Graphic: The Forest Advocate
Fuels reduction treatments are the Forest Service’s primary strategy for reducing high severity fire and increasing “resilience” in dry forests. These treatments typically involve cutting large amounts of trees and understory from forests, followed by repeated prescribed burns. But do the benefits of such treatments outweigh the substantial ecological and social risks and costs? This question should be comprehensively considered in a cost/benefit analysis for each proposed vegetation reduction project. Conservation strategies should be developed that ensure forest restoration projects are a net benefit.
The Forest Service claims that it is not required to compare the ecological and social costs and benefits of its large-scale cutting and burning project proposals under the National Environmental Policy Act (NEPA). Whether this contention is legally defensible or not, failing to weigh the benefits of large-scale fuels treatments against the risks and costs is an egregious violation of the agency’s responsibility to the public. The costs of potential ecosystem degradation and escaped controlled burns require careful consideration. As the climate becomes warmer and drier, it is increasingly difficult to design dry forest vegetation treatment plans so that they provide net benefits. NEPA requires that the public be informed about the potential consequences of projects, and a cost/benefit analysis is key to understanding the relative importance of consequences.
Fire — including high-severity fire — is a natural and important aspect of forest ecology. Under the right conditions, fire can promote biodiversity and ecosystem renewal. However, in recent decades, acres burned at high severity have been increasing, although there is still a historical fire deficit. Climate transition has made conifer regeneration after high-severity fire much less certain: it is often delayed, and sometimes appears to fail altogether, resulting in some forested landscapes type-converting into shrublands. Fuels reduction treatments can reduce the number of acres that burn at high severity for a period of time, but this benefit must be weighed against serious tradeoffs.
The agency claims that vegetation management treatments improve ecosystem resilience, but their treatments often appear to degrade ecosystems. Cutting and burning treatments frequently cause substantial ecological damage, such as soil erosion and compaction, damage to the trees that are left standing, bark beetle infestation, tree blowdown (because removing trees from a grouping decreases structural support for the remaining trees), sediment flow into waterways, and disruption of wildlife habitat. Cut areas are subsequently treated with prescribed fire at overly-frequent intervals. The natural understory tends to not return, and uncharacteristic understory often develops, including invasive species. Or little understory grows back at all, except for some grasses. The remaining landscape often becomes overly open, dried out, and ecologically stunted and dysfunctional.
Trees are already dying from drought stress and other impacts of climate change, which in many cases may amount to substantial vegetation reduction. Also, when considering how many fewer trees may burn during a high severity fire within treated areas, that estimate should be counterbalanced by the number of trees cut and burned during treatments. Often, more trees are destroyed by fuels reduction treatments than by wildfires.
Current fire ecology research indicates that the number of fuels treatments that have been encountered by a wildfire have been fairly low, less than one percent per year, although encounters are increasing due to climate change. This means that most vegetation reduction treatments will provide no benefit in terms of fire mitigation. Fuels reduction treatments have been shown to be of decreasing benefit during the very high intensity fires that burn during increasingly hot, dry and windy weather. Additionally, very open treated forests tend to be drier, and in some cases more flammable than forests with more closed canopies.
Whether forests should receive fuels reduction treatments, and what particular treatments should consist of, should be thoroughly and genuinely considered at the project level within environmental impact statements (EIS), which are the most comprehensive level of NEPA analysis. The goal of any forest treatment should be long-term forest restoration, while avoiding forest degradation. It’s an increasingly complex undertaking to determine which interventions will support forest restoration and which will result in forest degradation, and any attempt to find a “sweet spot” that provides a net benefit requires nuanced site-specific analysis.
Environmental impact statements consider a range of alternative actions, while less detailed environmental assessments typically include just an Action and No Action alternative. However, rarely, if ever, does the Forest Service complete a cost/benefit analysis of the alternatives, which should be part of any EIS. Although the agency must disclose potential environmental and social consequences of proposed actions, it is not required to select the alternative with the greatest net benefit or the fewest adverse impacts. Adverse impacts that are “necessary” to accomplish a project’s “purpose and need” are considered by the agency to be acceptable. A project’s purpose and need is generally based on a number of assumptions, some of which are often controversial, highly uncertain, or unproven.
In order to rationally compare costs and benefits of alternatives, it is necessary to base analysis on valid assumptions. Often, the Forest Service uses models that do not reflect current or future conditions and rely on best or worst case scenarios, resulting in analysis that is fundamentally flawed. An example of this is the assumptions that underlie the air quality section of the Santa Fe Mountains Project environmental assessment. In the Santa Fe area, prescribed burn smoke is a major issue because it seriously impacts vulnerable residents’ health. In order to analyze the air quality impacts, the Forest Service based their analysis on two assumptions:
– Not implementing the proposed project would result in the project area burning in its entirety – that is, two discontinuous sections spanning 18 miles.
– Implementing the proposed project would result in no wildfires at all occurring over a 10-year or more period.
