To: David Peters, Project Manager
Herger-Feinstein QLG Forest Recovery Act Pilot Project
P.O.B. 11500
Quincy, CA 95971

The following are our scoping comments on the Notice of Intent for the Herger-Feinstein QLG Forest Recovery Act Pilot Project EIS. The majority of our comments deal with concerns related to fire and fuels management. Please put us on the mailing list to receive the Draft EIS and all other documents and notices relating to this project. Thank you for your consideration.

NEED TO INCORPORATE THE FEDERAL WILDLAND FIRE POLICY INTO THE EIS PROCESS

The Sierra-wide EIS Notice of Intent has recognized that the eventual Forest Plan Amendment must be consistent with the Federal Wildland Fire Policy. Alarmingly, however, the QLG has publicly stated that its plan is inconsistent with the Federal Wildland Fire Policy (see "A Quincy Library Group Response to S.1028: Outdated Policies that will Increase Fire Risk, Endanger Firefighters, and Harm Forest Ecosystems," posted on the QLG’s Web page). But it is not an option for the Forest Service to ignore, delay, or obstruct full implementation of the new Fire Policy. This would defy explicit direction from Secretary Dan Glickman and other top Forest Service officials--including the former Regional Forester, Lynn Sprague--who have made commitments to the public that the Fire Policy will be implemented in full. Consequently, no alternative in the QLG EIS should contradict or fail to fully incorporate the letter and spirit of the Federal Wildland Fire Policy.

Interagency partners, especially the National Park Service, are doing their share of implementing the Policy--the Forest Service is overdue in fulfilling its responsibilities to implement the Policy. The Forest Plan Amendment process is the precise time and vehicle for developing new fire management plans for all Forest Service lands subject to wildland fires. Thus, the QLG EIS should not miss this opportunity to develop a framework for each Forest to develop site-specific new plans (preferably at the subwatershed level based on current fuel hazards and fire risk assessments) for managing wildland fires.

The QLG EIS should disclose to the public specific, relevant items from the Federal Wildland Fire Management Policy and Program Review that pertain to the QLG fuelbreak strategy, for example, the Policy’s mandates to develop new fire management plans, the admission of the impracticality and unfeasibility of suppressing all wildfires, and the stated need to integrate fire as an essential ecosystem process. This need for public disclosure on the Fire Policy is one of the ways the agency can serve the educational mandates of the Fire Policy, and is a necessary investment for garnering public support for future fire and fuels management activities in the northern Sierras. The Forest Service must use the QLG EIS process as an opportunity to inform and educate the public about the Federal Wildland Fire Policy and incorporate the Policy in all relevant aspects of developing alternatives and decisionmaking.

NEED TO INCLUDE INTERAGENCY PARTNERS IN FIRE AND FUELS MANAGEMENT PLANNING

Remarkably, the National Park Service has been almost entirely excluded from the process of developing the QLG plan. Yet, in order to comply with the Federal Wildland Fire Policy, the Forest Service needs to fully incorporate interagency partners (especially adjoining federal landowners from the Department of Interior) in fire planning and fuels management. Thus, interagency cooperation should be incorporated early on in the development of EIS alternatives. The agency’s historic failures to work with interagency partners in planning is already leading to inconsistent and contradictory strategies for managing fire and fuels in the Sierras. For example, whereas Lassen Volcanic National Park has been using prescribed understory burning for the last 15 years to create Fuels Reduction Zones along its borders, the QLG proposes to use commercial logging on Lassen National Forest to create quarter-mile wide defensible fuel profile zones to encircle Lassen Park's boundaries. Some of these new DFPZs will be located just a few hundred feet away from the Park’s existing FRZs! This will not only duplicate the Park's hazard fuel reduction work (at far greater economic and environmental costs), but the inherent fire exclusion goals behind the QLG's fuelbreak strategy is inconsistent with the Park Service's fire use strategy. Furthermore, it will needlessly fragment the landscape between the Park and the Forest, at a huge expense to wildlife and taxpayers.

This is but a single example of the folly inherent in failing to work closely with interagency partners, a flawed "turf" competition meant to be changed by the Federal Wildland Fire Policy. The Forest Service needs to become "more transparent" (Sierra Nevada Framework Draft Design Paper) in its fire management strategies and actions with its interagency partners as well as the public, and include input early on from NPS and BLM fire managers in the development of alternatives in the QLG EIS. Up-front cooperation in planning (beginning with the QLG pilot project) is the best means for bringing greater consistency in fire and fuels management in the northern Sierra Nevada.

