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Summary 

Past practices of fire suppression in the western United States have resulted in the 

overaccumulation of timber and undergrowth in forest and rangeland habitats. 

This overaccumulation of biomass has caused a degradation of forest habitat, 

wildlife habitat, forest health, and biodiversity; has reduced watershed water 

quality and quantity; has led to spiraling costs of fire suppression and elevated 

risks to both public and firefighters; and has increased the occurrence of 

catastrophic wildfires. For several decades, prescribed burning has been the 

preferred method for addressing fuel load management; however, it also results 

some adverse impacts. Specifically, in the context of this document, prescribed 

fire produces emissions that contribute to the increasing air quality problems in 

the western United States. 

In response to this problem, Congress in 1991 created the Grand Canyon 

Visibility Transport Commission (GCVTC) to advise the U.S. Environmental 

Protection Agency on strategies for protecting visual air quality at national parks 

and wilderness areas on the Colorado Plateau. The GCVTC conducted an 

extensive review of information relating to the problem, collaborating with 

governmental, business, tribal, and environmental interests and, in June 1996, 

approved its final report to the EPA. The report made more than 70 

recommendations for improving visibility in 16 national parks and wilderness 

areas on the Colorado Plateau. 

The Western Governorís Association (WGA), in conjunction with federal, state, 

tribal, and local entities, formed a voluntary organization of western states, tribes, 

and federal agencies. The purpose of the Western Regional Air Partnership 

(WRAP) is to build on the work of the GCVTC in developing and planning 

programs that can contribute to reducing emissions and improving visibility 

throughout the West. Participating states are Alaska, Arizona, California, 

Colorado, Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, 

Utah, Washington, and Wyoming. Participating tribal nations include Pueblos of 

Acoma, Campo Band of Kumeyaay Indians, Cortina Indian Rancheria, Hopi 

Tribe, Hualapai Nation of the Grand Canyon, Jicarilla Apache Tribe, Northern 

Cheyenne Tribe, Salish and Kootenai Confederated Tribes, Pueblo of San Felipe, 

and Shoshone-Bannock Tribes of Fort Hall. Representatives of other tribes 

participate on WRAP forums and committees. Participating federal agencies are 

the Department of the Interior (National Park Service and U.S. Fish and Wildlife 

Service), the Department of Agriculture (U.S. Forest Service), and the EPA. 

The WRAP is composed of a planning group, a technical group, and several 

forums tasked with the development of technical and policy options for specific 
 Summary 

Nonburning Alternatives for 

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areas of interest. The Fire Emission Joint Forum (FEJF) is responsible for 

making recommendations on strategies and methods to manage emissions from 

prescribed fire. Among the many tasks with which FEJF was charged was the 

responsibility of investigating the appropriate use of nonburning alternatives to 

prescribed fire on wildlands. 

The use of alternatives to prescribed burning, when such alternatives are feasible, 

result in fewer emissions than burning. However, practices vary widely from 

state to state, obstacles are numerous, and there is limited awareness of the 

existence of viable alternatives to burning. Accordingly, WGA retained Jones & 

Stokes to conduct a series of interviews with landowners, land managers, and 

stakeholder group members to examine the use of nonburning alternatives on 

wildlands. Information developed during the course of the interviews was used 

to: 

! identify nonburning alternatives, 

! establish criteria for the use of nonburning alternatives, 

! identify barriers to the use of nonburning alternatives, 

! investigate approaches to overcome these barriers, 

! examine current accountability mechanisms, and 

! develop recommendations to promote the use of nonburning alternatives. 

This document represents the compilation of the work done during the course of 

the interviews and other data collection. The objectives of this document are: 

(1) to provide landowners and land managers with a comprehensive reference 

document that describes alternatives to prescribed burning; (2) to provide 

decision makers with the tools necessary to develop cogent nonburning strategies 

for vegetation and fuel load management; and (3) to assist air quality regulators, 

environmental organizations, and the general public in understanding the 

environmental, economic, and practical advantages of nonburning alternatives. 
Nonburning Alternatives for 

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Chapter 1 

Introduction 

The 2000 fire season was the worst in 50 years. The scale and intensity of the 

2000 fire season capped a decade that was characterized by a dramatic rise in the 

number of large wildland fires, the costs associated with fire suppression, and the 

values at risk in the wildland-urban interface. In the 2000 fire season, 

approximately 123,000 fires burned more than 8.4 million acres. More than $2 

billion from federal accounts was spent suppressing wildland fires. This amount 

does not include state and local firefighting suppression costs; direct and indirect 

economic losses to communities; loss of private, state, and federal resources; or 

damage to ecosystems. 

In August 2000, President Clinton directed the Secretaries of Agriculture and the 

Interior to develop a response to severe wildland fires, reduce fire impacts on 

rural communities, and ensure sufficient firefighting capacity in the future. 

Congress in turn mandated implementation of a National Fire Plan (NFP) 

through legislation and appropriations. The NFP addresses conditions that have 

evolved over many decades and cannot, consequently, be reversed in a single 

year; these conditions will require consistent and ongoing future management 

efforts. The NFP is a long-term commitment based on cooperation and 

communication among federal agencies, states, local governments, tribes, and 

other interested parties. 

