Here’s the Lit Weekly version of the Court decision on NEPA and the Wolverine fire we discussed previously here (27 comments).
1. Fire I Region 6
The District Court for the Eastern District of Washington ruled for the Forest Service on a National Environmental Policy Act (NEPA) case challenging the construction of a Community Protection Line (CPL) to contain the Wolverine Fire on the Chelan Ranger District of the Okanogan-Wenatchee National Forest in Forest Service Employees for Environmental Ethics v. United States Forest Service et al. The Wolverine Fire was ignited by lightening on June 29, 2015. By August 27, 2015 the fire grew to approximately 62,000 acres. After two failed attempts to contain the fire, the Forest Service began constructing the CPL, described as an approximately 20-mile long contingency line consisting of a roughly 300 foot wide thinning of vegetation. The CPL was near completion when the Forest Service halted construction after rain showers slowed the fire. Plaintiffs filed suit against the Forest Service on August 16, 2016, – “well after the construction of the CPL— complaining that the CPL was constructed without complying with NEPA.”
Plaintiff’s NEPA claims assert: 1) NEPA does not have a waiver from its procedural requirements for emergency actions and 2) even if NEPA did have a waiver, the Forest Service did not meet the requirements for claiming that waiver and wildfires do not represent emergency situations.
The court rejected both of plaintiff’s claims. The court ruled that NEPA does allow agencies to take actions in emergency situations “without complying with the ordinary, burdensome reporting requirements” because to require agencies to do so “is generally not feasible or prudent.” Under NEPA, an agency can circumvent traditional NEPA requirements if a “responsible official” determines “an emergency exists that makes it necessary to take urgently needed actions before preparing a NEPA analysis,” and the action is “necessary to control the immediate impacts of the emergency.” The court concluded a responsible official did determine that the Wolverine Fire constituted an emergency situation and “just because wildfires are common and their general existence is foreseeable, the danger created by any specific wildfire is not so foreseeable and can create an emergency situation with little or no forewarning.” (16-293, E.D. Wash.)
Litigation Update 1. Wildlife I Region 9
Environmental groups submitted an amended complaint in the Southern District of Ohio adding Endangered Species Act (ESA) claims to National Environmental Policy Act (NEPA) claims against the Bureau of Land Management’s and Forest Service’s authorization of oil and gas leasing in the Wayne National Forest’s Marietta Unit in Center for Biological Diversity et al. v. U.S. Forest Service et al. The new ESA claims assert that both agencies relied heavily on a 2005 Biological Opinion (BO) which plaintiffs claim is out of date due to new conditions and listed species at the lease sites. Relying on an outdated BO, as per the complaint, means the agencies cannot ensure that the leases will not likely jeopardize threatened or endangered species and therefore the plaintiffs assert the agencies must reinitiate consultation with the Fish and Wildlife Service (FWS) to address new information and species that have been listed since the 2005 BO. (17-372, S.D. Ohio) New Case! 1. FOIA & Timber I Region 10
Public Employees for Environmental Responsibility (PEER) filed a complaint in the D.C. District Court alleging violations of the Freedom of Information Act (FOIA) in Public Employees for Environmental Responsibility v. United States Forest Service. PEER claims that on April 7, 2017, as a result of concerns about the mismanagement of commercial stewardship timber sales on the Tongass National Forest, the plaintiffs submitted a FOIA request asking for: 1) a news release allegedly issued by the agency related to commercial stewardship timber sales in the Tongass; and 2) records detailing how the agency addressed issues raised in an internal review of its timber sale administration. According to PEER the Forest Service is currently in violation of FOIA because the agency has yet to respond to PEER’s FOIA request despite being required to do so within 20 working days from its receipt. (17-1277, D.D.C)
Notices of Intent
1. North & South Pioneer Fire Salvage and Restoration Projects I Region 4
WildLands Defense, Inc. submitted a Notice of Intent to Sue (N01) related to the North and South Pioneer Fire Salvage and Restoration Projects on the Boise National Forest. The NOl claims these projects violate the ESA for both Canada lynx and bull trout. For Canada lynx the NOI asserts that, because both projects contain lynx habitat and Canada lynx has been ordered to undergo re-consultation, the project cannot go forward until that consultation process is complete. For Bull Trout, the NOI states that the Forest Service glossed over the impacts the projects would have on already at-risk population and habitat conditions. WildLands Defense believes the agency should have issued a ‘likely to adversely affect’ determination, instead of a ‘not likely to affect’ determination, and entered formal consultation with FWS to comply with the ESA.
