S O U N D O F F
June 25, 2010
Dear Senator Udall,
I read with interest your Newsletter Update: Fire Season in the Rockies [here] today. You note:
Fire season has officially begun in Colorado. Already we have three active forest fires across the state. The fire in the Great Sand Dunes National Park has burned nearly 5,000 acres, and on Monday, another fire near Cañon City destroyed several buildings, including at least one home. As U.S. Senator, I’m doing everything I can to ensure the Forest Service and the state have the resources they need to keep Coloradans and their property safe during fire season.
In Colorado, one of the biggest threats is bark-beetle-damaged trees. The bark-beetle epidemic, which has devastated large swaths of forest in Colorado and across the Mountain West, has created what is essentially a 3.6 million-acre tinderbox. We now have millions of acres of dead and dying trees that threaten public safety, add fuel to wildfires, endanger water supplies, and put mountain economies at risk.
Ever since I was first elected to Congress in 1998, I have been focused on maintaining the health and safety of our forests, and as your U.S. Senator, I have doubled my efforts to reduce the risks of another event like the Hayman Fire of 2002.
Thank you very much for your rational and reasonable concerns regarding fire risks to Coloradans and to the resources of the great state of Colorado. However, there may be a few items that you may be unaware of:
1. Two of the three active wildfires in Colorado today are Let It Burn fires: the Medano Fire [here] at the Great Sand Dunes NP and Pike and San Isabel NF in Saguache Co.; and the Water Creek Fire [here] on the Roan Plateau northwest of Rifle in Garfield Co.
2. By “Let It Burn” I mean the fire management strategy is not contain-control-extinguish but rather to “monitor” the fires while they burn unchecked.
3. In the case of the Water Creek Fire, the fire reports are sparse and inaccurate but some facts are evident. Wildland fire use (whoofoo) teams (modules) have assumed management of the fire. Although their job (ostensibly) is to monitor, not fight the fire, they do not file monitoring reports, ironically. The BLM, Colorado River Valley Field Office (formerly Glenwood Springs — site of Storm King Mountain Monument) is the responsible agency. Downwind of the fire are the communities of Rifle, Silt, New Castle, and Glenwood Springs. The Roan Plateau is a very valuable piece of property. In 2008 the Roan Plateau lease sale netted $113.9 million, making it the highest grossing onshore oil and natural gas lease sale in BLM history in the lower 48 states.
One might think that with such valuable resources at stake, the BLM could do a slightly better job in managing and reporting on fires in the vicinity. Do you think that allowing the Water Creek Fire to burn unchecked until October rains arrive is wise?
4. In the case of the Medano Fire, the fire was ignited by lightning June 6 at the Great Sand Dunes National Park. It could have put it out on that date with a garden hose, but the NPS chose to Let It Burn with no plan whatsoever, and then on June 17 it blew up to 3,000 acres. The fire burned off the Park onto the Reserve (still NPS). To date 4,891 acres have burned, including 120 on the Pike and San Isabel National Forest.
The NPS alleges to be doing “long-range planning” but that was an afterthought. There was no planning until the fire blew up. There is still no plan. The plan will come later. It’s already too late. The damage is done. No computer model is going to fix that.
The fire is still very active (it grew another 120 acres yesterday), and what little efforts are being made to “confine” the fire are ineffective. Over a $million have been spent not fighting a fire that could have been doused on the day of ignition for less than ten $thousand.
Do you think it is responsible or even sane to let a fire burn from now until October on the Rocky Mountain Front?
5. A pertinent issue has arisen in New Mexico. Certain elements are invoking the name of your late cousin Stewart Udall to promote the takeover of the Valles Caldera National Preserve by the National Park Service. It is important to note that the NPS is incompetent at fire management, lacks effective fire crews, and has adopted a Let It Burn fire policy. In 2000 the NPS actually lit a fire at the nearby Bandolier National Monument that burned all the way to Los Alamos and inflicted a billion dollars in damages.
Currently, the South Fork Fire immediately north of Valles Caldera is 15,000 acres on the Santa Fe National Forest. Direct attack of the fire has been unsuccessful and evaluation of conditions has shown it would be unsafe to place firefighters adjacent to the fire. An indirect strategy is being implemented instead, using the existing road network and extensive back burning. It is hoped that the strategy will contain the fire within the indirect lines until monsoon rains douse it (expected sometime in July).
