Fire and Fuels

Let’s Discuss the Wildfire Emergency Act 2021. II. Landscape-Scale Restoration.. Same Old NEPA?

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This is probably obtuse and abstruse but here goes- I think it’s an interesting window into the minds of some people who have power in federal lands policy. Again, here are links to the summary and the bill itself.  If you’ll remember, the Daines-Feinstein bill (and all others that tweak current NEPA procedures) tends to provoke this kind of language among many environmental groups.  And this bill is supported by them… so let’s take a look at what it says.  These are the NEPA procedures for the Landscape-Scale Forest Restoration Projects we discussed yesterday, the idea being to work on areas up to 100K acres.

(I) The project shall use an efficient approach to landscape-scale analysis and decisionmaking that is consistent with the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.), which may include—

1 (i) the preparation of a single environmental impact statement or environmental assessment, as applicable, for the entire project, incorporating the landscape assessment described in subparagraph (C);

(ii) the use of, as applicable—
(I) multiple records of decision to implement a single environmental impact statement; or multiple decision notices to implement a single environmental assessment;

(iii) the preparation of a programmatic environmental impact statement or environmental assessment, as applicable, for the entire project, incorporating the landscape assessment described in subparagraph (C), followed by focused, concise, and site-specific—
(I) environmental assessments; or
(II) categorical exclusions consistent with the National Environmental Policy Act of 1969 (42 U.S.C. 24 4321 et seq.); or

(iv) the use of the landscape assessment described in subparagraph (C),  through incorporation by reference and similar approaches, to support focused, concise, and site-specific—
(I) environmental assessments; or
(II) categorical exclusions consistent with the National Environmental Policy Act of 1969 (42 U.S.C. 10 4321 et seq.).

 

So I am not a lawyer, but I find this confusing.  If the idea of this bill is to make landscape scale projects more “efficient”, it seems to me that most efficient would be to develop a giant EIS (4FRI analyzed 1 mill acres and authorized 560K, without, as far as I know, supplemental site-specific NEPA).  There are problems with this approach, though; it takes a long time to do and to litigate, and by then many of your carefully analyzed acres may have burned up, perhaps requiring re-analysis.

I think iii raises an interesting question.. what good would it do to do a programmatic if you already have an assessment and you are going to use EAs or CEs for the site-specific analysis? When I worked in DC, I noticed at the interagency NEPA meetings that CEQ seemed fond of programmatics, the agencies not so much. Double the NEPA, double the quality of the decision?

I like iv… going from some kind of assessment to EAs or CEs.  But forests can do this already (even without the kind of assessment envisioned here).  They can use a recent forest plan vegetation assessment if they have one, or other kinds of collaborative work like the Zones of Agreement that the Blue Mountains developed.  So I’d argue that there could be a much simpler kind of assessment with which to support EAs and CE’s, and one that would be easier to update as needed.

So to get the more $ that goes with the Landscape Restoration Projects, you have to focus on returning to reference conditions (not helping suppression folks protect values at risk) and don’t seem to get any NEPA help- in fact you have to do more work (unnecessarily elaborate assessments). I’m not sure why this is part of a “Wildfire Emergency” Act.

 

Let’s Discuss The Wildfire Emergency Act of 2021-I: Landscape Projects

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There are many interesting things we could discuss about this bill… here’s a link to the summary, section by section, and the bill itself.  I’m interested in exploring Zones of Agreement above the collaborative forest organization level, and this legislation offers some clues to the environmental/conservation point of view. There’s plenty to discuss here, but I’ll start with the large landscape provisions (from the section by section):

Subsection (c)(1) establishes eligibility criteria for the a project, including:
o Purposes shall include 1) restoration of ecological integrity; 2) restoration of appropriate natural fire regimes; and 3) wildfire risk reduction in the wildland urban interface (WUI), to
the extent that the project includes lands in the WUI

o A collaborative group representing diverse interests must develop and support the project

