The Ten Cent Community Wildfire Protection Plan led to a fuel treatment proposal on the Umatilla and Wallowa-Whitman National Forests that included prescribed burning in the North Fork John Day Wilderness Area. Objections included alleged violations of the Wilderness Act. The objection decision included the following description of the process and requirements to conduct prescribed burning in wilderness.
The first two conditions that must be met are that “use of prescribed fire or other fuel treatment
measures outside of wilderness is not sufficient to achieve fire management objectives within
wilderness”. FSM 2324.22. A Minimum Requirements Decision Guide (MRDG) was prepared that determined that use of prescribed fire or other fuel treatment measures outside wilderness would not be sufficient. FEIS at 404. The second condition that must be met is that “an interdisciplinary team of resource specialists has evaluated and recommended the proposed use of prescribed fire”. FSM 2324.22. The proposal was developed by a team of interdisciplinary specialists. FEIS at 3. The third condition that must be met is that “the interested public has been involved appropriately in the decision”. FSM 2324.22. The public was provided opportunity to comment on the proposed action and draft EIS. Draft ROD at 8-9. The final condition that must be met is that “Lightning-caused fires cannot be allowed to burn because they will pose serious threats to life and/or property within wilderness or to life, property, or natural resources outside of wilderness”. FSM 2324.22. The MRDG documents the current situation in which natural ignitions in wilderness are suppressed to protect life, property, or natural resources outside of wilderness, including adjacent private residences and communities. FEIS at 403. The final condition to be met is that there must be objectives, standards, and guidelines for the use of prescribed fire specific to the wilderness area in a forest plan, interim wilderness management plan, or fire management area plan. FSM 2324.22. The North Fork John Day Wilderness Action Plan specifies that vegetative changes resulting from prescribed fire would not be considered unacceptable changes in forest cover or visual/scenic quality. LRMP at B-2, FEIS at 215.
Finally, policy specifies that manager-ignited fire should not be used where lightning-caused fire can achieve wilderness fire management objectives. FSM 2324.22. The history of fire suppression in the North Fork John Day Wilderness and resulting fuel loading have led to the current situation in which lightning-caused fires are not likely to achieve the second wilderness fire management objective (“Reduce, to an acceptable level, the risks and consequences of wildfire within wilderness or escaping from wilderness.” FSM 2324.21). FEIS at 403. Currently, these risks and consequences within wilderness include the likelihood that “when a fire does occur, it will be of high severity consuming most vegetation and soil cover” and “could potentially remove cover for big game, produce an influx of sediment into anadromous fish spawning habitat, and increase water temperatures due to loss of shade” as well as limit opportunities for primitive recreation. FEIS at 215, 403, 406 and 436.
The decision was then modified to eliminate the wilderness burning, and the rationale was “once areas outside the wilderness are treated, agency administrators may select to manage natural ignitions differently (e.g. confine and contain strategy) inside the North Fork John Day Wilderness to further meet the project purpose and need and improving the naturalness component of wilderness character.” The bottom line is that a “minimum requirements” analysis could allow intentional burning of a wilderness area without violating the Wilderness Act, but the objection process overruled those findings in this case and found that it was not necessary. Given that suppression is allowed in wilderness areas, I don’t automatically see a problem with using prescribed fire to offset that (so I guess I’m not a wilderness purist). (And someone might even say that logging could be good for wilderness.)