Pole Creek Salvage Fire & Fuels Specialist Report

Transcription

1 Pole Creek Salvage Fire & Fuels Specialist Report Jinny Reed July 2013 Introduction The purpose of this analysis is to assess impacts of the proposed actions on activity generated Coarse Woody Debris along with potential impacts to Air Quality during machine pile burning operations. This project proposes salvage logging and firewood cutting in burned areas with high vegetation mortality rates following the 2012 Pole Creek Fire. Activity fuels would be generated resulting in machine piles to be burned post harvesting methods. Machine pile burning of logging and firewood cutting activity generated fuels would occur in isolated areas associated with landings at treatment units. Issue: High concentrations of Coarse Woody Debris and meeting National Ambient Air Quality Standards. Issue Measures: Tons per acre of coarse woody debris burned, converted to pounds per acre of emissions released during machine pile burning operations. Current conditions will be quantified for an analysis of alternatives and their effect on Coarse Woody Debris and National Ambient Air Quality Standards. Regulatory Framework / Management Direction Coarse Woody Debris (CWD) Guidance for CWD on federal land is found in the Deschutes National Forest Land and Resource Management Plan (LRMP) 1990, as amended by the Northwest Forest Plan. The LRMP and NWFP give management direction for CWD. All proposed salvage units are within the Matrix land allocation. Standards and Guidelines for Matrix as stated in the NWFP A renewable supply of large down logs is critical for maintaining populations of fungi, arthropods, bryophytes and various other organisms that use this habitat structure. The objective is to provide CWD well distributed across the landscape in a manner which meets the needs of species and provides for ecological functions. An important factor is to provide the CWD within a forest patch so that the appropriate microclimate for various organisms that use this substrate is available (NWFP, pg.c-40). Specific measures for CWD follow. In eastern Oregon and Washington, a minimum of 120 linear feet of logs per acre or greater than or equal to 16 inches in diameter and 16 feet long should be retained. Decay class I and 2 logs can be counted towards these totals. Down logs should reflect the species mix of the original stand. In all cases, standards and guidelines from current plans and draft plan preferred alternatives apply if they provide greater amounts. In areas of partial harvest, the same basic guidelines should be applied, but they should be modified to reflect the timing of stand development cycles where partial harvesting is practiced (NWFP, pg.c-40). The proposed action has salvage units in two LRMP management areas: Front Country Unseen (FCU) and Scenic Views. Neither management area has a specific direction pertaining to salvage. Both management areas are to be managed for high scenic quality currently and in the future, and FCU has a higher emphasis on CWD.

2 Scenic Views (M9-90): Prescribed fire and other fuel management techniques will be used to minimize the hazard of a large high intensity fire. Front Country (M18-36): Slash will be treated to minimize the chances of large wildfires but will not be cleared to the extent that the forest floor is devoid of all slash and logs. Some slash and larger dead material will be left for ground cover for soil protection, microclimates for establishment of trees, and small mammal habitat. Air Quality & Smoke Management Air quality is an important aspect of the central Oregon area. For the most part, air quality conditions are good except during certain times in the winter when temperature inversions create woodstove pollution problems, and certain times in the spring and summer when prescribed burning activities are occurring (1990 LRMP, pg. EIS 2-131). Guidance for Air Quality Standards can be found in the Smoke Management Guide for Prescribed and Wildland Fire 2001 Edition and the Oregon State Smoke Management Plan (OAR-SMP ). Air Quality can be defined as the presence in the atmosphere of a substance or substances added directly or indirectly by a human act, in such amounts as to adversely affect humans, animals, vegetation, or materials. The 1990 federal Clean Air Act (CAA) is a legal mandate designed to protect human health and welfare from air pollution. Individual states develop programs for implementing the CAA through State Implementation Plans, for this area we utilize the Oregon Department of Forestry (ODF) Smoke Management Plan. National Ambient Air Quality Standards (NAAQS) are defined in the CAA as levels of pollutant above which detrimental effects on human health or welfare may result. NAAQS have been established for the following air pollutants: particulate matter (PM10 and PM 2.5), sulfur dioxide (SO2), nitrogen dioxide (NO2), ozone, carbon monoxide and lead. Primary NAAQS were established to protect human health; secondary NAAQS were established to protect human welfare. The standards are expressed in