Helping The Forest Service Improve Its Strategic Community Fuelbreak Improvement Project
The Fire Safe Council For Monterey County, joined by other organizations, has submitted a detailed comment letter to the U.S. Forest Service on its proposed Strategic Community Fuelbreak Improvement Project ("Project") The letter proposes changes to the Project to make it more likely the fuelbreak will be completed, and more effective when completed.
Important is that you can still submit comments to the Forest Service supporting the FSCMC's comment letter. Click here to see how you can email the Forest Service your comments of support.
The fuelbreak is proposed alongside part of the historic "Big Box Firebreak" that surrounds much of the Monterey County portion of the Los Padres National Forest. The Big Box Firebreak has been used for decades to stop some of the largest wildfires in U.S. history from burning through communities around the National Forest in Monterey County.
A fuelbreak is an area where vegetation is reduced but typically not removed entirely. Fuelbreaks are generally made in preparation for fires, before they start. Fuelbreaks can make it safer to install firebreaks during a fire. Firebreaks are a relatively narrow area where all vegetation is removed, which are usually installed after a fire has started. Fuelbreaks are used to make firebreaks more effective and to provide safety for firefighters. Properly designed and maintained fuelbreaks can also stop the spread of fire.
Here is a link to a 2011 Forest Service report on fuelbreaks that helped protect communities in New Mexico and Arizona from a forest fire, including before and after aerial photographs. Note that at least one fuelbreak was about 1/2-mile wide (bottom of page 2 in the report).
You can read the Forest Service's "scoping letter" that describes the current Project and asks the public to submit comments on it by clicking here.
The deadline for submitting comments that the Forest Service would be required to consider by federal law was February 12, 2013. However, you can continue to submit comments that the Forest Service has the option to consider, until the environmental impact statement is released, which may be another year.
That the Forest Service is proposing any fuelbreak project along part of the historic Big Box Firebreak around the Los Padres is a major step forward. However, as the Project is currently described, there is a need for substantial modifications to the Project to help ensure that the fuelbreak will be feasible to construct and be effective once finished.
For example, the current Project description does not include work along a 10-mile segment of the Big Box Firebreak that, in the past, has stopped fires from burning toward Carmel Valley. You can see the 2008 Basin Fire burning toward Carmel Valley in the photo at the top of this page, which was stopped using the portion of the Big Box Firebreak that is not included in the Project. There are a number of other substantial shortcomings in the current description of the Project, see below.
The point of the FSCMC comment letter, and the point of the public expressing support for it to the Forest Service, is to help the Forest Service justify modifying the Project.
Modifications To The Project Covered In FSCMC's Comment Letter
Modifications to the Project requested in the FSCMC comment letter include:
Remove maximum fuelbreak width and change to be the width needed to conform with the language in MCCWPP sections 9.1.1 and 9.1.2. The scoping letter provides for maximum fuelbreak widths of 150 feet in some areas and 300 feet in others. In some areas there is a fixed width of 150 feet (which is both a minimum and maximum width), but in other areas there is no minimum, meaning in some areas the minimum width can be zero feet. The FSCMC comment letter says to apply a minimum width of 150 feet in all areas, but not less than the width that will conform with MCCWPP sections 9.1.1. and 9.1.2., which is essentially the width needed for the fuelbreak to be effective given various conditions in the locality, and during adverse fire conditions.
Provide that any feathering of the fuelbreak for aesthetics will be outside the width needed to ensure the fuelbreak's effectiveness. Forest Service comments at a scoping meeting indicate that the width of the fuelbreak could be narrowed by "feathering" its edge for aesthetic purposes. The comment letter asks for clarification that any feathering will be outside the width needed for the fuelbreak to be effective.
Include a complete list of tools for constructing and maintaining the fuelbreak. The scoping letter's description of the Project leaves out tools that could be used to make completion of the Project feasible. This is especially important given that some of the Project will be in wilderness, where availability of alternative tools is critical given that some conventional tools will almost certainly be prohibited (motorized equipment is generally prohibited in wilderness before a fire has started, especially heavy equipment). If a full list of tools that are currently approved for use in wilderness is not considered, then the Project may not be completed due to needless high cost, making it infeasible.
Include protection of watersheds that provide water for domestic and commercial uses, including for agriculture. Federal law provides for protecting watersheds from fire where they provide water for water systems. Primary reservoirs in the county, important to the county's water supply and agricultural economy, have their headwaters in the Los Padres National Forest. The Project description in the scoping letter currently does not include this concept.
Include the northern portion of the historic Big Box in the Project. The map accompanying the scoping letter shows a 10-mile gap in the fuelbreak from about Botchers Gap on the west to the Los Padres Dam on the east. The comment letter explains how this portion of the historic Big Box Firebox has been proven to stop fires, protecting numerous at-risk communities including Carmel Valley, and was planned to be used when the Ventana Wilderness was being proposed for creation.
Include treatments along access to Tassajara and Church Ranch in the Project. These areas were left unprotected during the Basin Fire due to hazardous fuel accumulations along access roads.
Clarify that the Project will be completed sooner than 10 years. The scoping letter can be interpreted as saying that the Project may not be completed until 10 years after the Project is started. If started soon, 10 years would be about 15 years after the Basin Fire. However, the Kirk Fire and the Basin Fire were only 9 years apart, meaning the next major fire that starts in the Los Padres could occur before the project is competed unless completed sooner than described in the scoping letter.
Update the list of "at-risk communities" to include those named in the MCCWPP. The scoping letter says the Project is to help protect "at-risk communities," which is a term of art from federal law. However, it appears from comments and maps at a scoping meeting that an old, incomplete, list of at-risk communities is being used, which would leave many at-risk communities off the radar for protection. The MCCWPP identifies many at-risk communities that are not included in the old data.
Update areas designated as wildland urban interface in the MCCWPP as wildland urban interface for the Project.Federal law provides that WUI includes where it is designated to be in a community wildfire protection plan. The Monterey County Community Wildfire Protection Plan, extends WUI over the historic Big Box Firebreak, which can provide benefits to the Forest Service in accomplishing the Project. However, it appears the Forest Service is using old WUI data, from before the MCCWPP was executed, which shows little WUI in Monterey County, with little or none over the location of the historic Big Box Firebreak.
Include private land owned by willing participants in the Project. The original intent of the Forest Service's Firescape Monterey process was that it be an "all lands" approach to preparing for wildfires (including private land owned by willing participants). Including private land owned by willing participants in the Project could help avoid gaps in the fuelbreak.
The FSCMC comment letter also explains how applicable wilderness legislation and the National Environmental Policy Act support the modifications requested in the comment letter.
It is important to submit comments so they are included in the record, so they are available for the Forest Service to point to as justification for modifying the Project should it decide to do so.
The purpose of having as many people as possible support the FSCMC's comment letter was to provide the Forest Service with a consistent unambiguous message on how the Project should be modified, and to show that the proposed modifications have broad support.
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