Some Let It Burn Questions Answered

Correspondent Zeke asked some pertinent questions regarding the Oak Flat Fire [here].

Dear Zeke,

Thank you for your questions. Here are the answers:

1. This fire could indeed have been contained at 800 acres. On Aug 15 the fire grew from 600 to 800 acres. On that date there were already nearly 500 firefighting personnel on the scene, 8 helicopters, and air tankers standing by in Medford.

The area is not “wilderness” or roadless. It is well-roaded throughout. No additional dozer work was necessary to contain the fire. There have been no strong winds so far, thank goodness, or the fire would have swept into Grants Pass within hours. Allowing the fire to grow and grow for weeks on end runs the risk that winds will arise and the fire will become a major disaster, burning farms, homes, towns, and cities. The USFS has chosen to endanger tens of thousands of residents, none of whom had any say so in the matter. That increased risk is manifest right now and will be for weeks to come.

2. It was and is possible to SAFELY put this fire out by ‘going direct’ on it. Indirect attack is LESS SAFE. Right now the “plan” is to put 1,000 firefighters a day for weeks on this fire. That is 10 to 20 times the man-hours necessary to contain it. By expanding the man-hours enormously, the risk of accidents increases.

Most firefighting injuries and fatalities are not due to burning up. They are due to machine accidents and fireline accidents, such as helicopter crashes and falling trees. The chance that those kind of accidents will occur is INCREASED by extending the fire for weeks and by extending the fire perimeter 10-fold.

3. There are no “benefits” to resources from wildfire. The USFS does not claim such. The use of the term “wildland fire used for resource benefit” is kaput. You can read the memo [here].

It is important to note that the deliberate use of fire produces significant impacts to the environment. We have laws regarding federal agencies impacting the environment, such as NEPA. If you read that law, you will note that “benefit” or “detriment” do not matter. What matters is whether the impacts are “significant”. No one argues that fire effects are insignificant.

Yet the USFS did not follow the legally mandated NEPA process before deciding to expand this fire ten-fold. They broke the law. That makes them criminals. Nobody wants federal agencies to break the law. I don’t at any rate. Do you?

For more discussion on this aspect, see [here, here, here, here].

4. Instead of looking at Google Earth, you may wish to examine the forest road map. That will show you the existing road density of the area. The road network is extensive. No new roads are needed, or new dozer lines, to contain this fire.

5. 6. 7. So you think that they could have held it to this footprint? Have you ever fought fire in that country? Are you an expert on wildfire tactics? Yes, Yes, Yes.

8. Is anything about that ground worth killing a single firefighter? Hold on there, Zeke. I am not for killing anybody. As I discussed above, extending the fire in time and space INCREASES the risks to firefighters.

In 2008 over 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 in accord with a revised fire policy the USFS called “Appropriate Management Response” (since then the USFS has dropped that lingo term, too). Building firelines miles away from the fires and backburning hundreds of thousands of acres of private and public land alike were deemed “appropriate.” Despite the remote firefighting techniques, ostensibly intended to save money and protect firefighters, over $400 million was spent on suppression and 12 firefighters were killed.

In 2009 direct attack was used on a fire in the same area. The Backbone Fire [here] was 6,100 acres in steep un-roaded country when the decision was made to use direct attack. The fire was 100% contained within a week at 6,324 acres, with no accidents and no fatalities.

So you see, Zeke, extending this fire is far more likely to result in death to firefighters than direct attack would have. Perhaps you should aim your “killing firefighters” question at the USFS instead of at me.

9. What do you hope to accomplish with your rant? My purpose, indeed the purpose of W.I.S.E., is to educate. The “rant” characterization is impolite on your part, but whatever the literary quality, my post caught your attention. And now I am educating you further. Please read (study) the links provided. You have much to learn, and we are here to aid you in that.

Thank you again for your questions. Please feel free to ask us such good questions anytime.


Mike Dubrasich, Exec Dir W.I.S.E.

Criminal Incineration of the Rogue River-Siskiyou NF

The Oak Flat Fire [here] was reported this morning to be 1,706 acres. The plan, however, is to allow the fire to grow to 12,000 acres, either through inaction or deliberate backfiring.

