The BLM has released its final decision to implement 11,000 miles of fuel breaks in six states. The figure is in miles because the fuel breaks would be constructed along roads and right-of-ways. Given our discussion of the Forest Service trend towards large landscape “condition based” management decisions, this language from an article quoting the BLM piqued my curiosity (my emphasis added):
According to Jennifer Jones, a spokeswoman for the BLM, the program will help streamline the implementation process by reducing or eliminating the need for environmental analysis. Once the plan is finalized and funding available, said Jones, “offices will be able to use it immediately and for many years to come.”
The timeline for implementation and the location of fuel breaks will depend on what offices develop plans and apply for funding.
The BLM’s notice of availability added:
… these potential treatment areas cover approximately 38 million acres within the project area boundary.
The goal of these Programmatic EISs is to significantly minimize the subsequent National Environmental Policy Act (NEPA) work required to approve on-the-ground projects.
(A second EIS will address “fuel reduction and restoration” over the same area.)
These statements sound like the more conventional approach to programmatic NEPA analysis (such as has been done for the use of herbicides). They are intended to provide context for subsequent site-specific analysis that will produce overall savings in planning efficiency. They make no pretense that this large scale analysis would necessarily be a substitute for site-specific analysis as some Forest Service proposals have stated. This kind of “merely programmatic” analysis has sometimes been given more leeway by the courts because a subsequent site-specific analysis would follow that would address site-specific issues and effects that have not been addressed.
The BLM decided also to do an EIS, unlike some of the Forest Service efforts that used an EA. This analysis of effects of fuel breaks is also probably more site-specific than area-wide, “condition-based” Forest Service proposals because they know where the candidate corridors are, and they know the area of BLM lands where no action would be taken (away from these corridors). (The scientific validity of fuel breaks is also discussed.)