The Forest Service shall submit for NRE’s review all projects and activities that fall within the categories set out below by February 12, 2021. Consistent with applicable law, and subject to any exception expressly authorized by NRE, the Forest Service will defer making any final decision regarding the actions listed below until NRE has reviewed the decision and authorized the agency to proceed with decision-making.
These instructions are applicable to the classes of plans, projects and activities listed below for which the Forest Service expects or intends to make a decision prior to March 31, 2021:
• Activities in designated wilderness areas taken pursuant to Sections 4(c) and 4(d) of the Wilderness Act.
• Road construction, road reconstruction and timber harvesting activities on lands originally designated pursuant to 36 CFR 294, subpart B (2001) as well as any roadless lands designated in a subsequent roadless rulemaking.
• Special Use Authorizations (and any Forest Plan amendments) involving new construction or expansion of infrastructure for conventional energy production, including pipelines or transmission lines.
• New, modified, or expanded locatable or leasable minerals activities involving ground disturbance on greater than 500 acres.
• Activities involving cutting or removal of more than 3,000 acres of vegetation that will be categorically excluded from documentation in an Environmental Assessment or Environmental
Impact Statement.
• Final decisions for revisions or significant amendments of Land Management Plans.
Agency actions should be submitted for review in summary form with a brief description of the purpose and need, the intended selected action, significant effects to natural or social resources, and public involvement including with State, local and Tribal governments, and status of any objection process underway. The summary should include any legal or administrative timelines, including those associated with permit renewal.
The roadless one seems to be about Roadless Areas including those acres included in the Colorado and Idaho Roadless Rules. These all seem to fill the bill of “projects our friends are interested in” and “no PR surprises.” The good thing about having experienced politicals on board is that they have a good sense of what they need to look for.
The only one I thought was unusual was the cutting and removal of more than 3000 acres of vegetation in a CE. Since we know that legislative CEs HFRA Sections 603 and 605 are up to 3000 acres, they are apparently not watching those, so what can it be?
My guess is that it might be projects that use the wildlife habitat and thinning category, which has no acreage limit. Here’s an example of one from the Salmon-Challis. In that case, the project is designed to improve sagebrush habitat by removing conifers.
Here’s the category from the NEPA Handbook:
(6) Timber stand and/or wildlife habitat improvement activities that do not include the use of herbicides or do not require more than 1 mile of low standard road construction. Examples include but are not limited to:
(i) Girdling trees to create snags;
(ii) Thinning or brush control to improve growth or to reduce fire hazard including the opening of an existing road to a dense timber stand;
(iii) Prescribed burning to control understory hardwoods in stands of southern pine; and
(iv) Prescribed burning to reduce natural fuel build-up and improve plant vigor.
It’s easy to imagine large projects fitting this one as written, but the practice as I recall was generally not to use it for large projects.
But I don’t know. Other ideas?
I’d also note that there’s no hiring check, as with the BLM. Again, perhaps experience indicates to the politicals that this wouldn’t be a useful, and might be a demoralizing, exercise.
Here is the discussion about NEPA with my and Sam Evans’ perspectives from the Jack Igelman Carolina Public Press story here. What do you think?
Although politicians have portrayed NEPA as enforcing rigid and redundant rules that prevent action, within the agency, said Friedman, the view of NEPA is “based on how (its) tasks and practices affect them and their work.”
For example, she said, a public affairs specialist may appreciate the public input aspect of the law.
Friedman said that when she joined the agency in 1979, “a strong bias that the real work was in the woods and not chained to a desk” existed.
But the culture within the agency has changed, and some now see the law as a means to “getting involved in decision-making and influencing what the project does,” she said.
Still, within the agency, there are plenty of concerns about NEPA.
An October 2018 roundtable discussion hosted by the National Forest Foundation — the nonprofit arm of the Forest Service created by Congress — identified several concerns within the agency and its partners.
They included fear of litigation, the lack of capacity within the workforce, varying knowledge of NEPA among staff, and concerns that resources reallocated to fire suppression have dried up budgets, among many others.
Evans thinks an internal perspective exists among some bureaucrats within the Forest Service who “feel NEPA is a red tape obstacle they want to get rid of — that NEPA is the problem.”
“NEPA gets the blame but is a critical safeguard to make sure that the work the Forest Service does is good” and a counterweight to politicians who see the legislation as excessive bureaucratic regulation, he said.
