Bison in snowstorm, Blacktail Plateau, Yellowstone NP, Wyoming Photo George Wuerthner

Yellowstone National Park has produced an DEIS on bison management. The Park Service is accepting comments until September 25th. You can read the DEIS and make your own comment here:  Attached are the detailed comments of the Wild Bison Restoration Council, however, if you want to make your own comments here are some brief points.

1. Yellowstone Bison are unique and of international significance.
2. Alternative 3 is the best option, but it has numerous problems.
3. The transfer of brucellosis to livestock from bison is exaggerated.
4. The removal of bison by hunting, test and slaughter and transfer to tribal lands has real ecological and evolutionary impacts on Yellowstone Bison.
5. The underlying assumption of the management proposal rests on the assertion of treaty rights by tribes. This assertion has not been independently verified by the NPS, but a reading of treaties suggests there is NO LEGAL RIGHT to kill bison north of Yellowstone Park in Beatty Gulch.
6. Yellowstone bison belong to all Americans, and it behooves the NPS to manage bison for all Americans. If bison are transferred from Yellowstone they should be sent to other public lands like the Charles M. Russell NWR, and other locations under federal management.
7. The current proposals all manage bison for the benefit of tribal hunters, not the bison. What is good for bison should be the main focus of any decision.

We, the Montana Wild Bison Restoration Coalition (WBRC), offer the following comments on Yellowstone’s DEIS on bison management.

We commend Yellowstone NP for recognizing the unique character of Yellowstone bison.

We support Alternative 3 as a step in the right direction, but we have many concerns about the underlying assumptions of the document, and the lack of full ecological and evolutionary accounting that bison removal has on the Yellowstone herd and its impacts on the Greater Yellowstone Ecosystem.

The Yellowstone bison are the least manipulated remnant of wild bison that once roamed much of the West. They have been largely influenced by natural evolutionary processes like harsh weather, predation, natural breeding selection, and climate variability.

They are a globally significant population where protection and preservation should be given priority in any decision. Any management default position should be in the bison’s favor.

We recognize that bison management is political and the difficult political situation the NPS must negotiate. Nevertheless, the legislation that created Yellowstone provides a clear statement of the NPS mission to preserve and protect the park’s wildlife, including bison.

To quote Yellowstone Protection Act, the NPS “shall provide for the preservation, from injury or spoliation, of all timber, mineral deposits, natural curiosities, or wonders within said park, and their retention in their natural condition.” And leave them unimpaired for the enjoyment of future generations.”

By last count 1471 Yellowstone bison were culled or killed during 2023. However as reported in the DEIS, the tribes do not consistently report numbers, ages, and sexes of ungulates harvested under these permits to federal and state biologists so this should be considered a minimum count of tribal kill.

When transfers and slaughters are considered, the number rises to 1781 or approximately 40% of the northern herd was removed from the Yellowstone Park ecosystem.  Approximately 64 were killed by Montana hunters, but the majority of all bison kill (1059) was due to tribal members. It should be noted there is no final 2023 count that we are aware of, so totals could be higher.

We believe this has serious implications for the ecological integrity of the bison and the Yellowstone Ecosystem, which by law the NPS must prioritize in all decisions.

While this loss of bison occurred primarily outside of Yellowstone NP, it behooves the Park Service, in its obligation to “preserve and protect” Yellowstone to bison at least object to such losses. According to NPS Chris Geremia during the NPS zoom August 28^th 2023 noted that no more than 400 bison could be removed without affecting the herd’s biological viability.

The management proposal is based on the premise that tribes have treaty rights to hunt near Gardiner. The NPS has never investigated these claims. Instead, it has deferred to the state of Montana, which also has not fully investigated claims, relying primarily on tribal assertions of treaty rights, instead of independently validating these claims.

BISON DEMISE

While it may not be critical to the issue of Yellowstone bison management, the common “story” repeated by the DEIS under its American Indian Tribes and Ethnographic Resources section that white commercial hunting led to the demise of western bison is at best an exaggeration. Assuming that tribal hunters will practice “conservation” in hunting is not supported by historical or even present day behavior.

By the 1840s bison were essentially extirpated from Idaho, northern Utah, SW Montana and Wyoming west of the Continental Divide. By 1850 they were gone from Manitoba, Saskatchewan and North Dakota. This was all before there was any significant white settlement or bison hunting.

Indeed, most commercial hunting by white people did not occur until the 1870s and later after the railroads enabled easy transport of hides. By that time, bison were extirpated from much of their historic range in the western US.

There is abundant evidence that tribal hunting was a leading cause of bison extirpation, particularly after the advent of the horse and gun. The idea that somehow tribal people are “conservationists” is not supported by the evidence.

Here’s one link to an article in the New York Times.

https://www.nytimes.com/1999/11/16/science/historians-revisit-slaughter-on-the-plains.html#:~:text=The%20wanton%20slaughter%20of%20millions,that%20it%20is%20not%20true.

And several other articles that discuss the same topic.

https://www.thewildlifenews.com/2021/06/01/indian-culpability-in-bison-demise/

https://www.thewildlifenews.com/2023/01/27/indian-influence-on-the-extinction-of-bison-in-southeast-idaho-and-adjacent-areas/

Clearly tribal people are quite capable of overkill.

A commentary on the Wildlife News addresses some of the treaty rights claims. It is hoped the NPS will review it.

Bison migrating towards lower snowfall. Photo George Wuerthner

TRIBAL TREATY RIGHTS

The NPS document suggests they will rely on tribal hunting (and other state hunting) outside of the park to limit bison movements and numbers.

On page 36 of the DEIS, the NPS says:” In other words, tribal fishing and hunting rights include more than just the right to attempt to harvest wildlife; tribes need to be able to obtain a share of the actual harvest of a resource (Puyallup Tribe v. Department of Game of Washington, 391 U.S. 392 (1968), 414 U.S. 44 (1973), 433 U.S. 165 (1977)). By completely restricting bison migration onto unoccupied lands adjacent to the park, the NPS would be adversely affecting the exercise of reserved treaty rights by several tribes.”

However, we believe the tribes have no treaty rights to hunt adjacent to Yellowstone Park at Beatty Gulch.

Dead bison killed by tribal hunters at Beatty Gulch this past winter. 

There are three major assertions made by tribal entities and their supporters which assert treaty rights—but a close reading of the treaties themselves and subsequent legal decisions suggest that no treaties authorize hunting in this location.

The three most cited and misinterpreted treaty claims are the “Common Hunting Ground” of the 1855 Lame Bull Treaty, ceded lands common in most treaties and upheld by Herrera vs Wyoming, and the phrase “Usual and Accustomed” referring fishing rights in Columbia River tribal treaties. As we hope to demonstrate none of these provide valid legal rights to hunt bison adjacent to Yellowstone National Park.

Almost all the treaties of the specific tribes claiming a right to hunt just north of Gardiner refer to reservation boundaries as well as “ceded” lands. The ceded lands phrase is important and critical as to whether tribal hunting by Gardiner is legal.

Tribes and tribal advocates usually refer to the phrase in many treaties that suggests hunting on “unclaimed and open” lands. In practice these lands are determined to mean National Forest or BLM lands WITHIN the ceded lands as open to off-reservation hunting.

In other words, tribal hunting is limited to specific lands, usually determined by the specific lands ceded to the federal government in treaties.

Why would the treaties even bother to define “ceded” lands if it didn’t matter? They defined them because the government agents wanted limits on where tribes could hunt, and the tribes wanted definitive boundaries off the reservations where they knew they could continue to hunt. So both sides had a reason to put geographical, legal descriptions of the “ceded areas” into words.

Why is this important? Because none of the tribes have ceded lands north of Yellowstone. Here’s a map produced by Judicial Review that shows all the ceded lands in treaties. Note that none of the lands near Gardiner and the northern portion of Yellowstone are “ceded.”

The white areas on this map, including the area by Gardiner are not within the ceded territory of any tribes.

HERRERA VS WYOMING

All tribes when they signed treaties that established reservations gave up a larger piece of their original claimed territory known as “ceded lands.” In most instances, tribes retained the right to hunt, camp, etc. on ceded lands. The specific boundaries of ceded lands are described in the individual treaties, and no ceded lands exist for any tribe near Beatty Gulch.

The reference to “ceded lands” was a critical issue in the Supreme Court case Herrea vs Wyoming.

The Herrera vs Wyoming Supreme Court case was primarily about whether treaty rights were extinguished at Wyoming state hood, or continued, the courts recognized that the treaty allowed tribal members to hunt off reservation on “ceded” lands. This does not give the tribe the right to hunt anywhere, including lands they may have occasionally visited.  It only allows hunting on lands specifically “ceded” in the treaties. The Crow “ceded” lands do not reach the Gardiner area but lie east of the Yellowstone River.

Here’s a summary from the Native American Legal Fund; https://narf.org/cases/crow-hunting/

In May 1868, the United States and the Crow Tribe (Apsáalooke) signed the Second Treaty of Fort Laramie. In the treaty, the Tribe ceded a large piece of its reservation lands to the United States. However, tribal leaders reserved the right to hunt on those lands, even though they were no longer part of the reservation. The treaty clearly states  that the Tribe could continue to hunt on the ceded lands, as they always had done, so long as the lands remained unoccupied by settlement and the Tribe maintained peace with the United States.

Here’s the relevant section of the Crow treaty. Note under hunting rights on “ceded land”.

ARTICLE IV

[Hunting Rights on Ceded Land]

The Indians herein named agree, when the agency-house and other buildings shall be constructed on the reservation named, they will make said reservation their permanent home, and they will make no permanent settlement elsewhere, but they shall have the right to hunt on unoccupied lands or the United States so long as game may be found thereon, and as long as peace subsists among the whites and Indians on the borders of the hunting districts.

https://wdfw.wa.gov/hunting/management/tribal/history

The following refers to tribes in Washington State but provides some insights to court decisions regarding hunting on ceded lands.

Geographical scope of off-reservation hunting rights

In State v. Buchanan (1999), the Washington State Supreme Court ruled that this right extends to 1) the lands formally ceded by the tribes to the United States as those lands are described in the Treaties; and 2) other areas where it can be shown that those areas were “actually used for hunting and occupied [by the tribe] over an extended period of time.”

Significantly, in State vs Buchaman, the Washington Supreme Court has held that “open and unclaimed” land language of the Point Elliot Treaty applied only to land within a tribe’s “ceded areas under the treaties or other traditional areas.”

It is a stretch for any tribes in Washington or Oregon (Yakima, Cayuse, Nez Perce, etc.) to claim they hunted and occupied the area around Gardinier for an “extended period of time.” This is essentially true since the acquisition of the horse was a recent phenomenon for tribes west of the Bitterroot Mountains (Nez Perce, Yakima, etc.)  and tribal use of bison on the plains was sporadic and relatively short-lined.

USUAL AND ACCUSTOMED

Some tribes claim that the treaties of Columbia Basin tribes which possess a provision that they can fish at unusual and accustomed sites gives them the right to hunt near Gardiner. But a closer reading of those treaties suggests this this provision pertains to specific locations such as waterfalls where tribes historically caught salmon and other fish.

For instance, the 1855 Treaty with the Flathead reads: “The exclusive right of taking fish in all streams running through or bordering the reservation is further secured to the said Indians ; as also the right of taking fish at all the usual and accustomed places, in common with the citizens of the territory.”

It is important to note this reference to usual and accustomed, a reference to fish at specific locations like waterfalls, not hunting. Photo George Wuerthner 

It then goes on to say as is found in other treaties, “Erecting temporary buildings for curing ; together with the privilege of hunting, gathering roots and berries, and pasturing their horses and cattle upon open and unclaimed land.” Open and unclaimed land has been defined as Forest Service and BLM within the “ceded territory”. It is not the privilege of hunting on any public lands anyplace.

In lawsuits since the original treaties, the courts have found that tribes must show that they occupied sites for extensive periods of time, and to the exclusion of other tribes. While this obviously may pertain to fishing sites like waterfalls, it clearly can’t be demonstrated for bison hunting which required following highly mobile animals.

These treaties say the tribes could FISH off the reservation at the “usual and accustomed places”. First of all, this is clear from all the law and legal discussions since the treaties that this only applies to fish. You can read quite a few of these legal wranglings, but the basic idea is that tribes used to fish at waterfalls, etc. and wanted to ensure they could continue to do this. But these are “specific” locations. These tribes’ treaty rights do not confer the privilege of fishing anywhere on any Columbia system river. They are restricted to specific locations.

This goes into great detail about hunting off reservations in Washington based on a case where a Noonsack tribal member killed two elk out of season and off from his reservation but claimed he had a treaty right to hunt anywhere in Washington.  https://caselaw.findlaw.com/court/wa-supreme-court/1410983.html

Here’s a quote from the state: “The State argues that the hunting right reserved by the treaty was limited to the right previously exercised-that is to the ceded lands or to lands upon which the Nooksack Tribe traditionally hunted. ”

The scope of a tribe’s off-reservation hunting rights is  generally found in an Indian tribe’s aboriginal use of or title to land and its reservation of the right in a treaty, or by agreement, executive order or statute.   See generally Felix S. Cohen’s Handbook of Federal Indian Law 41-46 (Rennard Strickland & Charles F. Wilkinson eds., 1982).   Mr. Nye explains the origin of the right as follows:

To determine the existence of original Indian title to land, and the right to hunt and fish following from that title, courts have generally required a showing of actual use and occupancy  over an extended period of time.   In Mitchel v. United States [34 U.S. (9 Pet.) 711, 9 L.Ed. 283 (1835) ] the United States Supreme Court said:

Indian possession or occupation was considered with reference to their habits and modes of life;  their hunting grounds were as much in their actual possession as the cleared fields of the whites;  and their rights to its exclusive enjoyment in their own way and for their own purposes were as much respected, until they abandoned them, made a cession to the government, or an authorized sale to individuals.

In claims against the United States based upon original title, a requirement of exclusive use and occupancy has been satisfied by a showing that two or more tribes jointly or amicably hunted in the same area to the exclusion of others․

Thus, regards to hunting, these same treaties had a limitation that is ignored by tribal advocates. It states that hunting off-reservation and outside of “ceded lands” are only those places where the tribe “occupied” for an extended period of time.

None of the Columbia River tribes can make the case they exclusively “occupied” the Gardiner area for any time, much less an extended period of time. They occupied the Columbia Basin, not the Yellowstone River ecosystem.

Furthermore, when they did cross the mountains to hunt bison, they usually went out to the plains via Rogers Pass and the Blackfoot River or sometimes other routes from Missoula that got them to the plains for hunting. I.e. they did not bother to hunt by Gardiner, and they certainly did not “occupy” the area.

LIMITATION OF TREATY RIGHTS FOR CONSERVATION

A further decision by non-other than Supreme Court Justice William O Douglas, held that hunting or fishing treaty rights were not unlimited. That state or federal agencies could limit the take of species in the interest of conservation.

The United States Supreme Court has held that the treaty right to hunt, like the treaty right to fish, may only be regulated by the state “in the interest of conservation, provided the regulation meets appropriate standards and does not discriminate against the Indians.”

This is from the final paragraph of the Puyallup 1973 decision, a unanimous opinion of the Court, written by Justice William O. Douglas:

“We do not imply that these fishing rights persist down to the very last steelhead in the river. Rights can be controlled by the need to conserve a species, and the time may come when the life of a steelhead is so precarious in a particular stream that all fishing should be banned until the species regains assurance of survival. The police power of the State is adequate to prevent the steelhead from following the fate of the passenger pigeon, and the Treaty does not give the Indians a federal right to pursue the last living steelhead until it enters their nets.”

We believe one could make the assertion that removing 40% of the Yellowstone bison is harming the bison, and in the interest of bison conservation, the NPS should exercise its obligation to protect bison from overharvest.

COMMON HUNTING GROUND OF 1855 Lame Bull Treaty

Some tribal hunting advocates cite the “common hunting ground” clause of the Lame Bull Treaty. The 1855 treaty with the Blackfeet, among other clauses, defined a “common hunting area” for tribes west of the Continental Divide. The only signatories to this treaty from west of the divide were the Flathead and Nez Perce. No other tribes from the Columbia Basin were signatories to this treaty.

Nevertheless, the terms of the Lame Bull Treaty were specifically terminated after 99 years. I.e. 1954. Thus, the common hunting area does not exist.

Furthermore the 1855 Treaty limited the Blackfeet ceded lands to an area north of the Missouri River, clearly not anyplace near Gardiner. Nevertheless, the 99-year extirpation of the treaty even makes this a moot point.

The 1855 Lame Bull Treaty has a defined common hunting ground that some tribal advocates suggest gives tribes the right to hunt by Gardiner. A couple of points must be considered. First, the “common hunting ground” may not include Yellowstone NP as it defines the boundary as the “North” branch of the Yellowstone.

Furthermore, the treaty had a 99-year termination. I.e. the common hunting ground was extinguished in 1954.  Moreover, the only signatories to the treaty from west of the mountains were the Flathead and Nez Perce tribes. Tribes like Yakima, Umatilla, etc. were not part of the treaty.

Here’s the original treaty information. Note the 99 year termination.

ARTICLE 3.

Blackfoot territory recognized as common hunting ground.

The Blackfoot Nation consent and agree that all that portion of the country recognized and defined by the treaty of Laramie as Blackfoot territory, lying within lines drawn from the Hell Gate or Medicine Rock Passes in the main range of the Rocky Mountains, in an easterly direction to the nearest source of the Muscle Shell River, thence to the mouth of Twenty-five Yard Creek, thence up the Yellowstone River to its northern source, and thence along the main range of the Rocky Mountains, in a northerly direction, to the point of beginning, shall be a common hunting-ground for ninety-nine years, where all the nations, tribes and bands of Indians, parties to this treaty, may enjoy equal and uninterupted privileges of hunting, fishing and gathering fruit, grazing animals, curing meat and dressing robes. They further agree that they will not establish villages, or in any other way exercise exclusive rights within ten miles of the northern line of the common hunting-ground, and that the parties to this treaty may hunt on said northern boundary line and within ten miles thereof.

Provided, That the western Indians, parties to this treaty, may hunt on the trail leading down the Muscle Shell to the Yellowstone; the Muscle Shell River being the boundary separating the Blackfoot from the Crow territory.

No settlements to be made thereon.

And provided, That no nation, band, or tribe of Indians, parties to this treaty, nor any other Indians, shall be permitted to establish permanent settlements, or in any other way exercise, during the period above mentioned, exclusive rights or privileges within the limits of the above-described hunting-ground.

Vested rights not affected.

And provided further, That the rights of the western Indians to a whole or a part of the common hunting-ground, derived from occupancy and possession, shall not be affected by this article, except so far as said rights may be determined by the treaty of Laramie.

Also the hunting ground defined here does not include the Upper Yellowstone. The treaty describes what was the main hunting trail for buffalo hunters coming across the mountains to the plains. The usual route started at Hells Gate which is the Clark Fork by Missoula, then up the Blackfoot River and over Rogers Pass to headwaters of the Musselshell which is near White Sulphur Springs and Little Belt Mts. From the Musselshell the treaty says thence to the mouth of Twenty-Five Yard Creek which is the Shield’s River by Livingston (https://scholarworks.montana.edu/xmlui/bitstream/handle/1/7094/31762101682753.pdf;sequence=1)and then along the Yellowstone to its “NORTHERN” SOURCE.

We suspect reference to the “Northern Source” means up the Shields River to the Rockies (i.e. like the Big Belts, etc.) and back to Hells Gate. In other words, even if there were not a 99 year termination, it would not include the Yellowstone area as best as I can determine from the treaty wording.

This is especially true if you know the usual route that tribes traveled to hunt on the plains. They did not go south to Yellowstone. They wanted to hunt on the plains between the Missouri and Yellowstone Rivers.

Furthermore, I have another map that shows the “ceded’ territories and no tribe has ceded territory in SW Montana. This was judicially determined in 1978 and is from the Library of Congress.

https://www.loc.gov/resource/g3701e.ct008649/?r=0.123,0.047,0.299,0.179,0

DIRECTIVE FOR CO-MANAGEMENT.

We are also concerned that the NPS decision to give tribal entities greater oversight, collaboration and management is contrary to the Constitution. It creates a special category of people based solely on race.

