Wildfire 2021

I have a whole story of being out on a 2 man little helitack fire in Idaho, and finding our location downwind of a large fire having a freight-train blowup event.

Being separate from that other fire, we weren’t part of their command structure, or in their communications, and the radio was so clogged with frantic red-alert, civilians-in-danger, evacuation traffic we couldn’t really get into their loop. We ended up taking a study break to figure where the fuck we were and what our options were for retreat, then we took turns with one working the fire and the other up in a tree watching this bigger fire.

Tense day.

How are those Fishers gonna do when the whole thing runs natural?

This is the shit that drives me nuts…it’s not a choice between treatment and nothing, it’s going to burn eventually one way or the other. All you can do is try to get ahead of it so it’s not so catastrophic when it goes.

All these oppositions and legal actions set up a false dichotomy between mitigation vs nothing, as if nothing means it won’t be nuked by the next ripping crown fire. It’s so fucking dumb.

I haven’t heard about that fischer group.

Something that continued to not be well considered by many of the public and decisionmakers is the potential catastrophe of doing nothing or doing too little. We see over and over again how humans struggle to understand and plan for lower probability / high consequence events. With wildfire, doing nothing is shifting the probability and severity of consequences, and that shift seems even harder for most to grasp.

After the Camp Fire in the Paradise area, the air quality in the Bay Area was so bad that private corporations are starting to react and become engaged in decision making, which is good. Couple that the following very severe fire seasons that directly affected the Bay Area residents, and hopefully momentum will continue with more tangible and effective solutions. Better too late than never.

Speaking of the Camp Fire, I’ve stated this before, but the cost of clean up of the private property cost tax payers $1B. Of course, that’s only a fraction of fed $$ spent on the Camp Fire. $1B could have been spent making that area ready for a wildfire. Of course, mitigation projects probably would have been mired in challenges via NEPA compliance from various groups to have ever resulted in boots on the ground.

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Originally Posted by spanghew

Just curious--are these recreational residences built on Forest land in the 50s as part of that short-lived program to move people into the woods on public land? If not, how is SHPO involved at all? And if so, this represents a very small effect of the National Register in people's lives; most people probably know little or nothing about it or are ever affected by it.

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They are federally funded projects on private property. Typically funded by FEMA. Federal funding is an “undertaking” per section 106 of the national historic preservation act and consultation with the SHPO regarding potential effects to historic properties is required. It’s a very similar process to federal funding agency compliance with section 7 of the ESA.

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Originally Posted by bodywhomper

They are federally funded projects on private property. Typically funded by FEMA. Federal funding is an “undertaking” per section 106 of the national historic preservation act and consultation with the SHPO regarding potential effects to historic properties is required. It’s a very similar process to federal funding agency compliance with section 7 of the ESA.

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It's true that presumptive eligibility is poorly adapted to 'emergencies,' but Section 106 was created to deal with the emergency of cultural heritage being destroyed and modified at the whim of short-term land managers, generally in the thrall of industry or congressional mandates requiring the Forests to be cash-generators.

And the kind of work that needs to be done to actually determine eligibility has neither funding nor staff or the will of most Supervisors, even if the Heritage Program Managers would be very happy to get the work done. I've worked on Forests where the Rec Residences have been recorded by volunteers under a PIT project, and were then evaluated by the HPM; it takes a couple reams of paper and all the hundreds of hours necessary to create all those words, to complete the process and make recommendations, but it's nice to have it done for the whole development rather than on a case-by-case basis.

Presumptive eligibility is a tool of necessity due to lack of funding and personnel, and the eagerness of people to just get that pesky cultural heritage out of the way so real and important forward-thinking work can be accomplished by people unfettered by those [enter your favorite epithets here] delaying progress [yadda yadda].

Section 106 has a lot of problems, though generally because it fails to acknowledge important things that slip through the narrow parameters governing it. And it's a poor management tool that requires constant revision, ideally as more is known and understood, rather than as more is destroyed and lost.