terms of different averaging times, for example, annual, 24-hour, and 1-hour. An area that is found to be in violation of a NAAQS is called a non-attainment area. Particulate matter emissions are produced from common Forest Service activities such as prescribed fire, road construction, road use, and mining. Carbon monoxide, nitrous oxides (NO), and volatile organic compounds (VOC s) are produced from prescribed fire, and vehicle and machinery operation. Another provision of the CAA that affects Forest Service activities is the Prevention of Significant Deterioration provisions (PSD). The premise behind the PSD is to prevent areas that currently have very clean air from being polluted up to the maximum point established by the NAAQS. Three air quality classes were established, Class I, Class II, And Class III. Mandatory Class 1 Airsheds are protected by the PSD program and include national parks over 6,000 acres, national wilderness areas over 5,000 acres, national monuments, national seashores, and other areas of special national or regional natural, recreational, scenic, or historic values that were in existence as of August These are also considered smoke sensitive and require restrictions on prescribed burning during the Visibility Protection Period July 1 to September 15 (OAR , OAR , OAR ). When prescribed burning is conducted outside the Visibility Protection Period, in addition to compliance with smoke management instructions issued in the daily forecast and compliance with all conditions, burn bosses and field administrators are encouraged to closely observe local conditions at the burn site to avoid the main smoke plume entering a Class I Airshed at ground level. Class I Airsheds are subject to the tightest restrictions on how much additional pollution can be added to the air (DEQ, OAR , pg. 6). The Three Sisters Wilderness is the designated Class I Airshed for this project.

3 A Smoke Sensitive Receptor Area (SSRA) is an area designated by the board, in consultation with the Department of Environmental Quality that is provided the highest level of protection under the smoke management plan because of its past history of smoke incidents, density of population or other special legal status related to visibility (OAR ). The following are potential project area SSRA s: Redmond located 20 air miles and Bend approximately 12 air miles. In 2005, the ODF Smoke Management Program developed a concept known as the Best Burn Day Strategy. This strategy helps to reduce the amount of burning necessary on marginal days when a higher likelihood of smoke intrusions exists. Specifically, the Best Burn Day Strategy seeks to: provide maximum opportunities for land management objectives to be met while maintaining air quality, health standards and visibility objectives. Burning can be managed more effectively with improved coordination, communication, technology, public education, increased utilization of forest fuels and maximizing burning during optimum burning conditions whenever possible (ODF-SMP, pg. 1). Analysis Methods Measures for comparison purposes between alternatives for machine pile burning activity created fuels: Expected total particulate matter (PM) emissions Duration and timing of emissions Communities potentially affected Three Sisters Wilderness, Class I Airshed potentially affected Activity CWD will be determined using Photo Series for Quantifying Natural Fuels, (Ottmar et. al. 1998) In order to determine if proposed activities will potentially violate NAAQS or if PSD increments exceed Class I Airshed regulations, conversion calculations will be made utilizing estimated volumes from proposed salvage activity will be utilized to determine fuel loading in tons/acre for input into First Order Fire Effect Model (FOFEM) which calculates emissions in pounds per acre from pile burning residual fuels at landing sites. FOFEM is a computer program used to help determine particulate emission limits; developing timber salvage guidelines following wildfire; and comparing expected outcomes of alternative actions. In order to determine the effects to air quality resulting from machine pile burning, an analysis will be completed using FOFEM. The assumptions made within FOFEM and in this analysis are as follows: Smoke potentially impacts human health through inhalation of PM. The National Fuel Loading Models (FLM) data set was used for prescribed burning of machine piles. This data set was masked to areas within the Pole Creek Salvage project area where pile burning may occur under each Alternative. The FLM surface fuel classification system (Lutes et al. 2009) was developed by the Missoula Fire Sciences Laboratory to characterize wildland surface fuels. The FLM provide a simple and consistent way for managers to describe onsite fuels for input into the FOFEM model. For every ten acres of material harvested, 1 10 X 10 machine pile of CWD would be generated at unit landings. Approximately 14 tons of material per pile will be the input into the emissions calculator to measure pounds per acre of particulate matter emitted.