“There is also a perspective in the agency that NEPA is the only counterweight of the extreme pressure on staff to cut more timber,” Evans said.
“(NEPA) is the yin and yang of Forest Service decision-making, and the current reforms fundamentally shift the balance of power in agency decisions.”
I told Jack that when I started in 79, the first CEQ NEPA regs had only been out for a year. So to the work generation before mine, (I’d use the term “mothers” except I don’t remember any females in that cohort) doing NEPA was a completely new thing. It required hiring people who knew about obscure topics like fisheries, economics and so on, which required a massive cultural transition. But that was forty years ago now, and that generation and mostly my own (who worked on Process Predicament) have gone. Current employees have grown up with NEPA.
I also told Jack that CE’s are a bit like an IRS short form (it’s not a great analogy but..) the IRS mostly knows the situations that require long forms (think extraordinary circumstances). Some people don’t like doing their taxes, but everyone likes getting refunds (the equivalent of getting projects done?)
Many NEPA people love doing (at least part of) NEPA. It can be underappreciated and I always thought it was excellent preparation for line officer work. Some specialists see NEPA as something that makes them write boring docs when they could be in the field or working their program. Others look at it as way to gain influence over decisions, or faithfully represent the trade-offs to the best of their professional skill. Some people like me really like talking to people at public meeting and trying to figure out a way to design the project so that as many interests as possible would agree. Perhaps it was more fun for me, as the kinds of projects I worked on did not have timelines that were rigorously enforced.
In 2014, the Pisgah Ranger District conducted a 64-acre timber harvest in the Mills River watershed as part of an Brushy Ridge ecosystem improvement project to control nonnative pests and improve fish and wildlife habitat. Jack Igelman / Carolina Public Press.
Another detailed story from Jack Igelman of Carolina Public Press on the litigation against the new Forest Service NEPA Regulations. I’d like to discuss the NEPA attitude question that Sam Evans brought up in post 2 on this. This one will just focus on “how different is the new CE from current legislative CE’s?” and “what do we know about how the Forest Service has used those?”
We had an interesting discussion about the fact that there are existing legislative CE’s that already allow more acres than the Resilience CE. Those legislative CE’s require both scoping (as do all the relevant CEs), as well as a collaborative process.
Here’s what the new Restoration CE requires in addition to scoping:
Allows 2,800 acres of activities (which may include commercial/noncommercial timber harvest). Primary purpose of all activities must be achievement of restoration objectives.
Salvage harvest is not allowed under this category.
Requires project development via a collaborative process
It turns out that parts of the North Carolina forests are allowed to use CEs 603 and 605 due to the HFRA mapping. In fact, they have done so.
As explained by Sam Evans in the story:
In fact, the Forest Service used categorical exclusions for North Carolina timber projects before the rule change, including the 2017 Crawley Branch Southern Yellow Pine Restoration Project in the Grandfather Ranger District in Caldwell County.
The purpose of the project was to reduce the risk of Southern pine beetle infestation, and, using a categorical exclusion created to expedite threats caused by invasive pests and the rising risk of catastrophic wildfire, the Forest Service bypassed an environmental assessment.
“It’s a good project and it’s having good results on the ground,” Evans said. “The reason for that, however, is because you have a very capable district ranger who relied on a well-established, formally convened collaborative process.”
Although the categorical exclusion used for the Crawley Branch restoration has a limit of 3,000 project acres, it’s more limited than the recent restoration categorical exclusion, since it addresses very specific needs, such as wildfire suppression and pest infestations.
“(The categorical exclusion) also has important strings attached,” Evans said. “They don’t allow harvest of old-growth or large trees, for example. Congress gave the Forest Service the authority to take action for high priorities with limitations to prevent abuse so it could move ahead without consulting the public.”
However, the new categorical exclusion rules allow the Forest Service to reject the limits imposed by Congress, he said.
“The Forest Service wants to be able to move forward even with low-priority, high-controversy projects without consulting the public,” he said.
To me, the consultation is in the requirement for scoping and in the requirement for collaboration. Do to say that the FS wanted to move forward with high-controversy projects “without consulting the public” seems like a bit of a stretch. Here’s a link to the documents (including scoping and DM) for the Crawley Branch project.
I don’t see many other “important strings” other than the old growth requirement in Categories 603 and 605.
