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Stanislaus National Forest
Attn: Rim Fire Reforestation
19777 Greenley Road
Sonora, CA 95370
April 12, 2015
Dear Supervisor Higgins,
We respectfully request that you and the staff on the Stanislaus National Forest ensure
that diversity is valued and protected, that no native habitat is viewed as less than, and
that that all species be managed under the principle of Primum non nocer, first do no
harm.
While this is contrary to the forestry-centric focus of the current Scoping document for
Rim Fire Reforestation project, it is in line with Region 5’s new Ecological Restoration
Implementation Plan which states,
Ensure vegetation and fire management efforts are grounded in concern for
biodiversity and ecological process both before and after disturbances like fire.
To indicate, as the Purpose for the Project does, that iconic native shrub species such as
mazanita are merely “brush” that only serve to prevent “tree seedlings from reaching the
sun and limited water needed for establishment,” and will ultimately create “continuous
woody brushfields that impede wildlife movement,” is contrary to the new US Forest
Service vision and ignores most everything we know about healthy, biodiverse forest
ecosystems.
Forests are more than conifers. Native shrubs are critical components of a diverse, postfire environment. Unfortunately, the Scoping document focuses primarily on the growth
of trees at the expense of the Forest Service’s vision of maintaining an “ecologically
healthy and resilient landscape rich in biodiversity.”
The following five steps are needed to create a project Draft EIS that reflects this vision
and one that is based on current science:
1. Acknowledge the value of native biodiversity by eliminating the use of pejorative
references to native shrubs and shrubland plant communities.
www.californiachaparral.org
PO Box 545, Escondido, CA 92033
760-822-0029
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2. Do not use herbicide on native plants. The proposal to herbicide 18,552 acres of nonplantation forest will compromise natural post-fire succession and will likely result in the
loss of significant biodiversity.
3. Do not extend the ecological damage caused by previous tree plantation practices.
The proposal to “deep till” and cultivate 3,804 acres of fragile, post-fire habitat in areas
previously undisturbed by tree farming repeats mistakes made after the 1987 Stanislaus
Complex Fire – creating overly-dense, highly flammable tree plantations with minimal
biodiversity.
4. Incorporate the best available science. The claim that without this Project, “the land
will mostly return to continuous woody brushfields that impede wildlife movement and
remove the possible establishment of diverse forest habitat” is not only unsupported by
science, but falsely demonizes a valuable natural community. As a consequence, the
current Purpose needs to be rejected and replaced with what we actually know about
post-fire succession.
5. Defer to natural regeneration of conifers. Although salvage logging previously
approved for the Rim Fire area likely destroyed many naturally occurring conifer
seedlings, there are likely a significant number of high-severity burned areas within the
Project that remain capable of natural regeneration. Such areas need to be reassessed and
left undisturbed by reforestation activities.
Purpose Inconsistent with Proposed Action
If the overall purpose of the Project is to, “create a fire resilient mixed conifer forest that
contributes to an ecologically healthy and resilient landscape rich in biodiversity,” it is
contradictory that the primary references to shrubland habitat, a critical component of any
healthy forest, are negative. Beyond citing the requirements to retain selected elderberry
plants, riparian species, and occasional cover provided to deer, the Scoping document
has one prescription for shrubland plant communities, demonized as “brushfields”
– herbicide, shred, pile, and/or burn.
This forestry-centric viewpoint is inconsistent with the Forest Service’s stated goals for
Ecological Restoration or the stated purpose of the Project.
Opinions about native shrubs that border on hostility are often expressed by timber
industry representatives, such as those by Steve Brink during the Forest Service
sponsored Rim Fire field trip on June 16, 2014. However, subjective opinions should not
be used to justify land management actions. Unfortunately, the Project’s Purpose
statement does so when it claims,
Without intervention the rapidly resprouting brush prevents the slower growing
tree seedlings from reaching the sun and limited water needed for establishment.
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The land will mostly return to continuous woody brushfields that impede wildlife
movement and remove the possible establishment of diverse forest habitat.
