APPENDIX Ca123.g.akamai.net/7/123/11558/abc123/forestservic...[P.L. 108-148, Sec. 104. (f), emphasis added] . Deliberate striking of sporting/conservation organizations from mailing

ATTACHMENT F

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Additional Correspondence and Responses

TABLE OF CONTENTS

Page PACIFIC RIVERS COUNCIL LETTER, 1/6/2006 - DAVID BAYLES, GARY CARNEFIX & CHRIS FRISSELL, PhD AND AMERICAN WILDLANDS – JOSHUA BURNIM………………………..……1 PACIFIC RIVERS COUNCIL LETTER, 1/18/2006 - GARY CARNEFIX & CHRIS FRISSELL, PhD ….……..18 MARK A. FINNEY, PhD – ROCKY MOUNTAIN RESEARCH STATION ……………………………………...25 THOMAS E. DEMEO, PhD – PACIFIC NORTHWEST REGIONAL ECOLOGIST ………………...…………...33 DR. WENDEL HANN, NATIONAL INTERAGENCY FUELS TECHNOLOGY TEAM, CO-LEADER ………..35

Abigail R. KimbellNorthern Regional ForesterUSDA Forest Service, Northern RegionP.O. Box 7669Missoula, MT 59807(406) 329-3315 Fax: (406)329.3411

RECEtVEDIAN 132006

l:JinerrootNlltional ~orwt

Dave Bull, Superv.isorBitterroot National Forest ~:1801 North FirstStreet '.'Hamilton, MT59840 .

(406) 363-:7100dbull@fs,fed.usr1 bitterroot comments fs.fed.us

Dale 'Bosworth. ChiefUSDA Forest SerVice1400 Independence Ave., SWWashington, D..C. 20250-0003

Mark Rey, Under-Secretary for Natural. Resources and EnvironmentU.S. Department of Agriculture'Whitten Building, Room 217E1400 Independence Avenue, S. W.Washington, DC 20250 " , .'

Jan 6 2006

Re: Reviewing Officer's Response to Pacific Rivers Council/AmericanWildlands' O'bjections to the Middle East Fork Hazardous Fuel Reduction(MEF) Final EnvironmentallmpactStatemen,t (FEIS)

We received Supervisor Kimbell's response to our Middle East Fork Bitterrootfuels reduction project objection over the Thanksgiving weekend and have now

1

Middle East Fork ROD Attachment F Page 1 of 37

s~udied it in detail. We request that this page and the fol!owing 16 p,ages beentered into the record for the project and considered in the final Record ofDecision.

Briefly, we find substantial and extensive failure by the Bitterroot National Forest("the Forest") and the Reviewing Officer to fulfill legal obligations under TheNational Environmental Policy Act of 1969, as amended (NEPA) and under the"Healthy Forests Restoration Act of 2003" (HFRA). The Public CollaborationprovisJof1 of HFRA provides that

the Secretary shall facilitate collaboration amongState and tocalgovernments and Indian tribes, andparticipation of interested persons, during thepreparation of each authorized fuel reduction projectin a manner consistent with the Implementation Plan.[P.L. 108-148, Sec. 104. (f), emphasis added] .

Deliberate striking of sporting/conservation organizations from mailing 1ists fornotification of project-reJated public meetings (which is public knowledge only asa result of a FOIArequest) is a clear violation of this provision. Unfortunately,this is only the most egregious evidence of a process which was strongly slantedtowards !'collaboration" only '!iVith likely allies in developing and promoting th~Forest's preferred approach while ~xcluding potentia1 skeptics/critics from crucialearly "collaboration", including those best-qualified for professional assessmentof the scientific validity of rationales pres~nted !n support of the preferredalternative. Thu,s, by the time opportunity was publicized for the interested publicat large to comment at the DEIS stage, the shape of the proposal was largely"set" and far along down the tracks, with excessive momentum '(as evidenced bythe Forest's subsequent refusal to make substantive changes to it despiteextensive, substantive and expert comments and obje~tions regarding its flaws).

NEPA's guiding principle is that federal agencies should gather enoughinformation on a proposed action's environmental effects to make a reasonabledecision regarding that action, and sufficient information should be provided tothe pubJic to ensure an informed evaluation of the government decision-makingprocess. The Final ,EIS must include and respond to all substantive commentsreceived on the Draft EIS. 40 C.F.R. 1503.4(b). The FEIS must discu$S anyrespons.ible opposing view that was not adequately discussed in the Draft EISand must indicate the agency's response to the issues raised. If themethodology used in preparing a sectjon of the EIS is questioned,th~n theagency must, in a substantive and meaningful manner, explain why theparticular method was used and why an alternative methodology is not

2


appropriate. 40 C.F.R. 1503,4(a)(5), 1509.9(b). If the agency decides not torespond to a comment, it must cite the sources, authorities, or reasons thatsupport its position. 40 C. F. R. 1503.4(a )(b); As the following detailed.Information demonstrates, the Forest has failed to do this, and the ReviewingOfficer has failed to require it through the objection process. Thus, the Forest'sfailure to apply the best available science to meaningfully address numeroussubstantive comments and objection$, and the Reviewing Officer's conclusionthat our "issues have been addressed in the EIS and/or project record and thatthe project is in compliance with existing laws, regulations, and policy", arearbitrary, capricious and/or false.

Sincerely.j'J

~

David Executive DirectorPacific Rivers CouncilPO Box 10798Eugene, OR 97440(541) 345-0119

[email protected]

Gary Carnefix, M.Sc., Research AssociatePacific Rivers Council115 Turner Ct.. #3, Missoula, MT 59802-2836telephone number 406-543-5518e-mail gcarnefix@~ol.com

Chris Frissell, Ph.D., Senior ScientistPacific Rivers Council406-883-1503 (office), 406-883-1504 (fax)PMB 219; 61529 Hwy 93 Suite APolson, MT 59860

hanfri§@diqi§vs.oet

Joshua Burnim, AWL Lands Program CoordinatorAmerican Wildlands40 East Main Street, Suite 2Bozeman, MT 59715Phone: (406) 586-8175

[email protected]


PRC and AWL became interested In this project due, in part, to its potentiallyprecedent-setting role as one of the first projects proposed under HFRA authorityin Montana and Region 1, and the potentially far-reaching impacts of any suchprecedents to aquatic systems and species -this being PRC's primary focus.

Unfortunately, significant elements of the proposed project are not defensiblescientifically, ecologically, economically, or in terms of rational prioritization oftaxpayer dollars for a project putatively justified as "healthy forest restoration".Specifically, as we argued in both our comments and objections:

The deliberate decision to forego acknowledged road and watershedrestoration needs, including road decommissioning, maintenance,upgrading to BMP standards and culvert replacements that the Forest hasalready identified, prioritized, and estimated time ~nd costs for, is irrationalwhen these are among the most seriou$ existing degradations of "foresthealth" within the ecosystem, and the ecological benefits of addressingthem are well-documented, sc)entifically uncontroversial and certain. Weapplaud the addition of a few more such restoration activities~tthe FEISstage, but note that the absence of any assurances of theirimplementation renders them largely meaningless, and accounting fortheir predicted benefits in. the comparison of alternatives without alsoaccounting for the case of incomplete implementation can obscuresignificant differences among the effects of the alternatives.

.

This illogic is compounded by the proposal to. instead pursue "fueltreatments", especially those in previously unlogged, remnant mixed-conifer old growth, whose purported need is highly controversial, whosepredicted efficacy is at best highly uncertain, speculative and contradictedby some of the best available scientific literature, whose economicproceeds may not even cover the costs of planning/preparation (as theForest finally, belatedly acknowledged in the FEIS) and which will certainlyproduce further degradation of an already highly-degraded landscape,especially in the form of impacts from roads and soil disturbance~

Even more unfortunately, the precedents set so far by this project in its. planningand objections phases -in terms of public process, ecological and scientific'justification,

rational prioritization,. and economic sense -in our view woefLJlly failto meet the Forest's legal and ethical responsibilities and the standard for public

review and scientific integrity established by NEPA and other laws. Most

saliently,

4


....

Several DEIS comments were seriously misrepresented in the FEIS"response".. and thus not meaningfully addressed at all (we providedseveral,examptes in bur objection). '

Several of our objections were seriously misrepresented (details follow),and thus not addressed at all by the objection response.Several parties' DEIS comments (inctuding ours) were apparentlylost/ignored by ~he Forest, ahd so were unaddressed in the FEIS. Ourswere initially ignored ostensibly because, although we submitted them viae-mail from Eugene,Oregon before Midnight PDT of the commentdeadline date, this was after Midnigh't MDT as received in Montana. Toour knowledge, there was not even such a time-zone 'rationalization for theexclusion of pther parties' comments, The cursory comment "response"provided directly to us after the FEIS .was released (the first notice we hadthat our comments had been ighored) was highly inadequate andunresponsive and falls to fulfill the Forest's NEPAobligation to ,.1"meaningfully address substantive DEIS comments in the FEIS. ",

In both comments and objections, we called the Forest's attention tonumerous examples of scientific studies (see below), most published andpeer-reviewed, several by the Forest Service's own Research Stationscientists, which refute or seriously call into question important elementsof the Forest's rationales for the proposed project. To our knowledge, nota single one of these ha$ ever been specifically addressed either in directresponses to us or In proj~ct documents (e.g., FEIS).We pointed out that where the Fore$tdid -sele:ctively -cite the scientificliterature that it interprets to support the proposed activities, it frequentlyoversimplified conclusions and omitted caveats, constraints, exceptions,limitations and alternative interpretations included by the authors of thecited sources and/or deviated in Significant ways fromconclu$ions/recommendations of the cited sources (e.g., analysis period'for "historic condition"; FEIS p. 3.2-6; Hann 2003, as revised 2005). Theunrespon$ive "response" to this objection was largely limited to reiterationof a few of the limited and wholly inadequate caveat statements already,sprinkled in various places in the analysis documents.With a few minor exceptions, the Reviewing Officer's so-called responseto our objections (including the preceding points) simply points to andreiterates the original flawed/incomplete analyses and rationales in theD/FEIS, seriously misrepresent$ several of our objections, and shows.. ,little/no evidence of any fresh, independent, objective third-party review.