For instance, the DEIS suggests: “The NPS has collaborated with several tribes associated with YNP and the ITBC through agreements and other avenues to benefit their interests. These collaborations have included involving tribes as partners in the management of Yellowstone bison; coordinating with tribes that hunt bison on National Forest System lands adjacent to the park to reduce the effects of capture operations on hunting opportunities; and expanding the BCTP to identify more brucellosis-free bison and transfer them to tribes for restoration on their lands. The NPS would continue to collaborate with tribes and the ITBC on these issues, as well as the composition and distribution of bison captured for the BCTP, the processing of bison killed at Stephens Creek Administrative Area, the creation of new quarantine and terminal pastures for Yellowstone bison, the testing of bison in the BCTP to improve effectiveness and shorten timelines, the involvement of tribal interns in bison management, and the implementation of lower-stress handling techniques with captured bison to reduce trauma. These collaborations may be implemented through cooperative agreements or other appropriate avenues.”

While this is perhaps beyond the scope of this document, the assertion that tribal governments should be given any special priority over federal land management may be illegal. Such a proposal is based on race and would seem to be against anti-discrimination laws.

The Custer Gallatin NF in its forest plan suggests the tribes have treaty rights to hunt on the CGNF. However, when queried by the Gallatin Wildlife Federation FOIA on the Forest Service acknowledges that they could nothing justify the hunting of bison.

The FS wrote:

No records were found for data that records which tribes took bison, when they were taken, and the total number removed. And there were no Executive Orders empowering the tribes to hunt.

No records were found or statures other than treaties that empower tribes to hunt.

No records were found of the number of tribes authorized to authorized by YNP to hunt Yellowstone bison.

Finally, no records were found that “prove” rights to hunt. The CGNF acknowledge and approve treaty rights, however, they do not have any evidence that such treaty rights exist for the area around the Gardiner basin.

However, the FS, apparently like YNP, has not independently attempted to determine whether tribes have a treaty right to hunt just outside of Gardiner.

TRIBAL CULTURE AND NEED QUESTIONED

While beyond the scope of this document, WBRC believes that the excuse given by the tribes that the slaughter of Yellowstone bison sustains their culture is disingenuous. We know it is risky questioning someone else’s values, but given that tribal members arrive in expensive pickups, use ATVS, high powered rifles, stay in hotels, etc. the argument that merely killing bison sustains their “culture” is questionable.

Similarly, the idea that any tribe has to kill bison, much less Yellowstone bison which are globally significant, can also be disputed. There are plenty of other opportunities to kill bison on private ranchers, and existing tribal bison herds. Plus, hunting of other wildlife like elk on ceded lands and on existing reservations also provides sources for killing wild game.

In other parts of the world, where existence is far more tenuous than in the United States, countries have outlawed the slaughter of wildlife (gorillas, chimpanzees, elephants, etc.) even though local native people traditionally killed them.

It would behoove the United States and in particular, the premier federal agency (NPS) to begin to articulate why Yellowstone bison deserve protection from all sources of human mortality.

ECOLOGICAL AND EVOLUTIONARY IMPACTS OF BISON REMOVAL

The WBRC is concerned that the DEIS fails to fully disclose the continued and potential risks to Yellowstone bison and the ecological integrity of the Greater Yellowstone Ecosystem.

WBRC is pleased to see that the NPS and the CGNF recognize the need and desire to establish free roaming bison on other federal lands (USFS). 2015). The Custer Gallatin National Forest recently issued a Land Management Plan that allows for expanded tolerance of bison on the national forest, including a desired condition to have a self-sustaining population of bison on the forest year-round (USDA, USFS 2022). Allowing bison to occupy more public lands would create new opportunities for hunting, bolster tourism, and enhance conservation.

However, this is nothing more than lip service if the tribal hunting and other removal programs are continued.

The NPS is shrinking its duties to protect Yellowstone’s bison by washing its hand of any control over what happens to bison if they leave Yellowstone Park (page 14). “ However, the NPS would continue to have no authority or jurisdiction over when, where, and how hunter harvests of wildlife occur outside the park.”

While the NPS may have no authority and we even question this assumption, it can voice its objections.

For instance, back in the 1990s there were plans to develop geothermal projects outside of the Park, but the NPS objected, arguing that such development may jeopardize the park’s thermal features. The NPS made similar objections to a proposed gold mine outside of Cooke City, Montana.

An argument could be made that the way bison are killed outside of the park jeopardizes the ecological integrity of the park. More on this later, but killing bison removes the biomass from park carrion and predators. It may have genetic implications over time. It short circuits the cultural knowledge of migration by removing those bison more likely to colonize other lands.

In addition, per statute and policy, the NPS does not manage for minimum numbers of wildlife but, rather, to sustain populations in their natural condition, which was defined as “the condition of resources that would occur in the absence of human dominance over the landscape” (USDOI, NPS 2006a; 16 USC 21 et seq., 17 Stat. 32; 54 USC 100101a,b).

Thus, to the extent feasible, the NPS would allow bison and other wildlife to move freely and unpursued within the interior of the park, with their behaviors, movements, reproductive success, and survival primarily affected by their decisions and natural selection (White et al. 2013a; White 2016).

As recognized in this document, the NPS suggests that bison should be allowed to survive in the absence of significant human manipulation.  But the hunting outside of the park conflicts with this goal. The NPS cannot simply ignore these impacts.

CARRION AND ENDANGERED SPECIES

In its DEIS the NPS did not evaluate the impact on endangered species of bison removal. For instance, in the DEIS, the document reports that 25% of the diet of wolves is bison. Similarly, a grizzly coming out of hibernation and finding a bison carcass is like winning the lottery. Wolverine, fox, coyote, raven, eagle, and other wildlife also depend on this food source. Obviously, removal of 40% of the bison has serious impacts on prey for wolves, grizzlies and other wildlife in the park ecosystem.

GENETICS

WBRC is pleased to see the NPS acknowledges that it should maintain natural sex ratios, and sufficient numbers to maintain genetic diversity.

The NPS appears to be relying on Hedrick 2009 for genetic principles.

A geneticist consulted says the 2009 paper is obsolete and out of date. Much has occurred with regards to genetics and minimum population requirements since 2009. I have consulted several geneticists who feel that a minimum population of 3000 bison as desired by the NPS may be too limited.

One authority recommended 10,000 bison should be the long-term goal in or adjacent to the Park (i.e. a breeding population) and another said, there is no minimum as all these bison have incredible genetic value due to their long term influences of evolutionary pressures. I’m not an expert on genetics, but it might be a good idea for the NPS to solicit a few more genetic studies.

We believe the NPS should do a new review of genetics and ideas about minimum population.

MIGRATION

As far as can be determined the NPS has failed to review the impact of hunting and other removal techniques on migration. Migration is culturally learned. However, every year, the bison most likely to migrate are removed from the population. Loss of migration impacts the long term “wildness” of bison which the NPS is supposed to preserve.

ECOLOGICAL GOALS

We agree with the document’s ecological goals, but I feel that the hunting outside of the park boundaries may jeopardize these goals.

The goals as stated are:

“The NPS would manage for the following ecological objectives:

Sustain the Role of Bison as Ecosystem Engineers: To the extent feasible, the NPS would allow bison to move unfettered in the interior of YNP so they can fulfill their ecological role. When bison roam without human constraints, they begin to engineer the landscape as described by Geremia et al. (2019, 2022).

Maintain Functional Grasslands: The NPS would strive to maintain functional grassland and sage-steppe communities. Plant communities would vary widely in their appearance and composition depending on differences in soil and weather conditions, land use and management histories, and historic and current grazing intensities. Many communities would include invasive plants due to their previous spread. Ungulates would graze some areas intensely and others lightly, thereby providing a mosaic of conditions across the landscape to support a variety of plants and animals. However, each community should still maintain plant productivity, soil organic matter, and functioning energy, nutrient, and water cycles Geremia and Hamilton 2019, 2022).

Sustain Bison as a Meaningful Component of the Food Web Influencing Energy and Nutrient Transfer through the Ecosystem: To the extent feasible, the NPS would manage bison with minimal intervention in the interior of YNP, so bison continue to provide a key food source for species ranging from wolves to magpies to beetles and bacteria in the soil that redistribute nutrients across the landscape (Wallen et al. 2015a). Bison carcasses contribute to nutrient surges that greatly enhance the productivity of nearby plants. Carcasses of bison dying from injuries or malnutrition could continue to provide about 25% of the meat wolves eat during winter. This scavenging has reduced predation on elk during winter from about 18 elk per wolf per year (based on kill rates during winter) to about 12 elk per wolf per year (Metz et al. 2020a,b).”

However, we do not see how the NPS can achieve these goals when tribal and other hunting is removing such large numbers of bison from the ecosystem. And I do not see any stated mechanism that would ensure that these goals are maintained.

The NPS needs to provide a mechanism that supports these goals. Killing and removing much of the Yellowstone bison herd either by agency actions or through tribal hunting does not protect these valuable ecosystem and evolutionary goals.

In addition, the NPS needs to do more research on the long term genetic impacts of continuous bison removal. Bison, are, a tournament species with a small number of bulls doing the majority of breeding. What is the long term consequences of continuous population decline and bison removal? In the DEIS the NPS suggests the Park could sustain 10,000 bison. Perhaps a better measure might be how many bison are necessary to sustain long term genetic viability. This could be accomplished if there were other small herds on public lands that were part of a meta population.

YELLOWSTONE BISON BELONG TO ALL AMERICANS

Page 23 The document suggests it will continue to transfer brucellosis free bison to Fort Peck. This is essentially a privatization of public property. These animals belong to all Americans. Once on reservations, the American people no longer have any control or ownership of these bison.

We maintain the NPS has an obligation to keep public bison public!

Has the NPS seriously reviewed the potential for transfer to other state and federal lands? I.e. Charles M. Russell NWR, Little Missouri National Grasslands/Theordore Roosevelt NP, Red Desert, Wyoming, and elsewhere within the historic range of bison.

The Federal government has the authority to override state regulations or prohibitions. Shipping Yellowstone bison to tribal lands without fully exploring the opportunities for transfer to other federal lands where the American people would have full access to the bison is needed.

CONCLUSION:

The NPS proposal Alt. 3 is an improvement over current policy. WBRC supports Alt. 3, but has reservations about some of the underlying assumptions, in particular, that any tribes have a “treaty rights” to hunt by Gardiner, Montana.

We feel the NPS needs to articulate in greater detail and forcefulness the ecological and global significance of the Yellowstone bison herd. These are not just any old bison but are among the least manipulated bison in the United States. As such EVERY single bison has ecological and evolutionary value.

Furthermore, Yellowstone bison belong to all Americans. Transfer to Indian reservations or permitting significant slaughter by Indian tribes is not protecting and preserving Yellowstone bison for all Americans.

While the NPS articulates all the valuable ecological and ecosystem functions that bison perform or create, the proposed plan, by relying on removal of significant numbers of bison outside of the park whether through removal to reservations or by killing near the Park boundaries is counter to the expressed goals of maintaining these evolutionary and ecosystem values.

The DEIS is deficient in that it fails to analyze the long-term ecosystem harm caused by continuous bison removal either by agency action (i.e. slaughter, test or tribal transfer) as well as human slaughter on park boundaries. Merely articulating that bison have ecological and ecosystem value is not the same as expressing how the NPS will preserve these values.

George Wuerthner, President

Wild Bison Restoration Council

P.O. Box 5317, Bozeman, MT 59717

“Thinning” project on the Wallowa Whitman NF in Oregon. The removal of trees by chainsaw medicine eliminates evolutionary agents that would otherwise naturally “thin” the forest. Photo George Wuerthner 

The Forest Service and Forestry School researchers (funded by the Forest Service) continue to promote the idea that our forests are “unhealthy.” It is an example of the “Father Knows Best” philosophy that the agency and its researchers understand how to mend the forest. And, of course, it also assumes that the forest needs repairing.

Feller buncher cutting trees which the Forest Service asserts “improves forest resilency” while it ignores all the negatives of logging including spread of weeds, loss of biomass, loss of store carbon, disturbance to wildlife, and loss of genetic diversity, and other impacts. Photo George Wuerthner

The problem with the Forest Service’s current love affair with chainsaw medicine is that it assumes that anything that kills a tree (except a chainsaw) is undesirable.

The agency and its lackeys are like the snake oil salesman of old, promising that their magic elixir (logging) can cure whatever ails the forest, whether it is sick or not.

This Google photo shows the clearcuts that failed to stop the Holiday Farm Fire along the McKenzie River in Oregon  that burned under extreme fire weather with 50 mph or greater winds. The second photo is the same area showing the clearcuts in the background–all of which burned. If a massive deforestation such as this did not stop the wildfire spread, how can anyone believe that thinning will achieve positive results. 

We are told that chainsaw medicine treatments aim to reduce large, high-severity wildfires and enable trees to survive insects, drought, and disease.

The problem is that the above are the evolutionary factors that have maintained “healthy” forest communities for millennia. In a sense, these evolutionary agents select which trees are best adapted to current conditions (not some past historical situation that no longer exists).

Natural evolutionary agents like insects, disease, wildfire and drought are as the wolf to the deer or elk. They  naturally thin the forest and create resielency. Photo George Wuerthner 

To quote the poet, Roberson Jeffers, “What but the wolf’s tooth whittled so fine. The fleet limbs of the antelope?”

It is the same for our forests—wildfire, drought, insects, and disease are whittling the woodlands to withstand present and future challenges just as wolves select the least fit elk or deer for their prey, improving the species’ overall genetic health.
However, the Forest Service and OSU researchers have no idea which trees may have a genetic or physical trait that allows them to survive things like drought, wildfire, insects, and disease.

They are, in effect, with their chainsaw medicine interfering with evolution. That is a dangerous game to play.

Many genetic studies have shown that rare genetic alleles provide resilience to any population—including forests. Only one in a hundred or more individuals may possess these genetic features, and yet by removing a significant amount of the trees, the agency is degrading the forest’s resilience.

The snags that remain after a high severity fire creates habitat for numerous species and new ecological opportunities. Logging is no subsitute for natural evolutionary agents like wildfire. Photo George Wuerthner 

A second problem with the current mantra to log our way to forest health is that large, high-severity wildfires provide the habitat for numerous other species. Some biologists estimate that at least half of all wildlife depend on the snags that result from large blazes for their homes. The snags that fall into streams supply the bulk of the habitat for fish. The snags and downwood that remain after a wildfire, drought, insect, or disease outbreak store carbon for centuries.

In short, the Forest Service cannot see the forest ecosystem through the trees due to its Industrial Forestry bias. The focus on individual trees fails to see the long-term consequences of its chainsaw medicine program.

Given the climate changes we are experiencing, the way to increase resilience in our forests is to allow evolution to operate. Our forest communities will change and adapt to the current climate, and part of this adaptation may be the loss of some trees, but in the end, our forest communities will be stronger.

Here’s an example of a home that is vulnerable to wildfire. Home hardening includes removal of debris from roof and gutters (like the pine needles in this photo), screening vents, removal of flammable materials adjacent to exterior walls, and install non-flammable roofing material. Photo George Wuerthner 

In the meantime, the best way to protect communities is home hardening, not chainsaw medicine.

A few years ago, the Custer Gallatin National Forest thinned the area on Kirk Hill by Bozeman to reduce fuels.

As has been reported, one of the problems with any fuel reduction is that the probably that a fire will encounter it during the period when it’s potentially effective is very small–usually around 1%.

A second problem is that thinning often increases the abundance of “fine fuels’ like grasses, shrubs and small trees. Large trees are less likely to burn which is why we get snags. So removal of larger trees does not necesssarily result in less fire spread.

Below is the Kirk Hill area immediately after thinning. Within two years, the area is now covered with dried grass–a highly flammable fuel. The next picture shows the forest twenty feet from the previous photo but in forest that hasn’t been thinned. Note the fuel load is lower. The vegetation in the shade is still green–thus less flammable than the cured grass in the thinned area. s

The word Kobuk means “Big River” in the local native language.  Photo George Wuerthner 

I just returned from floating the Kobuk River in Alaska’s Brooks Range. The Kobuk headwaters are north of the Arctic Circle in the Gates of the Arctic National Park and flow west to the Bering Sea near Kotzebue, Alaska. The upper portion of the river is designated Wild and Scenic River.

Lake Selby, near the headwaters of the Kobuk River in the Gates of the Arctic National Park. The proposed road would run within a few miles of this lake. Photo George Wuerthner 

My companion, Bill Cunningham, and I chose to float the lower portion of the river from the village of Kobuk to the village of Kiana. Along the way, the river passes through the 1.7 million-acre Kobuk Valley National Park, the least visited national park in the country.

The Kobuk Valley sand dunes are among the special geological features of the Kobuk Valley National Park. Photo George Wuerthner 

I had two reasons for floating in the lower part of the river. One goal was to see what changes had occurred to the river and villages since the 1970s when I worked along the waterway surveying native allotments later as a ranger in the Gates of the Arctic National Park.

Fireweed frames the village of Shungnak. Photo George Wuerthner 

The allotments resulted from the Alaska Native Claims Settlement Act (ANCLA), which allowed individuals to garner ownership of small tracts of land, and for villages and regional native corporations to claim land. Over 44 million acres of land (about the size of two states of Maine) were conveyed to native ownership. Today approximately 81,000 acres in the Kobuk Valley National Park is native owned or state lands.

The second reason for this trip was to understand better how a proposal to build a 211-mile road from the Pipeline Haul Road (Dalton Highway) to the Ambler Mining District would impact the entire region. The proposed road’s official name is the Ambler Mining District Industrial Access Project.

The slim light line to the right of the lake in the upper portion of this photo is a road that leads from the village of Kobuk to the Ambler mining district. Photo George Wuerthner 

The Ambler Mining District is north of the river and the Inuipat villages of Kobuk, Shungnak, and Ambler. The proposed road would cut across along the southern edge of the Brooks Range, including through a portion of the Gates of the Arctic National Park and Kobuk Wild and Scenic River and native village selections and Native Corporation lands.

Surveying native allotments along the Kobuk River in 1973. Photo George Wuerthner 

While I was working along the Kobuk in the 1970s, a flurry of mineral exploration occurred simultaneously. Exploratory prospecting demonstrated that this copper-lead-zinc-cobalt mineral belt extended for miles across the southern edge of the Brooks Range. By 1975, more than 10,000 mining claims covered what has become known as the Ambler Mineral Belt.

Today, the Ambler Mining Belt is the world’s largest high-grade copper deposit. With the growing need for more copper to advance electric cars and other efforts to reduce greenhouse gas emissions, interest in developing the Ambler copper deposits has grown.

However, the high cost of mining and transportation in the Arctic has consistently thwarted the development of the Ambler copper depots. Hence, the interest in linking the Ambler district with the Pipeline Haul Road would, in theory, make the development of the minerals economically viable.

The Alaska Pipeline near Coldfoot, Alaska. The proposed Ambler Road would connect to the Pipeline Haul Road and provide year round access to to the port of Valdez on Prince William Sound.  Photo George Wuerthner 

Alaska has always wanted to create a road across the southern portion of the Brooks Range as part of its long-term transportation plans. The state proposes to fund a portion of the cost of a road.

In addition, the NANA, an NW Alaska Inupiat tribal corporation, represents the people who live in NW Alaska, including the villagers along the Kobuk River. NANA favors the development of the mine. Much of the mineralized area was selected by the natives as part of the ANCSA process, so if developed, the Kobuk villagers stand to garner not only royalties but local employment.

The village of Shungnak is one of the supporters of the proposed road. Photo George Wuerthner

Among the supporters of the road are Northwest Arctic Borough, the  Native Village of Shungnak, Alaska’s Congressional Delegation, the Alaska Chamber, the Alaska Miners Association, the Alaska Support Industry Alliance, the Council of Alaska Producers, and Resource Development Council for Alaska, Inc.

Most of the mining claims are owned by NANA corporation. In 2011, NANA and Trilogy Metals formed the Upper Kobuk Mineral Projects (UKMP). This partnership brings together Bornite and several other copper-rich prospects on NANA-owned lands with the world-class Arctic deposit and dozens of similar volcanogenic sulfide prospects on state, federal, and patented mining claims in the Ambler Mining District.

NANA wants to develop the Ambler mines as it has done for the Red Dog Mine (a zinc mine) north of Kotzebue. Red Dog is considered the most toxic mining operation in America. Profits from the Red Dog mine are a significant source of funds for NANA.

It’s important to note that if the first mines are developed, many other mineral deposits in the area will eventually follow. So this debate is about more than just this one mine and road. It will determine the future development of the entire western Brooks Range.

