A Quincy Library Group Response to

S. 1028: Outdated Policies that will Increase Fire Risk,
Endanger Firefighters, and Harm Forest Ecosystems

by Timothy Ingalsbee, Ph.D.
Director, Western Fire Ecology Center
Western Ancient Forest Campaign

Also see Dr. John Menke's review of this report

Dr. Ingalsbee's Report

QLG Response


   From September 4-12th, 1997, I traveled through the northern Sierra Nevada in order to better understand the possible social and ecological consequences of Senate bill 1028. I interviewed a number of federal fire scientists and fuels managers, private foresters, local environmentalists, and members of the Quincy Library Group. I also gathered official documents, took photographs, and purchased maps relating to the proposed project. Perhaps the most important data source was the opportunity to observe the condition of the landscape and walk the ground of proposed timber sale units.

   From 1980 to 1990 I was employed as a firefighter for the U.S.Forest Service and National Park Service. I did graduate research in fire ecology and fire management on my way to earning a doctoral degree from the University of Oregon. I have been a fire ecology educator for the last six years, and have produced several publications and conference presentations on fire ecology and fire management issues. From my personal background, and my recent field research in the forests covered by S.1028, I have come to the conclusion that significant ecological damage and community harm would occur from implementation of this bill. For the reasons explained below, I believe citizens and legislators concerned for the long-term health and sustainability of the National Forests and forest-dependent communities in California (and throughout the West) should vigorously oppose S.1028.


   Since no timber sales have yet been proposed under the QLG Bill, impressions gained from previous and currently proposed sale units are not necessarily relevant.


   S.1028 represents an outdated fire philosophy that is based on the suppression tactics developed during the 1930's, and the pre-suppression fuels management strategies developed during the 1950's. During this latter period, over two thousand miles of fuelbreaks were constructed throughout the Sierra Nevada as part of a Cold War era Civil Defense program to prepare for "conflagration control" in the event of thermonuclear warfare. This program was abruptly ended in the early 1970's because these fuelbreaks were too costly to implement and maintain, and more importantly, because in all but a few incidents they did not work during actual forest fires. The Forest Service currently lacks any scientific evidence to support its claim that shaded fuelbreaks allow safe, efficient firefighting, or will protect forests from fire. On the contrary, there is a large body of research making the opposite conclusion. For example, the research of Dr. Omi (1996), Director of the Western Forest Fire Research Center and the nation's top scholar of fuelbreaks, reveals that the agency has no documentation proving any reductions in wildfire losses with the use of fuelbreaks. Dr. Omi concludes that a broad landscape system of fuelbreaks (such as proposed by S.1028) cannot be economically justified. Other studies (e.g. Davis, 1965; Deeming,1990) have not only criticized the poor economics of fuelbreaks, but noted the controversial nature of their impacts on biological and scenic resources. S.1028 fails to address the repeated failures of past fuelbreak programs. Rather than "protect" the forest from fire, the new fuelbreaks would actually add to the existing groundfuel hazard, increase the intensity and severity of future fires, pose risks to firefighter safety, and increase the risk of large-scale, severe wildfires. In the name of firefighting efficiency, the construction of fuelbreaks would cause impacts to the very values of the forest---wildlife habitat, water quality, recreational opportunity, scenic beauty, and community stability---for which S.1028 claims to be protecting and restoring. In effect, S.1028 would sacrifice forest ecosystem health in exchange for a misguided, failed fire protection scheme.


According to QLG research, none of the fuelbreak theory or experience referred to in the adjacent frame was in accordance with a prescription compatible with the QLG proposal. Nevertheless, Ingalsbee has to acknowledge, though of course in a back-handed way, that some of the earlier fuelbreaks did work as intended. One point to remember is that the payoff from a single fuelbreak that does work can be huge.

   However, in general the earlier fuelbreaks were inadequately designed and maintained. They were significantly narrower (often much narrower), and were usually based on skinning a strip to bare ground and keeping it that way. In contrast, the QLG fuelbreaks are wide areas of much gentler treatment, with fuel reduced and shade retained. The QLG Bill specifies a five-year pilot project for the very reason that an updated fuelbreak strategy needs to be tested on the ground, at adequate scale to give valid results within a reasonable time. Pending completion of this pilot project, the best available science on the effectiveness of the proposed fuelbreak strategy is provided in the Sierra Nevada Ecosystem Project (SNEP) report. Two quotes from SNEP are of particular relevance:

   In discussing computer simulations of fire effects with and without fuelbreaks, SNEP says "...the DFPZs reduce the extent of [severe] fire by up to 1/3 over fifty years." (emphasis added) (Johnson et.al.)

