Ecological assessments should be the first step towards developing strategic plans for prioritizing sites needing fuels treatments, and are absolutely required prior to implementing fuels reduction or restoration projects.

Problems exist with over-generalizing the effects of fire exclusion, and misapplying data derived from short-interval forest ecosystems (e.g. ponderosa pine stands) to long-interval forest ecosystems that have not missed their fire cycles yet and are still within their historic range of variability for stand-replacing fire events (e.g.  high elevation lodgepole pine or fir stands).  Fire/fuels management prescriptions should reflect current conditions, and there should be no treatments without prior collection of site-specific field data.  This data should include research on local fire history, quantitative data on fuel loads, qualitative assessments of fuel profiles, population studies of vegetation and wildlife, and measures of soil and water quality.

ECONOMIC ASSESSMENTS SHOULD BE REQUIRED PRIOR TO FUELS REDUCTION OR WILDFIRE PROTECTION PROJECTS IN THE WILDLAND/URBAN INTERFACE ZONE

Economic assessments should be conducted to determine the most cost-effective and environmentally-sound means of implementing fuels reduction and wildfire protection projects in the wildland/urban interface zone.  Cost effectiveness criteria should be based on management methods that have the least net expenditures to taxpayers, not the most gross revenues to federal agencies.  For example, so-called hazardous fuels reduction projects which are designed as commercial timber sales often result in net deficit losses to the federal treasury.  Moreover, projects should not have environmental costs externalized to the ecosystem or future generations.  So-called mechanical treatments that rely on heavy equipment often cause long-term environmental impacts such as soil compaction and erosion, and can spread invasive weeds, which then require costly restoration treatments.

Economic assessments should also examine the local capacity of communities to supply labor and equipment needed for federal projects.  Projects should be designed on a scale that does not exceed the capacity of local communities and small companies to provide labor and equipment.  Projects designed at an appropriate scale will maximize economic benefits within those communities.  In many cases, the most cost-effective methods for reducing wildfire risks to the urban interface zone might be to fund homeowner fire prevention education, provide technical assistance for fuels management on private lands, and subsidize low-interest loans for home reconstruction projects that would replace flammable materials with non-flammable materials (e.g.  replace cedar shake roofs with metal roofs).

THE WILDLAND/URBAN INTERFACE ZONE NEEDS TO BE DEFINED AND MAPPED BASED ON THE BEST AVAILABLE SCIENCE ON HOME IGNITABILITY FACTORS

According to Jack Cohen, research scientist at the Forest Service's Fire Sciences Lab in Missoula, Montana, removing fuels from within 40 meters of a structure and reducing the flammability of structures are more effective and efficient methods than landscape-wide thinning to reduce home losses from wildfire.  Fuels reduction treatments carried out beyond 40 meters of structures are ineffective because they do not reduce the ignitability of homes from firebrands, and are inefficient because they are greater than necessary to prevent home losses from wildfire.  Accordingly, the wildland/urban interface zone should be a relatively narrow band approximately 200 feet surrounding communities and should not include expansive areas several miles radius outside of rural communities.
Also, the wildland/urban interface zone should be defined as urban, suburban, and rural areas directly adjacent to wildland areas with population densities exceeding 400 people per square mile.  The intermix zone with population densities typically less than 400 people per square mile should not be the focus of fuels treatments on public lands, but instead, homeowners could receive technical assistance to help make their private properties and structures more fire-resistant.

Finally, states and local communities should take responsibility for fire protection of private homes by developing zoning to prevent new housing construction in fire-prone wildlands, building codes to reduce home ignitability factors, laws mandating private lands fuels management, and educational programs to help create "firewise" communities.

COMMERCIAL TIMBER SALES AND STEWARDSHIP CONTRACTS THAT TRADE FOREST GOODS FOR LABOR SERVICES SHOULD BE PROHIBITED

Fuels reduction and forest restoration projects should prohibit the use of commercial timber sales and so-called stewardship contracts.  The primary problem with thinning projects that rely on commercial incentives is that larger trees are logged and excessive amounts of biomass are extracted in order to generate profits for private contractors.  Banning commercial logging and the use of goods-for-services stewardship contracts will remove financial incentives for abusive logging under the guise of thinning.  Any material of commercial value that must be extracted must be sold in a separate contract, and all revenues must be returned to the federal treasury.  All fuels reduction and forest restoration projects should be viewed as public "investments" in forest health and ecosystem restoration, and thus should be paid for with appropriated dollars.  In general, the most appropriate method for federal agencies to implement fuels reduction and forest restoration projects would be through service contracts that hire local workers.