2 o The project shall be based on a landscape assessment that
1) covers at least 100,000 acres (with limited exceptions for assessments of at least 50,000 acres for Eastern forests, or at least 80,000 acres if the assessments are already complete or substantially completed and the Secretary determines a larger assessment area is not necessary)
2) evaluates ecological integrity and reference conditions for the landscape;
3) identifies areas that have departed from reference conditions;
4) identifies criteria for determining appropriate restoration treatments;
5) are based on the best available scientific information, including, where applicable, high-resolution imagery and LiDAR; and
6) identifies priority restoration strategies.
o Restoration actions shall 1) emphasize the reintroduction of characteristic fire; 2) for any proposed mechanical treatments, seek to restore reference conditions and the establishment
of conditions facilitating prescribed fire; and 3) fully maintain or contribute to the restoration of reference old forest conditions, including protecting large old trees
o The project shall be consistent with all applicable environmental laws, and the roadless rule
o Multiparty monitoring is required
o No new permanent road may be built as part of the project, and any temporary roads needed to implement the project shall be decommissioned within 3 years of the project’s completion
o The project uses an efficient approach to landscape-scale analysis and decision-making that is consistent with NEPA (we’ll talk about this in post II in greater detail.)

 

I’ve some concerns with this part.

    1. As we’ve seen with the Blue Mountains, the extra funds are great and allow them to do great work. Still, it does tend to separate forests into haves and have-nots. It’s discouraging for busy forest workers and the public to work hard on a proposal and not be funded.  Those places may actually “need” the extra support the most.
    2.  Of course, I’m not a fan of spending megabucks determining “reference conditions” when we have no clue about whether it’s a good investment to try to “restore” them for (which?)  “ecological reasons”.  I still think we should have stuck with managing for individual wildlife species and trying to keep them on the landscape. I know that coarse-filter fine filter is supposed to work better, but has it? It’s always seemed like a full employment program for historic vegetation ecologists to me.
    3. People who want strategic fuel treatments to help suppression folks protect their communities seem to have no place in all this; in fact, it seems very wet (Coastal) in its focus.  It seems like instead of saying.. here is a landscape where threats from wildfires are serious as evidenced by these (x) criteria, we will fund communities and the Forest Service to plan and implement strategic fuel treatments and ongoing prescribed fire, considering factors as in the Stewardship and Fireshed Assessments.

You could have numerous considerations and restrictions proposed by the environmental community, but what’s fundamentally flawed about this section for me is that its’ not about protecting communities, infrastructure, plants, animals and watersheds from destructive wildfires at all, but about restoring to reference conditions with possible wildfire utility.

Not only do I think a Wildfire bill with landscape scale projects should focus on wildfire projects (but perhaps large landscapes are not the appropriate mechanism?), I also think it should have a preference for underserved and low-income communities at risk of disastrous wildfires and their druthers.

I’ve heard this proposal characterized as CFLRP 2.0, so it would be interesting to hear from CFLRP participants on what you all think about this.

 

Check Out the National Prescribed Fire Act of 2021

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A great summary of this bill from Bill Gabbert of Wildfire Today..

 

$600 million could be appropriated

Prescribed fire, Indiana Dunes National Lakeshore near Ogden Dunes in northwest Indiana
Prescribed fire, Indiana Dunes National Lakeshore near Ogden Dunes in northwest Indiana in 2013. NPS photo.

Legislation that did not pass in Congress last year to promote prescribed fire was reintroduced yesterday by four Senators. The National Prescribed Fire Act of 2021 would appropriate $300 million each to the Departments of the Interior (DOI) and Agriculture (DOA) to increase the pace and scale of controlled burns on state, county, and federally managed lands. Companion legislation with four sponsors was introduced in the House of Representatives.

Of the total of eight sponsors and co-sponsors, seven are Democrats and one is Republican. The legislation did not stand a chance in 2020 but it could fare better this year.

Senators have issued press releases promising that if the bill is passed it “would help prevent the blistering and destructive infernos from destroying homes, businesses and livelihoods.” ?