Specificex~mples of unresponsiv~~ness to and/or misrepresentation of ourcomments and obj~ctio!1S .

5


Unresp~~eness:

Neither in belated "response" to our DE IS comments (omttted from FEIS) nor inthis "response" was any of the scientiftc literature ..we ctted calttrig into question orrefuting elements of the jlJstification for this project directly ad.dresseq (Bebi et:al.20D.3;Brown et at. 1999; Fule et al.2004; Johnson and Larsen 1991; Rapp2005a; Raymond and Peterson 2005; Swetnam and Betancourt 1990) (importantmore-recent additions to thts list would include Pierce et a1. 2004; Stephens &Moghaddas 20.05 -see "Literature Cited"; as well as unpubltshed USDA ForestService Pacific Northwest Research Station data from the Biscuit Fire athtt ://www.fsl.orst.edu/ite /Biscuit/Biscuit05 files/frame,htm). Nor was the issueaddressed of the Forest's over-simplificatiqn and dropping of authors' caveats.. .

qualifications, exceptions, alternative interpretattons, etc. from scientific literaturethe Forest cited in support of its proposal, to create a false impression of muchstronger scientific support and consensu~ than extsts. The objection "response"(like that to DEIS comments) simply refers rep~atedly to the FEIS, ignoring that amajor contention of ours i~ that much relevant, countervailing scien,ce was left '

out of the DE IS and FEIS.

In a I~ngthy response to one of our objections that the Forest needs to

"...provide an analysis that credibly acknowledges andaccounts for the targe uncertainties in, limitations ofand constraints on itsmodeljng and analysespresented in support [of] the elements of. this proposaloutside the WUJ, and how these affect analyses of thecQsts and benefits, such an a§sessment mustdisclose the low likelihood that fire will occur-

under severe burnina conditions at anv ~artic~/artreatment location within the window of anv'purported effectiveness of the treatment, ..also ,disclose that such a project must... be followed by ,

regular re-treatment with all the associated ecologicaland economic costs. ..further disclose that it doesnot have resources for and is notcommittin,qitself to such a proaram :. .[PRC/AWL objection p;11; Kimbell objection response, pp.. 2-3, emphasisadded]

Supervisor Kimbell's objection response offered the following (one of the veryfew bits of information that were new, i.e., not simply referencing/reiterating.previous D/FE1S statements/argume.nts):

6


A local fire risk analysis using PROBACRE, whichincludes suppression actions, is cited in thereferences (Boyd, 2002). The results show that theprobability of having a fire that exceeds thesuppression capabilities of firefighting handcrews is37 percent in 1 year. On average, one of those fireswill result in a large fire (180-15,000 acres) every 6..5years (5- 7 year range). [Kimbell objection responsep. 4, emphasis added; Boyd 2002 appears to havebeen listed in Literature Cited, but not directlyreferenced/cited in text -at .least Adobe "search"function doesn't find it in the FE IS fire chapter.]

Of course, this information is meaningless and useless without specifying thesize of ~hearea modeled (i.e., given a large enough area, probability of a fire thatexceeds suppression by handcrews in 1 year is/approaches 1QO%!), besidesdodging the issue we raised of fire probability 1) atOa given treatment location,2) under moderate-high-severity burning conditions 3) within anyeffectiveness window at that location. This "response" thus completely anddisingenuouEily fails to respond to our objection.

Also as part of the same response, the Forest Service writes:

The actions being proposed are effective in changingthe key indicators for varying amounts of time. .Landscape level changes in FRCC are in affect [sic]until an historic fire cycle is missed or vegetativeingrowth causes structural change. Therefore, theduration of effectiveness ranges 0-100 years. Twoexamples of the potential effectiveness duration aregrasslands and lodgepole pine forest. The firefrequency of the grasslands is 0-10 years and theFRCC may revert from Class 1 to Class 2 after one ortwo missed fire cycles. The fire frequency oflodgepole is 60-100 years, a~d the FRCC mayremain in an improved class for 100 years.

With the addition of fo(low-up treatments, e.g.prescribed fire at the historic return interval, it ispossible to maintain post treatment levels of

T


effectiveness. For example, a 2-foot flame length'resulted following the typical mechanical andprescribed fire treatments, within 10-15 vearstheflam~ lenath increases to 4 feet. By simulatinganother pres~ribed fire treatment.. without mechanicaltreatment, the flame length was returned to 2 feelPlannina for follow-UD treatments is not coveredlnthis analvsis." [Kimbell objection response, p. 3";emphasis added] ,

It is unresponsive, highly misleadingand/or disingenuous to respond to thisobjection wtth lodgepole and grasslands as examples; since neither the proposedtreatments nor our objections focus on treatments to lodgepole stands orgrasslands outside the WUI (and we afso have notqbjected to their treatmentswithin theWUI). To be meaningful, a response would have to address theseissues for th~ treatments proposed'torthe unlogged, remnant, mixed-conifer oldgrowth stands, to which we have objected.

While the Forest Service did not interpret this information in a context useful toinforming the Middle, East Fork a)ternatives, the above respon$e and content ofBoyd 2002 (which we had to obtain from the Forest Service by request).. does -belatedly -provide some information that one can use for a rough-approximationanalysis of the type we have repeatedly stated is necessary and must bedisclosed to the public' to meet the Forest's legal obligations. In thefollowing paragraphs, we illustrate our concerns with a brief example of such ananalysis using the newly revealed information. ,

Note that, throughout the following analysis, we have consistently chosen the'assumption most favorable to the Forest's claims where, for example, theForest's analysis resu1ted in a range of values (e.g., using 15 years for durationof treatment effectiveness based on the Forest's response above that "flamelength reverts to 4 feet" within 10-15 years), .

Boyd's (2002) PROBACRE ana1ysis concludes:

In the next 100 years we can expect to burn between.27,500 and 40,700 acres in the [145,OOO-acre)influence area., equating rough~y to 20..30 percent ofthe tata.! influence area [actually, 19 -28%).

8


Taking the upper end of this range (28%) predicts that, on average, 0.28% of theanalysis ("influence") area will burn in any given year of 'the next 100,' This(0.28%) equates to Boyd's (2002) PROBACRE-predicted probability that anygiven acre burns in any given year.

The probability of an event with a known recurrence interval occurring within nyears is

q=1-(1-p)n (e.g., Dunne and Leopold 1978),

where, in this case, q is the probability that a fire occurs on a given acre of theanalysis area within nyears, pis the annual p~obability of fire at that location, andn is the duration In years of purported treatment effectiveness for modifying firebehavior. In the case at hand:

n = 15 yrs

p = 0.0028 (per acre per year)

Calculating q via the values of nand p and the equation ab<;>ve yields:

q = 0.0412 = 4.12o/Q;

That is, if we accept the conclusions of Boyd's (2002) PROBACRE modeling:over 15 years, the probability that any single treated acre .is affected by fire ofanyseverityrs 0;0412 (f.e.,'about 4%).

Assum,ng an estimated 15-yr treatment-effectiveness window based on theForest's statement above (which we find reasonable and consistent with thescientjfic literature, if we assume treatme,nts indeed have any effectiveness with ..regard to fuel reduction/fire behavior modification) results in a 4% probability thata giv~n treatment on a given, acre has any fire behavior modificationeffectiveness whatsoever, which equates to a 96% probability that a giventreatment on a given acre never has any effectiveness for its intended firebehavior modification purpose. Note that, even if we accepted validity of theForest's irrelevant loqgepole example and assum_ed treatment-effectivenessduration of 100 years (clearly out of the question for the unlogged, remnantmixed-conifer old growth in contention), this would only increase the probabnitythat a given treatment on a given acre would modify fire behavior at all, ever, toabout 24%.

9


We cannot emphasize too strongly that the above result represents a substantialoverestimate of any probably of treatment efficacy because: .

1. It. includes low-severity fire. Low-severity fire is all ecological benefit, with no ecological harm. Further, treatments can't eliminate low-severity

fire an~ay, and nobody claims they can. Even in recent ,large fires duringextreme weather following extended drought (e.g., Biscuit, Rodeo-Ched.iski, Hayman), roughly a third of the fire area burned at low severity.Thus, a more realistic probability of efficacy for proposed treatments is<3%.

