Purpose:

• Forest Health
• Watershed Protection
• Wildlife Habitat

• Improved Home Protection from Wildfire

Reasons:

Given that:

• the area of the Forsythe II project is all above 7600', in the northern half of Colorado, and falls into the upper montane zone, with a historical fire rotation of 100+ years, fire exclusion has probably had little effect on the forest. [1,2,5, 8]

• this fire regime is one of mixed intensity fire, with a predominance towards moderate and high severity fire, primarily dependent on weather and terrain, not on fuel density, thinning will likely have few mitigating effects on fire in this area. [1,2,3,4,5,6, 7, 8]

• the upper montane zone is not an area that has ever been similar to the pure ponderosa, open stands of the lower montane zone and that this area actually is transitioning to sub-alpine, as evident by the dominance of lodgepole pine over ponderosa or Douglas fir, all attempts to convert it into a lower montane zone should be abandoned. [1,5,8]

• continued chronic disturbances may degrade forest resilience, more recovery time should be allowed for the forest to continue in its return to equilibrium, along with allowing nature to determine resilience, rather than human guesswork. [9]

• the units proposed for treatment (in original Forsythe2 proposed action) have been clearcut, patch-cut, burned, &/or thinned multiple times in the past 100 years and have not, according to that proposal, been sufficiently mitigated, it could be concluded that this type of treatment doesn't work. [8]

• this is a fragmented area of forest WUI, with roads, residences, reservoirs, recreational trails, and small patches of forest, in which reside diverse species of wildlife, further cutting will have a negative impact on overall habitat for current species. [10]

• as the forest is opened, facilitating human traffic through the forest, including recreational users creating more social trails, which increases human pressure on wildlife, further cutting would have negative impacts on wildlife. [10]

• the wildlife in the area have not been monitored, catalogued, or studied for current health by the USFS, there is no evidence that changes would have a positive impact.

• this is an important migration corridor and core habitat for the Winiger elk herd, which has already been impacted by cutting and trails, further depredations could have a severe impact on the herd's ability to utilize traditional wintering and calving grounds. [11,12]

• Douglas firs are an important wildlife resource, providing nesting habitat, hiding & thermal cover, and forage for many species of wildlife, large and small, including American martens, blue grouse, Cooper’s & sharp-shinned hawks, chipmunks, and numerous songbirds, the emphasis on removing these trees from the landscape is misguided. The same is true for dwarf mistletoe. [13]

• producing more surface fuels, as scattered or piled slash, does not mitigate for fires, or promote forest health, slash should be removed, not increased by more cutting. [3,7, +]

• trees protect the watershed by providing shade to help retain soil moisture and increase soil absorbency, by holding soil on hillsides with their roots, and by providing a natural regulatory effect by taking in and releasing water, they should be retained, not cut, especially as tree removal can increase flood potential. [15,16]

• research has shown that pulsed disturbances from fire may be less deleterious than chronic watershed impacts from repeated treatments, mitigation should not be attempted. [8,15,17, 16]

• research has shown that the best defense for homes in the WUI is to have a mitigation zone up to 100' around the home, emphasis should be placed on this action. [3,9,18,19]

• residents and recreational users place a high value on a sense of wilderness and the biophysical factors that contribute to these natural amenities and that this importance is integral to community well-being, both socially and economically, any forest treatments that degrade this sense of wildness will be detrimental to
the community and county. [10]

• the “Theme” for the ARF Forest Plan emphasizes providing adequate amounts of quality forage, cover, escape terrain, solitude, breeding habitat, and protection for a wide variety of wildlife species and associated plant communities, as well as limited management, and given the above facts, less intervention is more in line with the Forest Plan.

Actions:

Regeneration Thin:

Units that were treated in the past 20 years should be assessed for conifer regeneration (trees < 18 years old). While dense lodgepole growth is the norm, some thinning of the regeneration at this stage could allow for increased growth and root strength, both of which would be advantageous given the high winds in this area.