LOCAL OPPOSITION

A sign in Kotzebue expresses opposition to the Ambler road. Photo George Wuerthner 

There is opposition to the road. Some of the local villagers were ambivalent about the road. Some told me it might impact subsistence practices, but the income from jobs and royalty makes modern subsistence with snowmachines, motorboats, and ATVS possible.

ATVs, snowmachines, motorboats and regular air service have changed village life. Photo George Wuerthner 

 On the other hand, the Tanana Chiefs Council represents the Athabascan people living along the route’s eastern portion. The villagers along this portion of the route will receive no financial benefit, but will get the impact of more people coming to hunt and fish on the lands they use for subsistence.

The Brooks Range Council has produced a video on the proposal, which you can see here.

Map showing the route of the proposed Ambler mine road from the pipeline haul road along the southern edge of the Brooks Range. The purple is Gates of the Arctic NP, the blue is Alaska state lands, the yellow is BLM and the varoius brown and gray represents native land ownership.

The development of the Ambler Mining District was the reason the Alaska National Interest Lands Conservation Act (ANILCA), passed in 1980, created many national parks like the Gates of the Arctic National Park. ANILCA had a clause authorizing the road. “Congress finds that there is a need for access for surface transportation purposes across the Western (Kobuk River) unit of the Gates of the Arctic National Preserve (from the Ambler Mining District to the Alaska Pipeline Haul Road), and the Secretary shall permit such access in accordance with the provisions of this subsection.”

The Trump administration in 2020 approved the road’s construction. Fortunately, the Biden Administration has remanded the decision to permit the Ambler Road back to the Bureau of Land Management for additional environmental review, giving the public another chance to halt this destructive project.

However, some observers believe this is just a delaying tactic and, ultimately, the road will be approved, especially given the Biden administration’s goal of creating more U.S. sources of critical minerals.

ECOLOGICAL IMPACTS

The road, if built, the construction will have numerous impacts. A tremendous amount of gravel will need to be mined to provide insulation of the permafrost, which underlies much of the proposed route.

It will cross 3000 streams, and three caribou migration routes.

Roads can be semi-permeable barriers, and although crossing such obstacles is possible, caribou may shift or entirely abandon their seasonal habitat when confronted with a road. The disturbance and activity along the road and mining operations will likely affect caribou in other ways. Studies have shown that caribou may travel up to 9.3 miles to avoid roads and 11.2 miles to avoid settlements.

For instance, a study of the Native-owned Red Dog Mine Industrial Access Road north of Kotzebue found that just four vehicles an hour affected the migration of 30 percent of collared caribou, or approximately 72,000 individuals of the 2017 population estimates.

Currently, residents can kill five caribou a day. However, the Western Arctic Caribou Herd has been in steep decline, and there is a discussion about reducing the kill. Road access may eventually result in more hunting pressure, and perhaps future reductions in caribou numbers.

Even if the Ambler Road is not built, the mine development may not go away. There are several other potential routes proposed including one that would traverse the Kobuk Valley, where I floated, and eventually reach Nome, where ore could be shipped south for processing.

OBSERVATIONS

While floating the river, I stopped at all the villages along the route to gauge the changes that had occurred during the intervening fifty years since I first set foot on the banks of the Kobuk.

Most residents were friendly and helpful.

Hunting caribou for food is still an important activity for villagers along the Kobuk River. Photo George Wuerthner 

Like nearly all Alaskan native villages, the modern world is evident everywhere. The shift from subsistence food gathering to a cash economy was visible everywhere. Patagonia clothing and blue jeans have replaced fur.

The need for cash is one reason why many villagers support the development of the Ambler mines. Many villagers I spoke with periodically worked at the NANA-owned Red Dog mine to earn cash for modern conveniences. They anticipated finding employment at the Ambler mining operations if developed. Given the scarcity of employment opportunities in rural Alaska, one can sympathize with the desire to have access to high-paying mining jobs.

Heavy equipment in Ambler. Buying and maintaining such equipment in a small village is costly. The proposed mines are viewed as one potential source of income for native people. Photo George Wuerthner 

Everyone from elementary school children to old elders now possess cell phones. The villages all have Wi-Fi access and transportation links. Even the tiny village of Kobuk, with just 200 residents, has two flights a day from Kotzebue, the transportation hub for the region. Most homes have indoor plumbing, electricity, and fuel oil heat, though wood stoves were also evident. Some buildings even have solar panels, though I am unsure how well they work in winter when there is virtually no sunlight.

A grocery store in Kotzebue, Alaska. Though expensive, food is readily available in all villages. However, many resident prefer eating wild game. Photo George Wuerthner 

New community buildings, modern schools, and small but insulated homes dominate the villages. Most of this construction was paid for with oil money. All villages had stores where you could buy basic food supplies, though the cost was probative. I recall seeing one bag of corn chips for $19.

All Terrain Vehicles (ATVs) and four four-wheelers were everywhere. I didn’t see many people walking as much as I observed people just riding around for fun, making a trip to the store, or visiting neighbors. In this way, the ATVs were used like cars are by most people outside of Alaska.

Some villagers also own motorboats to run up and down the river for hunting, fishing, or just going to their camps scattered along the Kobuk.

One change I noticed since I last lived near these villages is the absence of sled dogs. When I was on the Kobuk in the 1970s, dog sleds were still a practical transportation option for running track lines and going from village to village. With the advent of snowmachines and more regular air transportation, feeding sled dogs became an expensive liability. As one villager told me, at least when you are not using your snowmachine, you don’t have to feed it.

While running a snowmachine or ATV requires fuel, various subsidies the villagers enjoy help to keep this cost reasonable. For instance, I was told that gasoline in Kiana costs $4 a gallon, less than the price in many western states.

Fish drying on a rack along the Kobuk River in the 1970s. Photo George Wuerthner 

Machines changed the use of the river corridor. When sled dogs were common, villagers had fish camps along the river to net salmon and other fish, fed to the dogs or for personal consumption. This is an anecdotal opinion, but it seemed to me that there were more fish camps along the river in the 1970s than I observed on my recent float. I saw many abandoned shacks and cabins that were once used as camps during the fishing season.

Some cabins were still maintained and used as a base for hunting or trapping. Some villagers liked having a cabin as a recreational getaway even though the villages were surrounded by miles of wildlands.

LEAST VISITED NATIONAL PARK

During the entire float, we saw no other recreationalists on the river. Every other day, we might see some natives driving a boat up or down the stream, but we did not see anyone else floating or camping along the river corridor.

Grizzly bear tracks on the beach where we camped in Kobuk Valley National Park. Photo George Wuerthner

Indeed, when we stopped on river bars to stretch our legs or camp for the night, we never saw any other human footprints, though we saw plenty of grizzlies, wolves, and moose tracks.

A cow moose and calf peers at our camp along the Kobuk River. Photo George Wuerthner 

Even with the occasional boat passing by and a few cabins along the river, the overall impression one has of the Kobuk Valley National Park is its remoteness and wildness. And if my impression about the decline in fish camps and other native use of the river is accurate, it may even be wilder today than in the 1970s.

In keeping with its reputation as the least visited national park, there was no “Welcome to your National Park” sign. There were no ranger stations. There were no rangers. There were no trails. No interpretative signs.

Even one of the significant geological features of the park, the Kobuk Valley dunes, was inaccessible. We searched for a trail that would take us to the dunes but could not locate one if it existed.

CONCLUSIONS:

I recognize that if I were a villager living along the Kobuk River, I might support the proposed road. Although it is being called a private industrial road closed to public use, the same was said of the Dalton Highway. If opened to public use, the road would likely make it far less expensive for villagers to obtain everything from lumber to fuel oil to food.

In a region where job opportunities are notoriously seasonal and limited, employment at a mine would provide valuable income to villagers.

Nevertheless, the development of the Ambler Mining District will bring irreversible cultural and ecological changes to the Kobuk River valley.

I met a man in Ambler who had just returned from a hunting trip. He had moved to Ambler to pursue a subsistence lifestyle.

Not everyone, even villagers living along the river, would choose to return to a fully subsistence lifestyle. But where else can one even have such a choice?

For those who have grown up along the Kobuk, the decision to continue such a subsistence lifestyle is still available. While enjoying many of the modern amenities available everywhere, many native people choose to hunt and fish to supplement their cash economy. The full development of the Ambler Mining District, may preclude this choice.

We saw grizzly, wolf and moose tracks on just about every sandbar we stopped at. Photo George Wuerthner 

And where else can you go and see far more grizzly and wolf tracks than human footprints? Remote and wild places are increasingly scarce. The Brooks Range’s most outstanding value is its wildlands.

Sunrise on the Kobuk River and my tent, Kobuk Valley National Park.  Photo George Wuerthner 

The question for me and others who oppose the Ambler mine development is whether the benefits of industrialization of one of the wildest places in Alaska are worth the cost. While the Ambler mineral zone does possess globally significant ore resources, these minerals can be obtained elsewhere, where the ecological and social costs are lower.

Fall along the Kobuk River. Photo George Wuerthner

Are we wise enough to recognize that wilderness and wildness has intrinsic value, and that preservation of these attributes is worth more than copper and other minerals.

The answer to my question may be determined soon, depending on the outcome of the BLM and Biden administration decisions.

Public land livestock grazing has a significant social cost in terms of carbon emissions contributing to climate warming. Grand Staircase-Escalante NM Utah.  Photo George Wuerthner 

An important paper was published in Environmental Management about the social carbon costs of public land livestock grazing. The paper Climate, Ecological, and Social Costs of Livestock Grazing on Western Public Lands, authored by Boone Kauffman, Robert Beschta, Peter Lacy, and Marc Liverman, examines the actual carbon costs of livestock grazing and argues for the positive benefit of federal land livestock grazing termination to the public.

Cow pie spattered in Idaho streams. Livestock manure along with methene emissions from digestion are among the major sources of livestock GHG emissions. Photo George Wuerthner 

In their paper, the authors demonstrate that emissions from cattle (enteric formation and manure deposition) are a significant but unreported contribution to carbon emissions.

Public lands livestock grazing equaled 12.4 million t CO2e/year. They argue that the social costs of public land livestock grazing in terms of carbon emissions vastly surpass what the federal government receives in grazing fees.

They estimate the social carbon cost of public lands grazing to general taxpayers to be $1.1–2.4 billion/year. This massive subsidy to the livestock industry significantly exceeds the paltry amount that ranchers pay to graze their livestock on public lands.

However, more importantly, the researchers show that public land livestock grazing grossly exceeds the U.S. Environmental Protection Agency (EPA) on Industrial Greenhouse emitters and are essentially unreported GHG emissions from public lands.

Cows grazing riparian area on Little Pine Creek, Oregon

Grazing impacts from cattle on Oregon BLM lands. Photo George Wuerthner 

For instance, in the Lakeview District, Oregon Resource Management Plan (BLM 2004), the BLM authorized 164,128 AUMs of livestock grazing on nearly 1.2 million hectares of public land. Greenhouse gas emissions from that grazing totals between 64,000 and 144,000 t CO2e/ year, far above the 25,000 t CO2e/year EPA reporting limit.

Added to this direct contribution of livestock to GHG emissions, the authors note that livestock-induced degradation of native plant communities reduced carbon sequestration due to desertification, degradation, and land cover change associated with livestock activities.

The additional and collateral costs to society of CO2 emissions include 1) premature deaths caused by extreme heat, (2) impacts on agricultural yields, (3) energy use in response to temperature changes, and (4) sea-level rise.

Public lands management agencies like the Bureau of Land Management and Forest Service are required by law (Executive Order 13990 (2021) and Interior Secretarial Order 3399) to fully account for carbon emissions from federal lands. Yet these agencies regularly ignore the contribution that public lands livestock in its grazing permit authorizations has on carbon emissions.

The social carbon cost of livestock grazing on Oregon’s federal lands is estimated to be as much as $226 million a year. Photo George Wuerthner

For instance, the 1.4 million AUMs of grazing on Oregon’s federally managed public lands results in an SCC estimate of $ 101 million (100-year GWP) to $226 million (20-year GWP) per year for Oregon.

Forcing the federal agencies to include these social carbon costs in their analysis of any public lands grazing permit authorization would demonstrate that the federal government violates its own EPA standards.

Carbon emissions are only one cost of public lands grazing. Collateral damage includes the killing of predators like wolves, coyotes, bears, and mountain lions to beneift ranchers. Photo George Wuerthner 

Reducing carbon emissions is the only benefit that cessation of livestock grazing would provide. Numerous studies have documented the ongoing ecological costs of livestock grazing, which include pollution of waterways, damage to riparian areas, spread of flammable plants like cheatgrass, social displacement of native herbivores, the killing of native predators and “pests” (prairie dogs, grasshoppers, etc.), transfer of disease from domestic animals to native species, soil compaction, destruction of social crusts, among other social costs to the public.

Damage to riparian areas, the green vegetation along creeks, has a significant impact on western wildlife. Some 70-80% of western species depend on riparian habitat for their survivial. BLM lands, Arizona. Photo George Wuerthner 

For this reason, it is surprising that many environmental organizations, from the Greater Yellowstone Coalition to the Sierra Club, are unwilling to challenge public lands livestock grazing.

The contribution to the food supply of livestock produced on federally managed public lands is trivial; cattle grazed on these public lands account for <1.6% of all US beef production.

The continued livestock grazing on public lands violates federal mandates to reduce GHG emissions and a massive subsidy to public lands ranchers.

The Kauffman et al. paper provides more evidence that the termination of domestic livestock use of our public domain is economically and ecologically beneficial to the public.

Logging roads are a major negative impact on ecosystems. Photo George Wuerthner 

The latest attempt by the Forest Service to make logging palatable is using the terms “temporary” and “closed” roads. The implied message is that road impacts are magically eliminated if they are temporary or closed. Roads, temporary, “closed,” or permanent, are among the most significant effects on forest ecosystems. (For a good review of road impacts, see Trombulak and Frissell.)

An ineffective “road closure” on the Custer Gallatin National Forest, Montana. Photo George Wuerthner 

The Forest Service has at least 400,000 miles of roads on the lands it administers, and these roads have a significant environmental collateral impact associated with logging and other resource exploitation.

A “closed” road still provides access to hunters, ATV, dirt bikes and mounain bikes. Photo George Wuerthner 

However, “temporary” roads and so-called “closed” roads are not the same as no road. Even years ago, when I was a wildlife student at the U of Montana, research showed that even “closed” roads had a passive negative impact on wildlife because people used them.

Where ATVS have driven around a “closed” road gate. Beaverhead Deerlodge NF, Montana. Photo George Wuerthner 

Given the steep terrain in western Montana, I often hunted by walking on the “so-called” closed roads. And, of course, dirt bikes, ATVs, and mountain bikes regularly use them.

A “reclaimed” logging road on the Custer Gallatin National Forest, Montana. A truely reclaimed road would restore the slope and lens, ripped up compacted soil profile, and replant the natural vegetation. Photo George Wuerthner 

Worse for the ecosystem, these “closed” roads are seldom rehabilitated to restore the road lens and slope. Creating logging roads and skid trails increases soil density, reducing water infiltration. Soil compaction along logging roads can last for up to 100 years. Road cut the subsurface flow of water, which often winds up on the compacted roadbed where it gathers sediment that flows into streams, harming aquatic life.

Erosion and sedimentation from logging road, Rock Creek drainage, Beaverhead Deerlodge NF, Montana. Photo George Wuerthner 

Numerous studies have shown that roads are a chronic source of sedimentation into streams, while even the sediment after a fire usually only lasts a few years. Sedimentation from logging roads is why sensitive species like bull trout have declined across much of its range.

Logging roads also displace sensitive wildlife (i.e., elk, bears, and other wildlife) that avoid human intrusions.

Weeds growing along logging road. Logging roads are a major vector for the spread of weeds. Photo George Wuerthner 

Roads are also a major source of weed spread. Some of these weedy species, like cheatgrass, increase wildfire, and other species, like spotted knapweed, compete with native plants.

The construction of roads removes biomass and reduces carbon storage in the area.

Another critical factor today is that nearly all human ignitions occur near roads. One study found that 90% of all wildfires happened within a half mile of a road.

The miles and miles of FS roads are one of the factors in the growth of wildfires since most of these human ignitions occur when natural ignitions from lightning are not happening. . Human ignitions started 76% of the wildfires that destroyed structures, and those fires tended to be in flammable areas where homes, commercial structures and outbuildings are increasingly common.

Human ignitions, facilitated by access along logging roads, lengthen the fire season, contributing to more blazes.

Logging roads by opening the forest can lead to drier conditions and funnels of wind along the corridor, which enhance fire spread.

A fully reclaimed logging road in Redwood National Park. Photo George Wuerthner 

To fully reclaim a road is more than putting up a gate to block vehicle travel. It requires ripping up the roadbed to remove the compacted soil layers. The side slope soil has to be put back on the site and reshaped to restore subsurface and surface water flow. Culverts need to be removed. Stream channels are entirely restructured and reconstituted. Vegetation needs to be planted—and grass seed is not enough, especially if the area once supported forest. Logs, rocks, and other natural structures must be returned to the slope.

Essentially, these logging road ecological costs are a subsidy to the timber industry that is not internalized. If they were included in the cost of a timber sale, we would have a lot less logging on public lands.

Home hardening is by far the most effective means of reducing wildfire home losses.

Wildfire ravaged the community of Lahaina on the Hawaiian Island of Maui, and the death toll mounts. Are there any lessons to be learned from this tragedy?

The wildfire began in grasslands and, driven by near hurricane-force winds, the blaze rapidly ignited wooden homes in Lahaina. The fire then mushroomed into a house-to-house blaze. Since burning structures emit more heat than wildfire, a domino effect followed that consumed at least a thousand homes.

The Lahaina fire offers some insights into why the current Forest Service policy of focusing on fuel reduction is misguided.

Regrowth of vegetation after a prescribed burn has increased the amount of fine fuels like grass and shrubs on the ground. Photo George Wuerthner 

First, the Lahaina fire started in grasslands. About half of all wildfires are burning in non-forested habitats like sagebrush, grasslands, and chaparral, for which logging/thinning has no effect.

But the biggest problem is that extreme fire weather, particularly blazes driven by high winds, is impossible to stop. Since nearly all large blazes that threaten communities occur under extreme fire weather, it behooves us to ask whether the current public policy of fuel reductions is effective.

The answer is no amount of fuel reduction is effective under extreme fire weather with wind-driven conditions. Embers lofted by winds even ignited boats on the ocean in Lahaina’s harbor. If the sea with zero fuel isn’t an effective fire break, reducing the trees by logging won’t preclude wildfire spread.

Plus, logging/thinning results in collateral ecosystem damage, including the spread of fire-prone weeds, disturbance of wildlife, removal of biomass, loss of carbon storage, and the creation of roads, increasing human access and ignitions.

After agriculture, logging has reduced carbon storage more than any other human activity. On-going logging emits carbon that exacerbates climate warming, thus increasing the likelihood of wildfire ignition and spread.

Logging and wood products production releases significant amounts of CO2 into the atmosphere. Photo George Wuerthner 

In Europe, most homes are built of bricks, concrete, stone, and other fire-resistant materials. Building with steel, brick, adobe, and other materials is superior to exposed wood in new construction.

This home that survived the Lahiana blaze had recently been renovated with a metal roof, and stones that surrounded the house foundation. (Kevin Fujii/Civil Beat/2023)

Given these realities, reducing home ignition should be the preferred public policy. Renovating homes by installing metal or other non-burnable roofing material, screening vents, and removing vegetation immediately next to the structure can significantly enhance the house’s survivability. Encouraging non-wood home construction could further enhance community safety.

In the end, fuel reductions (other than immediately adjacent to homes and communities) are ineffective policies. We should shift the fire policy focus on the house and work outward.

The media and many others, including conservation groups, suggest the cause of today’s wildfires is the result of fire suppression. They point to the cessation of Native American cultural burning as a primary reason for larger blazes. This has led to expensive and often ecologically destructive forest management policies.

A Charles M. Russell painting showing Indians igniting a fire.

I repeatedly hear how tribal burning precluded large blazes by igniting frequent fires that reduced fuels.  Here’s a recent example from a CBS news report referring to fire scars, which some fire researchers use to reconstruct fire history: “Those scars, research shows, are evidence that Indigenous Americans successfully controlled wildfires by regularly setting smaller fires to reduce the buildup of fuel.” You can find similar assertions almost daily in the media.

