Draft YOSEMITE FIRE MANAGEMENT PLAN Comments

408 973 1085

Superintendent David Mihalic
Yosemite National Park
yose_planning@nps.gov
Fax: 209 379 1294

Re: Friends of Yosemite Valley comments on Draft Yosemite Fire Management Plan

Yosemite Planning Department and Superintendent Mihalic:

Today it is understood that fire is a natural process and necessary to the health of the Park. Fire suppression which has been practiced over the last century interfered with natural processes and has caused a build up in vegetation which can fuel unnaturally hot, large, or quickly spreading fires. In order to try to deal with this situation, various methods are being proposed -- but no one knows for sure how to handle this. In addition, it is highly doubtful that all of Yosemite underwent fire suppression, as there were certainly not resources to suppress all naturally caused fires all over Yosemite since 1860 nor up to recent times, yet this plan intends to treat almost all of Yosemite National Park.

Friends of Yosemite Valley supports development of a fire management plan for Yosemite; however, we cannot support any of the alternatives presented in this plan. This plan contains inadequate disclosure of the effects of the NPS preferred alternative and the other alternatives. It contains an inadequate range of alternatives, some alternative approaches and treatments are discussed below.

Any fire management actions or treatments taken now in Yosemite will affect the forests, the meadows and the ecology for decades and in many cases centuries. These actions can drastically change the ecosystem trajectory of the areas. This plan calls for major manipulation of the ecosystems in Yosemite carrying with it major risks of unintended consequences. The Park Service's Fire Management Plan for Yosemite could lead to more, not less "catastrophic" fires. It could lead to a shorter, rather than a longer "fire return time."

* NO COMMERCIAL LOGGING IN YOSEMITE.
All trees must remain in Yosemite. No trees must be allowed to be removed by commercial logging companies and no trees must be allowed to be removed by NPS and then given to commercial logging companies to sell. All trees logged must remain in the Park, as close to where they grew as possible.

The plan proposes to cut trees up to 31.5" in diameter. The plan hypothesizes that this is the minimum diameter the trees would be today that started growing before fire suppression began in 1860. While the plan does not call for selling the trees outright, it allows private companies to sell the logs -- that is commercial logging. The commercial incentive for saleable size trees to be cut, be it by the National Park Service or commercial enterprises, must be completely eliminated.

Government science reveals that removal of mature trees of 12" to 30" in diameter will increase, not decrease, severe fires. Removing larger trees reduces the forest canopy cover and creates hotter, drier conditions. It speeds the growth of easily ignited weeds and shrubs. There will be no financial incentive to reduce this brush, in fact, this is a labor intensive operation with a financial disincentive, then what?

This plan as constituted is a perscription for logging projects. Any tree removed over 4" DBH (diameter breast height) is a logged tree. If that tree is removed from the location at which it is cut, rather than being a downed tree with its ability to store water and release nutrients, it becomes timber, a commodity. Any tree which is sold, given away or traded to a commercial company or any entity which then sells it, is undergoing commercial logging.

* REDO THE PLAN.
This plan is not clear and does not adequately disclose its potential impacts, yet it sets up a massive amount of logging and manipulation in Yosemite.

A conservative estimate based on the plan is that 5 - 6 million board feet of timber per year would be logged for the next 6 - 8 years. Approximately 500 logging trucks per year heading from Yosemite to lumber mills. That does not include "hazard tree" cutting, nor set-backs from roads.

The drastic amount of tree removal, both large, medium and small saplings exhibited in the demonstration plot at Happy Isles, leaves us to wonder about the effects of so much opening to the sun all at one time on the soils, mosses, fungi and small, but important vegetation and what that could do to the existing fauna and ecology of the area.

* PRACTICE SENSIBLE PREVENTION.
It is now known that the most effective method to protect buildings is to clear brush or duff around the perimeter of the buildings and to utilize fire-proof or fire-resistant roofs. These are the first treatments the NPS should take. Obviously the more buildings and areas with buildings, the more this is an issue -- for example, the construction planned in the Yosemite Valley Plan --- cause and effect. In addition, will the Fire Management Plan be used to facilitate the new construction of buildings and roads by clearing those areas?

The first 10 years of the Fire Plan focuses on what is called the "wildland-urban interface" (WUI). These are the areas in which buildings are near woodlands. Because of the presence of the buildings, it is more likely that fire has been suppressed to protect the buildings, such as in Yosemite Valley and other developed areas of the park. However, a large threat to the native black oak trees in the Historic employee housing District in Yosemite Valley is the Park Service's allowing and encouraging of lawns and lawn watering, in the otherwise naturally dry season, which threatens to destroy these ancient oaks.

* FOLLOW-THROUGH AND OVERSIGHT.
Before any fire plan is initiated, existing slash and debris piles in which brush, duff, slash, and hazardous and flammable materials have been piled need to be burned or dealt with appropriately.

