Ecological Risk Assessment to Support Fuels Treatment Project Decisions

Jay O’Laughlin

This synthesis paper provides guidance managers can use to conduct environmental analysis to support fuels treatment projects designed to reduce post-wildfire risks to ecological attributes. Wildfires burning in the uncharacteristic fuel conditions now typical of much of the western US pose risks to ecosystems and the valuable goods and services they provide, including aquatic and terrestrial habitats for fish and wildlife. One goal of the National Fire Plan (NFP) is hazardous fuel reduction. Fuels treatment can modify uncharacteristic wildfire behavior and the subsequent severity of post-wildfire effects, thereby providing benefits by reducing risks to firefighters, ecosystems, and structures. Implementation of fuels treatment projects also poses risks to ecosystems. Unless systematically analyzed and compared to risks of not doing treatments, project implementation risks can inhibit fuel treatment implementation, especially in areas inhabited by species protected by the federal Endangered Species Act (ESA). According to the US Government Accountability Office (2004), agencies recognize the need to better analyze the risk of acting to reduce fuels versus not doing so, but neither the NFP nor National Environmental Policy Act (NEPA) provide guidance specifying how to do this. How then can land managers determine whether the risk of actively treating fuels is greater than the risk posed by no action? The Environmental Protection Agency’s Guidelines for Ecological Risk Assessment (EPA 1998) can be adapted for this purpose. The key to analysis supporting fuel treatment decisions is the incorporation of the risk-reduction benefits of fuels treatment into a framework that facilitates comparison of alternatives. The resulting analysis can be used in NEPA environmental analysis documents to evaluate management alternatives, including no action. Comparing risks from uncharacteristically severe wildfire effects to potentially less severe net effects resulting from fuel treatments is consistent with NEPA’s requirement for public land managers to analyze short- and long-term environmental effects. Formulating the problem as a temporal comparison of adverse effects, however, often results in decisions to reject fuels treatment projects near imperiled species habitat. Adverse effects from fuels treatment are certain in the short term, whereas wildfire occurrence is uncertain. An alternative problem formulation focuses on the relative magnitude of adverse and beneficial effects from wildfire burning under different fuel conditions. By selecting a long-term planning horizon corresponding to fire return interval, wildfire and its effects become certainties. Instead of trying to confront the landscape-level uncertainties of if, when and where an uncharacteristically severe wildfire will occur, the environmental analysis question in the project area simply becomes, which pre-fire condition produces the more desirable post-fire effect: fuel treatment or no fuel treatment? Managers may accept the fuels treatment hypothesis: The adverse effects of short-term project implementation actions will result in substantial long-term net benefits from reduced severity of wildfire effects that outweigh the implementation risks. However, they need evidence to convince others who may be skeptical about this. A process developed from the EPA’s ecological risk assessment guidelines proceeds as follows. Risk problems are first formulated in a conceptual model comparing the relative magnitude of risks. This requires identifying a specific ecological entity to serve as the risk assessment endpoint, and the cause-and-effect relationships of various threats (i.e., hazards or stressors) that adversely affect the endpoint. The EPA cautions against using vague endpoints like integrity or sustainability, thus risk assessment enhances the clarity of objectives and transparency of decision processes. For example, fish are a risk assessment endpoint, and one stressor adversely affecting them is sediment from logging and/or wildfire burning under different conditions that vary according to fuel loadings. The model compares short-term sediment effects of implementing fuels reduction treatments to the longer-term post-wildfire sediment pulse effects with and without fuel treatments, including risk reduction benefits. The analytical model graphically answers the question: Which is worse for fish, wildfire burning under untreated conditions, or the treatments designed to reduce wildfire risks? Used quantitatively or qualitatively, this conceptual model may contribute to sustainable resource management decisions by improving communication among interested publics, risk managers in land and resource management agencies, and risk assessors in agencies responsible for enforcing the ESA.

Wednesday Morning Plenary

corresponding author:

Jay OLaughlin
College of Natural Resources
University of Idaho
PO Box 441133
Moscow, ID 83844-1134
208-885-5776
jayo@uidaho.edu