Open Letter to Ken Salazar Re WFLC

Letter in pdf format may be downloaded [here]

To: The Honorable Ken Salazar
Secretary of the Interior
1849 C Street NW
Washington, DC 20240

Re: Reconvening the Wildland Fire Leadership Council

Dear Secretary Salazar,

In a letter to western governors dated February 19, 2010, you indicated your desire to reconvene the Wildland Fire Leadership Council (WFLC). You also stated in that letter that you are committed working closely with “key stakeholders at all levels” to address wildfire issues.

Please be advised that the prior manifestation of the WFLC did not work with stakeholders but instead was a closed door, exclusionary, non-transparent Federal advisory group that violated various laws with impunity. The laws repeatedly violated by the WFLC include the Federal Advisory Committee Act (FACA), the National Forest Management Act (NFMA), the Endangered Species Act (ESA), the National Historic Preservation Act (NHPA), the National Environmental Protection Act (NEPA), and the Administrative Procedure Act (APA).

The WFLC excluded the public and the press from their meetings. They did however seat deep-pocket lobby groups including the Nature Conservancy and the Wilderness Society. Federal funds were passed to these lobby groups through the WFLC. The lobby groups also provide a “revolving door” of high-paying positions to former government employees formerly seated on the WFLC.

During closed door meetings in 2008 the WFLC directed the five Federal land management agencies under their purview to adopt Appropriate Management Response (AMR) and Wildland Fire Use (WFU). The agencies did so without implementing any NEPA process, without public comment or review, and in violation of the laws listed above.

As a result, numerous wildfires were allowed to burn without aggressive suppression actions. Tremendous destruction and degradation of natural resource values occurred. Some examples:

* South Barker WFU Fire (2008, Sawtooth NF, 38,583 acres) – The South Barker WFU Fire escaped and burned 38,583 acres. The fire eventually cost over $7 million to suppress. It incinerated miles of riparian zones, stripped erodable hillsides of vegetation, and destroyed forest plantations that had been carefully tended for 50 years.

* Gunbarrel WFU Fire (2008, Shoshone NF, 67,141 acres ) – The Gunbarrel WFU Fire was allowed to burn until it blew up. The fire eventually cost over $11 million to suppress. An estimated 420 residences, 11 commercial buildings, and 149 outbuildings were threatened and 7 buildings destroyed. The highway leading to Yellowstone Park was closed, and numerous residents were evacuated. During the fire USFS officials proudly declared that the MMA (Maximum Manageable Area, or desired incineration zone) was 417,000 acres (652 sq miles) and included public and private properties north and south of Highway 14.

* East Slide Rock Ridge WFU Fire (2008, Humboldt-Toiyabe NF, 54,549 acres) – The ESRR WFU Fire was allowed to burn unchecked until it blew up and threatened the community of Murphy Hot Springs, ID, as well as numerous rural ranches and farms. The fire eventually cost over $9 million to suppress. Riparian zones adjacent to stream habitat for endangered bull trout were incinerated.

* Mill Flat WFU Fire (2009, Dixie NF, 12,607 acres) – The Mill Flat WFU Fire was monitored until it blew up. The fire roared into New Harmony, Utah, forced the evacuation of 170 New Harmony residents, destroyed three homes and damaged eight buildings. The fire eventually cost over $6.5 million to suppress.

* Iron Complex AMR Fire (2008) – Including this fire, 650,000 acres were incinerated in Northern California on the Shasta-Trinity, Six Rivers, and Klamath National Forests. The fires were allowed to burn vast tracts for three months in implementation of “Appropriate Management Response.” Building firelines miles away from the fires and backburning hundreds of thousands of acres of private and public land alike, including habitat for two endangered species, Salmon and Spotted Owl, were deemed “appropriate.” Despite the indirect firefighting techniques, ostensibly intended to save money and protect firefighters, over $400 million was spent on suppression and 12 firefighters were killed.

* Basin/Indians AMR Fire (2008) – 244,000 acres of the Los Padres National Forest and private lands were incinerated in 3rd largest fire in California history. Despite indirect AMR methods, more than $120,000,000 was spent on fire suppression, making the Basin/Indians AMR Fire the most expensive fire in California history, and the 2nd most expensive in U.S. history (the Biscuit Fire in Oregon in 2002 cost $150,000,000). In addition, 26 private residences were destroyed.

