Fire and Fuels

Several people, including WUI residents doing mitigation work, brought this High Country News article to my attention.

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Some of my pet peeves include redefining English words and making up abstractions, simply because those behaviors tend to increase disagreements just by misunderstandings.  So here we go:

Thinning is not logging. To its opponents, thinning is a form of “silviculture by stealth,” as wildfire historian Stephen Pyne put it. Pyne, however, says thinning is more like “woody weeding.” Logging, he explained, harvests large, mature trees over large areas, while thinning mostly removes small trees. Logging makes money; thinning almost always costs money.

In plain old Helms Dictionary of Forestry, thinning is a cultural treatment made to reduce stand density.  Now, Pyne, is a fire expert for sure, but Steve just posted about the Mount Baker-Snoqualmie project that, according to the Courthouse News article:

The Forest Service approved between 2,000 to 3,300 acres of commercial thinning and 1,060 acres of noncommercial thinning.

Now in plain English “commercial” means that you can make money from the stuff.  So conceivably the old way of thinking “must be traditional sized sawtimber” to make money.. it could also be commercial firewood or chips or material for engineered wood products or biochar or….

Please everyone, let thinning mean thinning and commercial mean commercial!

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I hadn’t seen this open-access Commentary by Jones et al, called “Counteracting Wildfire Misinformation” but maybe someone posted it previously. Short and worth a read.

A continually changing media ecosystem presents challenges and opportunities to mitigating the spread of misinformation. Here, journalists and news organizations have a weighty responsibility, playing a critical and often insufficient role in reducing misinformation.

More later on that.

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And here we go….

Thinning should be followed by prescribed fire. “If you don’t follow it up with the right fire, then it’s worthless, and in many cases may have made it worse,” said Pyne. Thinning and prescribed burning are the one-two punch that will knock out many severe wildfires. Prescribed fires do have drawbacks: They are complicated to plan and execute, they dump unwanted smoke on communities, they’re subject to litigation, and in rare instances they can spark destructive burns. Nevertheless, they are sorely needed, and without them, thinning rarely succeeds.

Thinning by itself is “worthless” and it “rarely” succeeds.  It seems to me that it’s more complicated than that.  Certainly thinning without removing the material could make things worse.  But what fuels practitioner would design a project that doesn’t remove the thinned material?  The discussion in the 10 common questions paper (cited in the HCN article) is more nuanced.

Thinning from below reduces ladder fuels and canopy bulk density concurrently, which can reduce the potential for both passive and active crown fire behavior (Agee and Skinner 2005). For instance, Harrod et al. (2009) found that thinning treatments that reduced tree density and canopy bulk density and increased canopy base height significantly reduced stand susceptibility to crown fire compared to untreated controls.

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Some studies show that thinning alone can mitigate wildfire severity (e.g., Pollet and Omi 2002, Prichard and Kennedy 2014, Prichard et al. 2020), but across a wide range of sites, thin and prescribed burn treatments are most effective at reducing fire severity (see reviews by Fulé et al. 2012, Martinson and Omi 2013, Kalies and Yocom Kent 2016).

When we talk about “prescribed fires” , pile burning is not the image that springs to mind of  “prescribed fire”.  Even though it is prescribed fire..  When I looked around for a definition of all the kinds of prescribed fire, I thought this was a pretty good explanation from the BLM. And pile burning is not as complicated to plan and execute as other kinds.  Fuels folks across the west have been doing it for years.

I find this discussion a little more confusing than it needs to be.

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Kelly Andersson of Wildfire Today had a piece today on this..

Opponents of thinning and other fuels treatment methods really need to take a look at the history of Lick Creek in Montana. The Lick Creek Demonstration – Research Forest studies were established back in 1991 in western Montana to evaluate tradeoffs among alternative cutting and burning strategies aimed at reducing fuels and moderating forest fire behavior while restoring historical stand structures and species compositions.

Firefighters and numerous studies over many years credit intensive forest thinning projects with helping save communities like those recently threatened near Lake Tahoe in California and Nevada, but dissent from some environmental advocacy groups still roils the scientific/environmental community. An Associated Press story out of Sacramento in October of 2021 noted that environmental advocates say data from recent gigantic wildfires support their long-running assertion that efforts to slow wildfires have instead accelerated their spread. “Not only did tens of thousands of acres of recent thinning, fuel breaks, and other forest management fail to stop or slow the fire’s rapid spread, but … the fire often moved fastest through such areas,” Los Padres ForestWatch, a California-based nonprofit, said in an analysis joined by the John Muir Project and Wild Heritage advocacy groups.