Unfortunately I’ve never been able to find a simple CE table that shows all vegetation CE’s and the restrictions so here are the 605 ce’s.. “wildfire resilience”. You have to look in the NEPA Handbook, so I’ve quoted 605 below:
4. Wildfire Resilience. The Consolidated Appropriations Act of 2018 (Public Law 115-171) amended Title VI of the Healthy Forests Restoration Act of 2003 (HFRA) (16 U.S.C. 6591 et seq.) to add Section 605. Section 605 establishes a categorical exclusion for hazardous fuels reduction projects in designated areas on National Forest System lands. A hazardous fuels reduction project that may be categorically excluded under this authority is a project that is designed to maximize the retention of old-growth and large trees, to the extent that the trees promote stands that are resilient to insects and disease, and reduce the risk or extent of, or increase the resilience to, wildfires (HFRA, Sections 605(b)(1)(A)).
This categorical exclusion may be used to carry out a hazardous fuels project in an insect and disease treatment area that was designated by the Secretary under HFRA section 602(b) by March 23, 2018. (HFRA, Section 605(c)(2)(C)) Within designated landscape scale areas, projects carried out under this authority are:
Prioritized in the wildland-urban interface; or
If located outside the wildland-urban interface, limited to Condition Classes 2 or
3 in Fire Regime Groups I, II, or III that contain very high wildfire hazard
potential.
(HFRA, Sections 605(c)(2)(A) & (B))
Projects carried out under this authority may not be implemented in any of the following
areas:
a component of the National Wilderness Preservation System;
any Federal land on which, by Act of Congress or Presidential proclamation, the removal of vegetation is restricted or prohibited;
a congressionally designated wilderness study area; or an area in which activities… would be inconsistent with the applicable land and resource management plan.
CHAPTER 30 – CATEGORICAL EXCLUSION FROM DOCUMENTATION
(HFRA, Sections 605(d)(1) – (4))
A project under this authority must either carry out a forest restoration treatment that:
complies with the eligibility requirements of the Collaborative Forest Landscape Restoration Program under section 4003(b) of the Omnibus Public Land Management Act of 2009 (16 U.S.C. 303(b)).
(HFRA, Sections 605(b)(2))
Or, a project under this authority must carry out a forest restoration treatment that:
maximizes the retention of old-growth and large trees, as appropriate for the forest type, to the extent that the trees promote stands that are resilient to insects and disease, and reduce the risk or extent of, or increase the resilience to, wildfires;
considers the best available scientific information to maintain or restore the ecological integrity, including maintaining or restoring structure, function, composition, and connectivity; and
is developed and implemented through a collaborative process that— includes multiple interested persons representing diverse interests; and is transparent and nonexclusive; or meets the requirements for a resource advisory committee under subsections (c) through (f) of section 205 of the Secure Rural Schools and Community Self-Determination Act of 2000 (16 U.S.C. 7125).
(HFRA, Sections 605(b)(1)(A) – (C)).
Projects carried out under this authority are subject to the following size limitation on the number of acres treated:
may not exceed 3000 acres.
(HFRA, Section 605(c)(1))
Projects carried out under this authority are subject to the following limitations relating to roads:
A project . . . shall not include the establishment of permanent roads.
The Secretary may carry out necessary maintenance and repairs on existing permanent roads for purposes of this section.
The Secretary shall decommission any temporary road constructed under a project under this section not later than 3 years after the date on which the project is completed.
(HFRA, Section 605(c)(3))
All projects and activities carried out under this authority:
shall be consistent with the land and resource management plans…”
(HFRA, Section 605(e))
For projects and actions carried out under this authority:
The Secretary shall conduct public notice and scoping for any project or action.
(HFRA, Section 605(f))
Document this category in a decision memo (FSH 1909.15, 33.2 – 33.3) and include it on the
Schedule of Proposed Actions (36 CFR 220.4 (d)). The decision memo should include a
description of the efforts taken by the Agency to meet the collaborative process
requirements in HFRA, Section 605(b)(1).
Cite this authority as Section 605 of HFRA (16 U.S.C.6591d)
Bloomburg news had this interesting story about APD’s (applications for permits to drill on previously purchased leases) being approved without political oversight.
“Approximately 70 permits were approved without proper review following the issuance of a department directive that temporarily elevates review of permitting activities,” said Interior spokeswoman Melissa Schwartz. “Operators have been notified that those applications for permits to drill must be resubmitted for appropriate and timely review. Interior continues to approve permits and will transmit final decisions as soon as possible.”