NEED TO DISCLOSE THE DIRECT, INDIRECT, AND CUMULATIVE EFFECTS OF FIRE EXCLUSION

The Federal Fire Management Policy mandates that NEPA analyses disclose the effects of wildfire, prescribed fire, and fire exclusion. The QLG fuelbreak strategy is inherently tiered to fire exclusion. Therefore, considering all of the known adverse ecological effects of excluding fire from the landscape, the EIS needs to analyze and disclose the effects of fire exclusion on biodiversity (especially fire-dependent vegetation and wildlife, soil fertility, and watershed stability. In particular, the IDT should check with Bill Leenhouts of USFWS, working out of the National Interagency Fire Center in Boise, for the current list of fire-dependent/fire-adapted species at risk due to fire exclusion.

Additionally, the decision to spend money and resources on constructing and maintaining fuelbreaks will likely detract from efforts to reintroduce landscape-scale prescribed understory burning. Therefore, the QLG EIS also needs to analyze and disclose the effects of continued fire exclusion on future fuels accumulations, anticipated wildfire behavior and effects, and wildfire suppression costs in the landscape blocks between fuelbreaks.

NEED TO ANALYZE AND DISCLOSE DIRECT, INDIRECT, AND CUMULATIVE EFFECTS OF FUTURE FIRE SUPPRESSION ACTIVITIES

The very purpose of fuelbreaks is to facilitate aggressive fire suppression actions within and adjacent to fuelbreaks. Indeed, the SNEP Report as well as numerous Forest Service NEPA documents for other fuelbreak-oriented timber sales have disclosed the fact that fuelbreaks alone will not help contain or control wildfires, but require fire suppression actions to take advantage of the fuelbreaks. Consequently, the QLG EIS must analyze and disclose the direct, indirect, and cumulative effects of fire suppression activities within and adjacent to fuelbreaks.

The environmental effects of fire suppression activities are significant and will cause additional impacts to fuelbreak sites. Some of these activities/effects include: felling of wildlife habitat trees, especially snags; dumping of chemical retardants and fuel in streams and soil; soil disturbance and erosion from handlines and dozerlines; sedimentation into streams; wildlife disturbance from motorized vehicles, helicopters, and chainsaws; homogenized fire effects from burnout operations; severe fire effects from backfire operations; scenic impacts from dozerlines and stumps; alteration of natural fire processes from fire suppression. There may be additional actions and effects which require analysis and disclosure, too.

The Forest Service cannot claim that fire suppression is an action that cannot be predicted, and cannot be analyzed in a NEPA document. On the contrary, fire suppression is part of an annual administratively planned and funded management program. Fire suppression actions are especially anticipated and intended to occur within and adjacent to fuelbreaks, and may add to the impacts of fuelbreak construction. For example, retaining a minimum of wildlife snags within fuelbreaks may result in zero snags within portions of fuelbreaks if and when they are felled during a suppression incident. Also, soil disturbance to fell and skid logs may be exacerbated if and when dozers construct firelines during a suppression incident. Consequently, the QLG EIS needs to analyze the direct, indirect, and cumulative effects of fire suppression actions within fuelbreaks in order for the public and decisionmakers to adequately assess the environmental consequences of a fuelbreak-based, suppression-oriented fire management strategy.

NEED TO SPECIFY THAT A "COST-EFFECTIVE" FUELS MANAGEMENT PROGRAM IS ONE THAT HAS THE LEAST NET EXPENDITURES TO TAXPAYERS, NOT SIMPLY GENERATES THE MOST GROSS REVENUES TO FEDERAL BUREAUCRACIES, AND DOES NOT EXTERNALIZE COSTS TO THE ECOSYSTEM OR FUTURE GENERATIONS

The Herger-Feinstein Act and the Notice of Intent for the QLG EIS mandate that the pilot project use the most cost-effective means available to construct fuelbreaks. Unfortunately, past Forest Service NEPA analyses have traditionally been skewed in favor of commercial logging under the flawed assumption that timber revenues defray some or all of the costs of fuels management. On the contrary, the TSPIRS Report has finally revealed that the commercial timber program is a net money loser. Moreover, the net effects of commercial logging results in externalized costs to the ecosystem and future generations because timber extraction reduces the value of non-commodity resources (e.g. biodiversity, water quality, etc.) and subsequently raises the overall costs of future ecosystem restoration.

The QLG EIS should honestly compare the total, net cost differences between prescribed burning, mechanical treatments, and commercial logging for constructing fuelbreaks and accomplishing fire and fuels management over the short- and long-term. The SNEP Report stated that in the Sierras prescribed burning has the lowest net costs per acre compared to other fuels treatment methods (and compared to wildfire suppression). Mechanical treatments and commercial logging have higher costs per acre, and cause other adverse resource and environmental impacts that add to overall future restoration costs. Furthermore, the chip market undergoes extreme fluctuations, and at times the market demand collapses and greatly drives up the costs of extractive "biomass" treatments. Therefore, the QLG EIS needs to deliver a full and honest accounting of what constitutes the most "cost-effective" and environmentally-sound method for reducing hazardous fuels and constructing and maintaining fuelbreaks.