The specter of an entire landscape being taken over by “brushfields” is based on
anecdotal experiences and a forestry-centric paradigm that devalues native shrubland
communities. It is not based on the best available science. The photo below (Photo 1)
from the Scoping document provides one such example.
Photo 1. Scoping document photo.
The Scoping document portrays a small patch of native shrubland on the left as
undesirable. The preferred vegetative cover is on the right, a densely packed conifer
plantation that resulted from artificial planting after a prescription that “included
mechanical site prep with follow-up herbicide release.” The tree density created within
plantations such as this contributed to the spread and intensity of the Rim Fire.
As ecologists, we see this scene as a collision between natural succession and commercial
silviculture.
Over time, the natural, post-fire succession that was allowed to proceed on the left side of
the ridge in the photo will eventually become the type of open forest structure with a
mixture of tree and understory species that defines a healthy, mixed-conifer environment
(note trees coming up through the shrub canopy). Allowing such a process to proceed
aligns with the Forest Service’s Ecological Restoration Implementation Plan goal to
ensure management efforts are “grounded in concern for biodiversity and ecological
process.” Eliminating native shrublands and creating highly flammable tree farms do not.
We offer a counter point to the Scoping document photo.
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Photo 2 below was taken in 2014 within American River Complex Fire perimeter on the
Tahoe National Forest. The area was slated for salvage logging and eventual
reforestation. However, the project was stopped due to a lawsuit filed by the John Muir
Project, allowing natural succession to proceed.
Photo 2. Natural forest regeneration after the 2008 American River Complex Fire, Tahoe National
Forest.
An important point to consider is that in contrast to the photo provided in the Scoping
document, the scene in the photo above actually represents what is happening across
much of the burned landscape. It is not an isolated patch. The post-American River
Complex Fire early seral forest is now exploding with a rich mix of native tree, shrub,
and herbaceous vegetation. Photo 3 on the next page shows the larger scene.
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Photo 3. Unlike the photo provided in the Scoping document, this photo offers evidence on a
landscape scale of a forest recovering naturally. Note foreground as well as area behind the burned
trees.
The Scoping documents claim that the land will be smothered with “continuous woody
brushfields” and “remove the possible establishment of diverse forest habitat” without
artificial reforestation is not supported by science.
Goals at Odds with Forest Biodiversity
We applaud the Forest Service in its approach to correct past land management mistakes
by acknowledging the flammability of tree farms and proposing actions to reduce that
flammability (thinning, prescribed burning, etc.). The proposed attempt to create diverse
spacing configurations in the proposed reforestation effort is also a positive.
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The Project, however, becomes problematic in how the 18,552 acres of non-plantation
forest proposed for reforestation is justified.
The Scoping document claims that,
…without mature live trees to provide a seed source within close proximity to the
burned areas, or the lack of a viable and healthy cone crop, natural conifer
regeneration cannot be counted on within large portions of the Rim Fire area.
…Under these situations, natural conifer regeneration resulting in a forested
landscape could take hundreds of years to develop.
There is a rich data source supporting the fact that all forests will return naturally. The
rate of return is highly variable dependent on the size of high-severity fire patches. The
Project attempts to artificially speed up that process in the Rim Fire area through
management actions.
We acknowledge the pressure the Forest Service is under to reforest. The public,
reinforced by official comments, views any large fire as unnatural and destructive and
wants to see the forest come back as quickly as possible. The desire for reforestation is a
function of how fast the public and vested interests (Congress) want the forest to return.
Therefore, the Project is more about goals than what we understand about natural forest
regeneration.
The Draft EIS should make this goal clear up front rather than attempting to justify the
Project with environmentally favorable outcomes such as enhancing biodiversity. Salvage
logging, tilling, using herbicides on native species, and creating tree plantations do not
enhance biodiversity.
One of the errors Forest Service silviculturists make that is not compatible with any
ecological goal is when replanting is done with different species, selected not because
they are natural components but because they satisfy silvicultural goals. For example,
replacing white fir with Jeffrey pine on the 2002 McNally Fire in the Sequoia National
Forest or Pseudotsuga macrocarpa with Pinus coulteri on the 2009 Station Fire in the
Angeles National Forest were silvicultural decisions, not ecological ones.