The approvals were invalid under the Interior Department’s Jan. 20 secretarial order requiring agency brass to authorize drilling permits, easements, hiring and other decisions, according to a notification letter seen by Bloomberg News.
Companies also are being assured they do not face penalties for any drilling or other activities they started under the invalidated permits, though they are being ordered to cease those operations while seeking new approvals.
If I’d worked on processing those APD’s I’d find that a bit demoralizing. Maybe that’s just me. Or if I were a company told to start one day and stop a few days later. I had to do that once with research grants (call and tell the people whom I had told they had gotten grants that they weren’t really getting them after all). I left that agency shortly after.
Suspension of Authority.
The delegations of authority to Department Bureaus and Offices to take any of the following actions are hereby temporarily suspended, but may be approved by leadership identified in Section 4 of this Order:
a. To publish, cause to be published, or aid in the publication ofany notice in the Federal Register, including, but not limited to, notices of proposed or final agency action and actions taken in accordance with the National Environmental Policy Act:
b. To issue, revise, or amend Resource Management Plans under the authority of Section 202 of the Federal Land Policy and Management Act as amended;
c. To grant rights of way. easements. or any conveyances of property or interests in property, including land sales or exchanges, or any notices to proceed under previous surface use authorizations that will authorize ground-disturbing activities;
d. To approve plans of operation, or to amend existing plans of operation under the General Mining Law of 1872; e. To issue any final decision with respect to R.S. 2477 claims, including recordable disclaimers of interest;
f. To appoint, hire, or promote personnel. or approve the appointment of any personnel. assigned to a position at or above the level of GS 13, but this does not apply to seasonal hires or emergency work force personnel:
g. To issue any onshore or offshore fossil fuel authorization, including but not limited to a lease, amendment to a lease, affirmative extension of a lease, contract, or other agreement, or permit to drill. This does not limit existing operations under valid leases. It also does not apply to authorizations necessary to: (1) avoid conditions that might pose a threat to human health, welfare, or safety; or (2) to avoid adverse impacts to public land or mineral resources.
These mostly sound a bit like business as usual for a new Admin, depending on how long “temporary” is.. usually Administrations realize that the multitudinous grinding gears of large bureaucracies are difficult to watch all the time, and some kind of trust in employees in general to follow the regulations develops. I did flinch a bit at the “GS-13s and above” moratorium. It isn’t clear whether it’s to check “do we really need this job?” or “do we approve of this person?”. The former would be understandable, the latter a little creepy.
Does anyone know if the Forest Service or USDA in general has the same kind of moratorium and what it might entail? Hopefully not, as the trust and working relationships of many folks involved in the Biden Admin would hold over from four years ago.
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I always like following oil and gas debates, as they remind me of a current version of the “timber wars.” There are corporations (which are bad, needless to say) and their workers (especially working-class rural folks) who provide products that we all use. But oil and gas and forest products are both scape-industries, in the sense that the folks running the (good corporate) brewpub or the marijuana shop running off natural gas, and built with wood, are not contaminated by the sin of producing these materials. There must be a ritual absolution process somewhere along the supply chain.
Tisha Schuller gave an excellent talk on a recent webinar, and made some points that I thought could equally apply to folks from the forest products industry, federal lands ranchers, and perhaps even OHV groups. Here’s a link to her post today and the most salient points to us excerpted below. I think her ideas are worth trying for any group that is traditionally less-favored-group during D Administrations.
How Gamechangers Are Responding
The disruptors have demonstrated that the focus on climate is directional. Remember, this isn’t political. Your investors are in the first car on the climate train. There is not a political pendulum that will swing back when it comes to the role of oil and gas in the energy future. The only choice remaining: We must lead.
Here’s what your responses sound like — if you’re a gamechanger:
· Share the aspiration. “We share the Biden administration’s sense of urgency on addressing climate change and accelerating decarbonization.”
· Take the first step. “We plan to work closely with the Biden administration on advancing clean energy innovation and execution. Addressing climate change happens better, faster, and cheaper with the oil and gas industry at the table. We bring millions of scientists and engineers, billions of dollars, world-class R&D, and millions of miles of existing infrastructure to the challenge at hand.”
· Show promise. “The first thing we want to collaborate with the administration on is ensuring that oil and gas development on federal lands is the most environmentally sustainable in the world, with the smallest footprint and the fastest path to decarbonization. This will allow the U.S. to be a global climate leader while managing the realities of economies, fuel and energy demand, available alternatives, and geopolitics.”
