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The six Utah national forests have released a scoping document which proposes to amend/modify each forest plan to provide "direction that allows appropriate use (time and scale) of prescribed fire to maintain or restore ecosystems..." The article below is a summary and edited version of a detailed letter by Dick Carter, HUPC, commenting on the Forest Service scoping letter. If you are interested in this issue, contact either our office or the Forest Service.

"...In general, of course, we fully support such an amendment and I’ve advocated for two decades now a reliance on fire as a major management tool. The evidence has existed for that long and it has been a bit frustrating waiting for the Forest Service to catch up.

The idea of a generalized, across- the- board amendment for all forests has merit from the perspective of "crossing boundaries," monitoring and implementing particular fire activities. We don’t necessarily agree that issues are similar on each forest simply because each forest harbors fire-adapted/dependent ecosystems. While that is true, it is only true at the broadest parameters. Lodgepole pine forests show remarkably different adaptations to fire and they are a magnitude different than ponderosa pine, pinyon/juniper or oak brush systems.

There are exceptions, but generally fire has been utilized on many Utah national forests quite haphazardly and without any clear objectives, implementation and, in particular, monitoring for desired results. The whole context of an ecological evaluation, desired condition and a relatively clear concept of a historic patch and pattern and variability within a particular landscape is an absolute priority. The amendment effort is useless unless this analysis is initiated simply because it will take us right back to guess work and ineffective objectives, results and monitoring. Thus a significant effort here must be analytical and descriptive, not simply "can do," burning.

We are deeply concerned that fire management not simply be done as an afterthought following timber harvesting or only in areas that are not scheduled for timber harvesting. If this amendment is going to be science/ ecological/ landscape driven, fire management must be the driving force in ecosystem management, not secondary to timber harvesting or grazing. The simple matter of fact is any approach where fire is a secondary or an after-thought activity assures fire will be relegated to an inappropriate ecological context. The research is clear in this arena. Fire can’t be used to perpetuate a landscape when that landscape is being regulated by timber harvesting or grazing which is outside of the fire adaptation/dependency. For this effort to mean anything the Forest Service is going to have to take a brave ecological step forward.

Under no conditions can we support human initiated prescribed fire ignitions in designated wildernesses or, for that matter, in most wild areas where anthropogenic activities such as timber harvesting and road access are limited. Those special places should be reserved for natural ignitions (based on the law and common ecological sense) and then be allowed to burn as natural fire starts. This context allows a wild landscape to move forward and backward through its life rather than represent an attempt at directing the landscape to move in a particular "human direction."

While the assumption of the scoping letter seems to be based, correctly, on the value and need for fire on many national forest landscapes, the COMMENTS section lays out an array of issues that may be of concern to people that harbor a strong bias against fire as a management concept. It will do little good to suggest that fire is a much needed management tool if the agency feels compelled to respond to these myths surrounding fire by restricting the ecological value of fires...

...Assuming a meaningful proposal is implemented, which is based on an ecological context with appropriate monitoring and goals, then fires must be ignited or allowed to ignite and burn or the whole context is lost."

Dick Carter

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