SOS Forests

Kimbell Axes Fire Planning

On April 2nd USFS Chief Abigail Kimbell decided that four Region 3 National Forests no longer needed Fire Management Plans (FMP’s) as part of their Land and Resource Management Plans (LCMP’s). As a result, the existing FMP’s on the Carson and Lincoln NF’s in New Mexico and the Apache-Sitgreaves and Tonto NF’s in Arizona were thrown in the dumpster.

Kimbell axed the FMP’s because an environmental group, the WildEarth Guardians (formerly the Forest Guardians), had sued the Forest Service in December, claiming the agency’s FMP’s for the four forests were inadequate because they were produced without any NEPA process (i.e. no Environmental Analyses or Environmental Impact Statements were created).

From the WildEarth Guardians’ Complaint for Declaratory and Injunctive Relief [here]:

61. The Apache-Sitgreaves, Tonto, Carson, and Lincoln National Forests did not solicit public input and did not prepare an EA or EIS before preparing and approving their FMPs. Consequently, the public had no opportunity to comment on the fire management practices required by the FMPs, and the Forest Service did not analyze alternatives to the FMPs.

Rather than comply with NEPA, Kimbell junked the FMP’s, and the next week the USFS requested the lawsuit be dropped. From the Las Cruses Sun-News [here]:

Forest Service seeks dismissal of fire plan lawsuit

By SUSAN MONTOYA BRYAN, Las Cruses Sun-News, 04/10/2008

ALBUQUERQUE, N.M.—The U.S. Forest Service is seeking dismissal of a federal lawsuit filed by environmentalists who had challenged the agency’s fire management plans for four Southwestern forests.

Forest Guardians, now called WildEarth Guardians, had sued the Forest Service in December, claiming the agency’s plans for the Carson and Lincoln forests in New Mexico and the Apache-Sitgreaves and Tonto forests in Arizona were inadequate and produced without enough public involvement.

The Forest Service, in a motion filed Thursday, argued that the lawsuit should be declared moot since the agency withdrew the fire plans last week.

“As a result, the purported decisions that are the basis for plaintiff’s claims are no longer in effect, such that there is no continuing case or controversy to support jurisdiction,” the agency’s lawyers wrote in the two-page motion.

Court documents also show that Forest Service Chief Abigail Kimbell on Wednesday waived a requirement that the four forests have fire management plans. …

On March 5th the Rogue River-Siskiyou NF issued a notice that they were going to prepare an EA to include Let It Burn fires in their FMP [here]. The Western Institute for Study of the Environment prepared a 170 page complaint requesting that the RR-SNF prepare an EIS before they adopted Let It Burn into their FMP [here].

Now it seems that the Chief of the USFS can merely dump the RR-SNF FMP altogether, rather than obey the law. This type of criminal behavior on Kimbell’s part has also been pointed out and documented many times at SOS Forests [here, for instance].

The USFS has devolved into a lawless outfit that spurns NEPA, ESA, NFMA, NHPA and other laws of the United States in their quest to incinerate America’s priceless heritage forests. The level of abuse and dismissal of the rule of law by this federal agency is appalling and bodes catastrophic disaster. Something must be done and soon.

Stubbing Their Tahoe Again

The Burn It Down contingent at Lake Tahoe are up to their old tricks again. Some authoritarian thugs never learn. The latest eco-nazi eruption at the Sierran lake was featured in the Sac Bee last week [here]:

Lake Tahoe resident could face prison over tree removal

By Todd Milbourn - Sack-a-tomatoes Bee, April 9, 2008

Environmental cops at Lake Tahoe say Patricia Vincent deserves a prison sentence and a huge fine.

Her alleged crime: chopping down three trees on federal land that improved her backyard view of the lake.

The enviro cops in question are functionaries of the Tahoe Regional Planning Agency, recently lambasted by the emergency California-Nevada Tahoe Basin Fire Commission [here] for creating the fire hazard that led to the Angora Fire (which incinerated 3,100 acres of public forest and 254 private homes, and caused an estimated $140 million in damages) last June.

Vincent says it was an honest mistake, but now she’s believed to be the first target of criminal charges of illegally cutting Tahoe trees.

It’s the clearest signal yet of how serious coniferous crime has become as regulators fight to preserve the Sierra Nevada jewel Mark Twain once deemed “the finest view the world affords.”

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Theory, Empiricism, Forests, and Global Warming Models

A popular statement, usually attributed to George Box, is that “all models are wrong, but some are useful.” The usefulness of models fall into two broad classes: theory and prediction. Theoretical models attempt to map known physical, chemical, and biological relationships. Predictive models (sometimes called “black box”) attempt to make accurate predictions.

There is a strong tendency to confuse or combine these utilities, and that is true in any modeling (my specialty is forest growth and yield models). Proponents of theoretical models are often adamant that their models are best (a value judgment) and insist that they be used in predictive situations. Predictive modelers, in contrast, may use crude rules of thumb that are unattractive to theoreticians, but predictive modelers emphasize that their goal is accurate prediction.

Hence Box’s assertion that models are wrong must also be bifurcated. Theoretical models are wrong if the theories behind them are invalid. Predictive models are wrong if they make poor predictions. It is easy (but not useful) to confuse these wrong-itudes.

Predictive models are generally empirical, that is, data-driven. Predictions are validated (or invalidated) by the data on actual outcomes. Theoretical models are validated (or invalidated) by tests of theory, which may or may not be empirical. Experiments (empiricism) are used to test theories, but theoretical models do not rest on predicted outcomes because theoretical models are not predictive by design.

