INTRODUCTION

From September 4-12th, 1997, I traveled through the northern Sierra Nevada in order to better understand the possible social and ecological consequences of Senate bill 1028. I interviewed a number of federal fire scientists and fuels managers, private foresters, local environmentalists, and members of the Quincy Library Group. I also gathered official documents, took photographs, and purchased maps relating to the proposed project. Perhaps the most important data source was the opportunity to observe the condition of the landscape and walk the ground of proposed timber sale units.

From 1980 to 1990 I was employed as a firefighter for the U.S. Forest Service and National Park Service. I did graduate research in fire ecology and fire management on my way to earning a doctoral degree from the University of Oregon. I have been a fire ecology educator for the last six years, and have produced several publications and conference presentations on fire ecology and fire management issues. From my personal background, and my recent field research in the forests covered by S.1028, I have come to the conclusion that significant ecological damage and community harm would occur from implementation of this bill. For the reasons explained below, I believe citizens and legislators concerned for the long-term health and sustainability of the National Forests and forest-dependent communities in California (and throughout the West) should vigorously oppose S.1028.

PROBLEM: S.1028 SACRIFICES FOREST HEALTH FOR A FAILED FIRE SUPPRESSION STRATEGY

S.1028 represents an outdated fire philosophy that is based on the suppression tactics developed during the 1930's, and the pre-suppression fuels management strategies developed during the 1950's. During this latter period, over two thousand miles of fuelbreaks were constructed throughout the Sierra Nevada as part of a Cold War era Civil Defense program to prepare for "conflagration control" in the event of thermonuclear warfare. This program was abruptly ended in the early 1970's because these fuelbreaks were too costly to implement and maintain, and more importantly, because in all but a few incidents they did not work during actual forest fires.

The Forest Service currently lacks any scientific evidence to support its claim that shaded fuelbreaks allow safe, efficient firefighting, or will protect forests from fire. On the contrary, there is a large body of research making the opposite conclusion. For example, the research of Dr. Omi (1996), Director of the Western Forest Fire Research Center and the nation's top scholar of fuelbreaks, reveals that the agency has no documentation proving any reductions in wildfire losses with the use of fuelbreaks. Dr. Omi concludes that a broad landscape system of fuelbreaks (such as proposed by S.1028) cannot be economically justified. Other studies (e.g. Davis, 1965; Deeming, 1990) have not only criticized the poor economics of fuelbreaks, but noted the controversial nature of their impacts on biological and scenic resources.

S.1028 fails to address the repeated failures of past fuelbreak programs. Rather than "protect" the forest from fire, the new fuelbreaks would actually add to the existing groundfuel hazard, increase the intensity and severity of future fires, pose risks to firefighter safety, and increase the risk of large-scale, severe wildfires. In the name of firefighting efficiency, the construction of fuelbreaks would cause impacts to the very values of the forest---wildlife habitat, water quality, recreational opportunity, scenic beauty, and community stability---for which S.1028 claims to be protecting and restoring. In effect, S.1028 would sacrifice forest ecosystem health in exchange for a misguided, failed fire protection scheme.

PROBLEM: S.1028 WOULD INCREASE FUEL HAZARDS

The landscape of the northern Sierra Nevada already suffers from excess groundfuels in the form of heavy slash left untreated from previous logging, and dense thickets of brush growing in cutover, managed stands. S.1028 offers no plan to remove this load of slash and brush; instead, S.1028 focuses strictly on the removal of new green trees. This would add even more groundfuels in the form of new slash and stumps. Additionally, S.1028 does not discuss how it plans to fund long-term maintenance of the fuelbreaks. The failure of all prior shaded fuelbreak programs in California has been their inability to control brush from colonizing the exposed, disturbed logging sites. Slash mixed with brush, particularly "chaparral" species like manzanita, is an extremely flammable fuel load that will increase the hazard and risk of severe wildfires. An authentic fire protection plan would seek ways to reduce this fuel type, not add to it, as S.1028 would do.

