On June 9th, the 9th Circuit Court of Appeals dismissed an appeal in a lawsuit against its revised forest plan. The appeal involved questions about ESA consultation on the plan’s effects on grizzly bears, and the proper environmental baseline for the amount of roads used in the consultation process. After the district court opinion found flaws in the analysis conducted for consultation, the Forest reinitiated consultation with the Fish and Wildlife Service, which has now been completed. The 9th Circuit held that the new biological opinion made that issue moot. (A new lawsuit was filed against the new biological opinion, discussed here.)
However, Kurt Steele won’t be overseeing the Flathead Forest Management Plan. As of Friday, USFS Region 1 press officer Dan Hottle said Steele “was offered and accepted” a new post as deputy director at the regional office that involves “environmental planning,” according to the Flathead Beacon. It is unknown who will be Steele’s replacement.
This was also announced on June 9th, but I assume there is no connection between the Flathead Forest Plan and Steele’s move to the regional office forest planning staff (he wasn’t hired by the Flathead until after the plan was done). However, there may be a connection to his work on Holland Lake (discussed most recently here), since it’s hard to imagine that a forest supervisor would consider a deputy position on a regional office planning staff to be a great career move. That connection is denied by the Forest Service.
“There’s no correlation with this (personnel change) and Holland Lake,” Hottle said. However, he said he did not know whether Steele had initiated applying for the position or if the Forest Service offered it to him first. Hottle characterized the change in position as a “lateral move” with a salary that should stay the same.
This is interesting to me because the regional planning staff didn’t have a deputy director position when I left, and the current agency directory does not show that there is such a position to apply for. It’s not unheard of for the agency to create a position to place someone where they will be out of the way, and I’ve observed that planning staffs tend to be seen as places to put people who need putting (and of course, anyone can be a planner). Or maybe there is some kind of vindication going on because he will nominally be overseeing the revision of the Lolo National Forest Plan, and the Lolo is where a lot of the same people who oppose the Holland Lake development like to hang out.
As I mentioned before, the Biden Administration has a tough row to hoe keeping its protectionist friends and its development friends (solar, wind and transmission) happy on the same pieces of ground. It’s really hard to write regs that favor some development, but not other development without stating some logic say.. uranium mining is bad, solar arrays and wind turbines are good, if the stated goal is carbon-free energy. Interest groups don’t have to be rational, but it’s nice to at least try in a regulation. Hence some degree of regulatory fuzz. But the regulatory fuzz may make your friends mistrustful, especially when, as in this case, two sets of friends are not in alignment. And here we are with the solar industry groups’ letter, (thanks to Sammy Roth of the LA Times) which I think generally says “we don’t really trust you.” Pretty much like many current user groups. From the letter:
The Renewable Energy Industry’s principal concerns with the Proposed Rule are as follows:
• Establishes Duplicative Land Conservation Program and Lowers Bar for Establishing ACECs. BLM already has effective and well-understood tools to conserve public lands that authorize the BLM State Director to evaluate and designate ACECs for resources of regional significance. Those existing tools can be used to protect landscapes and ecosystem resiliency without adoption of the Proposed Rule. The Proposed Rule would allow local BLM Field Managers to establish ACECs to protect resources of local importance, likely eliminating potential renewable energy development on vast tracts of Federal Land, and to do so without publication for notice and comment in the Federal Register. These changes to current regulations should not be adopted.
My bold: is this true? I like giving field managers authority, but aren’t we for public processes (and dare I say, well-known ones like the RMP process)?
• Establishes Broadly Defined and Unworkable Land Management Standards. The Proposed Rule requires local BLM Field Managers to protect broadly defined “intact landscapes,” prioritize “ecosystem resiliency,” and apply “land health” standards designed for grazing land in all areas and decisions. Local staff would likely not process applications (by giving them “low priority” under the regulations) in areas that will potentially be preserved in Resource Plan Amendments as “intact landscapes.” In addition, because arid lands cannot by their nature meet ecosystem resiliency or grazing land health standards, projects would be denied even though those standards are by their nature inappropriate for application to desert areas. Ecosystem resiliency standards and grazing land health standards should not be applied to renewable energy projects in desert areas; current biological resource protection standards amply protect these lands. Similarly, protection of landscapes, where appropriate, should occur through State Director approval of ACECs, not a separate process.
What is broken about current protections for projects of all kinds? Why do more meaningless paperwork about what “land health” means?