The Oak Flat Fire was ignited by unknown causes in the Briggs Creek area of Rogue River-Siskiyou NF, about 10 miles west of habitations in the Rogue River Valley and 8 miles northwest of the community of Selma in the Illinois River Valley.

Oak Flat Fire Briefing Map, August 19, 2010. From InciWeb [here]. Click for larger image.

The red outlined area is the current fire perimeter. The black lines indicate the positions of the “indirect” fire lines planned by the Southern Oregon/Northern California Type II Interagency IMT Incident Commander Brett Fillis [here] in collaboration with the Rogue River-Siskiyou NF Forest Supervisor Scott Conroy, and with the approval of Region 6 Regional Forester Mary Wagner.

The black lines encompass approximately 12,000 acres. The area to be burned includes portions of the Illinois Valley Wild and Scenic River corridor. It also includes known nesting sites of the Northern Spotted Owl, a species on the Threatened and Endangered Species list.

InciWeb reported:

…[F]ire managers are planning to conduct burnout operations aimed at efficiently connecting the fire into the containment lines within the few days. Both ground and aerial ignition methods will be used, with particular attention paid to minimizing tree mortality and preserving spotted owl habitat. …

The Regional Forester reviewed the fire management plan, activities and organization on Thursday, 8/19/10.

That language implies that deliberate ignition of spotted owls stands will be occurring as the fire managers expand the footprint of the fire 10-fold. Further, those operations have been approved by Regional Forester Mary Wagner.

Deliberate incineration of endangered species habitat is a violation of the Endangered Species Act. The USFS has not conducted any NEPA analysis, such as an Environmental Impact Statement. Nor have they conducted any Section 7 (of the ESA) consultation with the US Fish and Wildlife Service.

The entire area is an ancient cultural landscape, as indicated by place names such as Oak Flat and Onion Mountain. Soldier Creek was named during the Rogue River Indian Wars [here] of the 1850’s. As such the area has significant archaelogical and heritage sites. No Section 106 review (of the National Historical Preservation Act [here]) has been conducted.

The USFS is well-aware that deliberately expanding a wildfire by backburning thousands of acres of legally protected landscapes is illegal.

In March of 2008, the Rogue River-Siskiyou National Forest issued a notice of intent to produce a Fire Use Amendment Environmental Assessment [here] that would change the language in their Land and Resource Management Plan and Fire Management Plan to include “allowing” wildfires to burn across vast acreages.

That plan amendment has NOT been adopted. Serious objections have been raised and appeals filed. What the final outcome will be is unknown, but the Fire Use Amendment has NOT been adopted as yet.

Regardless, USFS officials are proceeding as if the laws do not apply to them.

This is not the first time the Rogue River-Siskiyou NF has ignored the law. Adjacent to the planned fire perimeter of the Oak Flat Fire is the Biscuit Burn, a 500,000 acre scar that resulted from a Let It Burn fire of 2002. The Biscuit Fire was the largest fire in Oregon state history and eventually cost over $150 million to suppress when it blew up into a 12-mile-long fire front and threatened the communities of Selma and Grants Pass (the same communities now threatened by the Oak Flat Fire).

Over 75 Northern Spotted Owl nesting sites were destroyed by the Biscuit Fire.

In 2008 the Rogue River-Siskiyou NF perpetrated another illegal Let It Burn fire, the Lonesome Complex/Middlefork Fire [here], which was allowed to grow from 500 acres to 21,000 acres, incinerating numerous old-growth and Northern Spotted Owl nesting stands.

The criminal activities by Federal government functionaries on the Oak Flat Fire will have devastating impacts to wildlife, wildlife habitat, heritage, scenery, recreation, and other natural resources. Those impacts will be long-lasting. Furthermore, allowing the fire to burn for weeks on end will pour smoke into communities and cause severe public health problems. Expanding the planned fire perimeter and backfiring thousands of acres will exacerbate those damages.

Allowing the fire to burn for weeks on end also runs the risk that a wind event could cause a fire blow-up and carry the fire to private lands and communities.

