A Real Cohesive Strategy
The Quincy Library Group's Response to the GAO Report
and the Forest Service Response

June 5, 2000

“Because of the high proportion of total area classified as high-risk, combined with the fact that without treatment more vegetation will 'grow' into these high-risk conditions, it is apparent that time is running out for a strategy to successfully avert high-cost, high-loss consequences.”
                                                -- Forest Service Response to the GAO Report, pg 14.    

    In April 1999 the Government Accounting Office (GAO) reported that “...the most extensive and serious problem related to the health of national forests in the interior West is the overaccumulation of vegetation, which has caused an increasing number of large, intense, uncontrollable, and catastrophically destructive wildfires;” and that “...the Forest Service has not yet developed a cohesive strategy for addressing several factors that present significant barriers to improving the health of the national forests by reducing fuels.” (GAO 1999)

    The Forest Service response of April 2000 (USDA FS 2000) agrees that there is very high and growing fire hazard to our inland western forests, and specifies the scale and pace of effort that will be required to reduce that hazard to an acceptable level. These are by far the best words the Forest Service has published on fire protection strategy for inland western forests, so what follows is intended to support and improve the Cohesive Strategy, not oppose it.

    The most difficult problem presented by the Forest Service Cohesive Strategy is that it places too great a reliance on prescribed fire as the primary tool for fuel reduction. Although it says the strategy “...relies on a variety of treatment options to achieve restoration objectives -- including mechanical thinning, some harvest, and prescribed fire,” the emphasis is clearly on prescribed fire, not mechanical thinning or harvest. Even where other methods are said to be appropriate or necessary, they are always described as preparation for the use of prescribed fire on virtually every acre treated.

    For the reasons outlined below, the Quincy Library Group does not believe it is feasible to use as much prescribed fire as is proposed by the Cohesive Strategy, but that other methods of removing fuel and thinning overgrown stands must be more widely employed, in addition to making the best possible use of such prescribed fire as the public will accept. A strategy is not real unless it can be implemented.

The Required Scale and Pace of Treatment.

    The Forest Service Cohesive Strategy identifies 40 million inland western acres that require fuel reduction within 15 years. It proposes a gradual increase to 3 million acres per year, treating 10 million acres during the first 5 years and the remaining 30 million acres in the following 10 years. That is more than five times as much fuel reduction as would occur if the current rate were continued. This increase of scale and pace are required because without these treatments “...wildfire suppression costs, natural resource losses, private property losses, and environmental damage are certain to escalate as fuels continue to accumulate and more acres become high-risk.” (USDA FS 2000)

Limits on the Use of Prescribed Fire.

    Without doubt some measure of fire use must underlie any successful strategy for sustainable management of our inland western forests, but it is a stretch well beyond 21st-century reality to assume that these forests can be largely restored and maintained by fire. Leaving aside the political difficulty of proposing such a program in the face of recent catastrophic escaped fires like Lewiston, Los Alamos, and the North Rim of the Grand Canyon, there are other technical, social, and economic barriers to a major dependence on prescribed fire.

    On the technical side, due to retirements and several years of cutbacks in overall personnel levels, the Forest Service has fewer experienced people to conduct prescribed fire and fewer backup suppression forces to protect against a catastrophic escape. Neither expertise nor backup capability is likely to recover its former level, much less be expanded and improved. Furthermore, any expanded program of prescribed fire will increasingly have to deal with “hard acres” that contain the heaviest and most volatile fuel loads, not just the “easy acres,” and this inevitably means less safety margin.

    When you have to burn more numerous and more difficult high-risk acres, your only choices are to push the edges of available “windows” of safe weather conditions, or put more fires or larger fires into each window. Either way you overload available resources and require them to operate in more difficult conditions where the probability and hazard of escaped fire are increased.

    Already, according to the Sierra Nevada Conservation Framework Draft EIS, there is one escaped prescribed fire for every 20,000 acres burned. The public already finds the number of escapes unacceptable. How would the public react to five times the current number of escapes? In fact the situation would very likely be worse than that, because the increased burning would have to be done in more difficult and dangerous conditions, so it is unlikely that even the current rate of one escape for every 20,000 acres burned could be maintained, much less improved.

