Logging for Firefighting: A Critical Analysis of the Quincy Library Group Fire Protection Plan
by Timothy Ingalsbee, Ph.D.
Director, Western Fire Ecology Center

1997 unpublished research paper for the Western Ancient Forest Campaign

INTRODUCTION

 The following critical analysis of the Quincy Library Group Bill (H.R.858), traces the origins of the legislation in the 1993 QLG Proposal and subsequent documents that together constitute the QLG "Plan." The 1993 QLG Community Stability Proposal began as a desperate plea for more federally-subsidized commercial logging, arguing that increased timber extraction was necessary to stabilize local economies in the wake of new federal restrictions on logging old-growth trees. Since then, the QLG has recast its original logging Proposal into an alleged firefighting Plan that claims increased timber extraction would both stablize local economies and protect public forests from wildfires. However, in its logging-for-firefighting strategy, the QLG has misidentified both the cause of and solution to large-scale, severe wildfires. This is not surprising since 20 out of the 30 members on the QLG Steering Committee are representatives of the timber industry, yet there is not a single fire ecologist or firefighter on the QLG. Congress compounded this absence by failing to gather input from the professional wildland fire community during hearings on H.R.858.

As attractive as the fantasy may be that we can log forests to protect them from fires, the reality is that the QLG Plan would feed yet another unsustainable short-term "boom and bust" logging cycle that would actually increase the fire risks, fuel hazards, and dangers to firefighter safety. Specifically, the QLG Plan would: 1) add to the existing load of hazard fuels from logging slash and brush in cutover sites; 2) create changes in the microclimatic conditions that would increase fire intensity; 3) change the vegetative cover in ways that would lead to more rapid fire spread; 4) fail to address the Forest Service's historical lack of slash treatment, monitoring, and brush maintenance on logged units, and continue this neglect into the future; 5) generally lead to more extreme fire behavior, resulting in large-scale, high-severity wildfires and put the safety of firefighters at greater risk. Therefore, citizens and legislators concerned for the long-term health and viability of public forests and rural communities in the Sierra Nevadas (and throughout the West) should vigorously oppose the QLG bill.

HISTORICAL CONTEXT OF THE QLG PLAN: THE QLG PROPOSAL
AND THE "FOREST HEALTH CRISIS" CAMPAIGN

Beginning in the early 1990s, the Forest Service faced a number of legal and political challenges over the impacts of its commercial timber sale program on spotted owl populations. Destruction of Northern Spotted Owl habitat by commercial timber extraction resulted in that species becoming listed as a Threatened species under the Endangered Species Act. Lawsuits forced an injunction over new commercial timber sales in spotted owl habitat throughout Oregon, Washington, and northern California. The California Spotted Owl (a seperate subspecies) and the National Forests in the Sierra Nevada were fast heading toward a similar fate, too. As a short-term effort to avert impending lawsuits and injunctions while the Forest Service developed a regional plan for the long-term management of California spotted owl habitat, the agency issued the "CASPO Report" in July, 1992. Based on the findings and recommendations in this report on the condition of the California spotted owl, the agency developed new regulations on commercial logging. These new regulations were the main impetus for the formation of the Quincy Library Group.

Coinciding with the crisis over declining spotted owl populations and restrictions on federal timber sales in the Pacific Northwest, the Forest Service, timber industry, and members of Congress representing timber interests declared that there suddenly was a "forest health crisis" throughout the West. This alleged "crisis" was first framed as the problem of too many "dead and dying" trees; the solution was they needed to be "salvage" logged immediately in order to capture the most economic value from the timber. This propaganda message had varying levels of success in winning public support for increased commercial logging on federal lands. Across the country, many abuses of so-called "salvage" logging occurred, especially during the Timber Salvage Rider. Public sentiment quickly became skeptical, if not openly antagonistic, toward salvage logging for economic reasons alone. Consequently, the forest health crisis-campaign changed its message to claim that the problem was "overstocked thickets of understory trees;" the solution was they needed to be "thinned" in order to "prevent catastrophic wildfires."

Currently, the timber industry and Forest Service's new justification for commercial timber extraction is that logging is a "tool" for "restoration of forest health" and "protection from wildfires." This message is apparently being effective in Congress, as evidenced by the House of Representatives vote on H.R.858. Variations on the theme of "fuels reduction for fire protection" has generated a host of similar legislative efforts attempting to ride on the coattails of the QLG and boost commercial timber sales on federal lands. Examples include the "Forest Recovery and Protection Act" (H.R.2515) sponsored by Rep. Bob Smith, chairman of the House Agriculture Committee, and the "Community Protection and Hazardous Fuels Reduction Act" (H.R.2458) sponsored by Rep. Helen Chenowith, chairman (sic) of the House Subcommittee on Forest Health.

THE 1993 QLG COMMUNITY STABILITY PROPOSAL

When the three founders of the QLG first came together in November, 1992, it was for the expressed purpose of ending the "timber wars" in the three National Forests of the northern Sierra Nevada. The combined effects of successful appeals and lawsuits against timber sales, appeals and impending lawsuits against the Lassen and Plumas Forest Plans, the new CASPO logging regulations covering ten National Forests in California, and the uncertainties of a future regional spotted owl management plan, all compelled the timber industry to meet with some of their environmental opponents to work out some kind of compromise. Sierra Pacific Industries' forester, Tom Nelson, and Plumas County Supervisor, Bill Coates, both realized that the "conservationist alternatives" submitted during the Lassen, Plumas, and Tahoe Forest Plan processes would have potentially yielded more timber volume than what the agency was prepared to offer under CASPO regulations. The primary motivation for the 1993 QLG Proposal, then, was to "provide an adequate timber supply for community stability." The QLG all agreed with the assertion--currently proven false five years later--that timber-dependent communities in Lassen, Plumas, and Sierra Communities "may not survive the current reductions in Federal timber harvests."

Accompanying this desire by industry supporters for more timber sales was another motive held especially by the handful of environmentalists on the QLG: to "promote forest health." The QLG Proposal believed that by using group-selection silvicultural strategies, carrying out the fire and fuels management objectives recommended in CASPO, and establishing a watershed restoration program, this would both promote forest health and "expand the existing landbase for timber production beyond that currently 'zoned' for timber production." Just like the wider forest health campaign, the QLG narrowly defined forests in terms of timber resources and proposed solutions based mainly on logging techniques. For example, a more recent QLG document reveals that proposed projects to implement forest health management objectives are (in order of preference according to the QLG) "biomass harvest, green sales, salvage sales, fuels reduction, watershed restoration, and 'other' projects." It should be noted that all but the watershed restoration projects involve commercial extraction of trees. A rare convergence thus developed between environmentalists who believed that commercial logging could be used to promote forest health and timber industry representatives who believed that forest health could be used to promote commercial logging.

QLG SILVICULTURAL PRESCRIPTIONS

Within the QLG "on-base" areas designated for logging, their Plan calls for two basic silvicultural strategies: "Intermediate Thinning" and "Regeneration Harvest." Both terms are code for commercial logging: the former indicates that lumber-grade sawlogs will be the prime targets, and the latter is jargon for clearcutting. CASPO guidelines prohibit the cutting of live trees greater than 30 inches DBH; consequently, the description of intermediate thinning states that logging will "mostly be thinning from below," and "generally be in the smaller diameter classes." (emphasis mine) Using language such as "mostly" and "generally" provide ample loopholes for logging large-diameter trees during these so-called thinning operations, and raise questions over compliance with CASPO. Unfortunately, the Forest Service has a well known problem of failing the public's trust by using similar vague language to violate its own regulations and the nation's environmental laws in order to get the timber cut out.

