Citizens for Fire Safe Forests
Mendocino County - June 7, 2016

Standing Dead Trees: Major Fire Hazard

Board of Supervisors Office
Mendocino County
501 Low Gap Road, Room 1090
Ukiah, CA 95482

Dear Supervisors:

I’m writing to you as a rural fire chief concerned about a local forestry practice slipping between the cracks of public oversight. I ask for the issue to be discussed and vetted. I want to work with you and industry to find a reasonable solution.

Our fire district, an area of approximately forty-four square miles situated between the Navarro River and the town of Mendocino (map attached), includes a strip of grassland along the coast, but is largely comprised of forest lands. Approximately half the land in our district is zoned for timber and most residential development consists of homes tucked away in forest settings. A considerable segment of our district’s population benefits from just one means of egress. Residents on Albion Ridge Road, Middle Ridge Road and a plethora of adjoining shared driveways all funnel to a single intersection with California State Route 1. Residents in Little River have more options for emergency escape, but demonstrated by the windstorm of February 8, 2015, which completely closed all access roads in Little River, it doesn’t take much for this community to become an unreachable island.

Late last year, I attended an onsite field presentation hosted by Mendocino Redwood Company as part of their 1-14-080 MEN timber harvest plan review. The tour highlighted a number of public safety concerns and inspired me to write to Leslie Markham, Deputy Chief, Forest Practice, CAL FIRE. To date, a response has not been received. Attached you can find my letter, dated Nov 15, 2014, as well as one from my board, dated January 14, 2015, asking that they be treated as a signatory to my letter. During the field walk, John Andersen, Director of Forest Operations for Mendocino Redwood Company, showed us an experimental area on “J Road” in Albion where brush had been pruned by hand crews. Admiring the work, I asked whether this pattern could be executed across the entire plan. He offered cost as the main impediment blocking widespread adoption.

Sitting at the agency table during the CAL FIRE Second Review of 1-14-080 on February 5, 2015, I asked Charlie Martin, Division Chief, CAL FIRE, whether fire risk to the neighboring residents had been studied. He didn’t respond directly to the question, but explained he has participated at nearly every “big fire” in our county over the past two decades. I don’t discount his expertise and we should commend him for his demonstrated commitment to public safety, but for a matter so critical to health and safety, I would prefer his expertise be combined with formal study. I further pressed for an answer: does CAL FIRE have responsibility to study fire risk in the course of evaluating a timber harvest plan? I mean no disrespect to Chief Martin or his staff, but I left frustrated by the lack of clarity on ownership of the domain. If CAL FIRE has authority, the lack of memorialized study should be scrutinized. If this is not within scope of CAL FIRE review, which agency does own the responsibility? Any oversight, at all?

I cannot fault the applicant. Best I can tell, they operate in compliance with applicable law and work in an environment of ever increasing and arguably onerous regulatory creep. In response to the questions I have raised, they’ve even stepped forward to brainstorm evacuation routes, adding credence to a public concern in desperate need of remedy. For this, I am thankful.

I’m also not ready to place culpability in the hands of state regulators. It appears they are diligently following process. Unfortunately, the process, as implemented, seems to omit consideration for public safety, perhaps because forest management methods have outpaced legislative action.

Regulatory process aside, I see the proposed harvest as part and parcel of a much larger scale forest management endeavor. An intense harvest will encourage unwanted species to flourish under what pre-harvest is shaded by a redwood canopy. Unmanaged, tanoak can pose a challenge to foresters who wish to rebalance the forest toward redwood production. Due to bottom line cost analysis, a method known as “hack and squirt” is locally employed to kill off the unwanted species by hacking into the tree trunk and injecting poison.

Herbicide use is outside the scope of fire concern, but I’ve come to understand that the practice involves leaving the dead trees standing. Attached is an aerial photograph of Comptche, showing us just how many dead trees are produced.

I have raised concerns to the Mendocino Unit of CAL FIRE about a predominately dead forest impacting fire risk, but oddly most responses have been of the form “your area is already a high risk” and “dead trees burn the same as live trees”. In my experience, dead, seasoned wood burns more efficiently than green wood. An intentionally dead forest in decay is a fabrication of fuel ladders, a pattern of vegetation that allows a fire to climb up from the forest floor into the tree canopy where it is more challenging to suppress. This is the very situation public policy attempts to prevent with California Public Resource Code 4291 as explained by CAL FIRE’s “Defensible Space” brochures.

David Shew, Staff Chief, Planning and Risk Analysis, Department of Forestry and Fire Prevention (CAL FIRE), wrote in response to my inquiry regarding dead standing timber, “From my education and experience, a forest with dead standing timber can pose additional and different risks versus a healthy forest.” His full letter is attached.

