What We Do Not Know: How to Ensure Thinning Reduces Forest Fire Intensity
	What We Do Know: Increased Fire Risk Affects Only Some Forests and Comes from Management Practices that Continue Today
	What Our Fire Risk Reduction Priorities Should Be, Based on What We Do and Do Not Know
	Conclusion

Mr. Chairman and Members of the Subcommittee: Thank you for your invitation to appear today. The National Fire Plan and its constituent documents, the so-called Cohesive Strategy and 10-Year Comprehensive Strategy, have a vital set of tasks to accomplish. Done right, they would safeguard rural and urban-interface communities, and help return vigor and resilience to forest, rangeland, and aquatic ecosystems. Done wrong, they will at best perpetuate current threats to those communities and degradation of those ecosystems, wasting taxpayer dollars at a time we have none to spare and failing the American public. As it stands now, the National Fire Plan does not ensure that underlying problems will be effectively dealt with or that funding will be well used. Congress cannot afford to ignore these problems, but it should not allow implementation of the National Fire Plan until assured that the needed priorities and standards are in place and will be followed.

Of the issues raised by the National Fire Plan, I want to focus on the use of thinning to reduce future fire risks in and around federal forests. To summarize, we know far less about fire risk reduction than many believe. What we do know points to three distinct forest zones, each calling for a different treatment approach and priority. The first is the immediate vicinity of homes and communities, where damage from fire can be greatly reduced and where our top priorities lie. The second is the heavily managed and altered forest. This is a zone where it makes sense to experiment carefully with thinning, monitoring and evaluating its actual impact on fire intensity and increasing our investment only if and when we have learned the impact of what we are doing and only after dealing with the first priority, the community zone. The third is the less altered forest, largely unlogged, unroaded backcountry, along with old growth and intact riparian areas. These forests are much less in need of remediation, more prone to harm from active management, and more remote from communities. Thinning here, if it is ever done, should be rare, light, and years away.

Unfortunately, the National Fire Plan is not designed to assure that these zones are dealt with in order of priority. Instead, it is a virtual black box, devoid of meaningful standards, constraints, or commitments about the kind and location of fire risk reduction in which the implementing agencies will engage. This approach is in the same vein as other trends at the U.S. Forest Service, in particular, which are away from standards and accountability and towards increased discretion to do as the agency chooses, notwithstanding public opinion, scientific evidence, and congressional direction. The recently adopted 10-Year Comprehensive Strategy^[1] is oriented toward a number of the needed priorities and standards, but does not supply them or assure they will be developed.

What We Do Not Know: How to Ensure Thinning Reduces Forest Fire Intensity

Above, I spoke of thinning to reduce fire risk as an "experiment." This is an essential point. The National Fire Plan treats thinning as an established cure for intense fire, something so routine that no criteria or sidebars for its use are needed. In point of fact, however, virtually no peer-reviewed, empirical studies show that thinning actually leads to a systematic reduction of forest fire intensity. ^[2] The Cohesive Strategy acknowledges this, somewhat obliquely, when it notes that "[a]t landscape scales, the effectiveness of treatments in improving watershed conditions has not been well documented." ^[3]

Actually, a series of studies - though not definitive - shows post-thinning increases in fire intensity or spread. ^[4] Anecdotal cases exist of both increased and decreased fire intensity after thinning. But in general we don't have the necessary scientific basis for predicting confidently that a given thinning project, as it ends up being implemented on the ground, will reduce fire intensity.

How can it be that thinning could increase fire risks? First, thinning lets in sunlight and wind, both of which dry out the forest interior and increase flammability. Second, the most flammable material - brush, limbs, twigs, needles, and saplings - is difficult to remove and often left behind. Third, opening up forests promotes brushy, flammable undergrowth. Fourth, logging equipment compacts soil so that water runs off instead of filtering in to keep soils moist and trees healthy. Fifth, thinning introduces diseases and pests, wounds the trees left behind, and generally disrupts natural processes, including some that regulate forest health, all the more so if new roads are used. ^[5]

This does not mean that thinning will never help reduce fire risks. Rather, it means that we don't know whether and under what conditions thinning will make things better, rather than worse. It is therefore only an experiment, a complicated, tricky, and dangerous experiment.