   In another chapter, SNEP says "Goal 1: Reduce substantially the area and average size burned by large, high intensity wildfires. ... Multiple benefits of DFPZs may include: (1) reducing severity of wildfires within treated areas, (2) providing broad zones within which firefighters can conduct suppression operations more safely and more efficiently, (3) effectively breaking up the continuity of hazardous fuels across a landscape, (4) providing "anchor" lines to facilitate subsequent areawide fuel treatments, and (5) providing various non-fire benefits. We are aware of no other strategy with as great a potential in the short term to progress reasonably rapidly toward achieving goal 1." (emphasis added) (Weatherspoon et.al.)

   The QLG strategy is not "based on suppression tactics developed during the 1930's." It is the logical five-year-long first step of a comprehensive fuel reduction program, which is widely recognized to be a necessary pre-condition for numerous forest health improvements, not just to reduce the risk of catastrophic fire. It is a pilot project for the purpose of designing and refining that fuel reduction program, not a substitute for area-wide fuel reduction. The major difference between the actual QLG strategy and Ingalsbee's version is that the earlier "fuelbreaks" he cites were largely designed as "firebreaks" intended to substitute for wide area fuel reduction, whereas the QLG fuelbreaks are the first step of large scale fuel reductions, done in a pattern designed to give early strategic leverage to the effect of "thin from below" fuel reduction on fire behavior.


   The landscape of the northern Sierra Nevada already suffers from excess groundfuels in the form of heavy slash left untreated from previous logging, and dense thickets of brush growing in cutover, managed stands. S.1028 offers no plan to remove this load of slash and brush; instead, S.1028 focuses strictly on the removal of new green trees. This would add even more groundfuels in the form of new slash and stumps. Additionally, S.1028 does not discuss how it plans to fund long-term maintenance of the fuelbreaks. The failure of all prior shaded fuelbreak programs in California has been their inability to control brush from colonizing the exposed, disturbed logging sites. Slash mixed with brush, particularly "chaparral" species like manzanita, is an extremely flammable fuel load that will increase the hazard and risk of severe wildfires. An authentic fire protection plan would seek ways to reduce this fuel type, not add to it, as S.1028 would do.

   In S-1028, Congress gives overall direction to the Forest Service, but does not provide a detailed operational plan. It is an authorization bill, not an appropriations bill. It specifically requires an EIS for the project, and that EIS is required under NFMA and NEPA to develop and publish a detailed operational plan with full public participation. QLG expects to participate in the NEPA process and continue recommending the QLG Proposal published in 1993, which calls for implementation of the California Spotted Owl Technical Report (CASPO) recommendations on fire and fuel management. QLG's intention has been and will continue to be that fuel reduction includes treatment of excess ground fuels. But QLG also recognizes that CASPO recommends retention of some ground fuels, not just wholesale removal.


   S.1028 plans to use commercial logging to reduce tree canopy cover to 40% or less. This reduction in crown closure would change microclimatic conditions in ways that feed intense fires. Groundfuels would be exposed to more sun and wind, causing them dry out earlier in the spring and sooner after rainstorms. Dr. James Agee's (1996) research has demonstrated that reducing groundfuels is the most effective treatment to prevent crownfires, while thinning tree canopies results in hotter, drier, windier conditions on the ground surface. With higher temperatures, lower humidities, and stronger winds, surface fires burn intensely and spread rapidly. The high heat column from slash-and-brush fires can ignite crownfires even when flame lengths fail to reach lower limbs or climb ladder fuels. And slash-and-brush fires cause root-scorch that can kill large old-growth trees even if their canopies do not ignite. Assuming that slash treatment does occur in the future (a huge assumption given the agency's abysmal track record), then burning the huge hand- or machine-piled mounds of slash generated by new logging would cause severe fire effects by essentially sterilizing the soil. Finally, using fuelbreaks to light backfires during firefighting incidents would cause severe burning of adjacent forest stands since they would be lit during extreme fire weather conditions. Often, the objective of backfires is 100% consumption of the vegetation from ground to crown, thereby sacrificing trees to stop fires. The impacts and uses of these fuelbreaks would thus increase fire intensity and severity---the very opposite effects S.1028 claims to achieve.