The Scoping document does not make clear which tree species will be planted where.
The Draft EIS needs to address this issue in addition to allowing the natural successional
process to occur in as many high-severity burned patches as possible.
In their study of conifer regeneration after high-severity forest fires in California and
Oregon, Shatford et al. (2007) stated that, “Assertions that burned areas, left unmanaged,
will remain unproductive for some indefinite period (Sessions et al. 2004) seem
unwarranted.” They also offered the following suggestions:
Forest managers who use natural regeneration will need to develop planning and
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decision tools that can accommodate spatial variability and include thresholds for
regeneration success with a much longer regeneration phase than commonly
accepted in the region (Minore and Laacke 1992). In contrast with previous
observations (Hayes 1959, Stein 1986), our findings suggest that the prognosis for
achieving reasonable conifer densities are fair to excellent, even on sites with high
cover of broad-leaved shrubs and hardwoods. Although conifer growth may be
delayed by competition over the short term, benefits in terms of wildlife habitat
and site fertility should be considered.
Chaparral as Essential Habitat
The scientific literature is quite clear about the important role shrubs and other non-tree
plant species contribute to an “ecologically healthy and resilient landscape rich in
biodiversity.”
Comparing estimates by Show and Kotok (1924) and USFS vegetation maps from the
mid-2000s, the landscape extent of montane and mixed chaparral has been reduced
significantly on the Stanislaus National Forest. Chaparral cover currently represents 9.9%
of the Forest as opposed to 16.2% in 1924. The cause for this reduction is not clear.
However, shrub cover in the forest understory is probably less than the natural range of
variability (NRV) due to shading by increasing tree density and canopy cover (Safford
2013).
In their paper on high-severity and chaparral, Nagel and Taylor (2005) point out that
“their data indicate that stands of chaparral were a conspicuous feature of the mixed
conifer forest landscape in the northern Sierra Nevada at or near the time of EuroAmerican settlement and that they were maintained mainly by fire.” High-severity fires
lethal to tree species are crucial to maintaining native chaparral vegetation.
Nagel and Taylor further point out that “Our study suggests that maintenance of chaparral
should be an integral part of ecosystem restoration plans for mixed conifer forest
landscapes in the Lake Tahoe basin and northern Sierra Nevada.”
Researchers have also found that post fire shrub dominated landscapes are critically
important wildlife habitat.
While some snag associated species (e.g. black-backed woodpecker) decline five
or six years after a fire, those associated with understory plant communities take
place resulting in similar avian diversity three and eleven years after fire (Burnett
et al. 2012).
Similarly, in a study commissioned by the Forest Service and conducted in the Sierra
Nevada, researchers concluded that native fire-following shrubs are vitally important
to biodiversity in complex early seral forests created by high-intensity fire.
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Many more species occur at high burn severity sites starting several years postfire… and these include the majority of ground and shrub nesters as well as many
cavity nesters. Secondary cavity nesters, such as swallows, bluebirds, and wrens,
are particularly associated with severe burns, but only after nest cavities have
been created, presumably by the pioneering cavity-excavating species such as the
Black-backed Woodpecker. Consequently, fires that create preferred conditions
for Black-backed Woodpeckers in the early post-fire years will likely result in
increased nesting sites for secondary cavity nesters in successive years (Siegel et
al. 2011).
Despite the fact that a significant amount of shrubland will likely be compromised by the
Project, the Scoping Package makes no mention of the important contribution it
represents in post-fire environments or healthy forest ecosystems. Native shrubs are only
seen as invading “brush” that is “already beginning to dominate sites, inhibiting conifer
survival and growth.” Such a view is not only contrary to the Forest’s Service’s stated
goal of enhancing biodiversity, but is contrary to science (Busse et al. 1996, Donato et al.
2009, Baker 2014).