NEED TO DESIGN ALTERNATIVE(S) THAT REDUCE HAZARDOUS SURFACE AND LADDER FUELS WITHOUT EXTRACTING TREES ABOVE 11 INCHES DBH

In similar "thinning" and fuelbreak timber sale projects, Forest Service line officers tend to focus their purpose and needs on reducing crown fire hazard rather than reducing crown fire risk because manipulating canopy fuels is more amenable to getting the timber cut out. Such analyses fail to disclose to the public the fact that independent crown fires are extremely rare and short-lived events. The QLG EIS needs to disclose these facts. Also, when the agency uses commercial logging, it does not remove canopy fuels, but essentially dumps them on the ground in the form of slash where they are available to burn in the most common, prolonged fire scenarios; thus, greatly increasing the fire risks and fuel hazards in the short-term. The QLG EIS needs to disclose these facts, too. Forest Service rhetoric about the use of commercial logging as a fuels reduction "tool" rather than a goal in itself rings hollow when the agency systematically ignores other methods for reducing wildfire risks and hazards at far less cost to taxpayers and ecosystems. Indeed, the agency’s sudden interest in "fuels reduction" through the use of commercial logging seems disingenuous and opportunistic, and does not engender must trust in the agency among conservationists and the environmentally aware public. The Forest Service should not attempt to use the QLG pilot project for yet another timber "scam," even if that is the real motivation behind the QLG and its Congressional supporters.

The best available science on the topic of crown fire initiation and propagation (Agee, 1996; Agee et.al., 1998) reveals that surface fuel load and ground-to-crown base height are the two primary variables accounting for the initiation of crown fires. These surface and ladder fuels can effectively be reduced through manual and prescribed fire treatments without the need for commercial timber extraction, which would only remove large boles (the least flammable above-ground part of a tree). For example, van Wagtendonk's (1996) paper in the SNEP Report revealed that prescribed burning alone had the greatest impact on reducing fire spread and intensity compared to any other fuels treatment method. Thus, the QLG EIS should include alternatives(s) that involve pruning of understory limbs, non-commercial thinning of understory saplings and poles, handpiling and burning, and understory broadcast burning without commercial logging or extraction of trees greater than 11 inches DBH. Trees 11 inches DBH is the maximum size of tree to be extracted by any method because according to the CASPO Report trees under 11 inches DBH have little or no use to spotted owls. Also these small understory trees would most likely succumb to mortality effects from prescribed fires. Trees with sizes greater than 11 inches DBH would be of potential habitat value to spotted owls, and would likely survive prescribed fires (depending on the prescription, of course).

Treatments that raise up the crown height rather than reduce crown cover would help reduce the risk of crown fires and create fire resilient stands. Retention of canopy cover would help retain surface fuel moistures, retard wind speed, reduce surface temperatures, and maintain a microclimatic that reduces surface fire intensity. Alternatives that reduce surface and understory ladder fuels, rather than remove commercial timber and overstory components, would also help maintain the values of closed-canopy forests for wildlife, water quality, and recreation. Hence, the QLG EIS needs to develop at least one alternative that does not commercially extract live trees above 11 inches DBH, and uses alternative prescribed fire and manual methods for hazard fuel reduction.

NEED TO COMPARE STRATEGIES OF LINEAR FUELBREAKS VERSUS AREA-WIDE PRESCRIBED BURNING FOR EFFECTS ON FIRE SUPPRESSION OPTIONS

The use of fuelbreaks for fire suppression is inherently tied to an indirect attack fire suppression strategy. This forces firefighters to either wait for wildfires to approach fuelbreaks, or to light backfires during extreme fire conditions. This strategy thus tends to "sacrifice" greater amounts of acreage in order to use fuelbreaks as predetermined fire control lines, resulting in larger-sized wildfires and more severe fire effects.

The QLG plan would build fuelbreaks while deferring fuels treatments in the landscape blocks between fuelbreaks until after the so-called pilot project is over (approximately five years from now). Given current fuel conditions, it may be unsafe to stage initial or extended attack fire suppression activities within these untreated landscape blocks. Analysis of the QLG fuelbreak strategy needs to calculate estimated size and severity of wildfires in landscape blocks between fuelbreaks under the assumption that fire suppression actions would predominantly be staged inside fuelbreaks.

The QLG EIS should analyze the effects on wildfire size and severity by comparing linear fuelbreak alternatives with alternative(s) proposing area-wide fuels reduction treatments, preferably with prescribed fire. Such area treatments would more closely mimic natural mosaics, and provide more options for initial and extended attack fire suppression to construct firelines that link various units of reduced fuels. The IDT should consult with Mark Finney, creator of FARSITE, who has done some of this analysis comparing the two different strategies, and then disclose this information in the EIS. Also, van Wagtendonk’s (1996) paper in SNEP reported the effects of area-wide prescribed burning--in all but the most extreme fire weather situations (95th percentile) wildfires burning through previously prescribed-burned areas failed to reach the locations of DFPZs at all! These analyses should be disclosed in the QLG EIS.