2. As the Forest acknowledges, any severity-reducing fuel-treatmenteffectj'veness declines over time. The previous calculations do notaccount for this. Clearly, if fire occurs on a treated acre during thefourteenth year following treatment, treatment will be far less effective inmodifying fir~ behavior than if fire occurs in the second year aftertreatment.

3. Fuel treatments are not 100% effective at reducing fire severity, andcan, in fact, increase it.. This: is not in dispute, as numerous examples inthe scientific literature, some of which we have repeatedly called to theForest's attention (and the Forest has consistently ignored), demonstrate{e.g., Raymond and Peterson 2005; Stephens and Moghaddas 2005. Seealso, Biscuit Fire, unpublished USDA Forest Service Pacific NorthwestResearch Station data,

http://Vllww. fsl.orst.edu/ltep/BiscuitlBiscuit05 _files/frame. htm).

Thus, as we have co,nsistently argued (and now have demonstrated using theForest's own assumptions, data and modeled predictions) the proposedtreatments of previously unlogged, remnant, mixed-conifer old growth standsrepresent a significant ecological and economic cost for what is at best anextremely small benefit in modification of fire beh~vior.

Simply put, fire must occur under conditions favorable for moderate-to-high'- .

severity fire (low-severity fir~ is universally recognized to be beneficial bothecologica1ly and in terms of reducing risk of future fire severity) within the windowof any putative treatment effectiveness at a given treatment location fortreatments to have any fire-modification benefit whats'oever. As we've repeatedlyasserted (and the Forest has largely ignored), and as this analysis using theForest's own conclusions clearly demonstrates, the probability of thisoccurring is very low. Given this low probabrlity, the Forest clearly has failed todemonstrate that any putative benefit justifies the inevitable negative ecologicalimpa~ts -damage to soils and watershed function, and harm to water qua1ity andfish habitat -of the treatments themselves and from the ongoing and increased

10


use of the existing substandard road network, plus new roads proposed for theproject. Thus the Forest has utterly failed to rationally justify its proposedtreatments of, in particular, the mixed-conifer old growth stands proposed fortreatments (other than prescribed fire), to which we have objected.

There are, of course, simplifying assumptions in the preceding analysis, but nomore so, and no more unreasonable. than those (often undisclosed) that pervagethe Forest's modeling and other analyses purporting to support the Purpose andNeed for the proposed project (e.g., FlamMap's simultaneous and independentignition of every pixel on the landscape after a week of continuous 90th-percentile[for fire severity] weather conditions -with 1hat9oth-percentile wind blowingupslope on every pixel, an obviously impossible occurrence in the real world).We emphasize, however, that most of these simplifying assumptions are inherentin the Forest's own analyses (e.g... Boyd 2002).

In fact, it is difficult to see -even if Boyd's (2002) analysis is highlyunreliable/inaccurate and were replaced by something better; even if everyassumption in the preceding analysis were stretched to the limit in favor of theForest's premises (or even beyond the limit to the point of deliberately attemptingto skew the results to support the Forest's premises) -how a credible analysis ofprobability of fire occurrence on any treated acre l)nder moderate-severe burningconditions within the period of any purported treatment effectiveness does notarrive at the same general conclusion we've repeatedly argued the Forest mustdisclose: this probability is very low; therefore, proposed treatments arehighly likely to entail all. economic and ecological cost for little/noecological benefit.

The preceding analysis (or an analogous one at least equally va1i9 and credible)is indispensable to a rational assessment of the costs and benefits of theproposed project, which is why we requested it and insisted the Forest has anobligation to disclose its results and weigh them in its decision process. We findit absurd that we are required to do the Forest's job for it in performing therequested analysis. We emphasize that even that has only been made possibleby the belated reference to Boyd 2002 provided in response to our obj~ctionafter the end of the entire designated public input process, includingobjections; i.e., withholding it until then -despite our earlier requests for thisanalysis and disclosure -is a clear failure of the Forest's legal obligation torespond substantively to substantive comments and fully disclose relevantinformation to the public.

Furthermore, putting a citatjon in Literature Cited without actually referencing it in"the public documents (especially regarding such a crucial issue -though the.

11


Forest Service hasn't seemed to. recognize it as such, yet) would seem extremelyinadequate for NEPAdisclosure requirements; especi~lly where, as here, the"cited" literatur~ actually leads to a conclusion that is the antithesis of support forthe proposed action. .

Even the very row probabiHty of efficacy of proposed treatments is wholly.dependent on future re""treatment a~ relatively short intervals fortheproposed :project to have any medium-10 long-term benefit that could conceivably justifythe proposed Jogging of remnant mixed-conifer old growth stands. Thus, whetheror not the Forest is committing to and has assured resources for such a long-term program of re,.treatment is not peripherar, but essential and integral to ar~tional cost/benefit assessment of the proposed activities. The Forest cannotescape the requirement for disclosure of these factors simply by declaring themoutside the "scope" of analysis for the project.

Serious misrepresentations of PRC/AWLstatements/positions:

Finally, this same objection "response" begins

The objector doesnotacknowledae that tnere arethre~ objectives for the Middle East Fork Project.The treatments outside the WUI are authorized underSection 1 02(a)(4) due to the presence of the Douglas-fir bark beetle epidemic. ,Part of theP-urpose andNeed of the Middle East'Fork (MEF) proposal is torestore fire-adapted ecosystems and restore standsaffected by1he Douglas- fir bark beetle to promoteecosystem function, composition and structure (FEIS,Section 1.2}. The purpose of treatments outside theWUlis to improve FRCC., restore fire-adaptedecosystems and 'forest health (FEIS, Section 1.2);however, there is an associated benefit in thatstrategically-placed fuel treatments (SPLATs) in thenon- WUllandscape will reduce the risk of loss due towildfire in the WUI by improving controllability..:[Kimbell objection response, po 3, emphasis added]

Contrary to the Forest Service's cfaim here, we acknowledged the multiple"objectives" throughout our comments,although we sometimes disagreed as totheir fundamental validity, practicality, and wisdom. This specific objection.however, was focused on the Forest's stated and implied claims regarding its'ability to predictably and reliably influence/control fire behavior and the c,?sts

12


versus benefits of attempting to do so. The above pretense that the Forest is notselling this purported ability as justification for its proposed treatn)entseverywhere outside the WUI is simply false, as shown by this statement:

Alternative 2 addresses reducing risk fromuncharacteristically severe fire across the wildlandurban interface and Middle East Fork landscape, ~reducina f~els and chanaina stand structures tomodify fire behavior on 6.472 acres [=total area of

aI/proposed treatments]. [po 2~14, FE/S, emphasisadded]

This is also only one of several examples that could be raised of the Forest"speaking out of both sides of its mouth", i.e., shifting between Inconsistent oreven contradictory rationales to serve the rationalization need of the moment.For example, when objectors reference the extensive scientific literaturequestioning or refuting the efficacy of attempting to address beetle outbreaks bylogging, BNF claims opponents are promoting a "misconception" that the'proposed "[t]reatments are designed to end the DFB epidemic" (thereby creatinga misconception of its own, since this description misrepresents most, if not all, ofthe comments on this issue included in the FEIS; the same could be said ofseVeral other purported "misconceptions"(pp. H-2, H-48-56). Meanwhile, whencomments like PRC/AWL's focus on the fire behavior-modification aspect of thepurported purpose and need, they are accused of "not acknowledg[ing,]" the barkbeetle objective. .

'Issue 6: (PROCESS) "...bundling of non-controversialWUI treatments with highty controversial treatments"Suggested remedy: " ...proceed withi~ the WUI;

eliminate the logging of old-growth stands"(definedbv the Objector as any stands outsidethe WU/). [Kimbell MEF response p, 6, emphasis

added]

What we actua11y said

'6) Needless and illogical saddling of un controversialcommunity fire protection activities 'for which a broQdpublic consensus and reasonable scientificjustification

exists with highly controversial and

13


scientifically unsupported logging of remnant mixed-conifer old-growth patches within an intensely loggedand managed landscape far from human habitation.[To clarify, in response to some obtuse-seemingreplies to our DEIS comments: We use "oldgrowth" and "logging" in referenceto'thisproposal with their plain English meanings, i.e.,

"old rowth"; forest stands with lar e" old i.e.re-datin Euro ean settlement trees which

have not been loaaed or otherwise "activelv

managed" except possibly" throuah use ofprescribed fire. regardless of any technicaldefinition of vegetation structure, composition,"characteristics, etc., that the Forest may apply toavoid classifying them as "old growth". ..[pp. 7-8, PRO/AWL objection, emphasis added]

Proposed resolution: proceed with the fuelmanagement treatments proposed within the WUI;elimlnate the loqqinq of old qrowth stands {asdefined above), unless validated by the expertscience panel proposed above. We are notautomatically opposed ~o the pre-commercialthinntnQ proposed in the terraced plantations,provided maximum precaution is exercised (e.g.,by aVoidance of ground-based equipment use)against additional soil d.isturbance to these alreadyheavily degraded units, subject to validation by thescientific review proposed above. [po 13, PRC/AWLobjection, emphasis 9dded]

Another misrepre$entation

Issue 5: (COMM) "..."apples-to-oranges" imfJactscomfJar;son of alternatives under implied assumptionthat only low-moderate severity fire occurs underAlternative 2 and only high-severity fire occurs underAlternatives 1 and 3 is fatally biased. "

14


Suggested remedy: " ...replace the current slanted

comparison with a credible comparison that modelsimp~cts of alternatives across the same range of fireseverity scenarios."

