United States Forest Deschutes National Forest Willamette National Forest Department of Service 63096 Deschutes Market Road 3106 Pierce Parkway, Suite D Agriculture Bend, OR 97701 Springfield, OR 97477

File Code: 1950 Date: January 9, 2013

Dear Interested Party: The Deschutes and Willamette National Forests would like to know your concerns, questions, and suggestions regarding a project proposal to use management-ignited prescribed fire in the Mt. Washington and Wildernesses. The proposed project is called Prescribed Fire in the Wilderness: Scott Mountain and Planning Areas and is located in two distinct geographic areas on the Deschutes and Willamette National Forests. The project proposes to use management-ignited prescribed fire to protect wilderness values and reduce risk to values outside of the wilderness by modifying fuel conditions within the wilderness. Modifying fuel conditions within the wilderness would increase the likelihood that lightning- caused fires can play their natural ecological role in the wildernesses. Modified fuel loadings within the wilderness would also reduce the threat of wilderness fires moving outside the wilderness and improve safety conditions for firefighters suppressing fires that threaten to burn outside of the wilderness.

The 1964 Wilderness Act envisions areas that are dedicated to, “…a future untrammeled, undeveloped, natural environment1 ….” Ideally, natural processes - including lightning-caused fires – are the predominant disturbances within these special areas. To this end, Forest Service policy directs the agency to, “Permit lightning-caused fires to play, as nearly as possible, their natural ecological role in wilderness2…,” and to, “Reduce, to an acceptable level, the risk and consequences of a wildfire within wilderness or escaping from wilderness3.”

The existing condition of forest fuels in the Mt. Washington and Three Sisters Wildernesses often prevent wilderness and fire managers from allowing lightning-caused fires to burn within the wilderness because of the high potential for small fires to grow into large, high intensity fires that could burn beyond the wilderness boundaries. High intensity fires coming out of the wildernesses threaten resources and values outside the wilderness, such as recreation facilities, private lands, and habitat for threatened, endangered, or sensitive species. These fires are also very costly to suppress. Recent fires such as the Pole Creek Fire (2012) and the Shadow Lake Fire (2011) cost the government and taxpayers more than $5.7 million and $17 million, respectively, to suppress.

After considering the fuels conditions of the wildernesses, values at risk in and around these areas, the potential for fire to occur and spread outside of the wilderness, and the relative strategic benefits of several areas along the crest of the Cascades, fire and wilderness managers selected two areas, Scott Mountain and Cascade Lakes. Managers believe that using prescribed fire to modify fuels conditions in these areas could help improve the likelihood of lightning- caused fires to play their natural role in these wildernesses, will reduce risk to resources and

1 Excerpt from the Wilderness Act (1964) 2 (Forest Service Manual 2324.21) 3 Ibid

It’s Cool to Be Safe Printed on Recycled Paper

values outside the wilderness, and will improve safety conditions for firefighters in the event a wildfire does threaten those values outside of the wilderness. Your comments will help us identify issues to be considered in the environmental review of this proposal.

Location The proposed project lies in two distinct geographic areas – or planning areas- within the Mt. Washington and Three Sisters Wildernesses located on the flanks of the central Cascade Mountains of within the Deschutes and Willamette National Forests. These two geographic areas are the Cascade Lakes planning area located on the Deschutes National Forest and the Scott Mountain planning area located on the Willamette National Forest (see project vicinity map).

Cascade Lakes: Deschutes National Forest The Cascade Lakes planning area falls entirely within Deschutes County, Oregon, on the Deschutes National Forest. The planning area is situated on the north side of the Cascade Lakes Highway in the vicinity of Sparks Lake. The planning area is about 9,000 acres in size with about 8,800 acres within the boundaries of the Three Sisters Wilderness and nearly 280 acres of non-wilderness situated between the Cascade Lakes Highway and the Three Sisters Wilderness boundary (see Cascade Lakes Planning Area map)

For the Cascade Lakes planning area, the maximum area within which ignitions would be planned and managed extends along the Cascade Lakes Highway near to the Mirror Lake trailhead, and then runs west along the Mirror Lake trail. From the trail confluence near Mirror Lake, the boundary continues toward the northeast following the timberline to the Green Lakes area where the boundary then turns south and ties into the Cascade Lakes Highway near Todd Lake.