None of those communities, or their elected officials or representatives, have any influence over the USFS fire decisions. The USFS acts like an occupying army with no regard for the local residents or the law, and with the malicious intent to devastate and destroy watersheds and landscapes no matter what the impact may be resources or to the local communities.

The Oak Flat Fire is growing and will continue to grow, due to deliberate actions of the USFS, because the criminals in charge feel that they are impervious to legalities and public opinion. But there will be a denouement after this fire. Their crimes will not be swept under the rug this time.

1 Jul 2010, 2:06pm
Federal forest policy Saving Forests
by admin

Let It Burn Plan Appealed

Western Institute for Study of the Environment

For Immediate Release, July 1, 2010

The Western Institute for Study of the Environment (W.I.S.E.) together with the Concerned Citizens for Responsible Fire Management (CCRFM) today appealed to USDA Forest Service Chief Tom Tidwell a decision by Region 6 Regional Forester Mary Wagner to approve the Rogue River-Siskiyou National Forest’s adoption of a Wildland Fire Use (WFU) program over strenuous objections by citizen watchdog groups.

The Rogue River and Siskiyou National Forests were merged in 2004. In March, 2008 the RR-SNF proposed inclusion of WFU fires in their Land and Resource Management Plan and Forest Fire Management Plan.

W.I.S.E. Executive Director Mike Dubrasich stated, “If this Let It Burn program is implemented, another Biscuit Fire will surely occur, possibly as soon as this summer.”

“The Biscuit Fire burned 500,000 acres of the then Siskiyou NF in 2002. It was the largest fire in recorded Oregon history and destroyed habitat for endangered species, including over 100,000 acres of prime spotted owl habitat (50 known nesting sites were destroyed).”

“Allowing wildfires to freely roam the landscape is a terribly destructive idea. Too much is at stake, including forests, watersheds, and wildlife habitat, as well as ranches, farms, homes, and entire communities that may lie in the path of uncontained Federal megafires.”

“Our culture and society have reached an important juncture in our understanding of our place in the landscape. As human beings we must become the caretakers of our environment and fulfill our sacred responsibilities, not abandon our priceless, heritage forests to catastrophic fire.”

The text of the Appeal may be downloaded [here].

Scoping Comments and Objections from W.I.S.E. and CCRFM may be downloaded [here, here, here].

The Western Institute for Study of the Environment is a non-profit organization headquartered in Lebanon, Oregon. W.I.S.E. is 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.

The Concerned Citizens for Responsible Fire Management is a citizens group based in Trinity County, CA. Members have extensive National Forest land and fire management backgrounds and/or are business people who are directly or indirectly affected by National Forest management. The CCRFM is dedicated to the oversight of land and wildfire management activities on National Forests.


27 Nov 2009, 11:58am
Federal forest policy Saving Forests
by admin

W.I.S.E. Objections to the RR-SNF Let It Burn Plan

In March of 2008, the Rogue River-Siskiyou National Forest issued a notice of intent to produce a Fire Use Amendment Environmental Assessment [here]. They requested scoping comments to be submitted within 30 calendar days.

The Western Institute for Study of the Environment responded in the time allotted with a 170-page discussion [here] of the pertinent issues accompanied by 450 MB of appendices containing references.

For one and a half years the RR-SNF remained silent about this process. They did not even acknowledge receipt of our comments. Then, 17 months later, the Fire Use Amendment EA [here] was distributed with a 30-day time limit (again) for submitting official objections.

While not expressly stated, the reason that a 17-member Interdisciplinary Team spent a year and a half preparing the EA was because of the size, breadth and depth of the W.I.S.E. scoping comments.

Yet at no time during that year-and a half did the RR-SNF contact us to discuss our concerns, to ask clarifying questions, to invite our expert consultation, to hold workshops, or to encourage our collaboration in any manner.

Instead, a year and a half later and unexpectedly, we were given very few days to review an EA over 100 pages long.

We have complied. Our official Objections are [here].

