25 Jun 2009, 10:55am
Economics Management Policy
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Fire History and Research, Big Bar Ranger District, Northwestern Trinity County, California: Critique of Fire Suppression Practices

Concerned Citizens for Responsible Fire Management*. 2008. Fire History and Research, Big Bar Ranger District, Northwestern Trinity County, California: Critique of Fire Suppression Practices. Report to Congressman Wally Herger, October 2008

* David Rhodes, Committee Chairperson, Lewiston, 37 years in Trinity County, retired, 30 years with the U. S. Forest Service (all in fire and fuels management);  11 years on the Angeles National Forest with 5 of those years as Hotshot Crew Foreman and the remainder as Fire Prevention Technician and Engine Captain.   19 years on the Big Bar Ranger District in Fire, Fuels Management and Law Enforcement, the last 15 of those years  as Fire Management Officer. Large Fire Qualifications, Class I Operations Chief,  Class II Incident Commander, Division Supervisor,  Helitorch Burn Boss, and Fire Behavior Officer, and Class II Planning Section Chief.  Incident Commander on the Shasta-Trinity Class II Fire Team for 14 years.  Fuels Management Qualifications:  Prescribed Fire Manager for Multi-Burns, Burn Boss, and Helitorch Burn Boss.

Charley Fitch, Redding, California resident for the last 42 years, having lived in Southern, Central and Northern California amongst the National Forests, employed by the Forest Service.  Twenty of the years were in Trinity County as District Ranger for the Big Bar Ranger District, later incorporated into the Trinity River Management Unit, before retiring in January 1999.  Fire suppression experience with the Forest Service included fire assignments ranging over 35 years.  Positions included Crew Boss, Sector Boss, Division Supervisor, Forest Supervisor’s Representative, Planning Section Chief Type II, Liaison Officer for both Type I and Type II Incident Teams as well as Line Officer for fires located within my Ranger District.  I am a professional forester with a degree from Colorado State University in Forest Management.  Other experience with fire beyond being a firefighter was as a project leader for controlled burns and a land manager dealing with post-fire land management.

Michael Jameson, Weaverville, resident of Trinity County for 18 years, retired California Department of Forestry (CALFIRE).  Started with CDF as a seasonal firefighter in 1978 with the San Bernardino Ranger Unit.  Promoted to Engineer in San Bernardino and worked in both schedule A and schedule B contracts (Structure and Wildland Fires).  Promoted to Captain in 1987 at the Fenner Canyon Camp in Los Angeles County, transferred to the Pilot Rock Camp in San Bernardino and then Trinity River Camp in Lewiston in 1990. Qualified for Division/Group Supervisor, Map display processor, Field Observer, Strike Team Leader and Task Force Leader.  25 years all in fire control.

Clarence Rose, Weaverville, Trinity County resident since 1974.  Oregon State University graduate, B.S. in Forest Engineering, 1974.  California Registered Professional Forester since 1977.  Member of California Board of Forestry, 1985-89.  Founder and co-owner of R&R Timber Co., Inc., a logging company which was active in contract logging in Trinity County from 1979-1998, averaging 2000+ truckloads of logs per year,  and which provided contract heavy equipment (dozers, water tenders) to CDF and USFS.  Currently owner and manager of 1,000 acres of sustainably managed commercial timberland in Trinity and Shasta County.  Member of Weaverville Community Forest steering committee, which works with Trinity County Resource Conservation District to attain fire-safe, fire-resilient forests on public lands in the Weaverville basin. Volunteer missionary in Russia (1994-95) and Ukraine (2001-2005).  Member of initial board of directors of Mountain Communities Healthcare District, which owns and operates the formerly county-owned Trinity Hospital.

Jerry McDonald, Lewiston, 40 years in Trinity County, retired, 30 years with the Forest Service, 27 of those years in fire and fuels management. District Fire Management Officer, Calaveras and Miwok districts, 4 years; retired as Stanislaus National Forest fire staff operations; Type II Team Deputy Incident Commander and, Operations Section and Safety Officer, Type I Team Safety Officer; prescribed fire manager for helitorch and hand fire; Interdisciplinary team leader and NEPA team leader for fuels and fire projects; fuels committee chair for Stanislaus National Forest for 5 years; member of Forest Service Southwest Region fuels committee for 6 years; HAZMAT coordinator, Spill Response coordinator; agency representative on fires and other projects, including with CDF; Forest representative for local fire companies in Calaveras and Tuolumne counties.

