SOS Forests

W.I.S.E. meets with the WFLC

I attended a forum on the Cohesive Strategy for Wildland Fire Management in Olympia yesterday. This was the tenth of 13 forums sponsored by the Wildland Fire Leadership Council (WFLC). They are part of the WFLC effort [here] to formulate a Cohesive Strategy for wildland fire management, as called for by Congress in the Federal Land Assistance, Management and Enhancement Act (FLAME Act) which was bundled with the FY 2010 Interior and Related Agencies Appropriations Act [here].

SEC. 503. COHESIVE WILDFIRE MANAGEMENT STRATEGY.
(a) STRATEGY REQUIRED.—Not later than one year after the date of enactment of this Act, the Secretary of the Interior and the Secretary of Agriculture, acting jointly, shall submit to Congress a report that contains a cohesive wildfire management strategy, consistent with the recommendations described in recent reports H. R. 2996—69 of the Government Accountability Office regarding management strategies.
(b) ELEMENTS OF STRATEGY.—The strategy required by subsection
(a) shall provide for—
(1) the identification of the most cost-effective means for allocating fire management budget resources;
(2) the reinvestment in non-fire programs by the Secretary of the Interior and the Secretary of Agriculture;
(3) employing the appropriate management response to wildfires;
(4) assessing the level of risk to communities;
(5) the allocation of hazardous fuels reduction funds based on the priority of hazardous fuels reduction projects;
(6) assessing the impacts of climate change on the frequency and severity of wildfire; and
(7) studying the effects of invasive species on wildfire risk.
(c) REVISION.—At least once during each five-year period beginning on the date of the submission of the cohesive wildfire management strategy under subsection (a), the Secretary of the Interior and the Secretary of Agriculture shall revise the strategy to address any changes affecting the strategy, including changes with respect to landscape, vegetation, climate, and weather. …

The forum was by invitation only, but I managed to wangle an invite. The agenda included a form to fill out “to help formulate significant questions that the cohesive strategy development process”. My filled-out form is [here]. The discussion followed the format on the agenda/form.

About 30 people attended the forum in Olympia. Two or three were private citizens (including myself) and the rest were government employees (some state, mostly federal). It was the only Cohesive Strategy forum to be held in the Pacific Northwest. No one from the Oregon Department of Forestry attended. No county officials or representatives of county organizations attended. Three BIA people attended, one being a Native American, but otherwise no Tribal representatives were there. No one from the National Park Service or U.S. Fish and Wildlife was there.

But the lack of diversity in the room did not bother me. I got my my points into the record, which was my goal. I can’t hold everybody’s hand. If your agency wasn’t represented there, that’s not my fault. It is not particularly to my credit either, though, nor yours, nor the WFLC’s.

The discussion was cordial if dull, as befitting a government functionary meeting. I was reserved and held my sparkling wit in check for the most part, baiting the moderator only once or twice. Really, I was very nice and so was everyone else. The moderator and I are friends now, and see things very similarly with one or two exceptions. He likes fire use (whoofoos, foofurbs, niados [here]) and I don’t.

The forums are something of a breakthrough for the WFLC. In prior manifestations they were a secretive and insular body that held closed door meetings. Now they are making an attempt to open the doors a little bit. Outreach is a new thing for them, and these first steps are toddling. They promise to set up an interactive (blog-like) website soon. When they do, I will let you know.

Are Whoofoo and Hammer Gone?

The latest missive from USFS Fire and Aviation Director Tom Harbour indicates that whoofoo (as we call it) is no more. Let It Burn is still happening; they just don’t want to refer to it as whoofoo, foofurb, or any other moniker we can satirize.

There are only two types of wildland fires: wildfires and prescribed fires. The terms “fire use fires,” “resource benefit fires,” or “suppression fires” will not be used. The agency reports activity on only these two types of fire. Manage natural ignitions to achieve desired Land and Resource Management Plan objectives when risk is within acceptable limits. A wildfire may be concurrently managed for more than one objective.

However, if you look close, they are now calling Let It Burn “natural ignitions to achieve desired objectives” or “niados”.

So niados are the new Let It Burn.

The authority to declare niados comes from the WFLC February 13, 2009 Guidance for the Implementation of Federal Wildland Fire Policy or GIFWFMP [here].

The new GIFWFMP (2009) replaces the old GIFWFMP (2004). the changes are, in a nutshell:

1. Wildland fires may be concurrently managed for one or more objectives and objectives can change as the fire spreads across the landscape. That replaces the old guidance that said “wildland fires will either be managed for resource benefits or suppressed. A wildland fire cannot be managed for both objectives concurrently.”

So now the objectives can be swapped around whenever. Note that fires can be managed “for resource benefits”; it’s just that nobody in charge is allowed to say so. See the new “niados” rule above.

2. Initial action on human-caused wildfire will be to suppress the fire… but not necessarily subsequent actions. That replaces “Human caused wildland fires will be suppressed in every instance and will not be managed for resource benefits.” The implication is that human-caused fires may now become niados and Let Burn, even though they are not “natural ignitions”.