The legislation:

  • Establishes a $10 million collaborative program, based on the successful Collaborative Forest Landscape Restoration Program, to implement controlled burns on county, state and private land at high risk of burning in a wildfire.
  • Establishes an incentive program to provide funding to state, county, and federal agencies for any large-scale controlled burn.S tates and counties could receive up to $100,000 for prescribed fire projects.
  • Establishes a workforce development program at the Forest Service and DOI to develop, train, and hire prescribed fire practitioners, and establishes employment programs for Tribes, veterans, women, and those formerly incarcerated.
  • Directs the DOI and DOA to hire additional personnel and procure equipment, including unmanned aerial systems equipped with aerial ignitions systems, in order to implement a greater number of prescribed fires.
  • Encourages large cross-boundary prescribed fires exceeding 50,000 acres.
  • Sets an annual target of at least one million acres treated with prescribed fire by federal agencies, but not to exceed 20 million.
  • Requires that by September 30, 2023 a minimum of one prescribed fire to be conducted on each unit of the National Forest System, unit of the National Wildlife Refuge System, unit of the National Park System, and Bureau of Land Management district under the jurisdiction of the two Departments. The intent is to increase familiarity with prescribed fire in local units.
  • The two Departments shall hire additional employees and provide training and development activities, including through partnerships with community colleges, to increase the number of skilled and qualified prescribed fire practitioners in the DOI, DOA, Indian Tribes, and other qualified organizations, including training in smoke management practices.
  • The Office of Personnel Management shall give the two Departments new authority to hire temporary personnel to perform work related to prescribed fire, including training, implementation, and post-prescribed burning activities. The workers could begin three days before the project and work through three days after “the prescribed fire has stopped burning.”
  • Overtime payments for prescribed fire could be paid out of wildfire suppression accounts.
  • Each Department shall create at least one crew for implementing prescribed fires. After a person works on the crew for five seasons they would become eligible for noncompetitive conversion to a permanent position.
  • The Departments may spend up to $1 million in working with the National Governors’ Association to host a conference to discuss the benefits of addressing liability protection related to prescribed fires, and possible incentives for States to enact a covered law.

“In the simplest terms, the National Prescribed Fire Act offers a legislative solution to increase the use of prescribed fire,” said National Association of State Foresters President, Arkansas State Forester, Joe Fox. “With this bill, state foresters would be able to maximize their utilization of controlled burns to enhance forest health while minimizing damages and mega smoke emissions from catastrophic wildfires. It is a win-win-win for forests, wildland fire management, and public health.”

Changing the Game: Using Potential Wildfire Operational Delineation (PODs) for a Better Future with Fire

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FACNET (Fire Adapted Communities Information Network) is one of my favorite information sources.  This article was originally posted on the Fire Adapted Communities Learning Network Blog and is reproduced here with their permission.

The whole thing is worth a read and I’ve included some excerpts that give you a taste for it. It probably won’t surprise you that I like the combination of local knowledge and spatial analytics. Check out the video about the Arapaho Roosevelt NF and the Cameron Peak fire.  The maps of that fire reminded me that we can talk past each other when people write “fuel treatment in the “backcountry” can’t help protect communities” and in some parts of the country with current megafires, we actually don’t have a “backcountry.”
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Editor’s Note: Tyler A. Beeton and Katarina Warnick are Research Associates with the Colorado Forest Restoration Institute at Colorado State University. They recently took part in a well-attended February, 2021 virtual workshop hosted by the Rocky Mountain Research Station’s (RMRS) Wildfire Risk Management Science team (WRMS). The workshop focused on Potential Operational Delineations also called PODs. The POD framework is an emerging collaborative spatial fire planning and decision support tool. Here Tyler and Katarina share their perspective on three key themes that emerged from the February workshop. They focus on how PODs can change the game for fire operations, strategic multi-year restoration investment and planning, and co-managing wildfire risk.