   A straw man burns exceedingly well. It is always possible to assume conditions where fire will kill big trees, or fire-fighters take extreme measures, or slash can be piled high enough to burn too hot. There is no "plan" to reduce all canopies to 40 percent coverage. The Project EIS will have to deal with this issue among many others. Any current talk of 40 percent is based on the mention of that number in the CASPO recommendations, which themselves do not apply to every stand in the forest, and allow for site-specific variation in those stands where they do apply. One of the tradeoffs that needs to be considered in each case is the relative advantage of retaining cover versus reducing the fuel contained in that cover. The QLG proposal is not conventional "logging" of the canopy (i.e. larger trees first), but "thin from below" (i.e. smaller trees first). QLG agrees that excess ground fuels are part of both the ground-fire and crown-fire hazards, but they are not the only component, and usually they are not the most critical component. Small green trees comprise most of the "fire ladder" that is necessary in almost all cases to take the fire into crowns and enable it to stay there and propagate. It simply isn't feasible to remove these fire ladder trees by using prescribed fire, because any fire hot enough to remove, for example, a six inch diameter tree will be hot enough to do fatal damage to larger trees. Mechanical removal is the only feasible initial treatment in most of our fuel situations, particularly in our worst fuel situations. And of course treating the worst fuel is a priority goal. Nibbling around the edges with prescribed fire or slash treatments is an easier concept to sell, but it can't do the job.

  Slash piles of the sizes actually specified by the Forest Service can be burned without damage to soils, and generally to great benefit. "Sterilizing" the soil with fire can be accomplished without making it into terra-cotta. It is easy to see, for example on Collins Pine land, that pines regenerate best in the precise areas where slash piles were burned, partly because damping off fungus was killed by the heat. Spot sterilization of soils is by no means non-reversible; indeed, fire-adapted forest ecosystems have their own mechanisms for both cleansing and culturing productive soils. Slash pile burning need not go outside the natural ranges of temperatures and heat pulses caused by beneficial natural fires.


  Proposed fuelbreaks are located alongside existing logging roads. These roads were built to access timber sales, not to aid fire suppression. Thus, roads in the Sierra Nevada commonly switchback up steep slopes, cut across mid-slopes, follow stream courses at the bottom of narrow canyons, and run through previously cutover areas where units are covered with slash, brush, and plantations. Firefighters staged in these fuelbreaks will either have to apply direct attack strategies and march down into steep drainages to fight fires below them (one of the most dangerous maneuvers in firefighting), or they will have to apply indirect attack strategies and wait for the fires to reach their control lines. In either case, firefighters would be at risk from being overrun by wildfire in the kinds of extreme fire behavior situations that are used to justify the fuelbreaks. S.1028 fails to prioritize treatment of the principal hazardous fuel load---slash and brush---and fails to provide long-term funding mechanisms for maintenance of the fuelbreaks. If new slash is untreated and new brush is allowed to grow, then these fuelbreaks will be extremely unsafe and inefficient areas for firefighting crews. The vast majority of firefighting fatalities have occurred from fires burning through thick brush, not closed canopy forests. The claim that adjacent roads will allow speedy evacuations of crews will likely tempt some fire bosses to put firefighters into risky situations that demand such emergency retreats. S.1028 perpetuates the myth of human ability to control extreme fire behavior, and puts firefighters at risk from the agency's futile attempts to live up to this myth.


  Fuelbreaks would not be built along all roads, and the need to include a bad road in the QLG area would be very rare or non-existent. A major effect of the QLG Proposal is to remove fuels from the very brush and slash choked stands that Ingalsbee postulates as the greatest hazards. We have yet to find anybody who would prefer to fight fire with bulldozers and shovels on unprepared ground instead of with water and foam along a good road in a pre-thinned forest. Ingalsbee's last argument is equivalent to some early objections raised by opponents of seat belts and air bags, who claimed that safety would be reduced if we made cars safer, because ordinary people would become daredevil drivers.


