Fire and Fuels

Indigenous fire management and cross-scale fire-climate relationships in the Southwest United States from 1500 to 1900 CE

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Many interesting things about this paper.. (no paywall, yay!) but the fact that effects at different scales can be different and that real world phenomena may not be detectable at larger scales. So a danger if “the science” is only done at a larger scale. People and organisms tend to live at the local scale or landscape,, so one would imagine impacts at that scale are most important to study.  So at least studies should be conscious (and explain in the text?) of their choice of scales, and relevance to the topic and  local people and environment.  Otherwise it may not only discount local observations and experiences, but give a veneer of “science” to those scale-dependent views.

At the landscape scale, drought remained a potent driver of fire activity even during intensive use, suggesting that even in heterogeneous fuelscapes created by Indigenous patch burning, climate could overcome limitations in fuel continuity and promote spreading fires. These observations corroborate prior research that Indigenous patch burning can buffer—but not entirely eliminate—local- to landscape-scale climate influences on widespread fire activity (10). We show that this effect is scale dependent. Locally, the buffering of climate influences was strongest. At the landscape scale, climate impacts were moderated, but drought persisted as an important influence on fire activity. At the regional scale, the canonical climate pattern continued to be the primary driver of fire activity through time. The repetition of this cross-scale variation in fire-climate drivers across all cultural regions and periods hints at a common cause—human impacts on fire regimes were scale dependent, in space and time (13). This scale dependency means that paleofire records composited and assessed at regional scales can mask important, localized Indigenous influences on fire activity and the ecological and social influences of this management (13).

 

Here are the management implications:

 

These results also have implications for modern fire management and policy. In the wake of recent wildfire disasters—fires that damages homes, infrastructure, water sources, and kill humans—there have been calls to restore traditional Indigenous burning practices in western North America (7, 65) and elsewhere (66). Indigenous-managed pyrodiversity offers the opportunity to reduce fire hazard (6), support fire-sensitive plant and animal species (8), reduce carbon emissions (67), and empower Indigenous people (7, 65, 68). Our results show that a further benefit of supporting, restoring, or emulating Indigenous burning practices, including modern prescribed burning efforts, would be the buffering of the impact of increasing fuel aridity on fire activity. To achieve landscape and regional scale fire-climate buffering, however, these applied burning practices would need to be conducted often and at the scales of interest or in strategic locations that have particularly important influence on landscape-scale fire behavior (69). Land managers have struggled to accomplish this goal (70), but future management aims for increasing prescribed burning by more than an order of magnitude (56, 71). As was the case in recent centuries, climate will continue to play a strong role in influencing fire activity even in the best-case management scenarios. However, Indigenous burning, prescribed burning, and managed wildfire at the appropriate scales (7, 65) can all contribute to undermine climate as a “force multiplier” in our wildfire challenges as we endeavor to get more “good fire” on the ground (22, 72).

Wildland Fire Metareview

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Here’s the link.

After the 2015 Twisp Fire, agency leadership directed the learning team to look across multiple years of incidents and accidents to see what lessons could be learned by taking a “meta” approach to systematically reviewing past events. Looking across multiple incidents allows themes to be detected in ways that single accidents don’t allow. Their review examined accidents and incidents, including fatality incidents, in the Forest Service over a 10-year period (2007-2016). Chapter 3 of the metareview includes the quantitative and qualitative analysis of this data.

 From their analysis, five themes emerged. To dive deeper into the learning around these themes, in 2019 the learning team conducted five focus groups comprised of a cross-section of Forest Service employees who work in wildland fire management and academic subject matter experts. The focus group findings are detailed in chapters 4-12. The format is intentionally presented in an open way that is intended to facilitate discussion and individual and group learning. Each chapter highlights information from the meta-analysis and focus groups and then broadens the conversation by including learning challenges to prompt discussion among your local work group.

Out of the quantitative and qualitative work of the previous chapters, chapter 13 introduces an ongoing learning strategy.

As you work through the discussion tool and learning challenges, you will see the themes that emerged from the metareview effort:

Fatalities and injuries: Why are they continuing to occur?
Fiscal incentives: How does the current pay structure affect operational strategies and risk management?
Society: How do social and political pressures play into the wildland fire system?
Ecological soundness: How do ecological health and land management factors currently play into wildland fire decision making and strategy planning processes?
Communication/work environment: What do current successes and failures look like in the context of communication and the wildland fire work environment?
All these are great questions and ones that as an agency we continue to grapple with.

