The Puzzle of Restoration/Fuels Priorities: Some National ENGO Views

I mentioned that I was working on a project to find areas of agreement between environmental groups of various kinds (ENGOs) and others on a variety of topics related to restoration, fuels management and wildfires. I looked at the Climate Smart Agriculture and Forestry public comment letters that USDA requested earlier this year.

Most, but not all, of the ENGOs agreed on the general concept of increasing the pace and scale of “ecological restoration.” This is a striking level of agreement, given the extensive history of disagreements around federal land management that we see here regularly on TSW.  There are also those groups whose letters said thing like “it’s a ruse to continue logging,” but it seemed more difficult or impossible to incorporate those views into an area of agreement.

To restore historic conditions in ponderosa pine and mixed conifer forests, thinning and prescribed burning are generally accepted tools. Conveniently, these same treatments provide opportunities for changing wildfire behavior.  Strategically placing restoration treatments on the landscape as described in the POD (Potential Operational Delineation)[1] process that combines local expertise and modeling to specifically support incident management can blend concern for appropriate suppression and the perceived need for restoration in these systems.

There seemed to be a difference between the Environmental Defense Fund, The Nature Conservancy and Defenders of Wildlife, all powerful political actors on the national scene.

Defenders of Wildlife (Defenders) state in their letter[2]Rather than characterizing wildfire management as a matter solely of risk reduction, we recommend that a USDA climate-smart policy be based upon the bedrock principles of the Cohesive Strategy and seek to maintain and restore the ecological integrity of fire adapted landscapes; develop fire adapted human communities; and improve effective wildfire response.”

The Cohesive Strategy (2014)[3] never uses those words; the actual wording is: “Landscapes across all jurisdictions are resilient to fire-related disturbances in accordance with management objectives.” (p.3.) A search of the document did not yield the term “integrity.”

Now as you all know, I am a fan of using the term “resilience,” and not so much “integrity”, so I won’t further belabor the point.

Defenders later recommend (p. 17): “Develop planning and decision-making structures and processes that ensure that the highest priority areas within mixed ownership landscapes are addressed first; this would include areas around communities as well as areas that are most degraded and departed from desired reference conditions. “

It’s not clear but it sounds like they would prioritize areas most “departed from reference conditions” before PODs (these might not be “around” communities).  We could call this the “departure first” view.

On the other hand, the Environmental Defense Fund has a detailed prescription[4], with perhaps different priorities than  Defenders.  We might call this one “safety first.”

“Our national wildfire strategy should have two priorities: 1) Protect communities in the line of fire; and 2) Reestablish natural fire patterns to protect ecosystem values and sustainably manage fuel loads. Reestablishing natural fire regimes can only be realized when fuel loads, particularly in the West, are greatly reduced using both mechanical treatments and prescribed and managed fire. Implementation will require an updated wildfire triage approach to ensure that we address the most pressing threats to communities and human lives, first.”

Similarly, The Nature Conservancy (TNC)[5] (p. 13) supports “highest priority fuels management.”

“Like the Forest Service, the Department of the Interior investments focused on highest-priority fuels management would result in boots on the ground, restored landscapes and safer communities and water supplies while providing substantial rural and tribal jobs. There are both climate mitigation and adaptation benefits to all this work.”

Perhaps they are all saying the same thing, and the different staff authors just use different words.

To me,  the key question would be what exactly would need to be done, and how far away, to protect communities? Would that look like PODs? Who would be involved in prioritizing and designing the treatments, and what would be the role of “restoration” driven by historic vegetation ecologists and desired reference conditions, compared to “treatments designed to help manage fire” driven by fuels and suppression practitioners? One of the criticisms that led to PODs on the Arapaho Roosevelt, at least in the story I heard, was that the they seemed to be “random acts of restoration”.  But with landscape fuels and fire knowledge, these same treatments might have been placed in a pattern to also have landscape fire management benefits. There’s also the issue of what if a community wants some fuel breaks, and they’re surrounded by tree species that aren’t adapted to fire, or are adapted to stand-replacing fire, so the whole “restoration to reference conditions” may not work for them.

And maybe this (safety first vs. departure first) doesn’t matter, as the collaborative groups whose “zones of agreement” I’ve viewed either don’t seem to see this as a dichotomy or have resolved it. That’s why I’d like to hear from others, especially those from collaborative groups, on how these two maybe different sets of priorities are worked out in practice, or if it’s even an issue on the ground.








9 thoughts on “The Puzzle of Restoration/Fuels Priorities: Some National ENGO Views”

  1. Does the answer to your question, Sharon, need to be one or the other? The Cohesive Strategy focuses on the three legs of the stool – resilient landscapes; fire-adapted communities; and safe and effective wildfire response. I believe the best available science indicates we need to do all three things, not just one or two. And not necessarily in any particular order: we need all of the things.