  An internal agency document yet to be released to the general public offers preliminary analysis of the kinds of environmental impacts that would occur from implementing S.1028. At the top of the list of impacts is the revelation that 117 miles of new logging roads would have to be constructed in order to fully develop the fuelbreaks. Additionally, permanent roads and temporary skid roads would need to be built to gain access to the several thousand "group selection" (i.e. clearcuts) sites in the Fuel Reduction Zones (FRZs) adjacent to fuelbreaks. Both the amount and density of roads would greatly increase, causing adverse effects to fish and other wildlife habitat, water quality, soils, and scenic resources. Moreover, the fragmentation and edge effects of existing roads would be greatly magnified by the substantial amounts of vegetation removal required for construction of fuelbreaks. Habitat for spotted owls, flying squirrels, bear, and deer, for example, would decline due to the loss of hiding cover, thermal cover, and forage. Also, negative impacts would occur from illegal activities that are routinely conducted alongside logging roads, such as wildlife poaching, timber theft, garbage dumping, and forest arson. The desire to restrict new road-building and remove old logging roads is prevalent among the public and members of Congress. Regardless, S.1028 is utterly dependent upon a quantumfold increase in the amount, density, and impacts of logging roads.

  There is no "plan" to build new roads for fuelbreaks, because that is one issue that needs to be decided in the project EIS required by S-1028. The National Forests in the QLG area are already intensively roaded, so it will be difficult to find any "necessity" for new roads. One major effect of the S-1028 will be to remove hundreds of thousands of acres from the area currently available for roadbuilding, and designate them "off base" or "deferred" areas. For at least the term of the QLG Bill, no road building or timber management activity would be permitted in those areas. The QLG fuelbreak strategy is not dependent on any quantumfold increase (whatever that is) in road building.

  Some tradeoffs are required, no doubt about it. Any reduction of wildlife cover within fuelbreaks must be balanced against the advantage to wildlife from the reduced threat of high intensity wildfire. QLG is attempting to address the major wildlife hazard identified in the CASPO report, SNEP, and elsewhere: that high intensity wildfire is the greatest single threat to wildlife habitat and wildlife survival.


  Roads are known conduits of human-caused fires. Proposed roadside fuelbreaks would increase human access and mechanized activities within timber sale units. This would lead to increased risk of accidental fires caused by logging and road-building activities, as well as from careless recreationists. It would also lead to increased intentional fires lit by Forest Service firefighters. One of the main purposes of fuelbreaks is to light backfires during wildfire suppression incidents. Backfires used to be a rare, desperate tactic because they cause considerable damage and inevitably add more burned acreage to a forest fire. But in recent years they have become almost a standard, routine practice. Backfires are ignited in the worst of all possible fire conditions; consequently, they often escape control, jump over firelines, and sometimes create separate wildfires of their own. The truth of the matter is that these fuelbreaks are not going to stop severe wildfires, but are places the agency intends to start backfires. The risk of large-scale, severe wildfires will inevitably increase due to the changed microclimatic conditions and fuel loads left in the wake of logging, as well as the management activities planned for the fuelbreaks---logging, road-building, and firefighting. The Achilles heel of S.1028 is the lack of a provision for funding long-term brush maintenance of the fuelbreaks, and lack of funding for fuels reduction within the landscape blocks between fuelbreaks. Without these two essential components of a hazard fuels reduction program, S.1028 would fail to address the real fire hazards today--slash, brush, and plantations. The fuelbreaks would defy the ability of firefighters to safely and efficiently use them during extreme fire events, and ironically, would only prime the pump for future severe fires. S.1028 does not protect forests or restore ecosystem health, but merely continues the agency's failed logging and firefighting policies of the past.

  This is mostly a re-hash of the road building and other issues dealt with earlier. Again, QLG does not intend to stop fuel reduction after the fuelbreaks are in place. They are just the first step to general area fuel reduction. Backfires might be used in fuelbreaks, but if so, they would be ignited in much less hazardous and damaging conditions, because a wide area right along the road would already have been thinned. A backfire would serve mostly to "update" the fuelbreak by removing residual fuel, and, in the scenario Ingalsbee postulates, the trees outside the fuelbreak would burn anyway, whether in the original fire or the backfire. Setting a backfire in current conditions is likely to be an act of extreme desperation because the fuel overload in both ground fuel and fire ladder trees is so hazardous. Backfires will become less hazardous and more useful as the QLG fuel reduction strategy progresses. Ingalsbee blames QLG for an action that it doesn't propose, and refuses to credit QLG with the most likely results of the strategy that it does propose.


