William & Mary Environmental Law and Policy Review
Abstract
Management plan revision is currently underway for national forests in the Sierra Nevada Mountains of California, the Pacific Northwest, and other regions of the country under the U.S. Forest Service’s 2012 Planning Rule. With respect to dry ponderosa pine and mixed-conifer forests in the Sierra Nevada and Pacific Northwest, agency scientists and others claim that these forests were historically open and parklike, with primarily large, well-distributed trees, few smaller trees, and sparse underlying vegetation, leaf litter, and woody debris. Large, high-severity fire was rare. Fire exclusion since the early 1900s has led to the “densification” of these forests and unnatural accumulations of flammable materials (“fuels”). Currently, the frequency and spatial extent of high-severity fire greatly exceed the “natural range of variation” (the historical range) for these forests. Agency scientists and others conclude that there is a need to restore these forests, bringing them closer to their historical structure and fire regime by means that include forest thinning (logging).
On the other hand, some scientists argue that, historically, western dry ponderosa pine and mixed-conifer forests burned with mixed severities. High-severity fire was infrequent, but not rare or exceptional, and occasionally burned over extensive areas. Historically, these forests were not uniformly open and parklike. They were generally dense, with many small trees and abundant underlying shrubs and other vegetation. These scientists claim that, currently, high-severity fires are not outside the natural range of variation for frequency and spatial extent for western dry forests. According to these authors, western dry forests have always been dangerous places for housing and other development.
This is an ongoing controversy in the scientific literature. With respect to western dry ponderosa pine and mixed-conifer forests, which model of historical fire and forest structure is accurate, and what should we conclude concerning current fire and forest structure in relation to historical conditions? Much depends on how this debate is resolved. If the mixed-severity model is accurate for western dry forests, and in these forests high-severity fires are currently no more frequent and extensive than they were historically, Forest Service proposals to “restore” these forests by means of thinning, with a goal of reducing tree densities to low levels over extensive areas, is misguided.
This Article will discuss this controversy. This Article will also discuss the faulty use of science in plan revision documents and cited sources. It will be argued that the 2012 Planning Rule and National Environmental Policy Act (NEPA) regulations compel the Forest Service to adopt a more genuinely scientific approach to management plan revision and forest management.