Numerous other disastrous AMR and WFU fires could be cited. The suppression costs noted above do not begin to account for the cost-plus-loss damages inflicted, which were 10 to 30 times the nominal suppression expenses. Nor do they express the tragic loss of human life.

Both Secretary of Agriculture Vilsack and US Forest Service Chief Tidwell have recognized (in public speeches) that an increasing number of catastrophic wildfires are plaguing the Nation, and that a collaborative management approach to restoration and conservation are needed.

The secretive and non-collaborative WFLC has been the cause, not a source of solutions, of our ongoing forest fire crisis.

The Obama Administration has promised transparency, accountability, and tougher restrictions on lobbyists. In his 2009 State of the Union address, President Obama said, “Let me say it as simply as I can – transparency and the rule of law will be the touchstones of this presidency.”

The WFLC in its prior manifestation violated transparency and the rule of law with disastrous consequences.

Please be advised that if you reconvene the WFLC under the previous format and model, you will be doing a great disservice to America.

Sincerely,

Mike Dubrasich
Executive Director, the Western Institute for Study of the Environment

cc: Secretary of Agriculture Thomas Vilsack
Chief of the US Forest Service Tom Tidwell
Bureau of Land Management Director Bob Abbey
National Park Service Director Jon Jarvis
Governor Brian Schweitzer, Chairman, Western Governors Assoc.
Governor C. L. “Butch” Otter, Vice Chairman, Western Governors Assoc.
Ann M. Walker, Forest & Rangeland Health Program Director - WGA
NM State Forester Arthur Blazer, Chair, Western Forestry Leadership Coalition
AK State Forester Chris Maisch, Chair-Elect, Western Forestry Leadership Coalition
Congressman Doc Hastings (WA-04)
Congressman Greg Walden (OR-02)
Congresswoman Cynthia Lummis (WY)
Congressman Wally Herger (CA-02)
Congressman Denny Rehberg (MT)
Congressman Norm Dicks (WA-06)
Congressman Raúl M. Grijalva, (AZ-07)
Congressman Peter A. DeFazio, (OR-04)
Congresswoman Stephanie Herseth Sandlin, (SD)
Senator Ron Wyden (OR)
Senator Maria Cantwell (WA)
Senator John Barrasso (WY)
Senator James E. Risch (ID)
Senator Robert Bennett (UT)

6 Mar 2010, 5:17pm
by Glenn B.


Great letter and right on.

8 Mar 2010, 2:36pm
by William Y.


As a smokejumper with 30 fire seasons of experience,(1953 to 1986) I say we are in a heap of trouble. Current smokejumpers say you can not fight fire at night which in my experience is the very best time. Lower temperature, higher humidity and low winds. What are these new guys thinking?

8 Mar 2010, 2:54pm
by Mike


Let It Burn is what they’re thinking. It’s horrible. We can do better. We should not allow a handful of insider wheeler dealers with a Let It Burn agenda set our forest and fire policies behind closed doors.

11 Mar 2010, 6:13am
by bear bait


We have all these “public safety” job titles and employees who are paid for assuming the risk associated with keeping societal order and dealing with dangerous people and situations. A public policy that says fires will be allowed to burn because fighting them might put firefighters at risk is unrealistic. If the firefighters are unsafe anywhere near a fire, then the rest of us are also unsafe. If firefighters can’t take any risks with their personal safety, then why do they get paid by the rest of us?

16 Mar 2010, 7:24pm
by Gordon S.


Is the problem the concept and guidelines, or the competence of those using the guidelines?

17 Mar 2010, 4:23pm
by Ned P.


The problem is all three — concept, guidelines and competence. When thousands of acres are burned in an intense wildfire due to WFU and AMR with no advance planning, guidelines or concept of the meaning of forest restoration by persons with little or no experience with wildfire and the effects of wildfire, there is a problem. One only needs to look at the result of intense wildfires in the last decade to understand there is a problem. I fought fires at night most of my over 50 year career and I never thought there was any danger at night. We always knew there was danger in fighting fire. That was the reason for the ten standard orders. There is a process called NEPA that would help establish concepts and guidelines. And you don’t have to wait until a fire starts in July or August to do NEPA and Forest Plans to establish the concepts and guidelines with public input for the fire starts. That was why NEPA passed in 1969.

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