NEED TO DESIGN ALTERNATIVE(S) THAT CONSTRUCT FUELBREAKS WITH PRESCRIBED BURNING INSTEAD OF COMMERCIAL LOGGING

The QLG plan began as an effort to gain access to federal timber, not fight wildfires. The evolution of the QLG "fire protection" strategy was an opportunistic, post hoc rationalization to supplement the QLG’s primary objective in gaining access to federal timber. Consequently, the QLG has focused on the use of commercial logging and extractive mechanical treatments to construct fuelbreaks while refusing to consider the possibility of using alternative non-extractive methods such as prescribed fire and non-extractive manual treatments.

Both the Herger-Feinstein Quincy Library Group Forest Recovery Act and the Notice of Intent for the QLG EIS discuss the possibility of using "other methods of vegetation management" for fuelbreak construction. These "other methods" must be "consistent with the Quincy Library Group Community Stability Proposal." In fact, the 1993 QLG Community Stability Proposal's discussion of fire and fuels management is extremely sparse, and does not even mention the terms "fuelbreak" or "defensible fuels profile zone"! Instead, the QLG Proposal simply says to carry out the fire and fuels management objectives recommended in CASPO. However, the CASPO Report also did not discuss the use of defensible fuel profile zones, nor required the use of commercial logging for managing fire or fuels--just the opposite!

Instead, in the Fire and Fuels Management chapter of the CASPO Report, the fire specialists clearly and explicitly gave recommendations to prioritize the use of prescribed fire rather than commercial logging for managing fire and fuels. Indeed, the CASPO fire team recommended using "a band of prescribed burns" to "disrupt fuel continuity"--i.e. using prescribed fire to construct fuelbreaks (Chapter 12, page 254). The QLG's assumption that only commercial logging is acceptable for fuelbreak construction is not born out by letter of the CASPO Report, the QLG’s original Proposal, or the Herger-Feinstein Act. Indeed, prescribed burning with manual pretreatments can and should be accepted as "other methods of vegetation management" for fuelbreak construction.

The specific language of the QLG Proposal and the QLG Act, coupled with the CASPO fire team's clear priority of using prescribed underburning to create de facto fuelbreaks, enables the Forest Service to use its discretion to develop an alternative(s) that uses prescribed fire as the exclusive or primary method for constructing (as well as maintaining) fuelbreaks. To exclude a prescribed fire-only alternative when it actually conforms to the letter of the 1992 CASPO Report and the 1993 QLG Community Stability Proposal would be arbitrary and capricious, and would put the EIS at legal jeopardy for failure to provide an adequate range of alternatives. Therefore, the Forest Service should design one or more alternatives that uses prescribed fire and related non-commodity extractive manual treatments as the primary method for constructing and maintaining fuelbreaks.

NEED TO DESIGN ALTERNATIVE(S) USING FUELBREAKS FOR PRESCRIBED BURNING FOR THE PURPOSE OF FIRE REINTRODUCTION RATHER THAN (OR IN ADDITION TO) FIRE SUPPRESSION

One of the main implications of the Federal Fire Management Policy is a fundamental change in strategy: wildfire protection would result from proactive restoration of fire processes rather than continued reactive wildfire suppression and fire exclusion. Accordingly, the QLG EIS needs to include an alternative with an entirely different objective: use of fuelbreaks as means for proactively using prescribed fire (or managing wildland fires for resource benefits, formerly called Prescribed Natural Fires) to apply prescribed fires across large landscape blocks. These kind of "fire-use" fuelbreaks could also potentially serve as containment lines in the event of wildfires, if necessary, but their primary purpose would be to prepare units for the reintroduction of prescribed fire into large landscape blocks.

The use of fuelbreaks for managing prescribed and wildland fire (as opposed to simply suppressing wildfire) must be the explicit primary purpose of fuelbreaks in a fire restoration-oriented alternative. The agency should not simply "bootstrap" prescribed burning as a secondary or future goal for fuelbreaks on top of their traditional, primary purpose for wildfire suppression. Given the agency's anti-fire history and most managers' aversion to the risks involved in prescribed burning, the public could never trust agency managers to fulfill promises to use fuelbreaks for fire reintroduction. Instead, a fire restoration alternative should be designed that uses fuelbreaks for prescribed fire management as their primary purpose, with wildfire suppression as an additional or secondary purpose. The ultimate goal of this fuelbreak-based fire restoration alternative should be to reduce the number of wildfire suppression incidents and increase the number of prescribed natural fire events.