3. Same as #1, but replacing the old guidance, “Once a wildland fire has been managed for suppression objectives, it may never be managed for resource benefit objectives.” Now the fire managers can change their minds whenever. They can suppress, then not suppress, then suppress, then not suppress. It all depends on the whim of the person in charge. No Environmental Impact Statement, study or analysis is required.

4. The term Appropriate Management Response is removed from implementation guidance with “Response to Wildland Fire” as the policy area defining the actions for managing a wildland fire.

What ho? Appropriate Management Response, or as we call it, “hammer”, was the official term that described the response to wildfires. Hammer was allegedly based on evaluation of threats to lives and safety, resource values, and fire conditions.

Now it’s gone. The word “appropriate” has been found to be inappropriate. Internal and
public use of the word “appropriate” are discouraged.

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The Burden of the Generalist

Foresters are generalists. Forest management requires stewardship of myriad resources, and the job of the forester is to consider them all, balance them all, and care for them all.

Some people think foresters are solely concerned with timber production. Nothing could be further from the truth. Foresters are responsible for producing forest products for the benefit of the economy, but we are also responsible for wildlife habitat for thousands of creatures; riparian zones, aquatic habitat, hydrology, and water quality and quantity; recreational uses and scenery; soils and soil productivity; heritage and historical cultural resources; fire control, management and prescribed burning; public health and safety; roads and engineering; education, outreach, and public involvement; laws and regulations; bookkeeping and accounting; biology, mathematics, statistics, and probably some more categories I missed.

Foresters need to understand and be well-versed in all the specialties because we oversee the work of wildlife biologists, loggers, campground hosts, and all the other specialized technicians involved in forest management activities. Foresters are similar to general contractors in some respects.

All the various resources and resource values must be considered, measured, accounted for, and managed for in a balanced way. Maximizing the output of any single resource generally diminishes the output of all the others. Hence an optimal mix must be provided for.

Many special interests and factions tug and pull at foresters to produce their favored resource to the exclusion of all others. Some factions want spotted owls and nothing else. Some want timber production and nothing else. Some want elk, or salmon, or hang gliding, or mountain biking, or mushrooms, or human-excluded wilderness, or what have you.

There is a faction with advocates for every resource. They can be notoriously closed minded. SOSF commenter and forester Ken P. noted a conversation he had with the Director of Idaho Conservation League who said that he’d rather see National Forests burn to the ground than one load of logs harvested.

How’s that for “conservation”?

That kind of bellicose all-or-nothing attitude is not uncommon. When I started blogging, a fellow who called himself “GreenInk” wrote to me saying that he would rather set off bombs in school rooms than see a single clearcut. He actually put plans for constructing “incendiary devices” on his website. I don’t know what happened to GreenInk. I think the FBI might have nabbed him. I hope so.

There are factions in SoCal that worship “old-growth” tick brush. They don’t care one whit if the cities in SoCal burn to the ground in catastrophic chaparral fires. Human life is secondary to preserving 50-year-old tick brush.

There are factions that advocate burning old-growth trees in order to “recycle” the forest. They would like to see 1,500-year-old giant sequoias killed in forest fires to make room for seedlings.

All these tuggers and pullers have to be dealt with by foresters. We can’t ignore them nor can we acquiesce to their demands. As generalists, foresters have to consider all resources and resource values. That includes the “value” of destroying resources in conflagrations.

We have been blogging about the Wildland Fire Leadership Council (WFLC) lately. The WFLC is a faction of government functionaries whose special interest is Let It Burn. They value holocaust destruction of all forest resources, primarily because that’s what funds their bureaucracy. The more fire, the more funding.

The WFLC is a particularly onerous faction because they are powerful and very well funded, to the tune of $billions per year. The “fire community” has circumvented the law and displaced foresters as the primary forest management decisionmakers in government forests. They do not balance resource demands — the fire community incinerates any and all resources without prejudice toward any one or the other. They favor Let It Burn on private land, too, including right down Main Street in communities that are within 30 miles of the Federal Estate.

In that regard the WFLC is no different than the Idaho Conservation League or GreenInk the would-be Unabomber Jr. They all have that crazed look in their eyes typical of criminally insane murderers and arsonists.

As generalists, we foresters have to deal with all factions, including the criminally insane. It’s not an easy job, but it’s the one we signed up for. Forests cannot be properly cared for with good stewardship unless all factions and their often outrageous demands are considered, addressed, and if necessary, quashed.

As you might imagine, it can be a frustrating job, especially when powerful bureaucracies are taken over by arsonists, and forests are subsequently incinerated in hundred-thousand-acre chunks. All the work of dozens of foresters over decades can be destroyed in a matter of hours by firestorms of biblical proportions, while the crazies cheer on the destruction.

Forestry used to be a honored profession. Society used to value and appreciate the work of foresters. Now society, large factions of it anyway, disrespects those would would care for our forests in a rational, balanced, professional manner.

A large portion of society is made up of hysterical nutwads who crave apocalyptic catastrophe for one reason or another. They may make money from catastrophe, or are inflamed with hatreds and welcome tragedies of biblical proportion, or are confused, disoriented, and drugged into stupors by the mass media, or who knows what or why.

