The last letter was from a group of some fire scientists (SFS). I don’t know how much experience they’ve had actually managing fires.
This letter is from a group of mostly agency retirees called the National Wildfire Institute (NWI). Similarly, I don’t know the specific fire experience of the folks who signed this letter. They raise, as might be expected, a number of different points from the fire scientists.
One of their concerns is the same as the fire scientists.. that there needs to be more support among communities for managed fire. The NWI solution is…planning and NEPA.
Chief, it’s time to declare that all fires will be promptly and aggressively extinguished, period. This would be direction until such time as the Agency would engage the public in a robust and comprehensive planning process to subject fire policy to widespread public involvement and public understanding. Anything less would simply serve to increase already fevered resistance to Forest Service fire policies. We reaffirm our strong support for Prescribed Fire and strong compliance with the law through approved burn plans.
As many of you know, I am a fan of the concept of standing down NFMA plan revisions, and standing up formal fire planning for forests, which could develop the support that both the SFS and NWI feel is needed. But even with delineations of areas where fires can be managed, possible condition and weather-based standards and guidelines, even with notice and comment of burn plans or other potential innovations, it seems to me that wildfire use is in a special category. WFU is opportunistic by nature, and I don’t think they can be nailed down in advance and carefully reviewed by scientists, the public and legal authorities, like, say, a hazard tree project or a grazing permit renewal or pretty much anything else that’s subject to NEPA.
Because it’s a judgment call given the ever-changing conditions. And we’d probably agree that the best folks to make those judgment calls are the experienced fire professionals certainly informed by whatever has been hammered out in a plan. Fires may not respect area delineations or any other plan components.
We also believe these uses of wildfire to manage natural resources and profoundly change ecosystems are not wise, especially during this time of severely clogged forests (forests are more than just trees); the expanding Wildland-Urban Interface; and the impacts of severe drought. We are concerned that the practice of “managed fire” has never been subjected to NEPA, NFMA, or to the plain requirements of the substantive Acts such as Clean Air, Clean Water, the Endangered Species Act, ARPA, and others. The truth is that our wildfire use has dramatically changed land and resource management plans and there seems to be no accounting for the cumulative effects and outcomes.
What’s interesting to me about this is that I agree in concept, the nature of different ICs doing different things on different fires under different conditions seems like it would make it impossible to predict any impacts. Of course, agency employees are perfectly capable of making assumptions.. but would they be meaningful, since fire weather and conditions are specific to time and place? I suppose you could do simulations under a variety of conditions but.. how close would they be to reality?
Perhaps public engagement is more important when impacts are more or less unknown or unknowable (and perhaps so is the no-action alternative), because only being honest and building a track record will build trust. In fact, we have many social scientists who have been studying communities and their responses to prescribed fire so those scientists could be brought together and asked to weigh in- and also explore peoples’ views about managed fires.
We think that now is the time to engage the public and the agency to disclose the cumulative effects of our wildfire use programs, gain public understanding and acceptance, align our actions with our appropriations, and carry on together in a unified way with our partners and our people.