Jon and I have been discussing how NEPA docs should display the uncertainty (probability) of success of fuel treatments. Should it be a paragraph somewhere saying “under certain conditions, fuel treatments tend not to be effective at changing fire behavior in the ways we want to change it”, and describing the conditions?
Well, I thought it would be interesting to see what people are putting in their environmental documents about that. So I went to the Seral EIS from the Stanislaus NF. Now one thing that’s interesting is how different the discussion feels in the Sierra compared to, say, Montana.
Here is what I found (my interpretation so you can check for yourself). It appears that the primary rationale for veg treatments in that EIS was… HRV (possibly NRV, I’ve never figured out the difference). Conveniently, the PSW had issued a GTR about past conditions.
So the Stanislaus folks seemed to be making the case (apologies to them if I got this wrong). 1. Plans and the planning rule tell us to move to HRV. 2. That is different density and age classes than what they have. 3. So they need to move in that direction by reducing density. 3. This should be better for wildfire resilience as well as forest health (because healthier trees are more resistant to bugs) and 4. By the way, this should also help with wildfire, and they have complicated models about flame length and so on, that they are using.
So I wonder how other forests are describing their purpose and need? It seems like the 2012 Planning Rule would inevitably lead to a need for de-densification after 100 years of fire suppression. Maybe you all could take a look at their neighboring forest’s EAs or EIS’s for vegetation management and see how the purpose and need is framed.
And if it turns out that H-NRV vegetation-wise is not a good goal.. maybe the 2012 Rule needs to be amended (or NFMA itself).
Treatment Types and Methods
The Proposed Action would apply treatments in different emphasis areas to meet objectives for enhancing forest resilience, restoring fire dynamics, and conserving biodiversity as described below and shown in Figure 2-1. The treatment scenario presented under the Proposed Action identifies approximately 146,000 acres for treatment. Treatments would be conducted in areas where existing conditions triggered a need to reduce fuel loading, reduce stand densities, develop large trees
(particularly fire-resistance pines and oak), create heterogeneous stand structures, and promote tree species composition aligned with an active fire regime.
Vegetation and fuels management treatments proposed include prescribed fire, thinning from below, variable density thinning, creation of 1- to 3- acre openings, strategic tree planting, and sanitation and stand improvement. The Proposed Action addresses a single round of treatments in each location. In this case a “single round” consists of all actions needed to achieve the target vegetation and fuels condition at the treatment site. Achieving target conditions may require multiple “entries”; for example, one entry to conduct thinning frombelow, then another entry to use prescribed fire to reduce fuel loads. Additional entries could also
result from post treatment monitoring indicating that a treatment did not achieve the desired result and further thinning, burning, or other activity is needed to achieve target conditions. However, once target conditions are achieved and restoration actions are complete (e.g., reclamation of temporary roads), a “single round” of treatment is considered complete and no further entries, treatment, or management are part of the action analyzed in this EIS.
Prescribed fire would include understory burning and pile or jackpot burning of fuels. Thinning from below focuses on removing trees from the lower canopy, thereby retaining larger overstory trees in the stand. Variable density thinning is a form of uneven-aged management designed to produce a mosaic of individual trees, clumps of trees, and small openings to enhance stand resilience to severe disturbances, create structural heterogeneity, and foster development of diverse tree species. Creation of 1- to 3- acre openings would be used to establish structural heterogeneity common in forest systems under a natural disturbance regime (Safford and Stevens 2017). Post-treatment density targets would be set based on residual basal area. Strategic tree planting of conifer and/or hardwood species would occur within approximately 10 to 20% of the 1- to 3-acre openings created while the remainder of openings created would not be planted. Sanitation and stand improvement would include the removal of mistletoe-infected overstory trees in past regeneration cuts in the red fir forest type (see Appendix A for additional detail on these treatments).
Yes, they are using variable density treatments that were deemed controversial (about wildfires) in the Bark vs. USFS case in Oregon. So I decided to take a look at the response to comments.
I never got to that specific response to that comment (fuel treatments don’t work), my rabbit trail energies ran out..but I’d guess it’s well done and interesting. Meanwhile I did find a response to some comments about what is actually allowed under the 2001 Roadless Rule, apparently not what some commenters think.
FEIS Chapter 3, Section 3.15 “Other Required Disclosures” addresses the Project’s compliance with the 2001 Roadless Area Conservation Rule. This section provides rationale for determining what constitutes generally small diameter timber in the East and West Yuba IRAs (36 CFR 294.13(b)(1)), explains why removal of generally small diameter timber is needed to maintain or restore the characteristics of ecosystem composition and structure (36 CFR 294.13(b)(1)(ii)), and describes how removal of generally small diameter timber would maintain or improve roadless area characteristics (36 CFR 294.13(b)(1)). Removing generally small diameter timber in the IRAs would meet multiple objectives, including reducing the risk of uncharacteristic wildfire effects, enhancing forest resilience
to reduce the risk of extensive tree mortality in the event of drought and associated insect infestation, and re-introducing fire in the IRAs, which has been largely absent for over a century.