2. Martin Basin Rangeland Project I Region 4
Martin Basin Permittees submitted a request to reinitiate consultation and a NOl concerning a 2016 Martin Basin Biological Opinion (BO) and the agency’s authorization of livestock grazing on the Santa Rosa Ranger District of the Humboldt-Toiyabe National Forest. The request and NOI concern a conflict between the 2016 Martin Basin BO and the 2017 Jarbridge BO. Permittees claim both BOs are “functional equivalents” since both implicate threatened Lahontan cutthroat trout fish management upon grazing, but apply opposite terms and conditions “without any rational or legal basis to do so.” According to the Permittees the 2016 BO imposes a stream alteration term and condition while the 2017 BO does not.
I have sadly fallen behind in posting these, and my previous workaround stopped working, so will be catching up…
1. Land Use I Region 1
The District of North Dakota ruled favorably for the Forest Service on actions filed by North Dakota and several counties seeking quite title to claims of section line rights-of-way on the Dakota Prairie Grasslands. The order consolidated North Dakota et al. v. United States of America and Billings County et al. v. United States of America. ….(more in the original LW)
The court ultimately agreed with the U.S. Specifically, the court found “the 1976/1977 Travel Plans for Sheyenne National Grassland and Little Missouri National Grassland and accompanying ‘Public Notice’ and signage, as well as the Public Notices issued by the Forest Service in 1982, 1984, and 1988, as to the Sheyenne national Grassland” were sufficient to put North Dakota on notice of the United States’ claim to
exclusive control over the 33 feet on either side of the section lines and trigger the QTA limitation period. As the plaintiffs’ complaints were filed more than 12 years after the travel plans and public notices, the plaintiffs’ claims were barred by the statute of limitations. (12-125 and 12-102, D.N.D.)
NEW CASE
1. Recreation and Land Use I Region 6
Plaintiffs filed suit in the District of Oregon challenging the Summit Trail System Project on the Ochoco National Forest claiming violations of the National Environmental Policy Act (NEPA) the Travel Management Rule, and the National Forest Management Act (NFMA) in WildEarth Guardians et al. v. Forson et al. The project proposes to establish a 137-mile trail system open to motorized vehicle use during certain times of year.
According to the complaint, the project violates NFMA because it does not comply with the Ochoco National Forest Plan. The complaint contends the project: 1) is inconsistent with the plan’s standards and guidelines for Rocky Mountain Elk and Mule Deer habitat; 2) fails to comply with the road density standards and guidelines; 3) fails to comply with the recreation opportunity spectrum; 4) fails to comply with standards and guidelines for recreation impacts on riparian habitat; and 5) fails to comply with the standards and guidelines for old growth and scabland areas.
The project, as per the complaint, violates the Travel Management Rule because it: 1) fails to minimize damage to soils, watersheds, vegetation and other natural resources; 2) does not minimize harassment of wildlife or significant disruption of wildlife habitat; and 3) fails to minimize conflicts among different types of forest uses.
Plaintiffs’ NEPA claims are based on the assertion the project fails “to take a hard look at the direct, indirect, and cumulative impacts of the Forest Service’s proposed actions.” Plaintiffs believe the Forest Service did not: 1) provide accurate baseline data to evaluate the environmental impacts of the project; 2) take a hard look at the impacts the project would have on gray wolves and elk; or 3) take a hard look at the cumulative impact of the project and other projects and activities near the project area. (17-1004, D. Or.)