  S.1028 claims to promote economic stability for the local community by mandating a five year period of accelerated logging. In recent years, job losses have occurred in the timber industry both through outright mill closures and the automation of logging and milling processes. This modernization has resulted in more wood being processed by fewer workers. Thus, while the old Sierra Pacific Industries mill in Quincy, California employs over 250 people, the new SPI mill employs just 7 (seven) workers per shift. And whereas formerly a crew of ten could be used to fell and yard trees on a typical timber sale unit, now mechanical harvesters (i.e. "fellerbunchers") need only 1 (one) worker to run these logging machines. Many of the roadside fuelbreaks, particularly on the eastside, would be logged by fellerbunchers. Local foresters admit that the pace and scale of logging mandated by S.1028 would exceed the current capacity of local falling and hauling contractors. This would require the agency to go outside the region and import contractors to get the cut out. There is no promise that after the five year period is over for this "pilot project," the program will be continued; thus, S.1028 appears to feed into yet another "boom and bust" cycle which has been the history of the timber industry throughout the West. After the logging capacity has been artificially inflated to fulfill the ambitious cutting goals set by S.1028, there may be pressure to continue the program for "economic stability" even if the environmental effects prove to be costly. The stability promised by S.1028 comes at a time when the region has already experienced and will continue to undergo economic change. Existing local businesses have learned to diversify their products and services, and the area continues to experience population growth. As the Sierra Nevada Ecosystem Project (SNEP) studies noted (e.g. Duane, Kusel), these newcomers are bringing human and financial capital with them, and are generating new employment opportunities in the region. The new immigrants are attracted to the area because of the recreational and scenic amenities provided by the region's natural environment---amenities that will be degraded by the scale of logging proposed by S.1028. Short-term stability should not come at the expense of long-term sustainability, and S.1028 favors one sector of the economy above all others, including southern California water users, dependent on a healthy forest ecosystem.


  While S-1028 specifies a five-year program, that is not intended to be the end of the process. It is a "pilot project" precisely because it is expected to teach lessons that will support an improved long term program. It is not feasible, even if some people might think it desirable, to go back to the days of 250-man sawmill crews. The new small-log mill at Quincy was installed because the owner foresaw that he either had to make lumber out of small "thin from below" trees or not make much lumber at all. Similarly, the use of feller-bunchers to harvest trees is here to stay, in large part because small logs can't be handled efficiently by the old fashioned methods. Ingalsbee's view on these matters is at best wishful thinking, but it sometimes borders on willful misrepresentation. Long term sustainability depends on employing these new mills and machines effectively to do the necessary fuel reduction and forest health work, not in refusing to see the necessity for doing that work or using those methods.


   The whole concept of "defensible" fuel profile zones continues the agency's adherence to the damaging practice of "fighting" forests to suppress fires. Ironically, each successful "battle" over blazes has only intensified the fury of subsequent fires in this never-ending, unwinnable "war" against Nature. The Forest Service now readily admits that aggressive firefighting has led to the kinds of forest health problems that S.1028 claims to be solving, yet it provides no alternative to the treadmill of mismanagement that annually wastes millions of tax dollars and priceless natural resources on firefighting spectacles. While S.1028 is based on the discredited fire suppression philosophy, tactics, and strategies of the past, it also stands in contradiction with recent revisions of fire management policies. The new Federal Wildland Fire Management Policies affect all land management agencies in the Departments of Interior and Agriculture. The interagency body that created the new policies admitted some vital truths: not all fires can or should be suppressed, and during large-scale, severe wildfire incidents, it is only a change in the weather that enables firefighters to "control" these kinds of fires. Among over 80 new fire management policies is the call to reeducate the general public and Forest Service employees about the ecological role and positive uses of fire. The new federal policies strongly advocate the use of prescribed fire from both natural and managed ignitions in order to promote forest ecosystem health, and to prevent the environmental, economic, and human costs of fire suppression.


  First, the QLG fuelbreak and fuel reduction strategy is precisely rooted in the need to provide an alternative to the continued increasing prevalence of "firefighting spectacles." This was explained in detail to Dr. Ingalsbee when he recently visited Quincy, so his continued misrepresentation of the QLG strategy cannot be inadvertent.