Compounding the QLG's vague description of its silvicultural strategies is the Forest Service's description of a "Defensible Fuel Profile Zone" (DFPZ), a key component of the QLG Plan. According to the agency's definition, "A defensible fuel profile zone may be any size, shape, or width. They may be located along roads, on a ridgetop, or in a canyon bottom." In effect, the definition of a DFPZ is so vague that it can mean almost anything. These kinds of vague definitions raise more questions than they answer, and are susceptible to misuse by Forest Service line officers compelled by Congress to get the timber cut out.

The QLG Plan emphasizes both "thinning from below" and "group selection harvest," but it is clear that the timber industry and Forest Service are most interested in the latter. For example, maps of the QLG Proposal highlight areas "available for group selection" commercial logging, but entirely omit existing special wildlife and riparian management areas that should restrict logging within those same QLG-defined "general forest" zones. Despite foresters' protestations to the contrary, "group-selection harvest" is really a deceptive euphemism for small clearcuts. At the end of the QLG Bill's five year "Pilot Project," 171,000 total acres would be clearcut under group-selection prescriptions. Of this total acreage, just seven District fuel management officers would have to deal with treating the slash from either 85,500 two-acre or 342,000 half-acre clearcut group selection units.

Additionally, agency fuel management officers would have to treat the slash from a cumulative 1,500 miles of fuelbreaks, which must be cut at a pace greater than one mile per day (assuming weekends are excluded). The task of treating this new slash would be daunting enough, but the well-documented backlog of untreated old slash already littering the National Forests of the Sierras demonstrates that the Forest Service is unable (or unwilling) to mitigate the fuel hazards created by commercial logging. Group selection clearcutting is primarily geared to the profit-making goals of the timber industry; it has little to do with forest health restoration or wildfire protection.

In addition to the vague prescriptions for "thinning from below", another problem is that in the National Forests of the northern Sierra Nevada, decades of "high-grade" logging have already taken most of the large, overstory trees. The QLG Plan to leave all trees over 30 inches in diameter is meaningless in areas where very few of these big old trees remain. Over extensive areas, there are few remaining old-growth trees "above" to be thinning smaller trees from "below." On the ground this would translate into more areas "available for group selection" clearcutting because nearly all of the trees are all under the 30 inch DBH cutting allowance.

According to the QLG Plan, group selection units would target "naturally occuring clumps of trees." From my observations in the field, it appeared that in places like Lassen National Park where there were still big old trees, they often grew together in clusters. Moreover, clusters of smaller trees often collectively produced enough shade from their stems and canopies to mimic the shade from old-growth trees. In the hot, dry summers of the Sierras, trees need to grow in clumps in order to create the kinds of microclimatic conditions necessary to reach the age and size characteristics of old-growth. The extirpation of natural tree clusters, however, will likely compromise the "shaded" aspect of fuelbreaks, and threaten the long-term viability of retained trees.

RECENT QLG TIMBER SALE SITES

A recent timber sale using federal money solicited by the QLG for a "pilot project" was conducted on the Beckwourth District of the Plumas National Forest. On this site, nearly all natural tree clumps were eliminated, leaving only single trees standing in their place. In some cases, trees that grew close together were nearly pried apart, causing damage to the retained trees. Furthermore, in order to achieve an even spacing between tree crowns, clumps of sawlogs were cut while some individual pole-sized trees were spared. These sole survivors of former clusters were uniformly and evenly distributed across the unit, almost as if they were artificially planted in a gridded pattern.

The result of this logging operation was a simplification of forest structure and a homogenization of the landscape, reducing the natural variation in tree sizes and spacing. Also, fire-resistant trees of lumber-grade dimensions were taken while fire-susceptible pole-sized trees were left behind. While natural tree clumps were targeted for cutting, existing gaps such as a seasonal wet meadow were virtually ignored as part of the design of this Community Defense Zone (CDZ). Finally, the slash was "treated" by machine-piling the limbs in a huge mound that was dumped in the middle of the meadow. Deep ruts were carved into the ground from the wheels of the logging machines, and except for the few trees that were left, there was no other living vegetation on the ground. The question arises: how representative of future timber sales under the QLG Bill is this logged site?

Over the last five years the QLG has continued to supplement their original Proposal with a series of position papers, charts, maps, and other documents that collectively constitute the QLG Plan. Many items are posted on their Web page (www.qlg.org), including two lengthy critiques of this author's earlier report on the QLG Bill. With this Web page and other public relations efforts, the QLG has recast their original Community Stability Proposal into an alleged Fire Protection Plan.

THE QLG "FIRE PROTECTION" PLAN

 In the original 1993 QLG Community Stability Proposal, fire played a relatively minor role. The Proposal simply stated that "in order to achieve stability in the system the Fire and Fuels management objectives recommended in CASPO must be carried out over the entire landbase." Beginning in 1994 the QLG began articulating the demand for a "network of defensible fuelbreaks" as a means to "improve our protection from large-scale high-intensity wildfire." Since then, the QLG has essentially defined the forest health "crisis" primarily in terms of fire and fuel hazards. According to the QLG, "We believe our efforts to gain some quick leverage on the hazard of intense wildfire is a pre-condition to any successful attack on the numerous other forest health and community stability problems that face us."

In their own words, "QLG hears a fire alarm" and wants a "fire emergency response." For example, in a list titled "Unavoidable Choices and Unavoidable Outcomes," the QLG warns that if its Plan isn't carried out to the letter,

 "Then we had better learn to deal with repeated 50,000+ acre blocks of charcoal and baked soil, unchecked runoff of rain and snowmelt, scoured streambeds, silted reservoirs, and greatly reduced flood control, among other problems too numerous to mention."

In the context of the wider forest health crisis-campaign that is fomenting "pyrophobia" (fear and hatred of fire), some critics believe the QLG is opportunistically "jumping on the fire bandwagon." Among the QLG members working specifically on fire issues, however, they sincerely believe that wildfire is the single greatest threat to the forest and local communities. In their minds, "the only questions are when and how big will the catastrophe be?" Unfortunately, the QLG lacks the experience or expertise to correctly identify the primary fire risks and fuel hazards, and their proposed solution emphasizing commercial logging would increase these risks and hazards.

Although the QLG's alarmist rhetoric on "catastrophic" wildfires sometimes verges on hysterical fear-mongering, their concern about the general issue of fire and fuel hazards in the Sierras is partially validated by recent events and scientific reports. For one thing, there have been a series of large-scale, severe wildfires in California, such as the 1994 Fountain Fire, that traumatized rural communities. Other large-scale fires throughout the West during last decade's drought have had a jarring effect on the public's perception of forest fires. This has forced the Forest Service to admit the role of its "past" logging and firefighting policies in creating current fire and fuel hazards.

