Some Let It Burn Questions Answered

Correspondent Zeke asked some pertinent questions regarding the Oak Flat Fire [here].

Dear Zeke,

Thank you for your questions. Here are the answers:

1. This fire could indeed have been contained at 800 acres. On Aug 15 the fire grew from 600 to 800 acres. On that date there were already nearly 500 firefighting personnel on the scene, 8 helicopters, and air tankers standing by in Medford.

The area is not “wilderness” or roadless. It is well-roaded throughout. No additional dozer work was necessary to contain the fire. There have been no strong winds so far, thank goodness, or the fire would have swept into Grants Pass within hours. Allowing the fire to grow and grow for weeks on end runs the risk that winds will arise and the fire will become a major disaster, burning farms, homes, towns, and cities. The USFS has chosen to endanger tens of thousands of residents, none of whom had any say so in the matter. That increased risk is manifest right now and will be for weeks to come.

2. It was and is possible to SAFELY put this fire out by ‘going direct’ on it. Indirect attack is LESS SAFE. Right now the “plan” is to put 1,000 firefighters a day for weeks on this fire. That is 10 to 20 times the man-hours necessary to contain it. By expanding the man-hours enormously, the risk of accidents increases.

Most firefighting injuries and fatalities are not due to burning up. They are due to machine accidents and fireline accidents, such as helicopter crashes and falling trees. The chance that those kind of accidents will occur is INCREASED by extending the fire for weeks and by extending the fire perimeter 10-fold.

3. There are no “benefits” to resources from wildfire. The USFS does not claim such. The use of the term “wildland fire used for resource benefit” is kaput. You can read the memo [here].

It is important to note that the deliberate use of fire produces significant impacts to the environment. We have laws regarding federal agencies impacting the environment, such as NEPA. If you read that law, you will note that “benefit” or “detriment” do not matter. What matters is whether the impacts are “significant”. No one argues that fire effects are insignificant.

Yet the USFS did not follow the legally mandated NEPA process before deciding to expand this fire ten-fold. They broke the law. That makes them criminals. Nobody wants federal agencies to break the law. I don’t at any rate. Do you?

For more discussion on this aspect, see [here, here, here, here].

4. Instead of looking at Google Earth, you may wish to examine the forest road map. That will show you the existing road density of the area. The road network is extensive. No new roads are needed, or new dozer lines, to contain this fire.

5. 6. 7. So you think that they could have held it to this footprint? Have you ever fought fire in that country? Are you an expert on wildfire tactics? Yes, Yes, Yes.

8. Is anything about that ground worth killing a single firefighter? Hold on there, Zeke. I am not for killing anybody. As I discussed above, extending the fire in time and space INCREASES the risks to firefighters.

In 2008 over 650,000 acres were incinerated in Northern California on the Shasta-Trinity, Six Rivers, and Klamath National Forests. The fires were allowed to burn vast tracts in accord with a revised fire policy the USFS called “Appropriate Management Response” (since then the USFS has dropped that lingo term, too). Building firelines miles away from the fires and backburning hundreds of thousands of acres of private and public land alike were deemed “appropriate.” Despite the remote firefighting techniques, ostensibly intended to save money and protect firefighters, over $400 million was spent on suppression and 12 firefighters were killed.

In 2009 direct attack was used on a fire in the same area. The Backbone Fire [here] was 6,100 acres in steep un-roaded country when the decision was made to use direct attack. The fire was 100% contained within a week at 6,324 acres, with no accidents and no fatalities.

So you see, Zeke, extending this fire is far more likely to result in death to firefighters than direct attack would have. Perhaps you should aim your “killing firefighters” question at the USFS instead of at me.

9. What do you hope to accomplish with your rant? My purpose, indeed the purpose of W.I.S.E., is to educate. The “rant” characterization is impolite on your part, but whatever the literary quality, my post caught your attention. And now I am educating you further. Please read (study) the links provided. You have much to learn, and we are here to aid you in that.

Thank you again for your questions. Please feel free to ask us such good questions anytime.


