The U.S. Forest Service announced Tuesday that they are withdrawing the draft Decision Notice and Finding of No Significant Impact issued in March for the 50,566-acre Santa Fe Mountains Landscape Resiliency Project. It would involve prescribed fire and vegetation thinning treatments on 36,680 acres east of Santa Fe, New Mexico on a landscape scale. Each year at least 750 acres would have been thinned and up to 4,000 acres would have been treated with prescribed fire during a 15- to 20-year time frame.
On July 12 the Board of County Commissioners of Santa Fe County passed a resolution urging the FS to conduct a full Environmental Impact Statement (EIS) for a planned very large fuel management project. The FS went through the much less complicated Environmental Assessment (EA) process, which included the draft EA, public outreach, and accepting comments, then issued a Finding of No Significant Impact (FONSI) which they felt enabled the implementation of the project.
The statement issued by the Santa Fe National Forest dated July 26, 2022 said, “The SFNF is taking this step to reengage with our partners and community on this very important project to improve forest health in and around Santa Fe…Our intent is to reinitiate the decision and NEPA process for this project after the Chiefs 90-day pause with the publication of a legal notice in the Albuquerque Journal, the newspaper of record. If you previously submitted an objection to the final environmental assessment and draft notice of decision, you will need to resubmit your objection at that time.”
After three prescribed burning projects on the Santa Fe National Forest got out of control since 2018 and had to be converted to wildfires, some of the locals are worried about future projects on the forest.
The current 341,735-acre Calf Canyon / Hermits Peak Fire is the result of two prescribed fires that escaped control earlier this year on the Santa Fe National Forest. One was a broadcast burn that crossed control lines during strong winds. The other originated from slash piles that were ignited in late January that continued burning for months. In mid-April one or more of those piles became very active during strong winds and merged with the other escaped fire on April 22. The fire has destroyed at least 400 homes, forced up to 18,000 people to evacuate their properties, resulted in flooding, and cost more than $248 million in firefighting expenses.
In 2018 another pile burning project on the Santa Fe escaped months after it was ignited and had to be converted to a wildfire. A Facilitated Learning Analysis found that “communication” and “prescribed fire preparation and risk” were common themes.
The notice from the FS is below.
[pdf-embedder url=”https://wildfiretoday.com/wp-content/uploads/2022/07/USFS_withdraws_Decision_Notice.pdf” title=”USFS withdraws Decision Notice Santa Fe National Forest”]
The USFS documents regarding the project can be found here.
Of course piles of dead and down trees would be a fire hazard. But I’m old enough to remember when companies and individuals could get permits to thin the forest and operate sawmills to make lumber instead of buying it all from China. And that lumber locks up CO2 as opposed to what is released by burning or decaying. A cord of firewood (4×4×8ft.) releases about 21 million BTUs when burned, gasoline about 114 thousand BTUs. Does anyone want to do the math of how much CO2 was released by all the wildfires and prescribed burns this fire season, probably more than all the vehicles driving around New Mexico.
Thank you Bill Gabbert for this site, Wildfire Today.
As I have read many of the articles over the last few months a couple of things have come to mind:
The USFS has failed many of its employees and the taxpayers. At times I feel that some forget that if you work for a public agency, you are working to serve the taxpayer. What does the taxpayer want from its land management agencies? They on the whole want their forests to be managed sustainably and efficiently. They want fires to be put out quickly and safely. They don’t care to see large areas of charred trees or smoky skies for 2 months a year. With regard to this specific topic, with the number of people working on NEPA and other justification for “fuels reduction” and the failures of those projects in the form of escaped burns and subsequent damage awards and suppression costs, the COST is exceeding the BENEFIT. It is past time to pause and rethink this policy and start a serious investment in aggressive initial attack.
The type of analysis and disclosure documentation -EA/EIS fiercely debated by the NEPA Ninjas would not change the outcome of an escaped prescribed broadcast burn or pile burn. Fire is its own physical force and only extreme hubris can think humans can safely prescribe and control fire. The Santa Fe Mountains Landscape Resiliency Project is too big and too risky to accomplish with the crude and erratic tool of fire. If each Rx burn unit in the “Resiliency” project was 100 acres, then there would be 506 individual ignitions to accomplish the project. With that many ignitions, the odds are in favor of fire escape with damage to the land and possibly loss of life. Hermits Peak/Calf Canyon, where there was loss of life from post-fire flooding, is the largest modern fire in NM history and which about half was on private lands and homes. The private forest landowners in San Miguel, Mora, Taos and Colfax counties did not want their forest burned, yet it happened. Now they are left with the consequences of failed government planning and policy.