TRIBAL CULTURAL BURNING

1. The claim that Indian burning precludes large fires feeds into the “fuels is the problem” narrative, which is increasingly discredited, as large wildfires are driven by extreme climate weather.
2. Climate and weather conditions, drought, low humidity, high temperatures, and high winds drive large fires.
3. These conditions have always existed, and paleo-climate-wildfire evidence demonstrates that large blazes have always occurred despite indigenous burning. However, they are being exacerbated today by human-caused climate warming.
4. Indigenous burning resulted primarily in localized fuel reductions but seldom affected the larger landscape.
5. Historical, scientific, ecological, and evolutionary evidence challenges the Indian burning narrative.
6. Large high-severity fires are not “destructive” but essential to many healthy forest ecosystems.
7. Across the West, lightning strikes are sufficient to ignite fires.
8. The way to protect homes is to start from the home outward, not to “treat” forests at the landscape scale.

CULTURAL BURNS PRIMARILY DONE IN SELF-INTEREST

Cultural burns were not done to promote ecosystem health or any such notions. Instead, they were conducted to advance human interests—attract game animals, clear pathways through vegetation to make human travel easier, clear forests for crop production, etc. These are all human self-interest concerns.

The influence of these human ignitions is debated, but much evidence suggests cultural burning was primarily localized and had limited impact on the larger landscape.

Tribal people were just as aware as people today that an ignition set when there is severe drought, high temperatures, low humidity, and wind results in uncontrollable and potentially lethal blazes. Thus, most planned human ignition fires likely charred a small area since they were set under the same moderate fire weather circumstances that occur today when any prescribed burn is authorized.

Sagebrush has no adaptation to frequent fire. The fact that sagebrush is one of the most widespread ecosystems across the West suggests that tribal burning had little landscape scale influence. 

No doubt some blazes got away just as today, but as generalization, most human ignitions did not significantly add to the natural fire rotation.

Evolutionary evidence supports this idea in that low-elevation plant communities like sagebrush did not burn frequently as they have no adaptations to fire. If Indian burning were as widespread as suggested, sagebrush would be relatively rare, not one of the most widespread plant communities in the West.

The fire rotation of sagebrush varies from species to species but is between 50 to 400 or more years. This evidence does not support the idea that frequent (5-10 years) cultural burning was common across the Western landscape.

The evolution of sagebrush-adapted species like the sage grouse and sage sparrows suggests a long association with this plant community.

Higher-elevation forest communities also tend to have long fire-free intervals of hundreds of years. Photo George Wuerthner

Furthermore, cultural burning or purposeful human ignitions is not unique to North American tribal people. Burning is a tradition across the globe. Evidence shows that Paleo-Europeans burned forests 20,000 years ago to attract and kill Ice Age mammals. Human ignitions were historically common in Asia, Africa, Australia, and elsewhere. It is by no means unique. But in all cases, it was done to further human interests, not the ecosystem or Nature’s.

REASONS FOR FIRE SUPPRESSION

Native Americans were not the only people who regularly set fires, as often implied. Burning vegetation for practical human ends was typical among settlers, hunters, livestock owners, and miners. Indeed, towards the end of the 1800s, it was common practice for sheepmen in the West to burn forests to create more pasture. Miners sometimes set fires to expose ore-bearing rock. In the Southern Appalachians, the famous bald mountain tops were likely the result of ignition set by the local community to promote livestock use. And in the days before bulldozers and chainsaws, settlers and Indians burned forests to create pasture and farmlands.

Burning for all the above reasons, including tribal cultural burning, makes sense from a human perspective. Humans exploit the environment for our self-preservation and survival.

However, the fire suppression era also has historical roots, which should be mentioned more. It was not that foresters were ignorant fools who wanted to “destroy” the forest by suppressing wildfires, as commonly implied.

Instead, at the end of the 1800s, there was a severe fear that America was running out of forests. In the 1800s, wood was far more critical to everyday life than today. People used wood to heat homes, run generators, power steam engines, not to mention for newsprint, and to construct wood structures.

The movement to create national forest reserves developed because Americans believed the country faced a wood famine without such reserves.

The other issue for Americans was that wildfire was a threat to settlements. In the days when fur trappers and tribal people roamed the West, the loss of a settlement or village was not a significant issue. For most tribal people, replacing teepees, wickiups, or even dug-out shelters with locally available materials like animal hides, logs, or shrubs was relatively easy.

However, significant fires threatened numerous communities by the turn of the 1900s. It was not uncommon for entire towns to burn to the ground if a fire was ignited—though most were, like now, started in the cities themselves. Therefore, fire suppression was a rational response to the menace created by wildfire.

This fear of wildfire and tree losses coincided with the establishment of the fledging U.S. Forest Service in 1905 by Gifford Pinchot. Pinchot faced tremendous opposition from western Congressional members and their constituents to federal forest reserves (now called national forests). Pinchot’s newly created Forest Service was under attack.

CLIMATE AND THE MYTH OF FIRE SUPPRESSION

The often-repeated notion that there have been 100 years of EFFECTIVE fire suppression is questionable.

The 1910 Big Burn raced across 3 million plus acres of Northern Idaho and Western Montana propelled by hurricane forest winds. Seen here is the proposed Great Burn Wilderness. Photo George Wuerthner 

The 1910 Big Burn that charred more than 3-3.5 million acres across Idaho and Montana shocked the nation. Even Westerners were upset that forests could disappear, creating economic hardships for the Nation. Pinchot, ever the strategic politician, used the Big Burn to argue that his newly created Forest Service could suppress fires and prevent large blazes. He argued that the Forest Service could be the anti-fire service.

At first, the newly created forest service hired forest rangers who primarily fought fires. The rangers built trails, set up fire lookout towers, put in thousands of miles of telephone lines, and jumped on all ignitions.

The Forest Service’s effect on fire acreage was insignificant because then, as now, fires are primarily controlled by climate-weather conditions. Thus, during the drought period that dominated some parts of the West between 1910 and 1930s, some of the most extensive acreage burned occurred. Indeed, in 1929, nearly 50 million acres burned across the West.

To put this into perspective, if 10 million acres burn across the West today, that is considered a “record year” for wildfire.

These drought conditions continued into the 1930s, and America experienced the Dust Bowl.

The fact that tens of millions of acres burned annually suggests the idea that we have had a hundred years of fire suppression is more exaggeration than fact. Some fires were likely extinguished, but given the vast acreage charred. It was a drop in the bucket.

In 1935, trying to improve its ability to put out fires, the Forest Service adopted its 10 AM policy. By 10 AM the day after a fire was spotted, the agency would try to put the blaze out.

The chart begins in 1926 and continues to 2016. It is clear that despite efforts to suppress wildfires, overall, large wildfires still prevailed during the earlier part of the 1900s with as much as 50 million acres burning, but decling to a low around mid-century that continued up until the 1980s.

The Forest Service’s 10 AM policy appeared to be successful. However, the low point in wildfires coincided with cooler and moister conditions from the 1940s to the 1980s. Glaciers were expanding in the Pacific Northwest, and calm, wet conditions prevailed across the West.

This chart shows how fire acreage declined between the late 1930s to late 1980s due to the Pacific Decadial Ossillation which favored cool, moist weather.

Indeed, some researchers suggest there is a fire deficit as a result of the Little Ice Age influence on wildfire.

Under less than extreme fire weather conditions, most wildfires self-extinguish without burning a significant amount of the landscape. So, the apparent decline in wildfire acreage during these decades is likely a consequence of Natural conditions unfavorable to fire spread than any human efforts to quell blazes.

In the aftermath of the decline in federal logging beginning in the 1990s due to environmental concerns and simple economics, significant funding shortages were shrinking the Forest Service. No bureaucracy likes to wither, so a new rationalization for logging and agency funding came. The Forest Service would again be the fire agency, putting out large blazes and, by happy coincidence, finding a justification for more logging, thus keeping the timber industry happy.

The Forest Service adopted prescribed burning and logging as the primary strategy for fire control. While somewhat effective during low to moderate fire weather, under extreme weather conditions, particularly with wind, neither of these fuel reduction tactics works to limit fire acreage burned.  Indeed, evidence suggests that active forest management often enhances fire spread.

FUEL TREATMENT EFFECTIVENESS

As explained, burning, thinning, and other prescriptions do not work under extreme fire conditions.

Why is this important? Because nearly all of the acreage burned annually occurs in a relatively few vast fires. These fires start under extreme fire weather and don’t go out or are even influenced by firefighting efforts until the weather changes. High winds drive embers around and through thinned stands and prescribed burning.

Helicopter view of the Angola Fire that charred South Lake Tahoe. The area in this photo had been thinned six months prior to the blaze. 

Some of the largest fires in recent years, such as the Holiday Farm Fire (OR) and Dixie Fire (CA), burned through areas with substantial logging.

One of the problems with statements like fire suppression is responsible for large blazes is that most fires remain small whether they are suppressed or not.

For example, between 1980 and 2003, 56,320 wildfires charred 9 million acres in the Rocky Mountains. Of these tens of thousands of fires, 98% of these fires (55,220) accounted for 4% of the area burned. Only 2% of all fires accounted for 96% of the acreage. Fifty fires, or 0.1% of all blazes, were responsible for half of the acres charred!

A further problem has to do with the way historical fire regimes are determined. The most popular means examining fire scars created when a blaze chars but does not kill the trees. However, there are numerous methodological problems with fire scar reconstruction. One of them is that they mainly count the number of fires but seldom provide their geographical extent. Since, as presented above, the vast majority of all blazes are minor and affect a tiny fraction of the landscape, fire scar studies are subject to essential biases that tend to reduce the fire-free intervals.

FIRE INDUSTRIAL COMPLEX

I do not doubt that many advocates for thinning and prescribed burning believe these activities change fire behavior. Nevertheless, across the West, we find that the highest severity fires occur where active forest management has occurred, while places such as wilderness areas where logging and burning are prohibited tend to burn at lower severity.

Even if thinning and prescribed burning were effective, the scale necessary to reduce large fires on the hundreds of millions across the West susceptible to wildfire is beyond human ability. As a report published by Environment Now stated, trying to change wildfire behavior with prescribed burning (and thinning) is analogous to a watering can that pretends to be a river.

A thinning project like this on the Wallowa Whitman National Forest removes carbon stored in trees, leaves little ground cover for small mammals to hide under, and can enhance fire spread by promoting wind penetration. Photo George Wuerthner

The desire to control wildfires, even high severity blazes where many of trees are killed, as well as thinning projects, have significant ecological consequences. Many species of wildlife depend on the snag forests, and down wood created by large blazes.

Even though there is more and more recognition that climate change is the ultimate culprit contributing to ever-larger blazes, the Forest Service and timber industry continue to promote the fire suppression myth since they can use it to justify logging. Furthermore, the public wants immediate relief from smoke and blazes; fuel reductions promise such relief.

The promotion of the fire suppression explanation for large blazes obviously favors a fuel reduction response. However, when seen in a longer context of how climate has always been the final arbitrator of wildfire in the West, it is clear that fire suppression is not the primary factor in the growing annual acreage burned.

One commonly asserted myth is that frequent burning can substantially reduce the area burned by wildfire across the landscape. Photo George Wuerthner 

Poorly informed journalists flood the public with misinformation about wildfire ecology. The common theme insinuates that we can and should manage nature.

I am sympathetic to the plight of journalists who are overworked and have little time for investigative research. Most journalists also come from a liberal arts academic background. Few are trained in science and even how to interpret and evaluate competing complicated scientific controversies. Still, I find it unacceptable for the national press to continue perpetuating myths about wildlife when they could easily obtain an alternative perspective with simple Google searches.

A continuous theme in the media is that we can “engineer” with human ingenuity with logging and prescribed burning in some way to control large blazes.

As Barrett et al. (2005) noted: “For many years, the importance of fire use by American Indians in altering North American ecosystems was underappreciated or ignored. Now, there seems to be an opposite trend… It is common now to read or hear statements to the effect that American Indians fired landscapes everywhere and all the time, so there is no such thing as a ‘natural’ ecosystem.”

A myth of human manipulation everywhere in pre-Columbus America is replacing the equally erroneous myth of a totally pristine wilderness.

An example of this tendency to exaggerate the influence of prescribed or cultural burning on wildfire is found in a recent article in the San Francisco Chronicle republished a piece that originally appeared in Canada’s Globe and Mail. The title was Canada Parks; Indigenous leaders fight fire with fire. Like so many articles about wildfire these days, the media again repeats misinformation and fails to do its homework.

The story’s main thread is that prescribed burns (intentionally set fires) can preclude large wildfires. A second theme is how this insight Native people have known for generations, and firefighters are only now rediscovering it.

Advocates of prescribed or cultural burning suggest frequent human ignition results in low-severity burns that emulate natural conditions across all ecosystems, improve forest “health,” and that such fuel treatments can significantly affect the acreage burned by wildfire.

Near the opening paragraphs, the author writes: “As wildfire seasons become longer and more intense, experts say prescribed burns can help prevent forests from becoming out-of-control infernos. For Indigenous peoples, revitalization of traditional fire knowledge and practices is emerging as an important strategy in adapting to wildfire threats.”

The story describes how the local tribe in SE British Columbia used fire to manage the landscape.  I see this mindset that humans know how to “manage” the landscape as one of the primary reasons for our environmental crisis.

Cultural burning (i.e., that done by tribal people), the article explains, was done to promote berries or attract big game to graze on the regrowth found in recently burned sites.

The article quotes tribal member Marty Williams, who says the fires will treat the “overgrown, unhealthy forests.” This narrative that forests are overgrown and unhealthy is identical to the rhetoric from the timber industry.

While it is true that burning can increase some berry production and ungulates like deer and elk are attracted to feed on the nutritious regrowth after a fire, to suggest this is “good” for Nature is just human arrogance. Nature isn’t “healthier because there are more elk to shoot or berries to consume. Tribal burning is about self-interest, not what is good” for the natural world.

The article accurately notes  that many forest communities are adapted to wildfire but then concludes that this improves “forest health.”

Indeed, many ecosystems are fire-adapted, but whether a fire is good or bad for “health” is a human value, certainly not an ecological value.

The author uses lodgepole pine as her example of a fire-adapted species in an article promoting frequent prescribed burns, failing to note that lodgepole typically has long fire rotations and is not historically burned at frequent intervals. The natural situation for lodgepole pine is to burn at high severity-stand replacement intensity.

Lodgepole pine tends to burn at long intervals often centuries apart,  and usually burn at high severity that results in even-aged regeneration seen here. Such dense forests are not “unhealthy” but the normal part of lodgepole pine ecology. Photo  George Wuerthner 

And herein is another one of the problems created by the ill-informed media. Most major plant communities in the West, except for ponderosa pine (even among pines stand replacement fires were natural), tend to have long, sometimes centuries-long intervals between significant burns. This includes lodgepole pine, spruces, firs, juniper, sagebrush, aspen, and numerous other dominant western ecosystems.

During this fire-free interval, fuels do accumulate. However, that is a natural process, not something that can be used as an excuse for prescribed burns or logging.

Frequent low severity fires is uncommon among most plant communities in the West.  Aspen, for instance, tend to burn under extreme fire weather conditions. Photo George Wuerthner 

The idea that prescribed burning is emulating natural fire regimes across most of the West’s ecosystems is ecologically inaccurate.

The article quotes a BC forestry consultant who says, “Prescribed burns can help prevent wildfires by reducing fuel built up over decades. And with climate change expected to dry fuel and make wildfires more intense, such preventive measures could become critical.”

The repeated “fuel build-up” over decades misinterprets fire regimes where fuel build-up is natural.

Later, the article says: “That included work over the past few seasons to thin and harvest some timber from the site to make for a safer burn.” Logging does not make the ecosystem healthier or reduce large wildfires.

Logging or thinning has numerous negative consequences including loss of carbon storage, loss of wildlife habitat, soil compaction, sedimentation of waterways from logging roads, and other collateral damage that seldom accounted for in any “fuel treatment”. Photo George Wuerthner 

Of course, logging is nearly always part of any prescription for fuel treatments.

The problem with all these assertions about prescribed burns and thinning is that they are largely ineffective and an inefficient means of dealing with wildflire, and they are not without ecological harm to ecosystems.

PRESCRIBED BURNING (CULTURAL BURNING) WON’T MAKE A DIFFERENCE IN ANNUAL ACREAGE FIRE-CHARRED.

As a report by Environment Now concluded, the use of prescribed burns is like using a watering can and pretending it is a river. In other words, even if prescribed burning did significantly reduce fire spread and fire severity, the amount of land that would need to be “treated” far beyond the ability or capacity of federal and state agencies to implement.

 Even if prescribed burning were effective at controlling large blazes, the acreage that can be treated is so small as to be irrelevant. Photo George Wuerthner 

For example, the article mentions that across all of British Columbia, approximately 10,000 hectares (about 25,000 acres) are scheduled to be burned this year. Of course, not all those planned burns will be successful due to limits imposed by weather, availability of personnel, and other factors. But 10,000 hectares is a drop in the bucket, so to speak, when it comes to fuel reductions.

High winds blow embers over, around, and through fuel treatments such as prescribed burning or thinning fail. Photo George Wuerthner 

The second problem with the idea that prescribed burns are the panacea for large wildfires is that all significant wildfires burn under extreme weather conditions. These conditions include low humidity, high temperatures, drought, and, most significantly, high winds. And under such conditions, thinning, burning, and other “fuel treatments” do not work.

High winds create a shower of embers that can travel a mile or more across the landscape. Thus, under such conditions, embers fly over, around and through any prescribed burn or thinning project.

Historically, there is little evidence that Indian burning  made any significant differences in overall acreage burned. There is plenty of paleo climate/fire evidence that go back thousands of years demonstrating that large blazes occurred during drought periods. In other words, large fires have always occurred with the right combination of extreme fire weather—with or without human ignitions.

The above chart shows that large wildfires occurred periodically in Yellowstone NP over centurties, despite the presence of presumed human ignnitions.

Furthermore that idea that human ignitons did not preclude large blazes. Paleo climate and fire research shows a correlation between years and decades of large fires long before there were any humans in North America to influence fires.

Even after human colonization of North America, with the right combination of weather/climate conditions there have always been large blazes across the West. To quote from a recent article on fires in Washington state: “1701 is given as the best estimate for the last devastating fire that occurred throughout Western Washington, a fire that burned an estimated 3 million to 10 million acres. At the upper end of that range, the area is roughly equal to 10 Olympic National Parks” (Puget Sound Institute).

The 1910 Big Burn that scrotched more than 3 million acres of Idaho and Montana occurred long before there was successful fire suppression and “fuel build-up.” 

All significant ecosystems existed for thousands of years before humans arrived. Ponderosa pine, for instance, has been around as a separate species for 55 million years. To suggest that ponderosa pine forests need human ignition to be healthy is the ultimate in human arrogance.

Sagebrush has no adaptations to wildfire. Frequent burning will eliminate it from the landscape. Photo George Wuerthner 

We also have evolutionary evidence that frequent, low severity fires that cultural or prescribed burning seeks to emulate, did not influence landscape scale fire regimes. For instance, sagebrush has no adaptation to fire, and is typically killed by blazes. If wildfire, whether those set by native people or lightning, were common as suggested, we would not have sagebrush steppe as one of the most widespread plant communities in the West. Nor would we have sage grouse, sage sparrow, pygmy rabbit and a host of other species that evolved to reside in these habitats.

Some Indigenious burning advocates focus on how tribal burning influenced small areas like the Yosemite Valley, but then extrapolate that Indian burning controled fire frequency and size on the larger landscape.

A smoke filled Yosemite Valley. Photo George Wuerthner 

A counter to this narrative are the findings of Vachula et al. (2019) did a study of what is now Yosemite National Park where, historically, large Indigenous communities resided. Their research found a direct correlation between climate and the amount of burning on the landscape.

“We analyzed charcoal preserved in lake sediments from Yosemite National Park and spanning the last 1400 years to reconstruct local and regional area burned. Warm and dry climates promoted burning at both local and regional scales…

Regional area burned peaked during the Medieval Climate Anomaly and declined during the last millennium, as climate became cooler and wetter and Native American burning declined.

Our record indicates that (1) climate changes influenced burning at all spatial scales, (2) Native American influences appear to have been limited to local scales, but (3) high Miwok populations resulted in fire even during periods of climate conditions unfavorable to fires. However, at the regional scale (< 150 km from the lake), fire was generally controlled by the top-down influence of climate.”

