Fire/Fuels Arguments for NEPA Comments

The National Environmental Policy Act (NEPA) requires federal agencies to fully analyze and disclose in public documents the direct, indirect, and cumulative environmental effects that could result from proposed government projects and management actions. Below is a list of effective fire/fuels related arguments you can use in comment letters critiquing NEPA documents that exhibit poor or missing data, flawed analysis, or biased reasoning. The arguments have come out of several of our own comment letters that we have sent the U.S. Forest Service over the last few years, responding to errors that have repeatedly appeared in their NEPA documents for fire-related timber sales purported to be "salvage," "thinning," "fuels reduction," or "ecosystem restoration" projects.

For your convenience, the list is alphabetically categorized according to various fire-related issues, however, any given argument may fit within more than one category or issue. Feel free to be creative in articulating and applying these arguments in a variety of ways to suit your needs and write powerful, effective comment letters. Also, for your convenience these arguments are generic and stated as briefly as possible. You will be most effective in getting federal agencies to improve their analysis and disclosure of environmental effects if you expand upon these brief arguments by providing additional information. For example, supplement these arguments with:

1) site-specific information about the project proposal and project site.
2) data from the given NEPA document (or data disclosed in other similar NEPA projects).
3) information and references from scientific articles or policy papers.
4) your personal insights, experiences, and opinions about the proposed project.

With your help, this list will continually grow and improve! Send us copies of some of your NEPA comments and/or proposed arguments, and we’ll share them on this web page. Email us your fire/fuels related arguments at: fire@efn.org.

Be sure to monitor the "What’s New" section of our home page to see when this list has been updated.

CROWN FIRE

The document failed to disclose quantitative data on crown bulk density in sites proposed for treatments. The document inappropriately uses canopy closure/crown closure as a surrogate for crown bulk density; the two concepts are qualitatively different, and the scientific literature only uses crown bulk density for assessing crown fire potential.

The document inappropriately uses the BEHAVE model to predict crown fire risk and/or behavior. BEHAVE is only suitable for modeling fire behavior of surface fires, and only for surface fuels three inches in diameter or less.

FIRE EXCLUSION

The document failed to analyze and disclose the full range of adverse effects on specific species and landscapes, and ecosystem structure, composition, functions and processes from continued fire exclusion and aggressive suppression. These adverse effects are particularly acute for fire-dependent species, communities, and systems.

The document failed to disclose the effects of continued fire exclusion on fuel loads and fuel profiles, fire behavior and fire effects over time.

FIRE EFFECTS

The document failed to disclose the beneficial effects on species, stands, landscapes, and ecosystems from prescribed and wildland fires. The document portrays wildland fire solely in a negative light, as something that is purely destructive and damaging.

FIRE POLICY

The document failed to disclose how the proposed project tiers to, and will successfully implement, the Federal Wildland Fire Policy.

FIRE RISK

The document failed to disclose that proposed logging sites are located in high-elevation zones and vegetation communities characterized by an infrequent, high-intensity fire regime. Hence, there is a relatively low risk of fire, but when fires do occur, it is natural for these fires to be high-intensity. Thus, efforts to "prevent" high-intensity fires or facilitate aggressive suppression in project sites will either be unnecessary, since the fire risk is low, or ineffective, since the conditions that support fires tend to defy human ability to contain or control fire.

The document failed to disclose quantitative data and analysis on the probability of fire occurrence in sites proposed for treatments.

The document fails to properly distinguish the concepts of fire risk and fire hazard. The two concepts are not interchangeable. Risk refers to the probability of a fire from any ignition source. Hazard refers to the potential intensity or severity of a fire given a particular fuel source. In some cases, it is more socially and ecologically acceptable to have areas containing high fuel hazards if the risk of fire is low, especially if the analysis demonstrates that impacts from fuels treatments would cause adverse effects to the environment.

FIRE SUPPRESSION

The proposed project is intended to facilitate future fire suppression actions; yet, the document failed to analyze and disclose the cumulative environmental effects of fire suppression activities within and adjacent to proposed treatment sites. These activities include: tree cutting, soil disturbance, chemical dumping, burning operations, and many others.

The document failed to disclose that fire suppression is neither safe nor effective during extreme fire weather conditions. The document misleads the public into believing that suppression will be effective in proposed treatment sites under all conditions or circumstances.

FUELBREAKS

The document failed to provide scientific evidence that proves the proposed fuelbreaks would facilitate safe, effective fire suppression. The document needs to provide scientific data, not subjective opinions from agency staff.

The location of proposed fuelbreaks along mid-slope logging roads will not facilitate safe, effective fire suppression, and will likely not be staffed by firefighters due to safety concern.

The document failed to disclose data on the maintenance status of logging roads alongside proposed fuelbreaks. The assumption that logging roads would provide for rapid evacuation of firefighters in the event of a "blow-up" event is unfounded.

The document failed to disclose the fact that fuelbreaks alone can not successfully contain or control wildland fires. Fuelbreaks are only effective when staffed by firefighters.

The document failed to analyze and disclose the cumulative effects of fuelbreak construction, maintenance, and firefighter use during fire suppression incidents. The document falls short in only analyzing, for example, soil disturbance caused by skidding logs during fuelbreak construction without analyzing future soil disturbance from firefighters and bulldozers cutting firelines within the fuelbreak.

