The "Region 5 Post-Fire Hazard Tree Project" is the Forest Service’s newest attempt to bypass meaningful environmental impact analysis. The project proposes to cover nine National Forests ranging across the state that were impacted by recent fires and would allow for the removal of thousands of acres of forest along the roadside, with little site-specific environmental review for the stated purpose of removing “hazard trees.”
There is some justification for the project. Snags can fall along roads, and in the worst case, on individuals. For highly-trafficked or important roads, ensuring safe road travel is important. The process by which this project has been pursued and the scale of the action is a problem. There can be a cure, however: downsizing to a more reasonable project that focuses attention on fewer roads.
First, to process. The project has its genesis from a seeming goal of the Forest Service to allow for larger projects with less environmental impact analysis in an era. This is somewhat understandable. In an era of underfunding, federal agencies are expected to do more with less. Here, it appears that there will be one or two “projects” that combine multiple National Forests together in one analysis. This is a departure from the past, where a project like this would be done at the individual National Forest level, with each Forest looking at the site-specific impacts that might be caused by their actions. Here, the risk is that by lumping together multiple National Forests into one project, we might miss the fine-scale analysis that is critical to ensuring that we protect things like Northern spotted owls, rare plants, or cultural resources.
A solution to this process issue could be to do a “programmatic” Environmental Impact Statement through the Regional Office of the Forest Service and then to “tier” fine-scale analysis at the individual National Forest level. This combines the desire to efficiently utilize resources by having some impact analysis be shared by multiple National Forests and the need to have analysis of the actual places that could be impacted.
The scale is also a problem. Instead of just targeting the most important roads, the Forest Service is going after primarily Maintenance Level 2 roads, which are so poorly maintained that it can sometimes be a challenge to know whether there is a road at all! What’s more, the choice of what constitutes a “hazard tree” is likely different than what you might expect. According to the Service’s marking guidelines, whole swaths on both sides of the road, upslope and downslope, could be removed, leaving snaking clearcuts jutting for miles through public land. The project could be improved by a narrower scope of work—focus on those roads that are vital to the functioning of the forest—and by a narrower definition of “hazard” to include only those trees which are wholly dead and are likely to fall in the immediate term.
EPIC has met with the Forest Service and have shared these thoughts, which were received with sincerity. It is our hope that the Service attempts to deliver a project that avoids impacts through meaningful analysis and that targets only high-risk areas for treatment. If not, they will have to contend with the combined efforts of forest defenders from nine separate National Forests!