Testimony Submitted for the Record to the House Agriculture Subcommittee on Conservation and Forestry on behalf of the Federal Forest Resource Coalition
The 2020 Fire Season Should be the Watershed Moment for Federal Forest Management
September 24, 2020
The wildfires that came in the late summer of the 2020 Fire Season have created unprecedented challenges for our public and private forest landowners. Yet these fires are just the latest in a series of catastrophic fire seasons over the last decade. The Wallow Fire in Arizona in 2011 scorched over half a million acres mostly on the Apache National Forest, burning stands of Ponderosa pine in a stand replacing fire because of overly dense conditions. The King Fire of 2014 was one of many serious and fast-moving fires that summer which burned across Federal forests and on to private lands. The summer of 2017 saw a season-long fire siege in Montana and Idaho that stretched until the fall rains arrived, while the Chetco Bar fire blew up late in the season and devastated parts of Oregon.
The fire storms of early September 2020 have more than eclipsed these traumatic experiences. In Oregon alone, about 800,000 acres of forests – about half of which is Federal lands – has burned in the last several weeks. These fires consumed forests at all stages of development, although they largely began during a wind event that brought down powerlines, mostly on Federal lands. In California, about 3 percent of the land area of the State burned this year, and five of the ten largest fires in State history were burning at one time in September. Three Forests in particular, the Mendocino, the Plumas, and the Sierra, have been impacted. While the final fire perimeters will take some time to establish, it appears that most of the Mendocino has been burned in high intensity fire. The Sierra National Forest, which had experienced a large-scale forest mortality event in recent years, saw the majority of the acres impacted by that event destroyed in the Creek Fire, which is still burning and is expected to burn until Halloween. The North Complex on the Plumas is approaching 300,000 acres and containment isn’t expected till mid-November.
We’re already aware of two fires – including the Creek Fire on the Sierra National Forest and the White River on the Mount Hood National Forest– that destroyed areas where the Forest Service had attempted to reduce hazardous fuel loads but were stymied because of red tape or litigation. The Crystal Clear Restoration Project on the Mount Hood, which sought to reduce fuels on about 11,000 acres, was the subject of nearly 4 years of analysis and litigation, which led to the Forest Service publishing over 1,900 pages of analysis on this relatively minor project. This analysis concluded that “if a fire were to move through the area without reducing fuels, it would likely be more severe.” A portion of the project area burned in intense fire conditions during the White River fire. The project had been sent back to the Forest Service for additional analysis by a misguided decision from the Ninth Circuit Court of Appeals.
On the Sierra, the Musick Fuels Reduction project moved relatively quickly through the analysis process, but the Creek Fire began 2 years almost to the day from the initial scoping effort for the project. The entire project area was destroyed in this highly predictable fire.
The story of this September’s Oregon and California fires has been repeated across the National Forest System, as noted in Arizona, Colorado, Montana, and elsewhere. Millions of acres have burned, frequently in uncharacteristically hot, stand-replacing fires. Some of these events have been primarily wind driven, others have been big and hot enough to generate their own weather. We have no doubt that both a warming and drying climate and the generally overstocked conditions on our National Forests have contributed to both the extent and intensity of recent blazes. The conditions on California’s National Forests are emblematic of this problem.
According to Forest Inventory Data and research conducted by Dr. Malcolm North of the Forest Service’s Pacific Southwest Research station, by 2015, California’s National Forests were carrying an average of over 320 conifer trees per acre. Historically, these forests supported less than one fifth of that number, about 64 trees per acre. These less dense forests in California were historically able to survive multiple disturbances, including wind, fire, and insect outbreaks. As we’ve seen dramatically in the last several years, our current, overstocked forests cannot.
This basic pattern repeats itself across of much of the National Forest System. Forests which typically had frequent fires are overstocked, full of suppressed trees that help create intense fires they cannot survive. Forest types adapted to higher intensity fires lack age class diversity, meaning that fires which would have burned in a mosaic of intensities instead scorch entire watersheds and destroy wildlife habitat. Together, they create a dangerous setting in which we ask our firefighters to risk their lives, and which threatens entire communities with obliteration.
We appreciate the opportunity to submit this testimony, and provide comments in two major areas, first, the immediate response required to begin restoring these forests so they can once again sequester carbon and begin to reestablish wildlife habitat and future timber supplies, and second, taking steps to make it easier to manage acres on the National Forest that are not in restricted land uses such as Wilderness and inventoried roadless areas.
Immediate Response: Focus on restoring access for forest management, prioritizing reforestation, converting NEPA ready projects to salvage:
While we are still sorting through the results from this fire season, it’s clear that there are several main tasks which will require immediate action and – it seems likely – a significant investment of additional resources: restoring access, prioritizing reforestation, and allowing NEPA ready projects to go forward without delay.
Damage to timber along both state highways and Forest Service roads will severely restrict access to these forests if immediate action is not taken to remove hazard trees and restore damaged infrastructure. Failure to quickly remove hazard trees will only increase future fire danger by restricting access for firefighters and egress for homeowners, residents, and recreationists.
Congress should immediately authorize the Forest Service and Bureau of Land Management to conduct roadside hazard tree removal out to 200 feet on either side of roads impacted by wildfires in the last 2 years. Existing administrative authorities for such removal are limited, and if experience is any guide, in many areas, the Forest Service will opt to close roads indefinitely unless they receive relief from administrative review and adequate funding to complete this task.