Credible research has been conducted and published in respected journals. The most applicable study I have read was coincidentally co-authored by Hugh Scanlon, Unit Chief of Humboldt-Del Norte Unit, CAL FIRE, “Sudden oak deathcaused changes to surface fuel loading and potential fire behavior in Douglas-firtanoak forests.1”

I strongly encourage you to read the full report. Of particular interest to this discussion, the researchers used our geographic area with our forest species as their study plot:

Our study area encompassed Douglas-fir-tanoak forests across three counties in northwestern California: Sonoma, Mendocino, and Humboldt…”

And further, they focused on trees killed using both the ‘hack and squirt’ method and the exact poison (Imazapyr) that we see in our area:

Tanoak trees in the study sites were killed via ‘hack and squirt’ injections of either glyphosate or imazapyr (DiTomaso et al., 2004) so that dead trees were killed while standing, as in the situation with P. ramorum2. It has been observed that the pattern of tanoak mortality across the landscape in many herbicide treatment areas strongly resembles that caused by P. ramorum.”

They discovered a twofold in downed debris:

“…total weight of downed woody debris (all size classes) approximately doubled with the herbicide treatment…”

And concluded:

Fuel models based on the observed surface fuel accumulations in herbicide-treated and diseased plots predict that for some early-to-midphase (2–8 years) herbicide-treated forests, and for late-phase (8 years plus) diseased forests, rates of spread, flame lengths, and fire line intensities could increase significantly over the baseline, challenging effective firefighter response.”

One of the co-authors of the above study is J. Morgan Varner, a professor who specializes in fire ecology. Parallels in fire behavior have been observed between trees killed by Sudden Oak Death and those killed by herbicides. In an article, “HSU Scientists Pinpoint Acute Forest Fire Threat” Humboldt State Now (May 06, 2010), Varner described fire behavior of dead tanoak trees:

The energy released is so great you can’t combat [crown fires] with standard firefighting practices,” Varner said. “You just have to move back, and let them die down. You could never imagine attacking this thing.”

Once the tree turns brown, we know it has really low foliage moisture content and it is ready to be ignited.”

Varner was again quoted in 2012 “Scientists warn of disease-borne North Coast fire threat” Northern California Society of American Foresters:

These unnatural fuel arrangements can lead to fires so intense that you can’t combat them with standard, ground-based fire-fighting tactics”

In a time of severe drought we desperately need all parties to cooperate on a path towards improved fire safety. Governance should not allow private industry to create a public nuisance, certainly not one which jeopardizes life and loss of property. Private property rights must be protected, but fire does not respect property boundaries. By its nature, a fire hazard on one property adversely affects the rights of adjoining owners to use and enjoy their property, in this case impacting the health and safety of a community at large. While it’s true that our residents freely chose to live in and against a forest, I do not believe anyone contemplated the practice of intentional dead standing timber. Property rights on both sides of the line and totality of the circumstances must be considered.

Our entire district overlaps with State Responsibility Area, where the State of California has primary financial responsibility for the prevention and suppression of wildland fires, but this does not preclude our involvement in forest fires. In fact, due to the placement and only seasonal staffing of the nearest CAL FIRE station, my fire department typically arrives first on scene. We were first on scene to our portion of the June, 2008 Lightning Complex fires and have a history of containing forest fires in the early stages. Firefighters accept the risks inherent in combating nature. They should not assume additional man made risks that could otherwise be mitigated. The perils created by intentional dead standing timber will harm our volunteer firefighters' ability to confidently contain small fires.

This predicament could be a consequence of a deficiency in public policy described by the Grand Jury in, “SEVEN FIRE DISTRICTS OF RURAL MENDOCINO COUNTY” (June 28, 2005). The Jury’s report touched on two shortcomings pertinent to fire safety: inadequate district funding and lack of a county fire prevention program. In response to the funding concern, last year voters in my district passed Measure M, significantly increasing their special assessment. The second deficiency, “Mendocino County does not have a program of fire prevention, as opposed to fire suppression. The Mendocino Board of Supervisors has the authority to adopt a more stringent fire safety code that would incorporate a fire prevention program” has not been addressed despite a finding of agreement. “The Board of Supervisors agrees with this finding if it pertains to County Government.”

Ideally, the fire community should remain isolated from political debates about forest practice and use of economic poisons, but this relatively new radical practice of generating dead standing timber combined with drought conditions and unprecedented climate change demands evenhanded and responsible action. Unchecked by public oversight, it poses life safety risks to both residents and firefighters.

To be clear, I am not advocating specific action, but rather suggesting we apply precaution and treat fire prevention as a core government health and safety function, while minimizing the impact on industry. Sudden Oak Death is an unfortunate natural hazard. Actually creating such conditions during a severe drought as means to increase profit should only be allowed under careful review.

I am obligated to express this concern now rather than waiting until after a major fire has occurred. While I respect the timber companies’ profit seeking goals and private property rights, we must all work together to avert what is potentially calamitous.

Let’s coordinate?


Ted R. Williams

Chief, Albion Little River Fire Protection District

Citizens For Fire Safe Forests
18452 Orr Springs Rd
Ukiah, CA 95482