The amount of regeneration thinned should be based on slope, aspect, species, and adjacent stands. Regeneration thinning on steeper, north facing slopes should be minimal to provide wildlife cover, moisture & soil retention, and prevent surface fuel growth (800-1400 stems/acre, spacing - irregular). On gentle slopes and south facing slopes, thinning of regeneration can be more aggressive to achieve a somewhat more open forest, although with clumps and heavier patches to provide cover and migration corridors for wildlife. Where ponderosa have regenerated, lodgepole can be thinned away from them. In areas of Douglas fir and
lodgepole, thinning would be consistent with historical variation for those species. (Basal area for sparse to moderate lodgepole would be 80-150 ft2/acre, or 300-700 stems/acre, 6.6'-10' random spacing betweentrunks). [20]

Areas that were cut in 2014 will need to be monitored and slated for regeneration thinning in the next 10-15 years.

Surface Fuel Reduction:

As fire still seems to be perceived as a threat to be mitigated, rather than an integral part of ecological restoration, addressing the preponderance of surface fuels in the area would be the best way to mitigate. The 1000's of slash piles produced by the USFS in the last 20 years should be removed, either by chipping & spreading (no deeper than 1"), incineration (preferably with mobile incinerator), or removed off-site. Burning all of these piles in situ produces high heat (inconsistent with natural fires), especially as many consist of cut boles, that sterilizes the soil, alters the soil chemistry, and kills natural seeds, such that nothing grows for years and/or invasive weeds are most likely to colonize the sites [14]. Many of the piles are barely ten feet apart, meaning that quite large areas will be at risk for invasive weeds, if piles are burned in situ, as well as an increased risk of escaped fire. Piling slash can also facilitate an increase in bark beetles, increasing mortality in residual trees (Six et al. 2002)

There are numerous areas with heavy downfall of small diameter lodgepole pines. Although woody debris is an important component to the ecosystem, providing habitat and nutrients to the forest floor as they decay, it is a slow process and they act as abundant surface fuel. It may not be practical to remove some of this debris, but it would be more effective as fire mitigation to do so, rather than to cut the forest. The natural progression of lodgepole forest is dense growth, followed by self-thinning, leading to undergrowth of other species. [20]

Weed Control:

Past treatment efforts have caused a proliferation of invasive weeds, particularly in sites that were treated by machine. Many of these weeds are highly flammable (e.g., wooly mullein, cheat grass) and should be removed. Canadian and Musk thistle spread rapidly and affect neighboring properties. These also need to be removed from FS lands. More personnel and funds are required to address this problem, which will only expand if not addressed now.

Private Home Defensible Space:

Property owners in cooperation with the Colorado State Forest Service and Boulder County are continuing to create areas of defensible space around homes and other improvements on private lands. In order to comply with home insurance companies, some private landowners have been required to complete defensible space mitigation around their homes. Defensible space is the area around a home or other structure that has been modified to reduce fire hazard. In this area, natural and manmade fuels are treated, cleared or reduced to slow the spread of wildfire. Creating an effective defensible space involves a series of management zones in which different treatment techniques are used. The materials the home is built out of, what you store on and around your home, and vegetation present within 30 feet of your home have the greatest influence over whether your home will survive a wildfire. [18]

Some of these private homes are in close proximity or adjacent to Forest Service lands. One of the purposes of this project is to provide homeowners the ability to complete the required defensible space across their property boundaries onto National Forest System lands.

In areas where there are private homes located within 100 feet of the Forest Service boundary, within the project boundary, private property owners would be permitted to complete defensible space treatments on Forest Service lands in accord with the USFS. Treatment would follow the guidelines outlined by the QUICK GUIDE SERIES FIRE 2012-1. Protecting Your Home from Wildfire: Creating Wildfire-Defensible Zones. http://static.colostate.edu/client-files/csfs/pdfs/FIRE2012_1_DspaceQuickGuide.pdf

There are three zones that characterize defensible space and are defined as the following:

1. Zone 1 is the area nearest to the structures that requires maximum hazard reduction. This zone extends up to 30 feet outward from a structure where the most flammable vegetation would be removed including most trees. Remaining trees would be pruned to a height of 10 feet from the ground and be spaced at least 30 feet between crowns.