Metal roofs are a band-aid to fix something that was built for a concept of life that no longer obtains. A lot of heritage preservation has built-in ironies, one of the biggest being the need to preserve something that was never made to last to begin with.

Ok well, I guess they’ll keep burning. ��♂️

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Originally Posted by ill-advised strategy

Ok well, I guess they’ll keep burning. ��♂️

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And people will keep looking for scapegoats?


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I mean…If we can’t do mitigation work because [whatever] needs to be “protected”, then fire rips through there and nukes a town, that town has pretty fucking good standing to lambaste whoever and whatever held up that mitigation.

In terms of public perception and Borg Momentum, never say never. Gay marriage, legal weed, yadda yadda. The tipping point is hard to predict but becomes clearer in retrospect. It sure seems like mainstream thought in the western states is increasingly supportive of (for example) more prescribed burns in the safer months. I don’t have the expertise of some of you to understand how this plays out in regulatory reform, liability reform, etc.

I tend to be extremely skeptical of suspending or rolling back environmental protections AND that in some cases they are anything more than a paperwork exercise. Certainly in some situations we would be fine with hiring resource professionals to be on the ground looking at active work and mitigating issues in real time instead of producing reports.

Is the NEPA bottleneck an issue of staffing or is it more of an issue of the process?

Oregon and NOAA marine fisheries has a MOU and a manual for implementing storm water BMPs that works well compared to the more formal process. It seems like something along those lines could work to help move projects forward.

I think that the emergency mitigation actions we are talking about need to be extremely targeted around values at risk (WUI, watersheds, etc.) if they would be eligible for any sort of waiver from the normal process.

I also think it falls heavily on private landowners to be proactive regarding protecting their property in advance. The magnitude of the problem and time scales involved necessitates that we look at the value at risk and target time and money there first. Houses aren’t being lost on federal land, so it seems more cost and time effective to spend money modifying the structures that are at risk than attempting to spend 6-10 years modifying fuels.

As for then106 issue, it seems like we have enough screens in that process that we could easily target money to non-106 eligible structures just based on build date alone. Maybe I don’t understand the requirements though.

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Originally Posted by ill-advised strategy

I mean…If we can’t do mitigation work because [whatever] needs to be “protected”, then fire rips through there and nukes a town, that town has pretty fucking good standing to lambaste whoever and whatever held up that mitigation.

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I think that if a fire rips through your town, you have some ownership over that as well. Now if you had a well implemented Firewise program, implemented all of the structural best practices, etc …

It’s sort of like saying “all of the houses in our town fell down during the earthquake” but not having a building code that requires consideration of seismic conditions while simultaneously knowing you are in a seismically active area.

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Originally Posted by ill-advised strategy

I mean…If we can’t do mitigation work because [whatever] needs to be “protected”, then fire rips through there and nukes a town, that town has pretty fucking good standing to lambaste whoever and whatever held up that mitigation.

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but the point seems to be that things that used to work well, like happy houses in the forest, don't work any more, and no amount of steel roofs or celar perimeter is going to fix that. It might feel good to point a finger at one small area affected by an obscure regulation, but just as people who buy houses in developments with covenants, you know what you're signing on to when you sign ze papers.

Lots of what FEMA does is indefensible: my neighbors lost their house to a flood, and FEMA gave them money to build a new one . . . with the stipulation it had to be on the same site, i.e. in the flood plain.

And I've put steel roofs on buildings almost certainly eligible for the National Register, and I've modified other structures in ways the land manager didn't like after the fact, and I've argued with a national overseer of historic reconstruction about the silliness of rules that want to trap buildings in amber instead of acknowledging that people would have adapted them over time based on new materials and influences.

At the same time, the intent of Section 106 is to mitigate, and generally it's the resource that gets 'mitigated' away. National Register is a bit different, as is historic reconstruction. Just as you can't mutate an elephant's genes so it will grow hair and call it a real wooly mammoth, you can't preserve an historic building by changing its major outer attributes (you can do pretty much what you like with most interiors, though).