Accordingly, the QLG has selected a few supportive statements from both the CASPO and SNEP Reports to bolster their fears of fire. The CASPO Report, for example, made the bold assertion that "Severe wildfire in Sierran mixed-conifer forests may represent the greatest threat to current owl habitat." The subsequent CASPO guidelines therefore ordered Forest Service managers to "reduce the threat of stand-destroying fires." The SNEP Report also highlighted the fire hazards of the Sierras, stating that "Current management strategies and those of the immediate past have contributed to forest conditions that encourage high-severity fires." The QLG has especially made use of the SNEP papers promoting Defensible Fuels Profile Zones (DFPZs).

The QLG believes that commercial logging to prepare for firefighting is an economically and ecologically beneficial thing to do. And they are very proud of their Plan. In their own words,

 The QLG has made strategic fuel management a central focus of its land management proposal. The fire management section is the most detailed and scientifically sophisticated plan that I know of, and was discussed at length and recognized in the SNEP Report...The QLG Plan is the most environmentally sound National Forest Management Plan in the U.S.

 To their credit, the QLG has raised some valid, important issues concerning contradictions between Forest Service timber and fire management policies and practices. The issue is not whether or not these fire and fuel hazards exist, or whether or not forest management policies and practices should be changed; rather, the question is has the QLG correctly identified the primary source of these hazards, and does its Plan represent a bona fide solution? Finally, a question arises as to whether or not the QLG is appropriately using the CASPO and SNEP Reports for scientific validation of its Plan. It is to these questions that we now turn.

FIRE AND FUEL HAZARDS

The QLG Plan conforms to the "fuels reduction for fire protection" ideology that is driving numerous other forest health-type timber sale projects throughout the West. According to the QLG, "the great excess of small trees are at the root of the area's worst fire hazard." And they believe that these "small" trees--which include trees up to 30 inches in diameter!--are the primary fuel hazard that enables surface fires (the most common type of forest fire) to climb into the tops of large, overstory trees and become crown fires (the rarest type of forest fire). Relatedly, the QLG believes that it is the horizontal density of tree crowns in closed-canopy forests that is the main factor causing crown fires to spread. The QLG hopes that by using experimental silivicultural and mechanical treatments, such as "thinning from below" and "shaded fuelbreaks," it will be able to "interrupt the vertical and horizontal continuity" of both ladder and canopy fuels, and thereby prevent the start or spread of crown fires.

The promotion of commercial logging to reduce hazard fuels is predicated on the QLG's belief that the main forest health problem in the Sierras are all the small trees that have grown because of firefighting, not all the stumps, slash, and brush that have accumulated because of logging. According to the QLG,

 The current fuel load in these national forests is largely the result of one fact: for about 70 years fires have been suppressed with increasing efficiency. Other factors were involved, such as logging that in many places removed the cover of large trees and in some places left untreated slash, but there is no doubt that fire suppression is the main reason for our excessive and rising fuel load."

 On the contrary, despite popular notions promulgated by certain politicians and the press, there is much scientific uncertainty whether current vegetation changes and fuel accumulation can be attributed solely or mainly to fire suppression.

The QLG should receive credit for briefly mentioning the problems associated with commercial logging; however, their belief that firefighting is the main culprit runs contrary to the conclusions of the SNEP Report, which stated unequivocally that,

 "Timber harvest, through its effects on forest structure, local microclimate, and fuel accumulation, has increased fire severity more than any other recent human activity."

 The QLG not only misidentifies the main source of the fire and fuel hazards, but offers an internally-contradictory strategy for fire protection. In the minds of the QLG, the solution to the forest health problems caused by "past" firefighting and logging is to continue logging for the sake of future firefighting. The QLG has yet to directly address this apparent contradiction between management activities that cause forest health and fire hazard problems but are somehow the proposed solutions to those problems.

"STRATEGIC SYSTEM OF DEFENSIBLE FUELBREAKS"

The heart of the QLG's fire protection plan is a "strategic system of shaded fuelbreaks" called Defensible Fuel Profile Zones (DFPZs). The purpose of these DFPZs is to provide a "network" of logged areas where, it is claimed, firefighters could "safely and efficiently" fight forest fires. Again, using commercial logging as a "tool" for fuels reduction, these DFPZs would average a quarter-mile in width, with tree cover "thinned" down to about 40% remaining canopy closure. Where possible, these DFPZs would be cut alongside existing logging roads, and form a network that would enclose blocks of forest approximately 10-12,000 acres in size. Theoretically, the amount of trees removed for DFPZs would reduce the intensity and rate of spread of wildfires, bring a crown fire back down to the ground, minimize "spotfires," and allow quick access or safe retreat for firefighters. According to their proponents, DFPZs are intended to "emulate the natural fire regime of the pre-settlement era" and "represent the Desired Future Condition of the surrounding forest."

The concept of DFPZs was a joint creation between the QLG and the Forest Service. An early sketch--significantly titled "Theoretical" at the top of the page--displayed two versions of the QLG's fuelbreak strategy: 1) fuelbreaks cut in parallel strips that would divide the forest into bands approximately 1.75 miles wide, and/or 2) fuelbreaks cut in a gridded pattern that would divide the forest into cells approximately 9,000 acres in size. The goal of this early proposal was four years of "fire emergency priority treatment" in which, at the end of that time, one-eighth of all the acreage slated for logging in the three National Forests would be converted into fuelbreaks. Given such a large portion of the forest desired for DFPZs, the question arises: will these fuelbreaks become forest breaks?

USFS TECHNICAL FUELS REPORT

This early conceptualization of DFPZs was given more rigorous development in a Forest Service document titled the "Technical Fuels Report" (TFR). The TFR was a special project funded by federal money actively solicited by the QLG. The TFR recommended three fuels treatment strategies to reduce fire and fuels hazards: Defensible Fuel Profile Zones (DFPZs) located mainly adjacent to logging roads, "Community Defense Zones" (CDZs) located nearby human communities, and Fuel Reduction Zones (FRZs) located in remaining wildlands. The TFR recommended that 210 DFPZs be cut (encompassing 169,000 acres) and 51 CDZs be cut (encompassing 314,000 acres) at an average cost of $250.00 per acre (totalling over $42.2 million). Additionally, the TFR recommended a ten year maintenance cycle, treating nearly 17,000 acres per year at an annual cost of $1.1 million. Importantly, the TFR stated that these fuels treatments could be accomplished by various methods--and prescribed burning was listed first, before silvicultural or mechanical treatments.. This order of treatments was no accident: it indicates that prescribed burning was and still is the preferred method for reducing the kind of forest fuels that are the primary fire hazards.

The QLG gave conditional support for the TFR as an elaboration of their fuelbreak strategy--even though the TFR did not define DFPZs as "fuelbreaks" nor even mentioned the word! "For the most part, QLG supports the TFR as far as it goes," (emphasis original). Some environmentalist members of the QLG rightly criticized the TFR for its lack of interdisciplinary analysis or public participation. Moreover, they noted that the TFR did not analyze the effects of its fuels modification strategies on special wildlife management or riparian zones, nor did it reveal specific prescriptions or priorities for the construction of DFPZs. Ironically, these shortcomings of the TFR also apply to the QLG's own DFPZ Plan.

