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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 Forest17c. Prescribed Burning (Part 3 of 6)5. EFFECTS OF FIRE ON AIR QUALITYIn addition to concerns about lack of assessment of the risk of prescribed burns, the public has expressed concern about the health effects from prescribed burns. From the Appendices for the FEIS for the Hoosier LRMP 144, public comment: "PC #5: The Hoosier National Forest should prepare a Supplemental Draft EIS. P) The Hoosier must analyze the effects of prescribed burning on air quality. Burning produces a plethora of noxious chemicals." Forest Service Response: Responses to 5 M through P request information that is better addressed at the site-specific, or project level of analysis. The final EIS in Chapter 1, under Planning Document, informs readers that the revised Forest Plan does not mandate any site-specific decision, nor does it contain a commitment to propose or select any specific project. Subsequent environmental analysis, including public involvement, will occur prior to any ground disturbing, site-specific project proposal. #5 P) Chapter 3 of the EIS under the subheading Air Quality discloses the effects on air quality from prescribed burning, as well as the benefits and objectives of such burning. The revised Forest Plan does not contain any site-specific proposals, and thus contain no site-specific analyses. The disclosure of potential air quality effects from the programmatic forest plan direction is appropriate for forest plan level decision-making. During the comment period for the Hoosier Forest Plan and in the subsequent appeal, we pointed out that: GreenFire: "While the Forest Plan may not have to contain site-specific analysis, we think it is imperative that the Forest Service provide, in a transparent way, the information that is necessary for the public to see clearly the different monetary and non-monetary costs and benefits of all plan alternatives. For that, it is not enough to state that there are air or water quality effects from burning. The more important piece of information is how much these impacts differ from one alternative to another. Just like the Plan contains information about how many acres would be cut with the different alternatives (Table 3.9 ), rather than just giving vague, statements of “more” or “less”, so also should the Plan have some clearly displayed information about the different environmental impacts of the 5 alternatives, and the costs of mitigation measures. That is important information to have on the Plan level, because it is at this level that the far-reaching decisions are made of how much more air pollution, sedimentation, CO2 etc. will be the result of the respective alternatives. It is also mandated by law, as we previously pointed out." Here we are at the project level, and we still do not have adequate information about the impacts of the different alternatives on air quality, in particular, the effects on human health, and the costs of these impacts. In fact, this should have been analyzed in the German Ridge FEIS 4.7.1 “Alternative A, Direct and Indirect Effects.” and the SDFEIS. What should have been done is an analysis of each alternative and the associated costs of burning on human health, just as the Forest Plan promised. We would then have seen that the no-action alternative would have no costs on human health, whereas the burning alternatives would have associated costs. Although the Forest Service does not seem to be taking the indirect effects of their prescribed burning seriously, others are. For example, in the article, “What Is the Cost of Wildfire Smoke?,” researchers point out that in addition to the millions of taxpayers’ dollars spent each year on the Forest Service fire program, there are also indirect expenses, such as the cost of health care for illnesses caused by smoke. The effects of smoke on humans are well known and have been documented in studies such as “Human Health Impacts of Forest Fires in the Southern United State: A Literature Review,” by Cynthia T. Fowler (Journal of Ecological Anthropology, Vol 7, 2003). Fine particulate matter—smoke particles less than 2.5 micrometers in diameter (PM2.5)—can cause minor irritations such as burning eyes and runny noise, cause illnesses such as bronchitis, and aggravate chronic heart and lung diseases and bring about premature death in people with these conditions. There are studies that have attempted to better clarify the economic effects of these smoke-related illnesses. For example, researchers (“Economic Analysis of Health Effects from Forest Fires,” Canadian Journal of Forest Resources, Vol. 36, 2006) found that the health effects of PM’s from a wildfire in Alberta in 2001 resulted in significant costs; an estimated $10-$12 million (CDN) in medical costs, lost wages, decreased productivity, and increased risk of mortality. The author also states that it is more than just hospitalization costs, that there are more pieces of the puzzle. “We’re going to need better integration with some of the health science disciplines to better understand the behavioral and physical effects of air quality changes.” Behavioral and physical effects of air quality changes? We see no mention of any of this in the EIS documents. In fact, the Forest Service tells us that: From Page 50, DSFEIS: “For all alternatives, the effects analysis area for air quality is Perry County, Indiana. Perry County was selected because patterns of dispersal allow EPA to measure and report air quality on a county basis. The timeframe