    On the social side a major barrier to increased use of prescribed fire is a growing public intolerance of smoke. The Cohesive Strategy tries to deflect that concern by arguing that the public's choice is either accept more smoke from prescribed fire now, or a lot more smoke from wildfire later. But the public is not in the mood to buy that argument. For good reason they want major reductions in smoke from both kinds of fire, not a play-off of one against the other. In other words, though fire is a necessary component of any long term strategy for managing fire-adapted inland western forests, in fact the use of prescribed fire will be severely limited by political, technical, economic, public health, and safety considerations.

    What do we do when a necessary resource is in short supply? A rational person would reserve the scarce resource for the uses where it is of greatest value. With prescribed fire the uses of highest value are probably to facilitate regeneration of fire-dependent tree and plant species, control pathogens, recycle nutrients, and reduce fuel in high hazard areas where no other treatment is feasible or permitted. High priority uses emphatically do NOT include routine fuel reduction in stands where other treatments are feasible, and prescribed fire is particularly not justified where it is used in two or three sequential treatments over several years, in an attempt to achieve the desired fuel regime with fire alone.

    Given the practical limits on use of prescribed fire, there is no rational choice except to shift emphasis toward other methods for removing the over-abundance of small and middle-size trees that are the major threat to remaining old growth stands, wildlife, and all other beneficial use of our national forests.

Other Methods of Removing the Excess Fuel.

    The over-abundance of small and middle-size trees in so many of our western forests is a major threat to overall forest health because it makes the forests more susceptible to drought, insect infestation, disease, and above all to catastrophic fire. It is not only fuel on the ground that creates hazardous conditions, it is also, and probably more so, the “fire ladder” trees, because they readily carry fire from the forest floor into the crowns of the larger trees that would otherwise survive a ground fire. This susceptibility to crown fire almost always marks the difference between a small fire with little damage and a large fire with catastrophic damage. Removing these fire ladder trees is the single most necessary and most effective measure to reduce the likelihood of catastrophic fire. In other words, it isn't sufficient to “clean up” the forest, in many places it must be “thinned out.”

    What methods are available for thinning fire ladder trees from over-crowded stands? The Quincy Library Group has recommended a comprehensive and balanced program that includes a strategically placed fuelbreak network, group selection, and individual tree selection, as well as reserves in roadless or other sensitive areas, and riparian area protection and restoration. Silvicultural management on the basis of group selection can put a solid foundation under all other fuel reduction and maintenance operations in the actively managed area. In reserves and other areas where mechanical fuels treatment is not feasible or permitted, hand thinning and prescribed fire would be the treatments of choice, and prescribed fire should be largely reserved to meet those needs.

    The QLG program may not be appropriate for other areas or all situations, but it illustrates the comprehensive approach to fuel reduction, with full attention to other necessary aspects of national forest management, that is required of any program that is capable of actually addressing the fire hazard in appropriate balance with other problems that must be faced.

Paying for the Necessary Fuel Reduction.

    Using means other than prescribed fire to remove excess fuel can produce revenue to offset some of the cost. For example, the recently completed Herger-Feinstein QLG Pilot Project EIS estimated three dollars of federal revenue for every one dollar spent on the combination of strategic fuel reduction and group selection silviculture.

The Herger-Feinstein QLG Pilot Project is Ready to Go.

    This Pilot Project has a completed EIS and is ready to go. It is the only place in the National Forest System where fuel reduction at the scale and pace specified in the Cohesive Strategy can actually be put on a significant area of national forest land without delay IF the administration decides to implement the HFQLG Act fully. After Congress wisely anticipated the growing fire hazard by passing the HFQLG Forest Recovery Act in 1998, it is inconceivable that a truly cohesive strategy would fail to assure its full implementation.

Viable Alternatives to a Comprehensive Fuel Reduction Program.

    There are none. QLG wholeheartedly supports a Forest Service conclusion stated in its Cohesive Strategy paper: “...'letting nature take its course' is not economically nor ecologically appropriate.”


     GAO, 1999. Western National Forests: A Cohesive Strategy to Address Catastrophic Wildfire Threats, Report to the Subcommittee on Forests and Forest Health, Committee on Resources, House of Representatives, April 1999, The US General Accounting Office. GAO/RCED-99-65

     USDA Forest Service, 2000.  Protecting People and Sustaining Resources in Fire-Adapted Ecosystems -- A Cohesive Strategy. The Forest Service Response to the GAO Report, GAO/RCED-99-65, April 13, 2000.

Other information

A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats Hearing before the Subcommittee on Forests and Forest Health of the Committee on Resources, House of Representatives, One Hundred Sixth Congress, First Session, June 29, 1999, Washington, D.C. (text version)