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 Three Sisters Wildernesses. The proposed project is called Prescribed Fire in the Wilderness: Scott Mountain and Cascade Lakes 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 Oregon 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 Todd Lake 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