4 The Pole Creek fire burned through the analysis area with a range of severities within the 10,683 acre project area: 2,297 acres/22% are low severity, 3,251 acres/30% are mixed severity, and 5,148 acres/48% are high severity or stand replacement. In moderate and high severity portions of the fire there are no surface fuels other than sparse patches of shrub, duff, and litter that remain. The standing material consists mainly of scorched trees. Ladder fuels and the standing trees have either completely consumed or all that remains is the bole and limb wood. Desired Condition Fireproofing the project area is not reasonable and is not an objective of this project. It is acknowledged that the desired condition for some wildlife species that are dependent on late and old forested habitat conditions require some areas of high forest fuel loading and that management to retain habitat for these species results in high wildfire risk remaining on the landscape. However, the desired condition from a fire and fuels standpoint is for the landscape to be as close to a characteristic level of disturbance as possible in order to create a safe environment for firefighters and the public while meeting regulatory framework and management directives. The main objectives are to: Reduce surplus activity fuels that remain after meeting wildlife and soil resource standards and guidelines Meet National Ambient Air Quality Standards Ecological Trends - Alternative 1 (no action) No management activities would occur; therefore, no activity fuels will be created resulting in no pile burning with no impacts to air quality. From an ecological stand point, it is estimated within 8 to 12 years CWD in moderate and high severity portions of the fire could exceed 70 tons per acre, meaning much of the fire killed trees would fall down (Russell et. al. 2006) resulting in a horizontal fuel bed exceeding the desirable fuel load average of 10 to 20 tons per acre (Brown, 2003). Fire behavior would exceed firefighter capabilities within a few years and suppression efforts would require indirect tactics. Future fires are expected to burn with high intensities impacting resources and killing most vegetation. Fire killed trees (snags) pose a hazard to firefighters and the public entering the area. As snags age they become less stable and are likely to fall (Russell et. al., 2006) increasing the risk to firefighters and the public. Fuel loading from fallen dead material and live vegetation growth are expected to accelerate dramatically by the end of the first decade (Russell et. al., 2006). The majority of the fire killed trees will have fallen creating a fuel bed with large amounts of CWD and live vegetation would continue to grow adding to the already volatile fuel loading, this fuel loading would have to be modeled as a slash blow down fuel type. The rate of accumulation would slow down but fire behavior would continue to increase as new live vegetation moves into the area. During fire activity live vegetation is dried by the advancing fire, making live vegetation available as fuel thus Machine pile burning is modeled under fall season conditions along with a high level of confidence of moisture in the weather forecast. PM outputs under both alternatives are modeled using the existing fuel loading profile. Post wildfire effects have ultimately reduced fuel loading emissions prior to pile burning. Using the existing fuel profile, rather than the post wildfire fuel profile, allows for the most conservative comparisons of emissions or a worst case scenario approach accounting for temporal variability associated with treatments across the project area.

