California Board of Forestry and Fire Protection Attn
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California Board of Forestry and Fire Protection Attn: Edith Hannigan, Land Use Planning Program Manager PO Box 944246 Sacramento, CA 94244-2460 Email: [email protected] Re: Notice of Preparation, VTP PEIR February 25, 2019 Dear Members of the Board, Thank you for revisiting the idea of revamping the Vegetation Treatment Program (VTP) and creating a new plan that has the potential of being a model, collaborative effort. With this letter, we offer 24 recommendations that will help guide you in shaping a fire risk reduction effort with the achievable goal of preventing wildfire catastrophes. As renowned US Forest Service fire scientist Jack Cohen has been demonstrating with his research for decades, while large wildfires are inevitable, the destruction of our communities is not. At the outset, however, the Board must reject the fuel-centric approach as described in the Notice of Preparation (NOP). With this, the 6th attempt since 2005 to produce a wildfire risk reduction plan for the state, the NOP is focusing again on the scientifically rejected notion that “the treatment of fire fuel” can “prevent wildfire” in State Responsibility Areas (SRA). The NOP’s prevention claim is based on the 95 percentile fires that can be controlled by traditional wildland firefighting strategies. It ignores, however, the wind-driven fires that cause nearly all the devastation to our communities. We also respectfully challenge the Board to question the NOP’s fundamental assumption that “decades of fire suppression” is directly responsible for the state’s most catastrophic wildfires. We are unaware of any research that directly ties fuel accumulation due to past fire suppression to the loss of life and property in any of the state’s most devastating wildfires. As evidenced by the 2017 and 2018 wildfires, the approach exemplified by the NOP is failing us. The focus must be on the wind-driven, fine-fueled, ember-generating fires that cause nearly all the loss of life and property. Otherwise, the next Vegetation Treatment Program will likely 2 make the landscape more flammable, not less, by increasing the non-native grass component (Syphard and Keeley 2015) and intensive forest management (Zald and Dunn 2018). Ignoring where the risk is greatest Despite overwhelming evidence indicating that fuel accumulation from past fire suppression applies only to some forested landscapes, the NOP claims the impacts of fire suppression is a key factor in creating fire risk to communities throughout California. This is false and is based on a forest-centric focus that does not recognize where the majority of the fire risk occurs for most Californians. Even the previous VTP Programmatic EIR partially recognized this distinction. Decades of fire suppression had nothing to do with the most devastating wildfires the NOP cites as providing the rationale for a new and expanded VTP. There are approximately 15 million acres of mixed conifer/ponderosa pine forests in California that may have missed several fire return intervals due to past fire suppression. Most of these forests are far from the communities most impacted by the 2017 and 2018 wildfires. Yet the NOP cites these forests as the main rationale for the program’s necessity. In contrast, the vast majority of the population at risk of wildfire live in and around approximately 12 million acres of native shrubland habitats, habitats that have suffered too much fire and as a consequence are at risk of type conversion to more flammable, weedy grasslands. Rather than suffering from decades of fire suppression, native shrublands have suffered from too much fire. This too was recognized by the previous draft EIR. So why is the NOP reverting back to previously erroneous assumptions about past fire suppression, assumptions that have been criticized by the Joint Fire Science Consortium, the National Park Service, the California Department of Fish and Wildlife, and many environmental organizations? Ignoring embers Despite overwhelming evidence that embers, flying more than a mile ahead of the fire front, are responsible for igniting communities far from wildland areas, the NOP is focusing on the same vegetation treatment strategies that do next to nothing to protect us from wind-driven wildfires. Coffey Park during the Tubbs Fire presents a classic example - embers blew over at least a mile of suburban development and vacant land, in addition to 300 feet of roadway (Highway 101), before igniting the community. This story has been repeated over and over again since the 2003 Cedar Fire in San Diego County. To justify the distant treatments of heavy fuels, some have claimed such treatments will significantly reduce the volume of embers hitting communities. Such a claim is unsupported by research and highly questionable, especially considering the production of embers during fast moving grass fires. Ignoring flammable, fine fuels Despite overwhelming evidence that significant portions of the Tubbs, Thomas, and