We also believe that a significant contributing factor to increased fire activity in the west is decreasing road access to our federal lands. This factor is often overshadowed by both climate change and fuels accumulation when the topic of wildfire is discussed in public forums. However, we believe that the deteriorating road infrastructure on our National Forests has also significantly contributed to recent spikes in wildfires. This deterioration has been a result of both reduced funding for road maintenance and the federal agency’s subsequent direction to reduce their overall road networks to through road decommissioning. The outcome is a forested landscape that is increasingly inaccessible to fire suppression agencies, delaying direct attack on nascent fires. Reversing this trend is vital to effective initial attack, as well as providing safe evacuation routes for impacted communities.
Second, the Forest Service should prioritize salvage and reforestation of as many acres as possible. In many places, salvage logging can help take some of the standing dead trees off the landscape. Using these trees for lumber will lock up carbon in long-lasting wood products while creating better growing conditions for the next stand of trees, which will sequester more carbon. The Forest Service should be able to remove hazard trees and take aggressive steps towards reforestation on non-reserved (i.e. – not Wilderness or Inventoried Roadless Areas) acres without further environmental review. The Forest Service should consider using aerial seeding techniques on high-cost, steep slope acres to keep reforestation costs down.
Third, the 2020 fires damaged millions of board feet of timber under contract, and tens of thousands of acres which had recently been through NEPA review in preparation for fuels reduction work. While some of the volume under contract will have lost all remaining value, Congress should direct the Forest Service and BLM to rapidly survey burned areas, and allow the agencies to convert projects that were damaged to salvage sales without further environmental review if they determine that the project still meets the original purpose and need statement. These projects should be converted to salvage sales within 60 days. All such sales should be allowed to proceed under HFRA’s judicial review provisions.
Going Forward: We Need to Manage Unreserved Forests Like Their Future – and Ours – Depends on it.
Since the mid-1990’s, Forest Management on National Forests west of the Mississippi has proceeded from one relatively simple premise: That the best way to conserve sensitive wildlife species is to not manipulate forests through management or timber harvests. This has been expressed through recovery plans and critical habitat designations for a wide variety of species, including the various Spotted Owls, Canada Lynx, Grizzly Bear, Wolves, and others.
This ‘hands off’ approach to management was adopted, in our view, without much regard for how much of our Federal estate is already off limits to much – if any – management. Fully one third of all National Forest acres in the Northwest Region (Oregon and Washington) are either Congressionally designated Wilderness Areas or Inventoried Roadless Areas. In California, the total in these two restrictive categories is 47 percent. Nation-wide, some 94 million acres of National Forests is either Wilderness or Roadless, fully 48 percent of the entire National Forest System. This tally does not include the millions of acres set aside as National Parks, including over 1.7 million acres of mostly forested National Parks in California. Millions more acres are difficult to manage because of assumptions about harm to species due to disturbance from harvest. As we’ve seen, if we don’t manage unreserved forests, we will wind up with disturbances from wildfires far more disruptive than a modest thinning project.
Americans should be proud of the conservation legacy they have created by setting up the Federal land management agencies and establishing protected areas like Wildernesses. However, the simple fact is that when the Forest Service tries to manage unreserved Federal lands, activist groups have abused a series of well-meaning laws to delay or stop needed management. As these forests mature after a century of fire suppression and decades of passive management, the slow pace of management the Forest Service has been able to achieve is simply slower than the fires we are experiencing.
The Congress has, over the last 17 years, provided the Forest Service with some tools which can help them put forest management projects on slightly faster tracks. The Healthy Forest Restoration Act was first passed in 2003, and has been amended several times, including in the 2014 and 2018 Farm Bills. The Forest Service has a few legislated Categorical Exclusions, Designation by Prescription authority, Good Neighbor Authority, and some other tools to expedite the NEPA process. This committee deserves much of the credit for enacting these laws.
While we’ve seen an uptick in management, and a slow increase in timber harvests in the last 12 years, we still see Forest Service staff shy away from managing what should be unreserved acres because of concerns that harvest will disrupt wildlife habitat. Instead of managing unreserved lands, we see small projects which leave many overstocked acres untouched, and even these go forward only after a laborious process that often involves administrative objection and litigation.
We are aware of legislation, including HR 7978, that would authorize a few larger projects on some national forests, while also allowing work on some fuel and fire breaks. We are supportive of the concepts in this bill and look forward to expanding them to make them more relevant to the scale of the challenges we are confronting.
Passive management, reduced access, combined with climate change and the development of homes in the wildland urban interface, have led us to spot where wildfires have likely caused more emissions than either cars or electric power generation in both Oregon and California this year, according to some early estimates. An equally passive approach to restoring these forests – and managing the remainder outside of Wilderness areas – will not help the global carbon balance. It’s time for Congress to weigh in here in favor of actively managing unreserved lands. Leaving the Forest Service to wrangle with environmental litigants and the vagaries of the court system is not an option.
We look forward to working with this committee to restore our National Forests so that future generations can look back and thank us for the legacy we are passing on to them.
You can also watch the full testimony here.
Cover photo from the LA Times.