A definition of generally small diameter timber is not specifically included in the Roadless Rule. “Such determinations are best made through project specific or land and resource management plan NEPA analyses, as guided by ecological considerations” (66 FR 3257). The Rule’s preamble states: “…all such determinations of what constitutes ‘‘generally small diameter timber’’ will consider how the cutting or removal of various size classes of trees would affect the potential for future
development of the stand, and the characteristics and interrelationships of plant and animal communities associated with the site and the overall landscape. Site productivity due to factors such as moisture and elevational gradients, site aspect, and soil types will be considered, as well as how such cutting or removal of various size classes of standing or down timber would mimic the role and legacies of natural disturbance regimes in providing the habitat patches, connectivity, and structural diversity critical to maintaining biological diversity” (66 FR 3257). As detailed in FEIS Chapter 3, Section 3.15, the rationale for determining generally small diameter timber considers site productivity; tree growth rates and maximum tree size; stand development, including the risk of uncharacteristic effects from wildfire and drought; and opportunities for re-introducing fire under low to moderate intensities that more closely mimic the natural fire regime.
The Sierra Nevada Forest Plan Amendment Record of Decision (SNFPA ROD 2004), which amended the Tahoe National Forest Land and Resource Management Plan, contains standards and guidelines for mechanical thinning treatments designed to retain larger trees, basal area, canopy cover, and stand structure (pp. 50 -51). The basis for applying these forest-wide standards and guidelines is California Wildlife Habitat Relationship (CWHR) classes, specifically for mature forest
habitat (CWHR types 4M, 4D, 5M, 5D, and 6). The proposed project-specific amendments for the Environmental Impact Statement – North Yuba Landscape Resilience Project
Based on CWHR tree size classification utilized in the Forest Plan, trees less than 24 inches dbh are within the small tree size class.
Existing and post-treatment diameter distributions for the IRA forest stands presented in the FEIS have been updated to include all tree sizes, including trees less than 10 inches dbh. The mid-point of the diameter distribution, quadratic mean diameter, median diameter, and mean diameter, both under existing conditions and post-treatment, are also displayed. Explanatory text has been added to the proposed action (FEIS Appendix A) and FEIS Chapter 3, Section 3.15 to clarify that thinning from below in the IRAs would involve selective removal of trees less than 24 inches dbh: not all trees less than 24 inches dbh would be removed. Some trees less than 24 inches dbh would be retained within the thinning units based on health of individual trees and crown position (healthy dominant and codominant trees less than 24 inches would be retained) and species (healthy pines would be retained). FEIS Figure 3.15-2. Immediate Post-Treatment Tree Size Class Distribution in Sampled IRA Forest Stands has been updated to illustrate selective removal of trees less than 24 inches dbh in the IRA thinning from below treatments.
As a Roadless geek, I thought this was very nicely laid out.
6 thoughts on “Two Sierra Forests’ Purpose and Need for Veg Treatments, Plus a Look at Thinning in Roadless”
I’m sorry I can’t spend a lot of time in these weeds myself, so thanks for doing this. What would make more sense to me than basal area as post treatment density targets is a target age class distribution. Using something like the CWHRs. Just using basal area could give you a skewed age distribution (the quickest way to reduce basal area could be to remove the largest trees).
“And if it turns out that H-NRV vegetation-wise is not a good goal.. maybe the 2012 Rule needs to be amended (or NFMA itself).” Well, if it’s not a good ecological goal (i.e. not sustainable under expected conditions), the forest plan needs to be amended to change the NRV. If ecological sustainability is not a good goal for a particular area (such as a WUI where big fires are the norm), then adjustments may need to be made in the plan for the rest of the ecosystem to compensate for that (since the NRV desired condition applies to ecosystems rather than sites.
Well, ‘logging for basal area’ could easily skew the data in the opposite direction if protections for trees 30″+ dbh are still protected (probable). In the past, Foresters have often complained that the markers didn’t take enough out. I’m guessing that some of those completed projects might be re-accessed, getting an opportunity to take out trees with a larger average diameter (but still under 30″ dbh). Adding another intermediate “thin from below” project to a stand might be a good compromise, in some situations.