• Creates Significant Litigation Risk. By establishing a programmatic mandate to require local officials to set aside intact landscapes and to apply inapposite ecosystem resiliency and grazing land health standards to solar applications on arid land, the Proposed Rule will expose BLM and developers to significant litigation risk from parties asserting that BLM failed to account properly for and consider these standards in the context of specific projects, or, more broadly, in the adoption of landscape level planning initiatives, such as the planned update to the Solar PEIS.
It appears that the solar industry’s Admin friends may have.. closer friends. Perhaps in large organizations with a contingent of environmental lawyers? Maybe a larger check needs to be written to the 24 campaign?
• Undermines the Administration’s Clean Energy Goals. Currently, BLM is considering approximately 220 applications for solar, wind, geothermal and transmission projects. Many BLM Field Offices are already understaffed, overworked, and unable to process renewable energy applications at the pace necessary to meet the Administration’s climate change goals on federally managed lands. Implementation of the Proposed Rule at the BLM Field Office level is likely to divert attention and already constrained resources from processing renewable energy permits. Furthermore, adoption of the Proposed Rule will likely result in conflicting standards and mandates at the BLM Field Office level without guidance as to how these conflicts should be resolved, resulting in ambiguity, uncertainty, increased risk and delay.
This was a concern of many of the people at our public meeting in Denver. So the BLM says it doesn’t have people to do the work it’s required to do by law, but needs to spend employees time on thinking and mapping intactness and defining land health. One person at our meeting wondered where the money was coming from for this, she was told that it was coming from the IRA. So climate bill money is used to make things more difficult for.. the renewable energy industry. OK, then.
The solar industry does like the conservation lease idea. At our Denver meeting, BLM folks said that conservation leases were an idea they undertook due to input from their “industry partners”. Why would you think federal land mitigation is better than private land mitigation, which the BLM already does? Perhaps to get more money for restoration? But when I asked in Denver, they said the funds from leases were going to the Treasury. So really, what they would do is enable BLM and industry to determine who else should be kicked off federal lands for an industry’s compensatory mitigation. To me, the idea of mitigation on private land makes more sense. That seems to give (certain) industries or NGO’s a leg up in determining what happens on federal land, beyond the permit boundary itself. What if Vail Resorts wants to kick some OHVers off someplace in Utah to mitigate its negative effects? It’s like dividing up the BLM between (certain) industries and certain non-users.. all in the name of the environment. Without actually making the case that the status quo with existing procedures is all that bad.
The comment period for what I call the Mature and Old Growth Advanced Notice of Proposed Rulemaking (the MOG ANPR) has been extended to July 20th. A nice gentleman at the Forest Service told me that it’s really called the ANPR on “climate-informed forestry” which would be different from the actual title at the Federal Register (Forest Service Functions). Anyway, it could be confusing if you just look at the main page which shows the old date and the number of days is wrong (see second screenshot above). This seems needlessly confusing IMHO.
If you’re interested in finding out about extensions, you can always subscribe for updates. Here’s where the the extension is posted.
As a non-paid person who often is asked to write or help with letters, I like to browse other people’s comments and see if they have interesting ideas. It would be handy if there were a search box that would not bring up form letters, or perhaps if you could set it to only include letters from organizations. Maybe more experienced people know if there’s a search possibility to do that?
Anyway, if you or your organization has submitted comments on either rule you would like to share, please link below.
It’s complex, that’s what this paper says, talking about Western Canada https://iopscience.iop.org/article/10.1088/1748-9326/ac7345
It’s interesting to take one set of facts -there are wildfires in Canada, the smoke is going toward the East Coast, and people who aren’t used to wildfire smoke were breathing it-, and see how those facts can be framed differently. There are different fires in Canada, in extremely different parts of the country, that are being managed differently, from full suppression to big boxes or what we might call wildland fire use, ignited by different sources. This tends to get lost in some of the reporting.
(Some) Legacy Coastal Media and Some Politicians- Wildfire Smoke, the Scent of Apocalypse
If you read the NYTimes or the WaPo, it’s the harbinger of apocalyptic climate change. Perhaps because the WaPo hired a bunch of climate reporters, it’s not surprising that any story could be seen through the climate lens.
I’m not saying that climate and weather don’t affect wildfires. I’m just saying that it’s difficult to tease apart the contributions of various climate change elements (different greenhouse gases, land use changes) from natural variability and a host of other factors (ignitions, fire policy) and the history of vegetation that has developed through time. I’m OK with saying “it’s complex, and we don’t really know, but from what we know, the sum of human impacts on climate have affected the situation.” It’s complicated. But to some politicians, it’s simple- and the answer- to quit fossil fuels:
So that’s one framing.