Through it all foresters hang tough. We have seen the enemy and shrugged them off. Nobody said it was going to be easy. We remain dedicated to good stewardship, balanced resource production and values, and professional forest management for the greater good.

We live in interesting times. Society seems poised to implode, again, in another outburst of mass insanity and inhumanity. But foresters take the long view. We study forest history deep into the past, and plan for forest perpetuation far into the future. We look at the big picture, and remain true to our profession and common sense stewardship.

That’s what generalists do. We are big picture adepts. And that’s how good forestry must be done.

Cost-Plus-Loss, the Tea Fire, and Al Gore

In the previous post [here] we discussed the concept of cost-plus-loss as it relates to wildfire damage assessment. Specifically we noted that a recent GAO report FAILED to consider potential damages from wildfires in its advice to the Wildland Fire Leadership Council (WFLC) “Cohesive Strategy” planning process.

All the GAO cares about, and by inference and extension all that Congress and the WFLC care about, is fire suppression expenses. They wish to minimize the amount spent on firefighting. Among their cost-saving strategies: Let It Burn wildfires and a “Leave Early Or Stay And Defend” policy that calls for homeowners to run for their lives or else defend their own properties from wildfires.

To the Federal Government “cost containment” means reducing fire suppression costs.

But to the real world, the costs of wildfires include the economic damages (losses) of the resources destroyed by the fire.

Allow me to segue for a moment. Hot off the news wire: Al and Tipper have just purchased a home in Montecito, CA.

Al Gore, Tipper Gore snap up Montecito-area villa

by Lauren Beale, Los Angeles Times, April 28, 2010 [here]

Former Vice President Al Gore and his wife, Tipper, have added a Montecito-area property to their real estate holdings, reports the Montecito Journal.

The couple spent $8,875,000 on an ocean-view villa on 1.5 acres with a swimming pool, spa and fountains, a real estate source familiar with the deal confirms. The Italian-style house has six fireplaces, five bedrooms and nine bathrooms.

Sounds swanky, eh?

Montecito just happens to be the site of the Tea Fire [here] in 2008. The Tea Fire burned up a mere 1,940 acres. Suppression costs were $5.7 million. That’s nearly $3,000 per acre, way too steep for the GAO. They’d like suppression costs down around $100 per acre.

The GAO fails to consider resource losses to wildfires, however, which in the case of the Tea Fire were in the $500 million ballpark.

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The GAO Let It Burn Policy

The newly reconstituted Wildland Fire Leadership Council (WFLC) has embarked on a “Cohesive Strategy” planning process [here, here, here].

The “Cohesive Strategy” was mandated by the Federal Land Assistance, Management and Enhancement or FLAME Act [here, here, here].

National Blueprint on Wildfire Management

by Phil Leggiere, HS Today, 26 April 2010 [here]

On Wednesday April 21 at the Wildland Fire Leadership Council in Washington, DC, Department of Homeland Security (DHS) Secretary Janet Napolitano, Secretary of Agriculture Tom Vilsack, and Secretary of the Interior Ken Salazar jointly announced a blueprint for the first comprehensive national strategy for wildfire management. …

The new strategy will analyze three key components: landscape restoration, fire-adapted communities, and response to wildfire and is scheduled to be completed this fall in accordance with a recent act of Congress.

The FLAME Act of 2009 requires the Forest Service and Department of Interior to submit to Congress a report that contains a cohesive wildfire management strategy consistent with recommendations in recent General Accountability Office (GAO) reports regarding management strategies. Following its formal approval by the Secretary of Agriculture and Secretary of Interior by October 2010, the Cohesive Wildfire Management Strategy is to be revised at least once during each five year period to address any changes with respect to landscape, vegetation, climate, and weather conditions.

According to the legislation the Cohesive Strategy is required to provide for the identification of the most cost effective means for allocating fire management budget resources. This includes the reinvestment in non-fire programs by the Secretaries of the Interior and Agriculture, employing the appropriate management response to wildfire, assessing the level of risk to communities, allocation of hazardous fuels reduction funds based on the priority of hazardous fuels reduction projects, and assessing the impacts of climate change on the frequency and impact of wildfire. …

Note two key points. First, the “Cohesive Strategy” is to be consistent with recent General Accountability Office (GAO) reports regarding fire management strategies. Second, the goal is “cost effective” fire management budgeting.

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WFLC Cohesive Strategy Field Forums

The newly reconstituted Wildland Fire Leadership Council (WFLC) has decided to open up their deliberations to a wider audience.

Background:

The WFLC is an intergovernmental committee of Federal, State, Tribal, County and Municipal government officials convened by the Secretaries of the Department of Interior, Agriculture and Homeland Security, that is dedicated to coordinated implementation of wildland fire policies, goals and management activities. The Council provides strategic oversight to ensure policy coordination, accountability and effective implementation of Federal wildland fire management policy and related long-term strategies to address wildfire suppression, assistance to communities, hazardous fuels reduction, habitat restoration and rehabilitation of the Nation’s forests and rangelands.

In the past the WFLC has been secretive and exclusionary. The policies they have promulgated have had a significant effect on the environment, both public and private lands, yet the WFLC has not complied with various environmental laws such as NEPA and the ESA.