In Wawona and in Yosemite Valley, slash piles have been observed sitting around creating possibly the biggest fire hazard of all. The numerous piles in Wawona are reported to have been there for years. Just off Northside Dr in Yosemite Valley, not visible from the road, members of FoYV three weeks ago saw a huge pile of slash around twenty feet tall by 40 feet in length NEXT TO numerous piles of broken up asphalt and other piles of asphalt covered with wood slash. Two days ago, the pile was even larger. Fuel for a catastrophic fire. If the Park service is serious about preventing those fires, then why are these piles being left? Obviously, these should be taken care of as the first order of business and we ask the Park Service to do so. If these identified piles are removed, will the Park Service then create new hazard piles in locations we cannot monitor?

* SITE SPECIFIC ANALYSIS.
Any cutting or tree thinning and prescribed burns must be preceded by individual site-specific analysis. Large areas and trees should be marked so the public can review and comment before-hand. For each site, steepness of slopes, their orientation to the sun, density of vegetation both alive and dead, etc, all need to be considered. This should be a transparent process.

The plan appears to exaggerate the risk of "catastrophic" fires and appears to exaggerate the potential for risk reduction achievable through the proposed treatments. Surprisingly, the plan does not analyze the three large fires which occurred in Yosemite.

* NO LOGGING ROADS.
No logging or other roads should be cut into Yosemite Wilderness or wild areas to accommodate tree thinning (logging) nor in developed areas. Any new logging roads in the Sierra and in Yosemite would be detrimental to ecosystem health. Each new road creates serious impacts (See the report on Roads in the Sierra).

* LOST KNOWLEDGE OF YOSEMITE NATIVE PEOPLES' POSSIBLE FIRE REGIME.
One of the greatest losses that occurred to Yosemite was cutting off the Yosemite native peoples from their cultural heritage in the 1800's and 1900's (and which is still continuing today in the Lower Yosemite Falls project). Because of the former, we do not have the knowledge of what the Yosemite native peoples actually did regarding fire or a fire regime in Yosemite Valley and possibly other areas of Yosemite. Since the Yosemite native people's were cut from their culture and children were taken from their parents, not allowed to speak their native tongues, and put into boarding schools the precious heritage and knowledge of their actual fire regime (when, how often, where, under what conditions, for what purposes, etc) appears to be lost forever. This knowledge could have proved to be invaluable to us today and our lack of knowledge and dilema about how to handle fire in Yosemite and especially Yosemite Valley.

Of course, it must be remembered that whatever they did or did not do "pre-history" was in the context of a very different hydrological situation in Yosemite Valley.

* RESTORE HYDROLOGY FIRST.
In Yosemite Valley in order to restore the meadows, flora, and presence or absence, density and species of trees, the hydrology needs to be restored first.

Fire suppression in Yosemite Valley since 1860 probably accounts for approximately 50% or less of the changes in the vegetation, while changes in hydrology might actually account for up to 90% of the changes. Yet the Park Service proposes to "restore" selected areas (view-sheds) in Yosemite Valley to what supposedly existed in the 1860's before fire suppression. This completely ignores the major role hydrology plays in Yosemite Valley and the major human-made changes in its hydrology since 1860 -- blasting of the terminal moraine, drainage ditches all over Yosemite Valley to drain meadows, riparian, and wetland areas to facilitate roads, tourists, orchards, and the effects of the roads themselves. Even if the Park Service could determine the mix of species, distribution, size, spacing, etc of the trees and other flora in the Valley and put it all back, the changes which have been made in the hydrology would prevent their survival in that form. The controlled burn of El Capitan Meadow appears to have stimulated more trees to grow in the meadow. Rather than fire suppression, perhaps it is the manipulated change in hydrology to a more dry Y. Valley that is causing the incursions of saplings.

* YOSEMITE SEQUOIAS.
In part because of the long life-span of the Sequoia trees, nobody knows the full range of natural conditions that Sequoia groves were formed by and have lived through. Evidence of hot fire in the past means that there must have been some severe fuel build ups. So, part of the natural variation over time would be that there are built up areas of fuels/kindling waiting for that lightning bolt. Sequoias do not need fire to germinate. They do respond to fire by germinating lots and lots of seedlings. but they also sprout wherever nature creates a small opening, such as when a giant falls down and its roots tip up moving a lot of bare soil to the surface, and also when a gopher digs a hole with a small patch of sunlight. The fact that Sequoias respond after a fire is not a reason to disturb the soil just to make them respond. The Sequoias reproduce and survive after disturbance, but when there is no disturbance there is a status quo... new seedlings are redundant. Consider that the trees there now can survive 3500 years and become up to 35 feet in diameter. Even if one seedling every century per acre survived, that would make 35 huge giants an acre, all producing cones and seeds. And consider that Sequoias do not usually occur in pure stands but are mixed with other conifer species, each requiring nutrients, etc. So, this alarm over groves not reproducing is probably not valid in Sequoia time. People have reported seening young Sequoia in almost every grove. A Sequoia grove is, of course, not a tree farm.