There is one kind of thinning we do know is productive. If drastic thinning is used within 150 feet of structures that have fire resistant roofs and siding, and saplings are kept cleared out, the buildings don't get hot enough in a fire to combust. ^[6] When trees are very widely spaced, fires physically cannot jump from treetop to treetop, ^[7] and they don't develop the heat to ignite properly constructed or retrofitted homes. It is important to note that you do not really have a forest left after this kind of thinning, but you do have safe communities.

What We Do Know: Increased Fire Risk Affects Only Some Forests and Comes from Management Practices that Continue Today.

What else do we know about fire risk? We know that increased fire risk is traceable to human intervention. Where forests are abnormally dense and thus more flammable, several kinds of forest management share the blame. The usually mentioned culprit is fire suppression. But also implicated are logging (especially removal of medium to large, fire resistant trees) and grazing^[8] (because cows and sheep crop forest grasses that otherwise would shade out tree seedlings and carry low intensity, brush-clearing fires^[9]).

We know that many forest types are not at greatly heightened risk, because in their natural, healthy state they burn only infrequently, so that intense fires are normal and unavoidable. We know that it is problematic to extrapolate just how dense or sparse forests actually were in pre-settlement times. ^[10] Even the dry pine forests said to be at greatest risk were sometimes much denser before management than people tend to think. The Forest Service's long-time poster child for supposedly pre-management open stand conditions in the dry West is this 1909 photograph from the Bitterroot National Forest. See Illustration 1 (see also Attachment A to this testimony, showing the photograph presented as an illustration of desirable, baseline conditions in a widely distributed 1998 Forest Service poster and in the first, i.e. May 31, 2000, edition of the agency's Coherent Strategy document^[11]). The photo actually is of a just-logged stand. ^[12] A pre-logging photo from the same area and year shows much closer spaced trees. ^[13] See Illustration 2.

We know that where increased tree density does make forests abnormally flammable, it is small trees that are responsible. These are the trees that started growing after fire suppression caused a normal fire event not to occur, or overstory logging and/or grazing opened up the forest floor so seedlings flourished. Large and medium-sized trees typically pre-date these events, so removing them would not return the stand to more normal conditions.

We know that our forests are not currently burning as much as they once did. True enough, in recent years the acreage burned annually by wildfire in the West has trended upwards. However, it is on average still much lower than it was in pre-settlement times. ^[14] Not widely publicized is the fact that much of the acreage reported as burning these days is not forest at all but rangeland and sagebrush, and that where forests do burn, they do so with variable intensities, as they did in the past. We do not really know much about how current wildfire intensity compares with the pre-settlement conditions that thinning is supposed to mimic, in part because current reporting emphasizes total acreage but does not systematically assess fire intensity.

And finally, we know that the management problems that caused small, flammable understories to develop where they did not earlier exist continue to this day, notwithstanding awareness of their adverse consequences. The Forest Service has known for more than seventy years that fire suppression caused subsequent fires to burn more and more intensely. ^[15] Nonetheless, the National Fire Plan focuses just as uncritically as ever on massive, broadscale fire supression, almost in the same breath with promising to address the ill effects of "decades of fire exclusion." ^[16] And much of the thinning done assertedly to reduce fire risk includes medium and large trees. Nothing in the National Fire Plan prevents this. The 10 Year Comprehensive Strategy evinces an understanding that small diameter timber is the necessary object of

restorative thinning efforts. However, it is increasingly the trend at the Forest Service to try to blur the distinction between commercial logging, which is driven by economic considerations to include larger, more valuable trees, and so-called restoration thinning, where precisely the opposite is needed. ^[17]

What Our Fire Risk Reduction Priorities Should Be, Based on What We Do and Do Not Know.

When you reflect on what we do and do not know, the prudent approach to forest fire risk reduction stares you in the face. First, very close to buildings and communities, we have an urgent need and a clear course of action. Second, further away, in the previously managed, general forest, we have far less idea what to do, but ample room and time for experimentation because fire is still well below pre-settlement levels. Third and finally, in the unlogged, undeveloped backcountry, we have the least damaged conditions, the least urgency, the least idea what to do, and the most to lose from active management.