Mike Dubrasich, Exec Dir W.I.S.E.

24 Aug 2010, 7:55pm
by Zeke

Thanks for a careful and thoughtful reply.
I am sorry that my first post was a little hot-headed.

I want to push back on a couple of points that you make here. I’ll number them to match your replies to my initial questions.

2. On the ‘longer fires = more chance for accidents’ - good point, but that doesn’t mean that aggressive direct firefighting is safer, or that the number of man-hours alone will predict the safety of an incident. There are many places where indirect tactics are the safest way to deal with a wildfire, and I don’t think that you should dismiss the use of indirect tactics out-of-hand, or write it off as a sneaky way to let a fire burn.

3. ‘There are no “benefits” to resources from wildfire.’ - This is an outrageous claim that flies in the face of millions of hours of direct experience accumulated by firefighters/practitioners over the last several million years - nuff said > go reread your Steven Pyne books.

4. Show me a road that would have allowed them to check the fire’s uphill spread (that it wasn’t already bumping when the fire was at 800 acres), and I will buy you a case of beer (or pop).

8. There were many differences between the NW California fires in 2008 and 2009. The 2008 fires started with a massive ignition event followed by smoke inversions that deprived us of most of our aerial resources for the better part of 6 weeks. We did not have enough crews to fight fire aggressively on many of the large backcountry fires, and many of these fires burned at low to moderate intensities under the inversions (achieving ‘resource benefits’).

Contrast that with the 2009 Backbone Fire that was the only large fire on the West Coast while it was burning. That fire had 27 Hot Shot crews on it (extraordinary), and the weather conditions cooperated, allowing them to go direct thru miles of snags in an old burn.

Going direct on the Backbone was not only very difficult - it required days of size-up, scouting, and logistics. It relied heavily on helicopters (flying those 540 Hot Shots and their overhead in and out). You might say that the only thing standing between a tragedy like the 2008 Iron Complex helicopter crash and the successful Backbone firefight was luck - the Backbone Fire also crashed a Type I helicopter, it just didn’t happen to be full of firefighters at the time. And there WERE accidents and a fatality - a crewman from the Chester Fly Crew died in a rappelling accident.

Firefighting is inherently dangerous, but sometimes we place our firefighters in unnecessary danger by choosing to suppress fires that should be allowed to burn or managed. As long as you deny (as a matter of principle) that fire can be an effective and appropriate land management tool, you place yourself on the side of full suppression, joining the ranks that ask us (firefighters) to take needless risks on your behalf. This could explain my hot-headedness about this topic

9. Ranting - I am guilty too, but also hope to educate.

25 Aug 2010, 10:05am
by Mike


If you want to manage forests (with catastrophic wildfire or otherwise), then you have to OBEY THE LAW.

I know this is a tough concept to drive home to non-professional foresters. Many ancillary types like firefighters and loggers, for instance, THINK they know how to manage forests.

“Just burn the holy crap out of it. That’s my prescription.”

Fine and dandy. You are free to have an opinion. But you are not free to break the law. What the law says is when a federal agency undertakes an action that may have significant impact to the environment, that action must be preceded by the NEPA process, i.e. preparation of an Environmental Impact Statement.

That’s the law. You may not like the law. It may cramp your desire to incinerate vast tracts of public and private forests. But the law is the law.

Do the crime, you do the time. Break the law, go to jail, do not pass go, do not collect $200.

The problem is firefighting has been utterly and completely disconnected from forest management. Firefighters not only cannot tell a fir tree from a pine tree, have zero local knowledge, do not know where the roads are, have no idea what the plan is for the forest in question, or the history of that forest, have never been to the area before, do not know a single soul in the area, have nothing at stake, do not care what happens to the forest or community — they are also completely ignorant of and/or dismissive of the LAW.

Firefighters break the law with impunity. You want to incinerate America’s forests, for all the “benefits” you claim incineration provides, but you don’t want to do it legally.

No thank you. As a paid government functionary, your job is dependent on the law. If the law doesn’t matter anymore, then you don’t get paid, either. It cuts both ways. We either have rule of law or we have anarchy, or tyranny.