The Hotshot Wakeup- It’s Complicated And You Need Suppression Folks- So Treat Them Decently and Support the Tim Hart Act
Let’s take a great the Hotshot Wakeup podcast from last week, titled “How Did the Canadian Wildfires Start? A Rational Response in a Sea of Conspiracy. What’s Really Happening?”
Tim does a terrific job of talking to people on the ground in Canada, and also trying to explain to people who aren’t familiar with the wildland fire world how things work. You can tell why he thinks the way he does because he gives his rationale. He also discusses some of the “out there” ideas that are floating around and, perhaps most importantly, doesn’t seem to have a specific axe to grind about causality (or would that be a pulaski?). He’s another one who looks at the situation and says “it’s complicated.”
He seems to come to the eminently practical suggestion that no matter what the different causes (ignitions, climate, past fire suppression), we are going to need wildland firefighters and they are not being paid or treated well and may walk off the job if Congress doesn’t get its act together. He suggests we all call our representatives and support the Tim Hart Act. NFFE has a link you can use to make it easy. I’d like to understand who is against it and why. Which goes back to the need for some Smokey Wire legislative contributors.
Anyway, I contacted my Congressperson’s office as a Smokey Wire reporter and asked whether they were supporting the Tim Hart Act, and if not, why not. They said their legislative team was reviewing it and did email me afterwards to say (sadly I’m not kidding) “I talked to our legislative team about the bill, and they said our office is not supportive as it’s a massive increase in expenditures for something that could be carried out at a state level.” I wrote back and said how can the state fund Federal firefighters?” and I haven’t heard back yet. I believe in fiscal responsibility, but the very same Congress just approved the IRA and BIL which the Admin seems to be sometimes using as a slush fund for their pet priorities (e.g., mapping intactness of BLM). After this depressing experience, I feel that filling out the NFFE form or calling would be helpful. It doesn’t matter is anthropogenic climate change is responsible for 5% or 40%, we need firefighters and they deserve to be treated decently.
Cliff Maas the Meteorologist- Smoke- Bad Luck Plus Some Climate Change? in the Wall Street Journal. I like how he mentions plants and seasonal drying. I don’t know how true this is of the areas involved.. would like to hear more local Canadian observations on the plants. The below is long, but in case you don’t get the Wall Street Journal..
The recent wildfires occurred in the boreal forests of northern Quebec. Fire isn’t rare in that region. The ecology of these forests relies on fire for the release of seeds and forest health. Many of the major boreal fires occur during a narrow temporal window from mid-April through early June, just after the winter snow has melted and before grasses and other small plants grow, reducing flammability. During this short window, the dead vegetation from the previous year can dry out sufficiently to burn if there is an ignition source such as lightning or errant human activity.
Many of the great Quebec fires have occurred during the spring, such as the May 2010 fire that spread massive amounts of smoke into New England and the May 1870 Saguenay fire, which spread smoke as far as the British Isles. Large boreal forest fires during the spring in Canada are neither unusual nor a sign of climate change.
The fires this month began on June 2, as hundreds of lightning strikes ignited vegetation dried by nearly a week of unusually warm weather. The weather prior to the warm spell wasn’t unusually dry, with the Canadian drought monitor showing normal moisture conditions and temperatures near or below normal.
Starting on May 27, an area of high pressure built over south-central Canada, warming and drying the area for several days into early June. With the light surface fuels, such as grasses ready to burn, all that was needed to start a fire was an ignition source, which occurred in early June with a lightning storm associated with low pressure.
The lightning ignited numerous fires and the low-pressure center’s circulation produced high winds that stoked the fires, resulting in rapid uncontrolled growth. Even worse, as the low center pushed south and intensified east of New York, it produced persistent strong winds from the northwest, moving the Quebec smoke into the New York metropolitan area.
It was the perfect storm for smoke in New York, with several independent elements occurring in exactly the right sequence. It’s difficult to find any plausible evidence for a significant climate-change connection to the recent New York smoke event. The preceding weather conditions over Quebec for the months prior to the wildfire event were near normal. There is no evidence that the strong high pressure over southern Canada that produced the warming was associated with climate change, as some media headlines claim. In fact, there is a deep literature in the peer-reviewed research that demonstrates no amplification of high- and low-pressure areas with a warming planet.
