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The Sierra Forest Voice Newsletter

The Sierra Forest Voice

Web Edition
Vol. 8, No. 1, March 12, 2015


Good Smoke, Bad Smoke:

Protecting public health while not limiting the ability of land managers to conduct ecological burns and manage natural ignitions for multiple resource benefits 

Balancing public health (clean air) and a key ecological process (fire and smoke) in California is no easy task. Today, the five cities with the worst air quality in the state (Bakersfield, Visalia, Madera, Central San Bernardino, and Metro Riverside) mostly border the Southern Sierra Nevada. While we all care about improving air quality in California, the focus should remain on the primary pollution targets, like emissions from fossil fuel combustion and manufacturing, and should avoid placing stricter limitations on prescribed and natural fire use in forest lands in California.

The Federal Environmental Protection Agency (FEPA) is proposing to change standards for ground-level ozone in California and the rest of the U.S. While welcomed in every other respect, the new rule could make it much harder for land managers to use ecological fire in strongly fire-dominated forests of the western United States. Fire here is essential to maintain the natural ecological processes and species which define California. 

The proposed ozone rule would lower the current standard of 75 parts per billion (the concentration of ozone pollution in the air we breathe) to a standard in the range of 65-70 parts per billion, while taking public comment on a level as low as 60.

Ozone figure

What is Ozone? 

Ground level or "bad" ozone is not emitted directly into the air, but is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight. Emissions from industrial facilities and electric utilities, motor vehicle exhaust, gasoline vapors, and chemical solvents are some of the major sources of NOx and VOC. Breathing ozone can trigger a variety of health problems, particularly for children, the elderly, and people of all ages who have lung diseases such as asthma. Ground level ozone can also have harmful effects on sensitive vegetation and ecosystems (source:

Read more Ozone Facts here.  

Ecologically, elevated Ozone levels are also causing injury to needles of important pine species in the Sierra Nevada.

.Ozone damage

From: Sierra Nevada Science Synthesis, PSW-GTR-247 Vol. II--Chapter 8.1 

Why we need to increase burning in the Sierra Nevada . . .

Historical Fire (Natural Background) 

In the pre-1800s landscape, fire had a much larger, natural role in ecosystem regulation. As described in an important 2007 research paper, scientists note that "approximately 1.8 million ha [4.4 million acres) burned annually in California prehistorically (pre-1800)" and "our estimates of prehistoric annual area burned in California is 88% of the total wildfire area in the entire US during a decade (1994-2004) characterized as 'extreme' regarding wildfires." The approximate estimate for annual area affected by wildfire today in the Sierra Nevada is about 500,000 acres/year. 

The historic or background natural disturbance level is what many scientists and natural historians characterize as the natural or pristine condition of the past. It is a variable condition that "delivered" the resilience missing from these very landscapes today. Re-introducing fire to the Sierra Nevada is a key ecological restoration goal of the Forest Service in 2015 (Ecological Restoration-Leadership Intent, Cohesive Strategy 2014, Sierra Forest Legacy et al. and Forest Service Settlement Agreement 2014[B1] ).

Recent research suggests increased fire treatments are essential to maintain and inprove forest resilience in the Sierra Nevada.

In recent research by forest ecologist Malcolm North and others (North et al. 2015 ) noted that, approximately 10.7 million acres of national forest ownership in the Sierra Nevada contain roughly 58% productive forest land, and 25% of those acres are available for mechanical treatment. In other words, if we can only restore 25% of the Sierra Nevada using mechanical treatments (which then need fire as a follow-up treatment), the other 75% will be "managed" by unplanned wildfire unless we design and implement a thoughtful, science-based use of natural ignitions and prescribed fire. Planned prescribed fire use or the appropriate use of natural ignitions significantly limits the emission of ozone precursor compounds that contribute to creating ozone pollution.   