2. Zone 2 is a transitional area of fuels reduction between Zones 1 and Zone 3 or the forest. Typically this zone should extend at least 100 feet from structures. Stressed, diseased, dead or dying trees would be removed along with ladder fuels. Trees would be thinned to a crown spacing of at least 10 feet. Retained trees would be pruned to a height of 10 feet from the ground. Groups of trees may be left in areas however these groups would have at least 30 feet spacing between the crowns of the group and any surrounding trees.

3. Zone 2 could be extended to 200' from the structure, where it slopes steeply down from the house. Thinning between tree crowns would occur to an average spacing of 10 feet. Ladder fuels may be removed from underneath retained trees.

4. Zone 3 does not apply in this case, as it is has no defined distance and is only to extend to the homeowners property boundaries. Studies have shown that a distance of 30-100’ is sufficient to protect homes from crown fires. [18,19]

Patrols and Enforcement:

Although the danger of lightning strike caused fire is ever present in this area, human caused fires are the most prevalent. The best form of mitigation is to reduce fire starts. Longer fire bans, bans on dispersed shooting, along with increased patrols and enforcement to ensure compliance, will do more to reduce the threat of catastrophic fire than any amount of thinning or patch cutting. Funding is required for these activities.


Wildlife Monitoring:

To improve wildlife habitat, one must first know what wildlife species are present and the types of habitat preferred by those species. The most recent study on the migration corridor for the Winiger Elk Herd was conducted in 1980’s. Large patches of forest have been cut and thinned since that time. Many residences have been built since that time, as well. Both of these may have had an undocumented impact on the elk herd. The Forsythe Project area falls directly in the path of the historical migration corridor. While elk do like open areas for browse, they need the shelter of denser forest to protect them from winter winds and to provide cover during migration (which can coincide with hunting season or calving).

Northern Goshawks, Ferruginous and Rough Legged Hawks, Golden Eagles, Lewis' Woodpeckers, Chorus Frogs, American Marten, American Mink, North American Porcupine, and River Otters are among a number of animals that have been sighted in this area and which are listed on Boulder County's list of "Wildlife Species of Special Concern", as well as on other lists. Many of these species require special habitats, including retaining wetland and dense forest, as well as protection from human contact. “Some wildlife species have adapted to limitations of suitable patches and tolerate habitat fragmentation, others may take advantage of changes and colonize new openings, however, with human habitation have come more openings and fragmentation, so those species that do not tolerate fragmentation and loss of denser habitat may suffer decline.[21]” Without a study to determine which species are present, where they are, and what habitat is essential for them, we can have no idea of how to improve habitat. Their presence would indicate that they are finding appropriate habitat, so to make changes, without knowledge, is to risk destroying essential habitat.

While it can be said that there is more habitat for these animal species in other parts of the forest, over time more and more habitat is removed from the landscape, with poor results for many species. The USFS needs to look at the mosaic of both public and private lands to determine available types of habitat. Personnel and funding should be provided to perform wildlife studies before any major changes to the forest structure are proposed.

References:

1. Sherriff RL, Platt RV, Veblen TT, Schoennagel T, Gartner MH (2014) Historical, Observed, & Modeled Wildfire Severity in Montane Forests of the Colorado Front Range
2. Odion DC, Hanson CT, Arsenault A, Baker WL, DelaSala DA, Hutto RL, Klenner W, Moritz MA, Sherriff RL, Veblen TT, Williams MA (2014) Examining Historical and Current Mixed-Severity Fire Regimes in Ponderosa Pine and Mixed-conifer Forests of Western North America
3. Reinhardt E, Keane RE, Calkin DE, Cohen JD (2008) Objectives and Considerations for Wildland Fuel treatment in Forested Ecosystems of the Interior Western U.S.
4. Graham R, Finney, Romme, Cohen, Robichaud (2003) Hayman Fire Case Study