The legal description is: T.17, R.08, sections 32, 33, 34, 35, 36; T.17, R.09, section 31; T.18, R.08, Sections 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 16, 17, 18 and T.18, R.09, sections 5, 6, 7, 8, 17, and 18 W. M.

Scott Mountain: Willamette National Forest The Scott Mountain planning area falls entirely within Lane County, Oregon, on the Willamette National Forest. The area is situated north and west of Highway 242, in the vicinity of Scott Mountain and the 2010 Scott Mountain Fire. The area is about 5,700 acres in size entirely within the boundaries of the Mount Washington Wilderness (see Scott Mountain Planning Area map).

For the Scott Mountain planning area, the maximum area within which ignitions would be planned and managed extends east along the southern portion of the 2010 Scott Mountain Fire and then south to the lava flow adjacent to Hand Lake. From Hand Lake, the boundary continues west and north along the Mt. Washington Wilderness boundary until reaching the 2010 Scott Mountain fire perimeter.

The legal description is T15S, R07E, sections 21, 22, 23, 24, 25, 26, 27, 28, 33, 34, 35, and 36 W. M.

Existing Condition Some of the physiographic and current biological conditions of the wildernesses along the Cascade Crest make it very difficult for the Forest Service to allow lightning-caused fires to play their natural ecological role. These conditions also increase the risk to fire fighter safety of suppressing fires and to public safety because of the fires’ potential to spread outside the wilderness and move into high use recreation areas or private lands. Some of these conditions include:

Portions of the Three Sisters and Mt. Washington Wildernesses are long, narrow bands, orientated in a north/south configuration, that span both sides of the Cascade Crest. The wildernesses are narrower on the east slopes than the west slopes of the Cascades. This shape, combined with homogenous vegetation, increases the potential for large fires to move outside the wilderness. When wilderness fires do move beyond the wilderness in these fuel conditions, fire suppression activities are costly and often hazardous to fire fighter safety due to the remote locations of fires and the limited access. This has been demonstrated with multiple large fires that start within the wildernesses, including the 2012 Pole Creek fire within the Three Sisters Wilderness. A century of fire suppression across a landscape prone to lightning-caused ignitions and affected by insect and disease-caused tree mortality has resulted in a continuous and homogeneous arrangement of forest fuels. This “fuel continuity” creates a susceptibility to wildfires that have the potential to burn large areas with high intensity and high severity4 under certain weather and atmospheric conditions. Fire suppression in wilderness, while permitted, affects the untrammeled and natural characteristics of wilderness by suppressing a natural process. Additional impacts from suppression activities include, but are not limited to, ground disturbance from hand line construction, even edges on the landscape from backlighting, and the application of fire retardant.

Desired Conditions The desired fuels conditions within the wilderness areas are a mosaic of vegetation conditions and age classes. Modeling has shown that the desired mosaic would be very likely to affect future fire behavior characteristics, including reducing fire intensity and/or crown fire potential of future wildfires.

Purpose and Need for Action There are three interconnected purposes for the project:

1. Improve the likelihood that land managers could allow naturally ignited fires to burn within the wilderness to protect wilderness values

4 Fire intensity is the heat produced by a fire (generally indicated by flame length), while fire severity describes the impact of that heat on soil and vegetation. Higher elevation forests burn with high intensity (with flame lengths greater than 30 feet) and mixed to high severity (a mosaic of unburned or lightly burned surface fuels to completely consumed ground and/or canopy fuels).

2. Reduce threats to values at risk outside of the wilderness from a high-intensity fire starting within the wilderness 3. Improve firefighter safety and potential for successful suppression efforts when wildfires threaten to move outside of the wilderness Based on an initial evaluation of conditions within and outside wilderness, there is a need to modify fuels in the strategically located Scott Mountain and Cascade Lakes areas to achieve these purposes.

Proposed Action Taking management action in a wilderness, such as that proposed, is not undertaken lightly by the Responsible Officials. The effects of human intrusion into and management of the wildernesses have been and will continue to be carefully considered throughout the analysis and decision process for this proposal. Minimum tools and techniques that would have the least impact on wilderness values and meet the project objectives, including minimizing risk to fire management personnel, have been assessed using a Minimum Resource Decision Guide. This Guide helps to identify the minimum tool to use for any management task to maintain wilderness values and meet the purposes of the project.