The long-term trend in Quebec has been for both precipitation and temperature to increase. Temperatures have warmed about 2 degrees Fahrenheit over the past half-century. Even assuming that this warming is entirely human-induced, it represents only a small proportion of the excessive heat during the event, in which Quebec temperatures climbed to 20 to 25 degrees above normal. The number of wildfires in Quebec is decreasing; there is no upward trend in area burned, which would be expected if global warming was dominant.
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The Hotshot Wakeup also has a new post on arson in the Canada wildfires titled “Alberta Premier Says She’s Bringing in Arson Investigators From Outside the Province.-175 fires in Alberta still have unknown causes. Very Interesting Indeed.”
But if we read what Google searches come up with on the Alberta arson question (or at least mine does), we get interesting anti-arsonist-explanation sentiment..
“There’s a certain logic to trying to distract from the terror of wildfires and the changing climate that helps set the conditions for them. For many individuals, perhaps the truth is so unimaginable, unsettling and unavoidable, they refuse to accept the complex origins of the new reality. ”
And pretty much call the interest in arson “disinformation”.
The facts will come out as to how many, if any, were started by arson, so we’ll see. It’s interesting to note the fact to spin ratio… But why is it so hard for many to say “it’s complicated” instead of “it’s climate”? Is that in itself “disinformation”?
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Side note: whatever your thoughts, please comment on the MOG ANPR here. That is Mature and Old Growth Advanced Notice of Proposed Rulemaking. Some people have had trouble finding the link, perhaps due to the bizarre title “Organization, Functions, and Procedures; Functions and Procedures; Forest Service Functions.” Comments are due June 20th. We appear to be in the middle of a major media campaign on the MOG, so this seems like a good time to discuss some concepts.
Norm Christenson and Jerry Franklin had a an op-ed in Politico yesterday. I’m a big Jerry Franklin fan, based on my personal interactions with him since the 80’s. I’ve told some of the stories before, so I won’t bore you with them again. Mostly our disagreements have been about west-side vs. east-side practices, ecology and experience.
I like how they tagged on the wildfires in Canada to “underscore the need to let our current mature forest grow old.” You could also argue that the wildfires in Canada underscore the fact that wildfires are a danger when trying to use forests to mitigate climate change. Because if you believe that climate change will cause forests not to grow back, you’ve just blown your last tree sequestration opportunity plus released much carbon (and PM2.5).
“It turns out the age and composition of forests makes a big difference in what role they play in preventing wildfires and storing carbon. Old growth forest is the best at both, but there is very little old growth left in either the western or eastern United States.”
I would argue that old growth forest in some species/places is not the best in “preventing” wildfires (what does “preventing” even mean in this context?). Take a mixed ponderosa/true fir understory stand with large old pp.. how exactly does that “prevent” wildfires? I won’t go into carbon because the sequestering/storage burning up all depends on assumptions which may differ.
As part of the MOG effort, the FS counted the BLM and FS Old Growth acres and you can see them in the above table. It looks like 33 mill acres or thereabouts, or about 18% of the total. Note that this is just FS and BLM, there is probably OG on other state and country and private lands as well. So.. are 33 ish mill acres plus other unknown acres “very little” or not? How would we know what the “right” amount is?
But a large amount of the forests on public lands is what foresters call “mature” forest, which is nearly as good as old growth and in fact is on the brink of becoming old growth. It is these older forests that will help us prevent future forest fires and will do the most to reduce climate change, and its these forests that we need to protect at all costs.
I’m still interested in the mechanism of older forests helping us “prevent” fires. I have to admit, the old forests in my neck of the wood seem to be slacking off on this.
Then there’s the “p” word.. protect- the question is “protect from what?” This op-ed seems to mean “protect from removing any trees”.. but you can in the chart below (in the ANPR) see the timber harvest acres (including ecological restoration and fire risk reduction) are relatively tiny compared to fire and bugs and diseases. I guess I can see the argument “we can’t affect wildfire, and insects and diseases, so let’s focus on timber”; except that we can affect acres impacted by wildfire by thinning. Unless you believe that fuel treatments, PODs, etc. don’t help protect mature and older forests. Which isn’t the view of the fire science community nor practitioners. In fact, that isn’t addressed in this op-ed.
Within a few years, tree seedlings grow quickly, and their canopies expand to form a continuous green “solar panel.” The time it takes for this growth depends on the site’s fertility and the number of pioneer trees in the environment. The result is an immature forest composed of trees of small stature and similar age. These immature forests pose a high risk of wildfire due to the abundance of fine fuel, small branches and leaves, near the ground.