PROBLEM: S.1028 WOULD INCREASE FIRE INTENSITY AND SEVERITY

S.1028 plans to use commercial logging to reduce tree canopy cover to 40% or less. This reduction in crown closure would change microclimatic conditions in ways that feed intense fires. Groundfuels would be exposed to more sun and wind, causing them dry out earlier in the spring and sooner after rainstorms. Dr. James Agee's (1996) research has demonstrated that reducing groundfuels is the most effective treatment to prevent crownfires, while thinning tree canopies results in hotter, drier, windier conditions on the ground surface. With higher temperatures, lower humidities, and stronger winds, surface fires burn intensely and spread rapidly. The high heat column from slash-and-brush fires can ignite crownfires even when flame lengths fail to reach lower limbs or climb ladder fuels. And slash-and-brush fires cause root-scorch that can kill large old-growth trees even if their canopies do not ignite.

Assuming that slash treatment does occur in the future (a huge assumption given the agency's abysmal track record), then burning the huge hand- or machine-piled mounds of slash generated by new logging would cause severe fire effects by essentially sterilizing the soil. Finally, using fuelbreaks to light backfires during firefighting incidents would cause severe burning of adjacent forest stands since they would be lit during extreme fire weather conditions. Often, the objective of backfires is 100% consumption of the vegetation from ground to crown, thereby sacrificing trees to stop fires. The impacts and uses of these fuelbreaks would thus increase fire intensity and severity---the very opposite effects S.1028 claims to achieve.

PROBLEM: S.1028 WOULD RISK FIREFIGHTER SAFETY

Proposed fuelbreaks are located alongside existing logging roads. These roads were built to access timber sales, not to aid fire suppression. Thus, roads in the Sierra Nevada commonly switchback up steep slopes, cut across mid-slopes, follow stream courses at the bottom of narrow canyons, and run through previously cutover areas where units are covered with slash, brush, and plantations. Firefighters staged in these fuelbreaks will either have to apply direct attack strategies and march down into steep drainages to fight fires below them (one of the most dangerous maneuvers in firefighting), or they will have to apply indirect attack strategies and wait for the fires to reach their control lines. In either case, firefighters would be at risk from being overrun by wildfire in the kinds of extreme fire behavior situations that are used to justify the fuelbreaks.

S.1028 fails to prioritize treatment of the principal hazardous fuel load---slash and brush---and fails to provide long-term funding mechanisms for maintenance of the fuelbreaks. If new slash is untreated and new brush is allowed to grow, then these fuelbreaks will be extremely unsafe and inefficient areas for firefighting crews. The vast majority of firefighting fatalities have occurred from fires burning through thick brush, not closed canopy forests. The claim that adjacent roads will allow speedy evacuations of crews will likely tempt some fire bosses to put firefighters into risky situations that demand such emergency retreats. S.1028 perpetuates the myth of human ability to control extreme fire behavior, and puts firefighters at risk from the agency's futile attempts to live up to this myth.

PROBLEM: S.1028 WOULD INCREASE ROAD-BUILDING

An internal agency document yet to be released to the general public offers preliminary analysis of the kinds of environmental impacts that would occur from implementing S.1028. At the top of the list of impacts is the revelation that 117 miles of new logging roads would have to be constructed in order to fully develop the fuelbreaks. Additionally, permanent roads and temporary skid roads would need to be built to gain access to the several thousand "group selection" (i.e. clearcuts) sites in the Fuel Reduction Zones (FRZs) adjacent to fuelbreaks. Both the amount and density of roads would greatly increase, causing adverse effects to fish and other wildlife habitat, water quality, soils, and scenic resources. Moreover, the fragmentation and edge effects of existing roads would be greatly magnified by the substantial amounts of vegetation removal required for construction of fuelbreaks. Habitat for spotted owls, flying squirrels, bear, and deer, for example, would decline due to the loss of hiding cover, thermal cover, and forage. Also, negative impacts would occur from illegal activities that are routinely conducted alongside logging roads, such as wildlife poaching, timber theft, garbage dumping, and forest arson. The desire to restrict new road-building and remove old logging roads is prevalent among the public and members of Congress. Regardless, S.1028 is utterly dependent upon a quantumfold increase in the amount, density, and impacts of logging roads.

PROBLEM: S.1028 WOULD INCREASE FIRE RISK

Roads are known conduits of human-caused fires. Proposed roadside fuelbreaks would increase human access and mechanized activities within timber sale units. This would lead to increased risk of accidental fires caused by logging and road-building activities, as well as from careless recreationists. It would also lead to increased intentional fires lit by Forest Service firefighters. One of the main purposes of fuelbreaks is to light backfires during wildfire suppression incidents. Backfires used to be a rare, desperate tactic because they cause considerable damage and inevitably add more burned acreage to a forest fire. But in recent years they have become almost a standard, routine practice. Backfires are ignited in the worst of all possible fire conditions; consequently, they often escape control, jump over firelines, and sometimes create separate wildfires of their own. The truth of the matter is that these fuelbreaks are not going to stop severe wildfires, but are places the agency intends to start backfires.

