The Sierra and Sequoia National Forests took an interesting and creative approach to project planning. It makes sense for neighboring forests with similar landscape conditions to work together. They did an EA and apparently tried to take the contentious stuff out… it’s for prescribed burning and the size of trees to be removed cannot exceed 12 inches. The EA uses CBM which some people don’t like. I think it’s particularly interesting because of the effort to optimize analysis of practices that are not particularly controversial. So shout-out to them!
The objectors included Wilderness Watch, Sierra Club and Sequoia Forestkeepers, the John Muir Project and the Fire Restoration Group. Some of the objections were procedural and predictable, but others had interesting (and in one case) stunning things to say…
I thought a couple of the objection letters were interesting…I bolded the parts I found of particular interest.
Our objection could be resolved if either of the two conditions is met: a) an EIS is prepared; or b) the draft decisions are modified to allow prescribed fire, managed wildfire, and Indigenous cultural burning, but would not involve mechanical thinning of trees up to 12 inches in diameter as is currently proposed.As detailed in our EA comments and attachments, which we incorporate by reference here, the final EA violates NEPA, as amended by the Builder Act of 2023, by failing to take a hard look at the submitted science showing that no removal of trees–not even small trees–is needed before conducting burning, even in the densest and most long-unburned stands, and even in stands with high levels of dead wood. Fire behavior is fundamentally about fire weather, and burning can be safely conducted in any forest if burning is done in mild fire weather during the early or late part of fire season (June or Oct./Nov.). Moreover, the final EA violates NEPA by failing to consider a reasonable range of alternatives, especially a burn-only alternative (nomechanical thinning), and by failing to prepare an EIS.
“No removal of trees is ever needed before conducting burning.” Technically I think this is true. You can burn through a dense, dead stand without removing any trees. But there’s another goal.. most people would like some living trees at the end of the project. Because if you lose them all you lose their carbon sequestering, the wildlife habitat, and the parent trees for future stands. If you want to keep living trees, though, I’ve seen those stands. No amount of JMP “science” can make me favor their views over my own experience. And I wonder about a process that makes federal employees take time to write a rebuttal, plus federal judges to consider it. Maybe, just maybe, there are more useful activities that feds and judges and OGC and DOJ could be doing.
Apparently the use of PF in Wilderness is an issue. I thought these comments by folks at the Fire Restoration Group were interesting… of course the link to the research paper in the letter didn’t work because of the FS website conversion, so here it is.
Abstract: Historical and contemporary policies and practices, including the suppression of lightning-ignited fires and the removal of intentional fires ignited by Indigenous peoples, have resulted in over a century of fire exclusion across many of the USA’s landscapes. Within many designated wilderness areas, this intentional exclusion of fire has clearly altered ecological processes and thus constitutes a fundamental and ubiquitous act of trammeling. Through a framework that recognizes four orders of trammeling, we demonstrate the substantial, long-term, and negative effects of fire exclusion on the natural conditions of fire-adapted wilderness ecosystems. In order to untrammel more than a century of fire exclusion, the implementation of active programs of intentional burning may be necessary across some wilderness landscapes. We also suggest greater recognition and accommodation of Indigenous cultural burning, a practice which Tribes used to shape and maintain many fire-adapted landscapes for thousands of years before Euro-American colonization, including landscapes today designated as wilderness.
Human-ignited fire may be critical to restoring the natural character of fire-adapted wilderness landscapes and can also support ecocultural restoration efforts sought by Indigenous peoples. In the DEA page. 77 states, “The existing risk of high-severity wildfires would persist on the landscape and fire suppression and its associated activities, departure of vegetation communities from natural fire regimes, and the potential effects of damaging wildfire would continue to degrade the untrammeled, natural, and undeveloped qualities of wilderness character as described below.”
Remedy: Basically, asserting in Boerigter et al. 2024, that POLICY can also trammel wilderness values, not just bulldozers. While the 1964 Wilderness Act went out of its way to call out the “hand of man” as in many cases damaging to pristine wilderness values, what it failed to consider is that “man” (Tribal men, women, and children) have been living in, traveling through, and actively burning in these wilderness landscapes for thousands of years.
Finally, the 1964 Wilderness Act allows for full suppression in Wilderness Areas, including significant dozer fire line construction, but somehow that action is acceptable, where planned, restorative fire that is a key part of wilderness ecological function and integrity is not-it makes no sense. As long as the planned fire use follows minimum impact strategies you are increasing resilience, ecological integrity, biodiversity enhancement and key wilderness values, i.e., a naturally functioning ecosystem. Point out this incongruency directly and more assertively.
An interesting thought.. “policy can also trammel wilderness values.” I’m not a Wilderness person, but I’d guess that there may be a tension between different sets of Wilderness values.
Here’s Wilderness Watch’s Take Action.
I would expect that JMP would lose on both (a) and (b), on their ends. I would think that decisions to thin, or not thin, before PF would be “condition-based”, anyway. An EIS for such a thing is ridiculous. Maybe an EA might be acceptable, based on the size and scope of the project. Prep for PF has a low impact, compared to uncontrolled wildfire. Taking out small submerchantable trees, more or less, ‘simulates’ a low-intensity burn…. without the risk of ‘unplanned ignitions’ and ‘unforeseen weather conditions’.
The notion that dozer fire line is allowed in wilderness and restorative prescribed fire is not allowed is flat wrong. Prescribed fire may be used in wilderness per current Forest Service policy. It should be done with proper deliberation – assessing impact to wilderness character and determining the minimum tool necessary to conduct the operation. Boerigter et al. 2024 are mistaken that it is not presently allowed. Boerigter et al. 2024 are right in that traditional indigenous practices should be taken into greater consideration in wilderness management and in broader land management overall.
Wilderness policy establishes qualities of wilderness character using descriptors from the legal definition of wilderness found in the Wilderness Act of 1964. The untrammeled quality assesses the degree to which humans intentionally manipulate – for good or for ill – wilderness. A less trammeled wilderness has fewer interventions; a more trammeled wilderness has more active management. Examples of trammeling actions include suppressing fire, setting fire, reintroducing species, engaging in predator control, damming a river and removing a dam. In these examples, we are not standing down and letting nature manage her affairs – we are intervening, even if with good intention.
Another wilderness character quality is the natural quality, the degree to which ecological systems are substantially free from the effects of modern civilization. A wilderness with a healthy natural quality would have unpolluted air and water, few or no invasive species and – in fire-adapted ecosystems – a landscape shaped by fire.
Prescribing fire would constitute a trammeling action (intentional human manipulation) degrading the untrammeled quality of wilderness character, but benefiting the natural quality by returning fire where it had been suppressed. There are metrics under each quality and it is not hard to envision prescribed fire scenarios where the impact to the untrammeled quality is more than offset by the benefits to the natural quality. I know many wilderness managers who recognize that the wilderness areas in their charge need to burn.
Another aspect of wilderness character is the other features of value quality which captures unique ecological, historic, educational and scientific features. Indigenous burning could be affirmed as part of this quality. Continuing traditional burning would then uphold both natural and other features of value qualities (while still degrading the untrammeled quality). This could help bridge the gap between wilderness management and indigenous practice.
Regarding prescribed fire in wilderness (including indigenous burning): the means are there – they just need to be applied.