Regional Review and Response:' It appears theobjector is defininq crown fire a~ hiah severitvand qrQund fire as low severity. If that is the case,than [sic] a quick way to vie~ the differences in firetype between alternatives is to review the FlamMap .figures in. the FEIS, pages 3.1-48 through 50. Notethat both types of fire are evident with all alternatives.The FEIS states that the models are for comparisonand ace not to be used for absolute numeric value$ (p.3.1-12). Also, it seems the objector may havemisinterpreted the methods. Identical burning90nditions were used for the comparisons. PublicConcern 63040 lists numerous citations used in thisanalysis, which further address your concern thatthere is not a creditable comparison. [Kimbell MEFobjection response, p. 6, emphasis added]

What we actually said:

Proposed resolution: replace the current slantedcomparison with a credible comparison that modelsimpacts of alternatives across the same range of fire-severity scenarios. At a minimum, this meansaddinq columns{*l modelina imo8cts under Alt. 2"if high severity fire occurs" (the impliedassumption that high severity fire CANNOT occurunder Alt. 2 is ludicrous) and under Alt. 3 "if low-moderate severity fire occurs" (the impliedconverse assumption is equally ludicrous). [PRC/AWLobjection, pp. 13-14, emphasis added]

*ReferrinQ to FE'S and §ummarv FE1S Tables 2-7 throuah 2-9 (though thiswas not explicitly stated because thought obvious and unnecessary ~ this iswhere the Forest summarizes for the public the putative comparative impa~ts ofthe 3 alternatives). comparing modeled/predicted impacts using only threecolumns consistently headed "Alternative 1 (Ifuncharacteristically severe fire

15


occurs) ", "Alternative 2 (If low to moderate severity fire occurs)" and'IAlternative 3 (If uncharacteristically severe fire occurs)" across all threesummary tables. As we stated, this conveys the clearly Implied mis-informationthat only low-moderate severity fire can or is .likely to occur underAlt 2, whileonly "unchar.acteristically severe" fire can or is likely to occur under Alt.s 1 and 3,fatally biasing the comparison -an example of gross mi,s-education of the publicby the Forest.

We 'of course used "hiah severitv'" and "low severitv" exactly as the ForestService does, i.e., as indicated by degree of resulting tree/vegetation mortality(not, as the response Jllogically and erroneously implies, whether fire is surfaceor crown).

Given that mischaracterization of DE IS comments. in the FEIS was one of ourobjections (also unaddressed by the "response"), we find these continuingmisrepresentations rema~kable and egregious:

Note also:

In terms of costs and benefits of doing the workoutside of the WU I, these -treatments will ~Isogenerate Knutson-Vandenberg (KV) funds, BrushDisposal Funds and Stew~rdship funds,which can beused for non-commercial fuel treatments, pre-commercial thinning, activity fuet1reatment, TMDLimprovements, and other mitigations. This isexplained in Appendix a (pp. a- 2 and a-3). [Kimbell'objection response, p. 3., emphasis added]

No, in fact; it is not. FEIS Appendix A describes and lists BMPs,

In summary, we would first emphasize that the above discussion is far from anexhaustive documentation of all the ways in w~ich the FEIS and objectionresponse were unresponsive to numerous substantive comments/objectionsand/or misrepresente~ them. Others include inadequate response to concernsexpressed by us and others regarding 1) justifying extensive soil disturbance inalready highly-disturbed units with arbitrary, scientifically unsupported andinadequate areal "standards:',. permissive and scientifically un$upported definitionof "detrimental" soil disturbance.. and only scientifically unproven "mitigation"measures which the Forest itself acknowledges are minimally effective; and 2)

16


essentially dismissing valid concerns regarding forest genetic resourc~s, despiteserious implications of "sanitation" fogging of live trees, and of non-local seedstock use in replanting, for those genetic resources (as well as low/unprovenprobability of efficacy of these activities as proposed). Thus in conclusion, givenfailure to 1) respond substantively to substantive comments/objections; 2)publicly disclose crucially relevant information requested in comments/objections;and 3) engage in a good':"faith effort to facilitate collaboration with andparticipation of the interested public, the Forest and the Reviewing Officer haveacted arbitrarily, capriciously, with abuse of discretion, an,d/or otherwise not in:compliance with the law, egregiously failing to meet their responsibilities underNEPA a'nd HFRA.

Literature cited

Bebi, P., D. Kulakowski, and To T. Veblen. 2003. Interactions between fire andspruce beetles in a subalpine Rocky Mountain forest landscape. Ecology84:362-371.

Brown, P. M., M. R. Kaufmann, and W. D. Shepperd. 1999. Long-term,landscape patterns of past fire events in a montane ponderosa pine forestof central Colorado. Landscape Ecology 14:513-532.

Dunne, T., and L. B. Leopold. 1978. Water in Environmental Planning. W.H.Freeman, New Yo~k. .

Fule, P. Z., A. E. Cocke, T. A. Heinlein, and W. W. Covington. 2004. Effects of anintense prescribed forest fire: is it ecological re~toration? RestorationEcology 12:220';230. .

Johnson, E. A., and C. P. S. Larsen.. 1991. Climatically induced change in firefrequency in the southern Canadian Rockies. Ecology 72:194-201.

Rapp, V. 2005a. Science update: western forests, fire risk, and climate change.Pacific Northwest Research Station. .

Rapp, V. 2005b.Sclence update: western forests, fire risk, and climate change(http:/!www.fs.fed.usfpnw). Pacific Northwest Research Station.

Raymond, C., and Do L. Peterson. 2005. How did prefire -treatments affect the.Biscuit fire? (htt ://www.fs.fed.us/fire/fmt/fmt dfsfFMT65-2. df. FireManagement Today 65(2):18-22.

Stephens, S. L., and J. J. Moghaddas. 2005. Silviculturaland reserve impacts onpotential fire behavior and forest conservation: Twenty-five years ofexperience from Sierra Nevada mixed conifer forests. BiologicalConservation 125:369-379.

Swetnam, T. W., and J. L. Betancourt. 1990. Fire-Southern Oscillation relationsin the southwestern United States. Science 249: 10.17 -1021.

17


1

Pacific Rivers Council PO Box 10798 Eugene, OR 97440 ph 541.345.0119 fax 541.345.0710

Dave Bull, Supervisor Bitterroot National Forest 1801 North First Street Hamilton, MT 59840 (406) 363-7100 [email protected] [email protected] Abigail R. Kimbell Northern Regional Forester USDA Forest Service, Northern Region P.O. Box 7669 Missoula, MT 59807 (406) 329-3315 Fax: (406) 329.3411 Dale Bosworth, Chief USDA Forest Service 1400 Independence Ave., SW Washington, D.C. 20250-0003 Mark Rey, Under-Secretary for Natural Resources and Environment U.S. Department of Agriculture Whitten Building, Room 217E 1400 Independence Avenue, S.W. Washington, DC 20250 January 18, 2006 Re: Additional significant scientific flaw in Bitterroot National Forest’s rationale for Middle East Fork Hazardous Fuel Reduction project (MEF) Dear Supervisor Bull, As we have recently made time to follow up on previous concerns regarding validity of the Forest’s citation of scientific literature in purported justification of


2

the MEF project, our suspicions were confirmed by a case of what can only be seen as scientific malpractice in the form of significant misrepresentation of the cited source (details follow). I thought you would want to be made aware of this, as I understand from our recent phone conversation that you are engaged in final deliberations for your Record of Decision for the proposed project. We request that this 7-page letter be entered into the project record and given due consideration in the final decision. Briefly, the following information documents a clear and significant misrepresentation of the scientific literature cited by the Forest in purported support of the project, on a matter central to the purported justification of its Purpose and Need. That matter is the choice of analysis period and data the Forest arbitrarily and illogically used as evidence of natural variability in estimating baseline conditions for comparison, in order to estimate purported departure from natural conditions, which underlies the claim of need for treatments. Commenters, including us, questioned these decisions and the stated rationale for them at each stage of the public process. Despite these attempts to call this specific scientifically flawed rationale to the Forest's attention, the misrepresentation documented below was apparently never discovered by the Forest (or at least, was never publicly disclosed or corrected). To say the least, this does not reflect well on the seriousness, thoroughness, or objectivity of the Forest's consideration of public input, and represents another failure in fulfilling its legal requirement to respond meaningfully and substantively to public comment. We also document yet another case of significant misrepresentation of public comment that contributes to the Forest's general unresponsiveness to public concerns, in addition to those we previously pointed out in comments, our objection, and our previous post-objection letter. Please feel free to contact us with any questions or if further clarification is needed (please direct or copy any communication to Gary Carnefix via the contact information below, not to our Eugene headquarters in the letterhead). Sincerely, Gary Carnefix, M.Sc., Research Associate Pacific Rivers Council 115 Turner Ct. #3, Missoula, MT 59802-2836 telephone number 406-543-5518 [email protected] Chris Frissell, Ph.D., Senior Scientist Pacific Rivers Council 406-883-1503 (office), 406-883-1504 (fax) PMB 219; 61529 Hwy 93 Suite A Polson, MT 59860 [email protected]


