P. O. Box 1749, Quincy CA 95971

January 26, 1995

Federal Wildfire Policy Review
Department of Interior
18th and C Streets
Mail Stop 7355
Washington, DC 20240

The Quincy Library Group represents diverse viewpoints among organizations and individuals in an area of northeast California largely covered by the Lassen NF, the Plumas NF, and the Sierraville RD of the Tahoe NF. The Group has reached consensus agreement on forest health issues that were previously the basis for ongoing disputes.

The QLG Community Stability Proposal is aimed at short-term survival (a five year program) while long-term plans are developed, and to assure adequate environmental protection during that period. With ongoing discussions and refinement of our proposal, we have become acutely sensitive to the high and rising threat of catastrophic wildfire. We believe we have identified the necessary elements of a strategy to meet that threat, and want to recommend it to you as a model for larger scale strategy.

The QLG Strategy for Reducing the Probability of Catastrophic Wildfire

1. It should have significant effect in four years.

2. It's essence is "divide and conquer" by means of a network of defensible fuel breaks.

To have significant effect within four years, we specify that 1/32 of the forest area should be treated each year in strips of approximately quarter-mile width, each strip including an existing road where possible. Within that quarter mile width the prescription would generally thin from below, reduce surface fuels, and break up the fire ladders, so as to slow the propagation of low intensity fires, tend to bring high intensity fires to the ground, and reduce the intensity of most fires, while providing fast access and a prepared defense line for efficient fire fighting. The resulting strips would look very little if any different from the "pre-settlement" forest that is widely accepted as a reasonable "desired future condition" for the whole forest.

The result in four years would be a network of defensible fuel breaks that sub-divide the forest down to areas of 10 to 15 thousand acres each, approximating the scale of many watersheds and isolated urban areas.

Treating 1/32 of the forest each year would require very high priority, but is feasible. Existing capacity for logging and trucking can move the required volume of material, and in peak years the Forest Service has processed more than the required acreage in local forests through fuels treatment and timber sales.

After four years, QLG proposes a gradual shift away from such tight focus on the fuels problem and toward our QLG Community Stability Proposal. This proposal provides for a silvicultural system that should reduce the need for fuelbreaks and likely prevent the recreation of this current catastrophic risk.

The Role of Fire in Natural Resource Management

The long-term goal of the QLG fuelbreak strategy is to permit re-introduction of low intensity wildfire into ecosystem management. We don't expect fire to resume completely its pre-settlement role, but we do believe there are essential functions that low intensity fire must perform or would most efficiently perform, and that the eventual forest must be tolerant of high intensity fires of limited size. A strategy initiated through fuel breaks is the only option we see that has a reasonable chance of meeting these objectives. We admit that large areas of forest will inevitably burn during initiation of this strategy; but much larger areas will burn during implementation of any other feasible strategy we have seen or can imagine.

Wildland Fire Protection and Preparedness

Conventional suppression strategies are on the verge of a breakdown. An attempt to meet the problem by adding suppression capacity is in the long run doomed. A protection strategy based on adding defensible fuelbreaks is more appropriate, because it would be the most efficient attack on excess fuel and non-adapted vegetation, which are the root causes of major forest health problems and catastrophic wildfire.

Use of Prescribed Fire and Other Fuel Treatments

We believe prescribed fire eventually has a large role to play, but in our forests almost all of it should come after a round of "other fuel treatments", not before. The arithmetic of our current situation is obvious: the yearly amount of fuel treatment that needs to be done is a large multiple of the most that has ever been done here by prescribed burning; expertise is in short supply and the risk of escape is very high; and current public opinion and air quality regulations are not amenable to large scale prescribed burning. Immediate large scale use of prescribed fire is not feasible.

