Testing the agency’s case

What the agency argues, and whether its own record backs it

6

Not fully backed

• Purpose and needNot fully backedThe Forest used modeling to prioritize the upper Cow Creek Basin, and it says the area has the district's highest concentrations of private lands, homes and structures, and critical access roads, and the greatest need for active management.

  The background section describes a district-wide analysis. It used fire behavior modeling under 90th percentile weather, a wildland-urban interface map and a suppression difficulty index, and Figure 1 maps the result. But the text gives no counts of homes or structures, no modeled fire severity and no comparison with other parts of the district.

  The agency’s words, the record +Hide the words

  The agency says

  “Through IFTDSS modeling, the Forest prioritized the upper Cow Creek Basin / southwest Tiller project area. This area includes the highest concentrations of private lands, homes and structures, and critical access roads across the district and has the greatest need for active management to prepare for future fires.”

  Project Purpose of and Need for Action

  Elsewhere in the same document

  “A district-wide analysis was conducted using fire behavior modeling for 90th percentile weather conditions, district Wildland-Urban Interface (WUI) map and the national Suppression Difficulty Index map which identified Upper Cow Creek as a top priority (Figure 1).”

  Background Information

• EffectsNot fully backedShaded fuel breaks and thinning will reduce fire intensity, give firefighters safe anchor points and reduce catastrophic wildfire risk on federal and nearby lands.

  The notice explains how the treatments are meant to work. Shaded fuel breaks would thin to make space between tree crowns, cut ground and ladder fuels, and keep a minimum 40% canopy cover. It says this limits surface fuels and lowers the potential for crown fire. Plantations would go from an average of 190 trees per acre to an average of 50-80 trees per acre. Fuel breaks would extend up to 75 feet from each side of the road in stands less than 80 years old and up to 150 feet in stands greater than 80 years old. But the notice gives no modeled flame lengths or crown fire potential before and after treatment, and it cites no study.

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  The agency says

  “These treatments reduce fireline intensity providing firefighters safe and effective anchor points to suppress and manage large fires and reduce the risk of catastrophic wildfire on both federal and adjacent lands.”

  Background Information

  Elsewhere in the same document

  “Where PODS intersect plantation thinning units, the thinning prescription may be modified to maintain a residual canopy cover of approximately 40% or greater to limit brush growth after treatment.”

  Plantation Thinning

• EffectsNot fully backedTreatments on approximately 850 acres in riparian reserves are designed to restore and maintain the ecological health of watersheds and aquatic ecosystems.

  Table 2 sets stream buffers. For plantation thinning they're 120 feet on each side of perennial fish streams. For fuels treatments they're 50 feet on streams with anadromous fish and 25 feet on intermittent or ephemeral streams. The notice says reserves outside the buffers would be thinned only where it helps meet aquatic conservation and fuels objectives. It also lists examples of riparian design features: limits on equipment use and temporary road construction in sensitive areas, and requirements for erosion control and shade protection. But those design features haven't been developed yet, and the notice doesn't analyze effects on shade, sediment or stream temperature.

  The agency’s words, the record and the law +Hide the words

  The agency says

  “All treatments inside RRs are designed to restore and maintain the ecological health of watershed and aquatic ecosystems through the Aquatic Conservation Strategy Objectives (ACSO; NWFP pp. C-30 to 38).”

  Treatment in Riparian Reserves

  Elsewhere in the same document

  “Project Design Features (PDFs) will be developed to prevent and minimize impacts to forest resources, and for water quality protection.”

  Apply Project Design Features and best management practices

  The law

  “Resource plans and permits, contracts, and other instruments for the use and occupancy of National Forest System lands shall be consistent with the land management plans.” National Forest Management Act, 16 U.S.C. 1604(i) ↗

• Show 3 more claims +Show fewer

  • EffectsNot fully backedRoad maintenance and reconstruction, including culvert replacement, will improve watershed conditions.

    The notice identifies approximately 20 stream culverts for replacement. It says many were installed too small for a 100-year flood, which is today's standard, and most will be made larger. That supports the watershed benefit of the culvert work. Approximately 22 miles of reconstructed and 4 miles of new temporary road are a separate effect that this claim doesn't weigh.

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    The agency says

    “Maintenance and reconstruction of system roads in the project area is needed to improve watershed conditions and to allow for project related haul.”

    Culvert Replacement, Road Maintenance, Temporary Roads, and Reconstruction

    Elsewhere in the same document

    “Most will be upsized since many culverts installed in the past were not large enough to accommodate a 100-year flood which is today’s standard.”

    Culvert Replacement, Road Maintenance, Temporary Roads, and Reconstruction

  • ScienceNot fully backedA century of fire exclusion and changed management has pushed forests far from historical conditions and raised the risk of harmful fire.

    The notice says these lands historically had mixed severity fire. But it gives no historical fire return intervals, no measure of how far conditions have departed and no fuel loading figures. Maintenance burning is supposed to match historic fire return intervals, yet those intervals are never stated.

    The agency’s words, the record and the law +Hide the words

    The agency says

    “However, over the course of a century, fire exclusion and changes to forest management have created large departures from historical vegetation patterns and increased the potential for adverse fire effects.”

    Project Purpose of and Need for Action

    Elsewhere in the same document

    “The proposed actions also include the implementation of maintenance burning to maintain the alignment with historic fire return intervals to ensure fuels accumulations do not reach or exceed the extent to which they are seen today, overall increasing stand resiliency into the future.”

    Prescribed Fire

    The law

    “ensure the professional integrity, including scientific integrity, of the discussion and analysis in an environmental document; (E) make use of reliable data and resources in carrying out this chapter;” National Environmental Policy Act, 42 U.S.C. 4332(2)(D)-(E) ↗

  • ProcessNot fully backedClosing Forest System Road 3242-201 to the public is needed to restrict access to the new weather station.

    The purpose and need section says actions are needed to protect the weather station and restrict access to it for fire-related and ongoing forest management needs. The notice also cites a project-level travel analysis. But it doesn't describe any threat to the station that requires closing the road to the public. It also gives two lengths for the closure: approximately 1.5 miles in the proposed action and approximately 0.25 miles in the transportation section.

    The agency’s words, the record +Hide the words

    The agency says

    “This the sole route to the Red Apple RAWS station and this action is needed to restrict access to this location.”

    Transportation System Changes

    Elsewhere in the same document

    “Change of Forest System Road 3242-201 (approximately 1.5 miles) from Road Open to all Vehicles to Road Closed for all vehicles except for administrative use only.”

    Proposed Action