* ADEQUATE SUPERVISION BY NPS NEEDED.
There is no supervision built into this plan. Crews hired to cut trees and brush need to be supervised by knowledgeable, trained NPS supervisors.

During the NPS fire field trip in July, the NPS Fire Manager in response to our question replied that she could not personally supervise the areas to be thinned and that the crews hired for the season would be the ones to determine what would be cut. We asked how they would know what to cut. She said, she would train them at the beginning of the season. Considering the magnitude of tree removal proposed and shown in the demonstration plot at Happy Isles, this is not confidence inspiring.

* USE NON-MOTORIZED HAND THINNING.
The use of large motorized equipment and skidding to remove trees brings a substantial disturbance to the soils. It prepares openings for new or additional incursions of non-native plants into all the areas of the Park where this equipment would be used.

* OBSERVATIONS REGARDING THE FIRE MANAGEMENT PLAN FIELD TRIP CONDUCTED BY THE YOSEMITE FIRE MANAGER IN YOSEMITE ON JULY 24, 2002.
FoYV appreciates the Field Trip and marking of the demonstration plot at Happy Isles put together by the NPS Fire Manager. This kind of opportunity to see an actual plot and discuss it with the manager is the kind of experience the public needs in order to better be able to review plans, project and proposals and ask questions and discuss them with the managers. We hope that this is seen as a two-way dialogue in which we all learn from each-other in our mutual quest to preserve and restore Yosemite. However, the amount of manipulation explained to be part of the fire plan's preferred alternative to the area was alarming.

* INADEQUATE RANGE OF ALTERNATIVES.
An example of a potential alternative that was not presented nor analyzed. It has been reported to us that in the early 1990s' or late 80s, in lower Yosemite, there was much success with saving some historic building-cabin(s), with a type of tent that inflated and sprayed with fire-retardent foam. While it would be a large financial investment to buy all those tents and foam, money would be saved with less personnel and fire trucks. Was this method evaluated? It could be a better method than clearing, which has its own problems with erosion, weeds, etc.

* DESIGN/BUILD A SCARY WAY TO MANAGE CALIFORNIA BLACK OAK WOODLANDS, ETC.
Table 2.3 indicates that determining the Gap Distribution, Density and Frequency by Species Composition and Fuel Load of the following vegetation types -- California Black Oak, Canyon Live Oak Forest, Ponderosa Pine/Bear Clover Forest, Low Meadows/Dry Montane Meadows, Foothill Pine/LiveOak/Chaparrral Woodland and Blue Oak Woodland -- "Will be determined through research and monitoring, i.e., through the adaptive management process." The major amount of manipulation in this plan will subject these areas to an unacceptible amount of human interference without knowing or being able to predict the consequences for the future. What right does one generation have to do this to Yosemite? Where is common sense? Where is respect for nature and the gift of Yosemite?

* EXCESSIVE SELF-CONFIDENCE REGARDING THE FIRE MANAGEMENT PLAN AND THE ALTERNATIVES.
The amount of confidence displayed in this Fire Management Plan with its major and significant amount of manipulation of the forests, meadows, riparian areas and vegetation and its potential unknown effects on the ecology is amazing. A small example of what is not known. During the Fire Management Plan field trip on July 24, the Yosemite Fire Manager explained that before the A-Rock fire no one knew there were Knob cone pines in Yosemite. In fact, there is a ridge below where we were standing when this was said which is known as, "Knob cone hill" in Foresta because of the Knob cone pines which are known to have been there by Foresta residents long before the fire. The cones roll down the hill, which is why in part there are many knob cone pines in Forest before the fire and now.

* SOME ADDITIONAL QUESTIONS REGARDING THIS PLAN:

Why has this plan intermingled fire management to prevent catastrophic or hazardous fires with vegetation restoration?

Are these compatible? Based on what criteria? What proof?

How much of the Rx and the M in the WUI and the Wilderness and wildlands areas, Project by Project as per Table A-6-2 and Table A-6-3, are for fire management?

How much of the Rx and the M in the WUI and the Wilderness and wildlands areas, project area by project area as per Table A-6-2 and Table A-6-3, are for vegetation restoration?

Why is the range of vegetation narrowed compared to the 1997 Vegetation Management Plan as per Appendix 10-2?

How can NPS know what, "would have existed today without Euro-American interference?"

What is the planning time frame this plan envisions? The Sequoias live for thousands of years, how can we plan what is right to do or not to do in and around the Yosemite Sequoia groves with the relatively short time concept we are working under?

What justifies the huge variability range in Table 2-3 of Gap Distribution, Density and Frequency by Species Composition and Fuel Load?

* FIRST DO NO HARM. The prescription of Hippocrates is as valid as ever.

Thank you, Joyce M Eden, for Friends of Yosemite Valley.

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