The approximately 60,000 acre forest would be established on the Flathead National Forest. All lands are within the LCCD boundaries and Lake County.
The Conservation Forest will be managed in trust by Montana’s Department of Natural Resources and Conservation (DNRC). The beneficiary of the trust is the LCCD.
The laws, rules and regulations governing the management of Montana’s State forest will be used by DNRC to manage the Conservation Forest.
All lands included in the Conservation Forest will continue to be owned by the United States Government. The people of the United States will continue to have the right to all lawful uses of these forest lands.
The Conservation Forest will revert to United States management 100 years after Congress approves establishment of the Conservation Forest.
All net revenues generated from proactively managing the Conservation Forest will be invested in conservation work in Lake County. The conservation work can occur on federal lands, State of Montana lands, private lands and tribal lands. Net revenues will most likely be invested in the Swan valley for a few decades.
Sheila Jasanoff, Sheila Jasanoff Pforzheimer Professor of Science and Technology Studies, Harvard Kennedy School
Andy Stahl’s comment here: reminded me of a recent piece I’d read by Sheila Jasanoff. Andy made the claim:
“While anecdotal information (“evidence based on hearsay“) can be helpful, scientific research and hard facts are a better basis for policy decisions.”
Sheila Jasanoff, Pforzheimer Professor of Science and Technology Studies at the Harvard Kennedy School, is an expert on the intersection of science, policy and law. This interesting piece by her recently came across my desk, and while it is fairly long, I’d like to draw your attention to her thoughts about how democracy, information and science come together (my italics).
To address the current retreat from reason—and indeed to restore confidence that “facts” and “truth” can be reclaimed in the public sphere—we need a discourse less crude than the stark binaries of good/bad, true/false, or science/antiscience. That oversimplification, we have seen, only augments political polarization and possibly yields unfair advantage to those in possession of the political megaphones of the moment. We need a discourse more attuned to findings from the history, sociology, and politics of knowledge that truth in the public domain is not simply out there, ready to be pulled into service like the magician’s rabbit from a hat. On the contrary, in democratic societies, public truths are precious collective achievements, arrived at just as good laws are, through slow sifting of alternative interpretations based on careful observation and argument and painstaking deliberation among trustworthy experts.
In good processes of public fact-making, judgment cannot be set side, nor facts wholly disentangled from values. The durability of public facts, accepted by citizens as “self-evident” truths, depends not on nature alone but on the procedural values of fairness, transparency, criticism, and appeal in the fact-finding process. These virtues, as the sociologist Robert K. Merton noted as long ago as 1942, are built into the ethos of science. How else, after all, did modern Western societies repudiate earlier structures of class, race, gender, religious, or ethnic inequality than by letting in the skeptical voices of the underrepresented? It is when ruling institutions bypass the virtues of openness and critique that public truthfulness suffers, yielding to what the comedian Stephen Colbert called “truthiness,” the shallow pretense of truth, or what the Israeli political scientist Yaron Ezrahi calls “out-formations,” baseless claims replacing reliable, institutionally certified information. That short-circuiting of democratic process is what happened when the governments of Tony Blair and George W. Bush disastrously claimed to have evidence of weapons of mass destruction in Iraq. A cavalier disregard for process, over and above the blatancy of lying, may similarly deal the harshest blows to the credibility of the Trump administration.
Public truths cannot be dictated—neither by a pure, all-knowing science nor unilaterally from the throne of power. Science and democracy, at their best, are modest enterprises because both are mistrustful of their own authority. Each gains by making its doubts explicit. This does not mean that the search for closure in either science or politics must be dismissed as unattainable. It does mean that we must ask and insist on good answers to questions about the procedures and practices that undergird both kinds of authority claims. For assertions of public knowledge, the following questions then seem indispensable:
Who claims to know?
In answer to whose questions?
On what authority?
With what evidence?
Subject to what oversight or opportunity for criticism?
With what openings for countervailing views to express themselves?
And with what mechanisms of closure in cases of disagreement?
