SOS Forests

Fire Retardant DEIS Scoping Letters

The two letters below, one from W.I.S.E. and one from the National Association of Forest Service Retirees, have been submitted the US Forest Service as official scoping comments for a draft environmental impact statement (DEIS) regarding the use of aerial application of fire retardants.

To: James E. Hubbard, Deputy Chief, State and Private Forestry
Joe Carbone, Assistant Director for Ecosystem Management Coordination
U.S. Forest Service, Post Office Box 26667, Salt Lake City, UT 84126-0667
FireRetardantEIS@fs.fed.us

From: Darrel Kenops, Executive Director
National Association of Forest Service Retirees

Comments on the Proposal to Prepare a DEIS on the Aerial Application of Fire Retardant

Thank you for the opportunity to comment on your proposal to prepare a draft environmental impact statement (DEIS) as outlined in your September 3, 2010 document to Forest User under file designation “1950/3120”. The document indicates that the focus of the environmental impact statement will be the continued use of aerial application of fire retardants to fight fires on National Forest Land.

The comments have been prepared by the National Association of Forest Service Retirees’ (NAFSR) Fire Committee. Committee members have significant fire management experience in managing National Forest Land and leadership in fire management and suppression activities at the national, regional and local levels.

NAFSR understands this proposal is to apply to National Forest System land nationwide. One concern is that to the general public your “background section” leaves the impression that all National Forests are the same. There is no recognition of regional differences, vegetation types, fuel condition, relationships to communities, etc. and great variations in weather both current and long term. The first paragraph under background is biased to the management of wildfire to restore fire-adapted ecosystems. In many National Forests, aggressive suppression is the only option available, including in the wildland-urban interface where aggressive initial attack with all available tools is necessary. We suggest the following rewrite should be considered:-

“Forest Service management direction for National Forest System Lands includes restoring fire-adapted ecosystems through prescribed fire, other fuel treatments and effective management of wildfire to achieve both protection and resource benefit objectives. In many circumstances fire must be suppressed to protect life, property or to preserve natural resources and critical habitat for threatened and endangered species. In addition the current and long term weather conditions are essential factors to be considered in suppression strategy. Fire retardant is one of the tools necessary to suppress fires.”

NAFSR’s position is it is critical that Forest Service land managers have the ability to use aerially applied fire retardant for aggressive suppression of wildfire, even in riparian areas, when it is part of the wildfire suppression strategy.

Retardant can slow a fast moving fire for the safe containment and control by ground forces. Sometimes this will occur along stream courses or near lakes. Prohibiting the use of retardant would simply increase the size of the fire and the associated impacts which can be particularly harmful along stream courses.

Given the poor condition of many forests in the nation, particularly in the west, wildfire can cause serious damage to sensitive soil and water resources without the use of aerially applied fire retardant. Prudent risk management dictates that land managers use all the tools available to prevent long term, irreparable harm to the natural resources that they are charged to protect.

It is also important to note that unfortunately, in many parts of the west, riparian areas have been totally void of any active management even when such management might represent the best protection. Lack of management has assured the continuing buildup of fuels in many riparian areas. During a fire event, riparian areas can represent the heaviest fuel loadings and can act as a topographic “funnel” for fire, resulting in the site of highest fire intensity. Totally eliminating use of retardant in a strip 600 feet wide in all cases may result in fire-related impacts much greater than any potential retardant impacts. Therefore, guidelines should allow for site-specific judgment by the line officer and incident team.

In addition, width of any “no-retardant’ zone should not be set at 300 fee across the board but rather should be a function of factors like fuel type, amount of riparian vegetation and coarse woody debris that can act as a filter, slope, and soil type. Addition of any such factors adds a complication that requires thought, but that is preferable to using a “one-size-fits-all” approach that may not make sense in many areas. Helicopters can be precise enough in dropping to avoid undue impacts and their use should be coupled with more flexibility than fixed wings.

Under the “Exception” section we would like to reinforce where it states “When potential damage to natural resources outweighs possible loss of aquatic life, the unit administrator may approve a deviation from these guidelines.”

This exception is critical to allow the Forest Service to protect riparian areas, which are among the most important habitats for sensitive and T&E species. Sacrificing riparian area habitat by prohibiting the use of retardant during fast moving fires would be a serious mistake.

While aerially applied retardant may cause some loss of aquatic life, the alternative may be worse. Large, high intensity fires have become much more common throughout the nation in the past few decades, especially in the west. The total loss of riparian area vegetation is more probably in a high intensity wildfire. This loss of riparian vegetation is significant and much more likely without the use of retardant. Thus, the consequence of large scale habitat loss will certainly cause more extensive and prolonged loss of aquatic life than that caused by the use of retardant.

There needs to be some discussion on optimization. That is the trade off of some species being compromised where necessary to prevent a larger catastrophe that would have even greater consequences for endangered species.

During your analysis you should investigate the work that has been done on San Clemente Island in California. The Department of Defense (Navy), working with the U.S. Fish & Wildlife Service and others, has been using retardants annually since 2001 to protect a large number of endangered species, upslope from a gun range, from the impacts of a potential large uncontrolled wild fire. We can provide references for you.

Thank you for the opportunity to comment. Please ensure us that we will have an opportunity to review and comment on the DEIS and any other environmental documents on the use of aerial application of retardants. It is important that we receive documents with an adequate period of time in which to review and make comments.