These types of clearly extreme and unrealistic baseline assumptions undermine any meaningful analysis. Such a skewed approach can support predetermined outcomes … and it usually does. The resulting analysis can be considered largely irrelevant – garbage in, garbage out. Responsible and legitimate analysis must be based on meaningful and real-world assumptions.
A meaningful comparison of costs and benefits of vegetation treatments also requires appropriate reference conditions. Reference conditions help define and inform what condition ecosystems should be restored to, after ecosystems have been damaged, degraded, or destroyed. The Forest Service continues to rely on historical reference conditions to determine the desired condition for projects post-treatment. But due to the rapidly changing climate, historical reference conditions are now largely obsolete for forest restoration project design and analysis. In order to truly restore forests, the agency must utilize current reference conditions that represent areas with high ecological integrity and that have the least amount of impacts from grazing, mining, logging and other fuels reduction projects, road construction, and invasive species, etc. Current reference conditions are virtually never considered by the agency, so little meaningful basis is provided for a cost/benefit analysis of potential project effects.
Without a comprehensive cost/benefit analysis, fuel reduction projects are essentially a shot in the dark and may result in disasters. The 342,000 acre Hermits Peak/Calf Canyon Fire, which was ignited in the Santa Fe National Forest in 2022 due to two separate escaped Forest Service prescribed burns, illustrates the need for balancing risks with benefits when designing and analyzing fuels treatment projects. The adverse consequences of these fires, including burning out entire communities and thousands of acres of forest in which conifers may or may not substantially regenerate, far outweigh any possible benefits that the fuel reduction treatments might have provided. The landscape was too dry for broadcast prescribed burns to have been implemented safely enough during the spring windy season. Fire can escape from smoldering slash piles when the snow has melted off of the ground, especially in very dry forests. Overly cut areas open up the tree canopy so much that vegetation dries out and becomes more flammable. Trees that have blown over due to overly aggressive thinning can create a fire hazard. These concerns should have been weighed against the potential benefits of the treatments in the project analysis.
By doing so, genuine mitigations could have been incorporated into the project plan, which may have greatly improved the outcome of the project. Appropriate mitigations could have included limiting burning to only the safest burn windows, which means refraining from burning during the spring when high winds are abundant. Also, refraining from overly opening up the forest canopy during tree cutting operations in order to retain moisture in the soils and vegetation, and greatly reducing the number of piles of thinning debris by implementing only very limited and strategic thinning.
In recent years, the Forest Service has been generally unwilling to prepare environmental impact statements for vegetation reduction projects. And the Trump administration is now in progress of rapidly and radically rolling back NEPA analysis and protections. Their impetus is to rush into cutting and prescribed burns as quickly as possible, with little environmental review, and increasingly under emergency authority. Such truncated review prohibits reasonable cost/benefit analysis and will likely bring about more disasters to our forests and communities. Recently the US House of Representatives passed the “Fix Our Forests Act,” which supports more logging of our forests, while further rolling back environmental analysis and safeguards for logging and other fuel reduction projects. The Act is now awaiting a vote in the Senate. The public still has the opportunity to let Senators know that the Fix Our Forests Act will not “fix” forests, but instead will degrade our forests. It will take immense pressure from the public to require responsible analysis, but it is absolutely necessary in order to maintain ecologically functional forests into the future.
It is incumbent upon forest managers and the conservation community to develop a new holistic management paradigm for dry forests in a warming and drying climate – an approach that strongly focuses on strategies that increase moisture retention in forests, instead of overly opening up tree canopy by aggressive cutting and burning. Vegetation treatment timing and soil and vegetation moisture must be carefully considered. Under certain conditions, a treatment may be a net benefit; under different conditions, the adverse impacts may substantially outweigh the benefits of the same treatment. Given the high potential for adverse impacts, careful analysis may support only limited, light-handed thinning that preserves substantial tree canopy and natural understory.
The primary focus of forest restoration should be to support the retention of water in ecosystems by very conservatively utilizing already known approaches – and by developing new conservation approaches suitable for dry forests undergoing climate transition. Approaches can include earthworks to allow water to infiltrate into soils, promoting beaver habitation in order to retain water, decommissioning unnecessary forest roads that cause water run-off, removing cows from forest lands, and restoring soil mycorrhizal fungi which hold soil moisture.
If there is a genuine desire to protect and restore forests, then there should be an effort to fully and deeply consider and weigh the short-term and long-term effects of all forest interventions, with an attitude of learning, a deep holistic understanding of forest ecology, and a concern for local communities. During the upcoming storm of NEPA rollbacks and ensuing forest degradation, it is more necessary than ever to actively support responsible and reasonable project analysis.
Forest apparently type-converting as a result of vegetation reduction treatments. Such a result was not realistically considered in a cost/benefit analysis — La Cueva fuel break, Santa Fe National Forest Photo: Sarah Hyden