But those defects have been brought to public attention (by SOS Forests), and now the WFLC is making an attempt to rectify the situation — to some extent.

First, the WFLC is undertaking a Cohesive Strategy process “to develop a strategy to more effectively address America’s wildland fire challenges.”

U.S. To Develop More Effective Wildfire Strategy

Source: U.S. Department of Agriculture, GovMonitor, 21st April 2010 [here]

Agriculture Secretary Tom Vilsack, Secretary of the Interior Ken Salazar, and Secretary of Homeland Security Janet Napolitano today announced the formation of a federal partnership with state, regional, local and tribal leaders to develop a strategy to more effectively address America’s wildland fire challenges.

“At a meeting of the Wildland Fire Leadership Council in Washington, D.C., local officials joined governors, representatives of tribal governments and the departments of Agriculture, Interior, and Homeland Security to establish a blueprint for a “Cohesive Wildfire Management Strategy.”

“The Council provides the right framework for a strong national strategy to address the growing threats of wildfire,” said Secretary Salazar. “The Council’s partnerships are key to the establishment of a national, intergovernmental wildfire policy that will ensure the safety of our firefighters and the citizens they protect as we confront longer and more intense fire seasons in more regions of the country.”

“There are no easy solutions to the challenges of wildland fire,” said Secretary Vilsack. “But a cohesive wildfire management strategy will provide the best blueprint to ensure community safety and the restoration of ecosystems that will, in the long run, benefit all Americans, especially those who live in rural areas.”

“Developing a comprehensive national strategy to prepare for and protect against wildfires that threaten the safety of Americans is an important part of our efforts to build a culture of resiliency in communities across the country,” said Secretary Napolitano.

At the Council meeting, federal, state, local and tribal government representatives agreed to develop a comprehensive landscape-scale analysis of all wildlands, based on the best available science, and a strategic blueprint of policy and program alternatives for the wildland fire community. The strategy will analyze three key components: landscape restoration, fire-adapted communities, and response to wildfire.

The Cohesive Wildfire Management Strategy will address America’s increasing wildland fire challenges. Currently, millions of acres of public lands across the country are at risk of large wildfires due to overcrowded stands of trees, insect infestations, and invasions of non-native species. …

As part of that process the WFLC will be conducting “field forums” to “to enhance collaboration and the raise the visibility of the strategy formulation process.” For an update (April 14) on that process see [here]. For an initial schedule see [here].

Attendance at the field forums is by invitation only. Yours truly has not received an invitation but I’m working on it. If I don’t receive one, I might go to one anyway, stand outside on the sidewalk, and pass out screeds. Or not — I haven’t come to any final decision on that.

Secondly, the WFLC has intimated that they might “establish a ‘public portal’ on the website to solicit and receive input for the Cohesive Strategy Oversight Committee and accommodate those interested but unable to attend the scheduled field forums.”

That particular accommodation has not been made yet, but if it happens, we will be the first to flood their new site with input. I will let you know so you, too, can participate in the process. Your forests, watersheds, and communities are in the line of fire, so to speak, and so you should avail yourself of the opportunity make your voice heard.

I am certainly going to do so. The fate of our forests should not be placed in the hands of non-foresters with a Let It Burn agenda who operate in noncompliance with the law. We have tried that style of forest management, and it has failed catastrophically.

DOI Responds to W.I.S.E. Letter to Salazar re WFLC

On March 6, 2010, in my capacity as Executive Director of W.I.S.E., I wrote an Open Letter to Ken Salazar regarding the reconvening of the Wildland Fire Leadership Council (WFLC) [here]. In that letter I observed that in the past 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).

I also observed that:

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.

and furthermore:

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.

Finally, I advised Sec. Salazar that:

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.

Yesterday I received a response from DOI, a very nice letter from Pamela Haze, Deputy Assistant Secretary for Budget, Finance, Performance and Acquisition acting on behalf of Ms. Rhea Suh, Assistant Secretary for Management & Budget and CFO.

That letter in its entirety follows:

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WFLC Up to Their Old Tricks

The Wildland Fire Leadership Council (WFLC) is up to their old tricks, and catastrophic megafires are sure to follow.

The WFLC is a Federal Advisory Board that was established in April 2002 to implement and coordinate the National Fire Plan, the Ten-Year Strategy (a component of the National Fire Plan) and the Federal Wildland Fire Management Policy. They are the group that has promulgated whoofoos (wildland use fires or WFU’s).

For A Short History of the WFLC see [here].

The WFLC excludes the public and the press from their meetings. They do however seat deep-pocket lobby groups (non-governmental organizations or NGO’s) 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 lthe 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).

As a result, numerous wildfires have been allowed to burn without aggressive suppression actions. Tremendous destruction and degradation of natural resource values has occurred [here].

Two days after I posted “A Short History” (above, March 15, 2010) the WFLC, reformed by Sec Interior Ken Salazar, had a meeting. They subsequently posted a brief summary of the minutes of that meeting [here].