LOGGING OF OLD-GROWTH, ENTRY INTO ROADLESS AREAS, AND HARM TO ENDANGERED SPECIES HABITAT SHOULD BE PROHIBITED FROM FUELS REDUCTION PROJECTS

Fuels reduction projects that extract old-growth trees, enter into roadless areas, or degrade habitat for endangered species should be prohibited.  In general, old-growth and mature trees are the least flammable trees in the forest, and the consequences of commercial logging is often to increase fuel hazards and fire risks.  The 1996 Sierra Nevada Ecosystem Project's Final Report to Congress highlighted the fact that, "Timber harvest, through its effects on forest structure, local microclimate, and fuels accumulation, has increased fire severity more than any other recent human activity."
Specifically, commercial extraction of large-diameter and old trees increases small-diameter surface fuels accumulation from the logging slash, and makes the microclimate hotter and drier by increasing surface temperatures and winds.

According to the scientific assessments for the Interior Columbia Ecosystem Management Project (ICBEMP), watersheds that have the highest forest integrity values were largely unroaded; conversely, watersheds that had been intensively roaded typically had the lowest forest integrity.  Forest integrity was strongly associated with the efficacy of fire exclusion, the intensity of timber management, and the degree to which succession/disturbance regimes have changed.  Thus, roadless areas are generally some of the most fire-resilient areas because they have experienced the least intensive timber management and less efficient fire suppression.

The ICBEMP analyses also determined that, "The high rate of human-caused fires has generally been associated with high recreational use in areas of higher road densities." Thus, entering roadless areas with new or so-called "temporary" roads to implement mechanical fuels reduction treatments also increases the risks of human-caused wildfires.
Habitat destruction from intensive timber management and associated road construction are two of the prime causes of decline in species populations and their listing under the Endangered Species Act as threatened or endangered.  Fuels reduction treatments that cause harm to endangered species habitat are therefore counterproductive since they degrade some of the values that such treatments allegedly seek to protect.

FUELS REDUCTION SHOULD BE VIEWED AS A MEANS FOR ECOSYSTEM RESTORATION; IT SHOULD NOT BECOME A GOAL OR ENDPOINT FOR MANAGEMENT

Fuels reduction should be clearly recognized as a means of attaining the goals of ecosystem restoration and protection-but fuels reduction should not become a management goal or ends in themselves.  The U.S.  Forest Service should avoid making fuels reduction the next reductionism in forest management.  Accordingly, all fuels reduction strategies and projects should be developed with inter-disciplinary teams of resource specialists to ensure that all the ecological components, functions, and processes of forest and grassland ecosystems are fully considered and are not further degraded from management activities.

Managers should strongly consider proactive restoration projects that prevent fuel hazards and fire risks.  For example, wildfires are almost twice as likely to occur in roaded areas than in roadless areas; consequently, road decommissioning and obliteration would greatly reduce human-caused wildfires.  Overgrazing has been a prime causal factor in shifting natural fire regimes from those characterized by frequent, low-severity fires to those now experiencing infrequent, high-severity fires.  Managers should strongly consider permanently retiring vacant grazing allottments in order to restore grass and herbaceous communities needed as fuel for low-intensity prescribed and wildland fires.  Invasive weeds like cheatgrass are responsible for shifting fire regimes in grassland communities and causing unnaturally severe fires in desert ecosystems.

Managers should strongly consider projects that eradicate invasives (preferably with prescribed fire treatments), and should not approve new projects that pose risks of spreading invasives.

In sum, fuels reduction treatments should be an important component of an integrated program that seeks long-term restoration and protection program of all ecosystem components, functions, and processes.

SITE-SPECIFIC ENVIRONMENTAL SAFEGUARDS NEED TO BE APPLIED IN ORDER TO PREVENT FURTHER ECOLOGICAL DEGRADATION UNDER THE GUISE OF "RESTORATION"

Many recent Forest Service "restoration" projects that rely on commercial thinning, temporary road construction, and intrusion into riparian zones have been justified as alleged tradeoffs pitting short-term impacts for dubious long-term benefits.  Environmental safeguards such as diameter limits and riparian buffers should be included in fuels reduction treatments to ensure that restoration projects are not simply justifying business-as-usual resource extraction and ecosystem degradation.  All projects should be grounded in site-specific ecological analysis of each proposed treatment area.  Thus, for example, the twelve-inch diameter limit proposed by Chief Mike Dombeck may be appropriate for some forest stands but not for other stands depending on the age, structural and spatial characteristics, and wildlife uses of trees less than twelve inches in diameter.