Frank Grovers, Big Bar, 11 years in Trinity County with an RV park business along the Trinity River; 40 years in sales experience in the U.S. and foreign countries, dealt with different teenagers in a counseling capacity, involved with church and local community; three children, five grandchildren, two great-grandchildren. 2008-09 Trinity County Grand Jury.

Stan Stetson, Hayfork, in 1968 began working summers for the U.S. Forest Service in Trinity County while attending Humboldt State College.  Upon graduating continued to work seasonally in fire prevention, fuels and fire suppression until 1973 when I received a permanent appointment.  Worked as Engine Foreman until 1979 when I became a Timber Sale Administrator.  Retired after 36 years, all in Trinity County, having served as Division Supervisor, Strike Team Leader, Burn Boss, Logistics and Ground Support Leader in Fire organization and Supervisor in Timber sale preparation and administration.  Three years with Watershed Center as Project Coordinator for fuels reduction and thinning operations. Present Commissioner of the Hayfork Fire Protection District. Currently retired and concerned citizen.

Dana Hord, Junction City, Trinity County resident 1993-present, business owner, Trinity River Rafting, Big Flat. Trinity River Rafting features scenic quality of the Wild and Scenic Trinity River and is tourism based. Appointed Member of Trinity Adaptive Management Working Group for Trinity River Restoration Program, 2001-present, representing Big Bar Community Development Group. Dana has been actively involved in the transition of the local economy from one focused on commodity production to one that is more dependent on tourism and recreation. Ms. Hord has a degree in sociology, and experience in small business management, grants administration, and public relations. Junction City Volunteer Fire Dept., 2002-present, trained in wildland fire suppression, and structural fire protection. Former Aide, U.S. Senator S.I. Hayakawa. Daughter of Donna Hord, deceased, Shasta County GOP delegate.

Gay Berrien, Committee Secretary, Big Bar, 45 years in Trinity County in Denny and Big Bar; retired U.S. Forest Service employee, clerk and archaeological technician for 30 years mostly Big Bar Ranger District; wrote all news releases for Big Bar for first several years of 1970s including articles on fire suppression, fuels reduction, controlled burns, special high elevation fire study (study by a fire behavior specialist, first such study in Forest Service Southwest Region), attended 32-hour fire training (but only participated in one controlled burn from 9 a.m. one morning until 9 a.m. the next and was on fire standby at Denny Guard Station one day), responded to fire assignments as initial attack and communications dispatcher, fire information officer, personnel time recorder, and procurement officer; Trinity County Historical Society board of directors, 2008-09 Trinity County Grand Jury.

Full text [here]

Selected excerpts:

CONTENTS

Cover Letter to Congressman Herger/Introduction ………. 3
Meet the Committee ……………………………….. 12
Fire Location Map 1999-2008 ……………………….. 14
One-Page Summary of Catastrophic Fire Analysis ………. 15
2006 Catastrophic Fire Analysis ……………………. 16
Fire and Forest Management on the Big Bar District …… 23
Local Businesses Affected by 2006 & 2008 Fires ………. 28
Heritage Resources in Iron/Alps Complex 2008 ………… 29
Big Bar Ranger District Annual Rainfall …………….. 31
Typical Fire Suppression 1930s-1970s ……………….. 33
Jim Jam Fire of 1951 ……………………………… 36
Denny Guard Station Removal ……………………….. 37
How Liability Fears Affect Fire Suppression …………. 41
Fires Burned Nationwide by Decade Compared with Timber Harvest, Fire Suppression Policies and Local Rainfall* ………………………. 43

* added after October 10 meeting with Congressman Herger

**********

Honorable Wally Herger
House of Representatives
410 Hemsted Drive, Suite 115
Redding, CA 96002

Dear Wally:

We seriously appreciate your taking the time to meet with us and we hope what we have to offer will, in turn, be seriously considered by you.  This letter explains our observations and also explains the enclosures and attachments for you to look over, documents and articles that support our analysis that the radical change in fire suppression tactics from several years ago is the primary reason there are more large fires now.  The letter also brings out points we think the Forest Service will refer to in explanation or as an excuse for failures in fire management.  If these management policies in suppression are not addressed and changed, then we can look forward to the same catastrophic fire scenario each summer until our Trinity forest is no longer a forest.

