The Sierra Forest Voice
Vol. 10, No. 3, September 18, 2017
Debunking the Wilderness – Fire Myth
Natural resource management is rarely simple, especially in the Sierra’s highly fire-adapted forests. Here, where land managers are working to reconcile a century of fire suppression in a landscape that would naturally burn as frequently as every 11 years, a strong public debate is taking place around the future of our forests. One unfortunate narrative emerging from this debate blames environmental protections for creating barriers to forest restoration. A common example of this is the critique that wilderness protections, by prohibiting certain uses, prevent federal land managers from effectively dealing with fire risk or restoring a natural fire regime. This misconception is frustrating to groups like SFL who believe that protecting wild places and restoring fire are mutually supportive – not incompatible – management goals.
The term “wilderness” represents the highest level of protection that federal lands can receive. Wilderness lands are undeveloped, with little-to-no visible evidence of human influence, where primarily natural processes shape the landscape. This translates to large (5,000+ acres) areas, lacking permanent roads, where extractive uses like mining and commercial timber harvest, along with motorized equipment and mechanized transportation (including mountain bikes) are prohibited. Although fishing, hunting, dogs, livestock grazing and pack animals are allowed in many wilderness preserves, for the most part wilderness areas are managed in a way that protects the untrammelled ecological values and opportunities for solitude that they provide.
Public lands stakeholders who favor extractive uses over environmental protections have long sought to paint a picture of wilderness areas as being legally “locked up” or off limits to uses other than pure nature conservation. Consider this quote from the Sierra’s own Congressman Tom McClintock, speaking at a 2016 House Natural Resources Committee hearing on a wilderness proposal in Central Oregon:
“Here’s a song we’ve heard before: despite the high fire risk, BLM is not performing adequate fire prevention activities, particularly mechanical treatments, in the area because it is managed as a Wilderness Study Area. In addition, the location of the WSA hampers firefighting tactics, leaving local firefighters with no maneuvering room to protect life and property in the event of catastrophic wildfire”
Here, McClintock uses a common argument for opposing wilderness protections: why limit the uses allowed on public land if it prevents land managers from keeping our forests healthy and our communities safe?
While McClintock’s argument works well to quickly inflame emotions, it isn’t based on actual facts. Fires can be suppressed, allowed to burn, or even intentionally lit in wilderness areas as long as certain conditions are met. Wilderness areas, by nature of their remote locations often provide unique circumstances where fires can burn safely without endangering people, structures, or communities. It can even be argued that a natural fire regime is a wilderness value unto itself.
The Wilderness Act and other relevant federal policies actually allow for a wide range of fire management activities in wilderness areas. The Act states that “…such measures may be taken as may be necessary in the control of fire, insects, and diseases, subject to such conditions as the Secretary (of Agriculture) deems desirable.” (16 U.S.C. 1133(d)(1)). The Forest Service’s own regulations further define how different types of fire management should be handled in wilderness areas:
Fire Suppression: The Forest Service can suppress fires in wilderness areas, and this remains the dominant policy in most situations. The Agency can employ the full spectrum of fire suppression techniques in and can even conduct pre-suppression activities like mechanical thinning and prescribed fire if fire objectives cannot be accomplished outside of a wilderness boundary.
Natural Ignitions: Forest Service policy states that the agency should “Permit lightning caused fires to play, as nearly as possible, their natural ecological role within wilderness” (Forest Service Manual 2324.21). So long as the agency has prepared a plan approving a natural burn stating the conditions in which it will be allowed, then natural fires can burn unsuppressed. If suppression is warranted, the Forest Service gives preference to suppression methods that leave a minimal impact. If no fire management plan exists, and specified conditions are not met, then natural fires are suppressed by default.
Prescribed Fire: The Forest Service can ignite prescribed fires in wilderness areas as long as the objective of the burn is to reduce fuels to allow for natural fires or to reduce the risks of future wildfires. Prescribed fires cannot be ignited purely for the purpose of benefitting wildlife, vegetation, forage or other resource values. The following conditions must also be met:
- Fire management outside of wilderness is not sufficient to achieve fire management objectives within wilderness.