In the short Objection time window we were unable to address in detail the probable significant impacts of the Proposed Action on flora, fauna, historical and cultural resources, watersheds and water quality, airsheds and air quality, recreation and scenery, and other forest resources and values. But we did address the inadequacy of the RR-SNF EA and again requested that a full Environmental Impact Statement (EIS) be prepared.

If the RR-SNF had acted in a more open and welcoming manner, those issues could have been explored in greater depth over the last year and a half. Instead, the RR-SNF chose to shun our involvement.

Our motives throughout this process have been to improve the stewardship of our public forests and landscapes and to avert poor management and poor planning that will inevitably lead to more Biscuit Fires. We hope the RR-SNF shares those motivations.

3 Apr 2008, 4:19pm
Federal forest policy Saving Forests
by admin

Some Brief Comments on the RRSNF’s AMR Proposal

by Dave Skinner, Hydra Project, Whitefish MT

As an irate citizen pressed for time, I wish to make brief comments on the RRSNF’s proposal to implement Appropriate Management Response protocols upon unplanned ignitions on the RRSNF. First, I have some involvement and interest in the area. Several of my Montana logging friends have worked on wild-fires on the RRSNF, including most recently the Biscuit. Since then, my buddies have been kept busy at home here in Montana fighting fires closer to home. I myself have visited the RRSNF several times in the past few years, either alone or with various forestry professionals. I am intimately familiar with the post-Biscuit “unsalvage” fiasco (code word: Rich Fairbanks/FSEEE) as well as the subsequent Donato/DellaSalla/Kauffman boondoggle. Let’s just say I am not happy with the prospect of the US Forest Service setting itself up for another disaster in southwest Oregon — as well as nationally.

I hereby request that RRSNF prepare an EIS preparatory to implementing AMR. I also request a CD copy of either that requested EIS, or at least a CD of the proposed EA; with PAPER copies of whatever maps would be included with paper copies of the EIS/EA. My mailing address is listed below.

I want to especially point out the concession before Congress by professors Norm Johnson and Jerry Franklin that unmanaged wildfire poses a great threat of loss to the so-called “old growth” Late Successional Reserves. To quote: “Prescribed fire is a useful tool in forest restoration but is not sufficient alone—mechanical silvicultural activities typically will be required.”

Now, both gentlemen have been profoundly wrong before, however, in this case they both realize it. While their call for mechanical treatment is limited by their adherence to the Beschta philosophy that no fire area ever be salvaged or “old growth” tree ever be cut (and I point out both the Sugarloaf project and Franklin’s 90-minute “peer-review” of the Donato salvage “science” travesty), they have nonetheless conceded the point.

If these gentlemen say prescription burns cannot accomplish their intended purpose without unacceptable risk, then logic forces the question of what sort of risks are presented by unscheduled or non-programmatic ignitions?

Until the risk is moderated by fuels pre-treatments on the appropriate landscape scale, then implementing an AMR program on an unprepared landscape is absolutely certain to have significant impacts upon the human and natural environment — not just those “precious” LSR’s, but as the Biscuit/Tiller and so on have proved, dang near every stick of every age class on every stinking acre of USFS-administered ground in western Oregon.

In the main, I concur with the comments prepared by the Western Institute for Study of the Environment and join their call for preparation of an Environmental Impact Statement before implementation of any so-called “Appropriate Management Response” to unscheduled wild fire events on the Rogue River-Siskiyou National Forest.

I furthermore encourage you to advise your superiors in the Washington office that implementation of an AMR policy on other national forests without full Environmental Impact Statements, in light of the clear environmental uncertainties of AMR implementation, would be in itself arbitrary and capricious.

Thank you for your consideration. Please do the right thing.

W.I.S.E. Challenges USFS Let It Burn Program



An Oregon environmental think tank has challenged the adoption of a Wildland Fire Use program on the Rogue River–Siskiyou National Forest.

“’Wildland Fire Use’ is a glorified name for Let It Burn” stated Mike Dubrasich, executive director of the Western Institute for Study of the Environment headquartered in Lebanon, OR.

“If the Rogue-Siskiyou adopts the WFU program, another Biscuit Fire is surely going to happen, possibly as soon as next summer.”