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It sounds like some groups say.. (1) thinning with burning doesn’t work (as the above statement in the AP story)

others (2) thinning plus mechanical removal doesn’t work without burning the smaller material left over, but that depends on site-specific conditions.

I ran across this paper by Cram et al. from NM and Arizona that said, for example,  increasing surface fuels may have advantages in terms of suppression tactics.

Furthermore, when forest canopies are opened up via mechanical means, fine understory fuels can be expected to increase. The silver lining in increased fine surface fuels is the improved potential and efficiency to use back-burns ahead of a wildland-head fire, not to mention a key ecological role in the symbiotic relationship between fire and pine forests. Backfires burning through fine surface fuels are more effective and efficient in burning out understory fuels as compared to a closed canopy forest with a deep, but compacted, litter understory. Estimates of fireline intensity indicated that hand and dozer lines would have been effective containment techniques in treated stand.

IMHO this topic could really use some reporting by interviewing fuels and suppression folks and dig into the specifics of their experiences in different parts of the country. Quoting the usual academic and interest suspects is not adding much value.

Ron Steffens at Wildfire Today has a nice summary with links. I don’t know anything about this topic, but  I thought these two were interesting…and might require attention in NEPA docs? Or perhaps a multi-fed programmatic for  drones?

Using Aviation for Prescribed Burns (p 35)

Aerial resources may be used to support the use of proactive, beneficial fire like prescribed fire, both through assisting with aerial ignitions and by being on hand to respond to contingencies or undesired outcomes. However, the Commission heard that cost and availability make it difficult for agencies to access aviation resources for these project-related (rather than response-related) purposes. For example, when used for project activities not associated with wildfire response, some aviation costs must be charged to agencies’ general program budgets, which are often strained by a number of needs and priorities. For most entities, this fact makes aviation resources cost prohibitive. As an additional challenge, Commission members shared that aerial assets are often unavailable during prescribed burn windows, either because those burns happen outside the terms of seasonal contracts or because resources are occupied on wildland fires in one region when other regions have opportunities to proactively burn. In sum, greater use of beneficial fire is currently limited, in part, by overall aviation capacity and available funding. Improved aviation availability and capacity may help allow for more proactive management options in addition to providing contingency resources [F8]. As such, the Commission recommends that Congress and agencies ensure greater availability of aviation resources for risk mitigation projects, including prescribed fire [R17]

National Drone Policy (p 36)

While issues of national security are clearly important and require careful consideration, the Commission recommends improvement in the availability of drone technology for use in wildland fire [R18]. Emerging development and integration of UAS technology is a significant operational innovation in wildland fire (NIAC, 2017) and is seen by some as potentially replacing or complementing use of manned aviation resources for activities such as sensing and monitoring.
Indeed, the NIAC Vision 2027 strategic plan notes that UAS “may be the first aviation-associated operational innovation for wildland fire management operations in almost fifty years” (NIAC, 2017). UAS technology can, and should, be more robustly utilized overall in the aerial wildland fire space. In addition to needs associated with the overall availability of UAS technology, the Commission was informed that at this time, the wildland fire community lacks a national strategy for integration of this technology. Given this status, the Commission recommends that agencies develop a national UAS strategy for wildland fire [R19].

For whatever reason, sometimes it happens that agencies don’t coordinate and run off in many directions self-aggrandizing and extending their own power and/or asking for duplicate kinds of funding.  And sometimes the White House tells departments to do things that may be in conflict with Congressional intent (e.g. mature and old growth initiative).  But for something as important and expensive as the Wildfire Crisis Strategy, would it be so hard to have someone review potential rules for consistency? Hopefully, the Wildland Fire Mitigation and Management Commission will be able to nip these things in an earlier stage of the bud. But think about it.. if it has to get to the OIRA stage before someone notices these kinds of issues…something is broken in Federal Agency Coordination World.

I received the below information third or fourth hand, so I don’t know what the originating organization was, although I think the letter is well written. So kudos to whomever at whatever organization. I also don’t know what the current status is, so that’s why I’m posting this. Hopefully someone out there will know.