  Second, in QLG's view the Wildland Fire Management Policies do not give sufficient attention to the need for reducing fuel prior to the increased use of prescribed fire. In its extensive comments on the draft Interagency Fire Policy Review and on the final publication of the new policies, QLG documented the continued lack of attention to fuel treatments other than prescribed fire, and ended with the following:

"Eventually, in a decade or two, prescribed fire might prove adequate for maintaining safe fuel levels, but only after a very large amount of fuel reduction by other methods is done first. In QLG's view, you have tinkered around the edges and done some bureaucratic tune-up, but still failed to face, or refused to face, the central issue: How do you propose to reduce these excess fuels to an acceptable level? For now we must conclude that, having failed to face the most urgent questions squarely, your year-long exercise in policy-making is a net failure. Having received a hurricane warning, you appear to have decided that the appropriate response is to re-arrange some furniture and polish the doorknobs."

  In that sense, QLG agrees that its strategy is not fully consistent with the new Wildland Fire Management Policies, which is one good reason why QLG found it necessary to ask Congress to step in and mandate a pilot project to test whether an alternative to the Agencies' ineffective policies can ever be developed and implemented.


   Hazard fuels reduction is not a new idea in the Sierra Nevada: Lassen Volcanic and Sequoia-Kings Canyon National Parks have been doing this for over fifteen years. The National Park Service reduces hazard fuels through understory prescribed burning, using both natural and managed ignitions. The Forest Service, however, claims that it is too dangerous to do understory prescribed burning, and insists that it must do "mechanical treatment" instead. But how is it that the Park Service has not had to cut build roads or clearcut timber in order to reduce hazardous fuels? What does the Park Service know that the Forest Service must learn? If forest ecosystem health and community stability are the real issues and not just phony excuses for harmful new timber sales, then the Forest Service should follow the lead of the Park Service and implement careful use of prescribed burning, with the goal of restoring a natural fire regime across the landscape. Susan Husari, Deputy Director of Fire and Aviation in Region Five, revealed in her SNEP study that on Forest Service lands in the Sierra Nevada it costs $6,400 to suppress a one acre wildfire while it only costs $50 per acre to do prescribed underburning. With increased prescribed burning, the size, severity, and costs of future wildfires will decrease. If the intent of Congress is to seek the most environmentally-sound and cost-effective means to reduce the fuel hazard and fire risk, then the Forest Service should be instructed and fully funded to implement understory prescribed burning without commercial logging. The long-term goal should be full restoration of ecological processes, including fire. The fire scientists and fuels managers participating in the SNEP studies (e.g. Husari & McKelvey; van Wagtendonk; Sessions, Johnson, Sapsis, Bahro, & Gabriel; Weatherspoon & Skinner) universally voiced strong support for prescribed fire to manage hazard fuels and reduce wildfire risks. Dr. Jan van Wagtendonk said it clearest: "Prescribed burning appears to be the most effective treatment for reducing a fire's rate of spread, fireline intensity, flame length, and heat per unit area." Although some of the SNEP papers gave some tentative support to the creation of fuelbreaks, their analyses were based on the assumption that these fuelbreaks would be used as the initial staging grounds for conducting prescribed fires across the landscape rather than as permanent sites to contain and control wildfires. Furthermore, personal interviews with Skinner and Weatherspoon revealed that they believe fuelbreaks should be located on the upper third portions of slopes in areas that naturally have lighter fuel loads rather than plow them through dense timber stands on lower slopes, as S.1028 intends to do. The fuel hazards and fire risks of the Sierra Nevada are real, but the SNEP Report revealed the bitter truth that the Forest Service's logging, road-building, and firefighting policies of the past are what have created the forest health and wildfire problems of today. It defies logic and simple common sense to think that more logging, road-building, and firefighting will be the cure. S.1028 ignores the best fire science, undermines the new federal fire management policies, and runs contrary to the views of the Forest Service's own fire experts. It is time address real problems with real solutions and S. 1028 does not meet that test.


  It would be nice for all of us if a method as "cheap" and "effective" as prescribed fire were also "feasible." But the plain fact is that in current conditions it is not feasible in these National Forests to expand the use of prescribed fire to the level required for significant reduction of current fuel loads and the fire hazard associated with those fuel loads. In favorable circumstances, prescribed fire can accompany other forms of initial fuel treatment, but prescribed fire cannot substitute for initial fuel treatment by non-fire methods. The are many differences between National Parks and National Forests. Among these are: (a) the National Parks have not been subject to wholesale removal of the large overstory trees; (b) the National Parks don't have the accumulations of untreated activity fuels; and (c) both natural fire and prescribed fire have more often burned out the accumulations of natural fuels before they reach excessive levels. The National Parks may offer models for a desired future condition, but they do not represent the current conditions of National Forests, which is what we have to deal with.

