limate change and the national economic crisis thrust federal wildlands front and center onto the policy-making stage in 2009. The federal government sees the nation’s wildlands as a critical component for resolving these two problems. Wildfires, droughts, hurricanes, and floods are increasing in intensity, forcing the government to take action to reduce greenhouse gases (GHGs) in an attempt to contain these natural phenomena. Catastrophic wildfires are believed to emit huge amounts of GHGs into the atmosphere and cost the federal government billions of dollars in suppression. These two issues have prompted the White House to direct land management agencies (LMAs) to create a cohesive, multi-agency solution to the problem. As a result, the Omnibus Public Lands Management Act of 2009 included the Collaborative Forest Landscape Restoration Program (CFLRP), created to reduce wildfire suppression costs, protect wildland-urban interface (WUI) communities, and promote forest health. Delayed governmental acknowledgement of climate change has led LMAs to rush headlong into the first, easiest, and cheapest solution available, a protocol of extensive forest “fire treatment,” projected to lower overall GHGs and fire suppression costs. The problem with this solution is that LMAs did not include the public in this decision-making and the protocol they have developed is of questionable scientific soundness, violates the Clean Air Act (CAA), the National Ambient Air Quality Standards (NAAQS), and the public’s right to clean air.
On December 7, 2009, the Environmental Protection Agency (EPA) announced that GHGs “threaten the public health and welfare of the American People.” This “final findings respond to the 2007 U.S. Supreme Court decision that GHGs fit within the CAA definition of air pollutants.” GHGs naturally occur in the Earth’s environment but have increased dramatically due to human activity. One of the most common GHGs is Carbon Dioxide (CO2). Forests serve as the planet’s mechanism to transform CO2 into oxygen. Trees absorb CO2, lock the carbon into their tissues, and emit oxygen. Because of this, healthy forests are described as “carbon sinks.” According to Western State Foresters, “if managed for maximum productivity, carbon sequestered in U.S. forests could account for 20-25% of the needed emissions reductions nation-wide.”
By implementing the CFLRP, LMAs claim they can avert catastrophic wildfires, prevent huge GHG emissions, and create better carbon sink forests while also lowering fire suppression costs. Scientific papers from organizations such as the National Center of Atmospheric Research (NCAR) have produced mixed reports on the benefits of fire treatment and the quantities of CO2 emissions from catastrophic wildfires. These reports use cautionary wording such as, “the use of prescribed burns to manage western forests may help the United States reduce its carbon footprint” and state their research on wildfire carbon emissions “have a margin of error of about 50 percent.” In light of these scientific findings, Sequoia and Yosemite’s management of the Sheep, Slope, and Vernon fires is reckless and irresponsible, especially given the fact that The Brookings Institute 2008 document, The Future of Wildland Fire Management, Advanced Briefing Report for the 2009 Quadrannial Fire Review states, “smoke will be an increasing health factor in the WUI as 30-35% of households in the WUI have smoke related health issues.” Interesting, the Quadrannial Fire Review’s 2009 Final Report reads somewhat differently, they removed the “30-35% of households” statistic and replaced it with “a number of households”—this wording is much less inflammatory.
The current state of our national forests is a result of 100 years of aggressive fire suppression and 50 years of intensive timber harvesting policies by LMAs. The protocol of fire suppression arose from a nationally traumatic event in 1910 called “The Big Burn,” which charred 3 million acres of forests in Idaho and Montana and killed 78 firefighters. This event served to define the U. S. Forest Service (USFS) as an organization. Created in 1905, the USFS came under the direction of one “the veterans” of The Big Burn in 1935. During his tenure, Chief Gus Silcox “declared that all forest fires should be extinguished by 10 am the following day.” The CFLRP has been enacted to reverse this “no burn” policy and “return fire to its natural environment” in order to avert conflagrations such as The Big Burn and last year’s Angeles National Forest Station Fire. The fallacy of this theory is that fire was part of the forest ecosystem in Idaho and Montana prior to 1910. These forests weren’t “overstocked” with dense stands of small trees yet The Big Burn happened anyway—in forests treated by fire.
Earlier this year, the Wildland Fire Leadership Council “chartered the Cohesive Strategy Oversight Committee (CSOC)” to create a cohesive national wildfire management strategy. The OSOC held 15 forums “with representatives from all levels of firefighting organizations, state and local governments and non-profit organizations to engage stakeholders in the wildfire issue for development of the strategy.” Interestingly, although this cohesive strategy is about managing public lands, apparently the public was not deemed a “stakeholder,” and therefore, was not invited. The forum summaries make for interesting reading. The Olympia, WA members were the most thoughtful and ethical group, stating, “Protect public health and safety, especially effects of smoke (Clean Air Act). Protect National Ambient Air Quality Standards, especially PM 2.5 [smoke emissions]. Determine cost for protecting resources, including human health. Coordinate and communicate with regulatory agencies, health agencies and general public. Protect visibility in Class I area with respect to smoke.” The Reno members asked, “How to remove politics and home rule from the planning and implementation? How do we get the public to accept even more smoke?” The Ruidoso, NM, members wondered, “Is air quality a value? or a desire?” Apparently, they misplaced their copy of the Clean Air Act. And the Sacramento members asked, “How can we restore the natural background smoke emissions while addressing the potential health impacts to local communities affected by 100 years of fire suppression and associated fuels accumulations? How can we reduce NEPA [National Environmental Policy Act] and CEQA [California Environmental Quality Act] requirements and time for fuel reduction, especially adjacent to communities?” Except for the Olympia forum’s comments, few of these statements are in any way reassuring that LMAs officials, implementing the CFLRP, will observe and uphold air quality laws and standards.
In 2004, the California Air Resources Board (CARB), San Joaquin, Tuolumne, Great Basin, Mariposa, Amador, Calaveras, and Placer Unified Air Pollution Control Districts, the National Park Service, Bureau of Land Management, the USFS, and the EPA, drafted a Wildland Fire Use Coordination and Communication Protocol (WFU). This document was created “to establish the coordination framework that will be used to minimize smoke/emission impacts from naturally ignited wildland fires that are managed for resource benefits.” According to this protocol, WFUs were subject to CARB’s smoke management plan (SMP), which required LMAs to have contingency plans should the smoke impact “smoke sensitive areas.” Since the CFLRP went into effect, CARB has decommissioned the WFU protocol and is in the process of drafting a new policy, one that is “not regulatory.” This change in policy suggests there will be no consequences for LMAs polluting the Eastern Sierra with smoke.
“I believe intelligent societies will not long accept incoherent actions. In wildland forest management, either we help establish a coherency of action at the local, state, and federal levels or the uninformed will do so,” stated Tom Harbour, Director of Fire and Aviation Management, USFS, and keynote speaker at the 2009 Quadrennial Fire Review. Given the smoke pollution Eastern Sierra residents have endured over the last few months, the CFLRP is far from a coherent plan. This policy is diametrically opposed to the intangible values Americans hold dear: good health, quality-of-life, and a clean environment. It is time for the “intelligent” but “uninformed” to tell the LMAs their forest management policies are incoherent and unacceptable. Contact your state and federal representatives.