Woolsey fires were fueled by non-native, invasive grasses, fuels that typically increase after fuel treatments, the NOP appears to focus primarily on the larger fuels that create the dramatic, large flames that are rarely responsible for the destruction of communities. Fire after fire has proven that few homes burn because of direct contact with flames from wildland fuels. Homes ignite by wind-driven embers generated by small diameter fuels often burning miles away. 3 The importance of small diameter fuels, and why habitat clearance projects fail to protect Californians from wind-driven wildfire, was demonstrated during the Camp Fire, a fire the NOP highlights as justification for even larger habitat clearance projects. One of the primary reasons the Camp Fire was so destructive was the condition of approximately 30,000 acres it burned through on the way to the town of Paradise. The terrain had been burned ten years before, had been salvaged logged, and contained numerous tree plantations (Fig. 5). This was not the landscape the NOP describes as suffering “decades of fire suppression.” In fact, one of the reasons the fire moved so fast was because there wasn’t a dense forest to slow down the fire’s wind-driven forward movement. A similar situation occurred when the 2013 Silver Fire in San Bernardino County burned through the 2006 Esperanza Fire scar (forty structures were destroyed in 2013, ignited by embers created by young fuels). According to assumptions underlying the NOP, a destructive fire driven by seven-year-old fuels is not supposed to happen. Ignoring science on how best to protect communities Despite overwhelming evidence from decades of research by Jack Cohen that shows reducing community flammability is the most effective way to protect lives and property, the NOP never mentions the subject once. We can stop wildfire disasters in our communities, but the VTP must be based on the most basic scientific principal of reducing wildfire risk - the wildfire problem is a home ignition problem, not a wildfire control problem. Misguided ecological restoration As with previous draft EIRs, the current NOP makes a sweeping statement about “restoring ecosystem processes” without acknowledging that such treatments only apply to limited areas, specifically some lower elevation, mixed conifer forests. Although the last draft EIR discussed this issue, the action portion of the draft contradicted the text by presenting maps of potential “ecological restoration” areas that did not need to be restored. The NOP appears to be on the path of repeating the same contradiction. Utilizing anecdotal evidence rather than scientific research Yes, there are a considerable number of examples of fires stopping or being controlled at previous fire perimeters and fuel treatments. Examples of such events were cited in previous draft EIRs. However, when examined scientifically, where a full set of data are examined, other variables are typically involved, particularly changes in weather. This is especially true when it comes to wind-driven fires, the fires the EIR must address. Typically, the most destructive wildfires only stop when the weather cooperates. The Board, Cal Fire, and the State of California must reexamine the fundamental assumptions about wildland fire to enable it to better protect Californians. It needs to be recognized that the fire threat is not miles away in forests, but within heavily populated suburban environments. We must accept the fact that like earthquakes, we cannot stop wildfires, but we can certainly limit the damage they cause. Unless wildland firefighting assumptions are reexamined and changed to adjust to our changing environment, the types of wildfire disasters we have faced since the 2003 Cedar Fire will continue. In fact, the NOP’s approach will likely increase the flammability of the landscape by: 4 1. Focusing on forested areas far from where California’s most devastating fires occur (Fig.1). 2. Facilitating the movement of embers toward homes through unwise clearance projects (Fig. 2). 3. Increasing the amount of flashy fuels (non-native grasses and weeds) (Fig. 3). 4. Increasing fire rate of spread by opening up forests (Figs. 4 and 5). 5. Failing to address the most dangerous accumulation of dead fuels – homes (Fig. 6). Homes burn because they are flammable and are built on fire-prone landscapes. Most structures ignite during wildfires because of flying embers. This is why so many families have lost their homes even though they have complied with defensible space regulations – their homes were still vulnerable to embers. This is why communities far from wildland areas have been destroyed during wildfire and why entire neighborhoods have burned to the ground while the trees around them have not (Fig 7). This is why fuel breaks, twelve-lane highways, and even large bodies of water fail to protect our homes during wind-driven wildfires. We understand that logging, clearing habitat, and fighting wildland fire are how the Board and Cal Fire have traditionally approached fire protection.