As reported by Odion (2011), the natural succession to conifer vegetation that follows a
fire is also marked by facilitation processes whereby the early species create conditions
that will favor conifers:
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The early successional shrub vegetation restores and increases soil productivity
due to the input of available nitrogen from N-fixing species like Ceanothus
(Conard et al. 1985, Busse 2000), and Fabaceous species (lupines and lotuses),
and the increased nutrients and organic matter in soils from fine root turnover of
the shrubs (Busse et al. 1996).
Conifer nutrition may be facilitated by mycorrhizae that are interconnected to
manzanita (Arctostaphylos) (e.g. Horton et al. 1999).
Facilitation of pine and fir growth by shrubs that reduce drought stress and
function as nurse plants has been documented (Zavitovsky and Newton 1969) and
appears to be a feature of conifer vegetation regions having summer dry
Mediterranean climate, such as the Sierra Nevada (Gomez-Aparicio et al. 2004).
Using historical photography, Russell et al. (1998) documented post-fire
regeneration of shrub vegetation and then succession to conifer forests, which
were again dominated by mature trees 100 years after fire in the 1800’s.
Considering all of these points, it is difficult to reconcile the Forest Service goal of
protecting biodiversity and the Project’s goal of eliminating the remarkable diversity that
is facilitated by shrubs during post-fire succession.
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Natural Conifer Regeneration
The following assumption is one of the primary justifications for the Project:
Without mature live trees to provide a seed source within close proximity to the
burned areas, or the lack of a viable and healthy cone crop, natural conifer
regeneration cannot be counted on within large portions of the Rim Fire area.
We have examined several areas within the Rim Fire perimeter that have been classified
as unnaturally large patches of high-severity. Contrary to the Forest Service’s claims, we
found significant numbers of conifer seedlings deep within these high-severity burn
areas. Data collected by our colleagues along two 1,600 meter transects within large
high-severity patches showed significant conifer regeneration – more than 300 conifer
seedlings per hectare. Areas more than approximately 1,000 square meters without
conifer regeneration were rare.
Photo 4. A conifer seedlings deep within a high-severity burn patch of the Rim Fire.
The Project’s assumption about conifer regeneration is likely based on the assumption
that Sierran mixed conifer trees may only be wind-dispersed and only over short
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distances. However, there is abundant evidence of secondary animal dispersal on Sierran
conifers by rodents and birds (e.g., Clarks nutcracker) (Vander Wall et al. 2005). Also,
even long-distance dispersal of the larger-seeded pines, such as ponderosa, by birds is
possible (Lesser and Jackson 2013). Sagio (1969) concluded that, “Rodent activities-especially those of C. lateralis --are an important contribution to the natural regeneration
of ponderosa pine in this area, especially following a major disturbance to the understory
and/or overstory, such as by logging, road-clearing, and, in the past, fire.”
Also the notion that high-severity fire destroys all seeds in the soil is questionable
because soil can be an effective insulator.
It is incumbent upon the Forest Service to demonstrate that natural conifer
regeneration is not occurring at the level claimed in the Scoping document and
provide that data in the Draft EIS.
Allowing the natural post-fire successional process to occur is the best way to maintain
an ecologically healthy, resilient forest because naturally regenerated forests possess the
greatest genetic variation. Selection pressures on fire-recruiting cohorts of non-sprouting
species allow for rapid rates of evolution needed to adapt to a rapidly changing
environment (Wells 1969). As emphasized by Swanson et al. (2010), naturally
regenerated, early successional forest ecosystems are likely to be better adapted to the
present day climate and may be more adaptable to future climate change. The diverse
genotypes in naturally regenerated forests are likely to provide greater resilience to
environmental stresses than nursery-grown, planted trees of the same species.
ACH – Alternative Competing Hypotheses
As cited in this letter, there is a growing body of literature that is seriously questioning
the fundamental assumptions being used to justify the Rim Fire Reforestation Project.
Namely that the size of high-severity burn patches within the Rim Fire were unnaturally
large, that this was the direct result of past fire suppression, that such an event will result
in the land being overwhelmed by shrubs, and that active management (artificial
reforestation) must occur for the forest to return.