If those questions can be raised and discussed, even if not resolved to everyone’s satisfaction, then factual disagreements retreat into the background and confidence builds that ours is indeed a government of reason. For those who are not satisfied, the possibility remains open that one can return some other day, with more persuasive data, and hope the wheel of knowledge will turn in synchrony with the arc of justice. In the end, what assures a polity that knowledge is justly coupled to power is not the assertion that science knows best, but the conviction that science itself has been subjected to norms of good government.
It might be fun to work through Jasanoff’s list of questions with the fire retardant issue. To someone outside this issue like me, it seems that we have practitioner experience vs. other knowledge approaches. It seems to me that any “serviceable truth” around fire retardant would have to incorporate both practitioner observations and explain the information (or lack thereof in the case of no studies) presented by Andy. Note that it doesn’t seem to be anyone’s paid position to arrive at “serviceable truths,” and it requires hard work to dig into the details. And of course, we could also use Sheila’s questions for our fuel treatment discussion after we have rounded up the relevant information and looked at it from a variety of angles.
The last few posts have been about what we might call “fuel treatments at the stand level.” Now we can move on to “fuel treatments on the landscape.” To that end, the next few posts are based on interviews with a scientist who specifically studies “where to put fuel treatments on the landscape.” Dr. Mark Finney, is the originator of SPLATs or “strategically placed landscape treatments.” Mark is a well-known fire scientist at the Missoula Fire Lab. Here is a link to his profile at Rocky Mountain Research Station (warning: people who study fires in action, and deal with fire suppression have more acronyms than you can shake a drip torch at.) Here is a more list of publications.
Below are my questions and his answers.
What is a “SPLAT”?
It stands for “strategically placed landscape area treatments.” They may also be called SPOTs for “strategic placement of treatments.” It derives from the theory that separate treatment units must overlap in the primary heading direction of the fire to interrupt routes of fires. The concept is not to stop fires, but to change the behavior, including spread rate and intensity. The pattern of disconnected treatments can interrupt the movement of the fire to reduce the intensity, buy time for weather to change or for suppression efforts. There can be an aggregated benefit if they are designed properly.
What’s the difference between a SPLAT and a fuel break?
A “fuel break” is a designed defensible location that requires active suppression. There is a long history of ineffective fuelbreaks. There have a number of limitations for landscape scale uses. First, they are intended to stop fires, and if they don’t then they’re not successful even if they modify fire behavior dramatically (lots of examples of green fuel breaks that are black on both sides). Second, stopping large fires on fuel breaks rarely succeeds because the length of the fuel break impacted by the fire perimeter requires too many personnel for suppression. Third, fuel breaks have to be maintained – which can become quite a burden in perpetuity. In contrast to the landscape objectives, fuel breaks are useful near areas of high value (structures) where defensive actions are going to be occurring anyway – reduced fire behavior will be very beneficial to protection even if the fire doesn’t stop (i.e. spots over).
How do you know where to place SPLATS?
They must overlap the primary wind heading direction. How do you know what wind direction?
In a given area, there can be a common wind direction from previous fires. “Large fires” are also called “problem fires”, from Bahro et al 2007. “A “problem” fire is a hypothetical wildfire that could be expected to burn in an area that would have severe or uncharacteristic effects or result in unacceptable consequences.” These past fires can give you a lot of information. You can use that information to find out how spread usually works in an area, usually or two main directions. You can look at fire weather and fire history and use that information to design treatments against exactly those fires.
What about size of individual treatment units? Ideas come from modeling. In the modeling, there is no exact size, it’s more about the pattern. In practice, there are a number of factors, one is operational constraints, one is the size of fire you are trying to interrupt. You can’t make them so large that fires can fit between untreated ones. Then you have to factor in spotting. Past suppression removes mild and moderate conditions, so now we have spreading under most extreme conditions, with more spotting. If, for example, spotting is ¼ mile then you need to have a ¼ mile. In theory, they can be small or big and they don’t have to be all the same size. You can choose them to fit terrain, ownership and roads. You can work around areas in which you can’t do the treatments.
