My thanks from me and from at least some TSW readers, to the employees and other folks who worked on this review!!

Here’s the link.

From the Chief’s letter:

Their work is an example of how we strive to hold ourselves accountable at the Forest Service, learn from our successes and mistakes, and find better ways to serve the American people and steward the lands entrusted to our care, for the benefit of current and future generations.

Here are the seven immediate actions:

A review team led by Forest Service personnel—with partner representation from municipalities, counties, States, and nongovernmental organizations from across the country—identified themes and findings to form the recommendations in this report. The Agency Co-Team Leaders made final recommendations to the Chief for immediate implementation to lift the program pause. The recommendations are tactical approaches the Forest Service can use to account for multiple factors affecting practitioners’ ability to carry out prescribed burns in a safe and effective manner.

These tactical recommendations are as follows:
1. Each Forest Service unit will review all prescribed fire plans and associated complexity analyses to ensure they reflect current conditions, prior to implementation. Prescribed fire plans and complexity analyses will be implemented only after receiving an updated approval by a technical reviewer and being certified by the appropriate agency administrator that they accurately reflect current conditions.
2. Ignition authorization briefings will be standardized to ensure consistent communication and collective mutual understanding on key points.
3. Instead of providing a window of authorized time for a planned prescribed fire, agency administrators will authorize ignitions only for the Operational Period (24 hours) for the day of
the burn. For prescribed fires requiring multi-day ignitions, agency administrators will authorize ignitions on each day. Agency administrators will document all elements required for ignition authorization.
4. Prior to ignition onsite, the burn boss will document whether all elements within the agency administrator’s authorization are still valid based on site conditions. The burn boss will also assess human factors, including the pressures, fatigue, and experience of the prescribed fire implementers.
5. Nationwide, approving agency administrators will be present on the unit for all high-complexity burns; unit line officers (or a line officer from another unit familiar with the burn unit) will be on unit for 30-40% of moderate complexity burns.
6. After the pause has been lifted, units will not resume their prescribed burning programs until forest supervisors go over the findings and recommendations in this review report with all employees involved in prescribed fire activities. Forest supervisors will certify that this has been done.
7. The Chief will designate a specific Forest Service point of contact at the national level to oversee and report on the implementation of these recommendations and on the progress made in carrying out other recommendations and considerations raised in this review report.

And additional steps

By January 1, 2023, we will establish a Western Prescribed Fire Training curriculum with the interagency fire and research community, and partners, to expand the successes of the National Interagency Prescribed Fire Training Center (NIPFTC) headquartered in Tallahassee, Florida. This curriculum will incorporate the knowledge and experience of Tribes, partners, and communities and include a strategy of training and developing skills together so we can build collective capacity to expand the use of prescribed burning on National Forest System and other
lands. We will identify and provide the additional staffing needed to support this action.

By December 15, 2022, our Incident Management Organization will develop a national strategic plan for prescribed fire implementation. The plan will include implementation timing, implementation command structure, and logistics to prioritize and mobilize resources for both suppression and prescribed burning activities. This plan will include necessary staffing, funding, and monitoring to help shape future system improvements.

By December 15, 2022, we will identify a strategy, in collaboration with partners, for having crews that can be dedicated to hazardous fuels work and mobilized across the country to support the highest priority hazardous fuels reduction work.

We will continue investing in potential operational delineations (PODs) and ensure that they are used as a tool for both wildfire response and vegetative/fuels management planning.

For clarity and consistency, we will use a standardized approach for declared wildfire reviews and improve current systems for tracking findings and recommendations for continuous learning.

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I liked the nod to PODs.

Thanks to a TSW reader for links to this July 2022 letter.  It’s located on the project website in the emergency response folder.  It appears to take the least controversial parts of the multi-forest zone level EAs and ask for an emergency response.  It appears to have been signed by the Chief on July 12.  What I think is interesting about it is in the context of the larger discussion about NEPA for permitting, with regard to the future permitting deal associated with the IRA bill.  Is inter-agency coordination slowing the EA down, or just regular “project planning” staffing, or other difficulties?. Also,  I think there was a discussion about the proposed Save the Sequoias act, in which I think I remember someone suggested the FS already had these authorities, and so there might not be a need for changes found in that proposed legislation.

I wonder how often that the Chief approved “emergency response/alternative arrangements” have been used in practice, and to what extent they are used consistently for the same kinds of emergencies? I’m supposing this needs to be run by the Department and CEQ as well in practice but I don’t know for sure (nor whether this is consistent across administrations). What do you all know about these questions?