You may think you know best how to treat my forest, by destroying it, but you may not do so illegally. That is arson, and we have laws, and the perps will eventually be caught, tried, and convicted. If you think firefighters are above the law, and don’t have to obey the law, then you are due for a rude awakening.

27 Aug 2010, 8:59pm
by Zeke

You did not address any of my rebuttals, and took the conversation into an unnecessary argument - I fully agree that Fire Plans for public lands should go through environmental review, and that firefighters should follow the law.

Back to the original discussion - I was at the Oak Flat Fire today and yesterday. I stand by my original claim that you are mistaken in your central assumption - that this fire could have been held at 800 acres. Also, regarding your claim that the area is well-roaded and that no new dozer lines are necessary, this is simply not the case. There are no roads with any tactical value (see bisecting the area that has burned since the fire was at 800 acres.


28 Aug 2010, 10:36am
by Mike


Your rebuttals? Okay, point by point:

1. You chose not to “rebut” my Point #1

2. I am not dismissing indirect attack out-of-hand. But in this case the decision was to expand the fire ten-fold and for weeks on end was not done for “safety” but for incineration purposes. As you note, “longer fires = more chance for accidents”. We are in agreement about that.

3. You cite “millions of firefighter hours” as “proof” that wildfires are “beneficial”. That’s an appeal to authority (or actually non-authority) and as such a logical fallacy. This fire in this place at this time is NOT beneficial, and no one to my knowledge claims it is. I recommend (again) that you read the Comments to the Rogue River-Siskiyou National Forest Regarding “Appropriate Management Response” from The Western Institute for Study of the Environment, Michael E. Dubrasich, Executive Director, Gregory J. Brenner Ph.D., Science Director, March 31, 2008 [here]. You will find a 170 pages and 450MB of cited studies in the Appendices that detail the myriad ways forest fires damage resources.

I also recommend that you read Objections to the Rogue River-Siskiyou National Forest Fire Use Amendment Environmental Assessment from The Western Institute for Study of the Environment, Michael E. Dubrasich, Executive Director, Gregory J. Brenner Ph.D., Science Director, November 24, 2009 [here] for further elucidation of the legal issues surrounding Let It Burn on the RR-SNF.

Since you mention Dr. Stephen J. Pyne, I recommend that you read Friendly Fire, his essay regarding the Warm Fire, a Let It Burn fiasco on the Kaibab NF in 2007 [here].

“If I were the Prince of Darkness, I could not have devised a better way to destroy the Kaibab Plateau.”

Wally Covington, professor, restoration ecologist, and a man who has been around burned woods all of his career, walked through the still-raw scar of a fire that had wiped out nine nesting reserves for the northern goshawk, shut down the only roads to the plateau, including one to Grand Canyon’s North Rim, threatened a substantial chunk of the remaining habitat of the flammulated owl and endemic Kaibab squirrel, may cause a quarter of the old-growth ponderosa pine to die, promoted gully-washing erosion, and rang up suppression costs of $7 million. …

Wally Covington thought it testified to ideology gone mad, and had the temerity to say so and the clout to be heard.

4. “Show me a road…” This fire occurs within a legal context related to the RR_SNF Fire Use Amendment which has NOT been legally adopted to-date. The above linked Comments and Objections should give you some idea of what that legal context entails. Because of the legal issues involved, the Oak Flat Fire is going to receive a thorough public review after the fact. All the possible roads that could have been used, all the decisions made, and all the documents and plans created and relied upon will be examined in detail. This fire is not going to go away. It is going to haunt the perpetrators for the rest of their careers.

5. 6. 7. 1. You chose not to “rebut” my Points #5, 6, and 7.

8. You say the Let It Burn fires in NorCal in 2008 were due to inadequate resources on the date of ignition. However, those fires burned for three solid months during which there were plenty of periods when ample resources were available. At no time during the Oak Flat Fire were resources in short supply. Air tankers sat idle on the tarmac for two weeks until day before yesterday. Again, the fire suppression (and non-suppression) decisions made will be thoroughly reviewed, by the public, in the aftermath of this fire. It make take repeated FOIA requests and exposure of the documents obtained, but all that is necessary to reveal the “strategy” employed is going to happen.