Despite their criticisms, the QLG published a map of the TFR that, upon close examination, reveals that some DFPZs would be cut through lands designated by the QLG as "off-base" (proposed wilderness areas) and "deferred" (inventoried roadless areas). Presumably, the QLG Bill would prohibit logging in these areas--in accordance with the QLG landbase agreement--yet questions arise over why were the DFPZs mapped in these areas? DFPZs would utterly fragment the Sierraville District of the Tahoe, yet to complete this network the Forest Service must convince adjacent private landowners to cut their own forests for DFPZ, too. Questions arise as to what happens to the integrity of the fuelbreak network if the agency does not gain this cooperation from private landowners? Most upsetting, considering the fact that the Park Service has never been invited to QLG meetings, is that Lassen Volcanic National Park and the Caribou Wilderness Area would be encircled by DFPZs running right up to and parallel with their boundaries. Lassen National Park has been creating its own fuelbreaks and reducing hazard fuels with prescribed burning for the last 15 years. Questions arise: why the need to impose environmental impacts and taxpayer expenses to construct new fuelbreaks on adjacent Forest Service lands? Many more questions arise as to the specific "strategy" behind the QLG's fuelbreak plan, as well as their preferred methods for creating DFPZs.

USFS FOREST ECOSYSTEM RESTORATION AND PROTECTION PROJECT

Whereas Forest Service line officers from the Chief on down have opposed the QLG Plan in the past, viewing this persistent group of citizens (and their corporate sponsors) to be an intrusion into the agency's bureaucratic authority, the Lassen Forest Supervisor has realized the potential timber management opportunities involved in a Congressionally mandated fuels reduction program. Consequently, the Forest Supervisor has authorized an interdisciplinary follow-up study to the TFR. The Lassen National Forest plans to construct DFPZs and other fuelbreaks whether or not the QLG Bill ever becomes law. The results of this study to date have been some excellent fire history research and fuels inventory analysis done by fuels management staff. But the team of resource specialists have also revealed that DFPZs would cause significant impacts to other resources and values, particularly soils, watersheds, and wildlife. Much as Congress and the QLG would like to ignore, the QLG Bill does not represent a "win-win" solution or "stability" from the perspective of the local biological community.

The follow-up study to the TFR is a document yet to be released to the public called the "Forest Ecosystem Restoration and Protection Project" (FERPP). This is not a NEPA document, and will not involve public input, not even from the QLG. Its purpose is to assess the environmental effects and economic costs of the TFR's fuel management strategies. The FERPP has enlarged the size of DFPZs in the QLG Plan: instead of 1/4 mile wide DFPZs using group-selection clearcuts up to two acres in size, the FERPP recommends that DFPZs be enlarged to 1/2 mile wide and incorporate group-selection clearcuts up to five acres in size. Although both the QLG Plan and the FERPP were allegedly based on the TFR, the TFR never mentioned the need for commercial logging to construct DFPZs or reduce hazardous fuels. Indeed, both the QLG and the Lassen Forest Supervisor have imposed their desires for logging onto the TFR and the work of the Lassen's fire and fuels managers. Fire hazard fuels reduction need not and should not involve commercial timber extraction--a point to be discussed in depth later.

If the QLG Bill becomes law and includes the provision for an EIS, then the FERPP would likely be integrated into the process, and thus represents a "head start" on the effects analysis. So far, the team of Forest Service specialists has determined that DFPZs, CDZs, and FRZs will cause a number of significant environmental effects on a number of forest resources and values: 1) In order to fully develop DFPZs and utilize group selection logging, the amount of permanent and temporary roads would vastly increase, resulting in increased road densities in what are already some of the most heavily roaded National Forests in the Sierras; 2) The detrimental effects of existing roads would be magnified by the amount of vegetation removal and soil disturbance necessary to convert them into DFPZs; 3) Not only would soil erosion and siltation increase, thereby affecting water quality and fish habitat, but other ongoing problems with Forest Service roads would be exacerbated, such as poaching and wildlife harrassment, timber theft, littering and garbage dumping, arson and accidental human-caused wildfires. All of these problems would likely be increased in the roadside DFPZs. It is not clear whether or not the QLG has seen a draft of the FERPP, because to this day they insist that the QLG Bill would not create any new roads.

The FERPP analysis also predicts an overall loss of species within DFPZs, and several proposed DFPZ sites intersect special wildlife management zones demarcated in the Lassen Forest Plan. Indeed, the 1/2 mile wide DFPZs would impact at least 30% (6,645 acres) of the existing spotted owl Protected Activity Centers on the Lassen. Consequently, the analysis team recommended that the boundaries of these wildlife management zones be "adjusted" in order to facilitate construction of DFPZs, CDZs, and FRZs. This raises the question whether or not the agency intends to forcibly relocate wildlife like spotted owls whose Protected Activity Centers have the misfortune of being located in an area desired for a DFPZ?

Despite these foreseeable negative environmental impacts, the analysis team frankly stated that,

"We do not know whether the proposed fuels network design features will be as effective in reducing the risk of a catastrophic fire as the fire behavior models would suggest. No network of this design has been put to the test of a large wildfire burning under adverse fire weather conditions."

Thus, while the environmental impacts and economic costs are fairly predictable, the agency's analysis validates critics, such as Senator Dale Bumpers, who assert that the management activities mandated by H.R.858 are "untested" and "are neither generally accepted nor supported by the scientific community."

A point to be reiterated is that regardless of whether or not the QLG Bill becomes law, the Forest Service intends to start implementing DFPZ and CDZ timber sales. Indeed, throughout the Sierras and even in other Forest Service Regions, there are DFPZ timber sale projects being planned, with scant opportunities for public involvement in the development of this so-called "strategy" for "fire protection." For example, the Sequoia National Forest tried (unsuccessfully) to push forward two timber sales depicted as DFPZs under the Salvage Logging Rider, and inadvertently leaked to the public a map showing their intentions to create DFPZ timber sales on every major ridge in the Forest. The QLG Bill, H.R.858, thus represents a kind of legislative overkill meant to shift the Forest Service into overdrive on its own internal plan. Ironically, the QLG Bill has helped raise public awareness and alarm about these emerging timber sale schemes masquerading as DFPZs for "strategic hazard fuels reduction."

THE QLG AND THE "CAL OWL RDEIS"

The CASPO "interim" guidelines on commercial logging were intended to last only for a brief period until the completion of a "Cal Owl EIS" on managing spotted owl habitat in the Sierra Nevada. This regional EIS process has suffered repeated delays, mainly due to the agency's reluctance to craft a plan that would significantly reduce both commercial logging, road-building, and other timber management-related activities. The Draft EIS was released in January, 1995, but was withdrawn after thousands of public comments criticizing the document's flaws were received. Most recently, the Revised Draft EIS (RDEIS) was withdrawn even before it was submitted to public comment because a special interagency review committee determined that the amount and kind of logging proposed in the RDEIS would jeopardize the existence of the spotted owl and other rare, threatened, or endangered species. Consequently, CASPO guidelines continue to be in effect as the default regional management regulations. The QLG Bill, H.R.858, however, precedes if not preempts the development of a final Cal Owl plan, and detracts management activities away from planning long-term solutions toward doing more short-term "quick fixes" with so-called "pilot projects."