Dubrasich’s organization filed a 170 page complaint with the RR-SNF earlier this week.

The Biscuit Fire burned 500,000 acres of the then Siskiyou NF in 2002. It was the largest fire in recorded Oregon history and destroyed habitat for endangered species, including over 100,000 acres of prime spotted owl habitat (50 known nesting sites were destroyed).

The Rogue River and Siskiyou NF’s were merged in 2004. The RR-SNF is preparing an Environmental Assessment to evaluate inclusion of WFU fires in their Fire Plan.

“We have suffered enough forest destruction from mega-sized forest fires,” said Dubrasich.

“Allowing to wildfire to freely roam the landscape is a terribly destructive idea. Too much is at stake, including watersheds and wildlife habitat, as well as ranches, farms, homes, and entire communities that may lie in the path of Federal megafires.”

“Their job should be rapid initial attack and full suppression of mid-season wildfires. If the USFS wants to do prescribed burning, it should be done on prepared ground, under controlled conditions, and at safe times of the year.”

“One Biscuit Fire is plenty. We need stewardship and active management, not abandonment of our national forests to catastrophic incineration. Unchecked wildfires are wasteful, costly, dangerous, and sometimes deadly.”

W.I.S.E has posted the complaint [here].

# 30 #

31 Mar 2008, 7:59am
Federal forest policy Saving Forests
by admin

W.I.S.E. Comments to the RR-SNF on AMR and WFU

On March 5th the Rogue River-Siskiyou National Forest issued a Notice regarding their intent to add WFU (Wildland Fire Use) in the guise of AMR (Appropriate Management Response) to their FMP (Fire Management Plan) portion of their LRMP (Land and Resources Management Plan). We discussed this previously [here].

In short, the RR-SNF wants to do whoofoos, i.e. Let-It-Burn fires. When lightning ignites a fire next summer on the RR-SNF, the fire dudes there will not do initial attack, or if they do, it will be half-hearted. They will not put any serious effort into containing, controlling, or extinguishing the fire, but instead will just let ‘er rip.

Chances a better than good that their whoofoo will explode into a firestorm and burn half a million acres or more. There is a likelihood that their whoofoo will burn out of the mountains and down into the valleys where ranches, farms, and rural homes will be destroyed in the inferno. There is every reason to believe the RR-SNF whoofoo next summer will make it all the way to town, and Medford, Grants Pass, and/or Ashland will be incinerated.

You see, it happened before. In 2002 the RR-SNF had a Let-It-Burn fire called the Biscuit Fire. The Biscuit Fire burned half a million acres, including over 100,000 acres of prime spotted owl habitat (50 known nesting sites were destroyed). After it burned the entire Kalmiopsis Wilderness Area, the Biscuit Fire kept going (imagine that!) and came raging down on the communities of the Illinois River Valley in a 12-mile-wide front.

The USFS had earlier decided not to do initial attack, and to just Let-It-Burn. Their excuses were that no firefighters were available during the summer fire season, and that it would be too expensive and a waste of money to fight the Biscuit Fire when it was small. But when the Biscuit Fire came roaring down upon the communities, the USFS realized that it would be bad form to burn out whole cities.

Every firefighter in the state and then some were called in (it turned out there actually were firefighters available). While radical arsonist wackos staged anti-firefighter demonstrations off to the side, the USFS threw everything but the kitchen sink at the Biscuit Fire. Grants Pass and Selma were saved, but it cost a pretty penny. In the end $150 million was spent on fire suppression on the Biscuit Fire, the most expensive fire in U.S. history.

But no lessons were learned from that experience. Now the RR-SNF wants to do it again! In fact, they want to permanently enshrine whoofoos in their Fire Management Plan. It’s Madness Motors time at the RR-SNF!

The Western Institute for Study of the Environment has prepared Comments to submit to the RR-SNF, as is our legal right to do. We post a link to those Comments [here]. Warning, the W.I.S.E. Comments to the RR-SNF are 168 pages long and 2.65 MB, so be prepared to wait a bit while they download.

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