- An interdisciplinary team of resource specialists has evaluated and recommended the proposed use of prescribed fire.
- The interested public has been involved appropriately in the decision.
- Lightning-caused fires cannot be allowed to burn because they will threaten life, property, or natural resources.
One local project that illustrates forward-thinking wilderness management is the Caples Ecological Restoration Project in the South Fork American River’s upper watershed. Here, the Eldorado National Forest, with the support of the South Fork American River Cohesive Strategy, plans to apply prescribed fire to approximately 6,800 acres of high elevation mixed conifer and red fir forest in the Caples Recommended Wilderness* that has not experienced fire since 1916. To help prevent a fire escape, the Forest Service plans to create fire lines with a bulldozer in strategic areas outside of the recommended wilderness area while using lighter-touch techniques like hand cutting within its boundary. Special attention will be given to protecting large old growth trees that helped inspire the wilderness recommendation in the first place.
Sierra Forest Legacy applauds the Eldorado National Forest for approving the Caples Project and hope that it will serve as a model for restoring fire to wilderness areas in the Sierra. A natural fire regime is a wilderness value that should be protected and restored. With the right balance of stakeholder input and creative planning, wilderness areas can be anchors – not liabilities – for fire resilience in our forests.
*While not officially designated by Congress, the Caples area has been recommended as a wilderness area by the Forest Service in a land management plan. It is managed as a wilderness area.For more information on the Caples Project:
Sierra Forest Legacy website
U.S. Forest Service website
Federal Policy and Sierra Forests
There has been plenty of news from Washington D.C. to keep up with lately. We’re using this new section Public Lands Watch to help our members keep track of current policy news that could affect forest ecosystems in the Sierra Nevada. This month, we’re profiling two bills that attempt to severely weaken one of America’s most basic environmental protections: the National Environmental Policy Act.
Background on NEPA: NEPA – our nation’s first major environmental law – requires the federal government to scientifically analyze the environmental impacts of actions that it proposes to take, and provide the means to mitigate any impacts that are deemed to be significant. The public is invited to comment on the content and quality of the analysis as they make their decision. The physical product of NEPA analysis is either a detailed Environmental Impact Statement or a less-detailed Environmental Assessment depending on how significant the effects of a proposed action may be on the environment. Although some criticize NEPA for stalling or preventing federal actions from occurring, NEPA’s importance for environmental protection cannot be overstated as it is often the only thing preventing irreversible environmental damage from occurring.
Under current law, activities proposed by the Forest Service can be exempted from NEPA’s requirements under something called a Categorical Exclusion, or CE. Originally, these were meant to be small-scale actions that have little effect on environmental health, for example, doing maintenance around Forest Service district ranger buildings and campgrounds, removing small numbers of hazard trees, and small-scale logging. Congress has authorized increased use of the CE through statutory changes over the previous decades, generally increasing the size of projects that would be permitted without NEPA analysis. Most recently, a provision in the 2014 Farm Bill authorizes the Forest Service to categorically exclude forest restoration and thinning projects of up to 3,000 acres from NEPA analysis, if they are at risk of insect-related mortality and meet a series of other requirements, and included a requirement to “maximize the retention of old-growth.”
The following two bills would further weaken the purpose of NEPA by, among other things, greatly expanding which logging projects would qualify as categorical exclusions.
Bill #1: Resilient Federal Forests Act of 2017 (H.R. 2936)
Sponsor: Rep. Bruce Westerman (AR-4)
Cosponsors from California: Rep. Tom McClintock (CA-4), Rep. David Valadao (CA-21)
Description: Misleadingly titled the “Resilient Federal Forests Act,” the bill reads like an exhaustive wish list from the timber industry. The astounding breadth of these changes are too numerous to even list in this article. The act would severely weaken the intent of both NEPA and the Endangered Species Act, while making it significantly harder for citizens to challenge ecologically harmful forest management decisions in court.
The bill offers a suite of new categories of project that can be excluded from environmental and public review (a.k.a categorical exclusions) and eliminates the Farm Bill requirement to protect old-growth.