Unfortunately, the Forest Service has exhibited and continues to exhibit a bias in favor of prescribed fire, and this bias is a barrier to adoption of the best strategy in our area and in much of the inland west. This bias showed strongly in the Fire & Aviation Management staffing paper "Fire Related Strategies and Considerations in Support of Ecosystem Management" (USFS 1993). A more balance view has gradually emerged in follow-on papers, and in the Western Forests Health Initiative; but the bias is still apparent, so you need to spell out in detail the available methods of fuel treatment and their appropriate sequencing, not just lump everything together in the usual phrase "prescribed fire and other fuel treatments".

Roles of Each Federal, State, Local and Private Organization at the Wildland/Urban Interface

One of the highest priority locations for a fuel break is at the wildland/urban interface. A strategic plan and supporting organization already exists for efficient coordination of various governments and private fire fighting capabilities. A similarly effective strategy and cooperative effort is needed to establish fuelbreaks related to the wildland/urban interface.

QLG participates with the Federal agencies (USFS, NPS, BLM and NRCS) in California Fire Strategies Committee. This is one potential venue for developing a fuelbreak strategy for the urban interface. However, we think the Committee has not given tight enough strategic focus to its deliberations. So far its output has been too much "wish list" and not enough "strategic priority". Federal representatives have made suggestions (e.g. USFS R5 letter of Oct 28, 1994, File 5100/3100), but it would be useful to have Federal members push even harder for a real strategic plan that focuses on fuel.

The QLG Strategy and the Western Forest Health Initiative

The most encouraging thing about WFHI is that it states explicit priorities. Because projects are so large, and potential resources severely limited, a clear implication is that PRIORITY ONE projects should be the focus of all effort for at least the first several years. Nevertheless, if we can significantly "reduce the hazard of catastrophic loss of key ecosystem, structure, composition, and processes", we will have done more than most of us think possible.

WFHI identifies fire and infestation as the two most significant immediate hazards of catastrophic loss at the watershed and landscape scales. Those hazards are dominated by two enabling factors: fuel buildup and the invasion of unadapted vegetation into fire-adapted landscapes.

If treatment is attempted in the typical pattern of conventional timber and biomass sales, then for decades there will still be connected untreated areas that are large enough to support catastrophic fires and epidemic spread of pests and disease. Therefore, in the near term (up to a decade), all treatments, both natural fuels and thinnings based on timber and biomass sales, must be focused on a strategic pattern of protection, not scattered among areas chosen by other priorities.

In the QLG area there has never been enough natural fuels treatment to cover even a fraction of the current rate of fuel accretion each year, but in many years approximately enough area has been processed by logging and other treatment. A key requirement is to have the logging done in a fuels strategy pattern according to a fuels reduction specification.

Once the forest has a strategic network of fuel breaks in place, it will be safer to reintroduce prescribed burning, to supplement and in some places gradually replace the mechanical treatments that will be required initially.

WFHI Example Projects

We note that four of the seven example projects featured in the expanded WFHI writeups center on recovery or restoration from large intense fires, and these four projects apparently absorb money and cover acreage very much above the average of other forest health activities. We aren't persuaded it is an "initiative", much less a "forest health initiative", as long as the majority of current and prospective efforts must go into hugely expensive mop-ups. If the responsible Federal officials want to be known as "health worker" instead of "morticians", they will have to produce a strategy that is capable of rather quickly turning the current trends around, and doing it largely by re-allocation of existing budget and available resources, not dependence on new money.

In summary, we believe that:

-- The key to success for the WFHI is to produce the nationwide forest health strategy the paper itself calls for.

-- The WFHI strategy needed for the inland west is one that will specify as its first priority and primary focus an efficient pattern for treating the overload of fuel.

-- Producing that strategy would be the best possible outcome of the Wildfire Policy Review.

If you are assembling a list of interested parties who will be sent materials regarding further actions, outputs, and opportunities to comment on the Fire Policy Review, please add QLG to that distribution.


/s/ Edward C. Murphy
Corresponding Secretary, Quincy Library Group