The risk of large-scale, severe wildfires will inevitably increase due to the changed microclimatic conditions and fuel loads left in the wake of logging, as well as the management activities planned for the fuelbreaks---logging, road-building, and firefighting. The Achilles heel of S.1028 is the lack of a provision for funding long-term brush maintenance of the fuelbreaks, and lack of funding for fuels reduction within the landscape blocks between fuelbreaks. Without these two essential components of a hazard fuels reduction program, S.1028 would fail to address the real fire hazards today--slash, brush, and plantations. The fuelbreaks would defy the ability of firefighters to safely and efficiently use them during extreme fire events, and ironically, would only prime the pump for future severe fires. S.1028 does not protect forests or restore ecosystem health, but merely continues the agency's failed logging and firefighting policies of the past.

PROBLEM: S.1028 WOULD CAUSE COMMUNITY INSTABILITY

S.1028 claims to promote economic stability for the local community by mandating a five year period of accelerated logging. In recent years, job losses have occurred in the timber industry both through outright mill closures and the automation of logging and milling processes. This modernization has resulted in more wood being processed by fewer workers. Thus, while the old Sierra Pacific Industries mill in Quincy, California employs over 250 people, the new SPI mill employs just 7 (seven) workers per shift. And whereas formerly a crew of ten could be used to fell and yard trees on a typical timber sale unit, now mechanical harvesters (i.e. "fellerbunchers") need only 1 (one) worker to run these logging machines. Many of the roadside fuelbreaks, particularly on the eastside, would be logged by fellerbunchers.

Local foresters admit that the pace and scale of logging mandated by S.1028 would exceed the current capacity of local falling and hauling contractors. This would require the agency to go outside the region and import contractors to get the cut out. There is no promise that after the five year period is over for this "pilot project," the program will be continued; thus, S.1028 appears to feed into yet another "boom and bust" cycle which has been the history of the timber industry throughout the West. After the logging capacity has been artificially inflated to fulfill the ambitious cutting goals set by S.1028, there may be pressure to continue the program for "economic stability" even if the environmental effects prove to be costly.

The stability promised by S.1028 comes at a time when the region has already experienced and will continue to undergo economic change. Existing local businesses have learned to diversify their products and services, and the area continues to experience population growth. As the Sierra Nevada Ecosystem Project (SNEP) studies noted (e.g. Duane, Kusel), these newcomers are bringing human and financial capital with them, and are generating new employment opportunities in the region. The new immigrants are attracted to the area because of the recreational and scenic amenities provided by the region's natural environment---amenities that will be degraded by the scale of logging proposed by S.1028. Short-term stability should not come at the expense of long-term sustainability, and S.1028 favors one sector of the economy above all others, including southern California water users, dependent on a healthy forest ecosystem.

S.1028 CONFLICTS WITH FEDERAL FIRE MANAGEMENT POLICIES

The whole concept of "defensible" fuel profile zones continues the agency's adherence to the damaging practice of "fighting" forests to suppress fires. Ironically, each successful "battle" over blazes has only intensified the fury of subsequent fires in this never-ending, unwinnable "war" against Nature. The Forest Service now readily admits that aggressive firefighting has led to the kinds forest health problems that S.1028 claims to be solving, yet it provides no alternative to the treadmill of mismanagement that annually wastes millions of tax dollars and priceless natural resources on firefighting spectacles.

While S.1028 is based on the discredited fire suppression philosophy, tactics, and strategies of the past, it also stands in contradiction with recent revisions of fire management policies. The new Federal Wildland Fire Management Policies affect all land management agencies in the Departments of Interior and Agriculture. The interagency body that created the new policies admitted some vital truths: not all fires can or should be suppressed, and during large-scale, severe wildfire incidents, it is only a change in the weather that enables firefighters to "control" these kinds of fires. Among over 80 new fire management policies is the call to reeducate the general public and Forest Service employees about the ecological role and positive uses of fire. The new federal policies strongly advocate the use of prescribed fire from both natural and managed ignitions in order to promote forest ecosystem health, and to prevent the environmental, economic, and human costs of fire suppression.

