As Brett says, an op-ed isn’t long enough to contain all the nuance that folks at TSW are interested in. Thanks to him for writing in with “the rest of his view of the story.”
I appreciate your thoughts on my editorial. As you can imagine it is not possible to get everything you want to say in 600 words or less. You covered the points I wanted to make well – the Fishlake NF may not have prioritized the right areas or right treatments if they wanted to limit effects on human infrastructure. My view of recent aerial photographs suggests they may have gotten some of the harvest done, but that they had not done enough. The Big Flat NEPA document never even talks about conflagration, despite the Twitchell Fire in 2010 burning in the exact same way (high intensity fire and flooding debris torrent) at the Northern boundary of this fire. Had it been more open about what was likely to happen rather than a general discussion of reducing fire risk, maybe the public would have been more involved. Like all big fires, it is hard to know if any thing the Forest Service did would have change the fire behavior – but they only had one action alternative so there is no way to critique their analysis of this topic. These large scale NEPA projects, where lots of acres are treated a long way from where people live, are common in this Utah. When I run into these treatments in the woods, it is clear that they will reduce fire intensity within the treated area but probably not at the larger scale. Given budget and staffing reductions, I don’t see this as the most successful approach for all places and situations. Don’t get me wrong, there are many forests in the West that are aggressively treating forests as close to human habitation as the public will allow (but NIMBYs are a different problem).
The issues I did not add for lack of space include there was no litigation of any of the three NEPA projects in the Cottonwood Burn area signed in 2011, 2016, and 2018. Lawsuits are often cited as a reason why the Forest Service can’t do the right thing. So, arguments that environmental groups were a problem does not fit this situation. It is important to recognize one of the reasons they justified treatments in this area (rightfully so) was it was in WUI. The descriptions of the treatments in the NEPA document are at best vague, which is becoming more common in Utah. Seems like the descriptions could have taken a little or a lot of the vegetation from most of the described units depending upon who was leading the effort.
As for the comment that this fire was so big the treatments couldn’t be expected to stop it. That might be true, but it is a best-case scenario as the Forest Service had asked for and received the authority to treat a lot of acres for a long time in the burn area. Finally, it is the big fires we can’t stop that cause most of the problems and are becoming more common. These are the fires the public are concerned about.
This is an important point as a number of politicians from Utah and other states came to this fire and suggested that if the Forest Service had just been allowed to manage this area (https://www.fox13now.com/news/politics/destruction-in-beaver-has-utahs-political-leaders-pushing-forest-management) we would have been better off. The problem was that the Agency had been able to manage it and the fire and floods still came.
More questions… were the fuel treatment decisions done with the idea of PODs and landscape-scale fuels designs? Because it does seem like consideration of different wildfire scenarios would be a topic considered in the NEPA document. I could see that they could still have one alternative, but have used different wildfire scenarios in developing the alternatives.
It would be interesting to see if other units approached their fuels reduction designs including different wildfire scenarios. Certainly “it happened before and now there are lots of dead fuels” seems like it would be a consideration.
There are two issues I struggle with daily that this discussion highlights.
The first is the random acts of thinning approach that often results from the status quo. If a stand is treated with mechanical and pile burning, the stand will be more resilient after the treatment, but what was the effect of the stand-level treatment on landscape wildfire risk? I have seen too many commercially thinned and burned stands next to untreated stands where the treated stand gets cooked from active crown fire moving in from the untreated stand. The cause of this problem is built into the existing planning paradigm, which I see goes like this: delineate as many commercial units as is feasible in a planning area based on where the timber is and also plan a lot of non-commercial pie in the sky fuel work. We know most of the commercial work will get done because it pays for itself. The pie in the sky non-commercial work will only get done if the stars align and there’s money, staff, and someone (internal or external) that is championing the work. This is also why staff are so pro-commercial. It’s work they know will get done and with much less effort. Unfortunately, the pie in the sky stuff is often necessary to tie the commercial work together. The result is that we end up with a bunch of random acts of thinning and then move on to the next planning area.
The second issue I have with this is we analyze the effects of the proposed action in our NEPA and ESA work assuming it is all going to get done. Such analyses are not based on reality. Assuming it’s all going to get done, when we know it won’t, suggests to the public that the project is great and will provide a resilient landscape, when the reality is there will only be a marginal benefit to landscape resilience, possibility at the cost of other values. The flip side to this is that I definitely don’t want to see less non-commercial work being planned. If we don’t plan it, it definitely will not get done. The fewer hurdles to getting the most important part of the work done (IMO) the better, but how do we account for the probability that a bunch of the planned work won’t get done in our analyses? NTM, folks are rarely honest with the public about the fact that the treatments will only be effective for 10 to 20 years in most dry forest systems. For a 20-year project, which I see as common these days, some of the treated stands will no longer be resilient halfway through project implementation.
It would be interesting for someone to bring this up as a NEPA/ESA issue where there is a track record indicating the noncommercial work is typically not being done, and make them “be honest with the public” (and the Fish and Wildlife Service) in their disclosure of effects. It seems like this would be similar to cases on mitigation, where the mitigation must be certain to occur before the effects analysis can take credit for it. Could a project decision (and contract) specify that the noncommercial work be completed prior to any commercial activity?