From the letter to the Chief (decision memorandum document):

BACKGROUND: Under Forest Service NEPA implementing regulations at 36 CFR 220.4(b)(2), the Chief or Associate Chief may grant emergency response or alternative arrangements for NEPA compliance when the responsible official finds that the nature and scope of proposed emergency actions are such that they must be undertaken prior to preparing any NEPA analysis and documentation associated with a Categorical Exclusion or Environmental Assessment (EA) and Finding of No Significant Impact (FONSI). This is not an alternative arrangement as defined by the Council of Environmental Quality in 40 CFR 1506.12.

California experienced record-setting wildfires in 2020 and 2021 that caused expansive stretches of fire-killed or damaged trees adjacent to roads, trails, and facilities which pose a threat to health, safety, and property. To address these hazards, the “R5 Post-disturbance Hazardous Tree Management Projects” were initiated, which propose the felling and removal of hazardous trees adjacent to roads, trails, and facilities within nine National Forests recently affected by wildfires. The project was initiated in October 2021 with the intent to issue final decisions in May 2022, in time to implement during the 2022 field season. However, project planning and Endangered Species Act (ESA) consultation is taking longer than anticipated. This along with the continued commitment to ensure adequate time for public involvement and accommodate the pre-decisional administrative review process have pushed anticipated decisions back to at least November 2022. Without an emergency response, most, if not all the emergency hazard tree abatement would be delayed until 2023. Trees will continue to deteriorate and fall, posing a serious risk of property damage, injury, or death as more time passes..

RECOMMENDATION
Approve the proposed emergency response for NEPA compliance under 36 CFR 220.4(b)(2) with associated conditions so that the Forests identified in the supporting documentation can immediately address the hazards to human health and safety in the highest priority portions of the project areas.

Proposed Emergency Response:
1. Grant authorization to begin the emergency hazard tree abatement on approximately 167 road miles and 18 developed recreation sites (displayed in attached maps) prior to completion of the Environmental Assessments and FONSIs, and exclude the requirement at 36 CFR 220.7(c) to document a decision to proceed with an action in a Decision Notice if an EA and FONSI have been prepared.

Associated Conditions:2. Ensure compliance with other laws, such as Endangered Species Act, National Historic Preservation Act, and Clean Water Act are in place before implementation of the emergency hazard tree abatement.
3. Ensure all required consultations and permitting are in place before implementation of the emergency hazard tree abatement. Emergency provisions may be employed where necessary, such as emergency consultation under ESA.
4. Implementation of emergency hazard tree abatement will address human health and safety and will be limited to treating imminent hazards (> 80 percent probability of mortality) and within 1 tree height striking distance of the specified roads and developed recreation sites prior to completion of the Environmental Assessments and FONSIs. Hazard trees would be identified in accordance with the Hazard Tree Identification and Mitigation Guidelines for Forest Service in the Pacific Southwest Region. The area assessed for hazard tree abatement would be within 300 feet of the centerline of roads (a 600-foot corridor), and around facilities and infrastructure.
5. Monitor the effects of the actions subject to this emergency response. Reconsult with my office through the Director of Ecosystem Management Coordination if monitoring reveals effects outside of those disclosed in the ongoing environmental analysis.
6. The Emergency Response for Emergency Hazard Tree Abatement is limited to the 2022 field season.
7. All other proposed actions in the EAs which are not part of this emergency response will follow the normal 36 CFR 220 and 36 CFR 218 process.

They also scoped the potential for using emergency authorities..

Both the scoping letter and comment period notice disclosed the possibility of utilizing emergency authorities to expedite hazard tree abatement on all or a portion of the project areas. There was some support for using emergency authorities, while others did not support this approach or suggested it be limited to addressing only imminent hazards.
In general, most of the public and tribes support hazard tree felling and removal near county roads, NFS Maintenance Level 3, 4, 5 roads, and developed recreation sites. While there is concern about the need for hazard tree removal near lower use ML 2 roads, there is general support for the ML 2 roads which access developed recreation sites, communities, or otherwise have more regular or moderate use. The emergency hazard tree abatement subject to the emergency response are focused on the imminent hazards in these higher priority areas where there is mostly general support.

And the problem with ESA consultation appears to be workload, and of course between USFWS and NMFS, the slowest would control the speed of the project.

In compliance with the Endangered Species Act (ESA), we have begun consultation with the U.S. Fish and Wildlife Service (USFWS) and National Marine Fisheries Service (NMFS). Consultation for the Central Sierra and Southern Sierra zones is anticipated to be completed in June 2022, though delays are possible due to USFWS and NMFS workload. Consultation for the North Zone is anticipated to be completed in August 2022. Emergency consultation will be employed to ensure compliance with ESA specific to the emergency actions if necessary.