3

Misrepresentation of cited scientific literature A major underpinning of the purported Purpose and Need for this proposal is the notion that forest stand conditions in the area are “uncharacteristically” dense, and therefore at risk of “uncharacteristically severe” wildfire. The basis for this argument is analyses that purport to show moderate-to-severe departures of stand conditions from some estimate of natural variability (i.e., “historic condition” “range of natural variability”, "common natural variability"). Thus, determination of baseline condition against which this purported departure is estimated is a fundamental, crucial issue on which validity of the Purpose and Need and proposed activities are wholly dependent. We and others have repeatedly attempted to call the Forest’s attention to the importance of this issue and the scientific inadequacy of the Forest’s rationale for its choice of baseline at each stage of the public process (public DEIS comments; FEIS, including response to DEIS comments; FEIS objection; and our recent letter documenting inadequacy of response to objection). Despite these attempts, the Forest has never significantly deviated at any stage from simply repeating this rationale, quoted from the FEIS:

3.2.3 HISTORIC CONDITIONS Natural resource managers increasingly rely on the “range of natural variation” or “historic condition” to develop plans that guide management within the range of ecological and evolutionary conditions appropriate for an area. This information is used to understand the past conditions and processes and provides context and guidance for managing ecological systems today and the disturbance-driven spatial and temporal variability that is a vital attribute of nearly all ecological systems. For the Interior Columbia Basin Ecosystem Management Project, Hann et al. (1997) used the last 2000 years as the appropriate temporal depth. A time period of 200 years will be used in this project and is appropriate based on studies showing the vegetation in this area was in relative equilibrium with the microclimate and Native American uses during that time (Schoonmaker & Foster, 1991 as cited in Landres et al., 1999). Within the natural range variability, there are extreme or rare events that define these bounds. As managers, we recognize these extreme and rare events, however we do not manage for them. We wish to manage for the


4

“common natural variability” that is associated with these ecosystems. This provides an ecological reference point, and gives us the ability to evaluate ecosystem change, as well as meet Forest Plan standards and socially desirable conditions (Morgan et al., 1994). [FEIS p. 3.2-6, emphasis added]

This citation of Schoonmaker-Foster-Landres, intended to support the claim of “relative equilibrium” during the past 200 years, is incorrect. The claim of "relative equilibrium" in fact contradicts the fundamental premise of the MEF proposal, i.e., purportedly increasing departure from “range of natural variation”/“historic condition”/”common natural variability” during the past 200 years (and absent “Native American uses” throughout most of that time), and the cited source in fact contradicts the claim that this is an appropriate period. What Landres et al. (1999) actually wrote:

For the Interior Columbia Basin Ecosystem Management Project, for example, Hann et al. (1997) used the last 2000 yr as the appropriate temporal depth, based on studies showing the vegetation in this area was in relative equilibrium with the macroclimate and native Americans during that time (Schoonmaker and Foster 1991). [Landres et al. 1999, p. 1181, emphasis added; document attached in electronic .pdf format]

So, the Forest does not merely imply, but deceptively states explicitly that a 200-yr analysis period “is appropriate based on” Schoonmaker and Foster (1991, as cited in Landres et al. 1999) “showing the vegetation in this area was in relative equilibrium with the microclimate and Native American uses during that time” [i.e., the preceding 200 years]; when in fact Landres et al. (1999) cited Schoonmaker and Foster (1991) in support of Hann et al.’s (1997) use of 2000 years as the “appropriate temporal depth, based on studies showing the vegetation in this area was in relative equilibrium with the macroclimate and native Americans during that time” [i.e., the preceding 2000 years]. While changing “macro” to “micro” may well be a simple, innocent error, it contributes to the false impression created by this passage that Schoonmaker and Foster (1991) analyzed conditions and reached conclusions relating to this specific project area of the Bitterroot National Forest within the past 200 years, rather than a much broader region within the past 2000 years. The cited source directly contradicts the claim it is cited to support. In fact, Schoonmaker and Foster (1991) "emphasizes [interdependence of contemporary ecology and paleoecology] with examples drawn mainly from


5

eastern North America and western Europe" (Introduction, pp. 205-206), and examination of this source (admittedly not exhaustive) reveals no evidence supporting the claimed "relative equilibrium" for any portion of western North America. This misrepresentation of the cited scientific literature is not trivial, but rather a fatal flaw, given that the justification of Purpose and Need for this proposed project is based on the contention that purported moderate-to-severe landscape-scale departure from “historic condition”, “range of natural variation” and/or “common range of variability” has created risk of “uncharacteristically severe” fire – a contention which appears to propagate directly from this unjustified decision to truncate both the analysis period and the actual range of variation within it (by excluding “extreme or rare events” from consideration). (We were initially highly skeptical of this claim, particularly for the mixed-conifer old growth stands proposed for fuel reduction treatments – which we judged to be probably well within any true “range of natural variation” – on the basis of our site visits to a number of them in May and June, 2005.) The Forest has misrepresented crucial scientific information in purported justification of the proposed project. The FEIS should be withdrawn. Similarly, though not the specific issue addressed here, the Forest Service quite commonly promotes the mistaken impression to the public that Fire Regime Condition Class (FRCC) measures departure from the “natural range of variability” when, in fact, it only purports to estimate departure from the central tendency of the range of variability [Hann et al. 2003, revised 2005]. While this fact is minimally acknowledged, the FEIS fails to disclose that landscape-scale departure of only 34% from this central tendency estimate – virtually certain to be well within any true measure of actual range of natural variation in many situations and/or at specific locations within the landscape – is judged to indicate “moderate” departure, i.e., FRCC 2, purportedly justifying fuel reduction treatments. If disclosed, this information raises serious doubts about the claim that this and many other areas of the West are outside "natural range of variation." Hence this represents yet another serious failure to disclose important, relevant information requested by the public. Why this matters The Forest asserts based on results of modeling that the proposed fuel reduction treatments are needed due to landscape-scale moderate-to-severe "departure" from natural conditions across the project area, and proponents of such projects generally promote the notion that they are needed because forests are outside the "range of natural variation". Yet the Forest's choice of analysis period and its truncation of the variability it considers directly conflict with the sources cited in support of these choices; its citation of at least one source seriously misrepresents its content; and although the Forest minimally acknowledges that it is modeling departure from central tendency, not from range of natural


6

variation, it fails to disclose or credibly justify the relatively small departure classified as "moderate" and purportedly justifying fuel treatments. Thus the Forest's rationale of Purpose and Need for the project fails every requirement to use best available science, to rationally explain its reasoning in support of the proposal, and to respond meaningfully and substantively to public comments. Mischaracterization of public concerns In a second but closely related matter, the Forest’s “response” to this concern in the FEIS is also an example of the significant mischaracterization of public DEIS comments that resulted in failure of the Forest Service to respond substantively to information and queries presented by commenters, which we noted both in our formal objection and in our previous letter. Specifically, we cite:

Public Concern ID 3604 Comment In fact, the MEF DEIS claimed that an appropriate scale for temporal depth was the last 2000 years, but then it stated only the last 200 years were to be used (DEIS, 3.2-6). This may be adequate for establishing a historic range of variability if all ecological events were factored in, but this is not the case. Instead a "common range of variability" is used that does not factor in rare or extreme events. The MEF DEIS states, "As managers, we recognize these extreme and rare events, however we do not manage for them[”] (DEIS, 3.2-6). It is unclear how this may impact the analysis, but in any case leaving out specific data so as to skew the reference condition is arbitrary and capricious. . . . (Organization, #152.8.36000..) [="Adam Rissien, Sierra Club-Bitterroot Mission Group", FEIS pp. H. 7, 34, emphasis added; these comments were similar to ours – which were ignored in the FEIS – except that we did not concede that 200 years might be appropriate;]

This comment was mischaracterized as: Public Concern The "common range of variability" leaves out all ecological events and may affect the analysis. . . . [FEIS p. H.33, emphasis added]

The difference between the commenter stating that not ‘all ecological events were factored in” because ‘“common range of variability” . . . does not factor in rare or extreme events’, versus the Forest claiming the commenter’s concern was that ‘[t]he "common range of variability" leaves out all ecological events . . . ’ should be abundantly clear and in need of no explanation. It’s analogous to


7

the difference between “I didn’t get paid for all hours I worked” and “I didn’t get paid for any hours I worked.”

After thus mischaracterizing the comment, the Forest’s “response” goes on to simply quote at some length the same misinformation (including the egregious misrepresentation noted above of Landres et al.’s (1999) citation of Schoonmaker and Foster (1991)), followed by the absurdity that “[t]o clarify, this section is describing the development of management actions or proposals, not analysis of historic conditions” [FEIS p. H-33]. As quoted in its entirety above, this section is titled “3.2.3 HISTORIC CONDITIONS.”

