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ALERT - December 4, 2006: Protect Our Woods joins allies to submit a response to the Draft Supplement to the Final Environmental Impact Statement (FEIS) for the German Ridge Restoration Project in Hoosier National Forest17a. Prescribed Burning (Part 1 of 6)1. JUSTIFICATION, EFFECTS AND RISKS OF BURNINGThe Forest Service is attempting to burn in a part of the country with: 1) high population areas in close proximity to the burn areas; 2) air quality “sensitive” areas; 3) existing air pollution problems due to a myriad of sources; and, 4) an extensive transportation system. For the Forest Service to even consider burning an ever-increasing amount of eastern forests, they need to consider the spatial, social, ecological, and economic impacts of the prescribed burn program. We do not feel that the agency has done due diligence in analyzing the indirect or cumulative effects of burns on these four parameters. In article after article from Forest Service researchers, personnel admit they do not know the long-term effects of prescribed burns. Yet the Forest Service is scheduling huge burns over a large portion of the Hoosier National Forest over the next decade. The German Ridge burn is just one of several already being planned. For example, the Forest Service is scheduled to burn: • 5,350 acres on Mogan Ridge, where fire could have been applied as early as the spring of 2006. The project would be located about 2.5 miles northeast from the northernmost boundary of the German Ridge Restoration Project. • 5,615 acres on Buzzard Roost, which is located about 12 miles northeast of the German Ridge project. Activities would not be implemented for several years. The burn area would be roughly the same size as the burn area for German Ridge. Burning is planned to remove damaged trees, reduce fuel loads, and facilitate conditions to promote reestablishment of oak species in these areas. • According to the 2006 HNF Plan, the Forest Service plans to burn up to 20,000 acres in the first decade. • Burning will also be a part of Tell City Windthrow project. During the comment and appeal phases for the German Ridge Project both Protect Our Woods and Heartwood commented that the cumulative effects analysis was inadequate. Here again we face the same concerns. For example, the Forest Service did not provide the public with a map in the DSFEIS that showed the number of acres to be burned with the different projects, and where they are located in relation to each other. Without an overlay map, the public (and the Forest Service for that matter) has no way to seriously consider how these fires are going to cumulatively affect the ecosystem in the short-term. In addition, there is no analysis of how all of these burning projects taken together would affect the ecosystem and humans in the long-term. In fact, as we will show below, the Forest Service admits to having no idea as to how the ecosystem will be affected in the long-term. As we will show below, concerning the short term, the Forest Service wishes effects away by pointing to a prescribed burn plan, which is not given to the public, or by pointing to other guidelines, which are no longer enforceable. Finally, as we will show below, we have never received any monitoring reports from the Forest Service about how the prescribed burns they have done in the past on the Hoosier have affected humans and the ecosystem; only anecdotes are found in both the FEIS and the DSFEIS. Monitoring is required, according to the HNF LRMP, and monitoring evaluations should be made available. For the projects planned on German Ridge, Mogan Ridge, Buzzard Roost and Tell City and in other parts of the HNF the Forest Service should have: • Specific, measurable objectives that the burns are supposed to accomplish. • Information regarding the need for pursuing these objectives. • Proof that their proposed actions (burning) will indeed accomplish the objectives. • Information about the harm caused by pursuing the objectives. The Forest Service needs to be able to prove that they will in fact be able to reach their objectives as a result of their proposed actions. If they don’t have that proof then the projects need to be very small and scientifically useful to actually create the evidence needed to make a decision. There is a lack of monitoring as to the claims being made about future conditions. For example, what is the soil’s condition in specific areas after fire? 2. No assessment of the risk of accidents From burning The Forest Service is attempting to burn in a part of the country with an extensive transportation system. PB-models (PB-Piedmont, PB-Coastal Plain, PBMountain) developed by Southern Research Station smoke modelers (Gary Achtemeier, Athens, GA) simulate movement of ground-level entrapped smoke over complex terrain at night. PB (“pregnant bubble”) models are designed to answer the following questions: 1) If I burn tomorrow, will I smoke up a road? 2) I just burned, where is my smoke going to be tonight? The Forest Service understands the importance of asking and answering these questions because not long ago a prescribed burn in the Smoky Mountains ended up causing a major traffic accident on a frequently traveled road. Yet the entire EIS never mentions this as a possibility, let alone analyzes the effects of these proposed burns on accident rates in Indiana. Nor does the EIS give us any indication that previous prescribed burns in other parts of the country have resulted in major accidents. One example is a prescribed burn on the Santa Fe National Forest that got out of control and reached Los Alamos Laboratory, which then caught on fire. There was then an emission of radioactive compounds into the air, which can cause major long-term health effects. This prescribed burn received a CE; that is, it was excluded from the NEPA process. Click here for Part 17b. Prescribed Burning (Part 2 of 6)Protect Our Woods
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