You are welcome to begin to build a legal defense for the Federal Government in this matter if you wish to. Your efforts in that regard may or may not be helpful to them as the public inquiry progresses. I suspect not. In any case, burning America’s forests with impunity and impudence is not going to slide by this observer unchallenged.

28 Aug 2010, 6:09pm
by Zeke

1, 4, and 5. “This fire occurs within a legal context related to the RR-SNF Fire Use Amendment” - Inconsequential. Tell me a good story about how they were going to safely put people in there to get your fire put out at 800 acres

2. “the decision was to expand the fire ten-fold and for weeks on end was not done for ’safety’ but for incineration purposes” - opinion or stated fact? Source?

3. Fire plays and ecological role in any ecosystem that has evovled with it. Take away fire, and you are causing an environmental impact. Am I asking you to do NEPA every time we SUPPRESS a fire? No.

Regarding Pyne - I didn’t invoke his name in defense of a failing fire use program, I invoked his name in defense of the ecological benefits of fire.

6,7. I do not know you, and I will never call you a liar.

8. This is a different discussion, worthy of its own books, threads, and stories. I am interested in talking about it too, but I think that it clouds the main point of the original article, which is about why Oak Flat didn’t get put out at 800 acres.

I am glad that you are pushing for the feds to develop a solid legal framework for fire management decision making. Firefighters deserve a clear mission, and some legal protection when they make tough tactical and land management decisions.

28 Aug 2010, 10:22pm
by Mike


You are starting to get it.

The legal context is NOT inconsequential. Obviously. The law must be obeyed.

The decision to expand the Oak Flat Fire was made to “meet objectives” including deliberate alteration of the environment. The documentation will show that clearly, in the WFDSS and the Regional Forester’s Review of the Long Term Plan. The placement of the indirect lines miles away from the fire, the choices of suppression tools to use or not use, the verbiage in the “strategy”, etc. are evidence that more than “suppression” was part of the plan.

The current RR-SNF LRMP amd FMP are NEPA-approved documents. They provide direction for suppressing fires. They do not, at this time, provide direction for “using” wildfires. But the RR-SNF said they were going to “use” wildfire. They titled their proposal “Fire Use Amendment”. They described the environmental “benefits”, such as “recycling the forest”, that they intend to achieve by “using” wildfire, by “allowing wildfires to burn”, by deliberate non-suppression actions on wildfires.

And now they have gone and done what they said they were going to do. And not for the first time, either. But they have jumped the gun (again). The RR-SNF Fire Use Amendment has not been adopted yet. It is quite controversial. Until the new amendment is adopted (and it may never be), the existing directives must be followed. That’s the law.

Firefighting is not exempted from NEPA. Witness the NEPA lawsuits over fire retardant. Nothing the USFS does is exempted from NEPA — not healthy forest thinnings, not other vegetation treatments, not prescribed fires, and not “fire use”. The Fire Use Manual in the Preface admonishes practitioners to obey NEPA.

Now, many (myself among them) aver that NEPA, ESA, CWA, CAA, and other Federal environmental laws are badly flawed. They are causing more harm than good in numerous cases. But that does not mean the USFS can pick and choose which flawed laws to obey and which to ignore. They do not have that authority. They must obey all the laws, flawed or otherwise, for good or ill.

PS - Steve Pyne is not an ecologist or a forester; he is a historian. He’d be the first to tell you that. And please recall, NEPA does not distinguish between alleged “beneficial” actions and “detrimental” actions. The key word is “significant”.

PPS - if you read the material I have linked to, you will get a much more detailed and nuanced discussion of these concepts.

29 Aug 2010, 2:35pm
by YPmule

We have seen some pretty crazy stuff, like fire “fighters” setting off backburns on red-flag days, and those fires blow up and make the main fire worse. Example the Knox Ranch Fire Camp burnover [here] was a backfire set by another fire crew. It put hundreds of firefighters and support crew in danger!