Conclusions Thus, while misrepresenting critical sources for at least the third time, the Forest Service utterly fails to respond meaningfully and substantively to comments objecting to the severe truncation of analysis period and range of variation in establishing a baseline of natural conditions – in direct contradiction to the scientific literature it cites in support of its analyses. This results in misleading the public and other interested parties regarding purported departure of forest conditions from the actual “range of natural variation”, which itself is the central justification of Purpose and Need for the project. The FEIS should be withdrawn and replaced by scientifically credible analysis, and the proposed project revised to reasonably reflect such reconsideration.


Agriculture

United StatesDepartment of

Forest Service

Rocky Mountain Research Station

P.O. Box 8089 Missoula, MT 59807

2/24/2006 Dave Bull Supervisor, Bitterroot National Forest 1801 North 1st Sreet Hamilton, MT 59840 Dear Mr. Bull, I was asked by Cathy Stewart (Region 1, Forest Service) to address some of the issues raised by the Pacific Rivers Council regarding the scientific basis for fuel treatments proposed in the Middle East Fork of the Bitterroot National Forest, Final Environmental Impact Statement (FEIS). I was shown two letters (PRC1 dated 1/6/2006 and PRC2 dated 1/18/2006) that specifically criticized 1) the justification for fuel treatments in “previously unlogged, remnant mixed-conifer old growth”, 2) the need for re-treatment or perpetual maintenance of areas to retain fuel treatment benefits of moderating fire behavior and effects, 3) the low probability per acre of areas expected to be impacted by wildfires, and 4) the justification of treatment based on current forest conditions in relation to historic conditions. Also raised in these letters were other issues on which I will not offer comment since these fall outside my expertise in fire ecology and fire behavior. I hope the following information can be useful in resolving some of the controversy. Please let me know if you have any questions. Sincerely, /s/ Mark A. Finney, Ph.D. Research Forester Rocky Mountain Research Station Fire Sciences Laboratory 5775 Hwy 10 West Missoula, MT 59802 406.329.4832 [email protected]

Caring for the Land and Serving People Printed on Recycled Paper Middle East Fork ROD Attachment F Page 25 of 37

Comments on letters from the Pacific Rivers Council Let me begin by briefly reviewing what is known of fuel treatment effects. Benefits of fuel treatments for mitigating the severity of wildfires have been documented for much of the 20th century (Weaver 1943, Cooper 1961, Biswell et al. 1973), particularly in ponderosa pine and dry mixed conifer forests (ponderosa pine and Douglas-fir). Recent wildfires and renewed interest in fuel treatments have prompted new studies that have confirmed these findings (Pollet and Omi 2002, Graham 2003, Graham et al. 2004, Finney et al. 2005, Raymond and Peterson 2005, Agee and Skinner 2005). Treatments that include removal of surface fuels by prescribed burning have shown the greatest effectiveness in reducing fire intensity and severity (Helms 1979, Martin et al. 1989, Raymond and Peterson 2005, Agee and Skinner 2005), either alone or in combination with silvicultural activities that reduce vertical and horizontal continuity of canopy fuels (Hirsch and Pengelly 1999, van Wagtendonk 1996, Stephens 1998, Graham et al. 1999). Not all forest management activities qualify as effective fuel treatments or are intended to target fuels (e.g. thinning or commercial harvest without prescribed burning). Much of the research literature has shown this too (Alexander and Yancik 1977, van Wagtendonk 1996, Brown et al. 2004, Stephens and Moghaddas 2005, Raymond and Peterson 2005). From a practical and safety perspective, silvicultural activities may be required before prescribed burning can be attempted. Fuel treatment effects don’t endure forever, perhaps lasting upwards of 15 years. Studies of treatment longevity are few, but don’t contradict this as a reasonable limit in the forests studied (Biswell et al. 1973, van Wagtendonk and Sydoriak 1987, Finney et al. 2005). Treatment of Mixed Conifer Forests Comments in PRC1 express concern about the efficacy of treatment in mixed conifer forests remote from urban development. Unfortunately, in the context of large wildfires and the attempts to mitigate their effects, none of the forests or stands on a particular landscape can be considered in isolation. The continuing fire management policy of suppressing all wildland ignitions has the paradoxical effect of restricting wildland fires to burn only the driest and windiest weather conditions that foster escape and resistance to control. Once established, large fires remain difficult to contain (consider the Bitterroot fires of 2000 and those in western Montana in 1994 and 2003). Such fires are prone to making large runs over long distances (and burning many forest stands) when extreme conditions periodically return (take for example the Black Mountain II fire of 2003 that ran 5 miles one afternoon to the edge of Missoula even after a week of aggressive suppression, and the Hayman fire which moved about 17 miles north the first day and then 7 miles east following a week of containment effort by two Type I Incident Management Teams). Most of the area burned under these modern fire regimes is under weather conditions that promote rapid spread rates in fuels common in the forests today, even though such weather is statistically “rare”. The choice of 90th percentile burning conditions for the FEIS analysis might even be considered too moderate since fire suppression resources are quite capable of suppressing fires at the 90th percentile. The authors of PRC1 seem focused narrowly on the direct impacts of treatment rather than appreciating the full consequence of the “no-action alternative”. No action (or really business as usual) necessarily includes effects of inevitable wildfires, externalities of firefighting tactics used against those fires (e.g. soil disturbance from dozer lines), and continued ecological change in

2Middle East Fork ROD Attachment F Page 26 of 37

vegetation and fuels from fire exclusion. From a practical perspective, suppression actions on large fires are very difficult to regulate, since they are excluded from environmental planning policy. Oversight for fire suppression is the responsibility of the line officer (e.g. Forest Supervisor) but political and social pressures for action often outweigh environmental concerns when a threat to human safety (e.g. smoke) or property (e.g. WUI) is perceived. Aggressive suppression action is typically advocated irrespective of the probability of success for such actions. Thus, not managing forests that historically were mediated by surface fire as a disturbance, essentially places faith in passive management (but continues the active policy of excluding fire) which is now well understood to lead to the demise of the very forests so treasured (Arno and Brown 1991, Agee 2002). Indeed, restoration efforts for previously “logged” and “unlogged” forests is needed for improving the resistance to the inevitable wildland fires (Arno and Brown 1989, Brown et al. 2004). Since stand-level fuel treatment benefits of reduced wildfire severity under extreme weather conditions are increasingly proven (Pollet and Omi 2002, Graham et al. 2004, Finney et al. 2005), the challenge to managers is really to decide which stands are to be treated to achieve the greatest benefits with the limited resources available. The analysis performed by the FEIS was performed for the landscape – a scale that is commensurate with the scale of the fires that inevitably will cause the greatest impact on environmental resources and human property. Individual areas may be excluded from consideration for treatment for various reasons (ownership, access, habitat etc.), but fire growth and behavior will not respect such distinctions unless the factors that influence burning (i.e. fuels and topography) physically change fire behavior. The choice of stands for treatment involves more than just the properties of the particular stand, but as research has shown (Finney 2001, Hirsch et al. 2001, Finney 2004), the choice involves the spatial juxtaposition of treatment units with respect to other units or landscape features that permit fire to move easily across the landscape and(or) facilitate containment (Bunnell 1998). Considering the entire landscape, as does the analysis in the FEIS, helps identify treatments that improve stand-level resistance to fires as well as mitigate the movement of fires at the level of the landscape. The latter ultimately benefits WUI interests as well because suppression is improved for fires igniting throughout the landscape that otherwise could be in position to rapidly close the distance under extreme episodes of weather (Finney and Cohen 2003). The FEIS analysis identifies treatment areas as component members of a landscape that influence the movement of fires and would locally benefit from restoration/treatment. Thus, I find that the concerns over particular stands or types of forests are misplaced when real attention should be focused on the broad picture and the role that all areas of the forest offer for mitigating wildfire impacts. Need for maintaining treatments As stated in PRC1 and the second paragraph of this response, fuel treatment benefits are known to lapse with surface fuel accumulation and stand changes. Historically, such changes were interrupted by recurrence of natural or anthropogenic fires on a much more frequent basis than permitted by current management. Throughout most of the western US, we invest hundreds of millions of dollars annually (sometimes more) in attempting to exclude fire, and in the process are doing an excellent job of growing fuels and vegetation in preparation for the next fire (Arno and Brown 1989, 1991). For this reason there is a continual need for investing in measures to