Our committee focuses primarily on the management of fires by the U.S. Forest Service and those other agencies which are part of the Incident Command teams.  We believe we can show a lack of responsible suppression policies and actions.  These management practices in the past several years have caused great damage and negative impacts to private property (timber, watersheds, water lines), the local economy, watersheds and soils, wildlife, aesthetics, cultural resources, and air quality—sometimes in radical proportions.  Safety in firefighting is also challenged.  When fires continue for such long periods of time, there is increased potential for accidents and, yes, fatalities.

We strongly believe an investigation should be conducted into this very complex and crucial situation.

Forest Service “Talking Points”

Mark Rey, Undersecretary of Agriculture who oversees the Forest Service attended a meeting in Weaverville on Friday, September 19, 2008, with the Board of Supervisors and a group of people concerned with the recent fires. The group, which also included Shasta-Trinity National Forest Supervisor Sharon Heywood, also visited a couple of field locations and Rey additionally was taken on a helicopter flight over some of the fire areas.  Rey and Heywood made several statements we would disagree with.  In this letter we would like to specifically address these statements as we believe these are the “talking points” or excuses the Forest Service will also use when you ask that agency’s staff about these things.

1. The June 21, 2023 thunderstorm and resulting hundreds of fires was unprecedented. (Rey)  [Interpretation:  The continuing burning of the fires is not the fault of the Forest Service fire suppression practices, but only Mother Nature.]

…. Rey stated that the magnitude of these lightning fires drained firefighting resources which required using a triage system to prioritize fires.  It is recognized using the Forest Service triage process that these fires in Trinity County were low priority, since fires burning in heavier populated areas took priority over the fires here.

What was not considered in their triage process was that if you leave these fires unattended they will become your “worst nightmare.” …

Most of the fires on the Big Bar District, those in the Iron and Alps Complex, crept along the first several days and even the first few weeks—with exception of when the Eagle Fire hit some heavy dry fuels during a wind and swept from the Eagle Creek area over toward Junction City, and the beginning of the Zeigler Fire when it started in a more flammable area.

Once enough resources were available, they should have been used to put out those fires which held the larger potential of spreading and causing damage.

This could have been accomplished if more aggressive actions, such as were widely and effectively used several years ago, had been taken.

The group of fires that made up the Eagle Fire was created from five individual lightning strikes.  Three of these were within a mile of each other.  A road system to the Eagle Ranch provides access to the area where these fires were. … These fires should have been a priority and had they been dealt with in the first few days, could have been extinguished, eliminating the threat to the Junction City area which would have then precluded the manmade burn outs and the evacuation of the community.

The Chaparral, Canadian, and Cedar fires, which eventually became the Cedar Fire, were also close to road systems which should have allowed easy, fast access to them.  The Monument Fire just to the east of these three was also close to a road and located near a ridge top.  Had these fires been attacked early on, there may not have been the need for the large burn outs that damaged water systems at Big Bar and Junction City, and over 10 million board feet of timber on private land.  There would have been no evacuations of Big Bar and Corral Bottom.  …

Again, Rey stated during his September 19 presentation that nothing has changed in suppression tactics and the difference was from the unprecedented nature of the 2008 fires, weather, and fuel conditions.  He was not correct—tactics have changed.

2. The goal of fire suppression is to have 98% of the fires put out on initial attack and, according to Mark Rey, they are doing just that.

Nation-wide maybe this is true.  Locally, no.  California annually has more fires and more acres burned.   Ninety-eight percent of the fires in California and in Trinity were not put out on initial attack.

3.  Nothing has changed in suppression actions, the difference here is due to weather conditions.  Mark Rey said that the agency’s climatological data shows the first part of the past century was wetter than the last half and this lends to increased flammability now.

Suppression actions have changed, radically—and the weather conditions in this part of California do not seem to be much different from earlier years as Rey suggests. …

Our experience in this area—over many years of time—and our familiarity with the area’s history, tell us that climate change was not the cause of the catastrophic fires this summer.