29 Aug 2010, 6:12pm
by Foo Furb


In Zeke’s defense, he has been pretty consistent about your claim that the fire could have been contained at 800 acres. Where (and why) does this claim originate? He has also been more specific about road locations. Do maps exist of roads that would substantiate your claims that additional firebreaks were not (initially) needed?

Also, for his personal edification: suppressing atypical fire (such as the types now occurring), should NOT require NEPA at all. These events are largely unprecedented, and for the many reasons stated clearly and often in your postings. As such, suppression actions should clearly not require the NEPA process.

29 Aug 2010, 11:25pm
by Mike


The Grants Pass Courier reported on 8/17 that ORCA (Oregon California IMT) intended to burn 12,000 acres, as revealed at the community meeting. ORCA had been on the fire for two days at that point, coming on when the fire was 600 acres.

But they had decided from the get-go to make the fire big. That’s what ORCA did with the Williams Creek [here] and the Rattle Fires [here] on the Umpqua NF in 2009, and the Blue 2 and Siskiyou Complex Fires [here] on the Klamath NF in 2008. It’s their modus operandi. Drop back miles from the fire and backburn.

I didn’t believe the GP Courier story, until I saw the fire map on InciWeb two days later and read about the Regional Forester’s review and approval (with the proviso that ORCA try to minimize tree mortality and protect spotted owl habitat).

The Horse Mountain Fire [here] in 2008 was a mile to the south of Briggs Creek (site of the the Oak Flat Fire). Same terrain and fuels. The Horse Mountain Fire was attacked indirectly, with backburning, and held to 1,062 acres. There is no reason to drop back 4 or 5 miles to do backburning. A half mile is plenty. Five miles is arson.

How do they minimize tree mortality and protect spotted owl habitat when they torch things off five miles away from the fire?

I just happen to have the Forest Road maps because I’ve done work down there. Of course they exist.

Nothing is “proved” yet. There will be a public review — of, by, and for the public — and all the pertinent documents (and maps) will be obtained and examined closely. There will be a cost-plus-loss appraisal using the U.S. Wildfire Cost-Plus-Loss Economics Project “One-Pager” Checklist [here]. Then we shall see what charges and claims are justified.

My purpose was to inform ORCA and the RR-SNF that the public review will be made, so that they might avoid doing anything particularly stupid. I had hoped that they would keep the fire small just to spite me, but no such luck. Maybe my saber-rattling caught their attention; maybe it didn’t. Maybe I saved Grants Pass from incineration just by letting ORCA and the RR-SNF know I am watching them closely. We have had some interaction, the RR-SNF and I. They know I am a serious customer.

There are some other Oregon fires I intend to investigate. The Mt Hood NF is torching the Bull of the Woods Wilderness right now [here]. The enviro nazi lobby had Congress set-aside old-growth spotted owl habitat as “wilderness”, and now the USFS is incinerating it sans any suppression effort. The Willamette NF is doing Let It Burn with the Scott Mountain Fire [here].

I don’t dig that, man. I have asked them nicely to please stop incinerating my forests, but they don’t listen or care. My opinion, which is local, expert, and firmly expressed, does not matter to them.

I’m not letting it slide, though. You don’t wreck my forests and walk away whistling. There will be a inquisition, I promise.

30 Aug 2010, 12:13am
by Foo Furb

Thanks, Mike.

1 Sep 2010, 9:54am
by Mike

Situation as of 08/31/2010 6:00 pm
Personnel: 737
Size: 6,515 acres
Percent Contained: 70%

Costs to Date: $14,564,245

Currently building line and preparing for burning out. Likelihood of burnout increases due to increase of favorable weather conditions. Burnout in Division D, H and F as the weather permits.

And they are still backburning!!!

The fire is out, there is zero danger from standing next to it, but the Liers That Be are still backburning from miles away in the name of safety!!!!!

What is safe about arson????

What is economic about spending $2,000 per acre to destroy resources worth $20,000 per acre????



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