If the media did its homework, it would discover there are alternative perspectives on wildfire frequency and ecological influence. For instance, a recent paper challenges the notion that low seveirty frequent blazes were a significant influence on many plant communities. Another review finds that high severity blazes are more common in areas with “active forest management” meaning prescribed burning and logging. Other papers refute the idea that tribal burning had any significant influence on the larger landscape and that most burning was localized.  Yes tribal burning influence small areas where humans frequented like villages, travel corridors and other areas, their mark on the larger landscape is greatly exaggerated.

As Paleo fire ecologist Cathy Whitlock noted in a study  of the fire history of Oregon’s Willamette Valley which historically was one of the most densely settled areas in the West. Regarding Indigenous ignitions in the Willamette Valley, Whitlock notes: “The idea that Native Americans burned from one end of the valley to the other is not supported by our data … Most fires seem to have been fairly localized, and broad changes in fire activity seem to track large-scale variations in climate.”

Instead of promoting false solutions that are largely ineffective and inefficient at controlling large blazes, the media would provide a better service to the public if articles focused on two things: reversing climate warming by reducing human carbon sources, and protecting homes and communities by hardening  homes, rather than trying to “manage” fuels on the forest.

I just saw the movie Wild Life about Doug and Kris Thompkins’s efforts to protect wildlands in Patagonia.

Doug and Kris Tompkins at Renihue Chile. Photo George Wuerthner 

I am very familiar with the effort as I worked for Doug and Kris for more than ten years and made numerous visits to Patagonia. Unfortunately, with Doug’s tragic death kayaking, we lost one of the world’s most ardent supporters of wildlands.

Lucky for the Patagonian wilds, Kris has continued to promote the vision of rewilding large, protected landscapes to preserve biodiversity, beauty, and wildness. Thus far, the couple has helped to preserve nearly 20 million acres as national parks.

Everyone who didn’t know Doug and Kris thought creating a landscape-scale protected area in Patagonia would be impossible.

Doug was a world-class climber and kayaker. Throughout his life, he was constantly confronting the “impossible.” Peaks people thought no one could climb. Rivers people thought were unrunnable. Later in his life, he advocated wildlands protection on a scale most people thought was impossible. Naysayers did not deter Doug.

The first Wildlands Project Meeting in 1991 at Doug Tompkin’s home in San Francisco, California. Photo George Wuerthner 

I first met Doug in 1991 when he gathered some wilderness activists and conservation biologists at his San Francisco home to discuss how to reinvigorate the conservation movement. Beyond meeting Doug, one consequence of that meeting was the formation of the Wildlands Project, which advocated for a continental vision of protected wildlands across North America using conservation biology concepts. I served on the board of the Wildlands Project for ten years.

This association eventually led to a job offer from Doug as Ecological Projects Director for the Foundation for Deep Ecology.

When I worked for Doug, we had numerous discussions about what we considered a fundamental crisis in the worldview of the environmental movement. Doug constantly reminded me that most conservation groups were too timid, too narrow in their vision, and lacked the imagination and courage to think big.

Doug used to quip: “We are always losing, no matter what, so you might try to preserve as much as possible.”

The vastness of the Maine Woods invites a bold proposal for a 3.2 million acre National Park as articulated by RESTORE. Photo George Wuerthner 

He even chided me as board president of RESTORE the North Woods because he thought our 3.2 million acre proposal for a Maine Woods National Park was too “small,” even though it was a million acres larger than Yellowstone National Park. Doug kept telling me to go bold—argue for 5 million acres.

Doug didn’t lack courage, vision, or imagination when advocating for large, protected landscapes.

BIOCENTRIC VS. ANTHROPOCENTRIC

With the Wild Life movie fresh in my mind, I’ve felt for years that wildlands advocates should work to expand Yellowstone National Park and preserve the entire Greater Yellowstone Ecosystem under National Park Management.

Map of Greater Yellowstone Ecosystem. 

The Greater Yellowstone Ecosystem is the largest intact temperate ecosystem in the world. But it is suffering the cumulative impacts of a thousand cuts. Something needs to change, or we may lose our last chance to get it right.

Across the globe, large, protected areas have been shown repeatedly to be the best way to preserve evolutionary processes and biodiversity. Even where species decline is noted, the creation and maintenance of protected preserves tend to slow the losses and, in some cases, reverse the trend.

Wildlands advocates are busy fighting every abuse and insult to the ecosystem’s integrity. It is a rear-guard action. Rather than spend time trying to contain these misuses, a more proactive strategy is to put forth a positive vision to counter most of these ecological insults.

If we can’t preserve the Greater Yellowstone Ecosystem here, where can we?

PROTECT THE ENTIRE GREATER YELLOWSTONE ECOSYSTEM

Yellowstone has become a model for conservation across the planet.

Yellowsotne National Park sign in Gardiner, Montana. Photo George Wuerthner

Depending on how you define the borders, Greater Yellowstone Ecosystem (GYE) is anywhere from 20-23 million acres. To put that into perspective, that is roughly the acreage of Maine. The heart of the ecosystem is the 2.2-million-acre Yellowstone National Park. Surrounding the park are other parklands like Grand Teton National Park and the John D. Rockefeller Parkway.

There are seven national forests. Many of these forestlands are designated Wilderness, one of the most stringent land management categories available. Wilderness is managed primarily to enhance and preserve wildness—or “self-willed lands.”

Drill rig outside of Pinedale, Wyoming. Photo George Wuerthner

Unfortunately, these public lands outside the Wilderness are “open” for business. Mining, logging, livestock grazing, oil and gas drilling, and Industrial recreation all find a favorable reception in the national forests.

Porcupine drainage in Gallatin Range, Montana. Photo George Wuerthner 

One of the most vulnerable NF landscapes is the Gallatin Range, which lies south of Bozeman, Montana. The Gallatin Range is currently part of a Wilderness Study Area but lacks Congressional designation as Wilderness. It is a crucial area that should be protected as Wilderness.

Pryor Mountains south of Billings, Montana. Photo George Wuerthner 

Another significant area currently without protection as Wilderness is the Pryor Range which lies on the eastern edge of the GYE. The Pryors have some of the greatest plant diversity of any mountain range in Montana. The FS, BLM, and NPS manage the range.

Wyoming Range, Bridger Teton National Park, Wyoming. Photo George Wuerthner 

Similarly, the Wyoming Range, Salt River Range, and Commissary Ridge on the Bridger Teton National Forest south of Jackson should also be given greater protection as Wilderness.

Though neither Yellowstone nor Grand Teton is currently covered by a wilderness overlay, for the most part, the NPS manages its lands as defacto wilderness.

The Northern Rockies Ecosystem Protection Act (NREPA)  is a bold and visionary proposal that would have made Doug Tompkins smile. NREPA would go a long way towards protecting these areas and many other roadless areas in other parts of the region. NPEPA would also finally bring wilderness designation to Yellowstone and Grand Teton national parks.

Though I support wilderness designation as an overlay to federal lands, even Wilderness alone is not necessarily as good as the national park designation overlain by Wilderness.

For instance, even with Wilderness surrounding Yellowstone on nearly all sides, wolves, grizzlies, bison, and other animals are regularly killed by trappers, hunters, and sometimes agencies like Wildlife Services. Livestock grazing is permitted.

The National Park Service’s mission tends to preserve evolutionary processes. The agency is willing to close large areas of Yellowstone to protect grizzly bears. These Bear Management Units cover as much as a quarter of the park. They are designed to minimize conflicts between bears and people. Similarly, the NPS will close areas to human use around wolf dens, eagle nesting sites, spawning streams, and other wildlife use areas to protect these animals from human intrusions.

For the most part, National Park management seeks to preserve evolutionary and ecological processes, not just species. Thus, wolves preying on elk or wildfire rejuvenating the landscape are tolerated and celebrated in national parks.

WHY THE NATIONAL PARK SERVICE

Other land management agencies fail to protect the GYE values. From the dominance of livestock grazing to promotion of logging and oil and gas development, the Forest Service, Bureau of Land Management, and even the Fish and Wildlife Service support resource extraction and activities that degrade the ecosystem’s ecological integrity.

Even though some national forest lands are preserved with an overlay of Wilderness, many areas outside Wilderness are vulnerable to resource extraction.

Logging on the Custer Gallatin National Forest near Bozeman, Montana. Photo George Wuerthner 

Therefore, putting the entire GYE under the jurisdiction of the National Park is the best way to ensure the long-term preservation of the Greater Yellowstone Ecosystem.

The National Park Service is the ideal agency for managing a Greater Yellowstone Ecosystem because its mission is to enhance and preserve natural processes and minimize human influences.

The NPS has a mandate to manage these lands for ALL people.

Only 1% of the current park is roaded, and nearly all human impact is limited to those few areas. While neither Yellowstone nor Grand Teton National Parks are designated Wilderness, the NPS still manages these lands as if they were designated Wilderness.

A enlarged Yellowstone National Park would protect a larger portion of migrating wildlife like bison from slaughter. Photo George Wuerthner 

Enlarging Yellowstone Park would ensure more winter range for the park’s ungulates like bison, elk, and pronghorn. It would ensure predators can roam freely over more of the landscape without fear of being trapped or shot. A bigger park would store more carbon and preserve more headwater streams from mining, grazing, and logging.

PRIVATE LANDS

Private lands are also a noteworthy feature of the GYE. I do not want to imply that conservation lies only on public lands. Private lands possess many conservation values. Unfortunately, we have few mechanisms to foster consistent conservation protection on private lands.

Nevertheless, efforts to protect critical landscapes are ongoing, including measures like zoning, conservation easements, and outright acquisition of biologically critical lands. Congressional funding for critical linkage, migration corridors, and important biological hot spots should be prioritized.

WHY CREATE A GREATER YELLOWSTONE NATIONAL PARK?

Beyond the mission of the NPS, there are other reasons for creating a Greater Yellowstone National Park.

BIODIVERSITY

There is abundant evidence that human exploitation and occupation of the planet are causing undue and unnecessary species extinction. Many suggest we are experiencing the Sixth Great Extinction (some argue there were more past extinctions). Whatever the number, there is no excuse for knowingly permitting millions of species to disappear without at least attempting to provide a lifeboat. Parks and Wilderness are among our best lifeboats for countering this species’ demise. Given the fundamental mission of the NPS to protect and preserve evolutionary and ecological processes, not to mention individual species, the creation of a Greater Yellowstone National Park would likely ensure that the ecosystem will continue to be a place where species have a chance of survival into the next century.

GRATITUDE

Whenever I spend time in Yellowstone, I am grateful that someone came up with the idea of a national park to preserve the landscape features. The prime consideration among park proponents was the protection of thermal features like geysers and hot springs, which there are more of in Yellowstone than in any other place in the world. However, since its original designation as a national park, its value for preserving wildlife and evolutionary processes has grown. Yellowstone prompts gratitude in my heart for its role in expanding the concept of “natural rights.”

BIOCENTRIC/INTRINSIC

Similarly, Yellowstone’s NPS management mandate tends to foster a biocentric perspective. Nature and all life have a right to exist beyond its economic or exploitative value to humans.

Wildland preservation is not about humans but acknowledging that other life has a fundamental right to existence. Parks and Wilderness foster humility and are an antidote to domination and human arrogance.

Wildland preservation is an expansion of “rights” to other creatures. It fosters an attitude of self-control and personal responsibility—both essential elements of any society.

However, this view is under increasing attack from social justice advocates who tend to view everything from a human perspective. Nevertheless, if Yellowstone persists as a conservation model, biocentric attitudes will likely continue to be valued.

Preservation of wildlife among wildlands splendor is one of the underrated values of Yellowstone National Park. Photo George Wuerthner

BEAUTY

It may seem unimportant, but parks preserve beauty. Beauty stimulates human appreciation and positive interactions. Studies have shown that immersion in nature demonstrates that people are just nicer to each other in a natural setting.

Preserving beauty is one of the values park designations seeks to maintain. Aesthetic value is often associated with natural landscapes. Beauty is not just a luxury but a fundamental human right. Wildlands preserve beauty not found in the humanized urban or even pastoral landscape.

GENETIC INTEGRITY

Predation is an important factor in genetic divesity and preservation of wildness. Photo George Wuerthner 

Greater Yellowstone National Park would increase the overall population size of most species protected from human manipulation, whether hunting/trapping or “thinning” of forests, and so forth. A larger metapopulation is the best insurance for preserving genetic integrity. In addition, since national parks generally keep and encourage ecological and evolutionary processes, such as predation, wildfire, floods, hurricanes, and other factors that select for genetic responses fundamental to genetic integrity, a large, protected area is our best bet for ensuring a reasonable chance of preserving genetic integrity.

CONSERVATION BIOLOGY

One of the essential values of conservation biology is preserving core populations and migration corridors. Placing the Greater Yellowstone Ecosystem under NPS management would likely enhance the prospect of sufficient representation of biological hot spots and critical corridors.

MANAGEMENT THAT IS CONSISTENT ACROSS BORDERS AND REGION

Currently, management responsibility of the Greater Yellowstone Ecosystem is fragmented among different administrators, including the Forest Service, Bureau of Land Management, National Wildlife Service, state lands departments, and Fish and Game agencies with variable missions. Consoling the Greater Yellowstone Ecosystem under one agency like the NPS would ensure equal and consistent ecosystem management.

CARBON STORAGE

Given climate change, One concern that is increasingly important is using natural landscapes for carbon storage. The Greater Yellowstone Ecosystem, as a unit, has tremendous potential for preserving carbon in soils, trees, and other vegetation.

MODEL OF HOW TO BEHAVE

Parks serve as “role models” of how people should interact with wildlife. Photo George Wuerthner 

National Parks consistently promote non-intrusive behaviors among visitors. Whether that is advising visitors to keep some distance from wildlife or even something as simple as not picking wildflowers. Leaving the landscape and wildlife unimpaired for future generations is a core value of NPS management. On a larger scale, wildland preservation is an expansion of justice beyond humans.

COUNTER TO THE ANTHROPOCENE MOVEMENT

There are increasing attacks on parks, Wilderness, and other preserves, such as colonialism, an offshoot of Western science, and other critiques. These are based primarily on progressive leftish politics that seeks to redress past and, in some cases, present injustices by denigrating anything that promotes consideration for other life as anti-human, racist, or simply imperialistic.

FORTRESS CONSERVATION

In line with this attack on wildlands protection is the idea that parks, wilderness areas, and other landscapes, aside from human exploitation, are a kind of “fortress conservation.” In the past, this idea was primarily concerned with creating conservation preserves in places like Africa with wardens who patrolled lands to capture or preclude intrusions from poachers, livestock intrusions, and loggers, which threatened the park’s integrity.

The critique from social justice advocates is that such parks disproportionally impact Indigenous populations who traditionally utilized these lands for survival. While there is some validity to this, particularly in the poorer regions of the world, it’s important to note that even poor people benefit from wildlands reserves by maintaining and providing clean water, clean air, carbon storage, biodiversity protection, and many other values that all humans require regardless of wealth and race.

Without wardens or parks, many valuable animals for human exploitation, such as elephants (tusks), gorillas, bears (gallbladders), and many others, would soon be extinct without strict protections. Fortress conservation is necessary in a world with exploding human population pressures.

There is no social justice on a dead planet. And Wildland reserves help to preserve planetary functions.

SPIRITUAL PRESERVATION

For many humans, wild landscapes have always been places for spiritual connection. Some see “God” in the natural world. John Muir, Henry David Thoreau, Rachel Carson,  to more recent scholars like Wallace Stegner, asserted, “Wilderness was the Geography of Hope. “Few find spiritual comfort in city streets, among factories, much less clearcuts, oil fields, and mines. Native Americans regularly claim that natural areas are essential to their spiritual traditions, as have many wildlands advocates. We should democratize this concept by preserving the Greater Yellowstone National Park, where everyone can discover their spiritual renewal.

SCIENTIFIC CONTROL

Wilderness and parks, while not immune from human influences (climate warming is a good example), nevertheless, they still provide a reasonable control where we can compare the manipulation of the landscape outside of these protected areas with places where human impact is reduced.

OBLIGATION TO THE PLANET

Protecting large landscapes by limiting and reducing human intrusions and exploitation is one way that all of us can pay our “obligation” to the planet that has sustained us. Setting aside landscapes like the Greater Yellowstone Ecosystem as a conservation model promotes a worldview that sees the Earth as more than a “cookie jar” for human consumption.

NATIONAL PARKS ARE AMERICA’S BEST IDEA

Increasingly, social justice advocates argue that the moniker that parks are America’s best idea is a myth. Yes, parks have not created social equity any more than the Civil Rights Act did, but both are a step toward that goal. Parks are among our most democratic institutions. They are even better than other institutions because they recognize more than humans having value worthy of “rights.”

HOW TO IMPLEMENT A GREATER YELLOWSTONE ECOSYSTEM

The first step in any political conservation concept is to lay out the vision. Only then can one begin to strategize how to implement it.

A national monument could be established on lands outside the existing national park boundaries, encompassing the entire ecosystem. National Monuments can be created by Presidential decree. Many national monuments are later codified by Congressional action as national parks.

However, independent of these west-wide proposals, legislation is the most secure way to expand Yellowstone’s borders to encapsulate Greater Yellowstone.

This change will not happen overnight. In the 1930s, Bob Marshall proposed that everything north of the Yukon River in Alaska should be preserved as one great wilderness national park. Marshall’s vision has not yet been fully realized. However, a review of a map of Alaska north of the Yukon River will show that most of the landscape is now in some protected category. You have the Koyukuk NWR, Selawik NWR, Kobuk Valley NP, Cape Krusenstern NM, Yukon Flats NWR, Kanuti NWR, Gates of the Arctic NP, Arctic Wildlife Refuge, Noatak Preserve, among other designations.

The first step in any campaign is to articulate the idea. That is what I have tried to do here.

WHAT YOU CAN DO

Write your Congressional Representatives to support NREPA. Passage of this legislation would be a significant step towards preserving the Greater Yellowstone Ecosystem and the entire Northern Rockies.

Write Sec. of Interior Haaland and urge her and the Biden Administration to support the Greater Yellowstone Preservation Campaign. Biden could declare the entire area a national monument under NPS management. It would go a long way towards helping his administration reach its 30 x 30 goals.

We should leave the Greater Yellowstone Ecosystem more intact than we found it, and we have an obligation to ensure that future Generations and the lands’ wildlife and plant life are enhanced and increased.

Thinning the forest is often less effective than eliminating human sources of ignition. Photo George Wuerthner 

The Deschutes National Forest wildfire policies are misdirected towards logging while ignoring the real threats that could lead to blazes on Bend’s doorstep.

Anyone driving around the national forest near Bend will note the abundance of homeless camps, RVs, campers, and people scattered along forest roads. Each one of these individuals is a potential source of ignition.

Dispersed camping along forest roads is a potential source of ignition. Photo George Wuerthner 

Instead of dealing with the often-illegal camping and increased likelihood of a human ignition, the Forest Service spends its funds logging the forest in a delusional effort to reduce wildfires.

HUMAINS AND WILDFIRES

Human-started wildfires accounted for 84% of all wildfires between 1988-2012, tripled the length of the fire season, dominated an area seven times greater than that affected by lightning fires, and were responsible for nearly half of all areas burned. More recent studies put the figure of human-caused wildfires even higher.

The further problem is that humans create ignitions when fuels are sufficiently dry enough to ignite and carry fire but when lightning is rare, as is often the case in Central Oregon. In other words, humans expand the fire season and occurrence of wildfire.

Most human-caused blazes are along forest roads. Photo George Wuerthner

Of these human-caused wildfires, 95% occurred within ½ mile of a road. Roads put more people in the forest matrix where everything from an untended campfire to grass fires from hot exhaust pipes can ignite the woods.

FOREST MANAGEMENT IS DELUSIONAL

Thinning and prescribed burns are ineffective at halting or even slowing most fires burning under extreme fire weather conditions defined as drought, high temperatures, low humidity, and high winds.

Winds blow embers over and around thinned forests. Indeed, thinning and prescribed burns may even increase fire spread. Thinning opens the forest stands to greater drying and greater wind penetration.

And prescribed burning favors the regrowth of fine fuels like grasses, shrubs, and small trees that are the primary “fuel” in wildfire spread.

Google Earth photo shows the failure of “active forest management” under extreme fire conditions to halt the 2021 Holiday Farm blaze along the McKenzie River, Oregon.  

Many studies document the failure of “fuel reductions” in halting fires. But anyone can travel down the McKenzie River to see how the 2021 Holiday Farm Fire raced through a heavily logged landscape.