NEED TO INCLUDE MANUAL TREATMENTS AS A PART OF PRESCRIBED FIRE TREATMENTS AND DISTINGUISH THEM FROM MECHANICAL TREATMENTS

The Forest Service sometimes overgeneralizes the concept of mechanical treatments to lump together hand-held chainsaws with fellerbunchers. (We have even seen managers portray the use of goats as a "mechanical" fuels treatment!) There is a qualitative difference in financial costs and environmental effects between chainsaws and other hand-held machines versus fellerbunchers, bulldozers, and similar machines running on wheels or tracks. The EIS needs to make an analytical distinction between manual and mechanical treatments.

In our opinion, there is much wisdom in planning the use of manual treatments to prepare sites for prescribed burning. Such manual treatments like non-commercial thinning, hand-piling, raking, pruning, brushing, etc. may be necessary or desirable to help construct containment lines or rearrange fuels for safe and effective prescribed burning. The EIS analysis should include these manual methods as part of prescribed fire treatments, and determine how they may or may not affect the costs and risks of prescribed burning. We are particularly interested in the estimated number of jobs for woodsworkers involved with manual versus mechanical treatments. The QLG EIS should not arbitrarily exclude manual treatments from prescribed burning treatments as a means of increasing the risks or adverse effects of burning (a common ploy by Forest Service managers opposed to burning and attempting to make silvicultural treatments look better by comparison), nor should the analysis lump manual treatments together with "mechanical" treatments that utilize heavy motorized equipment.

NEED TO FULLY ANALYZE AND DISCLOSE THE AREAS WHERE MECHANICAL TREATMENTS WOULD BE TECHNICALLY IMPOSSIBLE

Harvesters and other similar extractive machines are technically impossible (without completely destroying the ground surface) on certain kinds of rocky or wet terrain, steep slope gradients, or other sensitive sites. The QLG EIS cannot simply provide a small-scale map showing vast areas "available for mechanical treatments" (similar to the QLG map showing areas "available for group selection") when, in fact, mechanical treatments would be impossible within such areas due to technical, economic, or ecological factors. Indeed, the QLG EIS needs to provide rigorous site-specific analysis of the potential adverse impacts to wildlife, vegetation, soils, and streams from certain kinds of mechanical treatments, and disclose the areas where the use of mechanical treatments would be prohibited.

NEED TO INCLUDE THE BEST AVAILABLE FIRE SIMULATION MODELS IN ASSESSING CURRENT FIRE RISKS AND/OR FIRE BEHAVIOR PREDICTIONS OF VARIOUS FUELS TREATMENT ALTERNATIVES

The Forest Service continues to use inappropriate or archaic computer models for analyzing fuel models and predicting fire behavior. Specifically, the agency inappropriately uses the BEHAVE program to assess crown fire risk for many of its proposed timber sale projects, yet BEHAVE cannot make any predictions beyond the dynamics of surface fires burning through fine fuels. There are a number of newer, better models available (e.g. FOFEM, FARSITE, NEXUS), and the agency should take advantage of the analytical superiority of these models, especially FARSITE and NEXUS, in its analysis of fire risk assessments and effects of fuels treatment alternatives. The use of the "best available science" (including computerized fire simulation models) is yet another mandate of the Federal Fire Management Policy, and the agency needs to implement this part of the Policy in the QLG EIS.

NEED TO OFFER A RANGE OF ALTERNATIVES FOR CROWN FUEL REDUCTION LEVELS

The QLG arbitrarily calls for reduction of crown cover of 30% or 40% or even lower within their so-called "shaded" fuelbreaks. Analysis using FARSITE would model this as an "open stand" essentially having the same surface wind dynamics as a clearcut. On the other hand, in their simulation of fire effects in the SNEP Report, Sessions, et.al. (1996) assumed that "a fire that kills more than 60% of the basal area in a stand destroys the stand." The QLG EIS needs to explain to the public what exactly is the QLG fuelbreak strategy protecting when, by design, the effects of logging mimic the effects of severe wildfires. The QLG EIS thus needs to disclose the effects on habitat quality from DFPZs reducing canopy cover and/or basal area to 40% or below.

If canopy cover or crown fuel reduction will be part of the fuels treatment prescriptions for the pilot project, then the agency needs to offer a wider range alternatives; for example, crown cover retentions of 60% and 80%. Such analysis using FARSITE and/or NEXUS should focus on whether greater amounts of canopy cover in fuelbreaks reduces the risk of crown fire (through shading surface fine fuels from direct solar radiation and winds, retaining greater moisture and relative humidity, etc.) sufficiently to mitigate the hazard of higher crown fuel densities.