A forest management plan modelled after the QLG Plan was analyzed as an alternative in the RDEIS. Alternative F proposed management activities and land allocations that the agency claimed were "appropriate to the goals and objectives of the QLG Proposal," but extended the range of activities to include all nine National Forests in the Sierras. In comparison to the other alternatives analyzed in the RDEIS, the "QLG Alternative" would have resulted in the least amounts of spotted owl nesting and foraging habitat, and the least amount of large trees over 40 inches DBH. On the other hand, it would result in the most amount of land disturbance, soil impacts, road construction and equivalent roaded acreas. The QLG Alternative would produce the second highest amount of timber volume, yet would cost the most tax dollars in annual spending on vegetation management activities. The RDEIS concluded that,

 The prescriptions incorporated in the QLG area would change the character of the landscape. The fuelbreak system would create linear patterns on the landscape different from what would be expected to occur naturally...The long-term consequences are uncertain in regard to fire effects and forest health...The fuelbreak system artificially breaks the landscape into more uniform patterns and shapes. The effects of fire exclusion would continue to be felt outside the fuelbreak areas.

 Remarkably, the RDEIS admitted that none of its alternatives--including F--would have increased the amount of fire-resilient stands, or conversely, would have decreased the amount of stands with high potential for stand-replacing fires.

Understandably, an interagency review committee faulted the RDEIS in the harshest possible terms, stating that, "Fuel reduction treatments in the RDEIS are inadequate, are inappropriately measured, and have little impact on short-term fire hazard." Morover, the committee specifically questioned the concept of DFPZs and their alleged effectiveness in stopping catastrophic fires. The committee was particularly upset that all fuels treatments relied so heavily on mechanical means rather than precribed burning. The committee noted that,

 The science to support increased prescribed burning is extensive and has largely not been used by the RDEIS. Prescribed burning needs to be greatly expanded in at least one alternative in order to meet severe fire potential reduction objectives.

 The committee's justifiably harsh criticisms revealed flaws not only in the RDEIS, but also in the QLG Plan. Since the review committee determined that the RDEIS could not pass legal scrutinty, it was withdrawn before it was officially released and before the public could offer comments.

It must be noted that the QLG officially rejects the agency's "modified" version of their Plan in Alternative F of the RDEIS. Therefore, the QLG considers the analysis in the document to be irrelevant. Like criticisms directed against the TFR, and presumably against the FERPP (if and when it will be released to the public), the QLG simply dismisses all analyses by the Forest Service, the Congressional Budget Office, or the environmental community. The QLG does not admit to any foreseen environmental impacts or economic costs of its Plan; at times, the QLG even claims that "there is no plan" and that all of their documents are merely "proposals" that will be worked out and decided upon in a future EIS process. While this may be technically correct, it seems more like an attempt to evade reconciling its own ideas and beliefs with critical analyses and facts.

THE QLG AND CASPO

The 1992 CASPO Report and subsequent regional management guidelines restricting traditional logging practices compelled the timber industry to meet with willing environmentalists, and from these meetings the Quincy Library Group was born. The QLG's 1993 Community Stability Proposal stated that, "In order to achieve stability in the system the Fire and Fuels management objectives recommended in CASPO must be carried out over the entire landbase." The QLG Bill, however, mandates the "Construction of a strategic system of defensible, shaded fuelbreaks, consistent with Quincy Library Group Proposal of 1993." Unfortunately for the QLG and its Congressional supporters, neither the CASPO Report nor the QLG Community Stability Proposal ever discussed a strategic system of defensible, shaded fuelbreaks or anything even remotely resembling a DFPZ.

The 1993 CASPO regional interim management guidelines turned the CASPO Report's concerns about fire and fuels hazards into an edict to "reduce the threat of stand-destroying fires." The strategy to accomplish this goal was to increase the average size and age of stands by retaining larger diameter trees that were used by spotted owls for nesting habitat, and were most resistant to fire damage. The guidelines, it must be remembered, were focused on providing as much timber volume as possible while avoiding further destruction of occupied spotted owl habitat. Thus, it recommended the removal of trees which served as "fuel ladders," but it also recommended "widespread underburning (to) address the problem of reducing surface fire intensity." The QLG has focused on the former (remove ladder fuels) while downplaying the latter (underburn surface fuels) because the ladder fuels can translate into timber volume while surface fuels do not yield profitable timber outputs.

If the CASPO guidelines (authored by the Regional Forester) and the QLG Plan were authentically about wildfire protection and community stability--for the whole biological community-- then they would have paid closer attention to the recommendations of the CASPO Report's fire and fuels management specialists. This team did not recommend commercial logging, thinning, or other "mechanical" treatments; on the contrary, they strongly recommended a strategy of "light underburning" as the highest management priority for protecting spotted owl habitat.

Citing Countryman's (1955) pioneering research, the CASPO team noted that initial attack firefighters tend to be more successful in closed-canopy old-growth stands favored by spotted owls because

 These stands are less flammable under most conditions, because the dense canopies maintain higher relative humidities within the stands and reduce heating and drying of surface fuels by solar radiation and wind.

 Conversely, opening up the canopies through the kinds of "thinning" advocated by the QLG would enable more solar radiation and wind to reach the ground, resulting in hotter, drier, windier conditions which ignite surface fuels more easily and facilitate more intense, faster-spreading wildfires. The CASPO team did mention that dense canopies also meet the structural requirements necessary for the initiation and propagation of crown fires, but in the context of their chapter on fire and fuels management for spotted owl stands, thinning canopy fuels was of less importance than the priority need to reduce surface and understory fuel loads. Much of the problem with the CASPO Guidelines and the QLG Plan seems to hinge on their extremely broad definition of "ladder fuels" to mean overstory as well as understory trees. The fact is that without a high surface fuel load or a low ground-to-crown base height, crown fires are almost impossible to start or spread.

THE QLG AND SNEP

The Sierra Nevada Ecosystem Project (SNEP) Report was a Congressionally-mandated study of the entire Sierra Nevada range. One of the goals of SNEP was to "examine alternative management strategies that could help maintain the health and sustainability of the Sierra Nevada ecosystem while providing resources to meet human needs." In pursuit of this goal, the SNEP Report had to make some compromises between ecosystem restoration and resource extraction. Hence, there were several statements by scientists giving obligatory support to various kinds of "commercial harvest" in order to implement fuels reduction. At times, these pro-logging statements contradicted their prior discussions detailing the negative ecological impacts of logging. For example, SNEP's executive summary stated that,

 Timber harvest, through its effects on forest structure, local microclimate, and fuel accumulation, has increased fire severity more than any other recent human activity. If not accompanied by adequate reduction of fuels, logging (including salvage of dead and dying trees) increases fire hazard by increasing surface dead fuels and changing the local microclimate. Fire intensity and expected fire spread rates thus increase locally and in areas adjacent to harvest. However, logging can serve as a tool to help reduce fire hazard when slash is adequately treated and treatments are maintained.

 The last sentence of the above quote contains an essential qualification that, considering the Forest Service's historical and systematic neglect of slash treatment and fuelbreak maintence, makes it a theoretical rather than a factual statement. Unfortunately, the SNEP Report contains many similar contradictory and contingent statements about the theoretical ecological benefits of commercial logging.

A selective reading of SNEP can thus extract specific quotes to support all sides in the debate over resource extraction vs. environmental protection in management of National Forests and other public lands. This debate has been muddled by the assumption guiding the forest health crisis-campaign that commercial logging can be a "tool" for fire protection. Analysis of the scientific assessments of the SNEP Report, though, reveals that the statements in favor of prescribed burning and/or reintroduction of fire are far more numerous, emphatic, and factual than those in favor of continued commercial logging and fire suppression.