Obviously, the Forest Service did quite a bit of work on this. This isn’t an area of knowledge for me, so hoping TSW readers will look into this and give us your thoughts.

GAO Report on Barriers to Recruitment and Retention of Federal Wildland Firefighters

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Here’s a link to the report.

I don’t know how many TSW ites are involved in fire or fire hiring, but I’d be interested in your impressions of the report findings.

Also, I wonder which of these barriers are also barriers to other FS (and possibly BLM) hiring?
The FS retiree rumor network circulated that the FS was trying to hire 800 slots and at the end of the day would only get about 500 reporting (anyone with better info, please add). So it’s possible that there are barriers to hiring all kinds of folks; perhaps not the same barriers. Maybe it also depends on what the alternatives for employment are. I have heard that fewer folks want to work in the woods/brush/grass and more want to work in the office on computers, but I don’t know if that’s true.

But back to fire folks.. there’s an interesting discussion in the comments on Wildfire Today here.

What GAO Found
The federal wildland firefighting workforce is composed of approximately 18,700 firefighters (including fire management and support staff) from the Department of Agriculture’s Forest Service and from four agencies in the Department of the Interior. The Interior agencies are the Bureau of Indian Affairs, Bureau of Land Management, Fish and Wildlife Service, and National Park Service. GAO identified seven barriers to recruitment and retention of federal wildland firefighters through analysis of interviews with agency officials and 16 nonfederal stakeholders and a review of documents (see fig.).

Low pay was the most commonly cited barrier to recruiting and retaining federal wildland firefighters. Officials and all 16 stakeholders stated that the pay, which starts at $15 per hour for entry-level positions, is low. Officials and eight stakeholders also noted that the pay does not reflect the risk or physical demands of the work. Moreover, officials and stakeholders said that in some cases, firefighters can earn more at nonfederal firefighting entities or for less dangerous work in other fields, such as food service. The Forest Service and Interior agencies have taken steps to help address this barrier. For example, in 2022, the agencies worked with the Office of Personnel Management (OPM) to address a provision of the Infrastructure Investment and Jobs Act calling for the agencies to increase firefighter salaries by the lesser of $20,000 or 50 percent of base salary in locations where it is difficult to recruit or retain wildland firefighters. In June 2022, the agencies announced that the salary increase would apply to wildland firefighters in all geographic locations, as their analysis indicated that recruitment and retention challenges existed in all locations. The act authorized funding for the wildland firefighter provisions, including those related to salary increases, for fiscal years 2022 through 2026, and appropriated some funding toward those provisions.

The Forest Service and Interior are taking steps to address other barriers as well. For example, to help improve work-life balance for firefighters, the Forest Service increased the size of some firefighting crews, a change intended to allow crew members to more easily take time off for rest or personal reasons, according to Forest Service officials. In addition, in fiscal year 2021, 84 percent of federal firefighters identified as men and 72 percent identified as White. To increase diversity, the agencies have recruited women and underrepresented racial and ethnic groups, including through a wildland firefighter apprentice program. The agencies are also taking steps to improve mental health services and hiring practices

E&E News has an article on it, here’s an excerpt:

In a wildland fire review on the Forest Service website last Thursday, officials referenced the increased pay and new emphasis on mental health — a reflection of GAO’s finding that emotional strain remains one of the barriers to hiring and retention.

“We look forward to continuing this conversation with the wildland firefighter community as we work to build and solidify the well-supported, more permanent wildland firefighting force needed to address the wildfire crisis,” said Deputy Chief for State and Private Forestry Jaelith Hall-Rivera and acting Deputy Chief for Research and Development Cynthia West.

The Forest Service and the Interior Department together have a firefighting force of about 18,700, including support staff. Some 84 percent of firefighters in 2021 were men, and 72 percent white, although the agencies have focused recent recruitment at women and underrepresented racial and ethnic groups, GAO said.

To make further improvements, the Forest Service may need to pay particular attention to the concerns of people in their 20s who want to be firefighters, or to remain firefighters. That’s a priority for a group called the FireGeneration Collaborative, which sent representatives to the nation’s capital last week.

“They’re failing to connect with our generation,” said Kyle Trefny, a student at the University of Oregon and one of the group’s organizers, who’s also a wildland firefighter in the summer.