SOLUTION: IMPLEMENT UNDERSTORY PRESCRIBED BURNING

Hazard fuels reduction is not a new idea in the Sierra Nevada: Lassen Volcanic and Sequoia-Kings Canyon National Parks have been doing this for over fifteen years. The National Park Service reduces hazard fuels through understory prescribed burning, using both natural and managed ignitions. The Forest Service, however, claims that it is too dangerous to do understory prescribed burning, and insists that it must do "mechanical treatment" instead. But how is it that the Park Service has not had to cut build roads or clearcut timber in order to reduce hazardous fuels? What does the Park Service know that the Forest Service must learn?

If forest ecosystem health and community stability are the real issues and not just phony excuses for harmful new timber sales, then the Forest Service should follow the lead of the Park Service and implement careful use of prescribed burning, with the goal of restoring a natural fire regime across the landscape. Susan Husari, Deputy Director of Fire and Aviation in Region Five, revealed in her SNEP study that on Forest Service lands in the Sierra Nevada it costs $6,400 to suppress a one acre wildfire while it only costs $50 per acre to do prescribed underburning. With increased prescribed burning, the size, severity, and costs of future wildfires will decrease. If the intent of Congress is to seek the most environmentally-sound and cost-effective means to reduce the fuel hazard and fire risk, then the Forest Service should be instructed and fully funded to implement understory prescribed burning without commercial logging. The long-term goal should be full restoration of ecological processes, including fire.

The fire scientists and fuels managers participating in the SNEP studies (e.g. Husari & McKelvey; van Wagtendonk; Sessions, Johnson, Sapsis, Bahro, & Gabriel; Weatherspoon & Skinner) universally voiced strong support for prescribed fire to manage hazard fuels and reduce wildfire risks. Dr. Jan van Wagtendonk said it clearest: "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." Although some of the SNEP papers gave some tentative support to the creation of fuelbreaks, their analyses were based on the assumption that these fuelbreaks would be used as the initial staging grounds for conducting prescribed fires across the landscape rather than as permanent sites to contain and control wildfires. Furthermore, personal interviews with Skinner and Weatherspoon revealed that they believe fuelbreaks should be located on the upper third portions of slopes in areas that naturally have lighter fuel loads rather than plow them through dense timber stands on lower slopes, as S.1028 intends to do.

The fuel hazards and fire risks of the Sierra Nevada are real, but the SNEP Report revealed the bitter truth that the Forest Service's logging, road-building, and firefighting policies of the past are what have created the forest health and wildfire problems of today. It defies logic and simple common sense to think that more logging, road-building, and firefighting will be the cure. S.1028 ignores the best fire science, undermines the new federal fire management policies, and runs contrary to the views of the Forest Service's own fire experts. It is time address real problems with real solutions and S. 1028 does not meet that test.

REFERENCES

Agee, J.K. (1996) "The Influence of Forest Structure on Fire Behavior," Proceedings, 17th Annual Forest Vegetation Management Conference, Redding CA

Davis, L.S. (1965) "The Economics of Wildfire Protection with Emphasis on Fuel-Break Systems," Calif. Division of Forestry, Sacramento CA

Deeming, J.E. (1990) "Effects of Prescribed Fire on Wildfire Occurrence and Severity," in Walstad, J.D. et.al. (eds.) Natural and Prescribed Fire in Pacific Northwest Forests, Corvallis OR

Duane, T.P. (1996) "Human Settlement, 1850-2040," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

Husari, S.J. and K.S. McKelvey (1996) "Fire-Management Policies and Programs," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

Kusel, J. (1996) "Well-Being in Forest-Dependent Communities, Part I: A New Approach," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

Sessions, J., Johnson, K.N., Sapsis, D., Bahro, B., and J.T. Gabriel (1996) "Methodology for Simulating Forest Growth, Fire Effects, Timber Harvest, and Watershed Disturbance under Different Management Regimes," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

Weatherspoon, C.P. and C.N. Skinner (1996) "Landscape-Level Strategies for Forest Fuel Management," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

U.S. Dept. of Interior and Agriculture (1996) "Federal Wildland Fire Management Policy and Program Review Implementation Action Plan Report," National Interagency Fire Center, Boise ID

van Wagtendonk, J.W. (1996) "Use of a Deterministic Fire Growth Model to Test Fuel Treatments," Sierra Nevada Ecosystem Project, Vol. II, Davis CA