A critical distinction is that statements favoring burning are presented as fact-based research conclusions with ecological merits in their own right; on the other hand, statements favoring logging are presented as value-laden assumptions and/or management goals with no ecological merits of their own. Based on the differing ways the SNEP scientists discussed these items, it is likely that if the scientists had been given a mission to recommend techniques for restoring Sierra ecosystems based purely on the scientific merits and ecological benefits of those techniques without the need to be concerned about corporate profits or bureaucratic budgets, then commercial logging would not have been on their list of preferred "restoration" techniques.

SNEP AND DFPZs

The QLG's fuelbreak strategy gained some much-needed credibility from the SNEP Report whose fire and fuels specialists recommended thinning, underburning, and DFPZs to reduce fire severity and increase suppression effectiveness. A careful reading of the SNEP papers discussing DFPZs, however, reveals that not only does the scientific support for DFPZs rest completely on theoretical speculations and computer simulations, but more importantly, the scientists' vision of the purposes and places for DFPZs is far different from the desires of the QLG. Moreover, while the proposed design of DFPZs make them much different from the fuelbreaks of the past, the claims that DFPZs will overcome the systemic problems associated with other fuelbreaks programs remains little more than wishful thinking. And according to the specifics of the QLG Bill, these problems of past fuelbreaks will be enhanced with the "new, improved" DFPZs. Finally, some of the QLG's assumptions concerning crown fire hazards and the infeasibility of prescribed burning were refuted by SNEP analyses. The SNEP case for fire reintroduction through area-wide prescribed understory burning is far stronger than the claims made about DFPZs.

DFPZs IN THEORY

Among the SNEP fire scientists, Weatherspoon and Skinner are the strongest advocates for DFPZs. Most of their support for DFPZs was based on the assumption that these new kind of fuelbreaks would overcome the problems of past fuelbreak designs and programs. The authors desired to distinguish DFPZs from fuelbreaks because fuelbreaks "tend to carry some undesirable connotations" and "do not include some of the potential benefits we envision for DFPZs." Weatherspoon and Skinner critique past fuelbreaks, and in so doing, reveal many of the flaws of the QLG Plan and the QLG Bill. One of the most critical flaws of the QLG Bill is that it fails to authorize or appropriate funding for longterm monitoring and maintenance of these cutover sites. The Forest Service has historically failed to perform these responsibilities in past fuelbreak programs in the Sierras. This is a problem that apparently will continue into the future since the Cal Owl Federal Advisory Committee Report criticized the Cal Owl RDEIS for its assumption that once DFPZs were cut the agency did not plan to maintain them. Numerous publications have warned that fuelbreaks must have long-term maintenance for brush control, otherwise the DFPZs will revert to a more hazardous vegetation type.

Weatherspoon and Skinner's support for DFPZs also reveals the flaws in the strategy of the QLG Plan. The QLG's vision for DFPZs is fundamentally tied to commodity timber outputs; hence, the DFPZ network would be located adjacent to existing logging roads in areas where lumber-grade timber is conveniently (and profitably) accessible by heavy mechanized equipment. Weatherspoon and Skinner, on the other hand, prefer that DFPZs be located in the upper third portion of slopes in areas of naturally lighter fuels. These areas not only give firefighters the greatest opportunity for containing wildland fires, but they also allow "the biggest bang for the buck," meaning that more acres can be treated with less economic costs.

Weatherspoon and Skinner believe that alternative priority sites for DFPZs would be in the lower elevation foothill zone near the urban-wildland intermix, where the hazards and risks of wildfire are greatest. Both high- and low-elevation sites tend to have the least amount of lumber-grade timber available. Although Weatherspoon and Skinner do make several statements about using commercial harvest in order to help pay for DFPZ construction, their interest is tied to reducing fire and fuel hazards first, not timber extraction first. If sufficient funding were made available to construct DFPZs without the need to do commercial logging, it is doubtful that they would promote it to the extent the QLG does.

Two other papers in the SNEP Report analyzed the effects of DFPZs on potential fire behavior through the use of computer simulations. Van Wagtendonk's paper noted that "most land-management agencies generally prefer zones where fuels are reduced with prescribed fires." He then compared DFPZs (as designed by the QLG and the Cal Owl RDEIS) to a host of other fuels treatments, including prescribed fire. His findings were that "The prescribed-burn treatment without any overstory thinning produced the lowest average values for rate of spread, fireline intensity, and flame length." The maximum rate of spread was only ten feet per minute, and the maximum fireline intensity was reduced by 95% because crown fuels did not ignite. Indeed, in areas where only prescribed fire was used for fuels reduction, wildfires did not torch, crown, or spot. This data directly contradicts the QLG's belief that prescribed burning without "mechanical pretreatment" (e.g. commercial logging) would be impossible because it would immediately leap into the crowns and set off a raging inferno.

Van Wagtendonk also modelled the effects of DFPZs on fire behavior. Fire behavior within the DFPZs was modified sufficient enough for firefighters to be able to contain the fire--provided that firefighters were available on site when the fire reached the DFPZs. In the thinned overstory and grassy fuels of the DFPZs, the peak rate of fire spread was nearly 25 feet per minute, meaning that fire could spread across the quarter-mile wide DFPZs in less than an hour. Van Wagtendonk concluded that DFPZs alone would not be able to stop all wildfires without active fire suppression. This point is also reiterated by Weatherspoon and Skinner (and is conceded by the QLG).

Equally important, van Wagtendonk found that fuel reduction in the landscape blocks between DFPZs would be essential to the viability of DFPZs, for without such treatment, fires would spread faster through the landscape than the ability of firefighters to get to DFPZs and build containment lines. Van Wagtendonk concluded that,

It is obvious from this simulation project and from actual experience that fuel breaks alone will not alleviate the spread of wildfire. Although fuel breaks can form effective barriers to a fire during a suppression action if they are cleared of all flammable fuels and if they are wide enough, the time available to defend them is critical to their success. This time can be greatly increased if adjacent fuel treatments are accomplished beforehand. Prescribed burning appears to be the most effective treatment for reducing a fire's rate of spread, fireline intensity, flame length, and heat per unit area. Not only are surface fuels reduced by this treatment, but understory and ladder fuels are reduced to the point where spotting and crowning are not a serious threat.

A point that van Wagtendonk understated was the fact that in all but the most extreme fire weather situation (the 95th percentile) fires burning through previously prescribed-burned areas failed to reach the locations of DFPZs at all! This scenario means that DFPZs would be irrevelant if prescribed understory burning was carried out across the landscape.

The SNEP paper written by Sessions and four co-authors incorporated DFPZs in their development of a computer model to predict fire effects on late-successional stands. The issue of resource "trade-offs" was a key issue they addressed. They stated that, "Creation of fuel breaks can possibly increase the survivability of the ALSEs (Areas of Late-Successional Emphasis)...but at the cost of reducing the LS/OG (Late-Successional/Old-Growth) rank and potentially negatively affecting the functioning of ecological systems within the fuel breaks." (emphasis mine) Given this equation, the trade-off pits an uncertain possibility of increased fire protection against a certain probability of degradation of old-growth forests.