NEED TO OFFER A RANGE OF ALTERNATIVES FOR DFPZ WIDTHS, DEPENDENT ON LOCATIONS AND SITE-SPECIFIC CONDITIONS

The selection of quarter-mile widths for Defensible Fuels Profile Zones was somewhat of an arbitrary choice by SNEP scientists. A quarter-mile increment was the minimum size that could be run with their computer program, and was requested by non-fire resource specialists who need to analyze the effects of logging DFPZs on their given resources. Since then, the QLG has used the quarter-mile increment as if it was a sacred or "scientific" figure. It is neither. The QLG EIS should offer a range of different widths for DFPZs in order to better assess the tradeoffs between the adverse effects on natural resources (e.g. wildlife habitat, water quality, scenic beauty) versus alleged beneficial effects on fire suppression capability.

In its own internal analysis for the "Forest Ecosystem Restoration and Protection Project," the Lassen National Forest has worked some initial analyses for varying widths of DFPZs. To be fair, this wider range of alternatives should analyze the effects on resources and fire behavior from DFPZs that are both narrower and wider than a quarter-mile; however, we caution the agency from arbitrarily selecting a uniform prescription for width of DFPZs. Instead, each segment of a DFPZ should be tailored to site-specific conditions, such as existing fuels profile, topographic features, position on slope, aspect, and local fire history. The call by SNEP scientists to "feather" DFPZs into the surrounding forest landscape may thus be interpreted as an invitation to vary widths of DFPZs depending on their specific location and site conditions.

NEED TO ANALYZE AND DISCLOSE EXISTING CONDITIONS OF ROADS USED FOR DFPZs

The QLG has insisted that DFPZs be located adjacent to existing roads. This is under the false impression that these roads will make DFPZs "safer" for firefighting personnel because they offer the hope of speedy emergency evacuations. The QLG EIS needs to disclose the existing conditions of roads located near DFPZs, not simply display a map of these roads. Considering the fact that the agency has a huge backlog of maintenance needs for its existing road system, we believe that some of the roads to be used for DFPZs may not be suitable in their current condition for a convoy of school buses to make safe emergency evacuations of firefighters. Moreover, many of the existing forest roads were designed to access timber stands, not necessarily aid fire suppression. We are particularly concerned about the utility of DFPZs located along mid-slope roads on steep gradients, or run perpendicular to ridgelines. These locations seems very precarious for firefighter safety. We would urge that DFPZs not be located in these areas, but instead, be located either in valley bottoms or ridgetops where they offer slim but some hope of efficacy for fire control efforts. Indeed, Weatherspoon and Skinner (1996) in their paper in the SNEP Report suggested that DFPZs be located first in the upper third of slopes in areas of lighter fuels in order to "get the most bang for the buck" in terms of wildfire protection. This location may not yield the kind of timber volume that the QLG seeks, but it might offer a more practical approach to fuels management that would reduce the costs to taxpayers.

NEED TO ANALYZE EFFECTS OF POTENTIAL ILLEGAL ACTIVITIES WITHIN DFPZs

According to the preliminary analysis of the Lassen National Forest’s "Forest Ecosystem Restoration and Protection Project," the construction of roadside DFPZs will greater increase the existing detrimental effects of roads on wildlife populations and water quality. These effects need to be analyzed and disclosed in the QLG EIS. The Lassen’s analysis also disclosed that DFPZs would like serve as conduits for illegal activities associated with forest roads. Some of these illegal activities include: poaching and wildlife harassment, timber theft, littering and garbage dumping, arson, and accidental human-caused wildfires. The agency cannot claim that such illegal activities cannot be predicted; indeed, in Oregon a Federal Magistrate ruled against the Forest Service in its claim that it could not analyze in an EIS the effects salvage logging an arson-burned spotted owl habitat conservation area on encouraging future arson fires in similar areas. Consequently, the effects of these potential road-based criminal activities occurring within DFPZs also need to be analyzed and disclosed in the QLG EIS.

NEED TO PRIORITIZE DFPZs IN THE WILDLAND/URBAN INTERFACE ZONE

The QLG map of areas "available for group selection" should not be construed as the same base area for DFPZs. Indeed, carving the wildlands of the northern Sierra Nevada with DFPZs will not address the concerns of local communities or members of Congress who want to limit the threat of wildfires on lives and property. The QLG EIS should prioritize this pilot project as a means of addressing the wildfire hazards of the wildland/urban interface, not just another means of "getting the timber cut out" of the remote hinterlands.

The concern that DFPZs are being used to fragment wildlands while avoiding rural communities is justified by analysis of the map of the Quincy Library Group and Technical Fuels Report, published by VESTRA Resources, Inc. in August, 1997. On the one hand, DFPZs encircle Lassen Volcanic National Park, cut across QLG "off base" areas proposed for wilderness additions, run through QLG "deferred" areas of special botanical concern, run right up to the borders of existing designated Wilderness Areas, and there is even a DFPZ squeezed into the narrow corridor between Highway 89 and Lake Almanor! Are we to assume that the purpose of this last DFPZ is to protect the lakebed from burning?