There are plenty of people who know a lot more about this than I do. I'm just hearing a lot of arguments that favor throwing out the baby with the bath, or blaming a very small part of a very large picture for what it seems most are admitting is inevitable despite people's wishes it might be otherwise.

Probably do it all.

Burn, thin, firewise, all of it.

The nonsense stuff where you can’t thin because of a species that’s going to be fucked when it burns anyway, or can’t rx because it will smoke out a town that’s going to get smoked out when it burns anyway…can’t work in an area because it’s sacred to somebody but what’s it going to be when it’s a moonscape? All that drives me nuts.

My therapist helped me remember the unpleasant parts of my fire career, as a means of finding some relief of missing the good parts. All this bullshit wrangling about WUI and nimby over project work, and whole towns burning…yeah, you can have all that. I still miss cutting big snags, getting in the heli for an I.A….2 manners in the wilderness. I miss my buddies. But you can have all this shit with the politics and the lawyers and the media. Ugh. Puke.

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Originally Posted by old_newguy

Is the NEPA bottleneck an issue of staffing or is it more of an issue of the process?

Oregon and NOAA marine fisheries has a MOU and a manual for implementing storm water BMPs that works well compared to the more formal process. It seems like something along those lines could work to help move projects forward.

I think that the emergency mitigation actions we are talking about need to be extremely targeted around values at risk (WUI, watersheds, etc.) if they would be eligible for any sort of waiver from the normal process.

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The NEPA bottleneck is due to both staffing and process, in my experience. Our NEPA staff is completely overworked and needs to be doubled or tripled to really get things on track. Oregon has the Forest Practices Act that spells out BMPs and Fed forest projects use similar BMPs and project design features (PDFs), but I don't think they have as much to do with streamlining the NEPA process as they do individual projects. They provide a tiering mechanism for environmental reg. compliance. The real hang-up w/ NEPA is the litigation that all Fed projects are opened up to. The NEPA process, and compliance to, can be open to interpretation, and many times it is interpreted by courts in a way that was never intended. Are those interpretations correct or incorrect? Who knows? Seems to depend on what day it is. I do see that many, if not all, of the projects I work on are stalled for years while being litigated, or are eventually enjoined completely due to (mis?) interpretations of NEPA and other Acts by the courts. And this is after the projects are reviewed by internal solicitors.

This makes it very challenging, if not outright impossible, to actually do any real management. These days, no action is not viable management in the West. Forest fuels treatments have to be strategic and widespread, and they have to be implemented yesterday. There are a suite of tools that can be used to treat forests that still maintain a large percentage of big trees and habitat, etc. None of those tools are going to work if they can be implemented, and that fact wears on the folks that work to get these projects through the NEPA process. The folks that work in forest management at Fed agencies, in my experience, aren't looking to burn it all down, cut it all down, graze it or mine it into oblivion. Sure, there are holdouts with a different mindset from years ago, but the majority of folks would much rather spend their time in a woods with big trees and cool animals than a severely overstocked thicket, a monoculture plantation, a 3-year old clearcut, or a burned-out moonscape. These folks are knowledgeable and passionate about what they do, and they rely on the NEPA process for getting projects from the office to the forest. They live in and around the forests that they are supposed to be managing, and they want to do what is necessary and stay within the regs. They know how it is supposed to work and why it is important, and they choose to work in the Fed agencies because they want to see management strategies actually implemented for fear of losing it all.

That last paragraph is a bit of a rant/rave with a lot more that needs to be written, and is not directed at old_newguy. I left academia to work at actively putting solutions on the ground, and let's just say that things are not getting any easier. It can be very frustrating, at times, to have a bunch of wildland fire tools locked in the foil-wrapped shed, while the forest burns down around it.

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Originally Posted by ill-advised strategy

Probably do it all.

Burn, thin, firewise, all of it.