This reminds me of our 1980’s Central Oregon silviculture workshop with Bruce Larsen and Chad Oliver- when trees compete for water, they don’t grow the same way as the standard models and thinking based on competition for light. The old mesic forest bias. And when water is limiting, then thinning can increase vigor of trees and reduce beetle outbreaks in some cases. This isn’t scientifically controversial. There’s probably a literature review out there; here’s one example from the Northern Rockies
Our results show treatments designed to increase resistance to high-severity fire in ponderosa pine-dominated forests in the Northern Rockies can also increase resistance to MPB, even during an outbreak.
So “protecting” increases risks from pine beetles and wildfire, which doesn’t actually sound, in those cases, very protective.
As to the green “solar panel” well..that kind of implies an even-aged stand, which many stands that I observer are not. And then there are forests that never form continuous crowns due to competition for water.
I can understand if some don’t want to count pinyon-juniper as forests, but then maybe each kind of forest should be considered separately, including mesic and dry forests.
Here are some interesting and relevant Q&As from the ANPR.
Q. What restoration options are available to restore old-growth forest structure in frequent fire forests?
Mechanical thinning and prescribed fire represent the primary approaches to active restoration of frequent-fire mature and old-growth forest areas to reduce their vulnerability to wildfire. Reduction in tree density often increases resilience to the climate-driven impacts of droughts, insects and wildfire.
Restoration prescriptions generally aim to increase the diversity of trees – age, size, and species – and retain the largest trees of the most fire-resistant species in the area. Diverse forests are more resilient because threats are less likely to impact trees species, ages and sizes at once.
Q. Are old-growth forests climate resilient?
Many old-growth forests have resilient characteristics like thick bark, high canopies, and deep roots. Some, like coastal redwoods, require moderate year-round temperatures and abundant moisture to thrive. As such, they are highly vulnerable to shifting conditions. As climate continues to deviate from historical
norms, even otherwise resilient forests are expected to be at increasing risk from acute and chronic disturbances such as drought, wildfires, disease, and insect outbreaks. These threats heighten the vulnerability of mature and old-growth forests resulting in higher chance of forest loss.
On one hand, it seems like the Boulder County folks, with help, did an excellent job investigating the Marshall Fire, and changing their practices based on that knowledge. Along with the concept of “lessons learned”. All that information is posted on their website. including an After Action Report and a Facilitated Learning Analysis.
On the other hand, we’ve had a global pandemic. Two federal agencies (DOE and FBI) think it might have been due to a lab leak. Other federal agencies were funding the research that might have led to the lab leak, and don’t think it was.. which seems like an obvious conflict of interest.. and they are continuing to fund similar work. You don’t need to have WHO numbers at hand to know that the Covid pandemic had substantially worse impacts than the Marshall Fire. Through the work of independent investigators, we have found many unsavory things about how gain of function research was managed, and how the discussion was handled in the press and on social media. Scientists are asking “is this research a good use of federal funds? Are the risks too great? Was gain of function research actually helpful in this pandemic, as promoted in the proposals? If it’s essential should it be done in more isolated places..say like Plum Island is for foreign animal diseases. Would it make more sense to have a commission of independent folks look at all this holistically -whether this research is needed and how it’s managed- rather than a variety of intelligence, law enforcement and other agencies coming to different conclusions on the more narrow question of a specific lab leak? Or should the usual “management of research” questions be considered (from London Times story):
It could have been the end of the Wuhan-North Carolina collaboration, but a loophole allowed gain-of-function work to proceed if deemed urgent and safe. Baric made the argument to the NIH, which gave approval.
……..
This triggered alarm bells for the US government because it would have involved the type of gain-of-function experiments that were still barred. According to documents obtained by freedom of information campaigners, Daszak argued the Mers experiment was not gain of function because it was unlikely to make the virus more pathogenic. A compromise was reached whereby the scientists would stop work and report to US officials if they created a new mutant virus that grew ten times faster than the natural virus it was created from.
…….
And the old and familiar, one agency found out something but it didn’t make an impression on another agency.
The US embassy found out about the experiments in Wuhan and sent diplomats with scientific expertise to inspect the institute in January 2018, according to diplomatic cables leaked to The Washington Post. They observed “a serious shortage of appropriately trained technicians and investigators needed to safely operate this high-containment laboratory”.
In the case of the New Mexico fires last year, the Forest Service had a 90 day stand-down, and involved the public in figuring out how to improve, and changed practices based on those findings. There’s a public report.