We understand that EPA is considering a reduction in the primary annual average PM 2.5 NAAQS from 12 ug/m 3 to between 8 ug/m 3 and 10 ug/m. 3 If such a standard is implemented without consideration for beneficial fire, it would significantly limit the number of burn windows available to public, private, and tribal land managers to implement beneficial fire across the United States. Preliminary research indicates that some areas would see a reduction in available burn days of 70-80 percent, at a time when relevant experts agree that more burn days are needed to implement beneficial fire at a meaningful pace and scale.

A key purpose of OIRA review is to ensure that EPA’s proposed rule does not conflict with the policies or actions taken or planned by another agency or the Biden Administration. (Sharon’s bold)

However, adoption of the lower PM 2.5 NAAQS without consideration for beneficial fire would result in a significant conflict. For example, the U.S. Forest Service recently issued its Wildfire Crisis Strategy 1 , which calls for “dramatically increasing fuels and forest health treatments [including beneficial fire] by up to four times current treatment levels in the West.” The Department of the Interior likewise articulated the need to increase the pace and scale of priority fuel management treatments, including beneficial fire. 2 The Biden Administration has assembled the Wildland Fire Mitigation and Management Commission to develop strategies to better prevent and manage wildfires, including through expanded beneficial fire use. 3 All of these targets are supported by significantly increased funding from the Inflation Reduction Act and bipartisan Infrastructure and Jobs Act for beneficial fire activities. Federal agencies, however, will not be able to spend these dollars and implement their planned actions if the PM 2.5 NAAQS is modified without consideration for beneficial fire.

We understand that the EPA may believe that PM 2.5 emissions from beneficial fire can be adequately addressed under the Exceptional Events Rule. Indeed, EPA engaged in rulemaking in 2016 that codified the conditions under which prescribed fires could qualify as exceptional events. 4 However, the regulatory process developed in the 2016 rulemaking is not sufficient to enable the amount of beneficial fire experts say is necessary to reduce wildfire emissions.

Exceptional Events filings are technically demanding and expensive. As such, local air regulators simply declare burn bans or deny smoke management permit requests on days where beneficial fire smoke may lead to NAAQS exceedances, rather than agree to pursue an arduous Exceptional Events filing. Indeed, we are not aware of any Exceptional Events filings for prescribed fires since the rule was promulgated. If the EPA does reduce the PM 2.5 NAAQS, additional regulatory solutions—either within the Exceptional Events rule or elsewhere in the CAA regulations—are necessary to ensure that land owners and managers can implement needed beneficial fire projects. We urge OIRA to ensure that the Notice of Proposed Rulemaking is sufficiently expansive to allow development of these solutions in tandem with any revised PM 2.5 NAAQS.

We are strongly supportive of the EPA’s intent to reduce PM 2.5 emissions. Additional regulation of stationary sources, tailpipe emissions, and similar anthropogenic sources are clearly warranted to protect public health. However, as the EPA acknowledges, the single biggest threat to public health from PM 2.5 emissions is wildfire smoke, which is currently unregulated. 5 If we are serious about protecting public health, EPA’s regulations must enable significantly greater use of use of beneficial fire, rather than continuing to treat it like other forms of pollution. Modifying the PM 2.5 NAAQS without addressing the burden of such regulation on beneficial fire use will nearly eliminate our best tool to tackle wildfire emissions.

BTW, if you’re interested, the American Lung Association funded this 2022 report called  “Can Prescribed Fires Mitigate Health Harms?” which seems to be a good roundup of current information.

Thanks to Bill Gabbert and Wildfire Today (via Nick Smith) for this one…

The U.S. Fire Administrator and principal leaders from the American fire service, in partnership with the Fire Department of New York (FDNY), the Philadelphia Fire Department, and the Washington, D.C. Fire and Emergency Medical Services Department, will stand together on Jan. 10‑12 to speak with one voice to address the fire problem facing our nation.

• 99 million people or a third of the U.S. population now live in the WUI environment, yet most have no idea what WUI is or the dangers it poses.

