Apparently 89% of the Mendocino National Forest has been burned over in recent fires. This struck me as a pretty impressive statistic.
They have come up with a forest-wide condition-based management approach to prescribed fire and fuel treatment via an EA (outside of Wilderness). What I think is interesting is that the proposed alternative seems to neatly avoid issues around “logging” and whether fuel treatments are really about timber production.. by simply not selling or moving any material offsite as part of using this EA. Seems pretty innovative to me.. what do you all think?
Here’s the description of alternative 2, the proposed alternative.
Hand Thinning & Limbing Trees to Raise Canopy Base Height
In areas where specialists determine that fuel loading and/or stand structure is such that prescribed fire behavior might exceed acceptable thresholds and pose a risk to prescriptive objectives and/or WUI and highly valued resources, prescribed fire alone will not be the sole source of treatment. In these situations, hand thinning and limbing trees using chainsaws or other tools may occur prior to prescribed burning, to reduce ladder fuels and associated potential for crown fire initiation and spread. Resulting slash may be scattered or left in place to assist understory fire spread. When prescribed fire is unlikely to consume most residual slash or would result in undesired fire effects, some or all thinned vegetation may be piled and burned on site.Prescribed Fire Control Lines
Existing features such as roads, trails, rock outcrops, or existing fuelbreaks will be used for fire control lines where possible. Where existing control lines are absent, firelines will be constructed to facilitate broadcast burning and hand piling burning operations. Fireline construction will also be used for the protection of cultural sites, sensitive resources, administrative sites, infrastructure or private property, and other features as needed. Firelines will be constructed by hand. If ground disturbing mechanical methods are necessary, additional National Environmental Policy Act analysis may be required. The amount of fireline construction will vary depending on the size of the burn area and existing conditions.
They also have an alternative 3:
Prescribed Fire and Mechanical Treatments Alternative
In addition to the Proposed Action, the MNF would like to consider an alternative that utilizes both the use of prescribed fire and mechanical treatments to reduce fuel loads and modify fuel structure. In some places and under some conditions it may be too difficult to safely use prescribed burning and inefficient to hand-thin dense stands of small trees. This is where the mechanical treatment of hazardous fuels can be a valuable tool. Similar to hand thinning in the Proposed Action, mechanical treatments would be used to mulch or remove trees less than 14 inches in diameter, and understory shrubs. The resulting mulch could either be used as a pre-treatment for prescribed fire or left alone where conditions meet the purpose and need.
Mechanical treatments would include but not be limited to the use of equipment such as masticators and feller-bunchers. Equipment is generally limited to slopes less than 45% and would operate on top of generated slash and mulch without the need of skid trails. Material could be removed off-site for biomass operations if existing landings and roads provide adequate access.
No roads or landings would be constructed as part of this alternative.
Here’s a link.
I see no reason why the exchange of money should be relevant to analysis of environmental effects. The nature of the material treated, how it is treated and whether and how it is removed from the site matters, and they say some things about this that limit the likelihood of “timber production” (though that may be a concern about the “alternative”). “Additional National Environmental Policy Act analysis may be required” if anything they do or find is outside the scope of what they analyzed.
“When prescribed fire is unlikely to consume most residual slash or would result in undesired fire effects, some or all thinned vegetation may be piled and burned on site.” This suggests they don’t they know which one they are going to do, but NEPA analysis must occur when “the effects can be meaningfully evaluated” (40 CFR §1508.23). (Maybe there’s little difference in the effects of this particular decision, but I want to make the point that condition-based analysis works against this NEPA principle.)