Greenwire: Interior allows e-bikes on nonmotorized trails

From today’s edition:

Interior Secretary David Bernhardt issued an order yesterday that will require the National Park Service to open nonmotorized trails to e-bikes — a move that drew quick fire from green groups.

Under the long-awaited decision, e-bikes — electric bicycles — will be regulated the same way as human-powered bikes.

“E-bikes shall be allowed where other types of bicycles are allowed; and E-bikes shall not be allowed where other types of bicycles are prohibited,” Bernhardt said in his order.

With e-bikes growing rapidly in popularity, Bernhardt and other supporters say the order will make public lands more accessible to many Americans, including older people and those with disabilities who rely on them.

 

230 scientists nationwide oppose Forest Service move to squelch public comment

According to the Missoula Current:

Hundreds of scientists, including four from the University of Montana, have spoken as one in their opposition to a U.S. Forest Service proposal to squelch public input on future forest projects.

Just before the comment deadline on Monday, 230 scientists from across the nation signed and submitted a letter opposing a proposed Forest Service rule that would reduce public involvement currently required by the National Environmental Policy Act.

The Forest Service manages federal land that belongs to the American people, so the public should be able to have a say in how it’s managed, the scientists said. Especially if they have critical knowledge of how certain projects could degrade the land or ecosystems.

A copy of the full letter signed by 230 scientists is here.

Paper: Drought, Tree Mortality, and Wildfire in Forests Adapted to Frequent Fire

Here is a fascinating paper by Scott L. Stephens and 8 other authors from BioScience, February 2018 (open access):

Drought, Tree Mortality, and Wildfire in Forests Adapted to Frequent Fire

Stephens is a professor of fire science in the Department of Environmental Science, Policy, and Management at the University of California, Berkeley. He’s director of the university’s Fire Science Laboratory.

The authors suggest that “For long-term adaptation to climate change, we highlight the importance of moving beyond triage of dead and dying trees to making “green” (live) forests more resilient.” The focus on the central and southern Sierra Nevada, but the paper also applies to other areas of the west.

The recent massive tree mortality has many implications for the future of FF forests [forests adapted to frequent fire] and the ecological goods and services they provide to society (recreation, wildlife habitat, water storage, timber, aesthetics, carbon storage, etc.). It could be surmised that because FF forests have seen such dramatic increases in tree density relative to historical conditions, the bark-beetle-caused tree mortality could be helping to produce more resilient forest conditions (we define resilience as the ability of a forest to maintain characteristic structural components, such as large trees, and broad functionality following disturbance and/or chronic stressors). The actual outcome, however, will likely be forests that are very different from their historically resilient condition.

Also interesting: a sidebar entitled “The contrasting impacts of drought: Frequent fire forests in the western United States versus northwest Mexico.” The forests of the Sierra de San Pedro Mártir (SSPM) “have not seen the dramatic tree densification as occurred in California FF forests from fire suppression and logging.”

After the drought ended, a wildfire burned in the northern SSPM in 2003, but only 20% of the trees in this forest died from the combined effects of a severe 4-year drought followed by a wildfire (figure 4; Stephens et al. 2008), demonstrating considerable resilience to drought, tree-killing insects, and wildfire. FF-adapted forests in California and elsewhere once likely possessed similar resilience, which has been lost in the last 100 years.

I agree with the authors’ conclusion:

Many of our FF forests have failed to receive the very management that could increase resilience to disturbances exacerbated by climate change, such as the application of prescribed fire and mechanical restoration treatments (Stephens et al. 2016). Recent tree mortality raises serious questions about our willingness to address the underlying causes. If our society doesn’t like the outcomes from recent fires and extensive drought-induced tree mortality in FF forests, then we collectively need to move beyond the status quo. Working to increase the pace and scale of beneficial fire and mechanical treatments rather than focusing on continued fire suppression would be an important step forward.

 

Political Appointees, The Good and the Bad: Guest Post by Jim Furnish. I. Mt Wilson and Thirtymile Fire

Former Deputy Chief for National Forest Systems, Jim Furnish. Photo by Amanda Cowan of the Corvallis Gazette-Times
I think it’s important for folks who haven’t worked in the agencies, or with politicals, to hear what the interface between politicals and career civil servants can be like, in terms of the day-to-day management of the agency. For the Forest Service, anyway, pressure by politicals can be less like an assembly line of policy from DC to Ranger District, and more like the Administration punching a pillow, where the pressure dissipates through time and space.