The failure of “active forest management,” i.e., logging to alter wildfire outcomes, is one reason why more than 200 scientists wrote a letter to Congress: “Removing trees can alter a forest’s microclimate, and can often increase fire intensity. In contrast, forests protected from logging, and those with high carbon biomass and carbon storage, more often burn at equal or lower intensities when fires do occur.”

Various studies have also shown that the probability that a wildfire will actually encounter a “fuel reduction” site is extremely small-typically less than 1%.

What are the implications and relationship to Deschutes NF policies?

COMMUNITY HARDENING

One of the most effective ways to ensure a structure survives wildfire is known as “home hardening.” Home hardening means eliminating the potential sources of ignition like wooden roofs and decks, removing flammable vegetation immediately adjacent to the home and other fire-wise measures.

But communities can create their own “community hardening” by removing the source of ignitions near the town.

An example of an ineffective  “closed temporary road” used for thinning on the Deschutes National Forest. Roads are one of the main vectors for human access to the forest-hence effective road closures are one way to reduce human igntions. Photo George Wuerthner

Closing and removing forest service roads would significantly reduce the likelihood of human ignition.

Second, the Forest Service could enforce camping limitations on the forest. In most places, dispersed camping for more than 14 days is illegal. Yet virtual villages have sprouted in the woods with year-round residency.

The agency could ban dispersed camping within ten miles or so of town. Just as removing ignition sources near a house, eliminating sources near a town can significantly reduce the likelihood of a blaze. It might not eradicate human ignitions, but any blaze that did start would have to travel further to threaten homes, giving firefighters time to intervene.

Instead of funding “fuel reduction” in the backcountry, the FS could spend its funds eliminating the sources of ignition. Such policy changes would be a far more effective and economical means of protecting our communities.

Livestock grazing negatively impacts more public lands in the West than any other industry. Photo George Wuerhner 

Legislation that would have given the federal government authority to close grazing privileges on public lands was recently withdrawn.

Grazing permit buyouts allow the federal government to close public lands to future livestock grazing permanently.

New Mexico’s U.S. Senator Martin Heinrich introduced and sponsored the Wildlife-Livestock Conflict Resolution Act that would have applied only to New Mexico, but still has implications to national efforts to remove livestock from public lands. After significant pushback from the livestock community, Heinrich has decided to shelve the legislation for now.

Fortunately national permit retirement legislation, the VGPRA (Smith/Huffman)  is still waiting for Congresional action.

Many see buyouts as a “win-win” for the rancher and the public. In exchange for a pre-determined amount of money, private foundations and individuals can pay a rancher to relinquish their grazing privileges to public land allotments voluntarily. At the same time, the federal government permanently closes the allotment to future grazing.

Domestic sheep were removed by grazing permit reirement in the a portion of the Upper Green River area of Wyoming seen here, but the Bridger Teton Nationa Forest wants to reopen the allotment to cattle grazing. Photo George Wuerthner 

One of the benefits of federal legislation is that it makes any agreement permanent. Without permanence, federal agencies sometimes try to restock the allotments with livestock, as proposed for the Upper Green River area of Wyoming.

It’s important to note that grazing on public lands is a privilege. The federal government can close an allotment at any time for any reason. However, due to the political influence of the livestock industry, permanently retiring a grazing allotment is often tricky, even if a rancher agrees to relinquish their grazing privileges.

Legislation that created the Boulder White Cloud Wilderness areas in Idaho contained language for voluntary grazing permit retirement. Photo George Wuerthner 

For instance, livestock permits in Idaho were retired as part of the legislation passed to establish the Boulder-White Cloud Wilderness. Similar retirement of grazing privileges successfully closed several allotments on Steens Mountain in Oregon with the passage of the Steens Mountain Cooperative Management and Protection Act.

There are many advantages to grazing permit retirement for the public. Livestock grazing has the biggest negative impact on public lands across the arid West. For more on these impacts, read my book Welfare Ranching.

Livestock grazing is one of the most significant factors in species endangerment in the West.

Wolves are regularly killed to appease ranchers grazing on public lands. Grazing permit retirement could reduce these conflicts. Photo George Wuerthner 

It is the reason we are killing wolves, coyotes, and other native predators on public lands is to protect private livestock using public lands.

Grazing is also the number one factor in destroying the thin green lines of vegetation along waterways are crucial to 70-80% of the wildlife in the West.

Livestock grazing also spreads weeds by trampling biocrusts and consuming native grasses, giving exotic species like cheatgrass a competitive advantage.

Livestock manure is a major source of non-point pollution on public lands. Photo George Wuerthner 

Livestock manure is also one of the significant sources of water pollution on much of the federal lands.

Livestock can also transmit diseases to wildlife, such as pneumonia, from domestic sheep to wild bighorns.

Removing livestock from wilderness areas and parks also increases the natural integrity of these areas. For instance, WildEarth Guardians had agreed to buy out Taos County rancher Erminio Martinez’s permit in the Columbine-Hondo Wilderness. However, without the permanence guaranteed by Heinrich’s legislation, the deal might not go through.

Unfortunately for Heinrich and U.S. citizens who own these public lands, opposition from the New Mexico Association of Conservation Districts, the New Mexico Farm and Livestock Bureau, and individual ranchers scuttled the bill.

Nevertheless, many individual ranchers see permit retirement buyouts as a way to sustain existing ranch operations. With money from a buyout, a rancher could purchase other private lands, pay off mortgages and other debt and otherwise realign their economic priorities.

Heinrich’s decision not to reintroduce his legislation is a significant loss to the public.  Private domestic animals raised on public lands for private profit will continue to trash and degrade public lands and wildlife resources.

Cow hammered spring and riparian area in Idaho. Permit retirement could reduce such damage. Photo George Wuerthner 

There is other legislation that includes grazing permit buyouts as part of the package. One is the Northern Rockies Ecosystem Protection Act, sponsored by the Alliance for Wild Rockies which would protect nearly 23 million acres.

You can help WildEarth Guardians persuade Senator Heinrich to reintroduce his legislation here.

Among the organizations promoting livestock grazing permit retirement are Western Watersheds Project, the Center for Biological Diversity, Gallatin Wildlife Association, Oregon Natural Desert Association,  Alliance for Wild Rockies, Southern Utah Wilderness Alliance, Wilderness Watch, Great Old Broads For Wilderness, and the Sagebrush Habitat Conservation Fund. Supporting all these organizations can further the permit buyout option.

The burnt-out Safeway Store in Paradise, California. Even a big parking lot with no fuel could not prevent the loss of this structure due to wind-blown embers. Photo George Wuerthner 

A new report from Headwaters Economics titled: “Missing the Mark: Effectiveness and Funding in Community Wildfire Risk Reduction” is right on target when it comes to home and community fire issues, but misses the mark in many ways regarding wildfire ecology and firefighting.

I rely on Headwaters Economics for their good solid economic analysis, but when they stray into other areas, sometimes they, too, need to catch up.

In some ways, I hate to critique the report because there is much value in Missing the Mark report when they sick to home hardening and zoning issues, but the paper also supports what I consider misinformation about wildfire. They are heading in the right direction but frequently need help understanding the nuance of wildfire ecology.

The report has some critical and sound advice about home hardening and other effective ways of reducing the vulnerability of homes to wildfire. They argue that the Forest Service budget is disproportionally aimed at logging as a “solution” to wildfire.

As more and more homes are built in the Wildlands Urban Interface, we see more wildfires resulting from down power lines. Photo George Wuerthner 

The central theme of their report is that federal dollars should be spent on assisting communities and homeowners to reduce the flammability of their homes, not logging the backcountry.

However, the report also champions more logging to reduce fires, using biomass burners to consume the wood from thinning projects. It fails to consider the collateral damage (including the economic costs) of current Forest Service management. It suggests that NEPA reform may be needed to “speed” logging projects.

Sanitized and degraded forest ecosystem resulting from thinning project on Deschutes National Forest, Oregon. Note the lack of ground cover, few snags, and no down wood on forest floor–usually found in “healthy forest ecosystems.” Photo George Wuerthner 

One of the things I did immediately was to read the acknowledgments list of people interviewed. There was a firm reliance on pro-logging advocates and government officials from the research sector (almost all funded by the Forest Service) Forest Service and state forestry employees.

I also reviewed the list of references, and again, they are overwhelmingly studies paid for and often by agency scientists. I was surprised that few papers were referenced by scientists who question the dominant paradigm.

Using members of the agencies as your major sources of information is as disingenuous as relying on the coal industry as an authority on climate change. Sinclair Lewis said, “It is difficult to get a man to understand something when his salary depends on his not understanding it.”

I also looked up the two authors’ backgrounds. Though both have impressive resumes: Dr. Barrett’s research has focused on the true cost of wildfires, the cost of building wildfire-resistant homes, and measuring wildfire impacts through structure loss, while Dr. Dale from the Columbia University Climate School specializes in sustainability. They do an excellent job on those parts of the report.

Yet from what I can tell from their bios, they have little background or experience with wildfire/forest ecology and on-the-ground observations of the numerous failures of logging as a project prescription. This may explain why they support more harmful Forest Service activities like thinning and biomass burning.

The report focuses on reducing the risk of wildfire to communities, and in many ways, the information does an excellent job of advocating working from home outwards to reduce vulnerability to wildfires.

As the authors conclude: “the most effective policies for reducing community wildfire risk tend to be those that “manage the built environment, including mandated building codes and home hardening.” They note that such programs are underfunded, while efforts to suppress wildfires get almost unlimited federal and state financial support.

This is a message that I and others have been harping upon for years, so it’s good to see that the Headwaters report confirms and emphasizes that theme.

Prescribed burning has limited applicability as a landscape influence on wildfire. Far too much emphasis is given to the notion that if we only did more prescribed burning we would not have large blazes. Wind-driven embers regularly fly over and around such “fuel reductions.” Photo George Wuerthner 

However, a chart on page five points to prescribed burning as “highly effective” at protecting communities. That assertion is questionable for a host of reasons I have described elsewhere. But the chief reason is that wind-blown embers burn down homes.

Under extreme fire weather conditions, embers can be lofted several miles easily, flying over and around any prescribed burn effort. They acknowledge how embers are the main problem elsewhere in the paper but don’t always connect the dots. More on this later.

I was delighted to see the author acknowledge the role of wildfire in ecosystems and that suppression is not conducive to effective fire management or ecosystem health. Furthermore, they note that climate change is the dominant force “fueling” larger blazes.  On page nine, they have an entire paragraph on the numerous ecological benefits of wildfire.

The report notes: “So effective are these initial attack efforts that more than 99% of fires are suppressed before they exceed one acre in size. The large, damaging, and expensive fires that evade suppression make the news, but they represent a tiny fraction of the total.”

What the report fails to note (and what most fire authorities seem to miss) is that if you don’t have the right conditions for wildfire ignition and spread, wildfires self-extinguish without any suppression—usually burning less than 1 acre.

Graph showing wildfire acreage charred in Yellowstone NP. Note that long before there was “fire suppression” there were large blazes. 

In other words, fire suppression isn’t that effective because the fires are put out by agencies, rather the weather/climate largely controls the acreage charred. Even if firefighters left them alone, most would go out without human effort. On the other hand, when you have extreme fire weather, wildfires cannot be controlled.

And here is where the report starts to mimic Forest Service propaganda. “Without regular intervals of fire, many fire-dependent ecosystems become overly dense with woody biomass, creating flammable conditions that then contribute to more intense, larger wildfires when one inevitably escapes initial attack.”

Charred fir forest in the Bootleg Fire, Oregon. The vast majority of plant communities in the West tend to burn at mixed to high severity. Photo George Wuerthner 

However, not all scientists agree that the frequent fire/low severity models apply to most plant communities in the West. A critical paper discussing fire ecology and, by implication, fire policy was published in the Journal Fire.

The paper’s title: “Countering Omitted Evidence of Variable Historical Forests and Fire Regime in Western USA Dry Forests: The Low-Severity-Fire Model Rejected,” hints at the paper’s substance. The authors assert their research concludes that there is “a broad pattern of scientific misrepresentations and omissions by government forest and wildfire scientists.”

And this is where an understanding of ecology by someone with some wildfire ecology experience might have been helpful to the report. The authors repeat the misinterpretation of wildfire promoted by the timber industry, the Forest Service, and many FS researchers to justify human landscape manipulation.

While some ponderosa pine stands historically burned at frequent intervals that reduced fuels, and today have higher density and are burning more intensely than in the past, this does not apply to most plant communities in the West. Indeed, it doesn’t even apply to many ponderosa pine stands.

Nearly all the fire-dependent plant communities in the West, including aspen, sagebrush, juniper, fir, spruce, hemlocks, cedars, and even many pines, have very long intervals between wildfires of decades to centuries. They are not “overly dense” and naturally accumulate biomass over time, thus burning as “intense, large wildfires.” Even if it were practical, fire suppression has had little influence on these plant communities.

In other words, most wildfires in the West are burning at absolutely normal conditions under their ecological regimes.

While the authors, one of whom is a professor at the Columbia Climate School, acknowledge the role of current warming climate in fire spread, they need to recognize that climate has greatly influenced past wildfire occurrences.

Note the mid-century lack of large fires due to cool, moist climate conditions resulting from Pacific Decadal Osillation not fire suppresssion as commonly asserted. 

Between the late 1930s, when the Forest Service initiated its 10 AM policy, and the more recent decades starting in the late 1980s, the Pacific Decadal Oscillation brought cool, moist conditions to the West. Glaciers were even growing in the PNW at this time. And this is when the FS fire suppression was “effective.

Since the late 1980s, the climate has warmed considerably, and warmer temperatures, lower humidity, extensive drought, and high winds are the main factors contributing to large blazes, not fire suppression.

The long-term upward trend in temperature and vapor pressure deficit is also making droughts more severe, including the Western megadrought of the past 23 years, as hot and dry conditions pull more moisture from the landscape.

Dried up Lake Powell in Utah as a result of severe drought. Photo George Wuerthner 

Given that many parts of the West are experiencing the most severe drought in a thousand years, it’s unsurprising that such severe droughts, combined with warmer temperatures, are the driving force in large blazes, not alleged fire suppression.

However, when they stick to economics, the report has much value. For instance, they note that 50-90% of federal firefighting dollars go towards protecting private homes. Rural governments continue to permit home construction in the Wildland Lands Interface, the authors note that these costs will increase. As they point out, these costs should be a private or state responsibility. But instead, all US taxpayers are subsidizing home construction in fire-prone areas.

To their credit, the authors discuss the Fire Industrial Complex, a topic covered at great length in my book Wildfire: A Century of Failed Forest Policy.

As the authors correctly note: “Institutional path dependency traps firefighting agencies in an endless pattern of buying new planes for aerial suppression, deploying those aircraft to fight fire even in unacceptably dangerous conditions,34 and feeding public expectations for “performative firefighting”35 that may calm political nerves but ultimately fail to address the long-term threat wildfire poses to communities.”

One Forest Service official cynically noted that people love the “air show” even though most fires are nearly out when you can get planes dropping fire retardants.

The authors discuss “managed wildfire,” or allowing fires that do not pose a risk to homes to burn. One of the barriers they correctly identified is that promotion within the Forest Service and other agencies is based on “acres treated,” and managed wildfire does not count towards those totals. In other words, you get promoted if you log the forest but not if you allow wildfires to play their natural role in plant communities.

MISSING THE MARK

Headwaters misses the mark more than in any other part of the report under their section on managing fires. The authors perpetuate the Industrial Forestry paradigm by suggesting: “Even in the absence of fire, reducing fuels may contribute to healthier forests and better habitat for wildlife.”

This ignores that what constitutes a “healthy” forest ecosystem is primarily based on timber industry ideas that limit mortality to chainsaw medicine.

Thinning and logging are ineffective at influencing wildfire under extreme fire weather. Here a thinned forest stand by Chester California did nothing to halt the 2021 wind-driven Dixie Fire. Photo George Wuerthner 

Again demonstrating a poor understanding of wildfire behavior, the authors mimic the Forest Service in claiming that mechanical treatment (euphemism for logging) The authors contend that “Mechanical treatments are moderately effective at reducing fire severity, reducing the likelihood of crown fire, slowing the rate of spread, and moderating surface fire behavior.”

They don’t acknowledge the many qualifications that should accompany such a statement. The most important is that logging, prescribed burning, etc., have never worked at a landscape scale to reduce wildfires under wind-driven “extreme fire weather.”

If these authors had spent real time on the ground looking at large blazes across the West instead of relying on FS “research,” they would have noted that nearly all large fires burn through existing thinned and prescribed burn areas and that fuel treatment has failed repeatedly.

Area thinned “prior” to Millie Fire by Sisters, Oregon, did little to halt the blaze. It was a change in wind direction that “saved’ the town of Sisters. Photo George Wuerthner 

When some logging advocates suggest otherwise, you must look at the fine print. For instance, the Deschutes National Forest regularly promotes the Millie Fire as an example of how thinning “saved” Sisters Oregon from wildfire. Even though the Millie Fire charred areas that had been thinned and burned through two previous wildfires, the agency claims that thinning halted the fire’s march toward Sister.  However, if you look closely at the daily weather during the fire, a wind change drove the fire away from Sisters. This is frequently true when logging advocates suggest fuel reductions worked under extreme fire weather. (BTW, the agency has since removed the weather data on the Millie Fire from its website).

Map showing the pathway of the 2021 Holiday Farm Fire that burned down the McKenzie River in Oregon and Google Earth photo of clearcuts of the same area. 

Another excellent example of how logging failed to protect communities was the Holiday Farm Fire which charred hundreds of thousands of acres along the McKenzie River in Oregon. The blaze raced through FS and industrial timber lands marked by clearcuts.

The Camp Fire burned through Paradise, California despite the fact that the town was surrounded by clearcuts, previous “fuel reduction” logging, and several past blazes–all of which failed to preclude the loss of homes. Photo George Wuerthner 

The same is true for the Camp Fire that consumed Paradise, the Dixie Fire that destroyed Greenville, California, and many other examples, I could give.

Why is this important? Because all large fire burn under such conditions. Logging may alter fire under low to moderate conditions is irrelevant since most of these fires will burn out without any suppression, and they don’t burn hundreds of thousands of acres like wind-driven blazes.

Fortunately, the authors do recognize the inefficiency of fuel treatments. They report that the “influence of mechanical treatments on fire behavior is almost entirely ecological, short term, and localized.” They acknowledge that “Fuels-reduction projects can contribute to risk reduction in small, localized settings but do not offer a path to resolution of wildfire risk across the West. detrimental

But then one must wonder why to mention it at all.

Page 15 is one of the most troubling aspects of the report. Under barriers to “treatment” (they assume more fuel reductions is a good thing), they note that the National Environmental Policy Act (NEPA) is a problem because it slows the agency’s logging agenda.

Like PERC, Senator Daines, and other logging proponents, they complain that: “Litigation itself can derail projects, adding additional delays to implementation or blocking them entirely.” Instead of hiring foresters to treat fuels, land management agencies are forced to hire lawyers and analysts to navigate NEPA.”

Although they don’t specifically mention the Cottonwood Decision, they seem to condemn this as an unnecessary barrier because it requires NEPA analysis for thinning projects.

This is followed in the next segment by bemoaning that universities have shifted the emphasis of their programs as if this is a detrimental strategy. They say: “For example, many universities have re-configured their traditional forestry programs to meet better academic demand for popular but less forestry-focused environmental studies programs.”

This emphasis on speeding up logging implementation demonstrates that the authors must fully grasp the fire and ecological literature. If they did, they would recognize that in nearly all cases, logging has collateral environmental damage, including the spread of weeds, sediment in streams, disturbance to wildlife, impacts on water quality, loss of biomass (wildlife habitat to me), reduction in carbon storage, among others.

These are real ecological and economic costs of logging, and at the least, one would want the agencies to articulate these costs in a NEPA document.

Then the report goes on to repeat another myth. That logging the forest is profitable. Maybe for the timber companies subsidized in numerous economic and ecological ways, but certainly not for taxpayers. I unaware of any national forest in the country that makes a “profit” on timber sales—only the appearance of such because of false accounting, such as suggesting logging roads are a positive benefit because some people drive them for recreation or the failure to include all costs such the office rent, electrical power for computers, and the salaries of secretaries, other resource specialists, and personnel necessary to operate and implement a timber sale.

A report from Headwaters Economics should be aware of these accounting discrepancies.

TREATING THE HOME

Only when the authors focus on treating the home instead of the forest do they positively contribute to the fire discussion. As many have recognized for years, it is the treatment of the house that is both the most efficient and effective means of reducing home ignitions.