compensate for interruptions of fire cycles well beyond the timeframe of any existing planning framework (Agee 2002). To specifically address the concerns in PRC1, this does not mean that all areas proposed for treatment will require some kind of mechanical re-treatment. In fact, a periodic landscape level analysis will be needed and will likely identify some areas to receive prescribed burning for maintenance of fuel and vegetation dynamics as well as new areas that, once treated, compliment the function of the existing landscape structure. The goal of many fire managers is to achieve a landscape structure that permits more frequent use of prescribed fire consistent with the local ecology and expand the enlightened uses of naturally ignited fire. It is well understood now, at least academically, that our attempt at exerting total fire control is a failed experiment, and only by continually managing the forest and fuels on a landscape-wide basis can our efforts really achieve the desired management goals (Brackebusch 1979, Gill and Bradstock 1998, Hirsch et al. 2001). The FEIS represents only the initial phases of this work. Probability of burning The authors of PRC1 are concerned that the low probabilities calculated for burning a given acre negate justification for doing fuel treatments. Basically, they infer that it isn’t worth the various costs of treatment since wildfire is so unlikely to impact a treated area. This is currently an active area of research, and numerous efforts underway to try to understand how to account for costs and benefits of fuel treatment in the context of uncertainty. It is too early for any of this research work to be put into practice, but the current state of knowledge clearly indicates that the arguments put forth in PRC1 are in incomplete. The authors of PRC1 base their conclusions of risk only on the probability which is just one of the components necessary for truly dealing with risk management and planning in an environment of uncertainty. To help explain this I think the analogy of fire management and the insurance industry is useful, because in both cases future events are certain to happen at an estimated rate but the exact location and timing cannot be known. Rather than doing nothing or praying for good luck, the insurance industry thrives in this kind of environment because people will pay premiums based on the expected damages not just on the probability of damages as the PRC1 analysis has apparently done (e.g. as individuals we pay for homeowners insurance because the consequence is high, not the probability, but the insurance company charges rates based on expected loss for large populations of people). The calculation of an expectation (expected net value change) requires summation of the product of probabilities of various kinds of events and the resulting value changes resulting from those events (often losses, but can frequently be benefits especially for fire and fuel treatments). This summation of expected net value changes must occur over large populations and over long times, exactly the case in fire management where managers deal not with single isolated acres, but whole landscapes and time-frames of centuries as required to include the life-times of the forests and growth of desired products from those forests. I did not investigate the calculation (PRC1) of modern burn probability listed at ~2/1000 fires per acre per year based on a process referred to as PROBACRE, but this figure is substantially the same as I’ve estimated for the Deschuttes National Forest in eastern Oregon that supported similar historic fire regimes as the lower elevations of the Bitterroot front (Finney 2005). In the


context of the expected net value change calculation, these probabilities for a single acre in a single year are really not “low”. The PRC1 letter suggests they are aware of this since they question the size of the area included in the analysis. The summation of probabilities must also be taken over time – many decades in fact. It is very easy to see that the probability will exceed 1.0 for a large fire somewhere in the area if the summation is performed over a few 1000’s of acres and one or two decades. These scales of area and time are approximately equivalent to the longevity of fuel treatments and are, therefore, well within the scope of the FEIS. The point about “rare” fires really becomes moot because fire and forest managers are paid to oversee management of the whole forest for longer than their personal tenure in their positions and longer than the scope of a given EIS. The insurance industry charges premiums based on expected loss but it also provides inducements to reduce losses and likelihood of loss (e.g. driver education, credits for burglar alarms etc.). Fuel treatments might be viewed in the same way, since they can mitigate the consequence of inevitable fires and lower their probability. One final point on this subject illustrates to me the problem with conclusions based only on the probability of an event. Fire occurrence is the frequency of fires within a specific area and period of time, and implies nothing about the fire size or probability of burning at a given geographic location (Finney 2005). The probability of ignition is not the same as the probability of burning. My calculations for the Deschuttes National Forest (Finney 2005) indicate that the probability of a fire starting on a particular acre was about 10 times lower than the probability of burning (~1/10,000). Yet, despite this much lower figure, the Deschuttes NF still requires considerable funding for fire staff and the attention of suppression forces on many fires per season. They fight fires because the consequences of having free-burning fires are felt well beyond the immediate ignition location and for reasons that are unrelated to the probability of ignition per acre. Historic conditions It seems that the exasperated critique in PRC2 regarding the choice of a nominal historic reference period of 200 vs. 2000 years ago is overplayed as is the preoccupation with equilibrium. Focusing on a static past is like driving while only looking in the rear-view mirror and assuming the road ahead has the same turns. Looking at the past simply allows us to understand the processes that created and maintained the examples of dynamic vegetation structures that we see today. The recent past, say in the last 200 years, suggests some guidelines for process-oriented management of forests because it illustrates how various forest structures persisted in the presence of different disturbances. In other words, we know how our extant forests were able to deal with recorded disturbances – and if our society wants those results, then we at least have guidelines in how to emulate those regimes and outcomes. However, we don’t really know how low-elevation forests recover from rare and severe disturbance (say 1/2000 years) and it therefore seems negligent to advocate passive management that, as we’ve now extensively demonstrated in the western U.S., favors such events. Regardless of what management is done today, it is certain that our forests will face a future climate and host of disturbances that are different from those in the past (Brown et al. 2004). Arguments presented in PRC2 based on the range of historic conditions and disturbances excludes mention of more descriptive and relevant statistical parameters of disturbance regime,


like mean, mode, dispersion, and shape or skewness of the distributions. The range is defined as the distance between the minimum and maximum values of the distribution and says nothing about how the values are distributed between these extremes. As a guide for management, the range is probably the least specific and descriptive. For example, as claimed in PRC2, some fraction of past disturbances were likely similar to the stand-destroying fires now predominant in the ponderosa pine and mixed-conifer forests (i.e. fell within the range). Interpreted based only on historic range, the mere possibility of severe disturbance becomes ecological precedent, and therefore, is justification for doing nothing (since all is natural within the previous range). This argument ignores the wholesale shift in the distribution of disturbances brought about by modern management policy and cultural ignorance that now tacitly permits fire only under conditions where control is impossible. This shift in the mode of the magnitude and frequency of disturbances (toward long intervals of severe events) contrasts with past fire regimes that have repeatedly been shown to have wide distributions of fire intervals mostly shorter than today and of lower severity to the overstory trees (which have survived to the present with recorded histories of many underburns). Statistically, the lengthy fire-free intervals of today were rare, but without active management into the future, these will become the norm. Literature Cited Agee, J.K. 2002. The fallacy of passive management. Conservation Biology in Practice

3(1):18-25.

Agee, J.K. and C.N. Skinner. 2005. Basic principles of forest fuel reduction treatments. For. Ecol. Mgt. 211:83-96.

Alexander, ME, and RF Yancik. 1977. The effect of precommercial thinning on fire potential in a lodgepole pine stand. Fire Management Notes 38(3):7-9.

Arno, Stephen F.; Brown, James K. 1989. Managing fire in our forests: time for a new initiative. Journal of Forestry 87(12): 44-46.

Arno, Stephen F.; Brown, James K. 1991. Overcoming the paradox in managing wildland fire. West Wildl. 17(1):40-46.

Biswell, H.H., Kallander, H.R., Komarek, R., Vogl, R.J., and Weaver, H. 1973. Ponderosa fire management: A task force evaluation of controlled burning in ponderosa pine forest of central Arizona. Tall Timbers Research Station Misc. Publ. No. 2. Tallahassee, Florida.

Brackebusch, A.P. 1973. Fuel management: a prerequisite not an alternative to fire control. Journal of Forestry. 71(10): 637-639.

Brown, R.T., J.K. Agee and J.F. Franklin. 2004. Forest restoration and fire: principles in the context of place. Conservation Biology 18(4):903-912.

Bunnell, D. 1998. Old growth lodgepole pine and the Little Wolf Fire. In: Close, K.; Bartlette, R., eds. Proceedings of the 1994 interior West fire council meeting and program. International Association of Wildland Fire, USA: 155-160.

Cooper, C. F. 1961. Controlled burning and watershed condition in the White Mountains of Arizona. J. For. 59: 438-442.


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15 March 2006 Dave Bull Forest Supervisor Bitterroot National Forest 1801 North 1st Street Hamilton, MT 59840 Response to Comments on Fire Regime Condition Class (FRCC) Analysis, Middle East Fork Project Dear Sir: Following is a response to comments received from the Pacific Rivers Coalition and the Wilderness Society, regarding the fire regime condition class (FRCC) analysis conducted for the Middle East Fork (MEF) Project. FRCC is an ecological measure of landscapes. Landscapes are ranked in condition classes of departure from a range of natural conditions, usually an historic (pre-European settlement) range. Conditions are indicated by the mix of seral stages coupled with the fire frequency and severity on the landscape. Condition classes can be expressed as 1, 2, and 3, with 1 being similar to the historic range of variation (HRV), 2 being moderately departed from HRV, and 3 being severely departed. Highly departed landscapes are often those with high risk of severe wildfire, altered by invasive plants, and generally less ecological resilience in the face of disturbance. Note that FRCC is an ecological measure, not a policy decision. Policy decisions reflect social and economic considerations as well as ecological ones, and are best expressed as desired future conditions. The comments received can be categorized as concerns with 1) the time frame used for reference conditions; 2) the use of central tendency in FRCC calculations; 3) determination of uncharacteristic conditions; and 4) general concerns with the validity of FRCC methods:

1) Time Frame Used for Reference Conditions A response on this issue will be submitted separately by Wendel Hann, National Interagency Fuels Technology Team (NIFTT) co-leader.

2) Use of Central Tendency in FRCC Calculations FRCC methods were developed using departure from central tendency, a best estimate of the mean landscape coverage of historic seral stages. FRCC calculations for this project followed standard interagency methods. As part of the peer review process, and in order to use best available science, we continue to explore options to better describe the historic range.