In my experience, NEPA analyses too often present the effects of wildfire under the no action as negative, and the effects of wildfire under the action alternatives as beneficial. However, the 2017 Fuels Report for the East Hills Project on the Fremont-Winema NF admits that wildfires are expected to have beneficial effects even under the no action alternative
“Overall expected value of fire effects is moderately beneficial. This assumes that fires burn throughout the range of conditions – actual current practice is to suppress fires that are most likely to be beneficial.”
https://usfs-public.app.box.com/v/PinyonPublic/file/933489880976. Based on this information, the correct way to describe the effects of the action and no action alternatives with respect to how they interact with wildfire is varying degrees of beneficial impacts. This also indicates a need to modify fire suppression practices and work with fire when weather conditions are favorable.
Thanks for this example. I took a quick look at how they might have followed through on this in the NEPA documents.
Their purpose and need includes “improving resiliency to the effects of climate change, drought, wildfire risk, insects and disease.” As for wildfire under the no action alternative, “Areas would continue to accumulate fuels with the potential for a wildfire causing unwanted damage…” This doesn’t seem to line up too well with the idea that wildfires would be beneficial.
The fuels person used a model to arrive at those conclusions. Clearly it depends on weather at the time, presence of fuels, how big the fire is already when it hits a site, and so on. So any model would have to generalize somehow across all the possibilities. Similarly, the benefits would be different, say to invasive species, than to other factors. To say that “wildfires” in general would be “beneficial” involves making assumptions about which kinds of conditions are more likely, and weighing different impacts as more important than others albeit indirectly.
The discussion in the P&N and the fuels report seem to talk interchangeably about HRV and resilience. Keeping old trees is good either way. Some would argue the way to deal with that is to be able to make them less susceptible to burning up.
Do you think the fuels person modeled the likelihood of a fire occurring in this place within the relevant timeframes, and the potential and likely intensity, under no action (but didn’t discuss it)?
I’m sorry I can’t spend a lot of time in these weeds myself, so thanks for doing this. What would make more sense to me than basal area as post treatment density targets is a target age class distribution. Using something like the CWHRs. Just using basal area could give you a skewed age distribution (the quickest way to reduce basal area could be to remove the largest trees).
“And if it turns out that H-NRV vegetation-wise is not a good goal.. maybe the 2012 Rule needs to be amended (or NFMA itself).” Well, if it’s not a good ecological goal (i.e. not sustainable under expected conditions), the forest plan needs to be amended to change the NRV. If ecological sustainability is not a good goal for a particular area (such as a WUI where big fires are the norm), then adjustments may need to be made in the plan for the rest of the ecosystem to compensate for that (since the NRV desired condition applies to ecosystems rather than sites.
Well, ‘logging for basal area’ could easily skew the data in the opposite direction if protections for trees 30″+ dbh are still protected (probable). In the past, Foresters have often complained that the markers didn’t take enough out. I’m guessing that some of those completed projects might be re-accessed, getting an opportunity to take out trees with a larger average diameter (but still under 30″ dbh). Adding another intermediate “thin from below” project to a stand might be a good compromise, in some situations.
In my experience, NEPA analyses too often present the effects of wildfire under the no action as negative, and the effects of wildfire under the action alternatives as beneficial. However, the 2017 Fuels Report for the East Hills Project on the Fremont-Winema NF admits that wildfires are expected to have beneficial effects even under the no action alternative
https://usfs-public.app.box.com/v/PinyonPublic/file/933489880976. Based on this information, the correct way to describe the effects of the action and no action alternatives with respect to how they interact with wildfire is varying degrees of beneficial impacts. This also indicates a need to modify fire suppression practices and work with fire when weather conditions are favorable.
Thanks for this example. I took a quick look at how they might have followed through on this in the NEPA documents.
Their purpose and need includes “improving resiliency to the effects of climate change, drought, wildfire risk, insects and disease.” As for wildfire under the no action alternative, “Areas would continue to accumulate fuels with the potential for a wildfire causing unwanted damage…” This doesn’t seem to line up too well with the idea that wildfires would be beneficial.
The fuels person used a model to arrive at those conclusions. Clearly it depends on weather at the time, presence of fuels, how big the fire is already when it hits a site, and so on. So any model would have to generalize somehow across all the possibilities. Similarly, the benefits would be different, say to invasive species, than to other factors. To say that “wildfires” in general would be “beneficial” involves making assumptions about which kinds of conditions are more likely, and weighing different impacts as more important than others albeit indirectly.
The discussion in the P&N and the fuels report seem to talk interchangeably about HRV and resilience. Keeping old trees is good either way. Some would argue the way to deal with that is to be able to make them less susceptible to burning up.
Do you think the fuels person modeled the likelihood of a fire occurring in this place within the relevant timeframes, and the potential and likely intensity, under no action (but didn’t discuss it)?