal response to the increasing threat of wildﬁres. This act enourages public input and upholdsenvironmental standards. In the two years prior to the passage of this law, 147,049 ﬁres burnedapproximately 11 million acres, and 6800 structures were burned in 2003 alone. The seven key
components of this act are: to reduce ground and ladder fuels through thinning and prescribedburning; to improve public involvement and participation; to promote collaborative projects thatinclude local, tribal, state, Federal, and non-governmental stakeholders; to authorize projectson Federal lands that meet criteria for wildﬁre risk to communities, water supply systems, and theenvironment; to create the Healthy Forests Reserve Program for the protection and restoration ofdegraded forest ecosystems on private lands; to encourage biomass energy production; and todevelop an early detection and inventory program for sivicultural threats.Initial Critiques Initial reactions to the HFRA centered around concepts of unregulated subsidies for the timberindustry, exploitation of public fears about wildﬁre in order to promote swift passage, and lack ofdirection of logging efforts toward the WUI (safc.org 2003; Service, 2003; ). As mentioned earlier, theprovision limiting the NEPA proces, the public review process, and the 60 day injunction limit act tohinder opponents of proposed sale or harvesting the proper time to engage effective analysis (ibid). The following is an excerpt from the position statement of an environmental watchdog group,the Wilderness Society: The HFRA falls far short of what should be the primary goal of any wildﬁre legislation – protecting communities and keeping people safe from the risks of wildﬁre. The Bush- backed measure does not provide the funding needed to protect communities and instead uses the fear of ﬁre to gut bedrock environmental laws and tip the scales of justice in our courts. The wildﬁre provisions of the Act also focus solely on federal lands, but studies show that 85 percent of the land surrounding communities most at risk from wildﬁre is private, state, or tribal – not federal (wilderness.org, 2006).These critiques echo the nature of criticism surrounding this act. Within the four years since the lawhas been in force, communities active in WUI fuel suppression are ﬁnding little direct assistance fromthe Federal program, and have since redirected resources at securing State and local assistance(Johns, 2007; Worley, 2007). The beneﬁts of the HFRA, however, are not to be overlooked. Mandated public involvementin the CWPP process helps to educate residents, creates open channels of communication, andcreates relatively successful collaborative efforts which enable effective communication surroundingﬁre management decisions at all levels. The Cox canyon and Lakeview ﬁres, in Colorado and Nevada respectively, both illustratethe success of community fuel reduction projects and interagency collaboration during a ﬁre event(Forests and Rangelands.gov).Planning the Perfect WUI CommunityShelter in place Originally proposed for new communities, the concept of shelter-in-place wildﬁre protectionis now a mandate in San Diego county. In its original form, this theory encompassed speciﬁc buildingmaterials and components as well as conservative site clearing and planting techniques in orderto create an alternative life-safety measure to late evacuation. By constructing the residence withﬁre resistent cladding and roof material, installation of an exterior sprinkler system, boxed eaves,
tempered glass, and several other safety measures, shelter-in-place appeared to be the solution forwildland ﬁre safety. However, the safety is fully dependent on the structure’s components and abilityto resist ignition from spotting. Defensible space at the perimeter can be maintained such that ﬁrewould not spread to the structure. But the Haymen ﬁre in Colorado set new standards when spot ﬁresexceeded 1 mile ahead of the ﬁre front. This concept has recieved little scholarly attention in the past2 years, yet San Diego County created a shelter-in-place mandate. This appears to be for both newresidences (which could be built to the standard), but also existing residences. A breif feasibility studyby Threewitt, Wagonlander, and Worley suggested that the signiﬁcant investment in retroﬁtting anexisting structure for shelter-in-place would be signiﬁcantly higher than the purchase price of a newhome (2006). An early proponent of the shelter-in-place model was researcher Thomas Cova, yet norecent articles suggest it.Ingress/egress Modelling community development within the WUI in terms of ﬁre safety is a relatively newendeavor for planning ofﬁces. Many plats are still approved for rural subdivisions that only require oneor two access roads. The possibility of efﬁcient evacuation as well as ﬁreﬁghting access is severelydiminished as ingress/egress points are reduced. Even with ample egress options for a community,when routes are not effectively mitigated, severe threats to life are increased. One example of this is the Oakland-Berkeley ﬁre in 1991. The Buckingham neighborhoodincluded 337 homes with four full-time access roads. The road network was narrow, winding, anddensely vegetated. Total road length in the neighborhood is 5293 meters, equaling 16 meters perhome. This high density created and exit capacity of 3200 vehicles per hour with all roads available.There is no buffer zone or fuel mitigation at the roadsides. Based on the Cova egress model, thisneighborhood was compliant for the number of exits, exit capacity, and minimum exit distance.However, it was noncompliant for density, exit arrangement and exit fuel buffers or breaks. The origin of the Buckingham ﬁre was traced to an open space within the neighborhood. Aswith most wildifres, this was human activated. Within 30 minutes of the ﬁre’s report, 2 of the roads--Tunnel road East and West, were blocked by ﬁre. Evacuating residents proceeded uphill to theremaining exits. Most residents used Charing Cross road, a 13 foot wide “afterthought.” Of the 24 fatalities within the neighborhood from this ﬁrestorm, 12 were residents caught intheirs cars at the end of the evacuation cue. A 2001 Oakland wildﬁre planning study reports: “Thereasons why the 1991 ﬁre could not be stopped still exist today in many loacations throughout EastBay Hills.” The entire 1991 incident eliminated 2900 residential structures and burned 1600 acres. Norecord is available regarding any homes retrieved in the Buckingham neighborhood. The CaliforniaEast Bay Hills have lost 3542 homes to wildﬁres, which comprises 39% of all residences destroyed bywildﬁre in California. This event cost $1.7 billion in damage, and was the most costly ﬁre in the nation’shistory at the time (Cova, 2005; Cova and Church, 2000; Threewitt and Wagonlander, 2006). One component of new WUI plats that builders are attempting is full fuel mitigation prior todevelopment. Creating the prescribed fuel breaks at neighborhood boundaries and thinning allareas prior to building has been effective in Cathedral Pines, Colorado among others. The costs offuel management are assumed up front and passed on to homeowners at the point of purchase.Then, effective fuels treatment is a matter of regular maintenence instead of reactive managementof established systems (Worley, 2006).