To actually implement them, you need the to design them, work through the NEPA and appeals process. Through the appeals process, maybe you have to redesign everything if you can’t do a particular unit. But you can take that unit out and rerun the modeling and see what the impacts are and see if you need to redesign other units or add another unit.
The next post in this series will be on SPLATS in practice.
Supertanker arrives in Chile Since the editorial in the Colorado Springs Gazette posted previously about this plane mentioned environmental caution as a possible explanation, I thought I’d also post this op-ed, also found in the Gazette op-ed section over the weekend. I must say, if what is here is true (who knows?) I like the idea of the government independently testing the dispersion system.. who wants to be “crushed” even accidentally?). This op-ed is written by a fellow named Scott Weiser who blogs (?) something called AltNews.
We now know why the 747 firefighting jet is just sitting on the tarmac at the Colorado Springs Airport.
Some federal government bureaucrat has decided it is more important to glue thousands of paper cups to thousands of posts, arrange them in a grid, have the aircraft drop water on the grid and then weigh each cup to see how much water is in each of them than it is to put out fires.
This ridiculous exercise in bureaucracy is a required part of federal approval for an aircraft to dump water onto a raging forest fire.
Evidently the dispersion pattern of an air drop must be just so, must meet some exacting standard set up by the government that cannot possibly be set aside for now, so that lives and property can be saved. Talk about losing sight of the forest for the trees.
The company, GlobalSuperTanker has designed and tested the dispersion system extensively. It is designed to atomize the liquid to prevent crushing amounts of water smashing things as it comes down. It’s a system that exceeds what the government requires, but the government won’t believe its eyes or company data.
Here’s how they should be doing their approval: Load the aircraft up with 20,000 gallons of fire retardant or just plain water. Fly it over a forest fire. Dump the load on the fire. Repeat until the fire is out. Then, after the fire is out, examine the effectiveness of the air drops and if necessary make corrections to the system over the winter, when people’s lives and property are not at stake.
There’s a fundamental rule of firefighting: Get water on the flames. If you’ve got a bucket, use a bucket. If you’ve got a garden hose, use a garden hose. If you have a fire truck with a fire hose, use the fire hose. If you have an air tanker capable of dropping 20,000 gallons of water on a forest fire, use it.
There’s another fundamental premise of firefighting: Get water on the fire as soon as it is humanly possible to do so, because the smaller the fire is when you do so, the more quickly you can put it out. Five gallons of water at the right place at the right time can completely stop a forest fire from happening.
Twenty thousand gallons can put out a lot of fire instantly. The GlobalSuperTanker can lay down a 1.5-mile long strip of fire retardant or plain water in one pass. Using compressed air the tanks can be reloaded in less than 30 minutes. In Chile, they had it down to 13 minutes. One pass takes the place of five smaller 5,000-gallon drops in a fifth the time and is more effective.
It is not as if this aircraft has never put out a fire.
It is FAA-certified and has been doing so for some time, just not in the U.S. One need only view the many YouTube videos of this very aircraft saving the town of Santo Domingo, Chile, in January to see proof of this, and these videos should be all the Forest Service needs to put the GlobalSuperTanker in the air.
More delay only puts lives at risk without justification for doing so. Set aside bureaucratic obstacles and get it in the air, tomorrow.
Nobody in Chile cared how many drops of water were in a bureaucrat’s paper cup. They only cared that miles of fire line were snuffed out in moments by an aircraft that isn’t allowed to do the same thing here in the United States.
That is simply unconscionable and President Donald Trump needs to sign an executive order commanding the aircraft be placed into service immediately, suspending all further certification requirements until after fire season ends.
So give the White House a call, or send an email. Contact your members of Congress and demand that they contact the president and make him aware of this nonsensical bureaucratic obstructionism that is pointlessly endangering property and lives. Do whatever you can to get the GlobalSuperTanker into the air and free of the chains of bureaucracy that bind it to the ground for no good reason.