Those March 17, 2010 minutes are the first the WFLC has posted in 2 years. An excerpt:

The WFLC agreed to adopt the Cohesive Strategy (CS) proposal in the comprehensive form, including the three components of Landscape Restoration, Fire-Adapted Communities, and Fire Response as presented. The 2009 Quadrennial Fire Review (QFR) and National Policy Framework Documents (A Call to Action, Mutual Expectations, and Roles and Responsibilities) will be the foundational documents from which the CS will be developed, and that “Risk” will be the “common currency” used for scientific evaluation and assessment of alternatives.

Before April 15, 2010, the WFLC members will be provided with details of this CS blueprint approach including, process structure, locations of workshop, categories of invitees, a plan for tribal consultation and how this will meet the requirements of the FLAME Act.

The WFLC will act as Board of Directors, oversee the invitation process, and ensure the development process is collaborative.

The CS Oversight Committee, Tom Harbour and Kirk Rowdabaugh, will send Cohesive Strategy development process details to Ryan Yates, Mike Carrier, Ann Walker, Caitlyn Pollihan, Bob Roper, and Jim Erickson. They will make suggestions about who to invite and locations for local workshops. Invitations will be based upon the principles of inclusiveness and diversity, including geographical, levels of government, non-government, and cultural. These people, including Kirk and Tom, will comprise the Cohesive Strategy Oversight Committee.

I am pretty sure I will NOT be invited to the invitation-only meetings.

Note that the WFLC has chosen the 2009 Quadrennial Fire Review (QFR) to guide their “Cohesive Strategy”. SOS Forests posts regarding the QFR are [here, here, here]. The entire QFR may be downloaded [here].

The QFR includes endorsement of the “Leave Early Or Stay And Defend” policy that resulted in 200 deaths and more than 2,000 homes incinerated in Australia in February 2009. It also includes endorsement of the expansion of wildland fire use (whoofoo’s). The QFR was supposed to be a speculative look ahead, not a policy guidance document. It was never subject to public review and was never “adopted” by policy makers. Yet here it is guiding policy — again without public input or public review.

Also noted in the March 17, 2010 WFLC minutes is yet another revision of the Memorandum of Understanding (MOU) authorizing the WFLC. They did not include the revisions in their posting. The MOU is the legal document that justifies inclusion of NGO’s at WFLC meetings and the exclusion of the public. It would probably require a FOIA request to obtain that document, but there is no guarantee that the WFLC will obey a FOIA request. They do not feel they have to obey other Federal laws.

The fire community is philosophically divorced and estranged from the forest community. The fire people do what they do without consideration for the multiple values that form the foundation of forest stewardship and management such as timber, wildlife, water, soils, recreation, etc., and without consideration of the laws that guide forest management such as ESA, NEPA, MU-SY, NFMA, HFRA, etc.

Fire “management” is on its own separate track, seemingly above the law in many ways. That leads to huge conflicts, catastrophes, megafires, and circumvention of forest management goals, as well as a plethora of activities that are more or less illegal. The WFLC thumbs it nose at many laws, not just FACA and APA.

Dr. Stephen J. Pyne wrote two excellent essays that W.I.S.E. has posted about the widening gap between fire management and forest management. They are apropos and very much worth reading:

The Wrath of Kuhn [here]

Friendly Fire [here]

The WFLC typifies government at its worst: exclusionary, elitist, above the law, corrupt, and hugely destructive. Our forests, watersheds, homes, and very lives are put at risk whenever the WFLC meets. The “Risk” that is their “common currency” is yours and mine, not theirs.

Be prepared to flee your homes the next time a fire erupts on Federal land. Whether you live in a small town like New Harmony, Utah, or a big city like Los Angeles, when the fire community guided by the WFLC decides to burn you out, they will, without a second thought.

Blame the Victims: The Mill Flat Whoofoo Cover-up

The US Forest Service has issued a “Lessons Learned” report blaming the citizens of New Harmony, Utah for burning their own homes down in a whoofoo (wildland fire use fire).

The Mill Flat WFU Fire (2009, Dixie NF, 12,607 acres) [here] 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.

Now the USFS blames the victims for failing to express their wishes that the Agency put the fire out before it blew up. The Mill Flat Fire Review (4.5 MB PDF) was posted 4/2/2010 at the Wildland Fire Lessons Learned Center (WFLLC) [here]. (Note: The WFLLC is part of the National Advanced Fire & Resource Institute (NAFRI) [here], an “interagency consortium” supported by the USFS, BLM, NPS, BIA, and USFWS.)

Background [here]: The Mill Flat WFU Fire ignited July 25, 2009, in the Dixie National Forest. Bevan Killpack, Pine Valley District Ranger and Rob MacWhorter, Forest Supervisor for the Dixie NF, decided the fire should be allowed to burn unchecked. One person was assigned to monitor the fire and a 29,000 acre “maximum manageable area” was designated. The Mill Flat Fire was declared a foofurb, a “fire used for resource benefit”, despite the fact that no benefits were elucidated, no EIS created, and no public involvement or hearings held.

Note: Foofurb is the new (2009) designation for whoofoo. After eight years of promoting “wildland fire use” (WFU or whoofoo), the propaganda meisters decided to change the name to foofurb, “fire used for resource benefit”. In fact, whoofoos and foofurbs are Let It Burn fires. The USFS hates the term “Let It Burn” so they desperately seek obfuscations.