Suggested Courses of Action Many of the best management practices for community construction and maintenence arecurrently utilized regarding new construction. Further, many communities have adopted CWPP’s andare actively involved in fuel reduction programs within their neighborhood. Increasing numbers ofcommunities are adopting shelter-in-place construction standards, and individual home-owners arerequesting these components during new construction, whether they are required or not. The areas where community protection fall short are: federal and state responsibility foradequate forest thinning on public lands abutting the WUI, environmental stewardship both beforeand after wildﬁre events, effective mandates on neighborhood access for ﬁre professionals andresident evacuation, mandated defensible space requirements on private lands, and effecitvepolicy dealing with adjoining private land uses that threaten surrounding properties. The mandateof shelter-in-place, such as San Diego county has enacted, is not recommended at a level otherthan optional participation at the neighborhood level. While many have lost lives while detainedin the process of evacuating, staying put during a large event offers few alternatives once a ﬁrehas approached. Shelter-in-place should by no means be enacted unless communities havefully followed the construction mandates and independent analysis of structural and life safety isconducted on a neighborhood scale.
Swetnam, T.W., and Baisan, C.H. 1996. Historical ﬁre regime patternsin the southwestern United States since A.D. 1700. In FireEffects in Southwestern Forests: Proceedings of the Second LaMesa Fire Symposium, Los Alamos, N.M., 29–31 March 1994.Edited by C.D. Allen. USDA For. Serv. Gen. Tech. Rep. RM-286. pp. 11–32.Ricklefs, R.E. 1987. Community diversity: relative roles of local andregional processes. Science (Washington, D.C.), 235: 167–171.White, A.S. 1985. Presettlement regeneration patterns in a southwesternponderosa pine stand. Ecology, 66: 589–594.Covington, W.W., and Moore, M.M. 1994b. Postsettlement changesin natural ﬁre regime: ecological restoration of old-growth ponderosapine forests. J. Sustain. For. 2: 153–181.~Healthy Forests Report May 2007The Department of the Interior (DOI) and the USDA Forest ServiceSenator Feinstein Chairs Field Hearing on California WildﬁresWed, 11/28/2007 - 13:24 — newsdesk. Minutes of meeting from Sen. Feinstein’s ofﬁce~Wildland Fire Management: The National Fire Plan (2007 Budget Justiﬁcation)Daniel G. Neary and Elaine J. Zieroth (2006) Forest bioenergy system to reduce the hazard ofwildﬁres: White Mountains, Arizona. USDA Forest Service, Rocky Mountain Research Station.Iversen, Kenneth, Van Demark, Richard (2006). Integrating fuel reduction management with localbioenergy operations and businesses—A community responsibility. Biomass & Bioenergy; Apr2006,Vol. 30 Issue 4, p304-307, 4pVogt, Christine A.,Winter, Greg Fried, Jeremy S. (2005). Predicting Homeowners’ Approval of FuelManagement at the Wildland–Urban Interface Using the Theory of Reasoned Action. Society &Natural Resources; Apr2005, Vol. 18 Issue 4, p337-354, 18pAllen Farnsworth, Paul Summerfelt, Daniel Neary, Tatersall Smith. (2003). Flagstaff’s wildﬁre fuelstreatments: prescriptions for community involvement and a source of bioenergy. Biomass &Bioenergy; Apr2003, Vol. 24 Issue 4/5, p269, 8p
Margaret A. Reams, Terry K. Haines, Cheryl R. Renner, Michael W. Wascom and Harish Kingre (2005)Goals, Obstacles and Effective Strategies of Wildﬁre Mitigation Programs in the Wildland-UrbanInterface. Forest Policy and EconomicsVolume 7, Issue 5, August 2005, Pages 818-826Kim, T.H., Cova, T.J., and Brunelle, A. (2006) Exploratory map animation for post-event analysis ofwildﬁre protective action recommendations. Natural Hazards Review, 7(1): 1-11Cova, T.J. (2005) Public safety in the urban-wildland interface: Should ﬁre-prone communities have amaximum occupancy? Natural Hazards Review, 6(3): 