Then there’s the Durham Report. I recommend that if you’re interested, you read it yourself, not believe what others say about it. I think anyone working in a frequently FOIAed/litigated bureaucracy may enjoy it from a “glad that wasn’t me” perspective. There’s some humor in there as well. From page 258:
Within a day of receiving the Alfa Bank materials, Cyber Agent- I and Cyber Agent2 drafted a report of their analysis. he report’s summary stated that they had “assess[ ed) there is no CyD [Cyber Division] equity in this report and that the research conducted in the report reveals some questionable investigative steps taken and conclusions drawn.” The report acknowledged that there was no allegation of hacking and so there was no reason for the Cyber Division to investigate further. The report also said that
it appears abnormal that a presidential candidate, who wanted to conduct secret correspondence with the Russian government ( or a Russian bank), would (1) name his secret server ‘mail I.trump-email.com’, (2) use a domain (trump~ernail.com) registered to his own organization, and then (3) communicate directly to the Russian bank’s IP address (as opposed to using TOR or proxy servers).
Cyber Agent- I testified that both he and Cyber Agent-2 did not agree with the conclusion in the white paper and assessed that (i) the authors of the white paper ‘jumped to some conclusions that were not supported by the technical data,” (ii) the methodology was questionable, and (iii) the conclusions drawn did not “ring true at all.”
Now, I don’t expect the FBI to stand down for 90 days and look at how they went off the rails and how they might fix it. But why not have a report of what they found they had done wrong and how they plan to fix it in the future? After all, I’ve heard another election is coming up…
Here are my hypotheses:
-Fire culture has a history of lessons learned, others don’t.
-Important people don’t really want to know or improve; it’s OK for fire folks to undergo review, but not really important people.
– Partisans will try to get partisanship to creep in certain reviews and not others, and once partisan demons have entered the discussion, any review and improvement is DOA (dead on arrival). It has already reared its head with Covid in ways that I find, as a non-partisan, unfathomable. I understand how it happened with the Durham report, which was after all, about the FBI putting its thumb on the political scales before an election to the benefit of one party. Notice the Politico headline “Republicans dive into politically fraught push for Covid’s origin.”
But despite a growing chorus of bipartisan calls for such a probe, it’s unclear whether Democrats are actually willing to launch a wide-ranging review. The House’s select panel on Covid-19 has not committed to exploring how the deadly outbreak started, with its chair, Majority Whip Jim Clyburn (D-S.C.), recently suggesting he’d rather look forward than backward.
What is missing from this take on Clyburn’s take on (some) reviews is the idea that information helps agencies improve What if Chief Moore had said “I’d rather look forward than backward” after the New Mexico fires last year, or NASA had said that after the Challenger disaster?
Some (I would argue many or all) things are more important than partisan sparring. Like improving the way our agencies operate, especially those tasked with public health and law enforcement. Especially if you are in a party, I think, which holds the position that the government should be doing more things, an important piece of gaining trust would be being transparent about failures and fixing them… all across the interlocking mass of federal agencies. Among us the knowledge hasn’t been lost on how to do bipartisan commissions and reviews, all that’s lacking is political courage and a certain amount of bipartisan trust.
But even without the Congress setting up a bipartisan review, or the President setting one up.. perhaps they are all too embroiled in power-seeking to hear the call to good governance, there is nothing to keep NIH and CDC, and the FBI, from getting some fire folks in to help them develop the skills to have a more open, lessons-learned kind of culture. Who could be against better governance and developing trust?
In April of 2022, the Hermit’s Peak fire in New Mexico began as a prescribed fire that got out of control. The Forest Service’s Wildfire Review Report noted that pre-treatment was delayed by a Cottonwood-related injunction. A thinned project area would have had lower wildfire risk. The subsequent 341,000-acre fire destroyed habitat for the threatened Mexican spotted owls, elk and virtually all wildlife in the area.
Here in Montana, the Stonewall Vegetation Project in the Helena-Lewis and Clark Forest was one of the first projects halted by a Cottonwood injunction. A scientifically planned thinning and harvest of beetle-killed lodgepole pines and unnaturally dense stands of fire-prone trees was intended to enhance habitat and reduce fire risk.
An injunction halted the project in May of 2017 despite the court acknowledging “… that the Project area is susceptible to severe and intense wildfires due to elevated fuel levels caused by ‘heavy accumulations of dead and down timber.’ However, though there is the possibility of serious fire activity within the boundaries of the Project, there is no indication that this area is at risk of imminent fire activity.”
Less than two months later, lightning sparked the Park Creek fire that burned much of the proposed project area, proving that land management decisions are best made by resource professionals and not courts.