You may well be right……but an EIS is really the only context left, in which these issues can be considered.
My concern is with the application of the test burn. I think they are done between 8 and 10 am. Most wild fires have a witching hour when the fire behavior worsens during the day. Some blow up at 1pm others at 3. Air attack sups will tell you everything looks good at 10. So, by doing the test burn early in the day, you have not tested for the adverse conditions that might occur later. You are not even testing for the most expected scenario.
If you can’t do a FONSI for Rx Burn projects then a lot of people are in trouble. Its been part of the process for decades.
If the USFS and other land management agencies can’t put fire on the ground then they might as well get out of the fuels management business. They can do all the thinning and clean up they want, then do what with the material?
pile it up and leave it on the landscape? You haven’t reduced the fuel loading just rearranged it. Lets also keep in mind that the objective of any fuels management project is not to prevent or eliminate wildland fires, but to reduce the fire behavior to a point where suppression forces are effective in controlling the fire, and the damage to natural resources is minimized.
Usually (but not always) when prescribed fire escapes, mistakes were made somewhere. Those that happened this year are no exception. When I was keeping track for one of the agencies, somewhere between 30 and 40% of the escapes were during the patrol and mop up phase of the project. Check out the reports on the fires that escaped this year.
A couple more random thoughts. With the exception of a few interagency agreements the land management agencies are not responsible for protecting private lands. Maybe we should stop building in the WUI, or miles deep in the forest for that mater. Home owners need to acknowledge the risks associated with where they build. State and local governments could require fire resistant materials, defensible space and inclusion in fire protection districts, thus putting more of the responsibility on the owners.
Yes I know its not going to happen. And the whole issue issue is not going to get better anytime soon
Yes, WUI homeowners need to take much more responsibility for preventing their homes from burning. Why is it considered to be primarily the USFS’s responsibility, or any other agency’s responsibility? Requiring fire resistant building materials in the WUI is an excellent idea.
And yes, you can’t thin without burning the slash piles or the slash on the ground. People try to suggest thinning without burning could be a solution. If anything, that just increases fire hazard. Dead and dry wood left on the ground is probably more flammable than standing green trees. I once talked to Jack Cohen about this, and he thinks that is the case.
It’s not a black and white issue. Everything, every element has to be weighed in a big and thorough cost/benefit analysis. Nothing important should be left out, and certainly people’s health and that their property and homes not be burned up by prescribed burns is important. We know it happens.
When you add all major elements together, who knows what we will come up with. Maybe more innovation, maybe a lot of compromise. But unless all is considered, it’s not an honest analysis process. Here in the SFNF, we are paying the price for an inadequate planning and analysis. A huge one, and an unacceptable one.
Yeah, that’s why they prefer wildfires. So, they can skip all that NEPA BS. Cal Joyner’s words not mine!
I would have to agree with SR, that potentially burning up many square miles of forest, homes and communities from an escaped prescribed burn, say like the 341,000 acres that were just burned up adjacent to the Santa Fe Mountains Project area (the Hermits Peak/Calf Canyon Fire,) would constitute a “significant impact on the human environment.” So would the copious amounts of additional smoke this project would produce, that settles down into the Santa Fe basin and regularly sends people to the doctor with asthma and other health issues, or confines them to their homes for protracted periods of time. NEPA does require this to be considered. The USFS did not at all consider the risk of an escaped prescribed burn, nor seriously consider the health impacts of the smoke they generate in the Santa Fe Mountains Project EA.
If the USFS was not causing so much harm to both the public and the forest with their projects, then the public would not be so adamant about EIS’s. But the harm is too great. The Las Dispensas prescribed burn and the Calf Canyon pile burns, that both escaped and became the Hermits Peak/Calf Canyon Fire have proven beyond all reasonable doubt that we cannot afford to allow the USFS to continue on with these large-scale projects done with condition-based EAs, especially in very sensitive areas like the Santa Fe National Forest.
The Santa Fe Mountains Project is planned to be carried out in beautiful and relatively healthy forest right outside of Santa Fe and surrounding communities. They plan to burn right up to property lines. The public has a right to full participation in project planning, to protect their properties, to protect their health and to protect our cherished forest. We can’t afford to bypass legitimate NEPA.