· Embrace the leadership vacuum. “Our industry is unique in that it can bring the resources, existing infrastructure, talent, R&D capabilities, and 150 years of entrepreneurial excellence to partner with the Biden administration to achieve our shared vision for a decarbonizing energy future.”
It’s long past time to throw out the old-school industry political playbook. Let’s do what we are good at and lead into the energy future.
I bolded the Show Promise because you could substitute wood production (including from fuels reduction projects) “on federal lands is the most environmentally sustainable in the world, with the smallest footprint and the fastest path to decarbonization.” This reminds me a bit of the certification on federal lands debate, but we can think beyond FSC.
If you read the Daines-Feinstein bill, you can recognize that pieces of industry ideas are spliced in with others’ ideas. Maybe a more direct and meaningful route to good policy is to sit down and have a discussion with the new Administration. Ideally people can have thoughtful interactions and discuss choices without becoming a random mess of quid pro quo. What do you think?
The project would authorize Montana Fish, Wildlife & Parks (FWP) to implement fish management and stocking actions within the wilderness that would establish a secure population of native trout, replacing an existing hybrid population.
To restore and secure this population, the project proposes the following actions; application of a piscicide, rotenone, to eradicate the non-native fish species; use of motorized equipment such as a boat motor, generator, and a helicopter to transport equipment, supplies, and fish for stocking; temporary development of structures or installations; and use of chemicals (pesticides or herbicides). Additionally, public access in the area would be closed for 7-10 days during the late summer of 2021 to reduce user conflicts with management actions.
The Forest Service has assessed the suitability of the proposed activities in the Scapegoat Wilderness through a process called a “minimum requirements analysis.” This is a process used to identify, analyze, and recommend management actions that are the minimum necessary for wilderness administration, as directed by the Wilderness Act of 1964.
From the linked article:
Opponents challenged the plan’s use of motorized equipment in a federal wilderness area where such machinery is typically prohibited, the idea of stocking otherwise fishless waters in wilderness, use of fish poison and the potential of harming non-target fish in the area.
There doesn’t seem to be much disagreement with the project purpose, but resistance to how they would do it. The exception where “mechanical transport” and “structure or installation” would be allowed by the Wilderness Act is: “except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act.” It seems like their argument that they need motorized access is weak (see photo), but if chemicals are the only way to remove the non-native species, should they not do it?
Then there is the requirement to maintain viable populations of native species on national forests, which might for some species (maybe amphibians that evolved without fish predators) require them to do it.
Thanks to Bill Gabbert and Wildfire Today for this post to a video about fuel treatments and the Creek Fire.
Part of the post is a video produced by the Alaska Interagency Incident Management Team featuring folks from the Forest Service and Calfire about how their work…worked. For those of us who have worked in the Sierra, it may be interesting to see what the stands looked like after mechanical treatments and prescribed burns, and what they looked like after the fire came through.
I shed no tears for the death of “commercial filming” permits. Last week, a federal district court judge declared the law requiring permits for commercial filming on public lands an unconstitutional infringement on speech. The court entered a permanent injunction enjoining the permit program and its enforcement.
The court’s postscript noted that “a more targeted permitting regime for commercial filming, which is more closely connected to the threat posed by large groups and heavy filming equipment, may pass constitutional muster in the future.”
Special-use permit administrators everywhere should be breathing a sigh of relief.
This wind development-environmental conflict map can be found here https://wgfd.wyo.gov/Habitat/Habitat-Information/Wind-Energy-Development. You can click on it to make it larger.
A story by Angus Thuermer in Wyofile: I like how G&F used their experience with existing installations to develop a process; maybe other states can benefit? I also like the pre-monitoring and possible ongoing adaptive management.
The guidelines seek early engagement with developers and at least two years of wildlife monitoring before they break ground. By working with developers even when they’re selecting a location, impacts can be minimized, said Amanda Losch, the agency habitat protection program supervisor.
“We really wanted to clarify a process where we had a lot of communication and touch points … so there’s constantly a back and forth,” she said. “For us, it’s all about having open lines of communication.”…
A new section fleshes out what the agency wants in post-construction monitoring plans. The new guidelines also expand on the role of technical advisory panels for each project.
“In this document, there’s more information on who should be on it, what should they be doing,” Losch said.