It was clear from the get-go that we weren’t the only ones excited for the inaugural Potential Operational Delineations (PODs) Collaborative Fire Planning Workshop, hosted by the Rocky Mountain Research Station’s (RMRS) Wildfire Risk Management Science team (WRMS) held virtually in February 2021. Well over 500 people registered in just 3 weeks after registration went live, which maxed out the Zoom room capacity and forced the planning committee to close registration. This event and topic was something folks were ready to engage on. And there is reason why – the PODs process is an exciting and emerging framework that leverages local expertise with sophisticated modeling tools to identify features on the landscape – the streams, roads, ridges and fire scars – that have a high likelihood of containing a fire (see example below). Since taking off, the PODs framework has been developed and deployed in different contexts across the United States (over 40 national forests and counting). And while PODs were initially envisioned to support incident management, managers and communities have expanded the application of this tool in a number of ways. Several key themes related to the potential benefits of PODs emerged from the workshop, here are three.

PODs network on the Pike San Isabel National Forests. Fire managers deliberate and hand-draw effective control lines based on their local knowledge and spatial analytical tools. The control lines are then digitized to develop the PODs network seen here.

…..

Shifting strategy from random acts of restoration to a targeted approach

Several individuals emphasized that the current model of ‘stands and compartments’ vegetation management where ‘random acts of restoration’ occur opportunistically on the landscape have been largely unsuccessful at managing wildfire at scale. Big, bad fires are still happening and worsening, and the social and ecological impacts are significant. Panelists and participants noted that PODs provide a framework to shift our strategy to long-term, landscape-scale treatment prioritization. The scale of actions needed to restore fire-adapted ecosystems is immense, and it is impractical to treat the entire landscape. Using the adage ‘the only way to eat an elephant is one bite at time,’ one panelist suggested the need to strategically restore landscapes one POD at a time. Doing so could contribute to meaningful outcomes at meaningful scales, in this case changing wildfire behavior across the “fireshed”. A fireshed is conceptually similar to a watershed, though is defined as areas that encompass similar wildfire risk and where the identification and prioritization of treatments can modify wildfire behavior (Bahro et al. 2007).

The Arapaho Roosevelt National Forests leadership tested this new model of thinking. Forest managers worked with partners to construct a line of PODs running north to south slated for thinning treatments and prescribed fire, the goals of which were to inhibit fire spread and protect communities and other assets to the east. This line of defense was tested during the 2020 Cameron Peak Fire, the largest wildfire in Colorado state history. Although the fire occurred before the strategy was fully implemented, fire behavior was significantly modified in most cases where it interacted with treated PODs and previous fire scars. Check out the video below depicting the fire spread, dark red polygons depict previous fire scars. Blue polygons denote PODs that were treated (thinning, burned) prior to the fire.

This shows that if the management objective is to change wildfire behavior and risk across large landscapes, there is a need for a multi-year restoration strategy. PODs provide a useful way to carve up the landscape making it more manageable for restoration and more relevant for fire operations. In addition, PODs can provide more meaningful outcomes and a more useful and visual tool in communicating the “what” and “why” of management actions across specialists, organizations and communities. Lastly, the strategy of collaborative planning allows for a shift in focus from standard performance-measures that emphasize outputs, such as timber volume, to outcomes that promote resilient landscapes and communities.

Wildfire and Roadside Hazard Trees in Oregon- Info From Region 6

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Previously Steve posted this story from OPB that mostly focused on concerns about ODOT’s management of hazard tree removal. There was a link to a letter from a variety of groups which talked about the Forest Service.

There are a number of stories at OPB about ODOT’s efforts and management of hazard tree removal, including hearings with the state legislature.

There was one place in the article in which people agreed:

Law, Till, Ford and Allen all agreed it can take years for burned trees to become hazardous, but the state doesn’t plan to wait that long to see which trees need to be removed.

Andersen said arborists are monitoring trees for a few months to see if they become less hazardous over time but the state is sensitive to the risks involved in leaving potentially hazardous trees standing.