If HR2936 becomes law, the following actions would no longer require that the Forest Service (or BLM) solicit public input or even consider the environmental impacts for:
- Logging projects up to 10,000 acres in size (15 square miles), or up to 30,000 acres if a project is developed through a collaborative process, proposed by a resource advisory committee, or covered by a community wildfire protection plan. Projects need not be in the guise of wildfire protection, but can be proposed solely for producing commercial timber.
- Salvage logging projects up to 10,000 acres in size
- Clear cuts up to 10,000 acres if the purpose is creating “early successional wildlife habitat”
- Reforestation activities, including the use of herbicides on areas up to 10,000 acres
Further, H.R. 2936 specifically repeals portions of the “extraordinary circumstances” rule. Currently, if extraordinary circumstances exist, the agency cannot use the CE category. Extraordinary circumstances are defined as the presence of: listed (or proposed) threatened or endangered species; sensitive species; wilderness areas or proposed wilderness areas; inventoried roadless areas; flood plains, wetlands, and municipal watersheds; research natural areas, American Indian or Alaska Native religious or cultural sites; and archaeological or historical areas. Under this bill, the presence of sensitive species and potential wilderness areas are no longer considered extraordinary circumstances, and the Forest Service and BLM are authorized to ignore the findings of Section 7 consultation with the U.S. Fish and Wildlife Service when threatened or endangered species are present. It also directs the agencies to ignore cumulative effects.
Status: The text of this bill was released on June 20, 2017, and passed the House Natural Resources Committee on June 27. It’s anticipated that it will next be taken up by the House Agriculture Committee.
How to Take Action: We at Sierra Forest Legacy in cooperation with conservation groups across the country are drafting letters to Congress. You can use talking points from these letters in your communications with your own Congressional representatives:
Letter to Chairman Bishop and Ranking Member Grijalva, House Committee on Natural Resources
Letter to California Congressman Jimmy Panetta. We will be a co-signer on this letter along with conservation groups throughout California. This letter will also be sent to delegation members Jim Costa, and Salud Carbajal.
Call your own congressperson. Ask them to oppose the bill. Use the sample letters linked above, and for more detailed talking points, use the information on our website. If you are short on time, you can also go to this site to get your congressperson's contact information and a very short sample script to use.
California members of the House Agriculture Committee:
Congressman Tom McClintock (CA district 4, Republican co-sponsor of the bill): (202) 225-2511
Congressman David Valadao (CA district 21, Republican co-sponsor of the bill): (202) 225-4695
Congressman Jimmy Panetta (CA district 20, Democrat California member of House Agriculture Committee): (202) 225-2861
Congressman Jim Costa (CA district 16, Democrat California member of House Agriculture Committee): (202) 225-2341
Congressman Doug LaMalfa (CA district 1; Republican California member of House Agriculture Committee): (202) 225-3076
Congressman Jeff Denham (CA district 10; Republican California member of House Agriculture Committee): (202) 225-4540
Bill #2: Forest Management Improvement Act (S. 1731)
Sponsor: Senator John Thune (SD)
Cosponsors in California: None
Description: This bill offers a suite of provisions that would also limit environmental review of large logging projects and do away with requirements that the Forest Service engage the public before taking action. This bill exempts logging projects up to 10,000 acres from NEPA if their purpose is to create early seral habitat, improve wildlife habitat, commercially thin timberland, salvage log dead or dying trees, or reduce the risk of insect and disease infestation. Beyond these large-scale categorical exclusions, the bill also:
- Exempts the Forest Service from having to consider the cumulative environmental impacts of multiple categorical exclusions. This would mean multiple 10,000 acre logging projects could occur in the same area without the Forest Service having to consider their impact on an ecosystem as a whole.
- Eliminates NEPA’s requirement that the Forest Service consider the environmental effects of multiple alternatives.
- Allows state forestry agencies to build permanent roads on National Forest lands
- Weakens citizens’ and environmental groups’ ability to hold the Forest Service accountable in court for ecologically destructive logging projects
- Alters the terms of stewardship contracts to benefit timber companies
Click here to read the text of the Forest Management Improvement Act.