On the other hand, there are no DFPZs located within five miles of the communities of Beckworth, Westwood, Sierra City, Downieville, or Belden; no DFPZs within four miles from the community of Keddie or three miles from the communities of Portola, Blairsden, and Chester; there are no DFPZs at all protecting the communities of Paradise or Forest Ranch; and even the town of Quincy has no DFPZs within 15 miles north and east of the highway! Are we to assume that no wildfires burn in the area north of town? (the large burned areas show evidence to the contrary).

We are concerned that DFPZs are located only on public lands, while on private lands owned mostly by timber corporations, there are no DFPZs. Considering the fact that Sierra Pacific Industries was a major part of the QLG and will be a major bidder on the federal timber sales to come out of the QLG pilot project, we think it is unfair that public lands and taxpayers must bear the burden of providing wildfire protection for local communities when their "good corporate neighbors" like Sierra Pacific Industries are not doing their share by cutting DFPZs on their own lands. Indeed, we question the suppression efficacy of some of these DFPZs that end abruptly at the border of private/corporate timberlands.

The QLG EIS should not simply become yet another corporate welfare program offering subsidized timber sales under the false claim of offering wildfire protection. Instead, if any good is to be "salvaged" out of this pilot project, then it must come out of performing strategic fuels reduction in the wildland/urban interface zone. Thus, the QLG EIS must prioritize and focus the locations of DFPZs in the wildland/urban interface zone, not plow them throughout the remote wildlands as indicated on the QLG/TFR map (bought and paid for by Sierra Pacific Industries).

NEED TO SPECIFY HOW TREATMENT OF ACTIVITY FUELS (A.K.A. "SLASH") WILL BE IMPLEMENTED, FUNDED, AND GUARANTEED

As Weatherspoon (1996) revealed in the SNEP Report, the Forest Service has an extensive backlog of untreated logging slash from old timber sales. Fire hazards actually increase dramatically in the first 3-5 years following logging due to slash accumulations. Research in the dry forests of the Blue Mountains of eastern Oregon and Washington (Huff, et.al., 1995) reveals that slash can affect fire behavior for up to 30 years. Slash in the dry forests of the Sierras will likely have the same dynamics and effects. Some of the agency's preferred methods for slash "treatment," e.g. compaction via running over it with heavy machinery, do not significantly reduce flammability, especially in dry pine stands. Other methods, e.g. machine piling, create significant adverse effects on soil fertility. Unfortunately, specific methods, costs, and long-term funding sources for treating slash are rarely fully analyzed or disclosed in Forest Service NEPA documents. And slash treatment is often presented as a "mitigation measure" for commercial logging, when in fact, the agency’s preferred methods for slash treatment need their own mitigation since they cause significant effects. The QLG EIS needs to analyze and disclose this data on slash treatment for alternatives using commercial logging.

NEED TO SPECIFY HOW FUELBREAK MAINTENANCE WILL BE IMPLEMENTED, FUNDED, AND GUARANTEED OVER THE LONG-TERM

The great failure of all previous fuelbreak programs has been the agency’s inability or unwillingness to monitor and maintain fuelbreaks. Without periodic maintenance to control in-growth of tree saplings or colonization by brush, the effects of fuelbreaks on fire risks and fuel hazards can be negated--and in some cases, worsened! This is especially true in the Sierras where closed canopy forests are typically invaded by more hazardous vegetation types (e.g. manzanita chaparral) following logging disturbances. Thus, fuelbreak maintenance is a necessary, essential part of constructing fuelbreaks. Accordingly, the agency needs to disclose to the public the methods it intends to use to control vegetation from growing over fuelbreak sites. Mechanical treatments using dozers, chemical treatments with herbicides, and prescribed fire treatments all vary tremendously in their economic costs and effects on wildlife, soil, and water resources. The QLG EIS needs to fully disclose the costs and effects of fuelbreak maintenance.
Economic factors and historical experience cause much doubt that the Forest Service will be able to maintain the estimated 1,500 linear miles of fuelbreaks constructed by the pilot project. First, the two earlier periods where extensive fuelbreak systems were constructed (1930s and 1950s) were able to use abundant cheap labor supplies: workers from the Civilian Conservation Corps and convicts from the California penitentiary system. These labor sources are no longer available in sufficient quantities to construct or maintain fuelbreaks. Secondly, once commodity timber resources have been extracted from fuelbreak sites, the Forest Service loses interest in managing fuelbreaks. Maintenance costs become pure expenses funded from appropriated dollars since there are no means of generating revenues from commodity outputs on cutover fuelbreak sites. The historical experience is thus replete with examples of fuelbreaks that, once the timber cut has come out or the subsidized jobs program is over, the fuelbreaks become revegetated and lose their effectiveness for fire suppression. Most alarming, the 1997 Federal Advisory Committee reviewing the "Cal Owl RDEIS" faulted the RDEIS for the assumption that once DFPZs were cut the agency did not plan to maintain them!
The QLG EIS needs to include both long-term maintenance costs as well as short-term construction costs for assessing the overall economic effects of the fuelbreak program, and disclose this date in the EIS. Also, some kind of risk analysis needs to be tried to disclose the effects on fire and fuels if, as has occurred everywhere else with Forest Service fuelbreak programs, the agency fails to monitor and maintain fuelbreaks.