Sessions and his co-authors assumed that, "a fire that kills more than 60% of the basal area in a stand destroys the stand." This conforms to current knowledge of spotted owl biology which defines "severe" wildfire effects as causing 60% or greater overstory mortality on suitable nesting or roosting spotted owl habitat. Consequently, the CASPO Guidelines required a minimum 40% canopy closure and/or 40% basal area to be retained following logging operations. According to the QLG Plan, DFPZs would be "thinned" down to 40% canopy closure (i.e. 60% mortality through removal). Ironically, this is the very threshold defining a severe wildfire! Logging down to the bare minimum does not account for other additional disturbances such as fires, windstorms, disease, and future fire suppression operations, which could remove additional overstory trees and degrade such sites into unsuitable stands for spotted owls. The question arises: what is the benefit of an alleged wildfire protection plan that mimics the very effects of severe wildfires?

THE CASE FOR PRESCRIBED FIRE TO MANAGE FUEL HAZARDS

The QLG Plan has metamorphosed from a simple plea for more timber volume into a complex plan for increased fire protection. The dubious benefits of the QLG "fire protection plan" are corrupted by its dependency on commercial logging to reduce fuel loads. There is no argument with the thesis that past and recent Forest Service practices have created forest health problems, of which two symptoms are increased fire and fuel hazards. But the QLG has misidentified these hazards, has proposed activities that will likely exacerbate these hazards, and has wrongly rejected out-of-hand a proven practice that would effectively protect forests from high-severity fires at the same time it would restore a host of ecosystem components that are suffering from the suppression and exclusion of low-intensity fires.

The prime hazards are not tree canopies or crown fires; rather, they are the high surface fuel loads of untreated logging slash, dead limbs, chaparrel and other flammable brush, coupled with understory saplings and pole-sized trees. These "flashy" and "ladder" fuels feed rapid fire spread and high fireline intensity. Fuels treatments that propose "thinning" the overstory canopy cover not only increase surface fuel loads in the form of new logging slash (perhaps the most hazardous fuel type known), but also change the microclimate, making cutover sites hotter, drier, windier, and prone to encroachment by more flammable vegetation. The result of such fuels treatments are surface fuels which ignite more easily and feed more intense, faster-spreading fires. Though crown fire potential may be reduced by such thinning schemes, the increased fire intensity and rate of spread may still foster stand-destroying wildfires through root and cambium scorch without flames ever reaching the treetops.

Any given forest fire exhibits a variety of fire behavior in ground, surface, and crown fuels, but surface fires constitute the vast majority of wildfires. Fast-moving, high-intensity surface fires are just as capable of overwhelming firefighters as the much more rare phenomena of crown fires. In fact, it is only the surface fuel load of dead fuels three inches in diameter or less and live fuels 1/4 inch in diameter or less that are used in computer models to predict fire spread. Crown fires cannot start or spread without a sufficient load of surface fuels. The reason the agency and the QLG do not advocate for programs to aggressively reduce surface fuel loads as the priority treatment is because there are few commodity outputs and no profitable timber to be extracted from this kind of biomass.

Ironically, using commercial logging to reduce canopy fuels greatly increases fire hazard. Logging removes the main stem or trunk (the most fire-resistant part of a tree), and in so doing, relocates the canopy fuels of needles and limbs (the most fire-susceptible parts of a tree) from the sky where they escape all but the most extreme fires, and dumps them on the ground where they are readily available to burn in surface fires, the most prevalent kind of fire. This "red slash" is the most extreme fuel hazard known, causing fire hazards soar immediately after logging. In dry eastside pine stands, untreated slash can affect fire behavior for up to thirty years following logging. The focus on canopy fuels and crown fire overlooks the primary fuel and fire hazards on the ground surface, and simply reeks of opportunism by bureaucratic and corporate interests more concerned with getting the cut out than putting fires out.

Far from being the nemesis of firefighters or restorationists, dense closed-canopy stands are generally some of the most desirable places to do fire suppression or prescribed burning. The dense crown cover provides vital shade that protects surface fuels from exposure to the sun and wind, thereby keeping fuel moisture levels and relative humidities higher. The effect of such protective cover is to moderate fire behavior so that the controlled use of fire is possible. The QLG assumption that prescribed understory burning would be impossible in the northern Sierra Nevada flatly ignores the voluminous research and actual field experience of such hazard fuels reduction methods, particularly by the National Park Service which has been doing this valuable work in the Sierras for decades.

The only economically and ecologically feasible way to treat surface fuels over a landscape area is through prescribed understory burning. So-called "mechanical" treatments are not designed for small-diameter surface fuels. These machines tend to be confined to low-to-moderate slopes, cause impacts to soil and riparian zones, inflict damage and diseases to retained trees--and most pertinent to the QLG Bill, are far more expensive to use than prescribed burning. Indeed, the Forest Service estimates the QLG Plan would cost $250 per acre (for a total of $70,000,000 according to the Congressional Budget Office), but prescribed burning costs only an average $50 per acre in the Sierras. And although silvicultural treatments can mimic some of the effects of fire on forest structure, virtually no data exist on their ability to mimic the ecological functions and processes of natural fire. The fact is, there are no known mechanical or silvicultural surrogates for the array of ecological benefits--some known and many yet to be discovered--that are produced by fire. Larger areas can be treated in shorter timeframes at lower costs with less environmental impacts using prescribed fire. This would perhaps best fulfill the mandates of the QLG Bill to "use the most cost-effective" means available."

The QLG strategy of DFPZs allegedly "protects" forests by perpetuating the same discredited fire control and fire exclusion practices of the past. Prescribed understory burning, on the other hand, both protects and restores the ecosystem at the same time. A thought worth pursuing would be to implement something like DFPZs by using prescribed understory burning instead of commercial logging. A similar idea was advocated by the CASPO fire and fuels specialists, who urged that spotted owl habitat be protected from stand-destroying wildfires by "fuelbreaks" created through bands of prescribed understory burning. This technique was also endorsed by SNEP scientists as an appropriate fire protection strategy. It has also been successfully practiced for years in Lassen Volcanic National Park. In areas where site-specific analysis deems that entry burns would be too risky, then manual pretreatment methods (e.g. pruning, hand-piling, etc.) could be used to prepare sites for safe and efficient burning. Manual pretreatment and prescribed burning would also involve far more jobs than "mechanical" treatments using fellerbunchers and skidders. These kind of strategic fuel treatments would preferably be called something different than DFPZs because the proper management paradigm would not be based on a "defensive" strategy of fire control, but rather, a "proactive" strategy of fire use for forest ecosystem restoration.

CONCLUSION

The QLG began their six-year quest to change the Forest Plans of the Lassen, Plumas, and Tahoe National Forests based on assumptions that have since proven to be false. Immediately following the establishment of the CASPO Guidelines in1993, the QLG stated that,

The communities of Susanville, Chester, Quincy, Loyalton, Bieber, and Greenville are highly dependent upon the forest products industry and may not survive the current reductions in Federal timber harvests."

