SaveLGW responds:


Due to the 1964 Wilderness Act all of the following must be conducted prior to any allowance man-initiated burning for the purpose of fuel reduction:

1. Analyze whether the agency's plan for prescribed fire matches the area's historic fire regime in terms of such things as fire intensity, fire frequency, and time of year. (e.g., was the historic fire regime one of intense crown fires and/or stand-replacement fires, or one of less intense ground fires? At what time of year did fires historically burn in the Linville Gorge Wilderness, and does the FS plan match that temporally? Historically, how frequently did natural fires burn in the Linville Gorge Wilderness?)

2. Conduct a Minimum Requirements Decision Guide analysis for every non-conforming use that the agency proposes, for example, for chainsaw use within the Wilderness or aerial ignition via plane or helicopter.

3. Analyze the impacts to wilderness character of any fire lines cut in the wilderness, and analyze how cutting fire lines could increase the invasion of non-native invasive species within the Linville Gorge Wilderness.

4. Analyze why natural lightning-caused fire alone cannot be used to restore fire to the ecosystem. Please analyze whether lightning fires alone could not also benefit the Table Mountain, pitch, and shortleaf pines and oak woodlands.

5. Human-ignited prescribed fire is a major manipulation or trammeling of Wilderness. Please analyze the damage to the Linville Gorge Wilderness' untrammeled quality with the plan that extensively manipulates the Wilderness with fire, fire lines, etc.

6. Advise what if any retardants will be used within the Linville Gorge Wilderness and, if so, please conduct a full environmental analysis of the retardant's impacts on the Wilderness and the ecosystem.

7. Conduct a full Environmental Impact Statement (EIS) to validate any use of man-ignited fire for the purpose of fuel reduction. This proposal is a major federal action significantly affecting the environment of the Linville Gorge Wilderness and, as such, should have the full analysis of an EIS rather than an EA.

8. Advise how climate change will impact fire behavior and, particularly, extreme fire events?

9. Advise how climate change will impact existing fuel treatments modify future fire behavior so as to aid fire suppression?

10. Advise what fire sensitive flora and fauna exist in the Linville Gorge Wilderness and what measures will be instituted to protect them and their role in the forest.

11. Disprove new research which establishes that prescribed burn provides little to no reduction of severe fire.

12. Prove conclusively how fuel reduction can be accomplished without removal of wood materials from the Linville Gorge Wilderness.

13. Prove conclusively how prescribed burns will not violate the Class 1 air quality designation for the Linville Gorge Wilderness.

14. Prove conclusively how prescribed burns will significantly prevent forest fires in times of drought when these events are most likely to happen.

Posted on October 03, 2013