Status: This bill was introduced in the senate on August 2, 2017 and referred to the Senate Committee on Environment and Public Works. Senator Thune has stated that he intends to include the bill in the 2018 Farm Bill.
How to Take Action: The conservation community is closely tracking developments with this bill, which currently has no cosponsors. If this bill, or any of its provisions, become part of the 2018 Farm Bill, SFL and other groups will send out an alert to take action.Update on Revised Inyo Forest Plan
The Forest Service recently released a preview of the Inyo National Forest Plan. Based on comments received by the public in 2016, they decided to update their inventory of rivers eligible for Wild and Scenic River designation, improve their accounts of at-risk species, and revise plan components for sustainable recreation and aquatic conservation. The agency shared this new information this past May. Although comments were not solicited, we decided to provide feedback on this new information. Overall, we thought that the changes that were made were significant improvements and in several cases reflected the changes we sought in the comments we submitted in August 2016 on the draft plan. We did have specific concerns about some aspects of the new analysis and plan components; these are highlighted in our comment letter.
The agency expects to release a final plan for the Inyo National Forest with a draft decision by January 2018. At that point, we will review the final plan and decision and decide if they adequately address the concerns we raised in comments to date, or if improvements are still needed. If we think improvements are needed, we will have 60 days in which to file an objection to the revised plan.
Rally for Giant Sequoia National Monument
On August 22, a coalition of local and regional environmental and social justice groups including SFL hosted a rally in Bakersfield to support Giant Sequoia National Monument. The rally was held across the street from House Majority Leader Kevin McCarthy's office, whose district includes much of the monument. Thanks to all who participated in this grassroots action to encourage McCarthy to keep Giant Sequoia National Monument intact at its current size!
Images above by Pam Flick, Defenders of Wildlife
Women on Wheels for Wildlands (#WOWFWL)
On September 12, our team led by Sierra Forest organizer Jamie Ervin met with Women on Wheels for Wildlands as they traveled through the Eldorado National Forest.
The group is a team of Minnesotans, Hannah Scout Field, Katie Ledermann, Alex Benjamin, and Ariana Amini, that are biking across the United States to raise awareness about public lands and the threats they face with the new administration and Congress. Their route began in San Francisco on September 9 and ends mid-December in South Carolina.
We met the WOWFL team at Silver Lake near Carson Pass on Highway 88 just as they finished their first major climb up from the Central Valley. From there, we hiked to Castle Point to overlook the Caples Recommended Wilderness on the Eldorado Forest. While enjoying a spectacular sunset and 360-degree view, the group discussed what the wilderness protections at Caples Creek really mean, and what ordinary citizens can do to protect rare wild places on federal lands.We wish the WOWFWL team the best of luck on their journey and thank them for their efforts to protect our public lands! Check out their website to see their route and learn more about their mission
SFL's outreach team has been in full swing this summer working to get people outside to learn about and support our Sierra Forests. Throughout the summer SFL partnered with the California Wilderness Coalition and several local organizations to get people out onto some of the lesser-known, but spectacular wild places on the Eldorado and Stanislaus National Forests. We would like to send a big thank you to El Dorado CNPS, Tuolumne River Trust, Foothill Conservancy, and CalWild for making these three events successful! We had a lot of fun at all three hikes, and hope that our partnerships with these organizations continue to grow in the future. Brief recaps of each hike are below:
Hike to Caples Creek with California Native Plant Society - El Dorado Chapter
SFL co-hosted a hike to the Caples Creek Recommended Wilderness on 8/5 with the El Dorado Chapter of the California Native Plant Society. A total of twenty hikers joined for a one-way eight mile hike through old growth red fir and mixed conifer forests following the Silver Fork American River from Martin Meadows to the Fitch-Rantz Bridge. During the hike, we paused for discussion and to hear Steve Evans and Craig Thomas speak about expanding the Caples Recommended Wilderness in the revised forest plan for Eldorado National Forest, fire ecology, and the upcoming ecological prescribed fire project in the Caples Recommended Wilderness.