ALL FUELS REDUCTION AND FOREST RESTORATION PROJECTS SHOULD COMPLY WITH ALL APPLICABLE ENVIRONMENTAL LAWS, REGULATIONS, STANDARDS AND GUIDELINES, AND BE BASED ON THE BEST AVAILABLE SCIENCE AND PUBLIC INVOLVEMENT

There should be no repeat of the "Salvage Logging Rider" or other legislation that would mandate logging levels and/or exempt federal projects from fully complying with all environmental laws, agency regulations, and standards and guidelines.  Additionally, fuels reduction and forest restoration projects should utilize the best available science and full public involvement at each stage of the planning and citizen oversight process.

PRESCRIBED FIRE TREATMENTS AND MANUAL PRE-TREATMENTS SHOULD BE PRIORITIZED OVER MECHANICAL FUELS REDUCTION TREATMENTS
Prescribed fire treatments should be prioritized for fuels reduction projects since these are the most ecologically and economically sound methods for reducing hazardous fuels.  In general, hazardous fuels are small-diameter dead surface fuels and understory live vegetation such as grass, brush, saplings, and pole-sized trees.  There is no mechanical surrogate or technological substitute for the full array of ecological functions and benefits that fire provides.  Carefully planned prescribed fire is the most practical and most natural means for reducing small-diameter understory fuels.  Where necessary, manual pre-treatments such as hand-piling, pruning lower limbs, limbing and bucking downed logs, and raking fuels away from and ring-lining trees (especially habitat snags)
may be included to help ensure that prescribed burns are controllable and stay within their desired boundaries and environmental effects.

Mechanical treatments that utilize heavy equipment are more expensive on a per-acre basis, and can cause adverse environmental impacts such as soil compaction, sedimentation into streams, and spread invasive weeds.  Mechanical treatments should be considered only where existing fuels conditions and nearby values at risk would make prescribed fire too risky for an initial treatment.  In such cases, mechanical fuels reduction treatments should be followed by prescribed fire wherever possible in order help restore fire to its natural role in limiting fuels accumulations and stimulating native plant regeneration.

In general, prescribed fire is the superior fuels reduction method because it both protects sites from future severe wildfires and restores sites from the adverse effects of past fire exclusion.

THE FOREST SERVICE SHOULD BE REQUIRED TO IMMEDIATELY AND FULLY IMPLEMENT THE FEDERAL WILDLAND FIRE MANAGEMENT POLICY AND DEVELOP COMPLIANT FIRE MANAGEMENT PLANS

The Forest Service should be required to immediately and fully implement the
1995 Federal Wildland Fire Management Policy ("Fire Policy").  As a whole, the Forest Service has yet to begin implementing the Fire Policy and its most important provision to develop new fire management plans for each acre of federal land containing burnable vegetation.  Without such fire management plans that comply with the Fire Policy, the agency must resort to aggressive initial attack and full suppression against every wildland fire, with all the environmental impacts, economic costs, and risks to firefighters that come with aggressive suppression actions.  According to the Fire Policy and statements by high-level officials, these new fire management plans must utilize the best available science and public involvement at each stage in the planning process.

Department of Interior agencies, particularly the National Park Service, have been investing resources in implementation of the Fire Policy.  Accordingly, the NPS has been aggressively engaged in fire management planning, hiring and training fire personnel, public education programs on the natural role of fire, and has been implementing landscape-scale prescribed fires without commercial or mechanical treatments.  The Forest Service needs to perform its share of responsibility for proper fire/fuels management, and must fulfill its obligations to comply with the interagency Fire Policy.  Full and immediate implementation of the Fire Policy and development of new fire management plans would help the agency to develop a "cohesive strategy" for restoration of fire-dependent ecosystems, and prevent further ecosystem degradation from aggressive suppression and fire exclusion.  Until new fire management plans are completed, the agency should limit aggressive suppression actions and practice minimum impact suppression tactics (MIST) whenever and wherever possible, especially in sensitive habitats, riparian zones, roadless and wilderness areas.

Timothy Ingalsbee, Ph.D.
Director, Western Fire Ecology Center
P.O.B.  51026
Eugene, OR 97405
(541) 302-6218 fire@efn.org