NEED TO ANALYZE EFFECTS OF FUELBREAKS ON FIRE BEHAVIOR USING WORST-CASE SCENARIOS

Commercial logging for fuelbreak construction will likely cause significant adverse effects on the ecosystem. Despite the claims of the QLG that its fuelbreaks will provide "solutions" to wildfires, some of these adverse effects may actually enhance fire risks and fuel hazards depending on how the pilot project is designed and implemented. The EIS needs to analyze the potential effects on fire intensity, severity, rate of spread, risk of ignition, and safety hazards to wildland firefighters from the following potential effects associated with fuelbreak construction:
--increased ignition potential from the use of commercial logging equipment.
--increased ignition potential from careless recreationists and criminal arsonists using fuelbreaks for access.
--altered microclimatic conditions, particularly changes in surface fuel moistures, surface wind speeds and variability, and surface temperatures from reduction of overstory canopies.
--increased fuel loading and flammability from logging slash.
--increased fire intensity and severity from use of fuelbreaks for lighting backfires during extreme fire weather conditions.
--changes in fire spread rates and fireline intensities from converting closed-canopy timber models to open-canopy grass/brush fuel models.
--vegetation succession dynamics in fuelbreaks with and without regular maintenance (i.e. conversion from timber to grass/brush vegetation, especially chaparral), and effects of vegetation change on potential flammability.
--estimated time of responses for initial attack firefighting personnel compared to predicted fire spread rates (i.e. see van Wagtendonk's paper in the SNEP Report which questions the ability of fire crews to make effective use of remote fuelbreaks before wildfire breaches the fuelbreaks).
--estimated time for safe retreat for extended attack firefighting personnel given the existing conditions of poorly-maintained forest roads.
Again, the QLG EIS must utilize "worst-case scenarios" for analyzing the potential impacts of the pilot project, including the impacts and scenarios listed above.

NEED TO BALANCE LOCAL WITH REGIONAL AND NATIONAL INTERESTS, AND COLLABORATE WITH WILDLAND FIRE PROFESSIONALS

The EIS needs to disclose the fact that the Plumas, Lassen, and Tahoe are National Forests, not local fiefdoms for Sierra Pacific Industries, special interest groups like the QLG, or local communities. Citizens in New Jersey, for example, have as much ownership rights over National Forests in the northern Sierra Nevada as do local communities. In fact, taxpayers from across the country will be paying for implementation of the QLG pilot project (especially its subsidized timber extraction program) and yet the vast majority of the populace receive no benefits in terms of jobs, resources, or amenities compared to citizens living in local communities. Consequently, the QLG EIS process should expand its outreach, information, and participation processes to include the broader regional and national publics.

The need to expand the scope of outreach is especially critical to wildland firefighters who may be dispatched from anyplace in the country to suppress wildfires in California. Wildland firefighters are "stakeholders" with perhaps the most at stake--their very lives, health, and safety--in seeing that the Forest Service implements proper fire and fuels management programs in the Sierras. Thus, the Forest Service should devise an outreach strategy and the EIS should disclose how the agency intends to "collaborate" with these broader publics and stakeholders, especially wildland fire professionals, who do not necessarily live in communities within the pilot project area.

NEED TO FULLY ASSESS THE IMPACTS OF "PAST" MANAGEMENT ACTIVITIES AND EXPLAIN HOW THE USES OR EFFECTS OF THESE CONTINUED ACTIVITIES WILL BE QUALITATIVELY DIFFERENT IN THE FUTURE

The SNEP Report is full of references to the adverse ecological effects of so-called "past" timber extraction and fire suppression. In the QLG EIS chapter on existing conditions, only a full and honest assessment of the impacts of "past" resource extraction and fire suppression activities will satisfy NEPA and the public’s right-to-know. Assuming that these so-called "past" management activities will continue into the future, then the QLG EIS needs to explain to the public and decisionmakers how the ecological effects of future timber extraction and fire suppression policies, programs, and practices will qualitatively differ--if at all--in their effects from the adverse effects they have caused in the past. If this really is a pilot project, then it should not "stay the course on a sinking ship." The QLG EIS cannot simply replicate the failed management strategies and polices of the past, but instead, must propose real alternative strategies and practices for "caring for the land and serving people."

Thank you for consideration of our comments. We look forward to seeing the above issues and concerns worked into the Draft EIS.

Sincerely,


Timothy Ingalsbee, Ph.D.
Director, Western Fire Ecology Center