The environmental organizations that filed the suit and enabled this disaster were also paid $100,500 for attorney fees under the “Equal Access to Justice Act.”
Later today the Boulder County Sheriff’s Department will post their analysis on their website. Here’s a good story on it from the Colorado Sun.
It’s an interesting story of how homeowners burned material, put it out and buried it, and the wind came up a week later and blew the soil off and it started dry grass on fire. In dry areas with grasslands, dry grass is a natural feature for part of the year. Mountain View Fire determined that the reidents’ plan to extinguish it was reasonable and responsible. The Forest Service investigators and the Missoula Fire Lab were both mentioned as helping in the investigation.
We were talking about continuous improvement with regard to the NWFP; in this case, Boulder changed their rules to focus on water putting out fires.
So if we were to build a model of why this fire happened, we’d have:
Ignitions
Suppression Forces Stretched Thin by Several Ignitions, Covid
Wind- spread fire, plus air resources couldn’t be used.
Fuels- In many places with dry grass, grasses are eaten in the summer when they are green by grazing animals which reduces surface fuels. In fact, one one TV show I watched that day, the fire stopped at a rancher’s grazed area.
In our part of the country, these conditions are fairly common in the fall and winter and our county’s strategy is robust initial attack.
Originally coverage of this was all about climate change.
You might want to go back to my previous post on the Marshall Fire.
OK, so after unusually wet spring (is that AGW also?) precipitation below average and temperatures above average. But of course averages are averages because.. some observations are higher and some are lower. I would have said “the dry conditions we experienced (not the wet ones that encouraged plant growth?) are predicted to become more likely under AGW.” That is very different from being a “result” of climate change. Also there is a difference between the same conditions that used to happen, happening more frequently (we know how to adapt, and have to just do those things more often) and things that never happened before happening (where we need to respond differently). I’m not sure that distinction is often made.
Common narratives possibly contradicted by this example:
Current thinking: Cows are bad. And yet, they reduce grassy fuels and convert them to food.
Current thinking: Individual cars should be replaced by public transportation. And yet, people amazingly evacuated themselves and their animals quickly using.. individual vehicles.
Current thinking: Let’s build and maintain lots more power lines in dry places. And yet, maybe we should get better at maintaining the ones we have?
Current thinking: High density housing is best. And yet, house proximity caused fire transfer as in this Denver Post story.
Maybe communities in dry fire-prone ecosystems need to develop their own visions of how best to live with fire.
SUPERIOR – Too many houses built too close together on the tinder-dry high plains between Denver and Boulder led to the record Marshall firestorm losses topping $1 billion, insurance industry researchers found this week as they sifted through ashes and charred ruins.
….
“Conflagration happens when you get that proximity,” Roy Wright, chief executive of the insurance institute, said Thursday as his team began their investigation.
Spacing closer than 12 feet favors fire, researchers have established, and gaps between homes of 50 feet or more are advisable, Wright said. “Dispersion is one way to eliminate the domino effect” and with greater spacing “you would not have had so many structures lost.”
Re-making Colorado suburbs to endure worsening fires also will require clearing buffers at least five feet wide and “impeccably” bare, Wright said, along with screens on vents and retro-fitting with non-flammable roofing, siding and vegetation. Well-watered green lawns are less likely to burn than native grasses, he said.
And the mulch that residents increasingly use to help plants endure as temperatures rise “is like spreading match sticks around your home.”
From that story:
The question is what hardening would entail. A fire safety push for lower-density housing would collide with a push by some planners and developers toward higher-density “mixed-use” communities. Population growth in Colorado and other parts of the arid West has led some planners to encourage housing “units” clustered tightly like integrated circuits and surrounded by native vegetation that requires less water than lawns and parks.
Closer spacing and vegetation management for fire protection could clash with water conservation and other long-term objectives, said Molly Mowery, director of the Community Wildfire Planning Center, a nonprofit that guides town officials.
Looking at limits on growth opens “a huge can of worms,” Mowery said, anticipating that boosting fire resilience will require balancing climate warming preparedness measures. “There’s not going to be a solution that satisfies everything.”
