Oregon Natural Resource Industries Stand Against the ODF 2023 HCP
Wildfires increase when Timber Harvests decrease
Smoke is harmful to people and animals
One Million Acres Burned in the 2020 Labor Day Fire
One Million Acres Burned in the 2020 Labor Day Fire
One Million Acres Burned in the 2020 Labor Day Fire
One Million Acres Burned in the 2020 Labor Day Fire
One Million Acres Burned in the 2020 Labor Day Fire
HCP Lacks Wildfire Response Plan
Letter to the Board of Forestry
From: Jennifer Hamaker <jenhamaker1@gmail.com>
Date: July 14, 2023 at 10:33:25 PM PDT
To: Karla.S.Chambers@odf.oregon.gov, boardofforestry@odf.oregon.gov, Ben.Deumling@odf.oregon.gov, Liz.Agpaoa@odf.oregon.gov, Chandra.Ferrari@odf.oregon.gov, Brenda.McComb@odf.oregon.gov, Joe.Justice@odf.oregon.gov, Cal.T.Mukumoto@odf.oregon.gov, Olivos-Rood Odf <hilary.olivos-rood@odf.oregon.gov>, Jim.Kelly@odf.oregon.gov, Geoff.HUNTINGTON@oregon.gov, David Yamamoto <dyamamoto@co.tillamook.or.us>
Subject: Fire mitigation & Emergency Response integrated into HCP
To Chair Kelly, Board of Forestry Members, State Forester Mukumoto, Chief ODF Foresters, and Geoff Huntington,
Oregon experienced record-setting wildfires in 2020 and 2021 that caused expansive stretches of fire-killed or damaged trees adjacent to roads, trails, and facilities which pose a threat to health, safety, and property. These obstructions should have been removed as soon as possible to mitigate injury, property damage, road and rail access, and future fuel loads. 1 million trees burned in the Labor Day fires, the equivalent of 15 billion board feet of lumber which was a loss of $30 billion. These fires destroyed thousands of structures, displaced tens of thousands of people, and caused nine deaths. Hundreds of millions of dollars were spent fighting the fires. Fire suppression practices over the past 100 years have created overly dense forests, fueling bigger and more destructive forest fires. Industry Professionals, Scientists, and Foresters agree that the accumulation of ground fuels added to the massive amount of destruction. State forests are no exception.
We urge the Board of Forestry and ODF to learn from the Labor Day fires and protect our forests. It is important to have a mitigation plan and an emergency response plan. No where in the HCP does it address the fire mitigation, emergency response, or alternative arrangements, in regards to forest fire and the aftermath especially when it threatens or destroys private property, public access, causes injury or damage.
The HCP mentions controlled burns (as seen in the screenshot below). We know that controlled burns sometimes get out of control and become a cause of forest fire. There needs to be a plan incorporated into the HCP that addresses this risk.
Also, included below is a screenshot of section 3.8 of the HCP. This shows an estimated 90% increase in recreational use during the permit term (70 years). We know that humans cause many wildfires. With a 90% increase in human use and accumulation of fuels over 70 years is an equation with predictable results; FIRE!
Imminent forest fire risk to all unmanaged state (and federal) forests should include and incorporate a fire mitigation plan and an emergency response. The passively managed forests, identified in the Western Habitat Conservation Plan, needs another layer of fire mitigation and emergency response planning.
“NEPA compliance under 36 CFR 220.4(b)(1):
(b) Emergency responses. When the responsible official determines that an emergency exists that makes it necessary to take urgently needed actions before preparing a NEPA analysis and any required documentation in accordance with the provisions in §§ 220.5, 220.6, and 220.7 of this part, then the following provisions apply.
(1) The responsible official may take actions necessary to control the immediate impacts of the emergency and are urgently needed to mitigate harm to life, property, or important natural or cultural resources. When taking such actions, the responsible official shall take into account the probable environmental consequences of the emergency action and mitigate foreseeable adverse environmental effects to the extent practical.”
This is not an alternative arrangement as defined by the Council of Environmental Quality in 40 CFR 1506.12.
Ҥ 1506.12 Emergencies.
Where emergency circumstances make it necessary to take an action with significant environmental impact without observing the provisions of the regulations in this subchapter, the Federal agency taking the action should consult with the Council about alternative arrangements for compliance with section 102(2)(C) of NEPA. Agencies and the Council will limit such arrangements to actions necessary to control the immediate impacts of the emergency. Other actions remain subject to NEPA review.”
Under NEPA regulations, any of these forestlands that are under an HCP are required to file additional analysis to apply for any environmental impact permit before action is taken. This analysis and review process can take years. We suggest incorporating emergency response and fire mitigation plans into the initial permit to expedite an emergency response. We know fire will happen, let’s prepare now, not when it’s too late.
The Board of Forestry and ODF knows that project planning, the NEPA process, and Endangered Species Act (ESA) consultation takes forever. This HCP is a 70-year, multi-generational plan. A lot can happen in 70 years. Fuel loads will build and dry for 70 years, especially in passively managed forests. This plan needs fire mitigation plans and emergency response plan’s integrated into the HCP so fire fighters can respond quickly and effectively. The Board of Forestry has delayed the NEPA process until November. While we’re waiting, a fire mitigation plan and an emergency response plan needs to be incorporate into the HCP.
The Board of Forestry’s commitment to ensure adequate time for public involvement and accommodate the pre-decisional administrative review process will further slow the progress of removing dead, dying and obstructive trees that cause hazards. Trees will continue to deteriorate and fall, posing a serious risk of property damage, injury, or death. These trees also emit carbon while they decompose. Beetles and bugs infest burned wood quickly and cause further tree mortality and close the window for salvage harvesting. A plan to remove trees after a fire that pose a threat to property damage, injury, roads, etc. needs to be included in the HCP.
We are aware of the risk of forest fire. We are aware that passively managed forests burn hotter, longer, cause more damage, and cost more than fires in well managed forests. We are aware that a 90% increase of human use also increases fire risk. We are aware of the slow NEPA process and ESA consultation. We are aware that having the Federal Government involved further slows the response time for emergencies. Please, at least prepare for forest fires! Our forests and wildlife are important to Oregon. Don’t leave them to bear the burden of a policy that doesn’t protect them.
Sincerely and with grave concern,
Jen Hamaker
President
Oregon Natural Resource Industries
805-245-2612
