This is part 3 of our series “It’s time to declare war on wildfire”. You can read part 1 here and part 2 here. In part 2, Jim Petersen discusses two essays written by Frank Carrol, the first of which is referenced in part 2 of this series. Part 3 begins with references to the second of Frank’s essays. The second essay remains unpublished in its entirety.
The increasing , frequency, size and cost of these fires are direct results of the Forest Service’s ill-timed and poorly conceived effort to “return fire to fire-depleted landscapes” by allowing fires to burn when and where the risks are simply too high. It is fantasy to attempt to herd a fast-moving wildfire through a forest that is so dry that its’ moisture content is less than that of kiln-dried lumber.
Returning fire to “fire-depleted landscapes” is a utopian pipe dream rooted in the crazy idea that it is possible to return western forests to pre-European settlement conditions prevalent when there were only 23 million people living in our country – not 331 million – and most of them lived along the eastern seaboard. Our post-industrial society has a long list of wants needs that can’t be met by torching forests because – like nature itself – fire is unpredictable and indifferent to human need.
Frank’s second letter spans five and one-half pages, single-spaced. It is much too long and detailed for even our well-informed audience. However, the 12 main points he makes demand incoming Secretary Vilsack’s immediate and enduring attention. Here they are:
- Beginning in 2001, the Forest Service embarked on an intentional effort to burn the nation’s forests and grasslands in high wildfire season using a one-size-fits-all strategy that Chief Vicki Christiansen euphemistically calls, “using unplanned fire in the right place at the right time to reintroduce fire to fire-depleted ecosystems.”
- The Forest Service’s fire command structure shares no common understanding of the overarching principles of natural resource management. The historic connection between resource management – forestry – and firefighting has been severed.
- Wildland firefighting crews now carry more drip torches than shovels. They are wiping out private forestlands that have been well managed for decades. Private landowners have lost hundreds of millions of dollars in trees and buildings – and have no recourse.
- Tensions between private timberland owners and the Forest Service are at fever pitch. Fire crews are now calling sheriff’s deputies to remove landowners who are attempting to protect their property from fires that start on federal lands and spread to their lands.
- Some fire ecologists say that letting wildfires burn is good. It is also illegal and it ignores historic fire regimes, significant differences in forest types and fuel structure and volume, to say nothing of fire location in relation to communities and watersheds. There is no scientific or empirical data that justifies these actions and there are no measurable outcomes.
- The unplanned use of wildfire to return fire to forests ignores the requirements of five key federal laws: the National Environmental Policy Act [NEPA], the National Forest Management Act [NFMA], the Endangered Species Act [ESA], Clean Water Act [CWA] and the Clean Air Act [CAA]. Specifically, the use of unplanned fire constitutes a major federal action that produces significant environmental impacts. Thus, an Environmental Impact Statement is required – as is the opportunity for public comment – and a Record of Decision. None of this is happening. Crews are purposefully lighting fires at the discretion of their incident commanders.
- The Forest Service is counting total wildfire acres burned as targets met for fuel reduction. These acres are reported to Congress as though they represent a positive outcome for forests. They do not. They represent an alarming trend in forest loss that is just as destructive as are the land-clearing burnings that are occurring in Amazon rainforests.
- The Forest Service is burning because it can. Because no one is telling them to stop burning. They are burning because it is the last refuge for an agency fresh out of creative management ideas – an agency beaten into submission by radical environmentalists who neither understand nor support human interaction with wildlands.
- The wildfire hierarchy, which extends from the Chief’s office to field commanders, perpetuates the fiction that they are engaged in risk management. They are not. There is no real or practical connection between their decision support system and what happens on a particular fire. Crews on fire lines work on their perceived assignments on their own recognizance without supervision or direction. Crew leaders cannot possibly connect the dots and make the right choices. Again, the historic connection between forestry and wildland firefighting has been severed.
- If risk management was the goal, a small fire started by lightning or a campfire could be extinguished long before it became an excuse for “big box burning.” Reconnaissance firefighters who arrive first – say smokejumpers and hotshot crews– could easily and safely put it out. That’s risk management. It’s what happens when you don’t allow wildfires to grow so large that they cannot be attacked without injuries or deaths.
- Skilled wildland fire crews are hired and trained to rapidly attack and extinguish fires, not to sit around in brigade-sized fire camps while a fire they could have quickly controlled rages out of control. This is not risk management. This is the end of integrated resource management. This is the age of managed fire. But there is nothing managed about it. It is systemic and illegal.
- Tort claims and lawsuits against forest supervisors are now moving forward in five states on six large fires where in crews purposefully burned hundreds of square miles without regard to federal laws or environmental impacts.
Although these claims rest on court interpretations of NEPA, NFMA and the Tucker Act – which waives the government’s sovereign immunity in certain cases – Congress and the Forest Service should reread the still applicable 1897 Organic Act. Especially this section:
“No public forest reservation shall be established except to improve and protect the forest within the reservation, or for the purpose of securing favorable conditions of water flows, and to furnish a continuous supply of timber for the use and necessities of the citizens of the United States.”
Reading the Organic Act
There is no better example of what Congress intended when it ratified the Organic Act than the government’s first ever timber sale in South Dakota’s Black Hills Reserve in 1899. Case No 1 was laid out by Gifford Pinchot, who six years later was President Roosevelt’s choice to be the first Chief of the newly minted Forest Service. You can learn more about Case No. 1 in “Black Hills Green,” our most recent edition of Evergreen Magazine here.
Can anyone in the Forest Service explain to us how their reckless use of wildfire conforms to the Organic Act or any other environmental law ratified by Congress since Franklin Hough was named first Chief of the Division of Forestry – forerunner of the modern-day Forest Service – in 1881?
Declaring War on Wildfire
We asked several Forest Service retirees to read Frank’s essay and tell us what they thought. Agreement was unanimous. What to do? In our opinion, it is time for Congress and resource management agencies to declare war on our wildfire pandemic. No more low hanging fruit. No more annual targets. No more managed fire, no more excuses, caveats or weasel words. War!
And who in Congress will vote for this long overdue declaration of war?
There are people working for the Forest Service who believe that what is happening is just plain wrong. But who in leadership positions in the Forest Service and Department of Agriculture leaders is willing to step forward and publicly declare war on our wildfire pandemic? Who will say to the agency’s 30,000 employees, “It’s gut check time. We are failing our mission and we look like damned fools.”
We did not enter World War II prepared or able to win. That we won so decisively is a tribute to presidential and congressional leadership, the rapid mobilization of our nation’s entire industrial complex, young men and women who volunteered to serve our country on the front lines and, last but certainly not least, the leadership of World War I veterans who knew how to fight to win.
We can win this war but we need to start fighting like winners. Now.