As of August 22 the fire was 550 acres. Then a week later the wind came up, the fire blew up, and by August 31 the fire was 10,382 acres. The fire roared into New Harmony, Utah, forced the evacuation of 170 New Harmony residents, destroyed three homes and damaged eight buildings.

Some benefit, eh?

At the time Utah Governor Gary Herbert criticized the USFS [here]

“It appears the Forest Service started the fire,” Herbert said Sunday. “They should take responsibility.” …

Herbert also took aim at restrictions on federal wilderness areas. The Mill Flat fire started July 25 within the Pine Valley Mountain Wilderness Area.

Before Congress designated the area as protected wilderness, livestock grazing controlled vegetation overgrowth that causes fires to burn more intensely when they do start, he said.

“With wilderness, our hands are tied behind our backs,” Herbert said. “It sets us up for a tragedy.” …

Fire spokesman Kenton Call said questions about cost and the decision not to fight the fire earlier will be addressed at a later date.

The later date has arrived and the questions answered: the fire blow up and destruction it caused were the fault of the New Harmony residents, not the USFS.

According to the Lessons Learned report, one of the factors that led to the fire reaching town was that residents failed to inform the USFS that they did not wish to be burned out:

Several folks interviewed shared that although they had concerns or doubts about continuing with the strategy to manage the Mill Flat Fire after August 25, 2009, they did not speak up.

Evidently if you don’t scream in their ears, the USFS cannot hear you. Officious blobs of stupid will incinerate you, and then blame you for not explaining to them what a poor decision choice that might be.

According to the Lessons Learned report, the public was “confused” by the “multiple terms for various management options for wildland fire”.

“Fire for Resource Benefit”, “Suppression Fire” and “Benefit Fires” are terms and ideas that continue to narrow our vision. Labels can narrow one’s vision of management options and perhaps contribute to reduced situational awareness. … There were misconceptions among the participants regarding the interactions between wilderness and fire management policy.

One of the narrow visions that confused the public was that the USFS fuel break designed to protect the community of New Harmony would be effective at stopping a fire. The report clarifies that misunderstanding:

* The fuel break had not been maintained for years…

* The original design of the fuel break required all vegetation to be left in the drainages. This resulted in two “wicks” that, if left untreated, provided a clear path for the fire to cross. …

* The fuel break was built on the USFS property boundary; in many cases this was not best tactical location to be effective.

* The width of the fuel break was not adequate for the fire behavior that occurred.

* The fuel break was never intended to “stop” a fire but rather to reduce fire intensity to a more manageable level by reducing fuel loading and breaking the continuity between the wildlands and the community.

The fuel break was a joke. The residents of New Harmony should have known they were being played. They were told that “public safety” was the principal concern of the USFS in any fire situation. The residents were gullible enough to believe that, when the policy of the USFS over years and years was to ignore public safety with a fake fuel break that the USFS knew was inadequate and poorly designed.

Now the USFS says the purpose of the fuel break was NOT to stop fires from burning into town. The residents should have known that all along.

The Lesson Learned conclusions:

The team found that managers performed within the context of their experience and training. Their actions were reasonable based on what they knew and what they expected to happen and the policy available to guide their decisions.

Fire managers consistently made firefighter and public safety the highest priority on the Mill Flat Fire. Strong interagency relationships helped communicate with partners on fire status.

In other words, NO LESSONS WERE LEARNED AT ALL.

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A Short History of the WFLC

Questions have arisen regarding my Open Letter to Open Letter to Ken Salazar Re WFLC [here]. By way of clarification, I have prepared the following.

Note: this essay refers to the Wildland Fire Leadership Council, not the Western Forestry Leadership Coalition, which shares the same initials but is an entirely different organization.

The Wildland Fire Leadership Council (WFLC) was established in April 2002 by the Secretaries of Agriculture and the Interior to provide an intergovernmental committee to support the implementation and coordination of Federal Fire Management Policy. [here]

The Wildland Fire Leadership Council (WFLC) was established in April 2002 to implement and coordinate the National Fire Plan, the Ten-Year Strategy (a component of the National Fire Plan) and the Federal Wildland Fire Management Policy. WFLC consists of senior level department officials, federal, state, tribal and county representatives, including all five federal wildland firefighting agency heads. WFLC was established to address interagency, interdepartmental differences to ensure seamless delivery of a coordinated fire protection program. The Council brings together wildland firefighting organizations to implement the 10-Year Comprehensive Strategy and Implementation Plan. WFLC meets regularly to monitor progress of the Ten-Year Strategy, to discuss current issues, and to resolve differences among wildland firefighting agencies.

Authority. The Departments of Agriculture and the Interior are authorized to enter into cooperative agreements by the Protection Act of 1922 (42 Stat 857; 16 U.S.C. 594) and the Public Land Administration Act of 1960 (74 Stat 506; 43 U.S.C. 1361-1364).