Zone one is overwhelmingly the top priority, the zone where we must focus attention, resources, and work. It is where people and homes are at risk. And it is where we know what will work. There we need highly aggressive thinning, combined with up-grading of exterior building materials and regular clearing of saplings. I want to stress that this kind of treatment does not leave much of a forest behind, just widely scattered trees at most. But this is a zone where consideration of human safety, for residents and firefighters alike, is paramount. And as noted above, research shows that it is very narrow, extending only about 150 feet from structures. Because of the widespread penetration of human communities into forested landscapes, this is still a lot of acreage that will take years to treat effectively, but it is not the general forest. By any defensible calculation, this is where the National Forest Plan should ensure the large majority of our near term resources are focused.

Our longer range priority has to be learning the conditions, if any, under which less drastic thinning - thinning that retains forest character - will reliably reduce subsequent fire intensity better than do other techniques. And the place for this is zone two, the already roaded and logged landscape. This is where management has had far and away the greatest impact, and the forest is most altered. Thus it is where some sort of remediation is likely needed and natural values are least jeopardized, because they are least present. And the way to do it, so we maximize the chances of learning without making things worse, is to take out only small trees, and only in those specific slopes and conditions where science indicates frequent fire used to predominate and now does not. ^[18] The National Park Service is doing some of this already, undertaking small scale, targeted thinning of small trees and brush with strict size limits. ^[19] This was the original intent for the National Fire Plan. ^[20] However, as noted above, the plan now contains no standards to ensure these objectives are met while simultaneously the Forest Service is moving back towards the use of commercial logging on a restoration rationale.

Finally, there is zone three, unroaded areas and intact old growth and riparian stands. Here we have the most to lose, ecologically, from experimental management, because these are the places with the most residual natural values. Because they are among the least altered segments of the landscape they are least in need of intervention.

And because they are typically not adjacent to communities, they are not a priority from the standpoint of human safety. And the more sensitive these lands are, for example municipal watersheds and habitat for threatened and endangered species, the more important it is that we go slow and tread softly. If, because of truly exceptional circumstances, intervention is mandatory, we should look first to ending domestic grazing, removing very small woody material by hand, and reintroducing fire under controlled conditions. As far as the National Forest Plan currently stands, however, limited federal agency funds and authorities may focus on commercial logging of these areas ostensibly for restorative purposes.

Conclusion

Congress has provided billions of dollars in order to accomplish the goals of the National Fire Plan. This spending could result in great success -- in ecological, economic, and human safety terms -- or resounding failure and waste. In order to accomplish the Plan's goals, federal agencies must use federal dollars and authorizations where there is a solid understanding of the potential results and avoid activities that have uncertain outcomes. And federal agencies must be held accountable for following Congressional direction. Based on the research that is available, the needed course is simple -- resources must be prioritized so that most dollars and efforts are focused on the urban-wildland interface, only some are focused on thinning small trees in the disrupted and managed forest, and, for now at least, virtually none in the backcountry. The National Fire Plan as it stands makes no effort to examine or establish these kinds of priorities, let along ensure they will be accomplished. The 10-Year Comprehensive Strategy advances the dialogue about these issues in some measure, but does not include or adequately lay the groundwork for the needed standards, commitments, and accountability.

Thank you for the opportunity to testify today. I would be happy to answer any questions you might have.

Notes

1. A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment: 10-Year Comprehensive Strategy. August 2001. Publisher, place, and authorship unspecified.

2. Models and assessments that predict what future fire intensity might be abound, but they do not report the actual, near or long-range results of thinning as conducted under real world conditions. Similarly common are studies that look at occurrence and acreage of fire without considering intensity. However, thinning does not aim to reduce burning overall, indeed lack of low-intensity burning is seen as part of the problem. Rather, the postulated function of thinning is to make fires less intense. Thus, studies that ignore intensity do not provide useful information about the effectiveness of thinning. One masters degree thesis appears to provide a lone exception to this dearth of relevant research. Pollet, J., and Omi, P.N. 1999. Effect of thinning and prescribed burning on wildfire severity in ponderosa pine forests. Paper presented at the JFSC Fire Conference, "Crossing the Millennium: Integrating Spatial Technologies and Ecological Principles for a New Age in Fire Management." Boise, Idaho.

3. U.S. Forest Service. 2000b. Protecting People and Sustaining Resources in Fire-Adapted Ecosystems: A Cohesive Strategy. Oct. 13, 2000.