Honestly, this temporary withdrawal has the appearance of a political move, to get the elected representatives and certain conservation groups on board with the project, or at least in less resistance to it. I don’t think it will work. If this project is carried out as proposed, it will be largely imposed on us, against the will of the public and organizations who strive to truly protect our forest.
In the statement from the USFS, it says their analysis was sound. The multiple objections to the project submitted a few months back enumerated in great detail, with abundant references, that their analysis was not sound, and not in line with NEPA requirements. It doesn’t sound like the USFS so far is even considering what is in the objections at this point, nor willing to bend on just pushing the project through with a condition-based EA.
If they do that, they will discredit themselves entirely in many people’s view.
#1992S-290Grad, I agree with you about the Wx. The report says that they were in varance/prescription, but when you scroll down to the wx they were obviously out of varance/prescription.
Howabout saving all these arguments about NEPA, FONSI, and what not…
Howabout some common sense in RX burns by payin attention 10, 5, 7, and 2 days out WX forecasts , huh? RHs reported in the single digits, wind events, etc.
I ve been on some RX burn crews and these were some requirements as I remember
Too bad for today and all the after affects and the issues it has caused between USFS and State of NM…
Play silly games w the WX….get sillier games with locals and politicos….USFS knew damn well what they were in for, NEPA, EIS, or not…..thinkin ahead and 7Ps..would have gone a loooong way
WTF!!! You cannot issue a FONSI on a prescribe burn. PERIOD!!!
We can and we do. A FONSI is the conclusion of an Environmental Assessment (EA). It is all codified in law and regulation.
If you want to grind all restoration work to a halt across the West, require an EIS for all projects (which is not law or policy or guidance). We know the effects of our projects and only in rare cases will the effects rise to significant.
I think if you had NEPA planners and the other specialists only working on EIS’s, there would be a lot of people moving on to different work not with the agency. I know I would.
Militia Bro, I was the Regional Air Quality Specialist for Region 3 for the FS. I worked in NEPA for 27 years. I taught classes on Smoke Management and NEPA. You cannot issue a FONSI on a prescribe burn. PERIOD!!! The smoke from the prescibe fire is the impact. What Region 3 is doing is insane. A FONSI could be issued for changing a light switch or removing a shed, but not a prescibe burn. Plus, Region 3 is doing this all out of order. You would start with a FONSI. They have already done all the hard work. Why issue a FONSI after you’ve already done the EIS and the EA? This doesn’t make sense. That a complete waste of time. There are people in Region 3 who do nothing but NEPA…like the NEPA Coordinator. There’s a whole Team in each Region called Planning…that do nothing but NEPA. This is insane!!! Plus, Region 3 has lost 2 fires in New Mexico this year…that caused a HUGE impact! Are you saying burning down 1/4 of the state had no impact? Are you saying there was no impact to the people who lost their homes? That there was no impact to the people who lost their lives? This is insane!!!
There is a difference between impacts and significant impacts.
A FONSI is issued after an EA, a FONSI would not be issued after an EIS. An EIS is produced when we recognize there will be significant impacts to something – watersheds, species, etc. An EIS would be concluded with a Record of Decision (ROD) not a Finding of No Significant Impact. If I am wrong please let me know but that is information from a basic class. I hope I got it right.
The people completing NEPA are planning and providing decisions makers with the information needed to make decisions. There is a lot of us in that world doing good work. Making all prescribed burns go through an EIS is insane.
There are teams on each forest and lots of zones/districts that the majority of their work is planning. It is a long road before Fire Management on a Forest develops a burn plan.
SR – bless your passion but I doubt we can have a productive conversation. Out.