As far as I’m concerned, abstractions are hatchways to hokum.. and portals to privilege- because you can be pretty sure you won’t be in the room when the details of who benefits and who loses from the definition is hashed out. There’s a common concept of “over-thinking” something; perhaps there should also be a concept of “over-wording.” It would include
1. Making up new words when all the concepts already exist,
2. Using plain English words to mean something else,
And for feds in particular
3. Making up new meanings for words already used by other federal agencies.
In this rule, a few abstractions that raise red flags:
“FLPMA’s (Fip-ma) declaration of policy and definitions of “multiple use” and “sustained yield” reveal that conservation is a use on par with other uses under FLPMA.” Hmm.. somehow this revelation.. that “conservation” is a “use” lay unrevealed for lo these 47 or so years. So let’s start with the definition of conservation:
Conservation
The proposed rule would define “conservation” in the context of these regulations to mean maintaining resilient, functioning ecosystems by protecting or restoring natural habitats and ecological functions…. Within the framework of the proposed rule, “protection” and “restoration” together constitute conservation.
That’s not what partner agency on intermingled private lands, the Natural Resources CONSERVATION Service might mean by conservation.
The protection, preservation, management, or restoration of natural environments and the ecological communities that inhabit them. Conservation is generally held to include the management of human use of natural resources for current public benefit and sustainable social and economic utilization.
Whoa! Major #3 (other federal agency) foul. Yes, says the BLM, we want to work as partners, yes we want the public to be involved, but we can’t help but define commonly used words differently. Our behavior does not seem to match our words. Our behavior seems to say “we want people to be confused about what we are trying to do.”
means an unfragmented ecosystem that is free of local conditions that could permanently or significantly disrupt, impair, or degrade the landscape’s structure or ecosystem resilience, and that is large enough to maintain native biological diversity, including viable populations of wide-ranging species. Intact landscapes have high conservation value, provide critical ecosystem functions, and support ecosystem resilience.
That seems like any large tract of federal land.. “Permanently or significantly disrupt” it could be argued, I suppose that while oil and gas rigs are not permanent, they could be “significant” and solar arrays and wind turbines could be decided to be permanent, but not “significant.” So what’s a landscape?
Landscape
means a network of contiguous or adjacent ecosystems characterized by a set of common management concerns or conditions. The landscape is not defined by the size of the area, but rather by the interacting elements that are relevant and meaningful in a management context. Areas described in terms of aquatic conditions, such as watersheds or ecoregions, may also be “landscapes.”
So an entire ecoregion might be an intact landscape depending on judgments of “permanent” and “significant.” People might wonder who exactly will be making those judgments..
Land health: The idea is to take land health- a concept from the grazing program and apply it to renewable resources (should meet at the watershed scale). They want comments on how it will interact with non-renewable resources.
§ 4180.1 Fundamentals of rangeland health.
Standards and guidelines developed or revised by a Bureau of Land Management State Director under § 4180.2(b) must be consistent with the following fundamentals of rangeland health:
a) Watersheds are in, or are making significant progress toward, properly functioning physical condition, including their upland, riparian-wetland, and aquatic components; soil and plant conditions support infiltration, soil moisture storage, and the release of water that are in balance with climate and landform and maintain or improve water quality, water quantity, and timing and duration of flow.
(b) Ecological processes, including the hydrologic cycle, nutrient cycle, and energy flow, are maintained, or there is significant progress toward their attainment, in order to support healthy biotic populations and communities.
(c) Water quality complies with State water quality standards and achieves, or is making significant progress toward achieving, established BLM management objectives such as meeting wildlife needs.
(d) Habitats are, or are making significant progress toward being, restored or maintained for Federal threatened and endangered species, Federal proposed or candidate threatened and endangered species, and other special status species.
and related standards and guidelines to all renewable-resource management, instead of just to public-lands grazing. Broadening the applicability of the fundamentals of land health would ensure BLM programs will more formally and consistently consider the condition of public lands during decisionmaking processes. Renewable resources on public lands should meet the fundamentals of land health overall at the watershed scale. The proposed rule recognizes, however, that in determining which actions are required to achieve the land health standards and guidelines, the BLM must take into account current land uses, such as mining, energy production and transmission, and transportation, as well as other applicable law. The BLM welcomes comments on how applying the fundamentals of land health beyond lands allocated to grazing will interact with BLM’s management of non-renewable resources.
To implement the fundamentals of land health, the proposed rule directs BLM programs to use high-quality information to prepare land health assessments and evaluations and make determinations about the causes of failing to achieve land health. Such information is derived largely from assessing, inventorying, and monitoring renewable resources, as well as Indigenous Knowledge. The resulting data provides the means for detecting trends in land health and can be used to make management decisions, implement adaptive strategies, and support conservation efforts to build ecosystem resilience.
I’m not exactly sure what “renewable resources” are in this context, maybe someone from BLM could help out?