In another recent 2015 paper published in the Journal of Forestry, Dr. Marc Meyer, Forest Service Zone Ecologist for the southern Sierra Nevada, looked at the fire effects of natural ignitions (i.e., fires managed for resource objectives) and wildfires that escape initial suppression, and compared both to the science-based references for the natural range of variation (NRV) of fire effects. He found that "resource objective fires". . . "were overwhelmingly within the natural range of variation." In contrast the effects from fires that escape initial suppression were outside (NRV) for the areas studied.  

Dr. Lee Tarnay, air quality expert for the National Park Service (now with the Region 5, PSW Research Station) has also gathered ozone emissions information from burns in Yosemite National Park that demonstrate the limited duration of such emissions in the air shed. Air quality researchers are working to improve understanding about the intensity, duration and direction of smoke associated with ecological burning and its air pollution impacts. The refined modeling tools and local data collection will help air regulators better address pollution concerns and will likely ease restrictions on well managed burn events.  

Increasing forest resilience with prescribed and natural ignitions will limit uncharacteristic high severity fire and the significant emissions that follow mega-fires such as the recent fires (Rim and King) in the Sierra Nevada.

Burning and Protecting Public Health  

Sierra Forest Legacy and the Forest Service in Region 5 (Sequoia National Forest, Hume Lake Ranger District) have recently partnered with the Fresno-Madera Medical Society and others to establish an Air Quality Alert Notification System. Utilizing timely and best available weather information, the system will make direct contact with the air-quality challenged communities of the southern Sierra Nevada through their physicians, school nurses and the public health community. The purpose is to alert them to a pending prescribed fire, the ecological need for such fire as a restoration tool, AND to give them advanced notification of the event so they can better protect themselves and their families from the impacts of short-duration smoke in their communities. There has been a very positive response from San Joaquin Air Board staff and the Fresno Area Lung Association in developing this notification system. The notification system was successfully applied to the Boulder Creek Burn last year.   

What You Can Do: Write to Federal EPA Administrators by March 17, 2015 and ask:

  • While you consider new limits on ozone emissions for California to protect public health, do not limit the ability of land managers to use fire as a natural disturbance process and as a critical restoration tool.
  • Treat the major ozone pollution sources (automobile and diesel exhaust, coal plants and other stationary sources) as the serious health threats that they are.
  • But also recognize that fire (to burn or not) is not a choice in the Sierra Nevada or most fire-adapted ecosystems in California. Fire is a critical and necessary ecological process and management tool to build forest resilience in an uncertain climate future.
  • Prescribed and natural ignitions can be planned for and used for significant positive resource benefits while limiting uncharacteristic fire effects and the increased emissions as a result of these events.
  • Active fire suppression at the home and community level remain important responsibilities for homeowners and fire-fighting professionals but efforts to suppress large wildland fires (Moonlight, Rim, King fires) in California have largely failed to limit resource damage in the Sierra Nevada.
  • The best "tool" to manage fire on the California landscape is to significantly expand the use of prescribed and natural ignitions coupled with the best smoke modeling-mitigation approaches and an expanded public health notification system in an All Lands, All Hands, collaborative approach. 
  • Broaden and amend the Exceptional Events Rule to include all human ignitions used for resource benefit and reduce monitoring and acerage cost requirements for permitting prescribed burns in fire-associated ecosystems in the U.S.

Download the Federal Register notice here. The discussion regarding wildfire and emissions begins at page FR 75242. The EPA Ozone Proposed Rule acknowledges the contribution of prescribed fire as a management tool and fire as a natural process to manage and maintain fire adopted ecosystems, stabilize fire regimes, and limit uncontrolled emissions from wildfire. 

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-OAR-2008-0699, to the EPA by one of the following methods:

* Federal eRulemaking Portal: Follow the online instructions. 

* Email: Include docket ID No. EPA-HQ-OAR-2008-0699 in the subject line of the message.  

Learn more about air quality issues and prescribed burning at the SFL website. You can also download and read published papers in Fire Ecology, Fire History, and Fuels Management here.   