Countering such "doom and gloom" pronouncements still being perpetrated by timber industry propagandists, the SNEP studies discovered that communities in the Sierra Nevada region are in fact attracting new residents who are bringing human and financial capital with them, and are generating new employment opportunities. These newcomers are diversifying the local economies away from overdependency on resource extraction industries. They are moving to the region in large part because of the scenic and recreational amenities provided by the natural environment. These amenities would be degraded by the amount and kind of commercial logging mandated by the QLG Bill, which would subsidize the corporate timber industry at the expense of these other growing sectors of the economy.

The second erroneous assumption by the QLG was that fires were becoming larger, more destructive, and "all-consuming." Accordingly, the QLG believed that if nothing were done immediately, then the region would have to "learn to deal with repeated 50,000+ acre blocks of charcoal and baked soil," among other effects of so-called catastrophic wildfire. This kind of fear-mongering runs contrary to the factual analysis presented in the SNEP Report which concluded that,

Frequently...the assertion is made that current fires burn much larger contiguous areas at high intensities, resulting in a larger proportion of the burned area suffering severe fire effects. We have no direct data to support these assertions.. (emphasis mine)

On the contrary, in the heart of QLG country, the SNEP Report discovered that, "the Plumas National Forest has had no change in the observed size and frequency of fires during this century." SNEP scientists gently chided such claims about increasing fire size and intensity as products of "the vagaries of memory and human judgement about individual (fire) events." The QLG is thus pushing an alleged fire protection plan that is based on erroneous beliefs about the fire behavior of the past, present, and foreseeable future.

Certainly, such events as the devastating Fountain Fire traumatized local communities. However, it must be remembered that the Fountain Fire burned mainly on private industrial timberland which had been heavily logged and roaded prior to the fire. In spite of--or more likely because of--the intensive "fuels reduction" activities associated with commercial logging, the Fountain Fire was truly catastrophic in its effects. Again, the question arises: should forest management policies be based on such rare, extreme events, and should the management practices that contribute to such fires be allowed to continue? It is not enough for the Forest Service to admit the mistakes of its "past" policies and practices if it insists on continuing those policies and practices. And even "kinder, gentler" commercial logging still inflicts environmental impacts such as eroded topsoil, degraded water quality, destroyed wildlife habitat, and extirpated species that are every bit as much symptoms of forest health problems as large-scale, severe wildfires.

The QLG is not alone in feeling frustration over Forest Service mismanagement of public lands, but no other group of 30 people are able to rewrite the Forest Plans of three National Forests according to their own desires. Both the American people and the professional wildland fire community deserve a more open, democratic process to discuss and debate strategies for reducing the fire and fuel hazards in the National Forests of the Sierra Nevada. And after spending millions of dollars creating the SNEP Report, it seems wise to use its information, not ignore it or opportunistically select out statements clearly worded as assumptions, values, or goals which run contrary to factual research findings. The QLG Plan has much more to do with timber extraction than with genuine fire protection, and in that respect, it constitutes more of a forest health threat than a real solution.

The QLG Bill resembles similar "panic legislation" that was passed during the early 1970s in which, following some large-scale wildfires in California, Congress allowed the Forest Service to access emergency firefighting funds to conduct "presuppression" timber sales. Many fuelbreaks were cut in the Sierras during this period, and while costs rapidly rose into tens of millions of dollars, most of these fuelbreaks failed to perform adequately during wildfire suppression incidents. Congress quickly had to take away this funding source from the Forest Service. What has become of these old fuelbreaks? Almost without exception, the agency failed to monitor or maintain them, and in a modern-day version of "cut and run" logging, many of these old fuelbreaks have converted to chaparral brush and "dog-hair" thickets--a much more flammable vegetation type than the original forest cover. The QLG Bill appears to be 'deja vu' without evidence of Congress or the QLG being aware of this history of previous fuelbreak programs.

The QLG fuelbreak strategy represents a giant step backwards from the progressive development of rational fire policies established by the 1995 Federal Wildland Fire Management Policy and Program Review. Among 83 new policies developed by the federal government's top fire and fuels management specialists are commitments to ensure firefighter and public safety on all wildland fires, reintroduce fire into fire-dependent ecosystems, and educate the public and agency employees about the beneficial uses and ecological role of fire in land management. The fact that the QLG admits that its Plan is inconsistent with these new policies--indeed, is almost gleefully defiant of them--says a lot about the credibility of the QLG's self-purported fire management expertise.

It is also shocking that Congress passed an alleged fire protection Bill without ever consulting the professional wildland fire community, particularly ground-level firefighters, in whose name this logging-for-firefighting boondoggle would be waged. Since passage of the QLG Bill in the House of Representatives, concern has been raised by firefighters, environmentalists, and taxpayers about the potential human, ecological, and economic costs of this legislation. Some of the nation's most prestigious newspapers have voiced strong opposition to the QLG Bill, as well. Citizens and legislators truly concerned about the long-term sustainability of forest ecosystems and human communities in the Sierra Nevada and throughout the West, should vigorously oppose the QLG Bill.

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The New York Times (1997); "Avoiding Adjournment Blunders;" (November 12).

The Washington Post (1997); "Hacking Down the Forest;" (October 26).

USDA-FS (1993); "Decision Notice and Finding of No Significant Impact for California Spotted Owl Sierra Province Interim Guidelines;" Pacific Southwest Region; Albany, CA.

-----; (1996); Managing California Spotted Owl Habitat in the Sierra Nevada National Forests of California: An Ecosystem Approach; Draft Revised Environmental Impact Statement; Pacific Southwest Region; Albany, CA.

-----; (1997); "Forest Ecosystem Restoration and Protection Project;" Lassen National Forest Supervisor's Office; Susanville, CA (unpublished draft).

USDOI/USDA (1995); Federal Wildland Fire Management Policy and Program Review, Final Report; (December 18).

van Wagtendonk, Jan (1996b); "Use of a Deterministic Fire Growth Model to Test Fuel Treatments;" Sierra Nevada Ecosystem Project: Vol. II: Assessments and Scientific Basis for Management Options; Centers for Water and Wildland Resources; University of California at Davis.

Verner, Jared; McKelvey, Kevin; Noon, Barry; Gutierrez, R.; Gould, Gordon; and Thomas Beck (1992); "The California Spotted Owl: A Technical Assessment of its Current Status;" USDA-FS Gen. Tech. Rep. PSW-GTR-133; Albany, CA.

Weatherspoon, Phillip; Husari, Susan; and Jan van Wagtendonk (1992); "Fire and Fuels Management in Relation to Owl Habitat in Forests of the Sierra Nevada and Southern California;" In Verner, Jared; McKelvey, Kevin; Noon, Barry; Gutierrez, R.; Gould, Gordon; and Thomas Beck; The California Spotted Owl: A Technical Assessment of its Current Status; USDA-FS Gen. Tech. Rep. PSW-GTR-133; Albany, CA.

Weatherspoon, Phillip (1996b); "Fire-Silviculture Relationships in Sierra Forests;" Sierra Nevada Ecosystem Project: Vol. II: Assessments and Scientific Basis for Management Options; Centers for Water and Wildland Resources; University of California at Davis.

Weatherspoon, Phil; and Carl Skinner (1996b); "Landscape-Level Strategies for Forest Fuel Management;" Sierra Nevada Ecosystem Project: Vol. II: Assessments and Scientific Basis for Management Options; Centers for Water and Wildland Resources; University of California at Davis.

Yost, Michael (1997); letter to Ed Marston, Editor of the High Country News; (November 24).