The best weather prediction models are more empirical than theoretical. They look at current conditions (fronts, pressure gradients, jet streams, etc.) as they are cadastrally arrayed across the globe, and compare those to past dates when the same or very similar arrays occurred. Then the weather outcomes of the similar past conformations are examined, and used to predict the immediate future weather. Not much theory to that, more of a data mining of the past; hence the descriptor “empirical.”
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Paul Driessen on Eco-Imperialism

Paul Driessen is the author of Eco-Imperialism: Green Power. Black Death. and a website of the same name [here].

Some reviews of his book [here]:

“The environmental movement I helped found has lost its objectivity, morality and humanity. The pain and suffering it is inflicting on families in developing countries must no longer be tolerated. This is the first book I’ve seen that tells the truth and lays it on the line. It’s a must-read for anyone who cares about people, progress and our planet.” – Patrick Moore, Greenpeace co-founder

“Developing countries need to be free to make their own decisions about how to improve their people’s lives. Activists who’ve never had to worry about starvation, malaria and simple survival have no right to impose their fears, prejudices and ideologies on the world’s poor. That’s the central message of this book. It’s a message that needs to be spread far and wide.” – CS Prakash, Professor of plant genetics, Tuskegee University

“There is a shrill claim today by those that fill the streets to protest globalization, and by the organizations that put them there, that these white, relatively affluent groups are speaking on behalf of the world’s poor and powerless. This unfortunately, is a message that the Western media have bought uncritically – but not Paul Driessen. He cogently shows how the new Green Eco-Imperialists are seeking to impose their will on developing countries, interfering with their efforts to build dams or grow crops or do any of the things which can lift them out of poverty. These are life-and-death matters for the world’s poor, and Driessen is bold and honest enough to challenge the eco-interference in people’s lives as immoral and the cause of death and devastation in countries that are trying to develop and transform their lives. Both those who have bought the Green propaganda line and those who have not would benefit from reading Driessen’s Eco-Imperialism book.” – Thomas R. DeGregori, PhD, Professor of Economics, University of Houston

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The Monument, the Mill, and the Enviros

by Lee Belau, retired Fire Management Officer for the Sequoia National Forest

On his way out of the door in April of 2000, President Bill Clinton gave local environmentalists a gift that they had been unable to get through normal legislative action after numerous attempts. He signed a Presidential Proclamation creating the 327,769 acre Giant Sequoia National Monument.

There was no opportunity for public comments prior to this decision. There was no environmental analysis or development of alternatives. No study of the possible effects to the local economy was done. The “spin” was that a monument was necessary to save the Giant Sequoia trees from the evil loggers. We were told not to worry, because the out-of-work folks in the wood products industry would be retrained so that they could benefit from jobs in the new recreation-related business boom that the Monument would generate.

The Proclamation mandated that the Forest Service write a management plan with the guidance of a Scientific Advisory Board to be selected by the National Academy of Science. The Board was appointed and the plan-writing job began. Early in the process, the Board agreed that all of their recommendations to the Forest Supervisor would be by unanimous consent. For the next nearly four years, the Board held meetings that were open to the public. They listened to public comments, and took field trips to the forest, the National Park, the Tule River Indian Reservation and to Mt. Home State Forest to view giant sequoia stands and various management practices. In January of 2004, the final plan was signed.

Today, more than seven years after the Monument was proclaimed, virtually nothing that would enhance the protection, improvement or management of the Monument and the Giant Sequoia trees has been accomplished. This is because those same people who promoted the establishment, agreed to the proclamation language, and dictated the planning process, sent their attorneys to court and got the plan declared invalid. Additionally, in spite of Proclamation language that clearly states that timber sales under contract as of the date of the signing (4/2000) could be completed consistent with the terms of the contract, four sale projects were included in the Monument Plan lawsuit and similarly stopped.
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WFLC Stages Bloodless Coup — America To Be Incinerated

On March 24th the Wildland Fire Leadership Council (WFLC) held a conference call meeting in which they adopted new “anything goes” rules for Let It Burn fires.

The WFLC is the Federal Advisory Committee that oversees firefighting on Federal land, including USFS, BLM, NPS, USFWS, and BIA [here]. The March 24 meeting notes are [here].

Five unanimous decisions were made during the conference call meeting. First, any fire can be a suppression fire and a whoofoo at the same time. The fire can be suppressed over here and let burn over there.

Wildland Fire Leadership Council Meeting — Conference Call Notes, March 24, 2008

Actions and Decisions

TOPIC: Modifying Guidance for Implementation of Federal Wildland Fire Policy (AMR)

1. Current Direction: Only one management objective will be applied to a wildland fire. Wildland fires will either be managed for resource benefits or suppressed. A wildland fire cannot be managed for both objectives concurrently. If two wildland fires converge, they will be managed as a single wildland fire.

Proposed Direction: Wildland fires can be managed for one or more objective(s) based on the Land/Resource Management Plan direction.

DECISION: No objections – the WFLC approved new direction unanimously.

The new direction means the fire managers can be flexible about where they suppress and where they don’t. This is tantamount to a half-assed approach. The only criteria is that they have a policy known as “Appropriate Management Response” or AMR in their Land and Resource Management Plan (LRMP). This is one of the purposes of the change in the Rogue River-Siskiyou NF LRMP proposed March 5th [here] and commented upon by W.I.S.E. [here]

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Some Brief Comments on the RRSNF’s AMR Proposal

by Dave Skinner, Hydra Project, Whitefish MT

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

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

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

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

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

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

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

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

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

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

*PRESS RELEASE*

LOCAL GROUP CHALLENGES NEW NATIONAL FOREST LET IT BURN PROGRAM

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

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

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

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

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

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

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

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

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

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

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

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