Sierra Amphibian Programmatic Biological Opinion Issued

On April 29, 2014, the U.S. Fish and Wildlife Service published a final rule listing the Sierra Nevada and mountain yellow-legged frogs as endangered, and the Yosemite toad as threatened species under the authority of the Endangered Species Act. Under section 7 of the ESA, federal agencies are required to consult with FWS to insure that any action authorized, funded, or carried out by such agency is not likely to jeopardize the continued existence of any endangered or threatened species.

Photo right: Mountain Yellow-legged Frog (US FWS)

Mountain Yellow-legged FrogTherefore, as a result of the listing, the Forest Service was required to consult with FWS on all activities that may take these species. The definition of "take" under the ESA  includes "to wound, kill, and harm;" harm has been further defined to include significant habitat modification or degradation. When take is determined likely to occur as a result of a federal activity, the required consultation with FWS is documented in a Biological Opinion (BO). Two of the primary purposes of BOs are to document how FWS arrived at a jeopardy or non-jeopardy determination, and to authorize what is called "incidental take" of listed species as a result of federal actions. Incidental take is defined by the ESA as take that is "incidental to, and not the purpose of, the carrying out of an otherwise lawful activity." The BO process is not open to the public and does not require a separate NEPA analysis.

In December 2014, FWS issued a non-jeopardy Programmatic BO to the Forest Service for nine forest management programs administered by the Forest Service, for all Forest Service-managed lands in the Sierra Nevada that may affect the mountain and Sierra Nevada yellow-legged frogs and Yosemite toad. The forest management activities in the description of the proposed action of the BO are primarily based on the relevant standards and guidelines of the 2004 Sierra Nevada Forest Plan Amendment and Forest Service Best Management Practices. However, many of the discretionary standards and guidelines and best management practices were modified to be non-discretionary.  The Programmatic BO did not provide incidental take authorization of the species and requires the Forest Service to consult with FWS on a project-by-project basis to append such projects to the Programmatic BO and obtain incidental take authorization. 

In essence, the Programmatic BO streamlined the consultation process. Also of significance, the Programmatic BO includes a term and condition requiring the Forest Service to design and complete a FWS-approved scientific and statistically robust monitoring plan. The plan is to be designed and implemented by a team of scientists led by a herpetologist with experience with all three amphibians, and will determine whether the Forest Service conservation measures maintain the species and/or restore their habitat.  

Recently, FWS appended 1,116 specific projects across the Sierra to the Programmatic BO and provided incidental take authorization for all three amphibians. The specifics for each project were not provided in the appendage letter, but are on file at the FWS or the Forest Service Regional Office. On each National Forest, no more than one individual of each of the amphibians may be killed or injured as a result of project-related activities, but all individuals may be taken in the form of harm, harassment, or capture. Exceeding authorized take requires that all project activities likely to adversely affect these species cease on the National Forest in question and that the Forest Service reinitiate consultation with FWS.  

Read more:

FWS Programmatic Biological Opinion on Nine Forest Programs on Nine National Forests in the Sierra Nevada of California for the Endangered Sierra Nevada Yellow-legged Frog, Endangered Northern California Distinct Population Segment of the Mountain Yellow-legged Frog, and Threatened Yosemite Toad: December 19, 2014  

Appendage to the Programmatic Biological Opinion: February 17, 2015


Owl video imageTake a break and sit back and enjoy this video created by research scientist Sheila Whitmore of a nesting California spotted owl taking care of its nestlings.

Learn more about Whitmore's work with spotted owls at the SNAMP owl website. 



News Bytes from the Front

King Fire Scoping Comments

The 30-day comment period for the Forest Service's Notice of Scoping for an Environmental Impact Statement for the King Fire Restoration Project closed January 23, 2015. SFL submitted comments along with the California Native Plant Society, Sierra Club, and Center for Sierra Nevada Conservation. 

Our primary concerns were:  (1) the need to develop and implement a rational landscape-wide long-term fuels management strategy and to return fire to the system in under ten years; (2) avoiding the effects of salvage activities to spotted owls; (3) maximizing species diversity and abundance and fire resiliency in reforested areas; (4) recognizing the ecological value and need to conserve Complex Early Seral Forests (CESF); and (5) protection of lava caps, sensitive and special interest plant species, and spread of noxious weeds. 