Images: Upper left: CNPS-ers hiking down the trail to Caples Creek
Upper right: Silver Fork American River
Below: Overlook view of the Caples Creek Wilderness area
Photos by Steve Evans and Jamie Ervin
Hike to Preston Falls with the Tuolumne River Trust
SFL and the Tuolumne River Trust co-hosted a hike to Preston Falls on the Wild & Scenic Tuolumne River on Saturday September 9th. The group hiked 8-miles round trip through the wild river canyon and took time to swim in the Tuolumne in the gorgeous pool below Preston Falls. Much of this area burned at high severity during the 2013 Rim Fire, but plenty of majestic fire-scarred pines and black oaks still shade much of the trail. Part of the goal of the hike was to highlight the North Mountain Roadless Area, which could be recommended as wilderness in the upcoming Stanislaus National Forest plan revision.
Hike to Pacific Valley with Foothill Conservancy
On September 10th, SFL and Foothill Conservancy co-hosted a hike along the newly-built Mokelumne Coast-to-Crest Trail (MCCT) near Ebbetts Pass on the Stanislaus. Fifteen friends and members of the Jackson-based Foothill Conservancy joined to hike from Mosquito Lakes downhill along the MCCT into the Pacific Valley Roadless Area, a potential addition to the Carson-Iceberg Wilderness. This excellent hike took the group past granite outcrops and diverse high-elevation forests to a healthy meadow along a tributary of the North Fork Mokelumne River.
Highlighting what's new in published science that's relevant to Sierra Nevada forest conservation
Avian Monitoring in the Freds and Power Fire Areas
The 7,900-acre Freds Fire and the 17,200-acre Power Fire both burned in 2004 on the Eldorado National Forest. Avian use by three different bird guilds was monitored within the post-fire landscapes from 2014 through 2016. The study found that species abundance was similar between burn severity classes. However, the avian community using each burn severity class was different, and some species were associated with edges between burn severity classes. In fact, the results indicate that edges may actually provide distinct habitat from patch interiors.
Not surprisingly, forest dwelling species, which included Western wood pewee and olive-sided flycatcher, were associated with higher densities of large living trees.
Image above: Green-tailed towhee, Piplilo chlorurus. Photo by naturespicsonline.com (CC-BY_SA 3.0).
Early seral species, such as lazuli bunting and green-tailed towhee, became less abundant with increasing living tree density, and were highly associated with shrubs and young conifers. Snag-associated species like black-backed woodpecker and mountain bluebirds were more common in forests that had higher densities of snags and less live tree density. Perhaps most interesting, the study found that except for species associated with mature dense forests (for example, pileated woodpecker), 40-60% shrub cover benefited all of the avian communities evaluated, with species richness and abundance associated with increasing shrub cover. Therefore, it makes sense that herbicide treatments designed to control shrub cover negatively affected avian species abundance and richness.
Based on the results, the authors developed a list of post-fire management recommendations designed to support a diverse abundance of bird species in post-fire landscapes, including general recommendations for managing post-fire areas and recommendations specific to snags, early seral forests habitat, and shaping future forests. We highly recommend reviewing the list of recommendations included in the report and using the list to help develop post-fire restoration projects. Finally, the authors recommended that the Power Fire and Freds Fire landscapes be managed as early seral reserves where frequent managed wildfire and prescribed fire would be used as the primary management tool to maintain fire resilience.
Unfortunately, the draft decision for the Power Fire Restoration Project does not set aside the area as a reserve or recommend using fire as the primary management tool to provide fire resilience. Instead, the project includes using millions of dollars of herbicide to control shrubs followed by replanting high densities of conifer seedlings.
Foothill Yellow-legged Frog (Rana boylii)
In June of this year, the California Fish and Game Commission voted to accept the petition from Center for Biological Diversity to list the foothill yellow-legged frog, Rana boylii, under the California Endangered Species Act (CESA). As a "candidate" species, it will receive the same protections as if it were listed. The California Department of Fish and Wildlife now has twelve months to decide if the species should in fact be listed. On the federal side, the U.S. Fish and Wildlife Service will make a decision by 2020 on whether the species warrants federal protection under the Endangered Species Act.