To open the discussion, I asked Jim Furnish, former Deputy Chief of the National Forest System, to share the good and the bad of his experiences with politicals. For those of you who are not Forest Service folks, the chain of command goes like this: the Secretary of Agriculture (now Sonny Perdue) is over the Undersecretary over the Forest Service (now Jim Hubbard, formerly State Forester of Colorado). Those are political folks, and under that is the Chief of the Forest Service (not technically political, that’s a historic discussion in and of itself, but new Administrations of a different color tend to get rid of the old ones, in more or less dramatic ways), and the Deputy Chief for the National Forest System is the next layer down. There are other Deputy Chiefs, e.g. State and Private, that are over state and private programs and Fire, and Research and Development, Administration and International Programs, but the main issues that concern us here (other than fire) are all within the purview of the Deputy Chief for NFS. For example, the Director of Ecosystem Management Coordination (EMC) where litigation, NEPA and Planning are housed, works for that person in DC. One of the ways it’s confusing is that the Regional Foresters actually work for the Chief, but when Jim Furnish was Deputy Chief they worked for him. (See it’s even confusing to former employees). It’s fairly complicated-both the way it sounds and the way it works, with lots of opportunities for tension between the line and staff folks at various levels. Oh and let’s not forget that the Washington Office, at least before efforts for “work at home”, was a six-story rumor mill with tendrils of information, of unknown quality, like the game “Telephone” dissipating throughout the country.

For non-FS people this may be all too much bureaucracy, but it can help to understand the ways that authority can be both straightforward (line to line) and diffused (all those staff people at different levels).

I think Jim’s stories are all worthy of consideration, so this will be a series. Others are welcome to submit their own advice or stories, either as a separate post (email me) or in the comments below. As usual, let’s reflect on irritating or helpful behaviors on the part of politicals, not so much saying bad things about individual human beings. Also, I’d ask you to note how important trust is..the interface is people suddenly working together who feel that there are high stakes, and don’t have experience working together, nor, many times, any basic level of trust. I like the way Jim does the Good and the Bad, so these posts will be longer than usual. Now onto Jim’s post.

It Was the Best of Times; It Was the Worst of Times . . .

The interface which resource agencies and their leaders navigate between “doing right by the land” and doing the bidding of politicos is fraught with intrigue. As Deputy Chief of the Forest Service (1999-2002), I had a front row seat as observer and occasional participant during the latter part of the Clinton administration and early Bush one. The politicization of the agency has ramped up in an ever more partisan manner, especially since the spotted owl crisis. With Congress in gridlock, the executive branch has become the primary driver of policy formulation. I thought it might be instructive to share a couple “inside stories” that illustrate both the best and worst of agency politics. Each involves the Undersecretary for Agriculture — a political appointee overseeing the Forest Service and its Chief – a person I had frequent direct contact with while dealing with national forest issues.

Dave Tenney came to USDA in 2001 from a lead staff position with the House Natural Resources Committee. He remained in an “acting” capacity for many months while Mark Rey awaited Senate confirmation.

The Bad: When Ann Veneman of CA became Secretary of Agriculture, it seemed every party there with a bone to pick with the FS pestered her office for a fix. Early in 2001, Dave Tenney asked to see me about a matter involving TV towers atop Mt. Wilson in Angeles NF. Univision claimed that a tower that Disney had started to build would interfere with its transmission. Tenney noted these were “powerful, influential” parties and he directed me to “fix it” as he dropped an issue folder in front of me. I quickly examined the contents, and then explained that lawyers were already involved, the issue had a technical component that would require FCC involvement, and it would also be necessary to confer with the Region and Forest to inquire about background and what had already transpired. Then we could get the parties together with FCC and see about brokering a deal. “How long will that take?” I estimated about a week. He said he needed this done “tomorrow”. I noted this was unrealistic; simply impossible. He pressed on saying it was essential to get this fixed now (reflecting Veneman’s demand, I suspect). I quietly stared at him contemplating my next move. I told Tenney I understood the gravity and the urgency, but a substantive, reasonable solution needed a lot of work and coordination, many meetings, and a need to calm the lawyers while we found a solution that fit the facts. Tenney glared and demanded faster action. I then said “If you want me to take care of this I will – I need a week. If you want it done faster, then you do it.” Then I returned the folder. He reluctantly told me to deal with it and brief him when solved, which I did a week later. This was about March 2001, and I left the FS in January 2002. What little trust and optimism existed for a Clinton-era deputy chief to work effectively with a Bush appointee evaporated. Tenney and I almost never spoke again.