Fortuitously,  I ran across this Bloomberg Law  piece: Billions in Feds’ Spending on Megafire Risks Seen as Misdirected

Just after posting the research paper on PODs. What a contrast!

We policy wonks know that the people get to frame problems. In wonk-land we disagree about framings all the time, because of course different framings lead to different solutions. I frame the problem as “how best for people to live with fire and protect the things we consider to be important, communities, watersheds, old growth and so on”.

According to some, the issue is framed as “protecting houses”.  As I have said, and observed, people don’t want fire to run through their communities.  They don’t like evacuating. They don’t like moving people from hospitals and nursing homes, companion animals, livestock.  There is plenty of community infrastructure, not houses, that needs to be rebuilt, power lines and so on. People and communities have huge economic losses.  I agree that we residents are a piece of the puzzle and have responsibilities. I don’t see it as either/or.  But my home hardening is not going to save our watershed.  For some reason, it seems like this framing doesn’t resonate with some..    To me, it’s also not very compassionate toward human beings (many old, sick, low income and/or of color).

At least two things seem to be gone from earlier discussions:

1. Bad Republicans in bed with the Timber Industry are the only ones who want this (excuse for logging).

2. Fires are really good!! And we should just let them go because they’re natural, and you can never have enough snags.  (Notice how this turned when they became thought to be made worse by climate change, now we have all kinds of data on public health risks, watershed impacts, dead fish, which are now considered to be bad).

But now..

It’s the  D-Controlled Congress who are not following the real “science” and are wasting billions of dollars .. once you lose the “bad timber industry” rationale, though, I think you need some kind of motivation for why everyone on both sides of the aisle are for it.  I don’t actually see a replacement rationale in this story.

When someone disagrees on climate science, they are seen to be fringy, investigated by Congress, deplatformed and accused of purveying “misinformation.”  In this case, though, the minority is thought to be correct (by some media elements).  So..  both get framed as “it’s about science” but that’s a code for “scientists we agree with.”

Two things strike me about the people quoted (but I know that both Jim and Tony have more nuanced views than maybe these quotes show).

1. They frame this as being “managing wildfire to protect houses” but don’t consider the costs and dangers of evacuations.
2. They also don’t consider other values that wildfires can impact, most notably watersheds.  Water, which we need as the climate changes and in fact many fire-y places have always had droughts.

“As the federal government focuses on forest thinning, no scientific consensus exists that removing vegetation, especially at a landscape-scale, will save communities in the paths of firestorms amid the West’s historic 23-year drought.”

But it will help fire managers control wildfires, hence PODs.  Are the majority of working fire scientists just wrong? Or is the choice of framing (“save communities” unintentionally leading down the wrong path?) From the Ten Common Questions paper..V. Should Management be Concentrated in the WUI?

“Fuel reduction treatments can support cultural, ecological, ecosystem service, and management objectives beyond the WUI. For example, treatments that restore the ecological resilience of old growth forests and patches with large and old trees are critical to long term maintenance of wildlife habitats (Hessburg et al. 2020) of seasonally dry forests and terrestrial carbon stocks, and slowing the feedback cycle between fire and climate change (Hurteau and North 2009). Treatments in watersheds that are distant from the WUI and protect municipal and agricultural water supplies are critical to minimizing high-severity fire impacts that can jeopardize clean water delivery (Bladon 2018, Hallema et al. 2018). For example, post-fire erosion and debris flows may cause more detrimental and longer term impacts to watersheds than the wildfires themselves (Jones et al. 2018, Kolden and Henson 2019).”

Note that these fire scientists frame the issue of fuel treatments and what values are being protected more broadly.

Here are the fire scientists who wrote the “ten common questions” paper:

Susan J. Prichard, Paul F. Hessburg, R. Keala Hagmann, Nicholas A. Povak, Solomon Z. Dobrowski, Matthew D. Hurteau, Van R. Kane, Robert E. Keane, Leda N. Kobziar, Crystal A. Kolden, Malcolm North, Sean A. Parks, Hugh D. Safford, Jens T. Stevens, Larissa L. Yocom, Derek J. Churchill, Robert W. Gray, David W. Huffman, Frank K. Lake, Pratima Khatri-Chhetri.

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Some quotes from the Bloomberg Law article are below. I put links to the pubs of the quoted scientists in the article.  Judge for yourself compared to the folks above. My two cents is that Tony Cheng and  Michael Flannigan are voices worth listening to in this space. The others .. not so much.

