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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 Forest17b. Prescribed Burning (Part 2 of 6)3. No mention or honest discussion of the financial incentives motivating the Forest Service to burn and misuse Appropriated – possibly HFI - funds.It has been shown in the past by many researchers (see, for example, Randal O’Toole's book, "Reforming the Forest Service") that by far the strongest determinant of Forest Service activities is how much the particular activity will contribute to the agency’s budget. In the past, the logging program has always been the great generator of funds for the agency, both with appropriations from Congress and from off budget funds such as the Knutson-Vandenburg (K-V) Fund and Salvage Sale funds, funds the agency can keep part or all of. Recently, the USDA Inspector General’s office did an audit of the Forest Service’s use of the Healthy Forest Initiative hazardous fuels reduction program funds. In this audit, researchers found that Region 9 spent $11,885,000 in FY2004 on reduction of hazardous fuels, or five percent of the total budget of all regions. What are Healthy Forest Initiative funds supposed to be used for? The Healthy Forest Initiative (HFI): “requires allocating at least 50 percent of Federal hazardous fuels reduction funds to protect communities and priority is directed to protecting “at-risk communities” and municipal watersheds. Authorized projects must be consistent with land management plans and are generally to focus on small trees, thinning, fuel breaks, and prescribed burning. The law authorizes $760 million annually for authorized projects and for any other fuel reduction activities, including grants to States.” The Inspector General found that: “The FS lacks a consistent analytical process for identifying and funding those fuel reduction projects that would produce the most benefits by reducing the risk of catastrophic fires that impact communities and forest resources. This has occurred because the FS has not developed or implemented specific, national guidance for assessing the level of risk that communities face from wildland fire and based on this assessment identifying and assigning priorities to those projects that will provide the greatest benefits. Further, FS has not developed a process to ensure that the highest priority projects are funded first. Instead, FS relies on field level officials to identify communities at risk and prioritize projects based on their own criteria, which vary from region to region. Without a uniform methodology for identifying high priority projects, Forest Service may not focus its fuels reduction resources on the areas most at risk for catastrophic wildland fire.” In summary, the Forest Service is supposed to be using HFI funds to reduce fuels so that communities at risk can be protected from catastrophic wildfires. We are not told in the German Ridge FEIS or DSFEIS whether the money for the prescribed burn program is coming from the HFI funds. The DSFEIS only states that “The net cash flow does not reflect the total cost of burning…". Appropriated funds, rather than timber sale dollars, would pay these and some other costs.” The FEIS or DSFEIS also do not name any communities at risk, or give an assessment of the level of risk for these communities. Regardless of whether HFI funds or other appropriated funds are used, the issue of using appropriated funds to address the highest risks first makes economic and fiscal sense. Our questions to the Forest Service: 1) Is the Forest Service using HFI funds for prescribed burns on German Ridge and in other close by project areas? 2) If yes, has a risk assessment been done? 3) Are HFI funds used in the way they are intended, that is to reduce the risks to communities? The German Ridge planning documents certainly mention the risks of wildfires as a justification for prescribed burns. Interestingly, some of the risk to be addressed by prescribed burns results from logging activities. The documents also mention possible risks from prescribed burns. “The objective of prescribed burning for this project would be to reduce the total fuel loading after harvest treatments and to eliminate a portion of the maple or beech seedling population. Current fuel loading is typical for the forest floor except for the amount of increased pine fuel in red pine stands that accumulated as a result of mortality and trees falling to the forest floor.” (P. 79 GR FEIS) “Use of prescribed fire requires a prescribed burn plan. The burn plan would evaluate risk and prescribe mitigation measures to protect private lands and Forest resources. Some adjacent landowners are concerned that a Forest Service ignited prescribed burn may escape control lines and spread to their property. If the burn plan was not followed, the prescribed fire could burn too cool and go out, or burn too hot and escape to private land.” (P. 173 GR FEIS) In other words, the Hoosier National Forest seems to be trying to use appropriated funds to reduce the risk of wildfire that result from logging. In other words, they are creating a risk for wildfire by logging (increased slash, etc) and then spending public funds, possibly HFI funds, to decrease the risk they have just created. Instead of using appropriated funds/HFI funds to protect private landowners from