
Originally Posted by
bodywhomper
I could write a lot about this.... the example that old goat used was likely categorically excluded from NEPA. it definitely is below the threshold in acreage.
There was an article in Nature in 2020 that described that wildfire fuels reduction needs to occur on ~20M acres in California to reach a good ecological baseline and that there then needs to be active maintenance of that land after the initial treatment.
When there's an emergency or active WF suppression work, a lot of work is done on the ground with exemptions to the environmental regulations. There are SME's (e.g. archaeologists) that are coordinating and flagging sensitive resources for avoidance (if possible) but the work is not performed at the same level of scrutiny because of the emergency situation.
In California, the typical individual that opposed and halts larger wildfire mitigation projects on federal lands is Chad Hanson. He is often supported by a larger organization. For years it was the Sierra Club. Now it is the CBD. For a while, he was searching. He typically focuses on one or two NF's at a time. He halted many fuels reduction/thinning projects in Plumas (I believe) Tahoe, Eldorado, and Stanislaus NF's. He's now moved down to socal and seems to be focusing on Los Padres and Angeles. If you do a deep dive or have followed this, you will see that his MO and focus has evolved over the years. He gets a big mic sometimes with the NYT or WaPo. Most fire ecologist that I have met try to ignore him, but occasionally, there are some arguments in journals. There have been some specific projects that Hanson opposed using ESA, FSM/NEPA as the specific catalyst for challenging that have now burned down and the spp habitat is no longer present. Hanson has also challenged post WF recovery in the NF's (look up Starr Fire in Eldorado NF) in a manner that has resulted in no post fire recovery, the elimination of top soil, and habitat type conversion. Sierra Forest Legacy was another group, but they are now very supportive of wildfire fuel reductions and promote/organize groups like prescribed burn associations. The Nature Conservancy has now become n force pushing to green light large wildfire mitigation projects and gathering other enviro and community groups behind it in support. TNC is careful where they chose to focus their efforts because of Hanson and some groups that have aligned with him, like the chaparral institute.
After the Camp Fire, Newsom authorized something like $40M in wildfire mitigation projects to start immediately. He suspended all California enviro regulations for those projects. I'm not sure about how all those projects were implemented, but the one near me was in sensitive habitat (ultramorphic soils). Calfire coordinated with CNPS, local tribes, and a cultural resources organization to cruise the area together, to flag resources for avoidance and protection, flag the Rx, and coordinate resource protection and effectiveness of the Rx together on the ground. There was no CEQA compliance or other regulatory framework to guide that process. This is a similar process to what occurs during active wildfire suppression activities where archaeologist, foresters, or others that are qualified are flagging cultural resources for crews and dozers to avoid, if possible.
FEMA, as a policy, does not fund Rx burning for hazard mitigation projects, but they fund firing activities during wildfire suppression through their FMAG program. FEMA just announced phase 1 funding of a defensible space grant to Nevada County. Phase 2 involves getting individual property owners to sign-on to the project (they have to make a 25% match), then an Rx likely needs to be prepared for each property, each property must be evaluated for cultural resources, tribes must be consulted for each property, the SHPO must be consulted and concur with the effects analysis, a biologist has to evaluate the potential effects to federally-listed species and develop avoidance measures that the property owner must follow, the USFWS must be consulted with the evaluation of effects of the project on each property, and the USFWS must concur with the evaluation. FEMA can likely use a CE for its compliance with NEPA. I predict that the project will not be implemented anytime soon. FEMA prepared an EIS for a large fuels reduction in the SF East Bay Hills on UC, City of Oakland, and East Bay Regional Park District lands. Originally, FEMA's NEPA EA was challenged, which led to the EIS. It was also challenged, partially over the practices of the UC and partially related to ESA-listed species. The result was the FEMA will only fund the activities on the East Bay Regional Park District lands and the wildfire hazard will mostly go unmitigated on the UC and City lands. If that area burns with the modeled severity, the federally-listed species and their habitat will not survive.
A large area of the Sequoia NF that is currently burning that has not received any fuels mitigation treatment anytime recently has been in the planning/enviro compliance phase for over 6 years. Some of this overlaps the area that we are currently hearing in the news that people are most concerned about loosing some of the old growth trees because there's been no previous treatments. A lot of rough treatment has since occurred where WFF were able to prioritize as the wildfires approached.
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