“We wouldn’t monitor for years with safety being the top concern if that tree dies,” he said. “I don’t think anybody wants the unfortunate job of going and telling the family that someone died on the roadway because we were monitoring that tree that inevitably fell during an ice storm.”

But leaving ODOT and going back to “what is the Forest Service doing?”, here’s the Region 6 reply to our questions about roadside salvage.

Last summer’s wildfires burned more than 1.2 million acres across Oregon on federal, state, local, and private lands. In September we stood up a regional Operation Care and Recovery team to coordinate efforts to help our employees, the public and communities impacted, and the lands we manage recover. We have been focused on emergency safety and stabilization actions, including working with ODOT and FEMA to remove dead or fire-weakened hazard trees along roadways and near recreation areas to address safety risks to the public and our employees.

We have been completing this work under emergency response provisions and categorical exclusions.

 Below are the links for the danger tree and hazard tree guides. We’re using these along with environmental protection plans and the ODOT protection agreement to guide overall criteria.

 

You can find any Forest Service salvage (or other) projects by going to the forest’s webpage, going to land management on the sidebar and then projects.

Who’s An Expert to Whom?: Congressional Wildfire Theater (Hearing) on Thursday

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Many thanks to Bill Gabbert of Wildfire Today for this one:

“Investing to increase the capacity of the federal workforce to plan for and respond to wildfire:

Committee hearing April 29 fire wildfire

Riva Duncan, now retired from the Fire Staff Officer position on the Umpqua National Forest in Oregon, is scheduled to testify before Congress Thursday April 29.

The House Subcommittee on National Parks, Forests, and Public Lands, led by Chair Joe Neguse (D-Colo.), will host an oversight hearing titled Wildfire in a Warming World: Opportunities to Improve Community Collaboration, Climate Resilience, and Workforce Capacity.

The Subcommittee describes one of the topics of the hearing:

Congress and the Biden administration have an opportunity to better incorporate climate change into federal land and wildfire policies by protecting naturally resilient landscapes, prioritizing funding for community collaboration and protection, and investing to increase the capacity of the federal workforce to plan for and respond to wildfire.

Ms. Duncan is now the Executive Secretary of Grassroots Wildland Firefighters.

Other expected witnesses:

  • Courtney Schultz, Associate Professor of Forest & Natural Resource Policy, Director of the Public Lands Policy Group at CSU, Department of Forest and Rangeland Stewardship, Colorado State University.
  • Beverly Law, Professor Emeritus, Global Change Biology & Terrestrial Systems Science, Oregon State University
  • Minority witness to be announced

When:

1 p.m. EDT, Thursday April 29

Written testimony:

Written testimony from the witnesses will be posted at the Committee’s website shortly before the hearing begins. Ms. Duncan’s is 13 pages long.

How to watch live:

You can watch it right here. When the hearing begins, click on the Play button on the YouTube screen below.

After the hearing is over, it should be possible to replay it above, or on YouTube.

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There are many people we could consider experts on the topic of wildfire under climate change and what to do on workforce issues. I like that Neguse picked Schultz who is a social scientist; it would be interesting if more social scientists were included in, say, other hearings on science issues, say climate, for example, IMHO.  Of course, they are both from Colorado, so does that have anything to do with it? Also two Oregonians.  Which seems a bit odd considering all the work they do on this, and all the experts,  in California.  And of course,  there is nothing like a retired Fed to be an expert.

Of these, Law seems the outlier to me based on her research portfolio.

This is interesting to me from a political science perspective- since I’ve always found the machinations of politics difficult to understand (yes, even when I worked on Capitol Hill). For one thing, the USDA has a comment period open until Friday on climate-smart forestry and agriculture which includes dealing with wildfire. So..is this to help with that? Are they separate efforts? Are they coordinating between legislative and executive branches? As it says, “Congress and the Biden administration have an opportunity to better incorporate climate change into federal land and wildfire policies.”

Also who would you pick, if you were the minority, to round out the panel, and why? It might already be decided, but I’m interested in what you all think and why.