5 further increasing fire behavior. Fires burning in this fuel type are capable of generating extreme fire behavior resulting in heavy resource damage (Brown et. al., 2003). For example, the 2003 B&B fire, a burned area located on the Sisters Ranger District adjacent to the Mt. Jefferson Wilderness, large portions of the historic 90,000 acre fire burned as high severity. In unmanaged areas of the old fire, snags fell over time. The aerial hazards are reduced; however, this material is now available as ground fuel in the form of heavy loadings of CWD combined with regrowth of new vegetation thus increasing fire behavior and fire intensities. The resulting fuel bed is less than 10 years old which supported the 2012 Canyon Creek fire inside the previously burned area with very active fire behavior. The snag hazard along with increased fire line intensity due to fuel loadings made Canyon Creek fire suppression actions unattainable during the first burn period. Although wildfire ignition is no more likely under Alternative 1 than it is under Alternative 2 and 3, fire size and intensity have the potential to be greater; and therefore, smoke production would be greater and emit for longer duration in untreated areas versus treated areas. Direct and Indirect Effects - Alternatives 2 & 3 The Proposed Action described in detail in the Pole Creek Fire Environmental Assessment, would treat 980 acres within the project area through activities such as timber harvest and firewood sales. Alternatives 2 & 3 are combined for the purposes of this analysis due to the insignificant change in volume removed. It is recognized that CWD is an essential component of ecosystems within the Pole Creek fire area, providing wildlife habitat, soil protection and other important ecological functions. CWD and adequate snags would be maintained at required levels to meet resource needs. CWD The action alternatives would remove fire killed trees from harvest units, resulting in a reduction of CWD. Fire killed trees have lost most of their moisture making them brittle and more susceptible to breakage (Lowell et. al., 2010). During the felling and removal process it is anticipated that there would be higher than normal breakage typically associated with timber felling therefore more dead material would be left onsite scattered throughout the unit to meet resource needs. This material would be compact and keyed to the surface, reducing soil movement and providing additional resource benefits while having minimal effect on future fire behavior. Loading of yarded fire killed timber would generate concentrations of branch wood and possibly tree tops (ranging from 3 to 12 in diameter) at landing areas. Post logging methods, machine piles would be created at landings for fall season burning to further reduce isolated concentrations of CWD and to enhance visual quality within the project area. Fuels on the forest floor would consist of scattered material of various size classes. Snags and large logs would remain in the units to meet CWD standards and guidelines as addressed in NWFP and LRMP direction. These guidelines were developed with consideration for fire and its role in developing and sustaining these ecosystems. Out-year fire behavior is expected to be dominated by young shrubs along with small trees both planted and natural seedlings reoccupying the site. Direct and indirect effects to soil would be avoided, minimized, and mitigated prior to and during machine pile burning through utilization of the following Best Management Practices (2012 BMP s, pg. 56): Piling and burning only the CWD that is necessary to be disposed of to achieve treatment objectives. Locate CWD piles in areas where the potential for soil effects is lessened and that do not interfere with natural drainage patterns.

6 Minimize the amount of soil or other noncombustible material in slash piles to promote efficient burning. Piles would be constructed in such a manner as to promote efficient burning. Burning of large stumps and large sections of logs would be avoided to reduce the duration of the smoldering phase. Avoidance of burning when conditions would cause the fire to burn to hot and damage soil conditions. Resource specialists would monitor and evaluate landings for potential indirect effects, post pile burning operations. Specialists would access the need for further stabilization treatments to minimize soil and site productivity loss and deterioration of water quality both on and off the site. Indirect effects would result in some secondary benefits, such as vehicle access to the area would be less hazardous for firefighters and all forest users. Within the treated areas increased amounts of aerial hazards (snags) would have been removed. In addition, fire behavior and fire intensities adjacent to roads would be lowered as higher levels of vertical and horizontal CWD would be removed. Suppression forces would not be hindered by the high density of snags or high levels of CWD in the units which would allow immediate and appropriate action during fire suppression operations. Air Quality Past experience has shown that during pile burning operations, significant air quality declines are limited in scope to the general burn area and of short duration with the most significant impacts occurring under strong, persistent inversions or highly stable air masses. Burn plan prescriptions are implemented to avoid ignitions under these conditions. No direct and indirect effects would occur in the Three Sisters Wilderness Class I Airshed. The project area is adjacent to Three Sisters Wilderness a designated Class I Airshed. Prevailing wind patterns in the project area are typically a predominant west wind. Machine pile burning operations would occur outside the Visibility Protection Period (OAR , OAR , and OAR ) as stated and during meteorological conditions conducive to winds blowing out of the wilderness versus into the wilderness Class I area. Direct and indirect smoke impacts to non-attainment areas would be avoided through strategic planning. Oregon s non-attainment areas are Eugene/Springfield, Oakridge, and Klamath Falls all located >50 miles from the project area. The low expected total emissions; distance from project area, along with careful consideration of forecasted wind direction and ventilation index guidelines would eliminate impacts. Direct and indirect smoke impacts to SSRA s are expected to be minimal. Machine pile burning operations would occur during the fall months and would likely be visible from Highway 20, Highway 126, the town of Sisters, and other outlying sensitive communities east of Sisters including Bend and Redmond. Other than visual impacts, with low expected total emissions, and distance from these concern areas, no direct smoke impacts are expected to occur. Evening air-mass cooling may cause smoke to pool in drainages however, burning material in the pile form increases combustion therefore reducing emissions. In addition, the project burn boss would implement through meteorological scheduling for maximum smoke dispersion and favorable plume transport conditions. If the airshed becomes saturated from operations and domination of environmental factors further, ignitions would be delayed until atmospheric ventilation improves. Proper Go No Go planning based on atmospheric conditions would reduce all direct and indirect effects to sensitive communities from smoke emissions. Table 1 shows a comparison of estimated smoke emissions across the project area. Calculations were made using FOFEM 6.0. PM 2.5 is considered criteria pollutant deemed most harmful to public health and can be effectively monitored.

