A Double Standard?

The QLG Mitigation and the Management of
the Bucks Fire on the Plumas National Forest

The primary mitigation imposed by the USFS on implementation of the QLG Act is the prohibition of thinning and timber harvests in California spotted owl habitat. Absent any other management changes, according to USFS, the mitigation will result in no loss or degradation of California spotted owl habitat. Wildfires (on at least the Plumas National Forest) in August and September (1999) and USFS suppression tactics, have led to demonstrable loss and degradation of California Spotted owl habitat. This fact has been minimized or ignored to date by USFS. The USFS imposes strictures on implementation of the QLG Act (an attempt to increase fire resiliency through thinning near existing roads) that it ignores for its own, predictable, fire suppression activities.

At the site-specific project level...harvest areas will be designed and implemented to completely avoid California spotted owl habitat, including nesting habitat and foraging habitat.[Record of Decision, p.6, 8/20/99]

A Supplement to the [mandated] Biological Assessment/Biological Evaluation issued by USFS at the same time concluded (p.1) that:

Consequently, the threat to the spotted owl's long term viability caused by the pilot project management activities will be greatly reduced if not eliminated. With the mitigation there would be neither loss nor degradation of any nesting or foraging habitat. The number of home ranges with more than 50% suitable habitat will remain the same as the existing situation. Habitat fragmentation across the westside /transition Zones of the planning area...would be minimized.[Emphasis added].

The full BA/BE stated (p.59) that there were a total of 366 so-called PACs and SOHAs for California spotted owls in the three national forest project areas involved in QLG. The Plumas NF had 244 or 2/3s of these areas.

A series of wildland fires began in Northern California on August 22; just after the Record of Decision was adopted. Four of the fires (Lookout, Pidgeon, Bucks and Devils Gap) were on the westside of the Plumas NF and burned 40,000 acres into October.

The fires began on August 22 throughout Northern California after a dry lightning storm. The PNF Lightning Fire Summary, issued on 8/25, counted a dozen fires in progress on the Plumas National Forest alone. These included two fires greater than 1000 acres. There were two adjacent smaller fires in the (North Fork) Feather River Canyon-- referred to as Bucks and Big, both at 60 acres, both "monitored, not staffed". By 4 PM on that day, the PNF Summary reported both fires at 100 acres and still "not staffed". The 8/27 PNF Summary reported that Big (590 ac.) and Bucks (420 ac.) both had grown significantly but had been "scouted" by then. There were three other fires burning more than 1000 acres each at that time and nine uncontrolled fires. Big (1230 ac.) and Bucks (754 ac.) continued to grow through 9/29 but were staffed with firefighters by that time. The canyon highway (SR70) was closed for a time. There were four other uncontrolled fires over 1000 acres on the Forest. The next day, Big (1427 ac.) and Bucks (1810 ac.) became the largest uncontrolled fire "complex" on the Forest but there were still four other uncontrolled fires greater than 1000 acres. Big and Bucks totaled 4080 acres by the last day of August. The two fires were consolidated into "Bucks" as of September 2 at 6800 acres. All but two of the other major fires were contained by that date. .

*PNF Summary*
Date	Acres	*Summary* noted activity
8/31	4080	Indirect bulldozer line begun at top of fire
9/3	7100	Building a second defensible perimeter
9/4	9120
9/5	11720	Line construction along Oroville-Quincy Hwy.
9/6	12545
9/7	12900
9/8	14050	Firing operations at NE and SW corners
9/9	15400
9/10	19816	5 miles of indirect line and burnouts constructed
9/11	22300	Burnouts to East. Complete N & S. 15% Contained.
9/12	24613	Burnouts continue. 50% contained.
9/14	34175	100% contained

The Bucks Fire (Bucks) burned 34,175 acres (source: USFS Burned Area Report [BAR] 11/29/99). A total of 12,179 acres burned with high intensity and 27, 251 acres with either high or moderate intensity on these three fires (80% moderate or severe). High intensity means that all the ground cover, shrub and overstory have been consumed. Moderate connotes that ground cover and most of understory has been consumed. The overstory has been scorched but needles/leaves are still in place.

The Bucks Fire BAR analysis states that: "There is no known rare, threatened, or sensitive wildlife species or habitat within the burned area. Several California spotted owl PACs and SOHAs are included in the fire perimeter. Impacts to PACs and SOHAs varies."

The Plumas National Forest Land and Resource Management Plan (c. 1988) predated the establishment of formal PACs. Seven California spotted owl habitat areas were established in the two Management Areas [Grizzly Dome (#2) and Bucks(#5)] affected by the 1999 fire (pps. 4-125 and 1-143).

Two recent PNF produced maps were reviewed for this report. A black and white administrative and topographical map (developed contemporaneously with the fires) was called Bucks Fire Operational Containment Lines -9/12/99-1:28,000. A later multi- colored map, developed after fire overflights on 9/28/99, was called Bucks Fire Preliminary Fire Intensity Map- 10/19/99. The two maps are of similar scale.

The first map locates bulldozer and hand lines cut by the forest service as well as support areas, such as retardant bases, safety zones and helispots.

The second map defines those areas that burned at the various intensities noted in the BAR and also locates PACs and SOHAs across the landscape.

The Intensity map located at least four (multiple territory) PAC areas and one SOHA that were affected by the fire.

The SOHA is located in the Bucks Lake 7.5 Quad Map (USGS) and there are three nearby PAC territories. One of the three nearby gerrymandered PAC areas is in this same quad and is contained within the SOHA. The two other irregularly shaped PACs are located just to the West in the Storrie Quad map. The entire area is north and west of Lower Bucks Lake on the long westward slope above the Feather River Canyon. 20% of the SOHA burned to moderate intensity. The Camp Rogers PAC area burned 50 % moderate. The PAC area located west of Lower Bucks Lake (Secs. 23 and 24 in Bucks Creek drainage) completely burned with 60% severe and 40% moderate intensity. The fire suppression techniques included the construction of at least two miles of fire line (Lower Bucks Lake to Bucks Mountain summit) through the PAC below Bucks Mountain summit.

Grizzly Forebay (Storrie quad) has PAC areas to the north and west. PAC area in Sec 34 burned to 40% moderate but additionally had a bulldozer line cut cross contour through the PAC for a mile.

There are three territories (named above) within this PAC (Soapstone quad) and they completely burned at moderate to severe intensity. The most intense burn out was French Hotel Creek (Secs. 10 and 15) at 90% severe. A fire line was established on the paved Quincy-Oroville Highway as the eastern anchor for an approximately 8 mile reach between Four Trees and Grizzly Summit.

A four-mile long bulldozer line bisected one of the two PAC territories (Pulga quad). The PACs overall burned 90% moderate.

The Forest Service activities accompanying the Bucks Fire have led to "demonstrable loss and degradation of California spotted owl habitat". No further studies on or remediation of this injury to habitat are apparently contemplated by USFS. The effects of the Forest Service Fire Suppression system are to diminish the environment--particularly California spotted owl habitat; while preventing any other method of attempting to reduce the negative effects of wildland fires (see the QLG mitigation). The QLG Act calls for construction of a system of defensible fuelbreaks (primarily along existing roads). The USFS fire suppression system on the Bucks Fire developed fuelbreaks, but developed them in extremis, during the fire. Little or no deference was given to the habitat values that were compromised by the suppression activities.