In addition to the concerns raised in our comments, it now appears the Forest Service plans to log forests that burned at low and moderate-severity in the southern portion of the fire, despite repeated statements by the Forest Supervisor at stakeholder and public meetings that salvage of low and moderate-severity burned forests would not be proposed. There is relative scientific consensus that the Sierra Nevada were characterized by frequent mixed severity fire. Although the King Fire included some extraordinarily large patches of high severity fire in the north, there is little debate that the southern one-third of the King Fire burned as a mosaic of well-distributed low, moderate, and high severity patches: fire effects that are consistent with the Natural Range of Variation NRV). Therefore, it defies logic to suggest that any areas that burn within NRV, including patches of low, moderate, and high severity, require "restoration" beyond what is necessary to provide for public safety.  

Although the Forest Service is required to adhere to the best available science, officials still maintain that the purpose and need of salvage logging is to treat fuels. Yes, salvage logging affects the distribution and composition of fuels, but to what end?  Fine fuels, not large fuels, are the primary driver of several important fire behavior metrics, including rate-of-spread, fireline intensity, and flame length; because of this, many studies (Donato et al. 2006, McIver and Ottmar 2007, Keyser et al. 2009, McGinnis et al. 2010, Ritchie et al. 2013, Donato et al. 2013, Dunn and Bailey 2015) do not support the hypothesis that salvage logging reduces fuels in a manner or to the extent that the potential rate of fire spread, fireline intensity, flame length, or the probability that a site reburns at high severity are reduced. It's important to remember, pulses of dead wood are a natural characteristic of mixed-severity fire regimes and the southern portion of the King Fire burned within NRV. It's also ironic that many salvage-logged areas are then reforested as plantations, as studies have found that plantations are more likely to burn at high severity than unlogged forests (Thompson et al. 2007) and represent a significant fire hazard (Kobziar et al. 2009). Will the Forest Service use the ol' "Cut-Spray-Plant-Pray" method for the King Fire and justify it using contradictory and confounded logic? Experience with other recent post-fire salvage and reforestation projects in the Sierra Nevada suggests they will.  

View SFL et al comment letter here. 

References -- You can view these references here (Salvage Logging) and here (Fire Ecology) in the Fire Science section of the SFL website.   

Donato, D.C., J.B. Fontaine, J.L. Campbell, W.D., Robinson, J.B. Kauffman, and B.E. Law.  2006.  Post-wildfire logging hinders regeneration and increases fire risk. Science 311:352.

Donato, D.C., J.B. Fontaine, J.B. Kauffman, W.D. Robinson, and B.E. Law.  2013.  Fuel mass and forest structure following stand-replacement fire and post-fire logging in a mixed-evergreen forest.  International Journal of Wildland Fire 22:652-666.

Dunn, C.J. and J.D. Bailey.  2015.  Modeling the direct effects of salvage logging on long-term temporal fuel dynamics in dry-mixed conifer forests.  Forest Ecology and Management 341:93-109.

Keyser, T.L., F.W. Smith, and W.D. Shepperd.  2009.  Short-term impacts of post-fire salvage logging on regeneration, hazardous fuel accumulation, and understory development in ponderosa pine forests of the Black Hills, SD, USA.  International Journal of Wildland Fire 18:451-458.

Kobziar, L.N., J.R. McBride, and S.L. Stephens.  2009.  The efficacy of fire and fuels reduction treatments in a Sierra Nevada pine plantation.  International Journal of Wildland Fire 18:791-801.

McGinnis, T.W., J.E. Keeley, S.L. Stephens, and G.B. Roller.  2010.  Fuel buildup and potential fire behavior after stand-replacing fires, logging fire-killed trees and herbicide shrub removal in Sierra Nevada forests.  Forest Ecology and Management 260:22-35.

McIver, J.D. and R. Ottmar.  2007.  Fuel mass and stand structure after post-fire logging of a severely burned ponderosa pine forest in northeastern Oregon.  Forest Ecology and Management 238:268-279.