4. See, e.g. Fahnestock, G.R. 1968. Fire hazard from precommercial thinning of ponderosa pine. U.S. Forest Service Research Paper PNW-57. Portland, Oregon; Weatherspoon, C.P. and C.N. Skinner. 1995. An assessment of factors associated with damage to tree crowns from the 1987 wildfire in northern California. Forest Science. 41:430-451; Huff, M.H., R.D. Ottmar, E. Alvarado, R.E. Vihnanek, J.F. Lehmkuhl, P.F. Hessburg, and R.L. Everett. 1995. Historical and current landscapes in eastern Oregon and Washington. Part II: linking vegetation characteristics to potential fire behavior and related smoke production. U.S. Forest Service Pacific Northwest Forest and Range Experiment Station, GTR- 355. Portland, Oregon; U.S. Forest Service. 1995. Initial review of silvicultural treatments and fire effects on Tyee fire. Appendix A, Environmental Assessment for the Bear-Potato Analysis Area of the Tyee Fire, Chelan and Entiat Ranger Districts, Wenatchee National Forest, Wenatchee, WA. 5 pages.

5. Some of these phenomena are discussed in the fire effects section of the Final Environmental Impact Statement for the Roadless Areas Conservation Rule (FEIS). The Forest Service's fire specialist review of the scientific literature for the FEIS discusses a number of the underlying studies. See FEIS, Fuel Management and Fire Suppression Specialist's Report (available online at http://www.roadless.fs.fed.us/documents/feis/specrep/xfire_spec_rpt.pdf) at 22 ("The Congressional Research Service ... noted: 'timber harvesting does remove fuel, but it is unclear whether this fuel removal is significant;'" "Covington (1996) ... notes that, 'scientific data to support such management actions [either a hand's off approach or the use of timber harvesting] are inadequate'" (brackets in the source)); id. at 22-23 ("Kolb and others (1994) ... conclude that ... management activities to improve forest health [such as fuel management] are difficult to apply in the field" (brackets in the source)); id. at 21 ("Fahnstock's (1968) study of precommercial thinning found that timber stands thinned to a 12 feet by 12 feet spacing commonly produced fuels that 'rate high in rate of spread and resistance to control for at least 5 years after cutting, so that it would burn with relatively high intensity;'" "When precommercial thinning was used in lodgepole pine stands, Alexander and Yancik (1977) reported that a fire's rate of spread increased 3.5 times and that the fire's intensity increased 3 times"); id. at 23 ("Countryman (1955) found that 'opening up' a forest through logging changed the 'fire climate so that fires start more easily, spread faster, and burn hotter"). Others are discussed, along with adverse impacts to wildlife, in two annotated bibliographies of scientific research available from the Natural Resources Defense Council. Ercelawn, A. 1999. End of the Road -- The Adverse Ecological Impacts of Roads and Logging: A Compilation of Independently Reviewed Research. 130 pp. Natural Resources Defense Council. New York. Ercelawn, A. 2000. Wildlife Species and Their Habitat: The Adverse Impacts of Logging -- A Supplement to End of the Road. 41 pp. Natural Resources Defense Council. New York.

6. Cohen, Jack. 1999. Reducing the Wildland Fire Threat to Homes: Where and How Much? In proceedings of the Symposium on Fire Economics, Planning, and Policy: bottom lines; 1999 April 5-9. San Diego, CA; Gonzales-Caban, Armando; Omi, Philip N., technical coordinators. U.S. Forest Service Pacific Southwest Research Station Gen. Tech. Rep. PSW-GTR-173. Albany, CA.

7. Agee, J.K. 1996. The influence of forest structure on fire behavior. Presented at the 17th Annual Forest Vegetation Management Conference, Redding CA, January 16-18, 1996.

8. See The Comprehensive Strategy, supra note 3.

9. Belsky, A.J. and D. Blumenthal. 1997. Effects of Livestock Grazing on stand Dynamics and Soils in Upland Forests of the Interior West. Conservation Biology 11:315-327.

10. Stephenson, N.L. 1999. Reference conditions for Giant Sequoia forest restoration: structure, process, and precision. Ecological Applications. 9: 1253-1265; Landres, P.B., Morgan, P., and Swanson, F.J. 1999. Overview of the use of natural variability concepts in managing ecological systems. Ecological Applications 9: 1179-1188.