  There are many differences between National Parks and National Forests. Among these are: (a) the National Parks have not been subject to wholesale removal of large overstory trees; (b) the National Parks don't have the accumulations of untreated activity fuels; and (c) both natural fire and prescribed fire have more often burned out the accumulations of natural fuels before they reach excessive levels. the National Parks may offer models for a desired future condition, but they do not represent the current conditions of National Forests, which is what we have to deal with.

  This continued harping on the supposed advantages of immediate large scale use of prescribed fire is part of the problem, not the solution. False hopes are comforting to those who refuse to face facts, and they give high level bureaucrats perfect excuses for inactivity, but they not only won't work, they get in the way of opportunities that would work. Let's get real, people. Recent levels of prescribed burning on the National Forests in the QLG area have not been sufficient to complete a cycle of fuel treatment in less than 150 years. Even that grossly inadequate level of fuel treatment by fire has strained the capacity of current Forest Service staffing, has exhausted the dwindling availability of experienced fire managers, and has fully occupied the short windows of weather that meet fire safety and air quality criteria. Even though it has stuck pretty much to the least hazardous areas while conducting prescribed burns, the system is maxed out. It is simply inconceivable that prescribed fire can be expanded enough to treat the accumulated fuel within anybody's definition of a reasonable time.

  It is not inconsistent of SNEP scientists to support prescribed fire as a long term goal while also seeing the necessity for reducing fuel loads first by other means. See the QLG comment above for quotations from Johnson, Sessions, Franklin, Weatherspoon, and Skinner.


Agee, J.K. (1996) "The Influence of Forest Structure on Fire Behavior," Proceedings, 17th Annual Forest Vegetation Management Conference, Redding CA

Davis, L.S. (1965) "The Economics of Wildfire Protection with Emphasis on Fuel-Break Systems," Calif. Division of Forestry, Sacramento CA

Deeming, J.E. (1990) "Effects of Prescribed Fire on Wildfire Occurrence and Severity," in Walstad, J.D. et.al. (eds.) Natural and Prescribed Fire in Pacific Northwest Forests, Corvallis OR

Duane, T.P. (1996) "Human Settlement, 1850-2040," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

Husari, S.J. and K.S. McKelvey (1996) "Fire-Management Policies and Programs," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

Kusel, J. (1996) "Well-Being in Forest-Dependent Communities, Part I: A New Approach," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

Sessions, J., Johnson, K.N., Sapsis, D., Bahro, B., and J.T. Gabriel (1996) "Methodology for Simulating Forest Growth, Fire Effects, Timber Harvest, and Watershed Disturbance under Different Management Regimes," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

Weatherspoon, C.P. and C.N. Skinner (1996) "Landscape-Level Strategies for Forest Fuel Management," Sierra Nevada Ecosystem Project, Vol. II, Davis CA

U.S. Dept. of Interior and Agriculture (1996) "Federal Wildland Fire Management Policy and Program Review Implementation Action Plan Report," National Interagency Fire Center, Boise ID

van Wagtendonk,.W. (1996) "Use of a Deterministic Fire Growth Model to Test Fuel Treatments," Sierra Nevada Ecosystem Project, Vol. II, Davis CA


Johnson, K. Norman; Sessions, John; Franklin, Jerry F. (1997) Initial Results from Simulation of Alternative Forest management Strategies for Two national Forests of the Sierra Nevada, Sierra Nevada Ecosystem Project Addendum, ch 6, pg 187.

Weatherspoon, C. Phillip; Weatherspoon, Carl N. (1997) Landscape-Level Strategies for Forest Fuel Management, Sierra Nevada Ecosystem Project Volume II, ch 56, pg 1480.

Ingalsbee paper distributed by :

Western Ancient Forest Campaign Campaign Coordinator 1025 Vermont Ave. NW 3rd Floor
Washington, D.C. 20005 202/879-3188 202/879-3189 fax wafcdc@igc.org
QLG Comments coordinated by:

George Terhune Box 98, Meadow Valley, CA 95956.
(916) 283-0899. fax 283-1876
e-mail: gjt@psln.com