“Houses Spread Fire

Many wildfires also destroy communities far from forests because grasses are extremely flammable, said Erica Fleischman, director of the Oregon Climate Change Research Institute at Oregon State University.

Colorado’s most destructive wildfire, last December’s Marshall Fire, incinerated more than 1,000 suburban homes and buildings amid high winter winds in the plains of Boulder County—miles from the nearest forest.”

Really? Don’t do fuel treatments in forests, because..  grass fires exist?

“Most homes destroyed in wildfires burn because embers get inside the house through vents, not because they’re in the inferno’s path.

“It’s the houses that start each other on fire, not the forest,” said Jim Furnish, a retired deputy chief of the Forest Service.”

In the Marshall Fire, it was grass from wildlands that got the fire going and it transferred to residences.  It is a fact that fires can start in wildlands and spread to communities. I don’t really understand this argument.

“The package of wildfire bills would spend $182 million for wildfire risk reduction research, including the promotion and use of less-flammable building materials, at the National Institutes of Standards and Technology. Another $102 million is earmarked for the Federal Emergency Management Agency for wildfire preparation, promotion of better materials, and to retrofit existing homes.

Federal money should be spent on helping homeowners remodel their homes to make them more resistant to the embers, Law said. They can install ember-proof vents, use wildfire-resistant landscaping, and clear gutters of debris.

Wooden fences can spread fire in suburban areas, and lawmakers could consider updating urban land use plans and building codes to ensure that homes and yard structures are built of less-flammable materials, said Tony Cheng, a co-director of the Southwest Ecological Restoration Institutes at Colorado State University. The institutes are receiving $20 million from the infrastructure law to compile data on fuels treatment efforts.

No Scientific Consensus

As the federal government focuses on forest thinning, no scientific consensus exists that removing vegetation, especially at a landscape-scale, will save communities in the paths of firestorms amid the West’s historic 23-year drought.

The science is clear that “there isn’t a great connection between home loss and these fuel treatments,” though they sometimes help firefighters gain a foothold on some fires, Cheng said.

Moore, the Forest Service chief, said the agency is confident that as homes are built deeper and deeper into the woods, its research shows that removing “overstocked” trees is the best way to protect them.

“We know where we do nothing, or where we do a little, we’re seeing the evidence out on the landscape,” Moore said, referring to recent megafires. “We feel compelled to do something.”

Megafires Uncontrollable

But scientists say that even though vegetation has built up in forests because of a century of fire suppression, the extreme drought and heat are making large-scale thinning projects ineffective.

“When the whole forest is a dry tinderbox, having one area where you’ve done a fuels reduction may not be anywhere near enough to reduce fire risk,” said William Anderegg, a professor of biological sciences at the University of Utah. “We are not doing nearly enough to tackle the root of the problem, which is climate change.”

It makes “intuitive sense” that thinning forests would dramatically reduce wildfire risks, but independent research doesn’t back that up, said Chad Hanson, director of the John Muir Project, a forest advocacy group. Forest thinning is often motivated by logging interests instead of forest and community protection, he said.

“Are these thinning projects stopping weather and climate-driven fires?” he asked. “The answer is no.”

Clearing out forests may increase wildfire risk because it will further dry vegetation by exposing it to greater heat, sunlight and wind, said Michael Flannigan, science director for the Canadian Partnership for Wildland Fire Science at the University of Alberta.

Thinning 50 million acres at a landscape-scale is “wasting your time and money” unless fuels treatments occur very close to communities that could burn and are maintained so the trees don’t grow back, he said.

Often, wildfires just blow right through thinned forests, Flannigan said.

“Fire is opportunistic,” he said. “It jumps over rivers that are a kilometer wide. You’re not going to control it.””

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When I looked at this paper on which Flannigan is a coauthor, it modeled fuel treatments but not impacts of treated fuels on suppression tactics and strategies.  Maybe that’s another gap among scientists, and perhaps that’s a reason that we might find truer scientific answers about whether fuel treatments “work” by answering two questions before the study is designed:

1) Work at what exactly? Define what people intend to protect. Define what people want from fuel treatments.

2) Work on their own, or as a technique to help with operational fire management?

Flannigan is quoted as saying “you’re not going to control it.” And yet every day we have people working at controlling fires, and they mostly do. Check out the Hotshot Wakeup Twitter feed for videos. That’s sometimes true.. they are out of control.. but generally suppression works. And we are grateful to our wildland firefighter for making it so.