Certain ways of planning and fighting fires that proved efficient and effective some years ago, don’t seem to be applied now. …

4.  Priorities are set for protection of populations. (Rey)

Trinity County is small in population numbers but large in land mass, of which 73% is Federal lands.  The Forest Service’s goals in fire management has been as a wildland fire organization, trained and equipped to suppress forest fires.  The past 20 years seem to have slowly moved toward structure and private property protection.  This is not to say that in years past there was not a concern for structures and private property.  The wildland fire mission was to get to the fire, assess the situation if a structure was threatened, and try to protect it.  If the structure was totally involved, they concentrated efforts on keeping the fire out of the forest.

Keep in mind that during this period engine crews were not equipped to deal with structure fires, lacking proper equipment and in many cases, training.  But the Forest Service in these rural areas has always tackled fires in private residences and other structures bordering or within the National Forest as any helpful fire department would.  The Forest Service fire crews for scores of years here were the only organized crews that could respond to these fires—and they did.

Now, what is the definition of what private property the Forest Service protects?  Why does the Forest Service protect a $200,000 home and let burn (or conduct a burn out on) $2 million of private timber?  This does not mean the home has no value to the homeowner, but this story line seems to have actually occurred on the fires here this summer.

If the tactics were as aggressive and reasonable as they were several years ago, these fires would have been contained several ridges over from where they were finally stopped—precluding the necessity of having to protect these structures and private timber land at all.

5. On fuels treatment, the FS is doing a lot, but there are 60-70 million acres of fuel treatment needed.  (Rey)

However, Mark Rey failed to say where these areas are located and what type of treatment is prescribed.  Fuel treatment projects cost money, something that is in short supply in the present economy, especially when it has to come from appropriated dollars.  Once a fuels management project is completed, there needs to be reoccurring funds to maintain it at that level, or the original investment is lost.  This especially applies to fuel breaks and “fire safe” projects occurring in urban interface zones.  Back when the forests were being managed, much of this fuel reduction work was paid for out of timber sales. …

Regarding fuels suppression, we wonder if there is an underlying effort to burn the forest ground fuels and just let the fires burn partially for that reason.  Are fire suppression dollars being used to reduce fuels?  Is the Forest Service purposely burning these additional acres in order to meet a goal of burning up fuels?  Does this mean the Forest Service is using suppression dollars illegally to try to get rid of fuels?

Although we agree fuels are a problem, something to consider in fire management, they are not THE cause of these large-scale and long-enduring fires—the cause is the changes in fire suppression practices.  The fuels presently found on the Trinity Forest are not substantially different from what would have been found 20 and 30 years ago.

6. The liaison between an IC team and the local FS is sufficient in gathering local information on water sources, old roads and trails, old fuel breaks, etc.  (Heywood)

There were three or four Trinity River Management Unit employees helping on the Iron/Alps Complex in providing information.  Sharon Heywood said she thought the people involved as liaison or resource specialist on the Iron and Alps Complex were adequate.

Present liaison positions are apparently only a “resources” specialist and not someone who can observe and advise about conditions for suppression.    None, however, would have been able to help make decisions in suppression.

Although these four people had some good knowledge about the fire areas, especially one of them, they couldn’t be everywhere for everything, and apparently weren’t.   There were many instances where the fire crews did not know where helpful resources were (water sources, old roads, etc.).  This is where a well-organized “pre-attack plan” with descriptions and maps would have been useful, too.

7. Fire is beneficial. (Found in some news releases and general Forest Service statements)

A few people think all fires are beneficial, irregardless of the reality.  This is what is promoted by many environmental groups who do not seem to want any management of the National Forests.

Under controlled circumstances, such as the attached article about the 1976 prescribed wildlife burn on the Big Bar District, fire can be beneficial.   Uncontrolled wildfire is NOT beneficial.

Besides negative effects the fires had this summer on watersheds, wildlife, timber, local economy and recreation, cultural resources, aesthetics, and private property, there were serious and costly health issues from the many weeks of heavy smoke.  This was also true in 1987, 1999 and 2006 in this area. The cumulative effects of the smoke upon local citizens is being ignored by the Forest Service in its choices of suppression methods it employs.

Some of the wildlife studied in response to President Clinton’s Northwest Plan Option 9, the “survey and manage” work that was done for several years, were part of the casualties from these fires.   Many plantations of ponderosa pine and Douglas-fir that the Big Bar District spent many decades and money on to establish, of which much pride was felt, were burned.