The nonsense stuff where you can’t thin because of a species that’s going to be fucked when it burns anyway, or can’t rx because it will smoke out a town that’s going to get smoked out when it burns anyway…can’t work in an area because it’s sacred to somebody but what’s it going to be when it’s a moonscape? All that drives me nuts.

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This.

I often wonder if EAJA was modified, how much more would actually get accomplished.

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Originally Posted by altasnob

I assume the shitheads you are referring to is Unite the Parks and their recent lawsuit against the Forest Service challenging the the conservation plan for the Southern Sierra Nevada Pacific fisher, which was listed as an endangered species in May 2020. The fisher's habitat includes Sierra, Sequoia, and Stanislaus National Forests.

Unite the Parks argument is that the Forest Service is using fisher population data from pre-2011 studies, and failed to obtain new data after the 2020 fire season, which substantially reduced the fisher habitat (and likely fisher population). The Forest Service did conduct a review of their already-approved projects after the 2020 fires, but did not modify any of the projects. Also, the review conducted after 2020 fires still relied on data from pre-2011 studies, and was therefore flawed, according to Unite the Parks.

Unite the Parks points out that Forest Service agrees that removal of large trees and structural elements through logging, hazard logging, logging roads, and other vegetation management activities decreases the quality of den and rest sites and/or increase travel distances between safe sites even if den or rest structures themselves are not removed and may expose fishers to predation from mountain lions, bobcats, and coyotes. However, at the same time, the Forest Service argues that logging and other vegetation management activities also create potential positive effects by increasing habitat heterogeneity and promoting tree clumps and gaps within a stand, thereby increasing the resilience of these stands (Unite the Parks says the Forest Service cites no scientific evidence to support this). The Forest Service concedes that these projects may result in short-term impacts to fisher (through habitat modification or noise disturbance) but because many of the proposed projects are intended to reduce fuels and the risk of high-severity fires the Forest Service expects that these short term impacts are outweighed by the long-term benefits of these projects (again, Unite the Parks contends the Forest Service lacks scientific evidence to support this conclusion).

Unite the Parks main argument is that if the Forest Service is going to make the above conclusions, they need to go out and obtain new data on the fishers and not rely on data and studies pre-2011 to base their conclusions. The fisher population and habitat pre-2011 was very different than the fisher population and habitat today.

https://forestpolicypub.com/2021/04/...isher-habitat/

Unite the Parks court pleadings can be found below. I can't find the Forest Service's reply pleadings anywhere free on the internet.

https://drive.google.com/drive/folde...bm8IXf3o7KlSEx

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This is exactly the stuff that keeps the work from getting done. FS does the study in 2011, proposes a plan, the plan gets held up by bureaucratic delay and opposition, when it's held up long enough the opposition says--you took to long, get another study. This is an emergency. The kind of obstructionism I would be in favor of if we were talking about mining for example, doesn't work here.

If the plan is to restore the forest to some semblance of the pre-Columbian forest (which was human altered I realize) isn't that the forest in which the endangered species originally thrived?

Not related to wildfire per se but when the Truckee Donner Land Trust bought Royal Gorge they inherited an unsafe dam. You should have heard the screaming about the environmental impact of removing a dam.

But the Sierra Nevada Pacific fisher wasn't listed as endangered until May 2020, so I assume the Forest Service wasn't doing the requisite studies because they didn't know they needed to until after that. I think the Plaintiff's point is you can't use outdated data to formulate plans for a species that is just listed as endangered, and particularly after the 2020 fires destroyed 14% of fisher habitat (don't quote me on that).