Thuermer also had a round-up of some impacts with links to studies:
Development of industrial-scale renewable energy projects could be wildlife managers’ next challenge as consumer demand and federal policies favor them over fossil fuels. Wyoming is the top state for potential wind development, the Wyoming Energy Authority states.
Energy companies have developed 1,816 megawatts of wind power production capacity in Wyoming and are building another 4,341, according to the American Wind Energy Association. The wind farms are affecting wildlife.
Recent research suggests pronghorn antelope shy away from turbines on their winter range. “We found evidence that pronghorn avoided wind turbines in winters after development within their winter home ranges,” authors stated in the abstract of a 2020 scientific paper. They acknowledged the topic needs more study.
Before adoption of the new guidelines, Game and Fish already was recommending that the Industrial Siting Council allow no wind development in critical “core” greater sage grouse areas “without clear demonstration … that the activity will not cause a decline in sage grouse populations.”
A five-year study of 346 telemetry-tagged female grouse comparing undeveloped area to a wind farm detected that they were less likely to select brood-rearing and summer habitat in disturbed areas.
There’s also worry about turbine blades killing birds and bats. The first phase of the Chokecherry and Sierra Madre Wind Energy Project south of Rawlins, for example, is expected to kill two bald eagles and 14 golden eagles a year, according to the U.S. Fish and Wildlife Service.
Power Company of Wyoming LLC is developing that 1,000-turbine, 3,000-megawatt field across 320,000 acres on the private Overland Trail Cattle Company Ranch. The USFWS calculation of the turbines’ toll on eagles applied to the development of only the first 500 turbines, expected to be erected starting in 2022.
Sounds like the next act in the Sage Grouse Drama may introduce new characters…
Conceptual map of landscape zones and 27 fire and wood uses for Hemish people.
At a webinar I attended yesterday, one of the speakers worked for Indian Country Today. He spoke a bit about climate and pointed out that Native people have been adapting to changing climate for 10,000 years. Recently in the scientific literature, we’ve heard much more about traditional burning practices, and what we can learn from Native American practices. Perhaps the selection of Deb Haaland as Interior Secretary could accelerate this trend, especially with scientific research as USGS is in Interior.
Thanks to Rebecca Watson for the link to this interesting (open-source, yay!) study by Roos et al.
Policy Implications.
The Jemez ancient WUI obviously contrasts with modern WUI in the American West in ways that make the ancient WUI an imperfect analog for modern conditions. The economic, technological, and political differences are irreconcilable but they do not obviate the relevance of the ancient WUI for modern problems. The cultural contrasts between ancient and modern WUI highlight opportunities to cultivate more resilient communities by supporting particular cultural values. Two of the important characteristics of the Jemez ancient WUI are: 1) That it was a working landscape, in which properties of the fire regime were shaped by wood, land, and fire use that supported the livelihoods of the residents; and 2) that there was much greater acceptance of the positive benefits of fire and smoke. We emphasize that these are malleable cultural features, because reshaping western United States culture by learning from indigenous cultural values may be critical for building adaptive and transformative resilience in modern communities (26, 28, 85, 86). Learning to value the positive benefits of fire and smoke and to tolerate their presence will undoubtedly be critical to WUI fire adaptations. Furthermore, the ancient WUI highlights two key processes that may make modern WUI more resistant to extreme fires: 1) Intensive wood collecting and thinning, particularly in close proximity to settlements; and 2) using many small, patchy fires annually (approximately 100 ha) rather than using larger burn patches (thousands of hectares) to restore fire and reduce fuel hazards, particularly closer to settlements. Many WUI communities—especially rural and Indigenous communities—rely on domestic biomass burning for heat during the winter. Public/private–tribal partnerships to thin small diameter trees and collect downed and dead fuel for domestic use could have dual benefits for the community by meeting energy needs and reducing fuel loads. Tribal communities that have deep histories in a particular forested landscape may be ideal partners for supervising such a program (87). Lessons from the Jemez ancient WUI also suggest that federal and state programs to support prescribed burning by Native American tribes, WUI municipalities, and private land owners would provide equal benefit to modern communities (88). It is imperative that we understand the properties and dynamics of past human–natural systems that offer lessons for contemporary communities (89⇓–91). The Jemez ancient WUI is one of many such settings (72, 92⇓⇓⇓⇓–97) where centuries of sustainable human–fire interaction offer tangible lessons for adapting to wildfire for contemporary communities.