The Good: The tragic Thirtymile Fire (July 2001) in WA burned over a fire crew and 2 civilians, killing 4 firefighters and nearly all 16 hunkered in fire shelters. I received a midnight call asking if I would lead the fatality investigation. I agreed to do so. Chief Dombeck, shortly before he retired in April, had ripped into all his leadership group saying that the last time a fatality occurred, the safety officer had fielded 17 declinations until someone said ”Yes” to lead an investigation. In the future, Dombeck said “if your name is on top of the list when called, you WILL serve!” My name was on top for July 1-15. I departed for WA the next morning after briefing Chief Bosworth, who had just succeeded Dombeck.
The investigation team, including OSHA reps, proceeded briskly to determine the basics of what happened. Intensive Regional TV coverage covered every development and clamored for answers.

After 1 week we readied for a major press conference to lay out our findings. A lengthy report would follow after further investigation, but we had established a basic fact pattern that could dispel many myths. Then Chief Bosworth called to say he was sending his communications director to “manage the event”. This did not sit well with me. Our local public affairs officer and investigation team had performed well and we were ready as could be. My interactions with the natl comm dir led me to conclude he screwed up everything he touched and this event was too important. Further, I sensed the Chief had little or no confidence in me. I told the Chief he need not send him. Bosworth said it had “already been decided” (though I do not know if Tenney was involved, I suspected so). So I said he needed to understand that if he came to WA I would resign my position as investigation team leader immediately. I knew that the Chief could not stand the scandal of my departure one week in. There was a long pause on the phone.

Bosworth said “I’ll see what I can do”. The comm dir stayed home, and we had a good press conference that effectively addressed the media’s questions and allowed us to proceed with the balance of our work. In this case, I think my taking a stand had a good outcome and fostered improved respect and trust — with Bosworth, at least, who listened and understood and agreed to a mutually satisfactory outcome.

Colorado Trail Explorer and Its Ilk: Unintended Consequences?

Som Sai brought up an interesting point here that I hadn’t heard before.

I think handheld GPSs and apps like Caltopo which can be used with the GPS on one’s phone have driven a lot of use also. Many people who would hesitate to use a trail without marks and signage now feel confident on simply following the little arrow on the screen.

That has happened to me with one of my hiking buddies with COTREX a great app for those in Colorado. Maybe other states have these? I am not naturally an off-the-trail kind of hiker (too lazy), but some other hikers told us about a trail that was not on the map, and we could have done it without GPS, but (she) certainly did use the GPS. I can’t look at my phone and walk at the same time without tripping, let alone hiking. There is clearly a psychological tendency that I don’t have, and others do, to seek out undesignated trails.

Even in my part of Colorado, trails are getting more crowded (yes, and the tourism industry is trying to attract even more people, plus the resident population is increasing) and people who don’t want to be in crowds may naturally seek out user-designated trails or make their own. It seems to me that the topography in some areas might be more welcoming to this activity than others. Does anyone know of any studies of this dynamic? Or more personal experiences? It seems like where communities are adjacent to National Forests might be places where this dynamic has already occurred, and lessons could be learned.

Without painting mountain bike users as “the bad guys,” they certainly can go further into the back country in the same period of time as hikers. It seems like any user groups impacts would be a function of (numbers) (wildlife annoying properties- say accompanying dogs) (going places others don’t go). Would many horses, say, 15 miles in, be as bothersome to wildlife as a few mountain bikers? Or because of the cost, are there just a lot more MBers than horse people? At the same time, hikers could be camping that far in- how disruptive is that?

How disruptive are the “every day after work” in the front country, compared to the weekend type in the backcountry? Perhaps the residents vs. tourists? Are tourists more seasonal? Is there even a real distinction between the front, mid and back country where you live?

Restoring forests means less fuel for wildfire and more storage for carbon

More fuel for our continuing discussion of forest restoration (and active management in general), CO2, and wildfires. Mentions the USFS’s Four Foerst Restoration Initiative. Note that “simulations show that despite early decreases in the ecosystem’s stored carbon, a rapid restoration plan increases total carbon storage by 11-20%.”