Based on this preliminary assessment, fuel treatments conducted outside of the wilderness, by themselves, are unlikely to accomplish the purposes outlined in this letter. Although fuel management activities will continue in many of these same geographic areas outside the wilderness, and will help to support the purposes of this proposed action, our initial assessment has shown the need for human intervention within the wilderness to accomplish these purposes.

For project implementation, wilderness and fire managers expect that a helicopter(s) would be the minimum tool needed to ignite the prescribed fires. A helicopter would be expected to have less impact on the ground than the extensive use of hand crews to ignite fire at the desired scale, is less of a safety risk to personnel igniting the fire, and reduces some of the logistical challenges and therefore costs of the operation. Aerial ignition could be with use of Plastic Sphere Dispensers (PSD) or an aerial drip torch. Hand crews with drip torches would be expected to be used in concert with the aerial ignition in some situations for spot-lighting or to otherwise meet burn objectives.

Prescribed fire prescriptions and lighting techniques would favor surface fires5 with some crown torching. Applying fire aerially to trees would initiate crown fire, and is intended to consume foliage serving as canopy fuels. During wildfire events, canopy fuels contribute to fast moving crown fires and spotting, and are some of the most difficult fire behaviors to control.

Effects of the prescribed fire will likely vary in severity and amount of tree mortality depending upon the current vegetative conditions. For instance, tree mortality from prescribed fire in small diameter, dense lodgepole pine and mountain hemlock associated vegetative groups are expected to be high, killing a large percentage of the trees. Burned patches would range in size from tens to hundreds of acres and would consist of mostly blackened trees with scattered brown needled

5 A crown fire burns in the canopy of trees more or less independent of a surface fire; a surface fire burns loose debris including dead branches, leaves, and low vegetation; a ground fire consumes organic material beneath the surface litter of the forest floor.

trees killed by scorch or cambium6 heating. Tree mortality could be 100% in some areas, and other areas could have less mortality, creating a mosaic of burned and unburned patches across the planning area.

Planned ignition could occur at any time of the year with favorable fuel moisture and weather parameters and when air quality regulations can be met. Winter and spring provide opportunities to burn tree canopies utilizing an aerial platform for ignition while there is snow on the ground covering surface fuels. This approach would allow fire managers to ignite canopy fuels and surface fuels at different times, thus reducing fire intensities in areas that would otherwise be problematic. However, generating crown fires with prescribed fire would be more probable when foliar moisture levels are lowest during the summer and during the fall when new growth is complete, moisture reserves are low, and a wetting weather event is expected.

To maintain the natural character of wilderness with this prescribed fire, the proposed burning activity would utilize the least amount of human intervention possible before, during, and after the fire has been ignited. For instance, natural fire “breaks” in the landscape such as rocky areas and meadows would be utilized to the maximum extent possible as the boundaries for the areas within which the prescribed fire is expected to be contained. However, some areas would, by design, be specifically excluded from the direct application of fire or could require certain lighting or protection techniques to minimize the intensity of the prescribed fire where sensitive resources such as threatened or endangered species habitat, riparian reserves, or cultural sites occur.

Fire management personnel working within the wilderness would use holding techniques known as Minimum Impact Suppression Tactics (MIST) if holding actions are needed to contain fire spread within wildernesses. Ignitions would be expected and allowed to burn for several days depending on fire behavior, weather, and other conditions, and to be extinguished by natural conditions such as weather or topography. A final detailed prescribed fire plan and Minimum Resource Decision Guide would be prepared for each prescribed fire operation prior to igniting any prescribed fire. The prescribed fire plan identifies area specific fire management objectives and conditions under which the prescribed fire activity would be conducted and is approved by the Responsible Official for that location.

More specific information regarding the proposed action for each of the individual planning areas is included below.

Proposed Action: Cascade Lakes Planning Area: Deschutes National Forest Planned ignition opportunities have been strategically identified throughout the Cascade Lakes area. Specific areas and lighting conditions would be selected within the planning areas to naturally contain high mortality burned areas within 200 – 500 acre patches. Affected plant association groups include lodgepole pine and mountain hemlock.

There would be about 280 acres of mechanical and prescribed fire hazardous fuels treatments outside the wilderness between the wilderness boundary and the Cascade Lakes Highway to provide defensible space and increase the opportunities for firefighting personnel to safely

6 Inside lining of the bark of the tree that transports water and nutrients between the roots and the leaves

contain future fires within the wilderness. Treatments would include small diameter tree thinning, piling of logging slash, tree pruning, and the use of prescribed fire.

