(Not in the American Planning Association context of this publication, but in the NFMA context of national forests.)
I was alerted to the Tahoe situation by this supportive opinion piece in a local paper, which includes a link to the project record for the proposed plan amendment. It provides an opportunity for a look at how fire management, and in particular wildfire management for resource benefits, should be addressed in national forest planning. Fire and planning have had a rocky relationship in the Forest Service over the years, but here’s some current guidance.
Guidance for Implementation of Federal Wildland Fire Management Policy (February 2009) includes this:
Management response to a wildland fire on federal land is based on objectives established in the applicable Land/ Resource Management Plan and/or the Fire Management Plan.
Fire Management Plans, programs, and activities support land and resource management plans and their implementation.
The L/RMP will define and identify fire’s role in the ecosystem. The response to an ignition is guided by the strategies and objectives outlined in the L/RMP and/or the Fire Management Plan.
Values to be protected from and/or enhanced by wildland fire are defined in the L/RMP and/or the Fire Management Plan.
Wildland fire will be used to protect, maintain, and enhance resources and, as nearly as possible, be allowed to function in its natural ecological role. Use of fire will be based on L/RMP and associated Fire Management Plans and will follow specific prescriptions contained in operational plans.
Fire Management Plans are strategic plans that define a program to manage wildland fires based on the area’s approved land management plan.
The 2014 National Cohesive Wildland Fire Management Strategy required by the Federal Land Assistance, Management, and Enhancement Act of 2009 (FLAME Act), includes as a priority, “increasing use of wildland fire.” Figure 3.4 shows a national map: “Spatial pattern of counties where options for managing wildfires
for resource objectives and ecological purposes might prove useful.”
The Forest Service Planning Handbook advises (among other things, §23.11c):
Standards or guidelines. The plan may include standards or guidelines related to basic smoke management practices, non-fire fuels treatments, post-fire rehabilitation, prescribed fire treatments, and wildland fire responses. A guideline or standard may provide guidance on when or how a specific tool is appropriate.
Here is the language from the current Tahoe forest plan (a standard):
Fire suppression strategy is control (with fast, aggressive initial attack) except where the contain strategy is authorized for specific management areas at fire intensity levels described under the practice description. Strength of attack will be based on hazard rating, fire weather, and values at risk.
The Forest Plan allows Fire Managers to utilize fire for resource benefits in only a few limited areas of the Forest and only if the fire can be contained within an isolated fuelbed of 5 acres or less, a situation rarely encountered and at a scale too small to achieve meaningful ecological restoration or other resource benefits.
Here is the comparable language proposed for the amendment (a guideline):
Use naturally- (lightning-) caused wildfire ignitions to meet multiple resource objectives when and where conditions permit and risk is within acceptable limits. Multiple resource objectives include: re-introducing fire as a necessary ecological process; enhancing plant and wildlife habitat, including critical habitat for threatened and endangered species; improving forest health, conserving ecosystem services; managing smoke emissions; reducing fuel loading; and/or protecting communities and infrastructure.
So this all sounds like an improvement, but nowhere in the proposal or the discussion of the proposal does the Forest mention the role of the forest plan. The “multiple resource objectives” should come from there. They list 14 factors, and the only one that indirectly implicates the forest plan is “cultural and natural values at risk.” A simple fix to the proposed guideline would be to use such ignitions to “achieve the desired conditions and objectives of the forest plan,” and add to the factor “… values at risk based on the forest plan.” That should go without saying, but by failing to mention the plan, it suggests that decisions about prescribed wildfires could be made without reference to that document. The forest plan may not be the first thing that comes to mind when a fire starts, but management of a fire, like everything else a national forest does, must be consistent with the applicable forest plan.
I do like the direct approach the Tahoe is taking with the smoke issue.
While the amendment could have short-term adverse effects on certain resources, for example, air quality, its effects would be largely beneficial by restoring the ecological role of fire and protecting forests and communities from the significant adverse effects of large-scale, uncharacteristic wildfire.
The proposed amendment is aimed at restoring air quality (36 CFR 219.8(a)(2)(i) by serving to offset smoke emissions from large, uncharacteristic wildfires
When forest plans are revised, a more comprehensive approach should be taken. This will give you an idea what the Inyo has done.