These are “truths”?  What does that actually mean “most” have no idea what it means? I don’t think the social scientists who study fire-prone WUI areas tells us that.  First you’d have to determine the dangers (say in Maine or Florida, or California) then you’d do a survey to see how aware homeowners were.  And of course, fire isn’t the only WUI danger.  It’s kind of an amazingly generalized statement for folks who are supposed to be experts (and dare I say building trust).

So I looked at this interesting slideshow by FEMA

If you look at the hillside, you’ll see houses with trees around them.  Is that “undeveloped wildland”?  If you live in a treed environment, wouldn’t you want to keep trees when you build a house?  Does this forest count as “fire- dependent or fire-prone”? It looks like a generic eastern forest to me.

This almost seems to conflate all WUI  with “fire problems”.  I see a couple of problems with this..they seem to use all WUI to say “1/3 is in the WUI” but only “Fire WUI” to talk about fire danger.  Which inflates the danger.  Which could be the point of this exercise- it seems more marketing than thoughtful IMHO.

My point is that the WUI is not one thing, it’s not particularly well defined, and in some areas it’s key to developing affordable housing. Personally, I also don’t think saying that 1/3 of people the US are unaware of the issues related to where they live is a good marketing strategy nor develops trust in these experts.

 I’m curious as to why specifically this appears to be an issue in this area of NM and not so much elsewhere.  We’ve discussed this project a bit before, but I think the dueling op-eds are a good place to start. Note: I’m trying to piece this together and some of those involved are readers of TSW, so I’m hoping that you all will correct me if I got something wrong. A special shout-out to the Santa Fe New Mexican for allowing us to see them all without a subscription (I did register).

Perhaps it started with a public listening session about local forest management issues sponsored by Santa Fe County Commissioner Anna Hansen, Wildearth Guardians and the Forest Advocate.  Sarah Hyden of WEG wrote an op-ed on Nov. 19th “Groups stand up to speak for forest.”

As far as I can tell from the op-ed, DellaSala described:

Collateral damages that have been caused in the Santa Fe National Forest by past thinning and too-frequent prescribed burning treatments, and the potential damage the proposed project may cause. He made a series of recommendations to improve the effects of the project on our forest and suggested the Forest Service should seriously consider the public health impacts of prescribed burn smoke.

I thought this was pretty interesting since concerns about PB smoke would be much broader than just New Mexico.  And I think they do “seriously consider” it.  But what exactly does that mean?

WildEarth Guardians’ Adam Rissien gave a short presentation focused on the lack of specificity and detail of the project proposal, and the need for a range of alternatives to be considered that truly restore forest processes. He recommended creating wetter and cooler areas, restoring compacted and dried-out soils, and reducing unneeded forest roads. I spoke for The Forest Advocate about the need to consider the potential for escaped prescribed burns, and that parameters for prescribed burns specific to the Santa Fe Mountains landscape should be considered within the project analysis.

Mr. Rissien is from Missoula apparently. I’d be interested in his recommendations if anyone has them available.

Which led to an op-ed in the Santa Fe New Mexican by Craig Allen, Matthew Hurteau and Tom Swetnam, all forest scientists who work in the SW. Their Dec. 3 op-ed was called Southwestern Forests Need Active Management.

A couple of things are interesting about that to me..  first, why pick DellaSala to talk about Northern New Mexico? Possibly because he’s a scientist.  And not to wax epistemological here, but what scientific research is “truer”, that done by people working in a specific geographic area, or scientists from elsewhere? And what specifically would be DellaSala’s claim to know more about Northern New Mexico?

Much of DellaSala’s narrative was shockingly ignorant of local forest conditions, histories and trends. From a scientific perspective, much of DellaSala’s presentation was inaccurate, unbalanced, incomplete or inconsistent, exhibiting classic examples of wildfire misinformation (e.g., described here: esajournals.onlinelibrary.wiley.com/doi/epdf/10.1002/fee.2553).

So the NM scientists did their own webinar.

We also know that restoring the right kinds of fire and forest densities, based on a scientific understanding of the local ecology, can help our forests adaptively persist in the face of ongoing climate change. If interested in continuing the conversation, we will participate in an interactive public webinar at 6 p.m. Dec. 15 to share and discuss the best available forest and fire science for our Santa Fe mountains landscape, livestreamed through the Santa Fe Fireshed Coalition Facebook page.

Then another op-ed by Dominick Dellasala “Forest Service must hear concerns” on December 11.