Judges don't write the laws, Congress does. And judges get stuck having to decipher ambiguous and poorly written language in statutes. I think your ire should be directed to Congress to streamline the process, not the court system or environmental groups (they only get paid if they win). In a perfect world, a country as wealthy as the US would have no problem adequately funding the Forest Service. But they don't and the Forest Service is left with unfunded mandates. But IMO, that's not the Sierra Nevada Pacific fisher's problem. Lawsuits are the only way to hold the government's feet to the fire and get them to do what they are directed to do. I say the same thing in other areas of law, like Public Records Act litigation. I would concede some environmental lawsuits are nothing more than an attempt to obstruct and delay. But these lawsuits offer some benefit, long term, because they allow the case law to be developed. Agencies rely on that case law for future planning.

What do you guys envision is a properly managed forest? Roads have an impact. Fire lines have an impact. Don't you need those things to do controlled burns? Shouldn't those controlled burns be as narrowly tailored as necessary? I live in a different part of the country, but the forests around me are all wilderness with a let it burn policy (and seem healthy). I'd hate for a Forest Service manager to unilaterally be able to do fire mitigation without anyone having the ability to challenge that decision.

In the western Sierra, R. Bates of uc merced claims something like 1/3 the biomass and half the trees would approx. pre-1849, which he views as ideal but as politically unachievable.

In California, a workaround for federal (or contractor) staffing shortages has been “stewardship agreements” to allow state or local agencies to plan and implement forest restoration projects on USFS lands. There are also shortages in rx burn people and California Registered Professional Foresters.

Regarding the fisher. My guess is that it was a “forest sensitive species” prior to federal listing. The USFS is supposed to evaluate the effects of its actions on those species before taking action.

I’m still of the opinion that there can be alternative methods to the standard NEPA process developed and implemented to mitigate/minimize environment effects before it all burns down or is more severely affected during suppression efforts. (Anybody see the picture of that dozer line near South Lake Tahoe?) In NEPA EA’s and EIS’s, the evaluation of the “no action” alternative is often an armwave, but it should be taken much more seriously.

Good lord. This is why they give shot crews an ad site away from the office.

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Originally Posted by altasnob

But the Sierra Nevada Pacific fisher wasn't listed as endangered until May 2020, so I assume the Forest Service wasn't doing the requisite studies because they didn't know they needed to until after that. I think the Plaintiff's point is you can't use outdated data to formulate plans for a species that is just listed as endangered, and particularly after the 2020 fires destroyed 14% of fisher habitat (don't quote me on that).

Judges don't write the laws, Congress does. And judges get stuck having to decipher ambiguous and poorly written language in statutes. I think your ire should be directed to Congress to streamline the process, not the court system or environmental groups (they only get paid if they win). In a perfect world, a country as wealthy as the US would have no problem adequately funding the Forest Service. But they don't and the Forest Service is left with unfunded mandates. But IMO, that's not the Sierra Nevada Pacific fisher's problem. Lawsuits are the only way to hold the government's feet to the fire and get them to do what they are directed to do. I say the same thing in other areas of law, like Public Records Act litigation. I would concede some environmental lawsuits are nothing more than an attempt to obstruct and delay. But these lawsuits offer some benefit, long term, because they allow the case law to be developed. Agencies rely on that case law for future planning.

What do you guys envision is a properly managed forest? Roads have an impact. Fire lines have an impact. Don't you need those things to do controlled burns? Shouldn't those controlled burns be as narrowly tailored as necessary? I live in a different part of the country, but the forests around me are all wilderness with a let it burn policy (and seem healthy). I'd hate for a Forest Service manager to unilaterally be able to do fire mitigation without anyone having the ability to challenge that decision.

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I am assuming based on past posts that you live in Tacoma. You are not describing the fire management policy on any USFS unit in the PNW I am aware of.

The fire regime for west side forests in the PNW is dramatically different than east of the crest in drier forests with short fire return intervals.

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Originally Posted by old_newguy

You are not describing the fire management policy on any USFS unit in the PNW I am aware of.

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That comment was from Oly National Park's website, "when a fire is determined to be of no threat to life or property, it is often allowed to burn naturally." But you are right, that is NPS, and not USFS (although there are USFS lands around the NPS land, not positive if they adopt the same policy as the NPS). Rainer NP has a similar policy if the fire is naturally started and is in a place the superintendent deems desirable to burn. But yes, Western WA is different than Eastern WA, and even Western OR.