is 10 years because the activities and effects would be complete within that time and all smoke thoroughly dispersed.” We would like to know where the smoke is being “dispersed.” Is it into people’s lungs? Is it into wildlife’s lungs? Where does it disperse to? Also, the cumulative effects analysis area should not be limited to Perry County. Smoke and pollution from fire is not limited to an artificial county boundary. If the Forest Service can access county-level data, then the smoke dispersal models should have been referred to and the effects on counties nearby should have been described, especially highly populated areas like Louisville. There is some evidence that smoke from prescribed burns travels very far. For example, there is anecdotal evidence that smoke might have traveled from a prescribed burn in Arkansas to Chicago. Researchers have determined that ozone levels in Houston increased by 50 to 100 percent as a result of smoke wafting in from Alaskan and Canadian forest fires, thousands of miles away. The report, based on data from satellites and weather balloons, appears in the Sept. 26, 2006 issue of the Journal of Geophysical Research. Forest fires in Alaska gave Morris's team an opportunity to assess the air that was moving into the region. Using satellite and spacecraft data from NASA, the researchers tracked an air mass that originated as smoke from the fires. Originating in Alaska on July 12, 2004, the mass moved steadily across the U.S., arriving in the Houston area seven days later. The data from NASA, plus weather balloon measurements, revealed a 50 to 100 percent increase in Houston's tropospheric ozone on July 19 and 20, 2004—likely due to the arrival of the Alaskan air mass. "This study points out how interconnected things are," Morris said. "Over the last 15 to 20 years, there has been an increased awareness of the larger global impacts on local phenomena." “A short-term degradation of air quality could occur at localized sites from cumulative effects.” (GR FEIS P. 178) This type of cumulative effects analysis is what the public was asking for but has to this date not gotten. What is the cumulative effect, taking into account that areas around the Hoosier National Forest already experience high levels of pollution, of burning 20,000 acres of forest over ten years? What type of monitoring has the Forest Service done in the past from prescribed burns? Where has the smoke traveled? Who was affected? Monitoring of this kind is required by the Hoosier National Forest Land and Resource Management Plan (LRMP). What the Forest Service describes so nonchalantly on paper, “short-term degradation of air quality”, can mean the difference between life and death, or at least a low quality of life and a high quality of life, for humans, wildlife and domesticated animals. We do not see any analysis of this in the EIS. Instead we see: “Potentially, dust and smoke from projects such as German Ridge Restoration, Tell City Windthrow, Goosetown, and Mogan Ridge could combine and lead to undesired effects. However, it is unlikely that more than one of these projects would occur in the same year due to timing of harvest activities as well as mitigation measures. Even if two or more occurred in one year, if there were a few days between the actions, there would be no accumulation of smoke.” (P. 50 DSFEIS) What is an “undesired effect?” We thought that as the result of the appeal to the GR FEIS, the Forest Service was ordered to go back and analyze these effects seriously. This is inadequate. The only mitigation measures we could find is mention that the burning will be done when it is wet. However, wetness in the forests during prescribed burns often leads to very “smelly” smoke, making it very difficult to breath. According to Congressional Research Service (CRS) researcher Ross Gorte’s (adapted from Fire Effects Appraisal: The Wisconsin DNR Example, Ph.D. dissertation, Michigan State University, June 1981): There is increased air pollution effect from prescribed burns versus natural fires because the prescribed burns are set when it is wetter than a natural fire because they don’t want their fires to get out of control. Burning wet versus dry wood translates to smelly smoke. “Prescribed fire use on the Hoosier is generally completed in the spring or fall when air quality is good.” (DSFEIS p. 50) Why is air quality “generally good” in the spring or fall? What about the coal-fired plants burning nearby in Evansville and Tell City? Industry? Car pollution? Etc? What does “generally good” mean? The emission factor for carbon monoxide for prescribed burning is thought to be between 20-500 lbs/ton. How is this going to affect people’s health? “Smoke impacts to residents and the visiting public would be minimized by education and outreach efforts regarding the fire program, the temporary closure of potentially affected roads, trails, and recreation facilities, and adherence to smoke management plans that maximize smoke dispersion.” (DSFEIS p. 50) We fail to see just how education and outreach will help limit the health effects on residents and people driving by and into the national forest. A major highway and county roads go right by the area that is projected to be burned. People live nearby. Hunters and horseback riders are in the woods, especially in the fall and spring. Is the Forest Service going to close all roads nearby while they burn? How much is this going to cost the public? Click here for Part 17d. Prescribed Burning (Part 4 of 6)Protect Our Woods
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