In Summary

Mark Rey probably believes most of what he said while here in Trinity County, and feels that the Forest Service is doing a good job suppressing fires on National Forest lands.  The people of Trinity County are not happy with the mismanagement in the way fires are being suppressed, and the way the Forest Service is being managed.  Something needs to change.

We need to (1) get the Forest Service back to managing the timber and other resources on National Forest lands, (2) change fire management suppression tactics—if this includes adding more firefighters, then that is what should be done, (3) re-staff stations in remote areas, and (4) have the Forest Service address and resolve the “liability” issue.

There is a lot more documentation that we can provide or find for you if we are given more time.  Please look this over and let us know what additional information you would like to see.  There are also many other individuals who would be willing to relate similar observances as ours, if you wish to talk with them, too.  Just say the word, and they would be available.

As stated at the beginning of this letter, we believe it is imperative that this issue be thoroughly investigated.  We also believe it is imperative not to allow this to be an in-house (that is, within the Forest Service or involving people presently working for the Forest Service) investigation and report.

We look forward to hearing back from you soon.

Thank you very much.

Sincerely,

DAVID RHODES
Chairperson

Attachments

ONE-PAGE SUMMARY
CATASTROPHIC WILDFIRES – SUPPRESSION STRATEGIES FAIL

The management of fires by the Forest Service and other wildland firefighting agencies is the major factor in past years that has allowed for the continuing spread of fires. When a fire has not been put out during the first hours or day, it starts growing and the methods used in responding to this are not as aggressive or organized as in earlier years. This change in how fires are managed is the one main contributor to the large-scale fires: not heavy fuels, not lack of resources, and not global warming. Firefighters are not allowed to be as “hands on” during suppression of fires as they were several years ago and instead of constructing handlines or tractor lines close to a fire in order to contain it at a smaller size, lines are often constructed miles away from the active fire: thus, many hundreds of extra acres are burned when the wildfire finally meets the firebreak. “Burn outs,” those firefighter-caused fires to make a wide black line to contain a fire, include hundreds of extra acres than what would have been burned in earlier years.

Among the main elements in this change to less aggressive management were the Storm King Mountain, Colorado, fatalities several years ago and a subsequent year when there was a large number of additional fire fatalities.  Although the Forest Service’s safety standards and guidelines have stood up through the years, a is created when a crew or individual neglects some of the safety standards and guidelines. Liability  fears of fire supervisors have led to an increased indirect approach to fire suppression where crews are kept away from areas in which years ago they would have worked.   An incident commander in charge of a fire complex now is personally liable in the event of any fatality under his/her management.  This is one reason for the radically changed management of large fires.

Two years ago a group of individuals, people with many years’ experience in fire management including incident commanders on large complexes, put together a report on this “catastrophic fire” situation. This report states the situation as it applies to northwestern Trinity County, focusing on 1987, 1999, and 2006 as well as using earlier fires for comparison.  The report included information gathered from interviews, fire maps, historic fire records, and news articles.  The information can apply to the recent 2008 fire event.  Following is a summary of what was found:

WHY THE FIRES NOW GET SO LARGE:

1.  Inadequate response to lightning fires (putting them out before they begin to spread)
2.  Natural heavy fuels
3.  Insufficient aggressiveness in firefighting policy and activity
4.  Lack of natural defense areas—continuous heavy fuels
5.  Liability concerns that hamstring firefighting aggressiveness
6.  Insufficient resources
7.  Poor judgment of managers; impaired firefighting policy for wilderness area
8.  Insufficient follow-up and maintenance of land condition information—inventory of things that aid firefighting, such as locations of water sources, old roads that can be reopened, helispots, etc.
9.  Insufficient communication between district and fire team, and then insufficient follow-up/understanding between subsequent fire teams.

It is time for Congress to understand that the management of fires needs to be seriously looked into—and changed.   Not only is the situation burning up valuable forest resources, but it is certainly costing massive amounts of money.  (For example, the fires in northwestern Trinity in 2006 cost over $89 million; the 2008 fires have exceeded this.)

