Draft SNFPA Management Review and Recommendations

Conformance with the National Fire Plan

New Information and Understanding Gained from Review

Inconsistencies with National Fire Plan

National Fire Plan direction has evolved over the last two years from the USDA Forest Service's original "Cohesive Strategy" to the finalization of the 10-Year Comprehensive Strategy Implementation Plan described above. The ability of the forests to implement an effective landscape level hazardous fuels reduction strategy is fundamental to meeting the obligation to effectively implement this plan. The Regional Forester is ultimately accountable for achieving this plan under the Government Performance and Results Act of 1993. Performance measures outlined within the plan will be used to evaluate successful outcomes. The detailed Cosumnes Landscape Analysis documented earlier in this report surfaced significant barriers to the successful implementation of the fire and fuels strategy in the SNFPA. Thus, the Team found that while the priorities and goals are consistent, the expected outcomes under the ROD are not consistent with the "Goals and Implementation Outcomes" stated in the Implementation Plan.

Federal, state, tribal and local governments have endorsed the four goals of the Comprehensive Strategy. Forest Service units at the state and local level are expected to work collaboratively with other agencies to accomplish the associated implementation outcomes by specific dates. The Team has reviewed each goal and assessed the likelihood of achieving it under the existing management direction.

Goal One -- Improve Fire Prevention and Suppression -- Implementation Outcome -- Losses of life are eliminated, and firefighter injuries and damage to communities and the environment from severe, unplanned and unwanted wildland fires are reduced.

One of the measures of success (performance measure)in attaining this goal is the number of acres burned by unplanned and unwanted wildland fires. The analysis of the Middle Fork Cosumnes landscape provides evidence that the current direction will perform poorly under this measure since successful performance is predicated on reducing the number of acres burned.

While this performance measure strongly relates to developing and maintaining an efficient and well-trained suppression organization with improved prevention programs, it is also inextricably linked to implementing a successful strategy to reduce hazardous fuels across the landscape. Successful performance is influenced by the ability to reduce hazardous fuels to significantly lower wildfire intensity and rate of spread, thus directly contributing to more effective suppression efforts, and fewer acres burned.

The uncertainty of successful implementation of the fire and fuels management strategy adopted under the ROD was discussed in the FEIS. Alternative Modified 8 was identified as one of three alternatives that had the highest degree of uncertainty.^[7] Further analysis to more clearly determine the potential for successful implementation was not available when the ROD was signed.

While similar analysis of other representative watersheds will be useful, the Review Team's spatially explicit analysis of the Middle Fork Cosumnes landscape sheds more light on this uncertainty. It provides clear evidence that implementing the fire and fuels strategy under the existing suite of ROD standards and guidelines will not significantly reduce wildfire size and intensity across the bioregion. For example, on the Eldorado National Forest the number of acres per decade burned by wildfire is projected to increase to over 30,000 acres within 30 years under the current direction.  Other FEIS alternatives analyzed project a decrease below 20,000 acres per decade burned by wildfire over the same time period.

Goal Two -- Reduce Hazardous Fuels, Implementation Outcome -- Hazardous fuels are treated, using appropriate tools, to reduce the risk of unplanned and unwanted wildland fire to communities and to the environment.

The number of acres treated, and the number of acres treated per million dollars gross investment in targeted areas are two performance measures for goal two.

The Team found that the standards and guidelines in the ROD will allow for hazardous fuels to be effectively and economically treated within the defense zone of the urban-wildland intermix. However, outside this zone, the current standards and guidelines result in higher cost treatments. As discussed previously, treatment costs approximately doubled under current SNFPA direction. These elevated costs directly impact the current direction's performance under these measures.

A doubling of per acre costs reduces by one half the amounts of treatment acres possible under any fixed budget allocation. The current and reasonably foreseeable federal budget situation makes it unrealistic to expect that hazardous fuels treatment allocations will increase appreciably beyond current levels. Even if they did, expensive treatments indicated under the SNFPA would result in less acres treated per million dollars invested. As a result, it is very important that management direction enable the most cost efficient means to accomplish fuel treatments within environmental constraints. Because of this, the Team has found there is significant opportunity to better harmonize the SNFPA strategy and Goal Two of the Comprehensive Strategy.

Goal Three -- Restore Fire-adapted Ecosystems, Implementation Outcome -- Fire adapted ecosystems are restored, rehabilitated and maintained, using appropriate tools, in a manner that will provide sustainable environmental, social and economic benefits.

Performance measures for this goal include the number of acres moved to a better condition class, that were identified as high priority in total, and as a percent of total acres treated. Progress in the accomplishment of this goal is a key component of the Regional Forester's performance.

Condition classes 2 and 3 are the targets for treatment. Condition class 2 is composed of lands where fire regimes have been altered from their historic ranges creating a moderate risk of losing key ecosystem components as a result of wildfire. The vegetative composition, structure and diversity of lands in condition class 3 have been significantly altered due to missing multiple fire return intervals. These lands "verge on the greatest risk of ecological collapse."^[8]

The current estimate of acres in condition class 2 and 3 across the eleven Sierra Nevada National Forests is over seven million acres. Of this amount, about three million acres are thought to be in condition class 3.

This is one area in which the ROD is in significant conflict with the National Fire Plan. While the Implementation Plan goal is to restore fire adapted ecosystems, the ROD acknowledges that the amended direction "would increase homogenous vegetation structure across the landscape over time" and "would increase the potential for catastrophic effects when wildfire" occurs.^[9] Many District Rangers also pointed this out during the review. They told the Regional Forester that current direction attempts to maintain an unnaturally dense condition across the landscape. Fully one fourth of the Ranger responses indicated that the standards and guidelines prevented attaining ecologically desired conditions.

The current standards and guidelines limiting fuel treatment activities were not designed to restore or move forested landscapes toward their historic ecological condition. Instead, they were developed with the goal of minimally modifying fire behavior while avoiding short-term adverse effects to California spotted owl habitat. Because of this, they preclude embarking on meaningful restoration of the historic fire regimes and ecosystem function of the Sierra Nevada for at least the next few decades. This is not compatible with goal three of the Implementation Plan.

Goal Four -- Promote Community Assistance, Implementation Outcome -- Communities at risk have an increased capacity to prevent losses from wildland fire and the potential to seek economic opportunities resulting from treatments and services.

One performance measure is the percent of acres treated to reduce hazardous fuels by mechanical means with byproducts utilized. The current direction performs poorly relative to this measure.

While socio-economic effects were considered in the FEIS, relative to other potential outcomes, the SNFPA significantly limits the forests ability to design fuel treatments that allow utilization of commercial byproducts. A predictable, sustainable supply of forest products sufficient to sustain the local, community-based timber infrastructure was not an objective of Modified Alternative 8. Without this, there is likely to be a continued decline in the available equipment, labor, and processing facilities needed to address the objective of ecosystem restoration. Standards and guidelines that allow more flexibility to design hazardous fuel reduction projects which provide utilizable byproducts. would improve consistency with the National Fire Plan.

⁷ FEIS Volume 2, Chapter 3, part 3.5, page 305.
⁸ 10-Year Comprehensive Strategy Implementation Plan, page 18.
⁹ ROD page 24.

USDA Forest Service · Pacific Southwest Region