The document failed to disclose the management methods and financial means by which fuelbreaks will be monitored and maintained over the long-term. Without periodic maintenance, the effects of fuelbreaks are lost and sometimes even negated, i.e. sites increase in fire hazard due to regrowth of flammable surface vegetation.

The document failed to disclose the scientific controversy over the suppression effectiveness of fuelbreaks for containment and control of wildland fires. The document failed to provide scientific, empirical evidence that fuelbreaks will be effective for fire suppression.

The document failed to provide for a wider range of alternatives to construct fuelbreaks without extraction of large, commercial-grade overstory trees. Concentrating on fuels management of surface fine fuels and understory ladder fuels, preferably with prescribed fire and manual treatments, while retaining all overstory trees could accomplish the stated objectives of fuelbreaks with much less environmental damage than would be caused from logging operations and removal of habitat trees.

FUEL LOADS

The document discussed fuel loads in generic terms, but failed to provide site-specific quantitative data on fuel load accumulations.

The document failed to disclose quantitative data on fuel loads differentiated by fuel size classes. Large fuels add total tonnage of fuels, but only fine fuels (three inches or less in diameter) affect rate of fire spread. The document needs to analyze and disclose the fuel loads according to various size classes (e.g. 1 hour, 10 hour, 100 hour, 1000 and 10,000 hour time lags).

The document failed to disclose quantitative data on historic fuel loads. This is necessary to determine whether current fuel loads are outside their historic range of variability (HRV). If the current fuel loads are within the HRV, then proposed management activities to "restore" sites are not valid.

The document fails to define what are hazardous fuels. Large fuels (greater than three inches in diameter) are not the primary fire/fuels hazards because they do not contribute to fire spread. When embers are produced by large fuels (e.g. snags) they can only ignite in fine fuels; they do not ignite large-diameter fuels. In order to effectively reduce hazardous fuel loads, the project needs to prioritize treatment of genuine hazardous fuels (surface and understory fuels three inches in diameter or less) before removal of large, overstory trees.

FUEL MODELS

The document failed to disclose the fuel models for the planning area and specific sites proposed for fuels treatments.

The document failed to disclose the project’s effect on fuel models on sites proposed for fuels treatments.

LOGGING SLASH TREATMENTS

The document failed to disclose that untreated or ineffectively treated logging slash is highly flammable, and that fire hazard and risk will actually increase in the short-term following logging unless/until slash is effectively treated.

The document failed to disclose guaranteed sources of funding, and a commitment to apply funding, to effectively treat logging slash.

The document failed to disclose the specific time frame and methods to effectively treat logging slash. The document needs to fully disclose how and when logging slash will be effectively treated.

Not all slash treatments are equally effective. For example, the common practice of "compaction" of slash by running skidders and dozers over slash has minimal effectiveness in reducing potential fire hazard, especially in dry pine-dominated sites. Also, traditional "lop and scatter" methods have been shown by van Wagtendonk (1996) to be one of the worst methods for treating slash, since it increases rate of fire spread and fireline intensity more than any other fuels treatment. The project needs to ensure that slash treatments will be effective in reducing potential fire hazard.

The document failed to disclose that proposed logging will actually increase hazardous fuel loads by generating logging slash, and leaving behind downed cull logs and stumps.

MAINTENANCE OF FUELS TREATMENTS

The document failed to disclose that in logging sites exposed to soil disturbance and increased sunlight, grasses, forbs, brush, and saplings will grow on managed sites, providing a new highly-flammable fuel bed. This will undermine the stated purpose of the project--to reduce fire/fuels hazards. The document failed to disclose how these new fuels will be managed, and how fuels treatment sites will be maintained over the long-term.

PLANTATIONS AND FIRE

The document failed to disclose that young conifer plantations are extremely flammable, and are vulnerable to severe fire effects even from low-to-moderate intensity fires.

The document failed to disclose that conversion of stands from mature/old-growth trees to young artificial reproduction will increase fire risk and fuel hazards. Mid-/late-successional stands are generally relatively fire-resistant. Early successional stands, especially young conifers in densely-stocked even-aged plantations, are extremely flammable and subject to catastrophic burning during fire events.

PRESCRIBED BURNING

The document failed to disclose that prescribed burning of hand- or machine-piled logging slash causes severe soil impacts. This can "sterilize" the soil, and worse, can provide opportunities for invasive weeds to grow on exposed soil underneath burn piles.

The document failed to disclose the adverse effects on native flora and fauna from prescribed burning in early spring.

RANGE OF ALTERNATIVES

The document failed to provide a sufficient range of alternatives to avoid removing big, old, large-diameter, overstory trees in order to reduce fire hazard.

"REBURN HYPOTHESIS"

The document claims that that large-diameter fuels (standing snags or downed logs) pose a high risk of reburn. However, according to Beschta, et.al. (1995), Everett (1995), and McGiver and Starr (2000) there is no scientific, empirical evidence that supports the claim that removal of dead trees (standing snags or downed logs) decreases the intensity or severity of future fires on those sites. Nor is there scientific, empirical evidence that supports the claim that the presence of dead trees increases the risk of wildfire. Instead, the reburn hypothesis is based purely on untested assumptions and subjective opinions.