EIS decision: 30% of USFS lands now off limits for retardant

Retardant drop Whoopup fire
Tanker 45 makes a retardant drop on the Whoopup fire near Newcastle, WY, July 18, 2011. Photo by Bill Gabbert

On Tuesday U.S. Forest Service Chief Tom Tidwell signed off on a decision that establishes new policies for the use of aerial fire retardant when fighting wildfires on U.S. Forest Service lands. Tidwell chose one of three alternatives in the final Environmental Impact Statement (EIS) that studied the use of retardant and how it affects water resources and certain plant and wildlife species. The new policy puts buffer zones around waterways and habitat for some threatened, endangered, and sensitive species in order to avoid applying retardant in those areas.

This will result in approximately 30 percent of USFS lands being off limits for retardant while fighting fire. There is an exception if human life or public safety is threatened.

The EIS was written in response to a July, 2010 decision by U. S. District Court Judge Donald Molloy in a lawsuit filed in 2008 by the Forest Service Employees for Environmental Ethics. The agency began soliciting public input on the EIS in May of last year.

Now firefighters and Air Tactical Group Supervisors will have roughly 12,000 maps identifying avoidance areas on 98 National Forest System units that identify locations of waterways and areas for hundreds of plant and animal species. Professional liability insurance anyone?

Link to the EIS documents.

 

Thanks go out to Dick

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Author: Bill Gabbert

After working full time in wildland fire for 33 years, he continues to learn, and strives to be a Student of Fire.

14 thoughts on “EIS decision: 30% of USFS lands now off limits for retardant”

  1. Wow…0.8% , 30%, Records of Decision…on and on

    I am going to need a gallon of that hot toddy mix to fathom all that protection we need.

    Just exactly how many “aquatic avoidance areas” are there in the US that the issues of retardants get this much of a stir?

    How about all the pollutants and heavy metals, radiation, burned tires, chemicals, meth labs, etc
    that are created, stirred up from Rx fire and wildland fire?

    Surely has to EXCEED any amount of chemical from retardant?

    Woooow!! Back to my gallon of hot toddy!!

    BUUUUUUUUUUUUUUUUUURRRRRPPPP!!!!

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  2. Ken-

    Both Alternative 2 (the current program) and Alternative 3 (the selected alternative) prescribe a 300-foot buffer around “aquatic avoidance areas”. The “aquatic avoidance areas” comprise approximately 30% of National Forest System lands. This is stated in the Record of Decision, and in several places in the final EIS. Refer to the following pages in the EIS: 34, 88, and 95.

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  3. Bill,

    On Page 9, of the Record of Decision:

    “Like the Selected Alternative, the Proposed Action prescribed a 300-foot buffer area between retardant application and surface waters on national forests, excluding about 30 percent of NFS lands from aerially delivered retardant use.”

    YOU QUOTED an alternative that WAS NOT selected and I can’t find the reference to “30%” on that page or any other. Am I missing somewhere where you got 30% in the selected alternative?

    A reference to 300′ buffers is there… and that has been standard practice for at least the last 10 years… standard practice (SOP). Simply said, ‘don’t drop crap in a water way’.

    This EIS is ACTUALLY a good thing for folks actually on the side of suppression. Folks need to re-read the ROD and ask questions of peers.. IMHO

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  4. Where does it say that 30% of lands are off-limits? The record of decision says, “My decision increases the avoidance areas for excluding retardant use across approximately 0.8 percent of NFS lands in addition to the current direction.”

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    1. It says it on page 9 of the Record of Decision:

      “Like the Selected Alternative, the Proposed Action prescribed a 300-foot buffer area between retardant application and surface waters on national forests, excluding about 30 percent of NFS lands from aerially delivered retardant use.”

      The 0.8% refers to the “additional exclusion areas associated with Alternative 3″ when compared with Alternative 2, which was “current use”. Alternative 3 was the selected alternative.

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      1. Bill,

        The 0.8% addition refers to current policies. I agree. We’ve been working within those policies for years now.

        An 0.8% increase to somehow mean “30%” of lands being “off-limit” seems to be either a statistical error or a figure that must be validated..

        So where does the 30% “off-limits” come from? It wasn’t mentioned or addressed in ALTERNATIVE #2 either.

        Region 5 has been operating under the more stringent standard for the last 4+ years…. no gripes, no bitching, nor moaning until now.

        Airtankers are typically used on ridges and flat areas outside of the areas described by the EIS and ROD….

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  5. I agree with Ray

    Is it going to be yanking and banking by the pilot to adhere to some mickey mouse pattern when most retardant drops are rather linear?

    What? The pilot and the ATGS “gonna” follow some goofy zig zag pattern because of some sensitive plant or biome?

    Seriously? 12,000 maps? Hopefully the extra fuel burn will be added to the next years contract for that liitle exercise!!!!

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  6. Maybe it’s time to develope a new retardant product. If the current product is so harmful it is time to change. As an ATGS (t) I can tell you the job is taxing enough without a mosaic map of no drop zones all over the forest. Especially if we are working in areas adjacent to private lands that the tax payers expect us to protect. If we cannot apply a continuous retardant line it totally useless to start at all. Something to think about.

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  7. There seems to be a “trend” moving forward on Federal lands. First, the dramatic reduction of fixed-wing air tankers and now the limited use of retardant. Don’t kid yourself, those responsible for directing fixed-wing or helicopter retardant drops will be under the “watchful eye” of more than one monitor. Maybe its time to revisit the use of gels?

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    1. Right, Johnny, gels or water. Does anyone know — can gels be used near a stream?

      I’m working on an article that will explore the use of water-scooping air tankers. In a typical situation a scooper can put over 6,000 gallons per hour on a fire — everywhere — including the 30% of USFS lands near streams that are off limits to retardant-dropping aircraft.

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      1. Gels and foams are both treated like retardant and identified for exclusion in retardant avoidance areas.

        This “new” retardant policy was actually implemented over 4 years ago on National Forests in CA, and fire managers have been carrying around map books since then. The policy hasn’t caused much of a problem yet.

        There are exceptions to the rule though: When firefighter or public safety is jeopardized, or when there is a threat to infrastructure or residential structures.

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  8. I would have to agree on the PLI issue for BOTH the ATGS and the contract pilot. A 20 to 30 kt+ wind will blow silliness into a drop.

    I am sure Mr Tidwell has made a decision that isn’t going to make everyone happy…

    Hope the future AT, LAT, VLAT, and helo operators aren’t going to have to suffer the costs of printing all those silly 12,000 maps for avoidance. Bad enough we pilots have to pay for our own Sectional Charts at around $9 per pop every 56 days and not to mention Jepp charts and other maps. These best be on the land management agencies come contract time!!

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  9. I think you mean “Air Tactical Group Supervisors” (instead of Air Tanker Group Supervisors … All Aerial Supervisors, including “Aerial Supervision Modules”, “Lead Planes”, “Helicopter Coordinators” and “Air Tactical Group Supervisors” as well as Air Operations Branch Directors, Operations Section Chiefs and Incident Commanders will have one more “issue” to deal with.

    But of course the age old “human life and public safety” interpretation will add an interesting twist.. document, document, document..

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    1. Well said Tony. Without having looked at the EIS extensively what is the determining factor of waterways. I remember at a “burners” meeting and having a rep from USFWS telling me that “blue line streams” were any channel that had ever had water flow through it…..Really, come on man. Anyhow, it is going to provide for some very interesting decisions at all levels. Carpe Diem

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