Trefny and others who visited with Forest Service officials and lawmakers said they’re pushing the agency to adopt policies and approaches more in line with younger adults who want to pursue careers in firefighting. Those include more diversity in fire crews, an embrace of planned fire as a forest management tool and flexibility in certain hiring practices.

Themes from Forest Service/NFF Wildfire Crisis Roundtables’ Recommendations

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I received this email yesterday..

Thank you for your interest in the webinar “Wildfire Crisis Strategy Roundtables: Recommendations and Next Steps,” hosted on November 14, 2022, by the National Forest Foundation (NFF) in coordination with the USDA Forest Service.

A recording of the webinar and associated presentation is available on NFF’s Wildfire Crisis Strategy Roundtable webpage.

In addition, the Forest Service released a new ArcGIS StoryMap, “Confronting the Wildfire Crisis,” which provides context and shows the ten initial priority landscapes.

Here are the recommendations.

Some of these sound familiar from the EADM dialogues.  It looks like forest resilience is an important management objective (thank Gaia they got away from the unnecessary “resiliency”).  Which I’m sure will cause some to wonder “is that the same as integrity, or does the planning rule need to be revised?” Can integrity be redefined (and NRV) in the planning handbook to be the same as resilience?  Or are these abstractions headed for a showdown somewhere and sometime?

If I were asked how climate is incorporated into this list, I would say resilience includes climate, and the “tradeoffs and benefits” in 10 include carbon benefits.

Looking at these from the 10,000 foot level, I wonder if characterizing federal land management as responding to the “wildfire crisis” or the “climate crisis” leaves recreation, probably the #1 interest of the US public, once again sitting in the wings of important FS activities.  What do you think?

Shout Out to Blue Mountain Eagle for Burn Boss Arrest Coverage

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A firefighter uses a drip torch as part of the Starr 6 prescribed burn in Bear Valley on October 22, 2022. Tony Chiotti/Blue Mountain Eagle.

 

Thanks to the Hotshot Wakeup Person (HWP), I ran across what appeared to be excellent reporting on the Arrested Burn Boss incident in Oregon from the Blue Mountain Eagle. In the spirit of “catching people doing something right”,  check out their story.

A Forest Service Law Enforcement and Investigations officer had been requested for the Oct. 19 burn. This was not a standard arrangement, according to current and retired Forest Service officials. The request was made directly in response to verbal harassment and perceived threats the crews had reported on the previous day of burn operations on Oct. 13. That law enforcement officer was not able to be on the scene due to an injury, but the burn went ahead.

Because that officer was not on scene, there was no law enforcement authority on the federal side when the sheriff arrived.

Ludwig describes a scenario in which federal and local law enforcement authorities could have “concurrent jurisdiction,” meaning both could arrest individuals if they had probable cause to believe a crime had been committed. She sees nothing that could prevent a sheriff from arresting a federal employee, which is exactly what happened. But given that the confrontation between McKinley and Snodgrass happened while both were in the process of carrying out their lawful duties, it could have gone the other way, with the sheriff being placed under arrest.

“If somebody interferes or obstructs (a federal officer), in general, that could lead to a federal charge,” Ludwig said.

HWP wondered how the situation might have changed had the FS been able to fill the requested FS LEO slot.  Some people think perhaps both sides would have arrested each other; I think the two law enforcement folks would have communicated in their own shared verbal and nonverbal language, from their shared understandings of their work, and worked it out with no arrests.   Who knows?

Also I wonder how necessary it is to do prescribed fire in those specific locations (where it is felt necessary to have LEO support),  Maybe people with a wildfire background can add their perspective.

 

Sierra At Tahoe Ski Area Re-opens

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After the Caldor Fire seriously impacted the ski area, Sierra At Tahoe is open again. As you can see, it was a high intensity portion of the fire, with the previous forest being highly flammable and loaded with decades of heavy dead fuels. After several droughts, the area did not have any salvage operations. The area is also known to have nesting pairs of goshawks around.

As you can see, snow sports people will be enjoying a new experience of skiing and boarding, without so many trees ‘hindering their personal snow freedoms’. *smirk*

TGIF Smokey Wire Edition: Australians’ Fire Objectives, Surprising New Technologies and More

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Too many stories of interest to go into deeply.