SOLUTIONS TO PREVENT CATASTROPHIC FIRES:

Redistribute funds into potential costs for upcoming years, spending some millions of dollars as a preventive measure rather than for much larger suppression costs.  Spend this preventive funding to get firefighting units back to where they were on the National Forest in the mid-1970s in the same locations and numbers (or provide equal numbers in local contract crews).  Additionally,

(1) totally review the present suppression policies and rethink it all in regard to the liability issues—are there ways to remove some of this liability emphasis and return to most of the former more aggressive practices? and

(2) along with the additional Forest Service or contract fire crews, reinstall strong presuppression (”preattack”) documentation into the system so that when a large fire team does have to come into an area, it already has the informational package needed to work in any area and know where all the resources are (roads, water sources, any fuelbreaks or old cat roads, private lands, etc.). Hand-in-hand with these improvements in fire suppression would be the return to strong overall forest management.

HERITAGE RESOURCES WITHIN THE IRON/ALPS COMPLEX
DAMAGE TO NON-RENEWABLE FEATURES CAUSED BY FIRES THAT ARE ALLOWED TO SPREAD AND BY MAN-CAUSED BURN-OUTS

This summer’s fires in Trinity County created widespread damage to the natural resources, wildlife, the local economy, residents’ property such as timber, water lines and other interests, aesthetics, and the air quality.  Fire practices need modification not only to save these, but also to save another important resource that is not always as evident to the public:  heritage resources.
More than thirty-four locations of prehistoric Indian villages, sacred sites and camps, and historic mines, cabins, and ranches were either within or close to the fires that burned within the Iron and Alps Complex.  Most lie within the burn areas while a few are located nearby in areas where suppression support activities (equipment parking, spike camps, bulldozed safety areas, fuel breaks, etc.) may have disturbed them.

These sites are part of the National Forest’s non-renewable resources.  Once they are disturbed they cannot be restored to their original conditions.

According to Ken Wilson, Heritage Resources BAER Team Leader for the Megram Fire in 1999 and Heritage Resources Program Manager for the Six Rivers National Forest, in “A Summary of Findings and Recommendations for Heritage Resources Impacted by the 1999 Megram Fire, Big Bar Complex, Six Rivers and Shasta-Trinity National Forests, Region 5, California,” wildfires “clearly have the potential to damage, or destroy, heritage resources.”   Fires can cause this damage through:  (1) direct effects of the fire; (2) ground disturbing suppression activities; and/or (3) erosive movement caused by subsequent storm precipitation.

Results of fire damage may include completely destroyed historic and archaeological resources or surface and subsurface cultural remains that are altered in a way to disallow scientific analysis and interpretation.  Artifacts made of glass and ceramics may fracture or break from fire temperatures and, of course, any wood structures or wood remnants in historic sites may burn.  This was noticed in historic sites burned during the 1999 Megram Fire.

By burning protective duff, brush, and other natural forest growth over and around artifacts and ground features, wildfires may increase the accessibility and visibility of archaeological site locations making them more susceptible to vandalism/artifact looting and unauthorized recreation activity.  These factors, alone or combined, have the potential to impact the qualities of archaeological sites or areas held to be of significance by contemporary cultures such as local Native American communities.  The burning of the historic sites in the Old Denny Historic District in 1999 attracted illegal relic collectors to the area the following summer.

Background data for the 1999 Megram Fire area is similar to that for the 2008 Iron and Alps Complex which is also in northwestern Trinity County.  Heritage resource sites in the watersheds impacted by fires here are primarily associated with two broad categories of archaeological sites—prehistoric sites consisting primarily of lithic cultural materials including groundstone and flaked tool scatters, and historical sites linked to the gold mining era.  Archaeological studies in northwestern California suggest that prehistoric sites in this region date back as much as 5,000 years.  The historical period begins in 1849 with the discovery of gold in the Trinity Mountains.  Numerous claims were filed along the streams and washes of this region.  Ditches were constructed within many of the smaller drainages in the late 1800s to bring water to hydraulic mining areas.  There is a network of historic trails connecting the high country with the surrounding river valleys.  With the creation of the Klamath and Trinity National Forests in 1905 construction of a number of guard stations and administrative sites were undertaken.

The montane areas have been traditionally used by Native Americans for spiritual and ceremonial purposes.  These “spiritual areas” retain their importance to Native Americans and are still utilized for spiritual purposes.  These Traditional Cultural Properties are considered critical heritage resource values to the tribes and traditional practitioners who utilize these areas.  The same areas have also been used for gathering of plants by local Native Americans, both in the past and contemporarily.

 
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