 

When wildfires burn up forests, they don’t just damage the trees. They destroy a key part of the global carbon cycle. Restoring those trees as quickly as possible could tip the scale in favor of mitigating severe climate change.

Lisa A. McCauley, a spatial analyst at The Nature Conservancy, explains how quick action to thin out vegetation will actually increase carbon storage in forests by the end of this century. Her new paper is published in the Ecological Society of America’s journal Ecological Applications, and she will present the findings this August at ESA’s 2019 Annual Meeting in Louisville, KY.

“With predictions of widespread mortality of western U.S. forests under climate change,” McCauley states, “our study addresses how large-scale restoration of overly-dense, fire-adapted forests is one of the few tools available to managers that could minimize the adverse effects of climate change and maintain forest cover.”

Forests are a vital carbon sink – a natural sponge that pulls carbon out of the atmosphere through plant photosynthesis. Because carbon dioxide (CO2) emissions from human activities are a major cause of climate change, forests do humanity a huge service by disposing of much of its gaseous waste.

Unfortunately, wildfires are more common than they used to be. Higher tree density, more dry wood for fuel, and a warmer, drier climate have caused an increase in the frequency, size, and severity of wildfires in western U.S. forests. Restoring forests in a timely manner is critical in making subsequent wildfires are less likely. The U.S. Forest Service states that rehabilitation and restoration takes many years, and includes planting trees, reestablishing native species, restoring habitats, and treating for invasive plants. There is an urgent need for such restoration in the southwest U.S. to balance out the carbon cycle.

Enter, the Four Forest Restoration Initiative (4FRI). The U.S. Forest Service began the 4FRI in 2010 to restore 2.4 million acres (3750 square miles) of national forests in Arizona. The goals of the 4FRI are to restore the structure, pattern, composition, and health of fire-adapted (dependent on occasional fires for their lifecycle) ponderosa pine ecosystems; reduce fuels and the risk of unnaturally severe wildfires; and provide for wildlife and plant diversity. Doing so involves a full suite of restoration projects that are carried out by US Forest Service personnel, partners and volunteers, and contractors. Managers of the four forests – the Kaibab, Coconino, Apache-Sitgreaves, and Tonto – are engaged in a huge, collaborative initiative to with a diverse group of stakeholders to explore the best methods for restoring the ponderosa pine forests in the region.

One such exploration is a study in which researchers, including McCauley, use computer simulations to see how the carbon cycle and wildfire severity between the years 2010-2099 would be influenced by different rates of restoration of about 1500 square miles of forest.

A potential drawback to a very rapid restoration plan is that it includes the thinning out (harvesting) of dense, dry trees — possibly by controlled burns — to get rid of plants that could act as potential wildfire fuel. Reduction in overall vegetation could mean that the overall carbon uptake and storage of these forests would drop.

“The conventional wisdom has been that forest restoration in the western U.S. does not benefit carbon stocks,” McCauley says. “However, with wildfire size, frequency and severity increasing, we believe that additional research is needed across more forests so that we can better understand the fate of carbon and forest cover, particularly for fire-adapted forests where tree densities exceed historical norms and the risks of climate-induced forest loss are increasing.”

Interestingly, the simulations show that despite early decreases in the ecosystem’s stored carbon, a rapid restoration plan increases total carbon storage by 11-20%, which is about 8-14 million metric tons of carbon by the end of the century. This is equal to the removal of carbon emissions from 67,000-123,000 passenger vehicles per year until 2100.

“By minimizing high-severity fires,” McCauley explains, “accelerated forest thinning can stabilize forest carbon stocks and buy time – decades – to better adapt to the effects of climate change on forest cover.”

Restored forests provide other benefits than just increased carbon storage in the next century. A restored fire-adapted forest would be less dense, with fewer trees but more diversity, allowing more sunlight to penetrate the canopy, increasing cover of grass and encouraging a more diverse understory. The wildfires that do occur would burn at lower severity as ground fires that consume grasses rather than torching canopies that kills trees.

McCauley says this study is unique because it is a large, landscape-scale study that uses data from a real-world restoration project–the largest restoration being implemented in the U.S. The results are indeed promising, indicating that restoration is likely to stabilize carbon and the benefits are greater when the pace of restoration is faster.