Landscape-level Fire Management in California: Getting to Yes

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Thanks to Jon for posting this piece all for participating in the discussion on fishers and fuel treatments, and especially for Rene Voss being here to discuss his point of view. I’d like to further explore options for common ground.

“the agencies ignored a deep body of scientific evidence concluding that commercial thinning, post-fire logging, and other logging activities conducted under the rubric of ‘fuel reduction’ more often tend to increase, not decrease, fire severity (citing several sources, emphasis in original).

Having been on the other side (writing statements on “how the Forest Service considered those studies”, I tend to think that five or ten pages of explanation of how these studies were considered, is probably not what plaintiffs are ultimately after.

The view that “fuel treatments more often tend to increase fire severity” is not widely held by scientists, nor fire and fuels practitioners.

So we can only wonder what the plaintiffs are really after. Perhaps the problem is “commercial”? So in areas in which thinning is not “commercial” it can be helpful? But “commercial” is not a biological parameter. So, I guess my question is whether it’s possible for folks like Rene to articulate the parameters of what kinds of treatments would be OK with them. It seems to me that would save time and effort for everyone concerned.

Taking a look at California, we notice that in their State Forest Action Plan:

The Department of Forestry and Fire Protection (CAL FIRE) and other state entities will expand its fuels management crews, grant programs, and partnerships to scale up fuel treatments to 500,000 acres annually by 2025;
» California state agencies will lead by example by expanding forest management on state-owned lands to improve resilience against wildfires and other impacts of climate change; and
» The USFS will double its current forest treatment levels from 250,000 acres to 500,000 acres annually by 2025.

Governor Newsome asked for this funding in his budget.

In addition to electric vehicles, Newsom’s team actively highlighted the $1 billion investment it was making in wildfire management. That money would go to support firefighting, including 30 new fire crews and additional aircraft, as well as proactive fire management, ranging from tribal engagement on fire issues to creating markets for wood products sourced from forest thinning.

Natural Resources Secretary Wade Crowfoot said this budget signified a “paradigm shift” in how the state approaches fire management.

The administration realized, he said, that it needs to be more proactive in landscape-level fire management, an effort that would come from moving toward melding modern fire science with traditional Native American practices of prescribed burns.

It seems to me that the State feels that fuel treatments are effective and worthy of megabuck investment. I wonder whether that scientific discussion has occurred with the State. What’s most interesting to me are the processes by which scientific arguments and discussions take place (or don’t) and why, peculiarly, they have a role in the courts that is different from everyday policy development. The courts, as we’ve found out, are not the place for scientific discussions, and also not conducive to finding common ground and where agreements might occur…except in individual settlements, which don’t really help public understanding.

If Governor Newsome wants to “be more proactive in landscape-level fire management”, when 58% of California’s forests are federally managed, and lawsuits can delay these federal projects, we have to ask “how could we get (currently litigating) environmental groups to not only support efforts, but actually to help row the landscape-level fire management boat?” I’m using the analogy of Michael Webber, in this interview on decarbonization).

What policy changes, or changes in project design, might work?

Practice of Litigation Friday: Fire in Pacific Fisher Habitat

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U. S. Fish and Wildlife Service

This recently filed case (the complaint is at the end of the article) hasn’t generated a lot of news coverage, but it directly raises some of the questions we have discussed at length about the effects of fuel reduction activities.

On March 26, 2021, three California conservation groups filed a complaint for declaratory judgment and injunctive relief against the Forest Service and Fish and Wildlife Service in the federal district court for the Eastern District of California (Unite the Parks v. U. S. Forest Service).  They are challenging, “the failure … to adequately evaluate, protect, and conserve the critically endangered Southern Sierra Nevada Pacific fisher … on the Sierra, Sequoia, and Stanislaus National Forests …” after a substantial reduction in habitat since 2011 resulting from a multi-year draught, significant wildfires and Forest Service vegetation management.  Many of the variables considered in a prior 2011 analysis have been adversely affected by these changes. The plaintiffs implicate 45 individual Forest Service projects.