PRESCRIBED BURNING ADVOCATED

The report has a long section on prescribed burns, where fires are intentionally set under specific conditions that hopefully will not lead to a run-away blaze.

Research has shown that Indian burning had mostly localized influence on the landscape, and even with such activities there were always large blazes as a consequence of climate/weather. 

Many officials, politicians, and journalists have latched on to Native American prescribe burning as the solution to major wildfires. Much of this is part of a social justice agenda that seeks to legitimize Native American cultural burning as a forgotten “wisdom” that “kept forests healthy and less fire-prone.

Without getting into this too much, the bottom line is that numerous studies have concluded that Indian burning was primarily localized and did not influence the larger landscape. Paleo fire evidence shows that large wildfires always existed despite tribal burns and that the climate then, as now, was the controlling factor in large blazes.

 Snags from the 3 million acre plus 1910 “Big Burn” remain on a ridge line along the Idaho-Montana divide. No one can say that fire suppression created “excess” fuel for this blaze. Photo George Wuerthner

For instance, the 1910 “Big Burn” charred more than 3-3.5 million acres of Idaho and Montana long before anyone can suggest “fire suppression” had influenced fuels.

While advocating for a significant increase in prescribed burning, the authors provide numerous reasons why this is not really a panacea.

They admit that such burns are typically localized and don’t affect the larger landscape. And they also note that many plant communities like sagebrush, jumper, and chaparral did not frequently burn. Thus, prescribed burns in these ecosystems are inappropriate.

An additional problem they acknowledge is that the most effective location for prescribed burns is adjacent to homes and communities. However, this often leads to public opposition due to fears that fires may escape and char structures.

Smoke is yet another issue since ideally prescribed burns are conducted when fuels are somewhat moist, leading to less than complete combustion, more smoke, and a higher percentage of particles that are unhealthy to breathe.

While smoke from a large wildfire may influence community members more, one must remember that most thinning and prescribed burn treatments never encounter a fire, so you wind up with the negatives like smoke without any benefits. Plus, wildfire smoke travels hundreds of miles from the source, so even if you reduce fuels in the immediate area around the town, it may not affect the smoke you breathe during fire season.

It may be a reasonable gamble for most people to argue against repeated prescribed burns when the chances that a large wildfire will occur in that location are nearly zero.

In addition, prescribed burns may give homeowners a false sense of security. Given that, most of all large blazes and home ignitions result from flying embers that are lofted over and around any fuel reduction treatment; it casts doubt that even a massive increase in prescribed burning will protect homes.

A final barrier to a significant increase in prescribed burning is the narrow “window” for any controlled blaze. The fuel must be dry enough to ignite but not too dry to be explosive. You must consider factors like variability in the wind, which can blow up a burn into a major blaze.

One large wildfire consumes more biomass and affects far more acreage than thousands of prescribed burns. The focus on prescribed burning is a distraction. As one commentary explains, prescribed burning the watering can that pretends to be a hose-it simply will never influence enough landscape to make any significant difference in acreage burned.

This brings one back to the issue of the most effective and economical way to protect homes—managing the built environment and home hardening is the answer. And this is where the report is right on target.

A burning structure provides far more heat than a major wildfire. Wind-driven wildfires are like a tsunami. They offer a scorching but short tidal wave of heat. Most wooden walls can survive up to 20 minutes without ignition, and the house will survive if there is nothing adjacent to the home to ignite.

However, even if you harden your home to survive a wildfire, if your neighbor does not and their home ignites, the heat from a burning structure lasts longer and emits far more heat, often leading to the ignition of adjacent homes.

COMMUNITY STANDARDS NEEDED

Focusing on the home and town is one reason why community-wide fire-wise standards are critical. Zoning and construction with fire-resistance materials are among the most effective ways to reduce the cost of wildfire protection. For instance, in 2008, California mandated that all new homes be constructed with fire-resistant materials. A recent study found that new homes were 40% more likely to survive a blaze than older structures.

But as the authors correctly note, the idea of uniform building codes and standards is anathema in much of the rural West, where most vulnerable structures are located.

Funding for retrofitting homes is nearly nonexistent, even though such home hardening is the most effective and efficient means of reducing community vulnerability.

But even if hardened, homeowners must think outside of the box. The cause of home loss in one fire near Los Angeles was attributed to “doggie doors,” designed to swing open. During the windy conditions that characterize major blazes, embers could enter homes through these doors.

THEIR CONCLUSIONS

The report hits the mark and contributes to the wildfire policy discussion on issues related to community protection. The authors assert: “managing the built environment through home hardening and requiring those actions through robust and mandatory statewide building codes emerges here as by far the most effective tool for reducing wildfire risk.”

Their recommendations are for greater development of home hardening programs and for Congress to modify USFS budgets to support communities in implementing home hardening. The final recommendations for states and communities are right on the mark.

If you disregard most of the sections that promote thinning and burning as a strategy, the report has many worthwhile recommendations. I endorse the information with the above limitations.

Harsh winter weather forces bison to seek forage outside of Yellowstone National Park where tribal people slaughter them. Photo George Wuerthner 

https://helenair.com/outdoors/buffalo-field-campaign-yellowstone-national-park-bison/article_613ca670-2fbf-501c-b7a4-987bcff200ac.html#tracking-source=home-top-story

A press release from the Buffalo Field Campaign described a proposal for the tribes to develop a  plan to assume “primary jurisdiction” over Yellowstone National Park’s bison.

The first question anyone should ask is why any group, especially one based on a racial preference, should be given control of public wildlife. The announcement also mentioned that the tribes want control over wolves and grizzlies.

Yellowstone bison are unique. They are the least “domesticated” of all bison in the United States. Photo George Wuerthner 

The Yellowstone bison do not belong to the tribes. Wildlife is held in trust as part of the Public Trust Doctrine, and there is no reason why tribes should be given any greater authority or influence than any other American citizens. All tribal members are U.S. citizens and share the same access to public comment and influence as all other Americans.

The tribes and BFC are using bison as a pretext to further tribal interests and control of public lands and wildlife. The bison are pawns in this effort. Make no mistake. BFC is not concerned about bison welfare but tribal welfare.

A bison killed by tribal hunters outside of Yellowstone NP. Photo George Wuerthner

These public lands are part of our democratic heritage that belongs to all citizens, and I would suggest they are a global heritage that belongs to no one. They are under increasing threat from well-meaning people who see the public domain as political chips of the social justice movement.

We already know what happens when you give legal or otherwise concede authority to any interest group–ranchers, miners, loggers, ATVers, etc., all have undue influence over public land management. We do not need yet another group that will have greater control of what is a public resource.

This clearcut is on a tribal reservation. Indians are no different than the rest of humanity, they often put self interest first.  Photo George Wuerthner 

Most tribes do not manage their lands or wildlife in an exemplary fashion. When money is to be made, they act like all other humans-they put their self-interest first.

BFC advocacy for bison restoration is a subterfuge for expanding tribal power over public resources. One doesn’t need jurisdiction over bison to advocate for bison well-being. To see footage of recent tribal bison slaughter view this video from Yellowstone Voices.

BFC calls for the expansion of bison on public lands. On the surface, I certainly agree with the goal of bison restoration on public lands. But this goal should be for what is appropriate for wild bison, not what is good for the tribes. The Wild Bison Collition calls for bison restoration on the Charles M. Russell National Wildlife Refuge. Tribal members can support such policies, without assuming  “primary jurisdiction” over bison to promote bison restoration

Bison carcasses as evidence of tribal bison slaughter along road near Gardiner, Montana

The Buffalo Field Campaign letter talks about cultural restoration. Should public wildlife be managed and used for cultural purposes? Suppose culture is a valid reason for killing wildlife. In that case, the killing of elephants in Africa, the clubbing of seals by Newfoundlander fishermen, or the slaughter of whales by Japanese whalers, all cultural traditions in their countries, are equally valid.

Culture is not science; our wildlife should be managed on scientific principles, not religion or cultural justifications.

The BFC argues that the tribes should manage public bison using “traditional ecological knowledge.” Was the slaughter of more than a thousand bison outside Yellowstone Park this past winter an example of traditional ecological knowledge?

Remember that tribal hide hunting in the 1800s was responsible for the extirpation of bison in many parts of the West long before the final coup de grace resulting from commercial bison hunters in the 1870s. Indian hunting wiped out bison in Utah, Idaho, western Wyoming, western and southwestern Montana, North Dakota, Manitoba, and Minnesota by the 1850s.

This was long before most of these areas had any white settlement or commercial hide hunting, which did not begin in any effective manner until after the Civil War when railroads penetrated the West, enabling the transportation of heavy hides to the East.

Because tribal people believed that bison annually repopulated the plains from a hole in the ground each spring, they could not conceive of overkill. Superstition and religion guided their relationship with bison, and hunting success would continue if one did the correct dance and followed the proper procedures.

Do we really want superstition and religion to guide wildlife policy in the United States? I would suggest this is a grave step backward.

Plenty of other evidence exists for tribal ecological impacts, notwithstanding “traditional ecological knowledge.” Tribal people are like the rest of the human race, and prone to over-exploitation of natural resources—if and when they can.

For instance, Mayan deforestation led to a significant decline in soil carbon in Central America, Indian exploitation of sturgeon led to a reduction in population, California tribes reduced the apparent distribution and numbers of elk, and paleo hunters are often one of the factors that drove some Pleistocene extinctions. Even today, Indigenous hunting of beluga whales in Cook Inlet is cited as a significant contributing factor in the whales’ decline from 1300 in the 1970s to less than 300 animals today, among many other examples I could mention. Obviously “traditional ecological knowledge” doesn’t preclude over-exploitation of the land.

Buffalo Field Campaign (BFC) has repeatedly demonstrated that it does not put the bison first; it puts tribal interest first.

Yellowstone bison are unique. They are not like most other bison in the West. They are the least domesticated animals we have. The tribes do not concern themselves with wildness. Indeed, all tribal herds are domesticated animals and treated like livestock.

Coyotes feisting on a bison carcass. When tribal hunters remove bison from the ecosystem, they are literally taking the food out of the mouth of numerous dependent wildlife from wolves to grizzlies to ravens and coyotes. Photo George Wuerthner 

BFC has ignored the numerous ecological impacts of tribal bison slaughter by Gardiner, Montana, to promote tribal interests. The tribal massacre this winter removed biomass from the park ecosystem that would have sustained bears, wolves, and other wildlife. It reduced the population dangerously low with genetic implications, a reduction in bison numbers exacerbated by bison being tournament breeders, and one male can impregnate a dozen or more females, significantly reducing genetic diversity.  It selectively killed the very animals that are most likely to migrate. Tribal slaughter altered the age and sex structure of the herds since, under “natural” conditions, the young and old are the animals that naturally suffer mortality. (All removals have the same influence, including the capture and slaughter by NPS or Dept of Livestock).

Bison herd on a private ranch in Montana. Nearly all bison outside of Yellowstone are managed more or less like domestic livestock. Photo George Wuerthner

Remember that of the nearly 500,000 bison found outside of Yellowstone, all are “farmed” like other livestock. The Yellowstone bison are a tiny and unique subset of bison.

Imagine if nearly the salmon in the West were raised in hatcheries and you only had less than 1% of wild fish. Would we permit killing 25% of this small number of “wild” salmon? Yet this is precisely what the BFC advocates.

That is precisely what the BFC and tribes say is OK for “cultural” reasons.

Tribes use modern technology to assit in the bison slaughter. Use of a crane for gutting bison killed. Is this how you preserve “culture?” Photo George Wuerthner 

And as far as preserving “culture” is concerned, there is far more to culture than merely killing animals. Using modern weapons, trucks, ATVs, drones, etc., negates any claim that you are preserving “culture.” All you are preserving is killing. And you don’t have to kill Yellowstone wild bison if killing a bison is your goal. There are plenty of farmed buffalo on private ranches, tribal lands, etc. that are available for slaughter.

Regarding treaties, none of the tribes in the West have a legal right to hunt bison by Yellowstone. The so-called treaty rights put forth by tribal advocates extract clauses from the treaties and legal decisions without including the entire phrase or the limitations.

Tribal proponents extract clauses from various treaties, taking them out of context to seemingly give tribes the right to hunt any place on so-called “open and unoccupied” public lands (FS and BLM). These rights are limited to “ceded lands.” There are no tribal ceded lands anywhere in SW Montana, much less near Gardiner, immediately adjacent to Yellowstone.

Some tribes in the Columbia Basin were given the right to fish at selective locations like waterfalls where tribal people customarily sought salmon off reservations. Still, this right does not apply to hunting.

Furthermore, even this is restricted by a court decision that asserts that any tribe claiming such a right must demonstrate “occupation” to the exclusion of other tribes. No tribe can make such a claim for hunting anyplace on public lands.

Finally, there was a Supreme Court decision led by none other than William O Douglas that says even in the places where treaty rights do give tribes legitimate rights to kill wildlife off of reservations; tribes cannot harm the survival of the species.

This landmark judgment on treaty rights held that the federal government may regulate treaty fishing rights in the interest of conservation, so long as the said regulation is reasonable and necessary as well as non-discriminatory against Native Americans [Puyallup Tribe v Washington Department of Fish and Game 391. The US. 392 (1968)]. This same legal argument could be used to halt the tribal killing of Yellowstone bison, which due to their unique wild history, makes them of huge conservation interest.

The problem is that few people or organizations are willing to challenge the tribes-witness the total lack of criticism and silence by almost all conservation groups like GYC of the excessive bison slaughter this winter. The tribes are exploiting this lack of critical oversight.

Wildlife is supposed to be managed by the Public Trust Doctrine.

We need wild bison. Yellowstone bison are unique and should be treated with greater respect and protection than they are receiving today. Photo George Wuerthner 

Wildlife is supposed to be managed as a public trust. We need more wild bison. Tribal interests are not the public interest.

Those interested in preserving wild bison should join the Wild Bison Coalition.

Livestock grazing in the Great Basin has increased cheatgrass, a highly flammable annual grass. Livestock advocates allege targeted grazing can reduce large wildfires. Photo George Wuerthner

A recent publication in the Journal of Rangeland Ecology and Management, “Evaluating the efficacy of targeted cattle grazing for fuel break creation and maintenance,” perpetuates the myth that livestock grazing effectively reduces large wildfires.

Cheatgrass invasion promotes wildfire that is destroying sagebrush steppe ecosystems of the West. Photo George Wuerhner 

Due primarily to climate change and the invasion of the highly flammable alien annual cheatgrass, rangeland In the Great Basin between 2001 and 2021 experienced 40 mega fires that burned across over 3.3 million ha. This change in community structure poses a threat to sagebrush dependent species like sage grouse, pygmy rabbit, and sage sparrow.

The livestock industry continues to ballyhoo grazing as a cost-effective means of containing range fires. Still, as with many self-serving claims by the livestock industry, these assertions ignore many problematic aspects of grazing, its impacts on the ecosystem, and the overall failure of such strategies as an effectual fire control agent.

PROBLEMS WITH THIS STUDY

First, the study compared targeted grazed sites with “nominally grazed controls.” The authors concluded that targeted grazing produced “no consistent adverse effects or trends in ecosystem health within the fuel break treatments.

In other words, there were no ungrazed control sites for comparison. Livestock grazing has been shown to have numerous impacts on rangelands. So finding no “adverse effects” to ecosystems that are adversely impacted by grazing, in general, is not reassuring.

After four years of study, the treatment areas showed little stategical difference from control sites in their ability to slow or halt wildfire. Cheatgrass’s and cheatgrass’s height, cover, and soil coverage were similar in treatments and control sites.

Three small fires did encounter the targeted grazing sites. These fires were suppressed with fire-fighters and air support. Firefighters’ positive anecdotal reports were “evidence” for the effectiveness of targeted grazing. That is hardly “unbiased” science.

The paper also outlines many of the problematic aspects of targeted grazing. It is expensive, and few ranchers will commit to it even if the forage is “free.”

A few years ago, I attended a BLM field trip in Idaho to look at targeted grazing and fire breaks. The BLM officials asked the ranchers in attendance if they would be willing to participate in targeted grazing, and without hesitation, all declined. The cost of transporting cows to a specific treatment area and confining cattle to the targeted area, either with electric fencing or cowboys, needed to make more economic sense to all ranching participants.

Another area for improvement with targeted grazing is that livestock tends to select perennial grasses for consumption over cheatgrass. As a result, if there are desirable native grasses, these tend to be consumed and eliminated first, growing over time to eliminate native plants and increase annual grass cover. All of the treatment areas in this study were heavily infested with cheatgrass.

EFFECTIVENESS OF FUEL BREAKS AND TARGETED GRAZING QUESTIONED

Fuel break in southern Idaho. A review found fuel breaks had many negative impacts on rangeland ecosystems including serving as vectors for cheatgrass invasion. Photo George Wuerthner 

One review of fuel breaks concluded that they (1) directly alter ecosystems, (2) create edges and edge effects, (3) serve as vectors for wildlife movement and plant invasions, (4) fragment otherwise contiguous sagebrush landscapes, thus have questionable utility if all ecological impacts are considered.

Targeted grazing advocates ignore that high winds are responsible for most large fires, and wind-blown embers regularly fly over or around any fuel treatment areas.

In other words, the very fires fuel treatments seek to reduce are the ones that extreme fire weather with its high winds cannot influence. A frequently cited paper about targeted grazing in Arizona admitted as much in the second to last paragraph, where it admitted that targeted grazing failed under extreme fire weather conditions.

WHY CHEATGRASS IS A CONCERN

Relict perrenial grass among nearly continuous cheatgrass. Such situations favor the spread of wildfire. Photo George Wuerhner

The plant in this study targeted for reduction was cheatgrass.

A nearly pure stand of cheatgrass surrounds native sagebrush in northern Nevada. Frequent fires promoted by cheatgrass eliminates sagebrush from the landscape. Photo George Wuerthner 

Cheatgrass, a highly flammable annual grass, has converted much of the West’s rangelands from perennial native plant communities into monocultures of annual grass. A paper looking at long term trends on BLM rangelands “found widespread increases in cover and production of annual grasses and forbs, declines in herbaceous perennial cover.” This is particularly true of the Great Basin regions of Nevada, southeast Oregon, southern Idaho, eastern California, and many parts of Utah.

This has numerous impacts on the ecological stability of rangeland ecosystems. Annual grasses, as the name implies, vary significantly in their yearly biomass production. In wet years they produce lots of grass but in drought years, only some. By contrast, native perennial grasses remain far more constant in overall forage production.

Cheatgrass is also less palatable to native wildlife, insects, and even “fungi,” which decompose grasses.

Cheatgrass tends to “green up” earlier in the season, robbing the native plants of moisture and nutrients.

However, the biggest problem with cheatgrass is that it is highly flammable. It dries out earlier in the summer than native grasses, providing a significant source of readily combustible fuel.

Because it is an annual, and its seeds are somewhat protected from fire impacts in the soil, cheatgrass can burn and revegetate the site the following year.

By contrast, most native plants, including native grasses and sagebrush, historically burned at much longer intervals. Native bunchgrasses may require ten years to recover from a fire, and all species of sagebrush need decades to centuries to achieve complete restoration after a major fire.

Consequently, cheatgrass fires are the biggest threat to the sagebrush stepper across the West. The idea that fuel breaks are effective has been questioned. For instance, a review of fuel breaks concluded: “Fuel breaks were least successful in areas classified as having low resilience to disturbance and low resistance to invasion, in areas composed of primarily woody fuels, and when operating in high temperature and low precipitation conditions.” In short, places favorable to colonization and dominance by cheatgrass are unlikely to benefit from fuel reductions.

HOW CATTLE PROMOTES CHEATGRASS ESTABLISHMENT AND PERSISTENCE

One of the problems that cattle grazing advocates never mention is that cattle use promotes cheatgrass establishment and persistence.

Cattle selectively consume native grasses, ignoring cheatgrass unless no other forage is available. Over time, native grasses must use scarce resources to replace the loss of photosynthetic material (leaves) by transferring energy from roots to new leaves. Over time this reduces the root system of native grasses, so in times of drought, they are less competitive.

Cattle also trample biocrusts. Biocrust, including algae, lichens, moss, and other soil coverings, inhibit the establishment of cheatgrass. However, in places with significant cattle use, biocrust coverage is reduced, enabling cheatgrass to become established.