****An aside , I thought I had read somewhere that Calfire wanted to use this plane and while hunting for the quote ran across this cool Calfire recognition guide to its firefighting fleet. In case you wondered about Cal Fire…
The CAL FIRE Air Program has long been the premier firefighting aviation program in the world. CAL FIRE’s fleet of over 50 fixed wing and rotary wing, make it the largest department owned fleet of aerial firefighting equipment in the world. CAL FIRE’s aircraft are strategically located throughout the state at CAL FIRE ‘s 13 airbases and nine helicopter bases.
Colorado Gov. John Hickenlooper, left, greets the flight crew of the Boeing 747-400 Global SuperTanker after it dropped half its capacity of 19,400-gallons of water over the airfield during a ceremony Thursday, May 5, 2016, at the Colorado Springs, Colo., Airport demonstrating firefighting capabilities of the worlds largest firefighting plane. The Spirit of John Muir plane will be stationed out of the Colorado Springs Airport and will be able to respond to fires around the world. (Christian Murdock/The Gazette via AP)
Where you stand depends on where you sit and all that… not very often do I see a blog contributor mentioned in an editorial in my hometown paper…from the Colorado Springs Gazette editorial board. If anyone knows the FS side of the story, or the FS side of the Waldo Canyon story in the editorial, please comment. Here’s a link, and below is the editorial.
As fires race through forests in the West, threatening property and lives, the world’s mightiest firefighting air tanker sits idle on a runway at Peterson Air Force Base near Colorado Springs.
Like Nero watching Rome burn, federal officials fiddle with a contract and won’t let the aircraft fly. The plane offers taxpayers the lowest per-gallon delivery of retardant for any fire requiring two or more planes, with an ability to drop nearly 20,000 gallons of retardant.
U.S. Forest Service officials won’t offer Springs-based Global SuperTanker Services a contract allowing more than 5,000 gallons of suppressant. Forest officials won’t say why.
A 5,000-gallon limit defeats the purpose of fighting fires with a 747, which can dramatically increase the efficiency and results of aerial attacks.
The whole affair brings up sad memories of the Waldo Canyon fire, which burned for almost three days before federal authorities allowed a group of Air Force C-130 firefighting planes to fly.
Then-Mayor Steve Bach, U.S. Rep. Doug Lamborn and others expressed dismay when administrative process superseded the urgency of using every tool available to fight for property and lives.
The C-130s were based about 10 miles from Waldo Canyon, at Peterson, and could have battled the fire in its infancy – when airstrikes are more effective.
By the time the paperwork was signed, the inferno was out of control and consuming homes.
With a cruising speed of 600 miles an hour, the Spring-based Spirit of John Muir 747 can reach most wildfire-prone areas of the country in less than two hours. It can drop its entire load and leave a 200-foot wide fire barrier nearly a mile long. Alternatively, ground-based fire commanders can order multiple smaller drops.
The plane has double the capacity of any other tanker in the world. Unlike the others, it can fight fires throughout the night.
We don’t know why this tanker is grounded through fire season, but news reports suggest environmental politics may be in the mix.
Outside magazine reported on the Springs-based tanker in 2016. The publication paraphrased Timothy Ingalsbee, co-director of the Association of Fire Ecology, complaining that aerial fire retardants aren’t “ecologically friendly,” so why drop them from a bigger plane?
Andy Stahl heads the Forest Service Employees for Environmental Ethics, an activist group of federal workers dedicated to holding their employer accountable for “responsible land stewardship.” The Associated Press quoted him opposing the tanker last week, in a story about the grounding of John Muir.
Wildfires don’t negotiate. They don’t listen to environmentalists or seek permission from bureaucrats.
Wildfires quickly destroy forests, property and lives. The Forest Service is responsible for controlling them and should stop fiddling while our national forests burn.
For partisan-watchers, John Hickenlooper is a D governor.
For tech enthusiasts more on the tanker here at Wildfire Today (with videos).