This fisher population was listed as an endangered species on May 15, 2020, and the agencies conducted “programmatic” consultation at that time on 40 already-approved projects.  The agencies reinitiated consultation because of the 2020 wildfires, but did not modify any of the projects.  The purported rationale is that the short-term effects of the vegetation management projects are outweighed by long-term benefits, but plaintiffs assert, “There is no evidence-based science to support this theory…,” and “the agencies ignored a deep body of scientific evidence concluding that commercial thinning, post-fire logging, and other logging activities conducted under the rubric of ‘fuel reduction’ more often tend to increase, not decrease, fire severity (citing several sources, emphasis in original).  The complaint challenges the adequacy of the ESA consultation on these projects, and the failure to “prepare landscape-level supplemental environmental review of the cumulative impacts to the SSN fisher…” as required by NEPA.

Not mentioned in the lawsuit is the status or relevance of forest plans for these national forests, two of which (Sierra and Sequoia) are nearing completion of plan revision.  However, the linked article refers to an earlier explanation by the Forest Service that they would not be making any changes in the revised plans based on the 2020 fires because they had already considered such fires likely to happen and had accounted for them.  ESA consultation will also be required on the revised forest plans, and should be expected to address the same scientific questions, arguably at a more appropriate scale.  Reinitiation of consultation on the existing plans based on the changed conditions should have also occurred under ESA.  (This is another area where legislation has been proposed to excuse the Forest Service from reinitiating consultation on forest plans, similar to the “Cottonwood” legislation that removed that requirement for new listings or critical habitat designation.)

(And in relation to another topic that is popular on this blog, Unite the Parks also supports the establishment of the Range of Light National Monument in the affected area.)

Impacts of Wilderness Designation on Fire Suppression? Request for Information

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Freelance photographer Joe Randall and his wife have captured some amazing photos of the Decker fire near Salida. The fire burned more than 5,000 acres as of early Friday, Oct. 4, 2019. Visit his Digital Art Co. Facebook page here. This fire was a Fire Use fire that began in Wilderness.

I’ve never seen this written about much before, but I could have missed it. A person on Wildfire Today mentioned that an area being in a Wilderness Study Area made suppression more complex. So I became curious about Wilderness designations and their potential impacts on fire suppression, especially since we have many acres proposed for Wilderness in a bill here in Colorado. I don’t know if Recommended Wilderness in Forest Plans have to follow the same rules.

So I googled and due to their always-mysterious search algorithms ended up with this specific write-up from the Pike and San Isabel National Forest (and Cimarron and Comanche National Grasslands, but I don’t think they have any Wilderness).

It seems like you can do many of the same suppression activities, but you have to weigh the need against Wilderness values, and get approvals. I’m interested in whether other Forests have similar sets of guidance, and how these operate in practice.

At one time it seemed that letting fires burn was important for “naturalness”, but if climate is making fires “unnatural” then it’s not as simple.

As this wilderness.net pieces says..

Other reasons besides public sentiment may also perpetuate fire suppression. The small size of many wilderness areas results in natural ignitions outside of wilderness being suppressed before they can burn into wilderness, for example. With increases in settlement within the wildland urban interface, the risks of fire escaping onto adjacent lands, unnaturally intense fires burning as a result of unnatural fuel loads, and unacceptable smoke impacts to surrounding areas are also very real.

A person could say “natural” is a function of a)ignition source, b) weather/climate and c) naturalness of fuel loads. If we argue that both b and c are commonly unnatural, then it’s hard to argue that a makes much of a difference.

So here are my questions..
1. People who have been managing fires, have you seen instances in which managing for Wilderness fires worked or didn’t work? Did the Wilderness rules themselves or something about their implementation make it more difficult to suppress the fire out of Wilderness?
2. Does each Forest have a different policy, or it is pretty common across all Wildernesses?
3. When an area becomes RW, does the fire suppression policy move to Wilderness rules?