Australians Think About Objectives and Key Performance Indicators for Bushfire Management

It’s always interesting to see how other countries deal with the same issues we do.

The Goals described in the National Bushfire Management Policy Statement for “Effectively Managing the Land with Fire” can be divided into the following objective themes. These themes then need to be expressed in more specific terms to become landscape-level management objectives. For a management objective to be useful, it must be Specific, Measurable, Achievable, Relevant, and Time-bound (SMART). The themes identified are:
a) Reduce wildfire severity and extent
b) Reduce impact of fire on human life and property, social and commercial values, and critical
infrastructure.
c) Maintain viable, resilient and sustainable ecosystems
d) Maintain or enhance landscape productivity including wood, water, carbon, biodiversity and
other ecosystem services
e) Use adaptive management
f) Increase or maintain the level of social licence to manage forests and rangelands
g) Increase or maintain the level of Indigenous cultural and social connection through use of fire

The objectives and KPIs seem very down to earth. check it out here KPI-Doc. Lots of interesting stuff in this document.

Housing

More Colorado towns raised taxes on short-term rentals this election — and are using the money toward affordable housing

Interesting story on resort towns where people can’t afford to live.. related to difficulties FS employees’ retention.

Compelling New Technologies

Number 1.. sustainable batteries which also don’t depend on imported minerals..

Stora Enso and Northvolt are joining forces to create sustainable batteries using lignin-based hard carbon produced with renewable wood from the Nordic forests. The aim is to develop the world’s first industrialised battery featuring anode sourced entirely from European raw materials, lowering both the carbon footprint and the cost.
The companies have entered into a Joint Development Agreement to create a sustainable battery featuring anode produced from renewable raw materials sourced sustainably and locally in the Nordic countries.
“The joint battery development with Northvolt marks a step on our journey to serve the fast-growing battery market with renewable anode materials made from trees. Our lignin-based hard carbon, Lignode® by Stora Enso, will secure the strategic European supply of anode raw material, serving the sustainable battery needs for applications from mobility to stationary energy storage,” says Johanna Hagelberg, Executive Vice President for Biomaterials at Stora Enso.

And Number 2. (of course), from the always-informative and entertaining Cowboy State Daily.

What A Way To Go: ‘Krapp Strapp’ No. 1 Way For Wyo Outdoorsmen To Do No. 2, Inventor Says

The company specializes in hunting decoys, but one of its best-selling products is the “Krapp Strapp.” It’s a device that allows users to lean into a padded strap, thereby taking the weight off their joints while answering nature’s call. ..

When shown a photo of the Krapp Strapp, noted Wyoming outdoorsman Paul Ulrich agreed it would be great for older adventurers or other people with joint problems.  But he was incredulous about its practicality for younger, fit hunters trying to pack light in grizzly country.

“Reminds me of the scene with the goat in ‘Jurassic Park,’” Ulrich told Cowboy State Daily. “Nothing easier for a predator than a meal tethered to a tree with its pants down.”

This excerpt would be incomplete without a photo..

Californians Disagree About Solar

One of my favorite reporters, Sammy Roth, covers the always-watchable Californians grappling with decarbonization. Basically, people have solar panels. How much should utilities pay them for their energy? Does that come out of the pockets of people who can’t afford solar panels? How do you do decarbonizing and social justice at the same time? Indeed,  liquids are bubbling in the laboratories of democracy.

But it could still have dramatic ripple effects in the burgeoning rooftop solar market as the Golden State struggles to phase out planet-warming fossil fuels while avoiding blackouts and keeping electricity bills from spiraling out of control. And it’s sure to spark a bitter fight in Sacramento, as rooftop solar installers, monopoly utility companies and labor unions whose members build large-scale solar farms duke it out over the best way for California to confront the climate crisis. Already, the new plan is generating criticism from both the solar industry and a group backed by Southern California Edison and other utilities. The utilities say low-income households are being forced to subsidize wealthier solar customers.

 

New Steel et al. Paper: Mega-disturbances Cause Rapid Decline of Mature Conifer Forest Habitat in California

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The Rim Fire in the Stanislaus National Forest U.S. Forest Service photo.

I don’t think the findings of this paper will be surprising to many TSW readers. I usually try to excerpt from the discussion, but this paper also has a management implications section. The basic story is that ideas developed around mesic forests may not work in dry forests. “Protected” areas, including important endangered species habitat, may be lost to wildfire, beetles or drought, or any combination thereof, whether due to AGW, historic fire suppression, human ignitions or any combination of the above.. what is, is. Here’s a link in case it’s not posted on Treesearch yet.