wildfire, the Forest Service is instead creating a risk of fire to private landowners, and then using appropriated/HFI funds to protect landowners from Forest Service-created fire! Is this the way HFI funds are supposed to be used? 4. Contradictary analysis of the risk of wildfire While we don’t know whether HFI or other appropriations are used to conduct prescribed burns, one thing is striking when reading the German Ridge Planning documents: The Forest Service has no idea of what the risk of wildfires on the German Ridge is. HFI or not, without a clear idea of the risks of wildfires, any burning program designed to address risks of wildfires lacks justification, and therefore is wasteful, serving no obvious purpose. (We address early successional habitat as another supposed “need” elsewhere). Inadequate risk assessments are the chief complaint from the Inspector General. With no idea of the risk from wildfire, how can the Forest Service prioritize projects? Why is Region 9 trying to use HFI hazardous fuels reduction fund money that should be going to Forests that face a real risk? If the wildfire risk for the Hoosier National Forest is low, then the burning programs are much more expensive than the agency is estimating. The costs of burning in a low risk area would have to include the opportunity costs – losses due to wildfires in high risk areas that could not be treated because funds were misused for burning low risk areas. We find indications that prescribed burns on German Ridge may be waste of taxpayer money on page 173 (4.6 RISK OF WILDFIRE) of the German Ridge FEIS: “The risk of future fires is directly related to the amount of fuel available. Evaluation of the fuel loading and other factors affecting fire risk involves a great many factors, including green fuel, vertical continuity of the fuel, weather conditions, and atmospheric conditions, some unknowable far in advance. This makes such an evaluation speculative at this time and is not included in this effects analysis. IN OTHER WORDS, THE FOREST SERVICE DOES NOT KNOW THE RISK OF WILDFIRE. In spite of admitting that the risks of wildfire are not known, the Forest Services uses the risks of wildfire as a justification for burning elsewhere in the FEIS/SDFEIS:The FS claims there is a risk from wildfires, but that logging and burning will reduce that risk: From the SDFEIS, page 49: “Implementation of Alternative A plus present and foreseeable actions (such as Goosetown prescribed burning and Tell City Windthrow) in the analysis area would have a generally positive net benefit on the fuel loading, thereby reducing the risk of wildfire.” Also, from the DSFEIS p. 48 4.5.2.2. Alternative B [REPLACE THE CUMULATIVE EFFECTS SUBSECTION.] Cumulative Effects – Alt. B – Soils: “One potential cumulative effect of no action in combination with Goosetown prescribed burning and Tell City Windthrow 2004 and with past, present, and other reasonably foreseeable actions, including fire suppression and the likelihood of timber harvesting on privately owned forestlands, is a forest with greater potential for wildfire. Such fire could affect soils in a negative way, but fire of sufficient intensity to cause appreciable soil effects is rare in southern Indiana. Fire risk is only a small part of the overall picture of soils, and this alternative would have no effect on soils and hence no cumulative effect on them.” Also, from the SDFEIS, Page 46 (Cumulative Effects – Alt. B – Effects on Water Quality): “A potential cumulative effect of no action in combination with past, present, and reasonably foreseeable actions, including fire suppression and the possibility of timber harvesting on privately owned forestlands, could be a forest with greater potential for uncontrolled wildfire, depending partly on the degree of slash disposal with harvests on private land. Degradation of water quality following a severe fire is possible, but such an outcome is unlikely. Fire does not always have these effects, and combining that with the limited likelihood of a fire being ignited and spreading in this somewhat moist climate suggests a low likelihood of fire degrading the water quality. In addition, fire risk is only a small part of the overall picture of water quality, and effects for this alternative could otherwise be said to be negligible, and also negligible for cumulative effects to water quality.” Here we have the example of the Forest Service contradicting itself within one paragraph. We still have no idea what the risk of wildfires is in the German Ridge area. And how do we know the risk of wildfire will be reduced when the Forest Service has just told us in the FEIS that they have no way of really analyzing the risk? Also, if there is a risk of wildfires, then shouldn’t the money from the HFI funds be spent on protecting private homes, as is mandated by the law? Finally, from the HNF LRMP. One of the main objectives of the Forest Service over the next ten years is to: “Suppress all wildfires on NFS land.” Doesn’t suppression of wildfires then increase the risk of hotter burning fires? So the Forest Service will suppress natural fires, which we get for free, and charge the taxpayers hundreds of thousands of dollars to set their own fires? Click here for Part 17c. Prescribed Burning Part 3 of 6Protect Our Woods
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