The 2002 fire season was the second worst season in the past 50 years; 

approximately 6.7 million acres burned in more than 68,000 fires. Colorado, 

Arizona, and Oregon all suffered the largest fires recorded in the past century. 

Early in the season, about 45% of the country reported moderate to extreme 

drought conditions; nearly 50% remained in conditions of moderate to extreme 

drought as the season ended. Clearly, with the worst and second-worst seasons 

in half a century occurring only 2 years apart, the problem of catastrophic 

wildfire is becoming increasingly critical. 

Fire in the West 

For thousands of years, periodic fires, ignited by lightning or Native Americans, 

shaped the ecosystems of the western United States; forests and other western 

ecosystems supported an abundance of fire-tolerant or fire-adapted species. The 

historical fire regimes exerted profound influence on the accumulation of fuels, 
 Chapter 1 

Introduction 

Nonburning Alternatives for 

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nutrient cycling, patterns of vegetation growth, and distribution of natural 

communities. Because of the range of these influences, the fire-suppression 

activities of the twentieth century have had widespread effects, particularly on 

those systems that were most adapted to or dependent upon their historical fire 

regimes. 

Fire suppression can lead to marked changes in stand density. The increase of 

small- and medium-size classes of shade-tolerant and fire-sensitive species that 

can result from suppression is of particular concern. This change produces an 

increase in the amount and continuity of live fuels near the forest floor that can 

act as ladder fuels (i.e., fuels that can conduct fire from ground-level or surface 

fuels into the forest canopy). Moreover, harvest practices of the twentieth 

century have typically removed the larger overstory trees, accelerating growth in 

the dense understory and increasing the homogeneity of the fuel structure. The 

lack of fire has also caused dead fuels on the forest floor to accumulate in excess 

of their presuppression levels.1

 

In general, todayís typical forest stand is denser, contains more ladder fuels, and 

has a higher surface fuel load than historic forest stands. Contemporary forests 

contain a greater abundance of species that would historically have been 

excluded by fire (i.e., nonclimax or invasive species). Nonforest ecosystems 

have been similarly modified by fire suppression activities. 

Restoring the Balance 

Only in the past few decades has it become widely understood that the historical 

practice of fire suppression has had costly and potentially catastrophic 

repercussions. This new awareness has prompted a strong movement towards the 

use of prescribed burning, the intent of which is to reduce the risk of catastrophic 

wildfire and to restore wildland conditions to a more natural fire regime. 

However, because of the cumulative impacts of prescribed burning on air 

qualityalready compromised by automotive and industrial emissionsas well 

as on other environmental resources, there is a strong case to be made for the use 

of nonburning alternatives that have the potential to achieve many of the same 

results as prescribed burning but without the adverse effects. 

Under the auspices of WGA, WRAP, and FEFJ, Jones & Stokes has prepared this 

manual to foster a greater understanding of the benefits and mechanics of 

nonburning alternatives. Early in the process, it became clear that a great many 

answers to the complex issues involved in vegetation and fuel load management 

already exist, and that the judicious compilation of available knowledge and 

resources could provide a user-friendly roadmap to the arduous undertaking of 

developing site-appropriate strategies. Accordingly, Jones & Stokes conducted 

extensive interviews with a wide array of individuals involved in vegetation, fuel 

 

1

 Sierra Nevada Ecosystem Project, Final Report to Congress, vol. II, Assessments and Scientific Basis for 

Management Options (Davis: University of California, Centers for Water and Wildland Resources, 1996). 
 Chapter 1 

Introduction 

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load, and land management. Interviewees included federal land managers, state 

land managers, tribal land managers, researchers, timber industry representatives, 

and environmental interest group representatives. 

How to Use This Manual 

Because of the enormous complexity of the issues involved and the rather 

daunting variability of conditions throughout the western United States, it was 

not possible to create an exhaustive ìhow-toî manual that would address all the 

contingencies that might face decision makers. Accordingly, this document has 

been developed to address the categories of considerations that decision makers 

are likely to confront, the range of options available for development of 

nonburning fuel management strategies, and the approaches to finding the best 

solutions to each land managerís particular situation. It must be understood that 

every situation is unique, and that a ìone-size-fits-allî approach to development 

of a strategy for management of fuel loads is never appropriate. It is therefore 

the intent of this manual to provide decision makers (e.g., resource managers, 

landowners) with the tools to reach an informed decision. 

