Comments on SPI THP Hanging Schaad
Ebbetts Pass Forest Watch
PO Box 501
San Andreas, CA. 95249
www.ebbettspassforestwatch.org
Non-Profit ID# 68046695
February 14, 2024
Forest Practice Program Manager
CAL FIRE
1234 East Shaw Avenue
Fresno, California 93710
Ebbetts Pass Forest Watch (EPFW) Comments, THP 4-23-00186-CAL, Hanging Schaad Timber Harvest Plan (THP)
To whom it may concern:
The following comments concern the Cumulative Effects, Wildfire Risk and Hazard regarding the 4-23-00186-CAL, Hanging Schaad THP.
Hanging Schaad THP consists of a 557-acre timber harvest which includes 460 acres of clearcuts and 66 acres of firebreaks. The post-harvest stocking for clearcut lands consist of even-aged management with a 125-point count within 5-years post-harvest. The harvest area is located approximately nine miles east of the town of Wilseyville.
Section IV, page 268 (Wildfire Risk and Hazard Assessment) describes the THP as being in a Very High Fire Hazard Severity Zone. It is further stated that “The intent of the proposed Fuel break treatment is to reduce the level of surface and ladder fuels.”
Tree Plantations Increase Fire Risks
A number of recent forest fire studies have shown clearcut harvesting and subsequent even-aged tree plantations in accordance with the proposed project, will lead directly to increase in the intensity and spread of wildfire. Given the extensive clearcutting and harvesting operations that have taken place in this area alone in the past 10 to 20 years, there are significant wildfire risks and hazards caused by the proposed project.
Zald and Dunn 2018 found intensive plantation forestry characterized by young forests and spatially homogenized fuels (even-aged management), rather than pre‐fire biomass, were significant drivers of wildfire severity.
DellaSala, et.al., 2018 Examined the severity of 1,500 forest fires across the West over a four-decade period to determine if wilderness, roadless areas and national monuments burned more severely than logged areas. The studies found the forests with the most logging burned in the highest severities. It also determined logging slash that is often left strewn across the landscape and small trees densely planted (even-age management) both act like kindling for fires.
Thompson, Spies and Ganio, 2007. Fire severity studies in plantations and naturally regenerated vegetation of similar ages show that site history influences fire severity and have found an association of high-severity fire with conifer plantations.
Accordingly, we need to protect the "over-story" tree canopy that moderates the "microclimate" of the forest floor. Reduction of the tree canopy which occurs in a clearcut exposes the forest floor to increased sun and wind, causing increased surface temperatures, and decreased relative humidity. The temperature increase in turn causes surface fuels to be hotter and drier, resulting in faster rates of fire spread, greater flame lengths and fire line intensities, and more erratic shifts in the speed and direction of fires.
The Western Fire Ecology Center has also found that small-diameter surface fuels (such as even-aged plantations younger than ten years) are the primary carriers of fire. Current fire spread models do not even consider fuels greater than three inches in diameter because it is mainly the fine-sized surface fuels that allows fire spread. Commercial logging operations remove large-diameter fuels which are naturally fire resistant and replace them with even-aged plantations with fire-prone small-diameter fuels. Timber plantations are comprised of densely stocked, even-aged stands of young conifers that are extremely flammable and vulnerable to catastrophic fire effects. Consideration should be given to using Selective Harvest rather than Clearcuts because of the fire risks associated with those younger even-age tree plantations.
Remote Forest Sites Firebreaks
Examples that CAL FIRE used in the past to justify the extensive network of firebreaks have been to protect forest communities such as the town of Shaver Lake in the central Sierra 2020 Creek fire. These firebreaks examples do provide a greater level of protection for those structures in the WUI and can be justified along with other home hardening efforts. However, the construction of firebreaks in remote areas, away from structures and people such as used in Hanging Schaad are costly and can have a reverse effect on wildfires. Accordingly, there’s a strong argument that firebreaks dry out the soil and can create a wind tunnel effect whereby it would fan a fire’s growth rather than retard it.
According to Bryant Baker, conservation director Los Padres Forest Watch, of the 25 highest-profile firebreaks created in 2020, only about 2 percent of those 90,000 acres cleared by a fire crew ever encountered a wildfire. In today’s fire climate Baker states, “The fires just completely overrun the fuel breaks, especially under extreme, windy conditions. These extreme fires are the ones we need to be concerned about and the ones that are doing most of the damage.”
Alexandra Syphard, adjunct professor at San Diego State who studied the impacts of fuel breaks said, “When you have really high wind conditions, hot and dry, that are coming off mountains, fires are very difficult to control. There’s a very good change that the fire is going to continue through the break.”
Given our above concerns regarding the effectiveness of a fuel break, could CAL FIRE provide us with the criteria used to determine the size, location, and a cost analysis of the effectiveness of these firebreaks? Given the possible harmful effects caused by firebreaks (i.e., increases in fire spreading winds, drying of exposed fire break areas) an analysis should be included in this THP.
Satellite mapping of the Caldor Fire shows that even with extensive fuel reduction and firebreaks in the burned areas over the last several years, it had minimal effect on slowing the growth and intensity of the fire. In fact, the younger tree plantations likely contributed to the fire growth.
Given this THP’s inadequate analysis of the fire impacts, this THP should be disapproved or at a minimum delayed until further fire impacts and analysis, or other harvest alternatives can be studied. I further recommend that the RPF consider using selective harvest and uneven aged management as a much better alternative. This would minimize many of the fire risks as identified above while preserving the natural forest canopy and visual impacts caused as a result of this logging operation.
Thank you for your considerations,
Perry Metzger, President
Ebbetts Pass Forest Watch
3001 Tanya Court
Sacramento, California 95826
Copies furnished:
Central Sierra Environmental Resource Center, Executive Director, John Buckley
Secretary Wade Crowfoot, California Natural Resources Agency
Senator Henry I. Stern, Chair, California Senate Natural Resources and Water Committee