5. Graham R, Finney M, McHugh C, Cohen J, Calkin D, Stratton R, Bradshaw L, Nikolov N (2012) Fourmile Canyon fire Findings
6. Cochran, Finnet, Zhu, Eidenshuk, Morna, Wimberly, Baer (2011) Estimation of Wildfire Size and Risk Changes Due to Fuel Treatments
7. Brown R, Agee J, Franklin J (2004) Forest Restoration and Fire: principles in the context of place
8. Noss RF, Franklin JF, Baker WL, Schoennagel T, Moyle PB (2006) Ecology and Management of Fire-prone Forests of the Western United States
9. Hanson, Chad (2010) The Myth of “catastrophic” Wildfire – a new ecological paradigm of forest health
10. Hansen AJ, Rosler R, Maxwell B, Rotella J, Johnson JD, Parmenter AW, Langner U, Cohen WB, Lawrence R, Kraska M (2002) Ecological Causes & Consequences of Demographic Change in the New West
11. Bond M 2003 Principles of Wildlife Corridor Design
12. The Wilderness Society’s Brief (2012) Designating Wildlife Corridors on the Public Lands: Protection Through BLM’s Land Use Planning Process
13. Encyclopedia of Life Pseudotsuga meziesii var. glauca – Inland Douglas fir
14. Korb J, Johnson NC, Covington WW (2004) Slash Pile Burning Effects on Soil Biotic and Chemical Properties and Plant Establishment: recommendations For Amelioration
15. Rhodes JJ, Baker WL (2008) Fire Probability, Fuel Treatment Effectiveness, and Ecological Tradeoffs in Western U.S. Public Forests
16. National Research Council of the National Academies (2008) Hydrologic Effects of a changing Forest Landscape
17. Luce C, Morgan P, Dwire K, Isaak D, Holden Z, Rieman B (2012) Climate Change, Forests, Fire, Water, and Fish: building resilient landscapes, streams, and managers
18. Quarles SL Vulnerabilities of Buildings to Wildfire Exposures
19. Cohen JD (2008) The Wildland Urban Interface Problem – A consequence of the Fire Exclusion Paradigm
20. Anderson MD, (2003) Species: Pinus contorta var. latifolia
21. Greenwald DN, Crocker-Bedford DC, Broberg L, Suckling KF, Tibbitts T (2005) A Review of Northern Goshawk Habitat Selection in the Home Range and Implications for Forest Management in the Western U.S.

Forsythe II Proposal - Does It Pass Muster?

What have been left out of this proposal are the aesthetic and social effects of treatment.

Over the last year, we have pointed out that these treatments, with large cuts, raw areas full of stumps, invasive weeds, and slash piles have a deleterious effect on the community, both those that live here and those that live elsewhere and recreate here. These are not insignificant effects. The physical and mental health of the public require areas of wild & natural beauty for exercise and solace. A manufactured forest, especially one that will take 100 years to grow back does not meet these needs. Unfortunately, it is evident from this proposal that the USFS either doesn't care or doesn't know how to deal with this. We are better off facing the odds of the 250 year fire regime cycle (of this area), than the certain destruction wrought by unnecessary cutting. It is important to remember that fire is an integral part of the ecosystem, so as devastating as it seems, it is also restorative and essential. We aren't going to save the forest from fire and any promises from the USFS that this treatment will do that are empty ones. You can make a difference by mitigating around your home, if you live in the WUI. You may save your home from fire. The USFS is requesting comments on this proposal and we recommend that you provide some (look at the "how to comment section" near the bottom).


Read more on the background information and science.

The good news is that the proposal includes an opportunity for homeowners living next to US Forest lands to complete their defensible space (home mitigation zones) into those lands. They have been a bit over-zealous here, by allowing a 300' zone. Boulder County and Wildfire Mitigation Partners recommend a 100' zone, expanded to 200' if your home is uphill from dense forest. Computational modeling, laboratory, and field experiments that describe the heat transfer required for ignition have shown that the large flames of burning shrubs and tree canopies (crown fires) must be within 30' to 100' to ignite a home's wooden exterior. Homes are more likely to ignite from fuels actually touching the house, or from neighboring (within 40') structures on fire. (Cohen 2008, Quarles 2010) The upshot of this is that YOU can do more to protect your house than the USFS can do, especially if they allow completion of 100' zones.                                                                                                                           Mostly PASS.