11. After the erroneous description of this photograph, with its (in retrospect) obvious slash piles among the thinned trees was pointed out to then-Chief Dombeck, along with an actual pre-logging photograph of much denser conditions (see Illustration 2), the picture and description were dropped from the final edition of the Cohesive Strategy, released on October 13, 2000. The erroneous use of the photograph supposedly to illustrate baseline conditions was perpetuated when the General Accounting Office included it in Western National Forests: A Cohesive Strategy is Needed to Address Catastrophic Wildfire Threats. U.S. GAO. 1999. Report no. GAO/RCED-99-65 (Attachment B to this testimony). The mischaracterization was detailed in Ponderosa Poster Child: U.S. Forest Service Misrepresenting the Historic Condition of Western Forests and the Effects of Fire Suppression and Logging, by Keith J. Hammer, a report commissioned by Friends of the Wild Swan and Swan View Coalition.

12. Gruell, G.E. 1983. Fire and Vegetative Trends in the Northern Rockies: Interpretations from 1871-1982 Photographs. U.S. Forest Service, Intermountain Forest and Range Experiment Station GTR INT-158. Ogden, UT.

13. Arno, S.F., J.H. Scott, and M.G. Hartwell. 1995. Age-class Structure of Old Growth Ponderosa Pine/Douglas-fir stand and its relationship to fire history. U.S. Forest Service, Intermountain Research Station GTR INT-RP-481. Ogden, UT.

14. The Cohesive Strategy, supra note 2, notes that in "the upper Columbia River Basin alone - a small portion of the interior West - scientific assessments indicate that prior to European settlement, more than six million acres per year burned. Today, fewer than one-half million acres burn per year in this same area."

15. Benedict, M.A. [Supervisor of the Sierra National Forest]. 1930. Twenty-one years of Fire Protection in the National Forests of California. Journal of Forestry 28: 707-710.

16. Compare http://www.na.fs.fed.us/nfp/ff/ff_overview_text.htm with http://www.na.fs.fed.us/nfp/hazfuel/reports/brief_nfp_keypoint_hazfuel_032301.htm. Some fire suppression is, of course, essential. Missing from the National Fire Plan, however, is any awareness that ultimately all forests in the lower 48 states burn and that for those that naturally burn frequently, putting out small fires aggressively, rather than allowing some burning, stores up bigger problems for later on. The 10-Year Comprehensive Strategy, supra note 1, does show some awareness that restoration of fire is an integral part of the challenge faced in our Nation's forests.

17. See, e.g. Testimony of Chief Bosworth, May 8, 2001, on the U.S. Forest Service FY2002 Budget, before the Subcommittee on Forests and Public Land Management, pointing to "past inability of the Agency to view forest product production as an integral aspect of protecting and improving forest health," and asserting that "timber harvesting can restore forest ecosystem health, reduce invasive species, and reduce the risks of catastrophic fires."

18. Alarmingly, the 10-Year Comprehensive Strategy, supra note 1, does not distinguish between, one the one hand, forest locales and types that naturally had and could maintain low intensity burns and, on the other, forests that normally burn less frequently, where efforts to reduce fire intensity would disrupt and damage forest health. The Strategy's first listed action for hazardous fuel reduction, is simply "[r]educe the total number of acres at risk to severe wildland fire," a goal that if implemented indiscriminately across forest types and locations would entail enormous waste and harm.

19. See, e.g., National Park Service. 2001. Environmental Assessment, Hazard Fuel Reduction and Site Restoration, Sequoia & Kings Canyon National Parks, East Fork Kaweah Developed Areas, Oriole Lake and Silver City. Environmental Compliance Document #2001-19. Three Rivers, CA. This project uses hard and fast criteria that preserve all trees over 40 feet high and all down logs over 8 inches in diameter.

20. Babbitt, B. and D. Glickman. 2000. A Report to the President in Response to the Wildfires of 2000 (speaking of "an aggressive program to thin forest stands to reduce small diameter trees, underbrush and accumulated fuels"). A Cohesive Strategy, supra note 2, page 17 (mechanical treatment will target "already roaded and managed portions of the landscape" where we "need to reduce the disproportionately large number of small, non-merchantable trees, brush, and shrubs that dominate short interval fire-adapted ecosystems").