Militia Bro, a FONSI is a Finding of No Significant Impact. You can start with a FONSI. For example, I need to change a light switch in a bathroom. Sounds easy. You don’t have to do a EIS or an EA to change a light switch. You’d send an email to the appropriate personal and they would send an email back no impact. Then you can write a FONSI. There are no significant impacts to air, water, soil, plants, and animals. The building is less than 50 years old, so there are no historical concerns. Very simple. Move on to the other 500 projects. The problem comes when someone goes out to the building and starts to replace the light switch to find out that there are bees in the building. Let say the person changes the light switch and doesn’t get stung. FONSI stands. Everything is still fine. But let’s say the person says no I’m not going to change the switch, I could get stung or worse he does change it and he gets stung and maybe even dies. So, now you got a lawsuit. And the question will be why didn’t you do an EIS or EA? And your answer is I didn’t think this project warranted an EIS or EA. And it didn’t until the bees were discovered. Once the bees were discovered you’d need to do another project to remove the bees and then you’ll have to do an EIS and depending on what they discovered in the EIS, you may need to do a EA. With that said you might also want to do a BE and a BA. But that depends on when you did your last BE/BA. Now, this simple project has become more complicated, because you don’t know if those bees are on the ESA, Endangered Species List. So, you have to go talk to the biologist and you also need to talk to your Air Quality Specialist, if you are going to use a pesticide. And if the pesticide get on the ground or in the water, now you’ve got to talk to your geologist, hydrologist, riparian specialist. So, your very simple project became very complex. Now, I could have used an example of a precribe burn, but it that explanation would be much longer and NEVER EVER EVER can you say that smoke is not a significant impact…NEVER EVER EVER. There is a significant impact!!! (And just to let you know significant means different things to different people. To Air Quality Specialist there are numbers assigned to the word significant). And if you say there is no significant impact you could be sued!!! That is why the Regional Office is pissed at your office, because they are the ones who have to deal with all the lawsuits that you get them into. Seriously!!! Anyway, back to this article….it does not make sense what the FS did…unless this was a political decision. Look, you might think we can’t have a productive conversation, but I worked in NEPA for 27 years at the state and federal level. I have worked at the TAMU, TCEQ, UofA, NPS, FS, Air Force, and Army. And I’m telling you the FS is doing NEPA wrong!!! They take too long, spend too much money, and they do it under the guise of protecting the environment, but really it’s a fear of being sued and it’s job security. Many people are afraid, especially in the Regional Office, of being fired. I get it! There are people who are protected and their are people who are not. Who is going to get fired a woman in Planning doing NEPA all day or a firefighter? Yeah, it’s the woman. Because there is this sense that NEPA is not important. The problem is that the FS does NEPA wrong. We tried to stream line it and we were fired. So, yeah, I’m passionate about this issue, because there’s something else going on here!!!
Sorry, I’d like to make a correction, the sentence “Once the bees were discovered you’d need to do another project to remove the bees and then you’ll have to do an EIS and depending on what they discovered in the EIS, you may need to do a EA. ” Should be “Once the bees were discovered you’d need to do another project to remove the bees and then you’ll have to do an EA and depending on what they discovered in the EA, you may need to do a EIS. ”
Sorry, I flipped EA and EIS. I don’t think it matters in any of the other sentences. Sorry for the confusion.
For more info on EAs, FONSIs, and EISs, please check-out:
https://www.epa.gov/nepa/national-environmental-policy-act-review-process
Summary
Normally, you would do an EA, from there you would decide if it is a FONSI or an EIS.
My argument is that you can skip to the FONSI, but that opens you up to litigation.
Reading your stuff reminds of reading comments to our Forest Service NEPA from Dick Artley, especially in his later years.
We’ll agree to disagree.
Yes, the sad truth is that many of our forests will burn, and that means a substantial amount will be high severity. Who knows if they will eventually come back to be anything like what has been left behind. Probably not. But the FS seems to be making it all worse with their fuel treatments. No matter how you look at it, deciding to set the Las Dispensas prescribed burn in the midst of an intense spring wind pattern with red flag warnings nearby, and ignoring the warnings of the locals, shows the FS may simply be unfit to set fires in our forests.
The FS wants to “improve” roads in IRAs during the Santa Fe Mountains Project so they can thin in remote areas. Also to be able to drive equipment cross country. Once you do that, those roads and tracks become new user-created roads, then the public can drive further and further out into the forest, creating fire hazard further out. Not to mention the ecological damage unmaintained forest roads can cause.
Fire is natural in our forests, even high intensity. But we may be seeing an acceleration (although there is also some evidence we are not.) It’s all baked into the casserole now, so maybe all we can really do is to just protect structures and other important infrastructure, and make sure WUI communities have at least two roads out. Also do everything possible to protect forests against human-caused fire, even closing forests for protracted periods of time when necessary. Then otherwise, let it burn. This may be the great reset of our forests into ecosystems that are more adapted to a drier and hotter climate. It breaks my heart, but making it worse is even worse.
Personally I would be open to finding some middle way, but it would take a lot of innovation, open-mindedness and cooperation. Currently, the FS seems to be intent on imposing their outdated and dysfunctional paradigm onto the situation.