***Note: some of what these authors claim is contrary to the “science-based” claims of many MOG advocates. It’s easy to say your claims are based on “science”; it’s a bit harder to dig into the existing scientific studies and what they show; especially if they disagree. The authors also question static conservation approaches (if this reminds you of Botkin’s 1992 book Discordant Harmonies, the idea has been around for a while), e.g, “Thus even today, in both law and in practice, the scientific conservation of endangered marine species continues to be based on the idea that nature undisturbed is constant and stable . . .” I wonder whether resistance to change from this static worldview is perhaps a form of scientific/philosophical comfort with the status quo or that the momentum of law and policy is just too strong for the few voices saying “maybe not.” Anyway, back to the paper.***

Such “static” conservation approaches are heavily embedded in existing wildlife and ecosystem conservation policy (Leopold et al. 2018), as well as land management plans (e.g.,USDA 2004) in North America. Yet recent disturbance patterns and their cumulative impacts have demonstrated that efforts to resist change are often falling short in dynamic ecosystems, such that achieving the specific conservation objectives and possibly the intent outlined in policy documents may no longer be feasible in disturbance prone areas (Davis et al. In Press). In fact, continued attempts to resist change may be counterproductive where a hands-off approach (but continued fire suppression) creates a higher likelihood of rapid, transformational, and undesirable changes in the form of large scale type conversion and habitat loss from disturbance (Rissman et al. 2018). In our study region spotted owl Protected Activity Centers are often managed using a static conservation approach but our analysis shows they have recently experienced more declines in canopy cover (49% relative to 2011) than outside of their borders (40%). This observation suggests that conservation of habitat for old-forest dependent species may require a more dynamic approach that increases resilience to disturbance while maintaining valuable habitat features such as large, tall trees.

This is from the last section of the Discussion.

Rapid loss in mature forest habitat in the southern Sierra Nevada and longer term trends in fire-related forest decline throughout California (Stevens et al. 2017, Steel et al. 2018) suggest that existing forest management paradigms may be inadequate for maintaining mature mixed-conifer forests under current and projected future disturbance dynamics (North et al. 2022). If these rates of decline continue, we are likely to see near total loss of southern Sierra Nevada mature conifer forests in the coming decades. This would be much more rapid than the time horizon of mature forest loss estimated by Stephens et al. (2016b) (by 2089, or ~75 years). However, Stephens et al. (2016b) did not consider drought-related mortality, and only analyzed fire activity up through 2014, which missed the record fire year of 2020 (Safford et al. 2022). It is worth noting that the extreme fire activity documented in California during 2020 was likely not a one-off anomaly; recent observations indicate similar, if not exacerbated fire activity in 2021 (Shive et al. 2021).

The region has also reentered extreme drought (Williams et al. 2022) with implications for both drought and beetle mortality and severe wildfire. More optimistically, total loss of mature forests in this region could be delayed until mid-century if we enter a period of cooler, wetter years, if surviving mature forests within these fire footprints have gained resilience to future disturbances, or if recruitment of mature hardwood species compensate for losses of large conifers. Hardwood species may become a greater component of the Sierra Nevada landscape as conifers decline (Restaino et al. 2019, Steel et al. 2021b). Oaks, especially California black oaks, are relatively resilient to both wildfire and drought, and are utilized by species such as the spotted owl and fisher (North et al. 2000, Aubry et al. 2013, Green et al. 2019). However, loss of mature forest habitat, on any likely timeline, is unsustainable given that the recruitment of conifer or hardwood mature forests takes many decades to centuries. Stephens et al. (2016a) emphasize that policies prioritizing forest resilience over other resource concerns may be needed to meaningfully address the current backlog in forest management and shift course from forest decline to sustainable disturbance dynamics. Indeed, our analysis showed that areas of higher canopy cover are more at risk of loss, and that large areas of relatively homogenous moderate and higher density forests, like PACs, are at risk of larger declines if resilience needs are not addressed. Recognizing the dynamic nature of habitat in these forests, and prioritizing the restoration of these dynamics over the attempted strict preservation of existing habitat, may help minimize the impacts of these changes and maintain habitat functionality in the long term (Fabritius et al. 2017, Stoetzel et al. 2020, Gaines et al. 2022).