7 exacerbate the increases in fuel loadings. Application of prescribed fire is the most promising option for suppression actions, without the reintroduction of fire as a fuels management treatment, would further would continue to increase the risk to life, property, fire suppression crews, and natural resources. Continued response required in the current Fire Management Plan. Regardless of alternative, the increase in fuel loading scale and frequency within historical range would be difficult to achieve while providing for the suppression risk. The ability for appropriate management response is possible under certain circumstances, however the fires would continue to be managed in the project area with a suppression objective due to the resource values at Fire and Fuels Management Wildfires would continue to be suppressed in the analysis area. It is likely that Present and Ongoing Actions out. Air quality impacts from past prescription burns no longer occur since smoke disperses quickly after fires are of increased Forest visitation over the last decade in these areas (Whychus Watershed Analysis, 2009 & 2013). may be indicative This 2007) from fires human-caused 36 to compared from fires caused human- (19 increased dramatically has areas elevation high in fires human-caused of amount The watershed. the in fires total the of 63% or starts, caused human were (100) these of percent Thirty-six group. association plant pine ponderosa the within caused, human and lightning both fires, 280 been have There year. per stands hemlock mountain and lodgepole elevation higher the in 7 to stands pine the in 13 from ranging watershed Whychus the in year per starts fire 21 of average an are There action. suppression required that 2007 and 1980 between lands Forest National on watershed Whychus the within fires 535 were there level watershed the At actions. suppression fire past of result a partially is project this for need The Management Fuels and Fire area. analysis Fire Creek Pole the of effects fuels and fire cumulative the to contribute to potential the have that projects and processes activities, describes following The Actions Past - Table 1. Worst Case Scenario of PM Emission Outputs under Alternatives 2 & 3. ALTS Est. tons/acre Material Burned Est. # Machine Piles Burned PM 10 Emissions lbs./acre PM 2.5 Emissions lbs./acre Total Duration Hours & PM10 = suspended particulates less than 10 microns in size PM2.5 = suspended particulates less than 2.5 microns in size Implementation of the action alternatives (2&3) would remain consistent with the goals and objectives, and standards and guidelines of the NWFP as amended. Air Quality standards would be maintained at a level to meet state and federal standards (Clean Air Act) through the coordination and compliance with Oregon Department of Forestry Smoke Management Plan guidelines and approval process. All burn operations would be coordinated through Oregon Smoke Management Meteorologists and would follow the Oregon Department of Forestry Smoke Management Plan of Best Burn Day Strategy to eliminate effects associated with smoke emissions as it relates to Air Quality.