Most of the prescribed fire treatments would occur within the Three Sisters Wilderness area. Treatments along the Cascade Lakes Highway are within the Scenic Views Management Area of the Deschutes Forest Plan. Nearly 2,000 of the total acres included in the project area fall within a riparian reserve. Resources that would receive special design consideration within and outside the wilderness in this area include but are not limited to:

Habitat for the northern spotted owl Riparian Reserves Sisters Mirror Lake, Wickiup Planes, South Sisters/Devil’s Lake, Green Lakes, Soda Creek, and Spark Lakes trailheads Moraine Lake, Todd, , Mirror Lake, Wickiup Planes, Elks-Devil, South Sisters Climber, Green Lakes, Soda Creek, and Pacific Crest trails Mt. Bachelor Ski and Summer Resort Todd Lake Resorts and Campgrounds along the Cascade Lakes Scenic Byway Recreation Residence cabins Proposed Action: Scott Mountain Planning Area: Willamette National Forest Planned ignition opportunities have been strategically identified throughout the Scott Mountain Planning Area. Up to 30-50% of the area (1,700 – 2,850 acres) would be targeted for prescribed fire over a one to five-year period. Affected plant communities include mountain hemlock, pacific fir, and Douglas fir.

All of the proposed treatment area lies within the Mt. Washington Wilderness area. Nearly 1600 acres of this area fall within riparian reserves. The area is within the McKenzie Key Watershed. This watershed was identified as a Key Watershed in the Northwest Forest Plan to protect habitat for bull trout and spring Chinook salmon and water quality. Resources that would receive special design consideration within and outside of the wilderness in this area include but are not limited to: Habitat for northern spotted owl Riparian Reserves Boy Scout summer residents Bull trout spawning areas Historic Hand Lake Shelter Historic Highway 242 a National Scenic Byway listed on the National Register of Historic Places Scott Lake campground Robinson Lake, Benson, Deer Butte, Benson/Hand Lake, Scott, and Hand Lake trailheads Deer Butte, Hand Lake, Hand Lake Cutoff, Scott Way, and Benson trails

Land and Resource Management Plan and Other Management Direction The proposed action would meet the intent of the Wilderness Act, Forest Service policy and guidance related to Wilderness, and Forest-wide standards and guidelines and Management Area standards and guidelines as described in the Deschutes and Willamette National Forests Land and Resource Management Plans, as amended.

Decision Framework and Responsible Official The Cascade Lakes Planning Area is within the Bend-Ft. Rock Ranger District of the Deschutes National Forest. The Scott Mountain Planning Area is within the McKenzie River District Ranger on the Willamette National Forest. The Forest Supervisors for the Willamette and Deschutes National Forests are the Responsible Officials for approving this project.

Based on the analyses presented in the NEPA document and the project record, the Responsible Officials will decide whether to authorize the action as proposed or with slight modifications; to select an alternative to the proposed action that would meet the purpose and need for action; or to take no action.

How to Participate and Submit Comments You are invited to comment on this Proposed Action. We recognize that access to this area during the winter is limited. We are requesting your initial thoughts, based on what you may already know about the area and what we’ve included in this letter, by February 15, 2013. That may help guide our initial analysis. If there is interest, we intend to hold field visits to help explain this strategy and the importance of the proposal considered here. Your comments now will help identify your interest in future development of the proposals. Your initial comments can also help to identify issues that you think should be considered in the environmental review.

Please submit your comments to the Prescribed Fire in Wilderness Project: Scott Mountain and Cascade Lakes Planning Areas , Attention: Geoff Babb, 63095 Deschutes Market Road, Bend, Oregon 97701; Telephone (541) 383-5571; FAX (541) 383-5531; email: comments- [email protected]. Those submitting hand-delivered comments may do so during the regular office hours of 8:00 to 4:30 Monday through Friday except legal holidays.

Those submitting electronic copies must do so only to the email address listed above, must put the project name in the subject line, and must either submit comments as part of the e-mail message or as an attachment only in one of the following three formats: Microsoft Word, rich text format (rtf), or Adobe Portable Document Format (pdf).Thank you for your interest in wilderness management on the Deschutes and the Willamette National Forests.

Sincerely,

/s/ Gordie Blum /s/ John Allen MEG MITCHELL JOHN ALLEN Forest Supervisor Forest Supervisor, Deschutes National Forest Willamette National Forest