The fire/suppression, conifer-centric paradigm that seems to be the fundamental
foundation of the Scoping document needs to be honestly questioned within the EIS
process for the reforestation project. This is important because many of the statements
within the Scoping document are opinions shaped by the paradigm and cannot meet the
standards of scientific analysis. While some of the statements may be valid in limited
situations, they are so generalized and broadly applied that they sometimes border on
hyperbole.
Beyond the unsupportable claims that much of the post-fire forest will be over taken by
shrubs into the foreseeable future and that conifer seedlings do not exist within large,
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high-severity patches, the Scoping document attempts to justify the Project by
exaggerating the threat of fire. For example,
The brushfields, along with the dead trees that fall among them, can also quickly
spread high intensity fire.
Fire spreads through the burning of fine fuels and small diameter material - logs and large
pieces of wood burn by smoldering combustion, which do not play a significant role in
fire behavior. As noted above, high/mixed-severity fire is required to maintain a healthy
mosaic of forest habitat. The Scoping document also leaves the questionable impression
that high-intensity fire is inherently bad and something that it can be eliminated from the
landscape through management actions.
Spending scarce resources far from human communities in an attempt to prevent large
patches of high/mixed-severity fire is not fiscally or ecologically sound policy. As the
February 6, 2015, Round Fire near the Inyo National Forest demonstrated, given drought
and strong winds, high-severity fires will occur even with limited fuel. Forty homes were
lost and 7,000 acres were burned in a widely-spaced sagebrush environment (Photo 5).
Research by Lydersen, North, and Collins (2014) also raised questions concerning the
efficacy of high-severity fire prevention strategies.
Our results suggest that wildfire burning under extreme weather conditions, as is
often the case with fires that escape initial attack, can produce large areas of highseverity fire even in fuels-reduced forests with restored fire regimes.
It is time for the Forest Service to seriously consider a process used by other federal
agencies, such as the Central Intelligence Agency, when there are two or more competing
hypotheses concerning important policy/management decisions.
The Alternative Competing Hypothesis (ACH) process can take several forms, but it
often centers around two teams of analysts who have conducted Assumption Check
exercises to avoid personal bias. These two teams then examine all the available data and
argue for the validity of their conclusions.
We strongly encourage the Forest Service to conduct an ACH process through the
Draft EIS because the Scoping document clearly demonstrates there are inherent
biases that are shaping management policy that will not likely achieve the desired
outcomes – maintaining an ecologically healthy and resilient landscape rich in
biodiversity.
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Photo 5. Homes lost in the Round Fire, near Mammoth, Inyo National Forest.
Sincerely,
Richard W. Halsey
Director
California Chaparral Institute
www.californiachaparral.org
[email protected]
P.O. Box 545
Escondido, CA 92033
760-822-0029
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Citations
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reconstructed from General Land Office survey data. Ecosphere Vol 5 (7): 1-70.
Burnett, R.D., M. Preston, and N. Seavy. 2012. Plumas Lassen Study 2011 Annual
Report. U.S. Forest Service, Pacific Southwest Region, Vallejo, CA.
Busse, M. D. 2000. Ecological significance of Nitrogen Fixation by Actinorhizal shrubs
in interior forests of California and Oregon. USDA Forest Service, General Technical
Report PSW-GTR-178.
Busse, M. D., P. H. Cochran, and J.W. Barret. 1996. Changes in ponderosa pine site
productivity following removal of understory vegetation. Soil Science Society of
America Journal 60: 614-621.
Conard, S.G., A.E. Jaramillo, and S. Rose. 1985. The role of the genus Ceanothus in
western forest ecosystems. USDA Forest Service General Technical Report PNW-GTR182.
Donato, D.C., J.B. Fontaine, J.L.Campbell, W.D. Robinson, J.B. Kauffman, B.E. Law.
2009. Conifer regeneration in stand-replacement portions of a large mixed-severity
wildfire in the Klamath-Siskiyou Mountains. Can. J. For. Res. 39: 823-828
Gómez-Aparicio, L., R. Zamora, J. M. Gómez, J. A. Hódar, J. Castro, and E. Baraza.
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