Today, a federal appeals court ruled that the U.S. Forest Service is liable for toxic waste clean-up costs from mining on national forest land. The appeals court remanded the case back to the district court to determine how much the Forest Service would have to pay of the $1 billion in clean-up costs associated with a single molybdenum mine in New Mexico. The case is the first to conclude that the 1872 Mining Act, which gives mineral claimants the right to mine federal land, does not relieve the Forest Service from its CERCLA (“Comprehensive Environmental Response, Compensation, and Liability Act”) responsibility as landowner for the cost of cleaning up toxic wastes.
The unanimous opinion by Reagan, G.W. Bush and Clinton appointees, scolds the Forest Service for dereliction of its duty to regulate mining to avoid spendy clean-up costs:
There is no dispute that the United States held fee title to relevant portions of the Questa mining lands during the time of hazardous substance disposal, part of the area that today comprises the Questa Site. We do not doubt that it could have exercised greater powers, regulatory or otherwise, over the lands if it wanted to do so.
This decision could be a game changer. No longer can the Forest Service and BLM hide behind the 1872 Mining Act and ignore the environmental costs of the mining operations they approve on public lands. Just the existing liability for past mining waste could put a big dent in the Forest Service’s budget, which has a sum total of $0 appropriated for CERCLA clean-up costs.
From here on out, when the Forest Service approves surface occupancy plans for 1872 mining act claims, it had better look carefully at its clean-up liability. Under some scenarios, the Forest Service, as landowner, could be stuck with 100% of the clean-up costs.
A prescribed fire in the central Sierra Nevada is set to reduce fuel that could otherwise feed a catastrophic wildfire. (Jason Moghaddas photo) from Berkeley News here
Some of the fuels folks I’ve spoken with think you shouldn’t bother doing mechanical fuels treatment (in forests) unless you also do prescribed burning. The question to me is whether prescribed burning is 1) the only way or 2) the best possible, sort of the gold standard, but in some cases, fuel treatments can work without prescribed burning.
When you think about the world of fine fuels, it is easy to think about subdivisions and how we don’t run fires through them. So I looked at Firewise. In Firewise Zone 3, 100-200 feet from the house, it tells you here
“Zone 3 (High Hazard Areas) Thin this area, although less space is required than in Zone 2. Remove smaller conifers that are growing between taller trees. Remove heavy accumulation of woody debris. Reduce the density of tall trees so canopies are not touching*.”
Which sounds like getting rid of “heavy accumulations”, not exactly the same as burning, or mowing, or raking finer fuels.
(*Question that relates back to the “crown thinning” discussion: is this the same thing as “crown thinning”.. so is Firewise advice “wrong” to people who don’t think crown thinning is helpful for fuels treatments? Am I missing something here?)
Here’s an example of another paper about mastication in the Southwest. It talks about examples in which mastication without burning was successful in changing fire behavior, but it had to do with making sure the fuels were distributed across the site to avoid soil burning. You certainly get a feel for local differences in reading this paper.
I was hoping that there would be one paper that describes the situations where and why people do or don’t do burning and why, and how it works, but it seems that most of this work is thought and written about by fuels practitioners and at the local level based on their own experiences.
Potential Points of Agreement
1. Prescribed burning is generally best for fuels reduction in terms of fine fuels.
2. Due to long- term fire suppression, there are heavy accumulations of biomass in some areas. In these cases, you may need to do some kind of mechanical treatments in advance of prescribed burning, so you can run fire through and not kill them all.
3. There are situations (here, some mastication, and in wildland-urban interface, others?), in which you can’t do prescribed burning and mechanical treatments alone can be still helpful.
4. (I think the mastication paper is very helpful with this) It is hard to generalize because fuels and fire behavior tend to vary locally. Local fuels specialists may know the most about what works and what doesn’t.
Does everyone agree? Do you want to restate/clarify any of these?
(Note: this is not about the cultural, economic and environmental issues related to prescribed fire- that will follow later as we see where everyone is on the utility of prescribed burning for fuel treatments).