Saw a fisher along the Truckee river a couple of years ago--between TC and River Ranch.

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Originally Posted by altasnob

That comment was from Oly National Park's website, "when a fire is determined to be of no threat to life or property, it is often allowed to burn naturally." But you are right, that is NPS, and not USFS (although there are USFS lands around the NPS land, not positive if they adopt the same policy as the NPS). Rainer NP has a similar policy if the fire is naturally started and is in a place the superintendent deems desirable to burn. But yes, Western WA is different than Eastern WA, and even Western OR.

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The Olympic NPs fire management plan is not a “let burn” policy document. It is way more nuanced than “we let fires burn in Oly NP.”

It has a range of options available to managers from full suppression to “let burn” depending on location, fire season severity, available resources, etc. Like most FM plans do.

In the context of this conversation using Oly. NP as an example of good looking forest with a “let burn” policy is a little odd considering it is basically a temperate rain forest aside from the rain shadow piece and burns on a much, much longer fire return interval than 90% of the places where we are having problems with fires in the west.

I wasn't advocating that a let it burn policy is practical in places like the Southern Sierra Nevada as it is substantially drier, decades of mismanagement by the Forest Service have created the adverse conditions we currently are presented with, and there are way too many fucking people living in, and near the woods in CA. I was just pointing out the forests around me appear healthy and I would never want the government to be able to unilaterally decide what to do with them without judicial recourse (whatever side of the spectrum you are on).

Schneider Springs fire this year just east of Rainier NP burned over 100,000 acres, making it a top 15 fire in WA history. No structures were lost. Not many structures were ever even threatened of being lost. The area doesn't have a shit ton of people who think it is a good idea to retire to that cabin in the woods, like in CA. There was some fire suppression, mainly on the far east perimeter as Yakima is just down the road. I understand there was some control burns and thinning done in dry, eastern part, in the years leading up to the fire. But a good portion of this fire was in wilderness, that has never seen any fire management as far as I know. I got the impression they essentially just let this fire burn. And I also get the impression that this natural, let it burn fire, was very good ecologically for the area. In short, this natural fire did exactly what we want with area and is what I would like to see happen, naturally, on other areas on the east side of the Cascades. It is not scorched earth but is set up to thrive in the years going forward (so long as the Forest Service doesn't do a bunch of salvage logging and lets the logs rot naturally). Ya, this is WA, and not CA. WA had a wet early June. And we had August rains to help control this fire. Every single forest is different.

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Originally Posted by old_newguy

The Olympic NPs fire management plan is not a “let burn” policy document. It is way more nuanced than “we let fires burn in Oly NP.”

It has a range of options available to managers from full suppression to “let burn” depending on location, fire season severity, available resources, etc. Like most FM plans do.

In the context of this conversation using Oly. NP as an example of good looking forest with a “let burn” policy is a little odd considering it is basically a temperate rain forest aside from the rain shadow piece and burns on a much, much longer fire return interval than 90% of the places where we are having problems with fires in the west.

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Also, rarely windy, even when rarely hot or dry. Also real, real long climbs from ground fuels to canopy. Also few values at risk. Also: uphill runs into alpine anywhere you start. Also: super difficult IA scenario most places in the park, access-wise with thick and very tall timber and gnar burly tanglefuck hike-outs interspersed with burly un-hikeable rivers.

Oly NF on the other hand has some fire issues with lots of slash units all over, and wui exposure here and there.

Source: I lived in Port Angeles immediately after my fire career ended and one of my best fire buddies was an eng cpt out of Hoodsport.

Side note. Unite the Parks, the group sueing the Forest Service over the fisher, main objective is to create the Range of Light National Monument
between Yosemite and Kings Canyon National Parks. Sounds great to me.

Attachment 387814

https://www.unitetheparks.org/our-projects