Thanks, everyone!

Fuel Treatments and Carbon in Forests: Why Scientists Come to Different Conclusions

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Awhile back, Rene Voss commented with regard to the question “is “leaving things alone” the best for climate mitigation?”:

“There are several scientific analyses that show that leaving the forests vs. various management schemes to reduce fuels & fire risk is the best approach to help mitigate climate change.”

Mitchell et al. (2009) describes tradeoffs for managing for carbon storage (a valid goal in any forest management action) versus fuels reduction. That study suggests that, with the exception of some xeric ecosystems, “fuel reduction treatments should be forgone if forest ecosystems are to provide maximal amelioration of atmospheric CO2 over the next 100 years.” Id. at 653.

Depro et al., 2007, found that eliminating logging would result in massive increases in Carbon sequestration. “Our analysis found that a “no timber harvest” scenario eliminating harvests on public lands would result in an annual increase of 17–29 million metric tons of carbon (MMTC) per year between 2010 and 2050—as much as a 43% increase over current sequestration levels on public timberlands and would offset up to 1.5% of total U.S. GHG emissions.” (Depro et al., 2007 abstract)

Moreover, Mitchell et al. (2009) found the amount of net carbon released into the atmosphere, on an acreage basis with small diameter thinning for fuel reduction (if used for biomass), puts more carbon into the atmosphere than an average fire, on an acreage basis:

“Our simulations indicate that fuel reduction treatments in these ecosystems consistently reduced fire severity. However, reducing the fraction by which C is lost in a wildfire requires the removal of a much greater amount of C, since most of the C stored in forest biomass (stem wood, branches, coarse woody debris) remains unconsumed even by high-severity wildfires. For this reason, all of the fuel reduction treatments simulated for the west Cascades and Coast Range ecosystems as well as most of the treatments simulated for the east Cascades resulted in a reduced mean stand C storage. One suggested method of compensating for such losses in C storage is to utilize C harvested in fuel reduction treatments as biofuels. Our analysis indicates that this will not be an effective strategy in the west Cascades and Coast Range over the next 100 years.”

(my bolds)

And yet, other studies (and visible evidence) show that not burning forests is better for carbon sequestration (see the one Steve linked to here). So I went back to look at Mitchell 2009, which can be found here.

The authors picked three kinds of sites, the Coast Range, the west Cascades, and east of the Cascades (on the Deschutes). Now it may be just me, but I don’t think of fuel treatments in the Coast Range or the west Cascades. So I looked around a bit and found this interesting study by Ager et al. 2014, which indicates that no forests in the Coast Range, Western Oregon, or (surprisingly to me!) even the Deschutes are on the top 50% of areas where fires are likely to occur.

It seems likely that if an area doesn’t burn and keeps sequestering carbon that is a good carbon situation. Just like we have talked about before.. if you want to get a great deal of carbon sequestered, pick a place where trees and other plants grow well and there are no fires or bug outbreaks. On the other hand, some key questions for looking at fuel treatments are 1) is this area likely to burn and 2) are there critters or people and their stuff that need protection (despite whatever carbon impacts)? It looks like the Mitchell et al. authors selected two places unlikely to burn and said “fuel treatments will decrease carbon sequestration here.” That seems perfectly plausible. But most of us would ask “why would you even do that in the Coast Ranges and western Oregon?”. Another question is if fires are unprecedented due to cc, what do we really know about the fires of the future? Is it then “the best science” to use the past for input into models?” Or regionally downscaled climate models? Or just admit we really don’t have a clue? Or even “why do this study if the reason people do fuel treatments has very little to do with climate mitigation?”

A quick look at the Depro et al. paper that Rene also cites, shows that it is talking about timber harvests (across the country) and not fuel treatments in dry forests.

But back to Rene’s original point “several scientific analyses that show that leaving the forests vs. various management schemes to reduce fuels & fire risk is the best approach to help mitigate climate change.” To my mind that’s not what actually these studies show, and not exactly what the authors said in the papers.