Definitions of Underserved Communities and Wildfire Risk Reduction: More Than a Few Complications

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I thought I’d pull out some topics from the NFF/FS Wildfire Crisis Strategy Roundtables executive summary for more discussion.
Let’s pull this out:

• Work collaboratively to include a range of values into the criteria that guide prioritization and planning for restoration, fuels treatment, and management, such as:

• Fire risk reduction
• Source-water protection
• Habitat resilience
• Recreation and public access
• Local and regional economies
• Underserved, vulnerable, and fire-impacted communities
• Public health and water and air quality, both rural and urban
• Protecting cultural and heritage resources
• Guide investments through a lens of equity and serving fire-vulnerable communities.
. Recruit workers and share leadership with Tribal and rural communities.
• The definitions of “underserved” and vulnerable communities are not well understood or consistently interpreted.

For those of you who have been around awhile, you might remember that agencies were told they couldn’t prefer local residents for contracts because that was against the FARS. And certainly preferences for local people in federal hiring would be against all kinds of rules. Sharing leadership with rural communities.. well, we still discuss that, although perhaps we’d agree on sharing leadership with Tribes?

I’m not surprised that words like “underserved” and “vulnerable” haven’t been defined.

There is something that happens when people in DC use nice-sounding words, and someone else has to interpret them (see also “sustainability” “equity” various forms of justice “environmental” “climate” “social” and numerous other abstractions). Each agency can develop its own interpretation, NGOs have theirs, and it can lead to all kinds of unnecessary discussion and befuddlement.

I thought perhaps the Biden Administration would have a helpful definition of underserved, especially since in his first day in office President Biden signed Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government.

It is therefore the policy of my Administration that the Federal Government should pursue a comprehensive approach to advancing equity for all, including people of color and others who have been historically underserved, marginalized, and adversely affected by persistent poverty and inequality.

Here are the definitions in the EO:

Sec. 2. Definitions. For purposes of this order: (a) The term “equity” means the consistent and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to underserved communities that have been denied such treatment, such as Black, Latino, and Indigenous and Native American persons, Asian Americans and Pacific Islanders and other persons of color; members of religious minorities; lesbian, gay, bisexual, transgender, and queer (LGBTQ+) persons; persons with disabilities; persons who live in rural areas; and persons otherwise adversely affected by persistent poverty or inequality.

(b) The term “underserved communities” refers to populations sharing a particular characteristic, as well as geographic communities, that have been systematically denied a full opportunity to participate in aspects of economic, social, and civic life, as exemplified by the list in the preceding definition of “equity.”

I have to admit, I found this confusing, because:
“consistent and systematic fair, just, and impartial treatment” could mean one of (at least) two things. One (1) is today and forward “from now on, everything will be fair just and impartial of everyone”. The other (2) is trying to be fair in the sense of say, Aspen and Breckenridge already finished acres of fuel treatments, and so to be fair, fuel treatments around poorer communities should be brought up to the same level.

I think many of us think that (2) would be the “most fair” approach; but that’s not exactly what the definition says.

An example of a pragmatic approach, Colorado State for its wildfire grant programs has a map of the low income areas, which have to provide less of a match than other areas. Is that fair? Or would it be fairer to focus $ only on low income areas until some level of equity had been established? How inequitable have state grants been so far? Or even more broadly, does anyone keep track of the actual amount of money plugged into wildfire mitigation grants by county or zip or whatever scale? That would be feds, state, counties, NGO partners, landowners? Or it fairness by total acres treated and not by funding levels?

Now, fairness is a very difficult and complex topic in itself. But definitions may also require some kind of data collection, and I’m not sure that information is available. Maybe the first step would be analyze current inequities, and then take specific steps to equalize them.

Finally, in the EO definition, I thought the combination of “persons who live in rural areas” and “members of religious minorities” .. there is one state in particular with a high percentage of people who satisfy both of those criteria.

And yet President Biden also reinstated and added acres to Bears Ears Monument – I’m not sure how equitably this was perceived by folks in Utah. Can you have “fair just and impartial treatment of individuals” without involving them in how those decisions are made? Or in other words, should representatives of all the underserved be involved in determining how to achieve equity for them?

Lots to think about, and it’s not surprising that the people who are supposed to be carrying out this quest for justice have asked for more clarification.