If the fire had been on NPS land, no such strategy would have been employed. Instead, the NPS typically does Let It Burn until the fire is on someone else’s property and becomes someone else’s problem.
Do you think it is responsible to break the trust documents at Valles Caldera and convey the property to an agency that refuses to do fire suppression?
I sincerely appreciate and share your concerns about the looming threat of megafires, such as the 2002 Hayman Fire (138,000 acres). That fire cost $40 million to suppress and inflicted at least $170 million in direct, indirect, rehabilitation, and additional costs and losses.
The solution you have promoted, to “expand the Forest Service’s authority to take proactive measures to protect at-risk communities and watersheds,” is certainly laudable. May I respectfully offer some other suggestions?
1. Perhaps Congress could fund the Collaborative Forest Landscape Restoration Program (CFLRP) ten-fold or more over current meager levels. The CFLRP promises to do exactly what you advise: implement landscape-scale (50,000 acres and up) forest restoration projects designed to reduce fuels, enhance forest resiliency to fire and insects, restore ecological functions, and provide jobs.
The CFLRP is a national program. It applies to every state. It is not just for one state. Our forest and wildfire crisis is a national one, not confined to any one state. Therefore it makes sense to approach the issue in a holistic, comprehensive manner. I realize that you represent Colorado and seek what might be best for Coloradoans. But a piecemeal, state-by-state approach is actually counterproductive and will result in less forest restoration, not more. Don’t you think it would be wiser to fund the existing program, one that you voted for I might add, than to create 50 new little one-state programs?
2. Restoration forestry projects proposed under the authorities of the Healthy Forests Restoration Act (2003) and the Forest Landscape Restoration Act (2009) have been held up by an endless stream of lawsuits. Certain well-funded litigious groups have made it their mission to sabotage and undermine projects that were generated with the intention of fulfilling restoration mandates which Congress established. Federal land management agencies are attempting to impart forest resiliency as you instructed them to, but have been paralyzed by lawsuits.
Wouldn’t it be wise to examine the pitfalls of the National Environmental Policy Act, the Endangered Species Act, the Equal Access to Justice Act, and other laws that litigious groups use to monkey wrench and subvert the will of Congress? No matter what new initiative to restore forests that you promote, if lawsuits stymie implementation, then nothing substantial will have been accomplished and the megafire hazard will not be mitigated. Don’t you agree?
3. The current red tape that constrains Federal fire suppression and disconnects fire managers from land management programs has led to indecision and poor decision-making on wildfires. Let It Burn policies increase the probability of megafires. Allowing fires to burn unchecked and uncontrolled for months at a time invites catastrophes such as the Hayman Fire.
Ironically, fire suppression decisions are not subject to NEPA, ESA, or other environmental laws. Fire managers can make the choice to Let It Burn in abeyance of those laws, decisions that circumvent legally mandated intents, significantly impact the environment, destroy endangered species and their habitat, incinerate watersheds and pollute waterways, and compromise public health and safety.
Wouldn’t it be wise for Congress to investigate the policies that Federal fire managers are employing, to see if they comport with Congressional intent, and to see if they are effective in fulfilling the mandates you have established for Federal lands? If the fire policies implemented on the ground contravene Congressional intent, then no matter what new forest restoration programs you establish, the land will be incinerated anyway by misguided fire management. You don’t wish that to happen anymore, do you?
Thank you for your concerns and efforts to save lives and property, and to protect our Nation’s heritage and natural resources.
I look forward to receiving and reading your answers to the questions I have posed.
Sincerely,
Mike Dubrasich, Exec Dir W.I.S.E.
33862 Totem Pole Rd.
Lebanon, OR 97355
541-259-3787
http://westinstenv.org
The Western Institute for Study of the Environment is a 501(c)(3) non-profit educational corporation and a collaboration of environmental scientists, resource professionals and practitioners, and the interested public.
Our mission is to further advancements in knowledge and environmental stewardship across a spectrum of related environmental disciplines and professions. We are ready, willing, and able to teach good stewardship and caring for the land.
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