To represent legitimate public concerns is not misinformation; it’s truth telling, however inconvenient for some. Respectful communications are essential in avoiding my-way-or-the-highway attitudes — and for listening to an otherwise disenfranchised community that is anything but powerless.

So Dellasala has switched a bit to “representing legitimate public concerns” and people who don’t want thinning projects are “disenfranchised.” I thought that this was a little funny,,

The larger issue at stake is whether the U.S. Forest Service can listen to requests for a full environmental analysis of the impactful Santa Fe Mountains Landscape Resiliency Project and whether independent scientists without a stake in government funding are on equal footing. Strong-arming scientists and concerned citizens who speak truth to power never works.

He makes the common claim that people who disagree with him depend on government funding (same as the Sierra scientists).. I don’t know if that is respectful of them.  I don’t see the NM scientists “strong-arming” nor the Santa Fe NF.  And ah… speaking “truth to power”.. I would have to say that in terms of influencing forest policy DellaSala and WEG have much more power than the folks on the Santa Fe and their local collaborative groups.

But here’s my favorite statement from the op-ed:

Scientists often disagree over how we view the natural world. I see forests as a kind of super-organism, an interconnected marriage of form, function and process uniquely adapted to fit the environment and sometimes in need of legitimate restorative actions.

That’s actually a philosophical stance.  Which is fine (I don’t happen to agree, but we all get to have our own philosophical/spiritual beliefs).  But I think that having different philosophies about the natural world is different than claiming the authority of science for specific  philosophical views. And maybe that should be the centerpoint of the discussion.

The latest op-ed as of today is by Robert Kirmse.  It’s called “Forests in Danger; time to act is now.”

Moreover, DellaSala goes on to parrot more of the organizers’ twisted logic: that 98 percent of those who spoke at that one-sided event favored conducting an environment impact statement. Well, of course, they were; the meeting was organized and mainly attended by and promoted by well-meaning, but misguided, collaborators of those local nongovernmental organizations.

I don’t know about New Mexico, but the feeling I get is that these people want specific changes, but ask for more analysis, alternatives, etc.  I don’t actually believe, as in the Montana lodge expansion case, that more analysis will solve the problem of people disagreeing.  Certainly it will delay and provide more legal hooks for litigation, but the end result could be the same.  Especially if you really believe that the NM scientists and the local Forest Service people are “strong-arming concerned citizens” and are ignoring “the truth”.. there would just be more citations of papers some people disagree with and more pages for the real public not to read. I hear much frustration among everyone here, but shouldn’t the conversation be specifically about what changes some would like to see?  What are they afraid of the FS doing “wrong”? Maybe that’s there somewhere outside of the op-eds.

Also, in the areas I’ve worked there are local folks and groups with a variety of concerns about projects.  Perhaps we can ask them what their views are on all this; and specifically what changes they would like to make to the project.

Many thanks to Claudia Elliott for this guest post.

About a hundred people gathered at Calaveras Big Trees State Park on Dec. 14 to hear — and provide — updates to efforts to save giant sequoias. The purpose of the meeting was to allow members of the Giant Sequoia Lands Coalition to report accomplishments in the group’s first full year of operation.

The natural range of the giant sequoia is in a narrow belt of the southern and central Sierra Nevada where they grow in about 80 groves interspersed with other conifers. The region has been hit hard with high intensity wildfire in the past few years and the loss of giant sequoias has been shocking.

With snow on the ground outside the meeting room, speakers representing coalition members shared their progress on accelerated efforts to reduce fuels during 2022 and other efforts.

Collectively, according to a report prepared for the event, coalition members conducted restoration treatments — including thinning and prescribed fires — on 4,257 of 26,000 acres in 36 of approximately 80 giant sequoia groves.

Although much remains to be done, this was more than twice the 2,000 acres set as a goal for the year.

Fuel was reduced around more than 4,000 giant sequoia trees and coalition members planted more than 248,000 native conifers, including giant sequoias.

In addition to the work in the field, the coalition reported that numerous scientific studies were advanced this year and public outreach and education efforts resulted in placement of more than 10,000 stories about giant sequoia issues in the media.

The work cost about $10.5 million, according to the report, and involved 824 people.

You can read the report here.

And you can read a special edition of my weekly Giant Sequoia News newsletter here.

The coalition has just unveiled its website here.