For instance, a study of cheatgrass found that the “probability of a community transitioning to a cheatgrass state was (1) strongly and positively related to the initial (2007) cover of cheatgrass in hotspots where initial cheatgrass cover was >20%, and (2) negatively related to biocrust cover where the initial biocrust cover was >4% of ground area.

Biocrusts in this ungrazed site cover the soil inbetween sagebrush. Photo George Wuerthner

Another study found: “evidence that biocrusts increase site resistance to invasion at a landscape scale and mediate the effects of disturbance. Biocrust species richness, which is reduced by livestock grazing, also appears to promote native perennial grasses.”

The same thing is true of the creation of “fuel breaks,” which often eliminate all plant cover and soil disturbance, making an ideal medium for cheatgrass colonization.

The paper admits numerous other problems with targeted livestock grazing: “targeted grazing involves concentrated herbivory, trampling, and other intensive actions that could adversely impact rangeland ecosystems.”

Livestock grazing in general, has numerous other negative ecological impacts, including displacing of naïve herbivores, destruction of riparian areas, soil compaction, disease transmission from livestock to wildlife, water pollution, justification for the killing of native predators, and the previously mentioned destruction of biocrust, among many other adverse influences.

SUMMARY

A proposal by the BLM to create 11,000 miles of fuel breaks across the Great Basin, especially when the actual effectiveness of these fuel reductions created by targeted grazing is questionable, poses a significant threat to sagebrush ecosystems.

The study “Evaluating the efficacy of targeted cattle grazing for fuel break creation and maintenance” appears to be another pro-grazing publication using the fear of wildfire to justify the ongoing destruction of rangelands by domestic cattle.

Furthermore, the study ignores the collateral damage from livestock grazing, the nuances of fire ecology, and the inability of limited fuel reductions to influence wildfire during extreme fire weather conditions of drought, high temperature, low humidity, and high winds. Under such conditions, fuel reductions fail; thus, the “cure” of targeted grazing, which promotes disturbance and increase in cheatgrass, is another failed strategy perpetuated by the livestock industry.

This “thinning” is all but a clearcut in name. Wallowa Whitman National Forest, Oregon. Photo George Wuerthner 

I recently gave a talk on wildfire issues in Baker City, a small town in Eastern Oregon. On my way home, I drove the Elkhorn Scenic By-way, traversing the Wallowa Whitman National Forest (WWNF), and encountered shocking evidence of agency maleficence. The WWNF is engaging in massive new logging projects suggesting they are “restoring” the forests and reducing large blazes through “fuel reductions” and they are certainly not improving the “scenery” of the landscape.

HOW THE FS MISREPRESENTS WILDFIRE SCIENCE

I have written numerous articles on why such ideas misrepresent science.

Forest malfacience on the Wallowa Whitman NF. This kind of “thinning extended for miles along the Elkhorn Scenic Bi-way. Photo George Wuerthner 

First, climate/weather drive all large wildfires. I know of no exceptions. You will not have large blazes if you don’t have the right climate/weather conditions. The agency claims that fire suppression between the 1940s and 1980s led to increased fuel “loading” and forests that deviated from the historical past. During this period, fires were typically small, burning little of the landscape, and were quickly suppressed. Most went out without any suppression at all.

Photo George Wuerthner 

However, this was a period of cool and moist conditions due to the Pacific Decadal Oscillation, among other factors. During these years, glaciers were growing in the PNW due to the unusually wet weather. Indeed, Nature did a fine job of limiting fire spread and even ignitions.

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Note the reduction in acreage burned during the wet, cool period between the 1940s and 1980s. 

Then beginning in the late 1980s, these natural climate trends were overridden by climate warming due to human CO2 emissions. We are now at over 400 ppm carbon, and not surprisingly; we are experiencing extensive drought, higher temperatures, lower humidity, and higher average wind speeds, all of which promote extreme fire weather conditions.

Lodgepole pine is one of many tree species characterized by long fire-free intervals. However, when it does burn, it tends to burn at high severity. Yet much of the logging I witness was in lodgepole pine based on the idea that thinning would “restore” the natural condition. Photo George Wuerthner 

A further problem with the WWNF’s simplistic suggestion that the forest has deviated from its historical condition is that the majority of tree communities in the forest, including larch, lodgepole pine, subalpine fir, Douglas fir, sagebrush, among others, naturally have long fire-free intervals. None of these plant communities have “suffered” from the presumed fire suppression. I will come back to this point in a bit.

Finally, the WWNF suggests logging the forest to “restore” it to the presumed historical condition that existed several hundred years ago. The problem with this goal is that climate ultimately determines which trees grow where and in what abundance, and the climate is no longer the same as 200 years ago when the continent was under the influence of the cooler and moister conditions of the Little Ice Age.

COMPETING SCIENCE

A further problem with the entire WWNF logging program is that the forest stands that they are logging consist of fir, larch, and other species that typically have long fire-free intervals. They were never “open” and “park-like” until the agency got done logging them. Photo George Wuerthner 

The WWNF relies on the work of Oregon State forestry researchers who claim the forest historically the WWNF was characterized by low severity frequent fires that kept fuel loads low and woods open and park-like. By contrast, the WWNF today has more shade-tolerant trees like grand fir and is denser than they suggest the historical conditions were. These more luxuriant forests, it is asserted, are contributing to large wildfires. All of this is based on extrapolation from limited studies of fire scars.

However, there are numerous problems with fire scar studies. Other methods used to reconstruct the historic fire conditions typically come to different conclusions about the WWNF tree stand composition.

For instance, a study using Government Land Office (GLO) surveys concluded that eastern Oregon forests were historically denser than presumed by OSU researchers, and low severity blazes only dominated approximately 23% of the landscape. Mixed to high-severity blazes were the norm on much of the region’s forests.  GLO surveyors recorded the actual condition and species composition of the forest they encountered on their surveys. Furthermore, these surveys were done in the 1800s before “fire suppression” or other factors could be used to explain forest composition.

CARBON STORAGE

Even burnt forests store significant amounts of carbon in snags, soil, and down wood. Photo George Wuerthner 

Indeed, intact forest ecosystems play a massive role in carbon storage. Soils stored most of the ecosystem carbon (63 percent), followed by live vegetation (26 percent) and dead organic matter (11 percent).  Even heavily burnt forests maintain most of their carbon for decades to centuries as snags, soil carbon, and down wood. Large trees, in particular, are critical for carbon storage.

WHAT I FOUND

Forest “restoration” WWNF style. Photo George Wuerthner 

The WWNF uses the above misinterpretation of the historical forest conditions to rationalize massive deforestation. In the region between Granite and Sumpter, Oregon, the agency is logging lodgepole pine forests to “restore” the historical situation that never existed. Lodgepole pine typically has long fire-free intervals, but when it burns, it is often at high severity, where most trees are killed. However, lodgepole pine quickly reseeds after a blaze, constantly creating dense (doghair) stands. This is the natural condition, not some aberration. Yet, the WWNF is “thinning” to such a degree as to create what are clearcuts in all but in name in the effort to “restore” the forest.

DEGRADING THE FOREST

Deforestation on the WWNF. Photo George Wuerthner 

While the WWNF asserts it is “improving” forest health by removing the majority of existing trees from the sites, it is degrading the forest ecosystem.

First and most apparent, removing such a large amount of biomass significantly reduces the carbon storage on the site. Given the need to keep carbon in the forest, such removal is counterproductive for reducing climate warming.

Second, the indiscriminate removal of trees eliminates the very trees which may have genetic resistance to drought, insects, and other usual sources of mortality. Studies have shown that individual trees can vary in their susceptibility to these natural agents.

Logging removes carbon that would otherwise be stored on site. Photo George Wuerthner 

Third, thinning typically puts more fine fuels like small branches, needles, and other materials on the ground. It is fine fuels that sustain and drive fire spread. In addition, thinning opens the forest to greater wind penetration and drying. The wind has been demonstrated to be responsible for most of all large blazes and home loss due to embers that can travel as much as 1-2 miles ahead of the fire front.

Fourth, logging disturbs sensitive wildlife and removes wildlife habitat.

Feller buncher logging the forest. Photo George Wuerthner 

Firth, wood products production releases a tremendous amount of CO2 emissions. Indeed, 66% of the carbon losses across the West were due to logging, while only 15% was due to wildfire.

Thinning in lodgepole pine forest that naturally grows in dense stands does not ‘restore” the forest ecosystem. Photo George Wuerthner 

Sixth, thinning could be more effective at stopping and even slowing fires during extreme fire weather conditions. Since all large high-severity blazes only occur during such situations, the idea that thinning will preclude large fits is fallacious. Studies have shown that lands protected from logging, like wilderness and parks tend to have fewer acres burning at high severity compared to areas with “active forest management.

Thinning puts more fine fuels on the forest floor which contributes to fire spread. Photo George Wuerthner 

Seventh, the likelihood that any fuel reduction will encounter a fire is typically less than 1%. So given the numerous ecological impacts of thinning, and the cost to taxpayers, it simply doesn’t make any rationale sense.

The brush piles will likely be burned in the fall, but in the meantime, they are real source of fuel for blazes. Photo George Wuerthner 

The photos speak for themselves, but the WWNF is embarked on numerous misguided forest degradation and deforestation projects.

I encourage anyone who doubts my interpretation to review these photos and get involved in the WWNF. The WWNF is proposing a massive deforestation project called the Morgan Nesbit Forest Resiliency Project near Joseph, Oregon. Note the euphemism that logging will result in “resiliency,” as if the forest can’t survive without human intervention and “active forest management.”

Logging lodgepole pine on the Deschutes NF in Oregon. Photo George Wuerthner 

Across the West, the Forest Service and logging proponents continue to mischaracterize forest health by the standards of the Industrial Forestry Paradigm. Under this logging juggernaut paradigm, any natural evolutionary agent that kills a tree, such as a drought, wildfire, insects, or disease, is considered a threat.

Such a perspective exemplifies the failure to see the forest for the trees. These natural morality agents are the same factors that shape and maintain healthy forest ecosystems.

Furthermore, terms like “active forest management,’ “restoration,” “resilience,” and “fuel reduction” are euphemisms for logging and ecosystem manipulation better characterized as chainsaw medicine and are premised on flawed assumptions.

Logging removes carbon, contributes to spread of weeds, remove wildlife habitat, and can enhance fire spread. Photo George Wuerthner 

The Forest Service continues to characterize natural disturbances that it cannot control as the problem while ignoring the one thing it can control, namely chainsaw medicine and other forest manipulation.

Large fires are driven by climate/weather factors such as drought, high temperatures, low humidity and especially wind. All large blazes are associated with extreme drought, and historically there were larger wildfires in the past than at present.

For instance, the 1910 Big Burn that raced across 3-3.5 million acres of Idaho and Montana occurred long before anyone could suggest fire suppression and fuel buildup were the cause.

Logging in the backcountry and prescribed burning will not counter the main driving force sharping forest ecosystems-namely climate warming due to increases in atmospheric greenhouse gases. In May, global CO2 levels surpassed 417 ppm, 50% higher than in the pre-industrial era, the highest level in 4 million years!

“Forest restoration” at Kirk Hill, Custer Gallatin National Forest, Montana. Photo George Wuerthner 

Moreover, some studies suggest that up to ten times as much carbon is released by logging as natural disturbances (like wildfire). For instance, 66% of the carbon losses across the West were due to logging, while only 15% was due to wildfire.

Old growth trees play an important role in carbon storage. Photo George Wuerthner 

Indeed, intact forest ecosystems play a massive role in carbon storage. Soils stored most of the ecosystem carbon (63 percent), followed by live vegetation (26 percent) and dead organic matter (11 percent).  Even heavily burnt forests maintain most of their carbon for decades to centuries as snags, soil carbon, and down wood. Large trees, in particular, are critical for carbon storage.

By contrast, transforming forests into wood products releases most of the carbon into the atmosphere immediately or only stores it for short periods as paper or slightly longer as structural beams and wood siding.

Contrary to Forest Service propaganda, natural evolutionary agents like insects, wildfire, and drought create healthy forest ecosystems. Biological agents select and kill the trees that lack the genetic and physical traits to survive under current climate conditions, creating resilience in the ecosystem.

Trying to “restore” the forest to some historical condition that existed a hundred or more years ago is a fool’s errand. All vegetation reflects the influence of climate. The climate today is warmer and drier than in the recent past. We must expect the vegetation communities to change, not remain static.

Mosiac pattern of the Bootleg Fire in southern Oregon. Photo George Wuerthner 

The prevailing mantra that historically wildfire was frequent and low severity (i.e., few trees were killed) is misleading. Most western plant communities naturally experienced mixed to high severity fire for intervals of decades to hundreds of years, including chaparral, juniper, sagebrush, lodgepole pine, hemlock, spruce-fir forests, and aspen.

There is no abnormal fuel build-up in these plant communities.

Clearcuts and heavy logging did not preclude the 2021 Holiday Farm Fire from spreading down the McKenzie River drainage in Oregon. Photo George Wuerthner 

In addition, there is evidence that logging can enhance fire spread by opening the forest to greater wind penetration and drying. That is one reason numerous studies have shown that lands protected from logging, like wilderness and parks tend to have fewer acres burning at high severity compared to areas with “active forest management.”

Furthermore, chainsaw medicine has collateral damage, including loss of carbon storage, disturbance of wildlife, increased spread of weeds, chronic sedimentation of streams from logging roads, and many other well-documented impacts.

The current misguided policy of ramping up “active forest management” or logging in the backcountry to protect homes and communities is delusional. Structure loss was driven primarily by wildfires from unplanned human-related ignitions (e.g. backyard burning, power lines, etc.), which accounted for 76% of all structure loss and resulted in 10 times more structures destroyed per unit area burned compared to lightning-ignited fires.

Therefore we need to reduce the construction of homes in the Wildlands Urban Interface and focus on hardening homes against fire.

Home hardening, including elmination of things like pine needles on the roof, can go a long ways towards reducing home losses. Photo George Wuerthner 

The primary threat to homes comes from wind-driven embers. A recent California study of wildfire found that home hardening, zoning reforms, and buffering could result in 75% fewer homes ignitions.  Metal roofs, screened vents, and other modifications significantly improve the chances of a home surviving even a high-severity blaze.

Rather than continue to spend billions on logging our forests, we should be strategic and focus on working from the home outward. Chainsaw medicine is not the cure, but the problem.

On May 31, 2023, the West lost one of its most ardent wildlife advocates, Dr. James (Jim) Bailey of Belgrade, Montana died peacefully at home. He was 87.

I saw Jim in Bozeman in mid-April. He attended a lecture I gave for Earth Day Celebrations and then, during the same week, gave a talk on wild bison.

Jim ceaselessly advocated for the restoration of American bison. He was one of the few people that I knew that also promoted wildness. What Jim meant by “wildness” is that evolutionary processes would dominate and influence wildlife.

Jim was particularly interested in bison. He wrote American Plains Bison: Rewilding an Icon in 2013. In particular, Jim was committed to Yellowstone bison.

He has pointed out that bison are not endangered. There are hundreds of thousands of bison, most on commercial ranches. But the biggest threat to bison isn’t extinction but the loss of wildness. Domestication is occurring among nearly all bison herds from tribal herds to private ranches to numerous partially wild herds in between.

Yellowstone bison are the only significant bison herd in the United States that has been more or less continuously wild. By wild, we mean the bison were influenced mainly by natural processes like predators, drought, harsh winters, tournament breeding, and selection for mobile and hardy animals.

Jim’s dream was to see public wild bison restored to the Charles M. Russell Wildlife Refuge in central Montana. To Jim, restoring bison or any other animal was mainly about a hands-off approach to management. Most bison herds, including those on tribal lands, are being domesticated.

In an interview in 2014, Bailey explained his concern: “Most people think there is no issue with the bison because Ted Turner owns a bunch, but we’re domesticating them,” Bailey said. “We’re stripping out the wild genes and replacing them with domestic genes. We’re losing the wild bison.”

Jim started the Montana Wild Bison Restoration Coalition. Jim was concerned that nearly all bison in the United States are domesticated. Worse, they are getting more domesticated all the time due to management and policy decisions such as the annual slaughter of Yellowstone bison near Gardiner, which kills all bison, not the individuals that native predators or other mortality factors like starvation might kill. He has listed the ten leading causes of bison loss of wild genes.

Jim grew up in Chicago, but early in his college studies decided that he was interested in a profession in wildlife. So he did graduate work at the State University of New York at Syracuse and the University of Michigan. He eventually got a Ph.D. from the State University of New York at Syracuse.

In 1968 he left the East for an instructor’s position in wildlife management at the University of Montana. This was followed by a professorship at Colorado State University, where he retired as a full professor in 1990.

He then served as Assistant Director of the Conservation Services Division in the New Mexico Department of Game and Fish, overseeing endangered species programs, habitat conservation, and watchable wildlife. He eventually moved to Belgrade and actively promoted the restoration of wild bison.

Unfortunately, Jim died before achieving his dream of wild bison restoration. But others, including myself, continue to advocate for wild bison.

Montana lost an effective wildlife advocate, but his vision will continue.

Remains of a home burned in the Camp Fire which destroyed 19,000 structures in the town of Paradise, California. Photo George Wuerthner 

State Farm Insurance Company announced it would no longer take on new insurance clients in California due to the rising cost of fire-related losses.

The company cited “rapidly growing” catastrophe risks like wildfires, “historic increases” in construction costs, and a challenging reinsurance market for its decision.

The company says that it will continue to insure existing customers.

In recent years, wildfires have increased in frequency and severity—15 of the top 20 fires in the state’s history, in terms of structure damage, have occurred since 2015.

Remains of medical clinic in Paradise, California after the Camp Fire swept through the community. Photo George Wuerthner 

The 2018 Camp Fire, for example, caused 85 deaths and destroyed nearly 19,000 properties in the town of Paradise, California. Eight of the top 10 fires in insured losses in the United States have occurred since 2017.

Since mortgage companies require that any borrower for a home mortgage must have insurance, the decision by State Farm, especially if other companies follow suit, could make buying a home in California difficult.

Those who can’t find private insurance can obtain state-subsidized policies at a high cost. Known as the Fair Access to Insurance Requirements (FAIR) Plan, the state has created a pool of all insurers authorized to operate.

FAIR Plan policies tend to be significantly more expensive for their limited coverage because the properties covered tend to be high risk. Therefore, the FAIR Plan is an option of last resort.

At this point, approximately 3% of all California homes are covered by FAIR insurance policies.

Home that survived the Thomas Fire by Santa Barbara, California. Photo George Wuerthner 

A recent study determined which zip codes were most at risk from wildfire. The researchers found that the very high and high-risk ZIP codes account for 22 percent and 41 percent, respectively, of the total land area. In addition, these ZIP codes tend to be suburban or rural and include the area commonly known as the “wildland-urban interface” (WUI).

Geographically speaking, the highest risk ZIP Code areas were the Sierra Nevada foothills, the coastal mountains of southern California, and the Klamath Mountains in NW California. For example, I have a friend who lives in Mariposa in the Sierra Nevada foothills near Yosemite, and her home insurance is nearly $5000 a year.

This sign exempiflies the attitude of rural residents who believe more logging will preclude large blazes. Photo George Wuerthner 

Across the state, nonrenewal of insurance was highest in the eastern portions of San Diego County (dominated by chaparral) and the Sierra foothills. Interestingly very few insurance policies were canceled by companies in urban areas.

Nevertheless, areas with the highest wildfire risk have the highest nonrenewal rates.

But insurance rates have declined since 2008 (when adjusted for inflation) except for high wildfire risk areas.

One interesting research finding is that “insurance nonrenewal issues are not predominantly experienced by communities with more vulnerable or minority populations.”

Homes in South Lake Tahoe that burned to the ground even with green trees surrounding them–demonstrating that reducing home flammability is key to reducing fire-related home losses. Photo George Wuerthner 

Some may bemoan the higher insurance costs in wildfire-risk areas, but insurance costs or cancellations may begin to limit home construction in fire-prone areas or what I call the “fire plain.”

Just like river flood plains, home construction in the Wildlands Urban Interface, or what can be called “rural sprawl,” is costing everyone in society because much of all fire fighting is focused on these areas.

Ironically in most “rural” counties, the attitude of residents and county officials is “Don’t tell me where I can build my home.” But they are often the first to come with their hands out, asking for more “fire fighting” and more “forest management (i.e., logging).

With global warming, we expect wildfires to continue and increase in number and size. If county commissioners are unwilling to limit rural home building, insurance companies will accomplish the goal by deciding who to insure and how much to charge them.