8 24p. Ogden, UT: U.S. Department of Agriculture, Forest Service, Intermountain Forest & Range Experiment Station. Brown, J.K Handbook for inventorying downed woody material. General Technical Report INT : Management and Ecology Forest treatments. reduction fuel forest of principles Basic Skinner. C.N. and J.K. Agee, minimizing fire behavior and crown fire potential in ponderosa pine type forests. There are no upland areas currently analyzed for fuel reduction treatments inside or adjacent to the project analysis area. Air Quality Recent lowland restoration projects, which are still being implemented on the south end of the Sisters Ranger District, including Sisters Area Fuels Reduction, Glaze Restoration, Highway 20, and McCache used a strategic fuels treatment approach utilizing prescribed fire in consideration of fire resilient species. Smoke from prescribed fires, during mostly spring and fall seasons, would continue in the above mentioned lowland project areas. Smoke from prescribed fires and nearby private and State owned lands is regulated by Oregon Department of Forestry Smoke Management Division. Even with regulation, prescribed fire smoke can create short-term impacts. These usually last only a few hours and quickly disperse due to burn approval from ODF Smoke Management coming at times of favorable atmospheric conditions. ODF approves the amount of prescribed burning based on expected smoke dispersal. Prescribed burning in this geographical area has never resulted in a violation of air quality standards, although nuisance smoke occasionally occurs. District Prescribed Fire Managers in conjunction with ODF Smoke Management would monitor atmospheric conditions and emissions from all sources of smoke to curtail potential smoke impacts. Potential cumulative effects of smoke to the general population would likely be from a visual or nuisance perspective. Foreseeable Future Actions Fire and Fuels Management Future upland restoration projects are on the horizon. These management projects would be analyzed to allow for prescribed restorative fire to be utilized across the fire area to maintain and enhance forested ecosystems where appropriate, considering historical fire frequency and history. Air Quality Prescribed burning will continue to be coordinated and monitored through ODF Smoke Management, which restricts burning to times when conditions for smoke dispersal are optimal for compliance with national and state air quality regulations.

9 Brown, J.K., E.D. Reinhardt, and K.A. Kramer Coarse Woody Debris: Managing Benefits and Fire Hazard in the Recovering Forest. (U.S. Department of Agriculture Forest Service Rocky Mountain Research Station, Ogden, UT), RMRS-GTR p. Lowell, Eini C., V. Rapp., R. Haynes, C. Cray, Effects of fire, insect, and pathogen damage on wood quality of dead and dying western conifers. Geneeral Technical Report PNW-GTR-816: 73. Portland, OR: USDA Forest Service, Pacific Northwest Research Station. Lutes, Duncan First Order Fire Effects 6.0 User Guide, Rocky Mountain Research Station. National Wildfire Coordination Group (NWCG) Smoke Management Guide for Prescribed and Wildland Fire 2001 Edition. NFES Boise, ID: U.S. Department of Agriculture, U.S. Department of the Interior, National Association of State Foresters. 226 p. Ottmar, R.D, Vihnanek, R.E, Wright, C.S Stereo photo series for quantifying natural fuels. Volume I: mixed conifer with mortality, western juniper, sagebrush, and grassland types in the interior Pacific Northwest. PMS 830. Boise, Idaho: National Wildfire Coordinating Group, National Interagency Fire Center, 73 p. OAR Oregon Administrative Rules, Department of Environmental Quality, Division 200. General Air Pollution Procedures and Definitions. Available at: [Accessed November 18, 2011] OAR Oregon Administrative Rules. Visibility Protection Plan for Class 1 Areas. Available at: [Accessed December 27, 2011] OAR Oregon Administrative Rules. Department of Forestry, Division 48. Smoke Management. Available at: [Accessed November 18, 2011] Oregon Department of Forestry, Smoke Management Plan, Recognizing optimum conditions and maximizing/creating opportunities - Best Burn Day Strategy September Available at: Russell, R.E., V.A. Saab, J.G. Dudley, and J.J. Rotella Snag longevity in relation to wildfire and postfire salvage logging. Forest Ecology and Management. 233: USDA Forest Service Land and Resource Management Plan: Deschutes National Forest. USDA Forest Service. USDA Forest Service Final Environmental Impact Statement, Land and Resource Management Plan: Deschutes National Forest. USDA Forest Service. USDA Forest Service Photo Series for Quantifying Natural Fuels. Volume I: Mixed-Conifer with Mortality Interior Pacific Northwest. USDA Forest Service National Best Management Practices for Water Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide. Whychus Watershed Analysis, 1998, 2009, Deschutes National Forest, Sisters Ranger District.