May 4, 2010
Sherry Tune, District Ranger
Monterey Ranger DistrictLos Padres National Forest
406 S Mildred Street
King City, CA 95814
RE: FireScapes Planning Process
Dear Ms. Tune,
We look forward to participating in the FireScapes process planned for the Monterey Ranger District of the Los Padres National Forest. Since implementation of FireScapes would include designated wilderness, we would like to respectfully submit our views regarding fire presupression methods inside wilderness.
We believe that the maintenance of certain fuel breaks constructed during previous fire events may be an appropriate means to provide for public safety and protect both private property adjacent to public lands and wilderness resources. However, any fuel break maintenance or other presupression measures in wilderness areas should be conducted in a manner that preserves wilderness character and is consistent with wilderness values.
Fuel breaks should only be maintained for use as anchor points for firing operations during wildfire or prescribed fire projects. Fuel breaks should not exceed the minimum width or vegetation reduction necessary to accomplish that purpose. Where it is determined to be suitable, prescribed fire may also be utilized as an alternative to or in conjunction with managed fuel breaks and is the preferred vegetation treatment method in designated wilderness.
Fuel breaks should be designed and implemented in a manner that allows them to retain an appropriate amount of vegetative cover, yet still allow for timely clearing by mechanized or motorized methods during fire events. During wildfires, reopening these managed fuel breaks with bulldozers should be undertaken only when absolutely necessary.
Fuel breaks should be restricted to ridge tops or similar topographic features. Mid-slope fuel breaks are strongly discouraged.
Safety zones created for firefighter safety should be implemented using prescribed fire. They should be situated at appropriate and ecologically sound intervals along fuel breaks.
The use of mechanized or motorized equipment for presupression treatments in wilderness should be carefully analyzed with a “Minimum Requirements Analysis” process. In contrast with treatment areas along wilderness boundaries, those that bisect wilderness should emphasize the use of traditional, non-motorized tools for fuel break maintenance. Where fuel breaks bisect wilderness, suppression efforts should consider use of MIST (Minimum Impact Suppression Tactics) if conditions allow.
All presupression actions should be consistent with the direction provided by the Forest Service Manual in Section 2324.2 - Management of Fire.
Where practicable to do so, fuel breaks, safety zones and other presupression treatments should be located outside wilderness. Public lands and wilderness should not bear the full burden of fire control when more effective alternatives may be available outside both wilderness and the Monterey Ranger District.
The design and implementation of presupression measures that may be proposed by the FireScapes planning process should be based on the best available science.
Sincerely,