In addition, the Secretaries entered into a Memorandum of Understanding dated January 28, 1943, and February 21, 1963, to provide adequate wildfire management and protection to the lands under their respective jurisdictions. State representation is authorized by the Clarke-McNary Act of June 7, 1924, Sec. 1 (43 Stat 653, 16 U.S.C. 564). [here]

In Fall of 2006 it came to my attention that lobbying groups, specifically the Nature Conservancy (TNC) and the Wilderness Society (TWS), were participating in WFLC meetings. I made an inquiry to the Committee Management Secretariat (CMS) of the GSA which oversees the Federal Advisory Committee Act (FACA). They informed me that the incorporation of registered lobbyists on Federal Advisory Committees was a “gray area” of the law, and that I could file a lawsuit if I so desired.

I consulted with my attorney and he asked me how much money I had. That killed that idea.

In the meantime the WFLC received some sort of communication from the CMS regarding my inquiry, and in early 2007 they asked Federal attorneys to draw up a Memorandum of Understanding that would declare them NOT to be a Federal Advisory Group and to allow registered lobbyists to continue to participate. From the WFLC minutes of February 22, 2007 [here]:

WFLC MOU

* Request Secretaries to extend MOU
* Revise MOU language for NGO participation consistent with WFLC goals. WFLC should not become a Federal Advisory Committee. Consider addition of a fire chief’s representative as WFLC member, in a manner consistent with FACA. Confer with legal counsel. Draft business rules for review.
* Circulate draft, convene conference call to discuss. (WFLC Staff)
* New MOU at June meeting

TNC and other NGOs will assist with communication plan for wildland fire use as part of TYIP Goal 3, Task 2.

On April 3, 2007 I reported all this at SOS Forests [here]. As a direct result, on April 5, 2007 the WFLC removed the Feb. 22 minutes and their entire directory at http://fireplan.gov, a URL that no longer exists.

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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)

Jon Tester’s Forest Bait and Switch

Last week Montana Senator Jon Tester unveiled his new proposed “Forest Jobs And Recreation Act of 2009.” Sounds like a good thing, right? Don’t be fooled — it’s a Burn Baby Burn wilderness bill.

Tester announced his “jobs” bill at a news conference in Townsend, MT. His press release is larded by feel good statements that don’t wash:

Tester introduces forest bill; will discuss in Seeley Lake at noon Saturday

Clark Fork Chronicle, July 17 2009 [here]

Standing with loggers, outfitters, conservationists, hunters and fishermen who spent years working together on a plan for Montana’s forests, Senator Jon Tester today introduced his much-anticipated legislation to reform forest management to “make it work” for Montana.

“Our forests, and the communities and folks who rely on them, face a crisis right now,” Tester said today at a news conference at RY Timber in Townsend. “Our local sawmills are on the brink, families are out of work, while our forests turn red from an unprecedented outbreak of pine beetles, waiting for the next big wildfire. It’s a crisis that demands action now. This bill is a made-in-Montana solution that took years of working together and hearing input to create a common sense forest plan.”

He said his 80-page bill, formally called the Forest Jobs and Recreation Act, will create jobs, protect clean water and keep Montana’s prized hunting and fishing habitat healthy for future generations. …

The legislation is available for public viewing on a new website Tester’s staff set up [here]. Careful reading of the actual language reveals the following:

* Tester’s bill will add 669,060 acres of new designated wilderness, primarily chopped out of the Deerlodge National Forest

* An additional 336,205 acres of “Protection” and “Special Management” areas will be also be put off-limits to forest treatments.

* All told, over a million acres will be set aside for No Touch, Let It Burn, Watch It Rot destruction.

Create jobs? Those new Let It Burn zones won’t even create jobs for firefighters, except when the unmanaged fires jump the boundary lines and rage down into private land.

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The Unfinished Saga of the Backbone Fire

By Mike Dubrasich

The Backbone Fire was ignited by lightning on July 1st and is currently burning in the Salmon Mountains of Trinity County in Northern California. As I write, the Backbone Fire [here] is reported to be 6,324 acres and 80 percent contained. Both direct and indirect fire suppression actions are being undertaken.

Thus the Saga of the Backbone Fire has no ending, yet. Furthermore, surprising as it may seem, the story begins deep in the misty past, long before there was even a forest there.

In this essay we will attempt to tell the saga, as best we are able, in full knowledge that the whole story is beyond the scope, backwards and forwards, which we peer through. And we hope to add to this essay in the future, when it arrives, and the final chapters transpire in the present-to-be.

Ancient History

Before the Great Warming occurred that signaled the end of the Wisconsin Glaciation about 12,500 years ago, the Salmon Mountains were icy peaks laden with glaciers. Along the California coast to the west was an Ice Age refugia, warmed by oceanic currents and kept free of ice. There towering Pleistocene redwoods grew, isolated from the rest of the continent by tundra and ice.

Some 13,000 years ago, or perhaps earlier, hardy bands of human beings made their way south to the redwoods from the Bering Land Bridge, or perhaps north from already inhabited South America, no one knows for sure. They were likely a maritime people, living on the edge of the ocean and dining mainly on seafood. Some evidence (there is very little remaining) suggests that those people were also knowledgeable about and utilized the vegetation of the refugia, for food, clothing, shelter, medicines, and fuel.