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Americans’ love of hiking has driven elk to the brink, scientists say: The Guardian

Elk stand in an open field in 2014 between the Eagle River and Interstate 70 just east of the town of Eagle, Colorado, near Vail, Colorado. Photograph: Richard Spitzer/The Guardian
The headline is seriously overstated, but that seems par for the course these days. Here’s the link. The same story is in High Country News.

Biologists used to count over 1,000 head of elk from the air near Vail, Colorado. The majestic brown animals, a symbol of the American west, dotted hundreds of square miles of slopes and valleys.

But when researchers flew the same area in February for an annual elk count, they saw only 53.

“Very few elk, not even many tracks,” their notes read. “Lots of backcountry skiing tracks.”

The surprising culprit isn’t expanding fossil-fuel development, herd mismanagement by state agencies or predators, wildlife managers say. It’s increasing numbers of outdoor recreationists – everything from hikers, mountain bikers and backcountry skiers to Jeep, all-terrain vehicle and motorcycle riders. Researchers are now starting to understand why.

Outdoor recreation has long been popular in Colorado, but trail use near Vail has more than doubled since 2009. Some trails host as many as 170,000 people in a year.

Recreation continues nearly 24 hours a day, 365 days a year, said Bill Andree, who retired as Colorado Parks and Wildlife’s Vail district wildlife manager in 2018. Night trail use in some areas has also gone up 30% in the past decade. People are traveling even deeper into woods and higher up peaks in part because of improved technology, and in part to escape crowds.

The elk in unit 45, as it’s called, live between 7,000 and 11,000 feet on the pine, spruce and aspen-covered hillsides and peaks of the Colorado Rockies, about 100 miles from Denver. Their numbers have been dropping precipitously since the early 2010s.

Outdoor recreation has long been popular in Colorado, but trail use near Vail has more than doubled since 2009. Some trails host as many as 170,000 people in a year.

Recreation continues nearly 24 hours a day, 365 days a year, said Bill Andree, who retired as Colorado Parks and Wildlife’s Vail district wildlife manager in 2018. Night trail use in some areas has also gone up 30% in the past decade. People are traveling even deeper into woods and higher up peaks in part because of improved technology, and in part to escape crowds.

The elk in unit 45, as it’s called, live between 7,000 and 11,000 feet on the pine, spruce and aspen-covered hillsides and peaks of the Colorado Rockies, about 100 miles from Denver. Their numbers have been dropping precipitously since the early 2010s.

To measure the impact on calves, he deliberately sent eight people hiking into calving areas until radio-collared elk showed signs of disturbance, such as standing up or walking away. The consequences were startling. About 30% of the elk calves died when their mothers were disturbed an average of seven times during calving. Models showed that if each cow elk was bothered 10 times during calving, all their calves would die.

When disturbances stopped, the number of calves bounced back.

Why, exactly, elk calves die after human activity as mellow as hiking is not entirely clear. Some likely perish because the mothers, startled by passing humans and their canine companions, run too far away for the calves to catch up, weakening the young and making them more susceptible to starvation or predation from lions or bears. Other times it may be that stress from passing recreationists results in the mother making less milk.

“If you’ve ever had a pregnant wife, and in the third trimester you chase her around the house in two feet of snow, you’ll get an idea of what she thinks about it,” Andree said.

Andree wrote a letter explaining the dire impact of constant recreation on elk. Even if certain trails were closed during calving season, he said, elk would still be disturbed because some people simply disregarded instructions for them to keep out.

“Generally when you ask people to stay out of the area no matter what the reason is, 80-90% obey you,” Andree said. “But if you get 10% who don’t obey you, you haven’t done any good.”

The recreation community acknowledges its impact on wildlife as well as other development, said Ernest Saeger, the executive director of the mountain trails alliance. Many people don’t understand the significance of the closures. Others, he acknowledged, just don’t care.

So the group formed a trail ambassador program to post more informative signs at closures and even place volunteers at trailheads to explain why trails are closed. The scheme reduced closure violations in 2018, according to Forest Service numbers.

If trail building and closure violations in critical habitat continue, Devin Duval, Colorado Parks and Wildlife’s district wildlife manager in the area, anticipates the worst.

“It will be a biological desert,” he said.