Ritchie, M.W., E.E. Knapp, C.N. Skinner.  2013.  Snag longevity and surface fuel accumulations following post-fire logging in a ponderosa pine dominated forest.  Ecology and Forest Management 287:113-122.

Thompson, J.R., T.A. Spies, and L.M. Ganio.  2007.  Reburn severity in managed and unmanaged vegetation in a large wildfire.  PNAS 104:10743-10748.


Rim Fire "Reforestation"?

The Stanislaus National Forest has released its proposal to implement ripping, planting, herbicide applications, and other silvicultural activities on approximately 43,000 acres burned in the 2013 Rim Fire. Surprisingly, the scoping package made no mention of the value and importance of complex early seral ecosystems, which arise after fire and are extremely important to a variety of plants and wildlife. Indeed, it appears that the Forest Service is eager to reinstall plantations and eliminate early successional shrubs and other non-conifer species as quickly as possible. The agency will accept comments from the public and scientific community through April 13, 2015. Download all the pertinent documents here.

Learning Corner

Looking to the future, foresters fear larger, hotter, more destructive wildfires. Climate change is part of it...the effort to control nature has only shown that nature answers to its own rules." -- Timothy Egan, author of The Big Burn (See NL Vol. 7 No. 1).

Watch The Big Burn video online, on the PBS American Experience program.

Spotlight on Species: Bear Sphinx Moth (Proserpinus lucidus)

Bear Sphinx Moth Abby Lawless

Bear sphinx moth, also known as Pacific green sphinx moth, (Proserpinus lucidus, formerly Arctonotus lucidus) is a beautiful, emerald green but rarely seen moth in the Sphingidae family of hawk moths. (Another sphinx moth, also called green sphinx moth, is not the same species). It ranges from British Columbia to at least San Diego County in the south. Its habitat is also diverse, ranging from coastal grassland, interior valley grassland and foothill oak woodlands, to dry Ponderosa pine forests, juniper woodlands, and sagebrush on the east side of the Cascades.


Photo above: Adult Proserpinus lucidus, (c) Abigail Lawless

Appearance: Overall this moth is very hairy (hence the original name, bear sphinx moth). The adult moth wingspan is approximately 4-6 cm. The upper surfaces of the forewings are marked with blotches of emerald green edged with bands of light purple. The surface of the hindwing is pale rose pinkish tan with a reddish band. The entire wing surfaces are edged with a golden tan border, and the legs and antennae are also golden tan.

The caterpillars of this species vary significantly between the five instars. They are approximately 70 mm long at the last (fifth) instar, and they are a greenish gray in color with a rose-tan head. In the third instar, the caterpillar appears with an anal horn (as do many other sphinx moths). At the last instar, a distinctive black eyespot ringed by a white circlet and outer black circle replaces the anal horn that appears in the third instar. 

Bear sphinx moth is considered a management sensitive species in the Pacific Northwest, due to loss of habitat and lack of disturbance factors (fire), and it is likely that it is sensitive here as well. 

Unfortunately, in California, no one has conducted this type of evaluation, so its status is unknown here. The only natural host records for the species indicate that the larva are specific to Clarkia species, although captive rearing has been successful on Camissonia as well (unpublished studies). This species is likely to benefit from recurring fire, like its host plant Clarkia.  

Photo right: Proserpinus lucidus larva. Image by David Wikle, © Creative CommonsLarva

Clarkia are fire followers, annuals in the Onagraceae family that may be declining due to fire suppression, post-fire "restoration" activities, and other forest management activities that destroy habitat and cut life cycles short, thereby impeding reproduction. As we described in the September, 2014 issue of Sierra Voice, the Sierra Nevada is a hotspot of Clarkia species diversity, where 16 taxa are considered rare and require protection (in contrast, the Pacific Northwest has only 3 species of Clarkia in total). Clearly, California's frequent fire disturbance regime is a factor in the presence and diversity of Clarkia species. However, it has not been confirmed if bear sphinx moth is limited to one or more species in the genus, as very little research has been conducted.