Decrease of crown fire elsewhere within the project area is a much more complex problem. "Thinning treatments at higher elevations of the montane zone [here] will not return the fire regime to an historic low-severity regime, and are of questionable effectiveness in preventing severe wildfires. Based on present-day fuels, predicted fire behavior under extreme fire weather continues to indicate a mixed-
severity fire regime throughout most of the montane forest zone. Recent large wildfires in the Front Range are not fundamentally different from similar events that occurred historically under extreme weather conditions." (Sherriff, Plat, Gartner) The potential for passive crown fires is reduced most efficiently by the reduction of surface fuels followed by a reduction of ladder fuels. Conversely, thinning from above, or removal of overstory dominant and co-dominant trees, decreases fire resistance." (Stephens et al 2012) Thinning may add to surface fuels (and increase surface fire intensity) unless the fine fuels that result from the thinning are removed from the stand or otherwise treated. (USDA FS 2004) The occurrence of mixed-severity fire prior to fire exclusion is also well supported by another line of evidence: the potential behavior of wildfire as affected by weather and climate. Based on direct observations of fire behavior, high winds may subject virtually any conifer forest, regardless of fuel density, to crown fire. (Odion, Hansen, et al 2014)                                                                                                                                               
As the methods employed in this proposal are to remove trees (overstory) and not remove surface and ground fuels, AND as they are notoriously bad at removing slash piles, AND as thinning provides questionable results, they FAIL.



B.

See below this article for our alternative.

A.

MFG's Alternate Forsythe II Plan

MAGNOLIA FOREST GROUP, NFP



Working for better management within the Arapaho Roosevelt National Forest

Fire in the WUI (Wildland Urban Interface) is a threat. The question is how to best address it and minimize the risk. I think most of us want it all: a safe place to live, a vibrant ecosystem with varied wildlife, and a place to find joy. The question is whether that is possible.


It has been a year since we halted the Forsythe Project in Boulder County, CO and the USFS has a "new" Forsythe II Proposal. Depite a year of meetings, field trips, and input from the community, the new proposal looks a lot like the old one. While their justifications and reasons have changed, they are following a pattern they have used for many years - cutting trees - despite recent science that contradicts their justifications.


What are they proposing and why shouldn't we believe they know best?


The proposal states the intention to


  1. "Restore" the mixed conifer to a more characteristic and historic pattern,
  2. Increase aspen stands and meadows,
  3. Improve wildlife habitat to benefit species,
  4. Protect the watershed from the impacts of fire, &
  5. Decrease risk of crown fire, particularly next to homes.


That all sounds reasonable and good, but do their proposals succeed in achieving these objectives? Let's look at each objective and see whether they pass or fail.


  1. The first contradiction in the message is that they intend to "restore" mixed conifers, while at the same time create an artificial structure of mixed age lodgepole pine. The second and more problematic aspect of the plan is that they are using an idealized, static image of a historic forest that could apply to forests at lower elevations (below ~7000'), but not to the forests in this 8000-9000' range. They plan to achieve this with aggressive thinning, clearcuts, and patch-cuts. Their imaginary picture sees this forest as an open, park-like area with large meadows, large aspen stands, and widely spaced conifers with a few small clumps (2-12 trees). While this may sound visually attractive, it is not characteristic of this Upper Montane area. "Historically, this area was not predominated by frequent low-severity fire, nor was it predominantly open forest." (Kaufmann, Veblen, Romme 2006) This forest was characterized by dense stands of lodgepole on north-facing slopes and variable stands, predominantly dense, of mixed-conifer elsewhere. Some gentler south-facing slopes may have had some open stands of ponderosa pine, with some smaller meadows and periodic patches of aspen. "This landscape probably was never characterized by large, homogeneous stands with low tree densities. On the contrary, variation in forest structure was important across the area, as were changes over decades and centuries. For these reasons, creating large landscapes with uniformly low tree densities probably would be unprecedented in the ecological history of this area." (Kaufmann, Veblen, Romme 2006).                                                                               For this aspect of the plan - FAIL.                                                                                                                                                                                                                    - The cutting of additional (let's not forget they cut a lot last year) patches of lodgepole, by their own admission, is not in accord with a historical fire regime. The stated reason is to create age variability to promote insect & disease resilience. Having different age groups of lodgepole side by side increases the risk of crown fire. The young dense regenerated trees act as significant ladder fuel to ignite the crowns of the older stands. They do not necessarily give protection from insects, as masses of dead regeneration near Cameron Pass prove.                                                                                                                                                                                     Patch-cuts and clearcuts get a FAIL.                                                                                                                                                                                                      Thinning regeneration is a good idea, as long as it isn't taken to excess. Regeneration from previous cuts can be thinned to create moderately dense and slightly more open forests, as long as it is done with variability.                                                                                                                                                                                           It will depend on the task orders, but we give this aspect a PASS.