Some thoughts: (1) Night trail use, I didn’t know about that, let alone it increasing. Maybe others can shed some light (so to speak) on that.
(2) Since most recreationists take gas powered vehicles to get to trail heads, perhaps there should be a moratorium on driving to outdoor recreation?
(3) How do these increasing numbers of people fit in with the “nature deficit” idea that still holds some sway?
(4) Are there better ways than harassing animals to study this problem?
(5) I’d be interested in how much is due to humans and how much to off-leash dogs (no, I am not suggesting a similar experiment with dogs).

Mountain Bikers and State Intervene in Ten Mile- South Helena Project

Helena District Ranger Heather DeGeest, center, talks about the use of existing roads in inventoried roadless areas to reduce fuels by logging and prescribed fire.
TOM KUGLIN, Independent Record

Lourenço Marques posted this as a comment:
He had seen this on FB.

Today the Montana Bicycle Guild, Inc., filed a motion to intervene in the lawsuit in the U.S. District Court brought by Helena Hunters & Anglers and Montana Wildlife Federation against the U.S. Forest Service. The MBG is intervening to support the Forest Service’s decision on the Ten Mile-South Helena Project and to protect the interests of mountain bikers.

“As part of the post-disturbance restoration for this project, the Forest Service adopted several long-established trails into the trail system inventory and also approved the construction of three new thoroughly vetted and needed trails.

“The lawsuit brought by Helena Hunters & Anglers and Montana Wildlife Federation challenges the incorporation of existing trails into the inventoried system. Their lawsuit also seeks to prevent two of the new trails in this area from being built. . . .

“This would end-run years of work and collaboration to impose a de facto ban of bicycles from every trail in this area targeted by their lawsuit. If the Helena Hunters & Anglers and Montana Wildlife Federation lawsuit is successful, the bicycling community would suffer a major loss and be banned from this entire area.

“This project doesn’t only impact bikers—every public land user would lose a couple of well-thought-out new trails that is the result of numerous people and groups working together for many years, including the MBG, to plan and collaborate with the Forest Service.”

Lourenço asks “Would any employees of or participants in the public-lands litigation factory care to explain how this lawsuit benefits the cause of conservation?”

It seems pretty much BAU to litigate fuel treatment projects in Montana. The interesting twist is about the trails. From this Independence Record story:

The project calls for logging, thinning and prescribed burning on 17,500 acres near Helena. Goals primarily focus on wildfire concerns, with the aim of creating safe places to insert firefighters and reducing a wildfire’s potential severity. A smaller aspect of the project includes trail designations and construction, which has drawn some criticism — and now lawsuits — over concerns of drawing mountain bikes into roadless areas.

The association and federation’s lawsuit was recently consolidated with a separate and much broader lawsuit filed by Alliance for the Wild Rockies and Native Ecosystems Council. While the first lawsuit only challenges work in inventoried roadless areas, the second lawsuit challenges the entirety of the project and calls for it to be halted due to allegations of inadequate environmental analysis and impacts to wildlife.

The guild is challenging the trail portion of the lawsuit. The group contends that multiple trails in the project area have been used for decades by mountain bikers and notes that the project decision prohibits mountain bikes from leaving designated trails. The project officially designates two trails that have seen traditional bike use as well as construction of two multi-use trails in the Jericho and Lazyman Gulch inventoried roadless areas, the guild says.

Is this about kicking bikers off trails they currently use? But bike use is legal in roadless areas.. It’s all very confusing.

I also noted that the State is an intervenor as in this story from KTVH.

Finally, to make the whole project even more confusing, the project is currently underway while the lawsuits move forward according to this article that talks about the implementation (with good photos).

“Courts have not ruled on or temporarily halted the project as it hears the cases, however the Forest Service has agreed to suspend work in roadless areas until the court has ruled on the first lawsuit.”

Here’s an op-ed on the Collaborative and how their opinions were used in the decision.

Here’s a link to the EIS and Matthew Garrity’s (AWR) objection letter

Some of his claims are interesting:

The purpose of the project according to the DROD is to: “Reduce the probability of high-severity wildfires and their associated detrimental watershed effects in the Tenmile Municipal Watershed and surrounding area.”
This is a violation of NEPA since the project will not do this and the purpose also violates NFMA and the APA since trying to fireproof a forest destroys a forest and makes an unhealthy watershed.