3) Uncharacteristic Conditions The term “uncharacteristic” is used in FRCC in two manners. Wildfires in departed condition classes (2 and 3) are described in the FRCC condition class descriptions as “moderately to highly uncharacteristic compared to the natural fire regime behavior, severity, and patterns”. “Uncharacteristic” conditions, as defined in FRCC methods for determining Vegetation Fuel Classes, have a precise meaning: areas affected by factors not occurring historically (prior to European settlement). These categories include:

Uncharacteristic; invasive plants; invasive plants, such as annual grasses or knapweed; difficult to reverse with restoration if large and scattered infestations; most effective to prevent and contain.

Uncharacteristic timber mgmt. not mimicking natural regime; timber harvest, stand improvement, and tree planning is not similar to natural regime; road density may be excessive; often lacks dead and down trees and logs; patterns are typically linear or uniform rather that irregular and random or clumped

Uncharacteristic; fuels/succession/lack fire effects; natural disturbance frequency is beyond maximum allowing fuel accumulation or structure that did not occur naturally.

Characterizing this area as uncharacteristic in FRCC calculations is therefore appropriate.

4) General Concerns With the Validity of FRCC Methods I concur with the Regional review and response in Abigail Kimbell’s letter on this project dated November 23, 2005. FRCC is a peer-reviewed method officially adopted by multiple Federal agencies and The Nature Conservancy, for the purpose of landscape assessment when restoring ecosystems across landscapes. Kimbell’s letter cites Hann and Strom (2003), Schmidt et al. (2002), and Hann (2004) as affirming the FRCC method. FRCC was also formally reviewed by a panel of scientists (see FRCC Guidebook, ver. 1.2, Appendix C), who concluded “that the concept of fire regime condition class is science-based, and that it appropriately tries to reflect changes in vegetation and fuel conditions as a result of changes in fire regimes, other disturbances, and land use.” Finally, FRCC is being continually evaluated and improved as peer review is received, and experience in the field is reported by the hundreds of resource professionals who have been trained in these methods. Sincerely, /s/Thomas DeMeo Thomas E. DeMeo, Ph.D. National Interagency Fuels Technology Team and Pacific Northwest Regional Ecologist USDA Forest Service


National Interagency Fuels Technology Team (NIFTT) 1

Date: March 16, 2006 To: Dave Bull Forest Supervisor Bitterroot National Forest 1801 North 1st Street Hamilton, MT 59840

From: Dr. Wendel Hann, NIFTT Co-Leader, National Interagency Fuels Technology Team

(NIFTT)

Subject: Bitterroot NF “Middle East Fork Hazardous Fuels Reduction Project” FEIS and comment letters from Pacific Rivers Council dated Jan 6, 2006 and Jan 18, 2006 The National Interagency Fuels Technology Team (NIFTT) is sponsored by the National Interagency Fuels Coordination Group (NIFCG) located in Boise at the National Interagency Fire Center (NIFC). The NIFTT is a group of technical specialists with education and experience in fire, fuels, and resource science and management. Group membership is made up of Agency, The Nature Conservancy, and contract personnel. The NIFTT has technical responsibility for the Interagency Fire Regime Condition Class (FRCC) Guidebook content, tool development, and technology transfer. In addition, NIFTT has responsibility for fuels and fire behavior assessment tools development, technology transfer, and LANDFIRE data technology transfer. In providing comments on the subject letters I am restricting comments to those related to the technical responsibility of NIFTT for FRCC and general fire and fuels ecology and assessment. Pacific Rivers Council Jan 18 2006 Letter: The Choice of analysis periods for the Middle East Fork project appears to be logical and appropriate. The statement by Pacific Rivers Council relative to interpretation of “Hann et al.’s (1997) …” is taken out of content. Suggesting that this work would support 2000 years as an appropriate temporal depth for this site specific management action is incorrect. Hann et al (1997) reviewed paleoecological data and literature of a broad nature for the Interior Columbia Basin relative to the last 2000 years in a context of 1.2 million years of potential associated trends in ecosystem components. This review provided broad context for the evolution of adaptations of species and interaction of fire and hydrologic regimes with vegetation conditions. There was no intent in Hann et al. (1997) to make this 2000 year period a reference period for estimating departure from Natural Range of Variability (NRV) or Historical Range of Variability (HRV). The intent for the Hann et al. (1997) NRV or HRV baseline was to establish a central tendency and range of conditions for a historical period with a climate similar to the current. Hann et al (1997) did not specify a time period for development of the non-spatial Vegetation Dynamics Development Tool (VDDT) models because modelers’ simulated periods long enough to display the fluctuations that would occur through time, given the succession and disturbance time cycles specific to their model. These models were used to develop base probabilities for change due to



succession and disturbance. The spatially modeled time period was a 100 year period that had a starting point composition taken from the historic map composite that represented vegetation conditions for the late 1800s’. This 100 year time period was determined to be adequate for display of spatial variability using the Columbia River Basin Succession Model (CRBSUM). The non-spatial VDDT developed probabilities were used as inputs to the CRBSUM. FRCC was an appropriate tool for the Middle East Fork Analysis and appears to be applied correctly. For Fire Regime Condition Class (FRCC), the time period that is important for estimating historical conditions is specifically related to a modeled estimate using a time period that reflects the succession and disturbance cycles for the given Potential Natural Vegetation (PNV) or BioPhysical Setting (BPS), for the current climate with historical disturbance regimes. These estimates are published and available on the FRCC website (www.frcc.gov) as reference conditions. These reference conditions have been developed and reviewed through modeling workshops. The reference conditions used to determine departure are a central tendency. Central tendency for reference conditions is used in the FRCC guidebook because it causes the least bias in estimate and classification of current departure. Within the PNV or BPS description there is discussion relative to historical or natural range of variation of reference conditions and historical disturbance regimes. The historical or natural range of variability is accounted for in the FRCC method of departure calculation and classification, not in the reference conditions. The method of departure calculation allows for a plus or minus 33% range of departure within condition class 1. This is the class assumed to represent the HRV. In tests of these methods using both non-spatial and spatial data, the 33% and 66% breaks between classes 1 and 2, and 2 and 3 respectively, appear to provide the least biased classification of range of variation and departure from that range. Literature review, spatial simulation, tree ring studies, or other methods to characterize historical range of variation do not fully capture an accurate range of variation. There is no way to assess accuracy of the historical range of variation because there are no measurable records of all conditions and disturbances. The FRCC methods and reference conditions do not require users to customize estimates of range of variation or reference conditions. In fact, the guidebook emphasizes that they not do this unless fully trained in these modeling or field assessment techniques. A complete study of historical range of variation is not the point or the focus of management applications of FRCC technology. The focus of FRCC management implications is not to focus management implications on any 1 condition class. The management implications emphasize that class 1 may need maintenance, and classes 2 and 3 may need restoration. The methods focus the user on relative differences; lesser departures may need more emphasis on maintenance, while larger departures may need more emphasis on restoration. Users may choose how they use these implications in NEPA purpose and need statements or for other applications. Assessment and management implications for FRCC are complex and technical. This is why the federal land and fire management agencies have implemented a guidebook and certification process for Users and Trainers. The specialists conducting the FRCC analysis for the Middle East Fork project are trained and certified in FRCC. People that critique the application or methods of FRCC that are not trained tend to interpret or apply the information out of context or incorrectly. In our own weighting of comments and critiques on the FRCC guidebook we put much more weight on those from trained and experienced on-the-ground Users or Trainers, and from research scientists that have been both trained in the methods and are conducting research or studies using spatial and non-spatial techniques.


http://www.frcc.gov/


From a purpose and need perspective, it appears the EIS is focused primarily on wildland fire hazard to wildland urban interface (WUI), condition class, and forest health considerations relative to insect and disease. The majority of the treatments, it appears (91%), improve the FRCC condition. Assessment of FRCC has little relevance to “fuels driven fire behavior hazard” to WUI. The specialists appropriately used other tools, as discussed in the EIS, to assess these fire behavior factors (FlamMap used to assess flame length, crowning index and rate of spread in the WUI). There is a side benefit to assessing FRCC relative to design of WUI fuel treatments, in that many WUI treatments can be designed to reduce both “fuels fire behavior hazard” and improve condition, as apparently is the case with this project. FRCC may or may not be relevant to insect and disease management implications. Similar to the WUI situation, there may be a side benefit to assessing FRCC in this context, and again, this appears to be the case with this project. October 20, 2005 letter from The Wilderness Society (TWS) It is unclear if TWS discussion of “flawed FRCC methodology” is directed at how the FRCC technology was applied by the Bitterroot NF or if directed at the methods in the Interagency FRCC guidebook. If directed at the guidebook methods I refer you to my previous discussion related to comments from the Pacific Rivers Council. If directed at how the FRCC technology was applied by the Bitterroot NF, also see above.


Documents

APPENDIX Ca123.g.akamai.net/7/123/11558/abc123/forestservic...[P.L. 108-148, Sec. 104. (f), emphasis added] . Deliberate striking of sporting/conservation organizations from mailing