  2. Increasing aspen stands isn't an objectionable goal. They don't necessarily fall into the historical pattern, but there is variability and aspen stands fall into that category. They are less flammable, so help from a fire-mitigation perspective and they are good animal habitat. The problem is that one won't necessarily expand an aspen patch simply by cutting the conifers around it. There are other conditions that have to be met, including the right amount of soil moisture, soil type, and wind protection. To expand a patch, you have to pick the right patch. Also, conifers that existed before the aspens grew cannot be said to be encroaching and obviously have not inhibited growth of the stand. Therefore there is no need to cut conifers over 6" out of an aspen stand. And if USFS predictions of increasing temperatures and dryness are correct, aspen stands will increasingly depend for their survival on the shade and wind protection large conifers provide.                                                                      For the idea to increase aspens PASS, Implementation methods - FAIL.                                                                                                                                                       - Expanding meadows is a little more problematic. We may want to retain meadows that we have by cutting out young trees, but cutting any tree over 6" DBH is creating meadow that is not historically accurate. Well, does that matter? Wouldn't it be better to have more larger meadows? Remember that any large opening has the potential to increase fire behavior, by increasing wind speed and providing more ladder fuels and thus higher flames that can lead to crown fires. So, no; more larger meadows are not always good.                                                                                                                                                                                                  PARTIAL PASS, if larger trees are retained.

  3. How can we go wrong with improving wildlife habitat? "Generally, the response of wildlife to specific changes in landscape patterns of forest structure is poorly understood." (Dickenson et al 2014) "The goals of fuels reduction to decrease the likelihood of severe wildfires and restore historical forest structure and species composition are complementary in ecosystems where fuels and fire severity have increased [lower elevations], yet are incompatible elsewhere and threaten ecosystem integrity and ecosystem services." (Sherriff, Plat, Gartner) We are unaware of any long term, systematic inventory of wildlife species here, other than our own in the 1990's. It is hard to know for certain whether changes are benefiting species, unless you know the diversity of species present. While some species may benefit from an open, park-like structure, with more understory and shrubby meadows, these same characteristics will be detrimental to other potentially important species.           FAIL.

  4. Another stated purpose of the plan is to "reduce the effects of wildfire to limit erosion from contaminating municipal water sources." The proposal is to create roads and use mechanical thinning, patch-cutting, & clear-cutting, despite the fact that this has the worst impact on soil erosion. Trees hold the soil in place. They shade the soil, retaining moisture and preventing crusting that reduces the soil's ability to absorb water. Trees shade the snowpack allowing it to melt slowly and reduce high runoff. Trees provide resilience and help to prevent flooding. The impacts of fuel treatments and the necessity to repeat them at frequent intervals are more damaging than the pulsed disturbances of fire. Treatments would have to be repeated every 10-20 years for 340-700 years before 50% of the treatment areas would've been affected by high-severity fire. (Rhodes & Baker 2008). Given the low probability of damaging effects from fire and the guaranteed effects of continuous, chronic damage from treatments, it makes more sense not to treat to protect the watershed.                                                                                                                                                     FAIL.
  5. Okay, this is probably the objective you are most interested in - saving homes and forests from devastating crown fires. There are two parts to this.