Bear sphinx moths emerge as adults from their underground pupation chamber in late winter or early spring, and fly only long enough to attract mates. They may sip nectar in flight like most moths and butterflies do to keep energy reserves up. After mating, the female lays eggs on Clarkia. The caterpillars eat the host vegetation and when ready to pupate, they burrow into a tunnel several centimeters or more in the ground near the host plants.

Like most moths, bear sphinx moths are attracted to lights, and most records of these uncommon moths are associated with artificial lights. They are considered difficult to study because they emerge earlier in the year than most moths (February-March), and the caterpillars are difficult to distinguish from related species (much like their host plants). Only recently did scientists discover that one of the instar stages of the caterpillars look almost identical to a related species (ironically named P. clarkiae, since this species may not utilize Clarkia). Because of this, and the lack of natural history information documented for this species, anecdotal records may not be accurate when reporting information about the host plants for the caterpillars. 

The rarely seen bear sphinx moth is just one example of the biological diversity of California's unique biome, where species have evolved with, and habitats have been shaped by, regular fire.  

Learn more:

Miller, J.C. and P.C. Hammond.  2007. Butterflies and Moths of Pacific Northwest Forests and Woodlands: Rare, Endangered, and Management Sensitive Species. Forest Health Technology Enterprise Team, Technology Transfer Species Identification. FH-TET-2006-7. USDA Forest Service.  

Sierra Forest Legacy Bookshelf

Book CoverTrees and Shrubs of Nevada and Placer Counties, California by the Redbud Chapter of the California Native Plant Society. 2014. Redbud Chapter and CNPS Press. 529 pp.  

Four years of outstanding teamwork has produced a gorgeous new collaboration, Trees and Shrubs of Nevada and Placer Counties, California, while setting a new standard for local, place-based botanical guides. Created by a talented team from the Redbud Chapter of the California Native Plant Society (CNPS) that included professional botanists, naturalists, photographers, and technical specialists in digital photography and formatting, this book will be an indispensable addition to the naturalist's library.   

Every species of tree, shrub, and woody vine--some 212 species--known to occur in Nevada and Placer Counties are described and illustrated. Several beautiful photographs accompany each species description, representing a first for an effort of this nature (some species are uncommon and rarely photographed to begin with). The descriptions cover all the pertinent facts including both the common and botanical name of the species, information about blooming time, native or non-native, habitat, and specific locations where the species can be seen.

Also included in the volume are occasional tidbits about the species' ecology, interesting quotes, or social and ethnobotanical uses. Finally, the book also includes a chapter that describes 17 different locations in the two counties where many of the species can be seen, an ecologically rich chapter on galls by Alan Stahler, and an illustrated glossary.  

If the guide has any drawback, it would be the lack of dichotomous keys (with one exception, Pinaceae). The plants are arranged in alphabetical order, first by family and then by genus within the family, leaving species identification for the uninitiated to the "flipping through the book" method. This is a problem for all creators of field guides: how best to serve all audiences? Inclusion of simplified keys for at least several of the other large families would be a significant improvement for future editions, and would help less experienced users to distinguish between similar species. Nevertheless, this ambitious undertaking has no precedent and will likely stand alone for some time to come.  

Nevada and Placer Counties cover a wide range of habitats and elevations in the central Sierra Nevada, including valley grasslands and foothill woodlands, and ranging upwards to the mountains, forests, and ultimately to subalpine habitats. Equipped with this guide, readers will find it to be widely applicable not only to Nevada and Placer Counties, but to the central Sierra Nevada and beyond.   

Order the book here, or go the Redbud Chapter's website for a list of book sellers in the region. 


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Help Protect Our Sierra Nevada Forests

The work we do to protect the forests, with all of their unique and rare plants and animals, and the many wild places of the Range of Light cannot be done without the generosity of our supporters. Please help us to keep up our efforts. You can make a safe and secure donation from this website. Thanks to all who have so generously supported our work - together we form a multitude of voices. Join us in saying, "Si, se puede" on behalf of the wild forests of the Sierra Nevada.   

"A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community. It is wrong when it does otherwise."
~Aldo Leopold

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