The Great Warming came, in fits and spurts, and by 11,000 years ago the climate had warmed to more or less modern conditions. The Salmon glaciers melted and forests invaded the formerly frozen ridges and valleys.

This timeline has one telling feature: human beings preceded the forests in the Trinity Mountains, as we did across much of North America. People came before the forests, not after.

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Wildfire — Beneficial or Damaging?

The US Forest Service is incinerating millions of acres this year with dozens of wildfires they Let Burn under the rubric of “fires used for resource benefit” (FUFRB’s), or as we called them, foofurbs. Foofurbs have replaced whoofoos (Wildland Fire Use fires or WFU’s) [here].

Background: the illegally constituted Wildland Fire Leadership Council (WFLC) [here] is the Federal Advisory Committee that oversees firefighting on Federal land, including USFS, BLM, NPS, USFWS, and BIA. The WFLC seated radical enviro lobbyist groups such as the Wilderness Society, promulgated a “Black, Dead Forests Are Beautiful” campaign [here] and invented whoofoos [here] as a substitute for Let It Burn. After complaints were received, the WFLC went underground. They no longer post meeting notices or minutes [here] or even their membership list [here] (note that the names and dates are over a year out-of-date).

This year, in secret backroom meetings with radical enviro holocaust advocates, the WFLC dumped whoofoo and replaced it with foofurb. This is despite the push over the last two years to write WFU into over 30 National Forest Plans nationwide. Now the WFU language is defunct, and all the illegal altering of Forest Plans must happen again.

In the meantime, foofurbs have sprung up all over. The Southwest Region has already burned a half million acres this year in foofurbs. The Southern California, Alaska, Eastern Great Basin, and Rocky Mountain Regions all have foofurbs burning right now.

Interestingly, in none of these foofurb fires has the USFS specified exactly what the alleged benefits of “fires used for resource benefit” are. There have been no analyses made, no declarations, no public hearings, and most importantly, no Environmental Impact Statements produced.

The National Environmental Policy Act (NEPA) is quite clear in stating that any major Federal action that will have significant effects and impacts on resources and the human environment requires an Environmental Impact Statement (EIS) prior to implementation of that action. Potential “significant effects” require an EIS whether or not those effects are characterized as detrimental or beneficial:

“Significantly” as used in NEPA requires considerations of both context and intensity:

(a) Context. This means that the significance of an action must be analyzed in several contexts such as society as a whole (human, national), the affected region, the affected interests, and the locality. Significance varies with the setting of the proposed action. For instance, in the case of a site-specific action, significance would usually depend upon the effects in the locale rather than in the world as a whole. Both short- and long-term effects are relevant.

(b) Intensity. This refers to the severity of impact. Responsible officials must bear in mind that more than one agency may make decisions about partial aspects of a major action. The following should be considered in evaluating intensity:

Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial.

From Sec. 1508.27, the Environmental Quality Improvement Act of 1970, as amended (42 U.S.C. 4371 et seq.), sec. 309 of the Clean Air Act, as amended (42 U.S.C. 7609), and E.O. 11514 (Mar. 5, 1970, as amended by E.O. 11991, May 24, 1977). Source: 43 FR 56003, Nov. 29, 1978, unless otherwise noted.

When the USFS deliberately conducts foofurb fires, it does not matter what their excuse is. “Restore ecological function” or “rejuvenate wildlands” are largely pseudo-scientific BS, but they are also tacit admissions that the actions will have significant effect on the environment. Ergo, the USFS is in multiple violation of NEPA and they know it.

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Let It Burners Obfuscate the Facts

The Redding Record Searchlight continued its series of articles about forests and fire [here, here] this week with a Dylan Darling piece on firefighting methods [here].

Firefighting methods questioned

By Dylan Darling, Redding Record Searchlight, May 1, 2009

Last summer Rayola Pratt experienced the fear that haunts so many in the north state. Wildfire tore through the woods near her home off Rock Creek Road west of Redding.

“From here we could just watch the trees burst into flames,” she said.

When she evacuated as the Motion Fire pushed flames toward her place, she left her home in the care of a fire crew from Montana that slept on her deck between shifts. It was the biggest fire to burn near the home in the 40 years Pratt has lived there and she partially credits the firefighters for saving it.

While people with opposing points of view about wildfire issues in the north state agree that homes threatened by flames should be saved, they disagree about the level at which fire should be fought in the wildland.

At the crux of most any debate about wildfire suppression is the question of how aggressively to attack — when should firefighters hit fires with everything available, and when should they let them burn. The issue is complex, with firefighter safety, threats to life or property and potential benefits of fire for the land all taken into consideration by the agencies fighting the flames.

That would be nice if it were true, but it isn’t. The “agencies fighting the flames” do not take “potential benefits of fire for the land” into consideration, principally because there aren’t any.

Wildfires that are allowed to burn hundreds of thousands of acres all summer long do not benefit the environment. That canard is mousy propaganda, a falsehood, a raft of bilge, not the facts, sophistry, and too easy fodder for numskull journalists anxious to grovel in front their government informants.

The facts are that wildfires destroy forests, incinerate habitat, pollute air and water, cripple rural economies, and scar landscapes for lifetimes.

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