99-108Cova, T.J., Dennison, P.E., Kim, T.H., and Moritz, M.A. (2005) Setting wildﬁre evacuation trigger-pointsusing ﬁre spread modeling and GIS. Transactions in GIS, 9(4): 603-617Larsen, Royce (2002) Open Your Window to Overcome Impediments to Controlled Burning.Livestock, Range, and Watershed. University of California, Cooperative ExtensionArnold, Dewey (2003) Making a Difference: Helena National Forest-Montana. USDA Fact Sheet.www.doi.govSlater, Deborah (2004) Not Dead Yet: Forest Experts Feel the Ax. Sierra Magazine.Firescience (2007). Community Wildﬁre Protection Plans: Enhancing Collaboration and BuildingCommunity Capacity. Workship ProceedingsAnonymous(2006) Forest Regeneration Slowed by Logging. Environmental Science and Technology.P. 2865Levy, Sharon (2006) Scorched Earth. Audobon. May/June 2006, P. 10Rancho Santa Fe Fire Protection District (2004). Sheltering In Place During Wildﬁres: A ModernApproach to Living Safely in a Wildland-Urban Interface Community.University of Wisconsin Board of Regents (2006). Study on Post-Fire Timber Harvest Ignites Controversy.Ecological Restoration. 24:2. P. 68Wildﬁre Mitigation Practicioner Series (2004). How Prepared is Your Community for Living WithWildﬁre? Ofﬁce of Community Services, Fort Lewis CollegeDumroese, Deborah Page et al. (2006). Monitoring Changes in Soil Quality from Post-Fire Logging inthe Inland Northwest. USDA Forest Service Proceedings, RMRS P-41. Pp 605-624
www.wilderness.org Fact Sheet: “Healthy Forests” Law Fails to Protect Communities.Farnsworth, Allen et al. (2003). Flagstaff’s Wildﬁre Fuels Treatments: Prescriptions for CommunityInvolvement and a Source of Bioenergy. Biomass & Bioenergy 24: 269-276Iversen, Kenneth and Van Demark, Richard (2006). Integrating Fuel Reduction Management withLocal Bioenergy Operations and Business--A Community Responsibility. Biomass & Bioenergy 30:304-309Vogt, Christine et al. (2005) Predicting Homeowners’ Approval of Fuel Management at the Wildland-Urban Interface Using the Theory of Resoned Action. Society and Natural Resources, 18:337-354Neary, Daniel and Zieroth, Elaine. (2007). Forest Bioenergy System to Reduce the Hazard of Wildﬁres:White Mountains, Arizona. Biomass & Bioenergy 31:638-645Robinson, Robert A. USGAO (2006). Wildland Fire Suppression: Better Guidance Needed to ClarifySharing of Costs between Federal and Nonfederal Entities. Testimony Before the Subcommittee onPublic Lands and Forests, Committee on Energy and Natural Resources, US SenateReams, Margaret A. et al. (2005). Goals, Obstacles and Effective Strategies of Wildﬁre MitigationPrograms in the Wildland-Urban Interface. Forest Policy and Economics 7:5 Pp 818-826Donato, D. C. et al (2007). Post-Wildﬁre Logging Hinders Regeneration and Increases Fire Risk.Science. 311:352Threewitt, D and Wagonlander, W (2006). Perry Park Second Access Analysis. (Unpublished)Worley, Kieth (2006) Personal Interview. Perry Park Metropolitan District Coordinator. FirewiseMember. Perry Park, ColoradoJohns, Scott. (2007). Telephone Interview. City of Port Angeles, Washington, Department of Planningand Community Development. Planner and Certiﬁed Arborist. Interview Conducted on December 9,2007.http://www.nifc.gov/index.html National Interagency Fire Centerhttp://gacc.nifc.gov/rmcc Rocky Mountain Area Cordination Centerhttp://www.southwestcoloradoﬁres.org/default.asp Southwest Colorado Fire InformationClearinghousehttp://jfsp.fortlewis.edu/ Joint Fire Science Programhttp://www.forestsandrangelands.gov/ Healthy Forests and Rangelands: Managing our NaturalHeritage
http://www.theorator.com/bills108/hr1904.html Healthy Forests Restoration Act of 2003http://www.ﬁrewise.org/index.php Firewisehttp://www.ncdc.noaa.gov/oa/climate/research/2007/ﬁre07.html NOAA 2007 Wildﬁre SeasonSummaryhttp://geomac.usgs.gov/ Geospatial Multi-Agency Coordination: Wildland Fire Supportﬁle:///C:/Documents%20and%20Settings/d3/Desktop/ECOPLANNING/WILDFIRE%20RESEARCH/douglas.county.wildﬁre.rules.htm