Two other species of yellow-legged frog in California, the mountain yellow-legged frog, Rana sierra in the north, and Rana muscosa in the south, are already listed as endangered under both the federal and state Endangered Species Acts. The three species are similar in appearance and are best distinguished based on geography. Foothill yellow-legged frog can be found in rivers, creeks, and streams in the Sierra Nevada foothills or on the coast at elevations between sea level and 6,400 feet. Mountain yellow-legged frogs are found at higher elevations, usually above 6,000 feet.
Foothill yellow-legged frogs are gray, tan, reddish, or olive in coloration with rough, granular skin and gray-black flecking and mottling, matching the rocks in the perennial streams in which they are found. Their ventral side is cream to pale buff with characteristic lemon-yellow markings on the legs and around the abdomen. There are many variations in coloration, including some with reddish markings on the back and legs. They are about 1.5 to 3.25 inches long.
This species historically ranged from northern Oregon, south to southern California on the coast and the San Gabriel Mountains and the Tehachapi Mountains, and in the Sierra Nevada. There was an isolated population in the San Pedro Martir mountains in Baja California. All populations south of Santa Barbara on the coast are now likely extinct, and in the Tehachapi Mountains. The species is threatened with extinction on the southern and central coast, in the San Francisco bay area, and in the southern Sierra Nevada.
Currently, the best populations of foothill yellow-legged frogs are found mostly in the north coast range, including the Smith River, tributaries of the Klamath River, the South Fork Trinity River, the South Fork Eel River, Redwood Creek, coastal tributaries in Mendocino County and tributaries of the Russian River. Healthy numbers are also found in the Diablo Range, throughout Sonoma County and in the upper Sacramento River basin, and foothill yellow-legged frogs are still found in river systems in the northern and central Sierras, including the American, Clavey, Cosumnes, Feather, Merced, Mokelumne, Stanislaus, Tuolumne and Yuba rivers. Researchers who have studied the frog for decades are concerned that none of the populations have sufficient numbers to ensure that stable populations can be maintained.
Amphibian populations have been declining at local and global scales for some time, and the explanation for these declines is not fully understood. However, recent studies suggest that the most significant impact harming survival and reproduction of foothill yellow-legged frogs comes from water development and diversions. Based on the most robust data collected, even small-scale changes in local water habitat conditions can impact reproductive success. Regulated rivers and streams result in changes in the velocity of the water, its depth, and its temperature. These factors result in reduced habitat suitability for breeding and rearing. The foothill yellow-legged frog life cycle is closely tied to seasonal timing of natural streamflow. Reservoir and river management cause inconsistent environmental cues for breeding, lower growth rates for tadpoles, and scouring or stranding of egg masses and tadpoles. Reservoirs create barriers to gene flow, and contribute to establishment of nonnative predators which then spread into rivers and streams.
Releases of cold water from reservoirs can flush out the eggs that are attached to rocks in the streams where they live. Tadpoles are also washed out during these periodic fluctuations. Cold water releases from reservoirs may be beneficial for salmonids, but the water may be too cold for rearing healthy foothill yellow-legged frogs. Similarly, dewatering of streams for downstream human use can be devastating to foothill-yellow legged frogs and other aquatic species, as seen in the photo below. Suction gold dredging may be another significant factor in occupied habitat. Other threats to amphibians in the Sierra Nevada include the introduced infectious Batrachochytrium dendrobatidis (Bd) chytrid fungus, fish stocking in mountain streams, introduced bullfrogs, logging, livestock grazing, off-road vehicle recreation, pesticide drift from agriculture, marijuana cultivation, fire suppression activities, and forestry use of herbicides.
Photo above: Desiccated Rana boylii egg masses stuck on rock after flow stage change. Credit: J. Drennan, PSW.
For more information:
Hayes, Marc P.; Wheeler, Clara A.; Lind, Amy J.; Green, Gregory A.; Macfarlane, Diane C., tech. coords. 2016.Foothill yellow-legged frog conservation assessment in California. Gen. Tech. Rep. PSW-GTR-248. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station. 193 p.
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