    Some ENGOs are more comfortable embracing all three components than others, hence why you see a difference in emphasis between community preparedness (“fire-adapted communities”) and ecological integrity across the landscape (“resilient landscapes”) among groups.

    And, FWIW, you see “ecological integrity” in some groups’ messaging – like Defenders – because it is in the Forest Service’s 2012 planning rule and many of us really like the concept. I’ve written on this topic and have urged the Biden Administration to embrace it:

    • Susan, I agree that we need “all of the above” strategies. Some ENGO’s don’t agree.

      Thanks for this cite.. my memory was that Defenders had an important role in putting it in the Rule.. and I don’t think the concept has been tested in court. Quite a stretch from NFMA, IMHO, but then I’m not a lawyer.

      I don’t think resilience and integrity are the same thing. My question is only “can we disagree about this and move forward agreeing with specific treatments on the land”? Or is “integrity” a legal hook that will only apply to something that some litigation- oriented ENGO’s disagree with?

      • Correct, there hasn’t been any litigation around “ecological integrity.” Yet. The only place where this would currently come up in litigation is in forest plan revision, but the pathway to make that argument is not straightforward and is fraught with peril in my view.

        We can agree to disagree about whether the concept fairly stems from NFMA 🙂

        I agree that resilience and integrity aren’t the same things, but they are closely related. And I personally think that we can disagree about it and still move forward with treatments on the land: many collaboratives do this regularly. For example, there may not be agreement on anthropogenic climate change, but there is agreement that losing structures in a wildfire is an undesirable outcome and that community preparedness and landscape RESILIENCE are things we can take steps to accomplish.

  2. Thank you for the summary. “Most departed” types of strategies can sound good, but they may be very expensive to treat compared to lesser departed areas and may require a lot of initial and continued investment to maintain them in a less-departed condition. And a landscape-scale view is very important. It may not be that bad to have a relatively small area of “most-departed” in an otherwise undeparted landscape. And focusing on most-departed, particularly when resources are limited, may divert resources away from protecting communities.
    Maintaining areas that are in good condition is also important, but often overlooked. And restoring areas that are less departed may be much more economical and effective than focusing efforts on “most departed” areas.

    • “And a landscape-scale view is very important. It may not be that bad to have a relatively small area of “most-departed” in an otherwise undeparted landscape.”

      I agree with this being an answer to Sharon’s good question about circumstances where “reference conditions” won’t work. To be more specific than “landscape-scale,” the Planning Rule requirement for ecological integrity applies to “ecosystems.” That allows for “departure” to be determined at an appropriate scale. This may require too much of something in one part of an ecosystem to offset not enough of something in another (or vice versa).

  3. Good stuff, Sharon! Thank you for digging into this. I hope you write a paper/article for publication. I know one editor who’d be happy to have it .

    Did you find any mention of positions on commercial sales of materials from fuels and thinning? As we’ve talked here about before, some groups are against commercial timber sales, and that may extend to commercial thinning and even biomass sales (chips, for example, that might go into pellets, power generation, mulch, and other products) — not logging in the traditional sense (as far as these groups are concerned), but still commercial.

  4. “Now as you all know, I am a fan of using the term “resilience,” and not so much “integrity”, so I won’t further belabor the point.”

    I’d like to further belabor the point (maybe again) – the point is that there is no difference between the two. Here is what the Preamble to the 2012 Planning Rule says about this (emphasis added):

    “The Department finds that Modified Alternative A provides the best planning framework for meeting the various elements of the purpose and need by creating a rule that: 1. Emphasizes restoration of natural resources to make NFS lands more RESILIENT to climate change, protect water resources, and improve forest health. The Department concludes that Modified Alternative A will result in plans that are adaptive and therefore more likely to remain relevant and implementable, including by providing an adaptive framework that will help responsible officials to respond to changing conditions and new information.

    Plans will include plan components to maintain or restore ecological INTEGRITY, SO THAT ecosystems can resist change, are RESILIENT under changing conditions, and are able to recover from disturbance.

    The Department modified the wording of the proposed rule to … replace the term ‘‘healthy and RESILIENT’’ with ‘‘ecological INTEGRITY;’’ … These changes are not changes in requirements; they are just clarifications and reorganizations.”

    Also, “This change responds to public concern about how to define and measure ‘‘health’’ and ‘‘RESILIENCE.’’ Ecosystem INTEGRITY is a more scientifically supported term, has established metrics for measurement, and is used by both the National Park Service and the Bureau of Land Management.”


Leave a Comment