Sincerely,

Darrel Kenops, Executive Director
National Association of Forest Service Retirees

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To: James E. Hubbard, Deputy Chief, State and Private Forestry
Joe Carbone, Assistant Director for Ecosystem Management Coordination
U.S. Forest Service, Post Office Box 26667, Salt Lake City, UT 84126-0667
FireRetardantEIS@fs.fed.us

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

Comments Concerning the Scope of the Analysis

If the USFS restricts aerial application of fire retardant on National Forest System lands, significant negative impacts to water quality, stream flow, forest hydrology, and riparian and aquatic conditions will likely result. Additional acreage will be burned, and additional negative impact will ensue.

Placing limits on fire retardant use will result in significant environmental damage. The environmental effects of wildfire are far worse than the effects of fire retardant (which are minimal).

The “alternative” to fire retardant is uncontrolled fire. The latter is what damages ecosystems, not the former.

The effects of fire on forest soils, water, and hydrology have been the subject of much scientific study over the last century. In 2005 the Rocky Mountain Research Station of the USDA Forest Service released a synopsis report entitled “Wildland fire in ecosystems: effects of fire on soils and water.” From that report:

This state-of-knowledge review about the effects of fire on soils and water can assist land and fire managers with information on the physical, chemical, and biological effects of fire needed to successfully conduct ecosystem management, and effectively inform others about the role and impacts of wildland fire. Chapter topics include the soil resource, soil physical properties and fire, soil chemistry effects, soil biology responses, the hydrologic cycle and water resources, water quality, aquatic biology, fire effects on wetland and riparian systems, fire effects models, and watershed rehabilitation. Keywords: ecosystem, fire effects, fire regime, fire severity, soil, water, watersheds, rehabilitation, soil properties, hydrology, hydrologic cycle, soil chemistry, soil biology, fire effects models. …

The purpose of this volume, Effects of Fire on Soils and Water, is to assist land managers with ecosystem restoration and fire management planning responsibilities in their efforts to inform others about the impacts of fire on these ecosystem resources. The geographic coverage in this volume is North America, but the principles and effects can be applied to any ecosystem in which fire is a major disturbance process. The fire-related changes associated with different severities of burn produce diverse responses in the water, soil, floral, and faunal components of the burned ecosystems because of the interdependency between fire severity and ecosystem response. Both immediate and long-term responses to fire occur. …

From Neary, Daniel G.; Ryan, Kevin C.; DeBano, Leonard F., eds. 2005. Wildland fire in ecosystems: effects of fire on soils and water. Gen. Tech. Rep. RMRS-GTR-42-vol.4. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 250 p.

Among the effects of fire on soil and water are (this is a short list):

* Changes in infiltration due to collapse of soil structure, increase in bulk density, removal of organic matter, reduction in soil porosity, clogged soil pores, and increased reaction to rainfall droplet kinetics

* Decrease in soil wettability (hydrophobia), concretion, increased water repellence, increases in surface flow, increase soil particle transport, rilling, gulleying, and increased erosion

* Substantial changes in stream water chemistry, solid and dissolved material transport, pH, bacteriological characteristics, sediment influx and transport, dissolved sulfates, nitrates, nitrites, chlorides, iron, and other cations, and turbidity,

* Increases and decreases in discharge rates and seasonal streamflows, peak flows including flash flooding, minimum flows, as well as total annual streamflows,

* Degradation of aquatic habitat, aquatic biota, spawning gravels, fish populations, cultural resources, and human health and safety.

In addition to damaging aquatic ecosystems, wildfire inflicts predictable and preventable detrimental impacts on:

• Flora
• Fauna
• Historic/cultural resources
• Water and watersheds
• Air and airsheds
• Carbon emissions
• Fire suppression costs
• Public and worker safety
• Local economies
• Recreation opportunities
• Soils
• Hydrology
• Transportation networks
• Social resources
• Fisheries
• Invasive and noxious weeds
• Insects and disease
• Wilderness and roadless areas
• Wild and scenic rivers
• Scenic quality
• Short-term and long-term productivity
• Irreversible and irretrievable commitment of resources
• Wetlands and floodplains
• Farmland, rangeland, and private property
• Energy sources
• Civil rights and environmental justice

The significant and detrimental impacts from wildfire are immediate and also accumulate over the long-term. Hundreds of peer-reviewed reports, studies, and testimonies that support that contention.

There is no evidence of any harm ever done to aquatic ecosystems by fire retardant. There is abundant evidence of catastrophic damage to aquatic ecosystems by wildfire.

There is no evidence of any harm ever done to firefighters by fire retardant. There is abundant evidence of hundreds (possibly thousands) of firefighter and general public lives saved by wildfire.

There is no evidence of any harm ever done to communities by fire retardant. There is abundant evidence of catastrophic destruction and death inflicted upon communities by wildfire. There is abundant evidence of the value of fire retardant in saving communities from destruction..

The programmatic EIS for the continued nationwide aerial application of fire retardant on National Forest System lands must examine, compare, and elucidate the relative harms done by wildfire and/or by fire retardant.

Thank you for this opportunity to comment.

Mike Dubrasich, Exec Dir W.I.S.E.
https://westinstenv.org

The Western Institute for Study of the Environment is a 501(c)(3) non-profit educational corporation and a collaboration of environmental scientists, resource professionals and practitioners, and the interested public.

Our mission is to further advancements in knowledge and environmental stewardship across a spectrum of related environmental disciplines and professions. We are ready, willing, and able to teach good stewardship and caring for the land.