Chapter 2 (Vegetation Management: To Burn or Not To Burn) considers the 

scope of variables that must be weighed in developing a vegetation or fuel load 

management strategy. Chapter 3 (Nonburning Alternatives: Variables, Criteria, 

and Definitions) provides an overview of the concepts and vocabulary of 

vegetation and fuel load management, and summarizes the options available for 

nonburning treatment programs. Chapter 4 (Getting to Work: How to Build a 

Nonburning Strategy) guides the decision maker through the technical and 

nontechnical considerations one must navigate in designing a vegetation or fuel 

load management program. Chapter 5 (Conclusions and Recommendations) 

explores means by which the increased acceptance of nonburning alternatives 

might be promoted. Appendix A presents a sample worksheet for evaluating the 

options that might be appropriate for any given set of circumstances, as well as 

an example of the chain of reasoning used to develop a similar site-specific 

evaluation tool. Other appendices provide [. . . .] 
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Chapter 2 

Vegetation Management: 

To Burn or Not To Burn 

The Rationale for Treatment 

As discussed in Chapter 1 (Introduction), the need for management activities to 

correct the results a century of fire suppression is clear. In considering the 

approach to developing management strategies, it might be useful to review the 

concept of fire and fire management in its broadest theoretical context. 

Fire in the most basic sense is a chemical reaction, involving the rapid oxidation 

of combustible material and characterized by the release of energy in the form of 

heat and light. The familiar diagram known as the fire triangle [Figure 2-1; Fire 

Triangle] illustrates the three components essential to the oxidation process we 

know as fire: fuel, heat, and oxygen. 

In the context of wildland fire, fuel is in reality the only one of these components 

over which humans can hope to exert any meaningful control. The 

characteristics of the fuel, considered in the context of topography and climate, 

determine the manner in which fire is likely to ignite, develop, and spread. This 

process of ignition, development, and movement through the habitat is termed 

fire behavior. 

The approach to reduction of fire risk through management activities involves 

implementing actions that will modify the behavior of fire. The attributes of fuel 

that management activities can effectively address are, for all intents and 

purposes, limited to the quantity and arrangement of the fuel load. On the most 

basic level, vegetation and fuel load management entails disarranging or reducing 

the quantity of the fuel load to impede fireís ability to pass through the habitat. 

Continuity of the fuel load can be disrupted vertically or horizontally; firebreaks 

can be created; fuel can be removed off site. The optimum strategy is governed 

by numerous variables, and the body of knowledge concerning fire ecology and 

fire management is continually expanding. The mechanics of fuel load 

management are discussed in greater detail in Chapter 3 (Nonburning 

Alternatives: Variables, Criteria, and Definitions) and Chapter 4 (Getting to 

Work: How to Build a Nonburning Strategy). 
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Vegetation Management: To Burn or Not To Burn 

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Development of a reasonable vegetation and fuel load management strategy must 

be predicated upon an understanding of the desired future condition. The desired 

future condition, in turn, requires an understanding of the disparity between 

historic conditions (i.e., the conditions that existed before fire suppression 

activities or other land use practices altered the vegetative conditions of the area 

under consideration) and current conditions. The management strategy, then, is 

the roadmap for moving from current conditions to the desired future condition. 

Typically, the objective of the management strategy is either to restore forest 

health or to protect human life and property. While these objectives frequently 

overlap, such is not always the case. Restoration of forest health generally 

entails returning the habitat to its historic fire regime, defined by the natural 

patterns of frequency, predictability, seasonality, intensity, duration, and scale 

with which fire historically passed through the habitat. Protection of human life 

and property is frequently addressed by restoring the historic fire regime; 

however, some habitats are naturally subject to severe fire regimes. In such 

cases, additional treatment may be necessary to attain the desired future 

condition. 

Fire regimes have been classified into five groups; these are summarized in Table 

1. 

Table 1. Fire Regimes 

Classification Fire Return Interval Severity Example Habitats 

Group I 0ñ35 years Low Ponderosa pine, other long needle pine species, 

and dry site Douglas-fir 

Group II 0ñ35 years Stand replacement Drier grasslands, tall grass prairie, and some 

Pacific chaparral ecosystems 

Group III 35ñ100+ years Mixed Interior dry site shrub communities such as 

sagebrush and chaparral ecosystems 

Group IV 35ñ100+ years Stand replacement Lodgepole pine and jack pine 

Group V >200 years Stand replacement Temperate rain forest, boreal forest, and high 

elevation conifer species 

A corollary descriptor of fire conditions describes a fire regimeís extent of 

deviation from historic conditions. These condition classes also measure general 

wildfire risk; however, it is important to understand that the criterion of fire risk 

is based upon the loss of key components of the ecosystem. For example, a 

habitat with a naturally severe (i.e., stand-replacing) fire regime, while 

potentially posing a serious risk to human property, might be considered to have 
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Vegetation Management: To Burn or Not To Burn 

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low risk because the ecosystem is adapted to fire and would be likely to 

reestablish in accordance with historic patterns. 

! Condition Class 1: Fire regimes in this condition class are mostly within 

historical ranges. Vegetation composition and structure are intact. The risk 

of losing key components of the ecosystem from fire is low. 

! Condition Class 2: Fire regimes in this condition class have been moderately 

altered from their historic range, either by increasing or decreasing the fire 

frequency. The risk of losing key components of the ecosystem from fire is 

moderate. 

! Condition Class 3: Fire regimes in this condition class have been 

significantly altered from their historical return intervals. Vegetation 

composition, structure, and diversity have been significantly altered. The 

risk of losing key components of the ecosystem from fire is high. 

As mentioned above, treatment of a habitat may be appropriate to restore a 

habitatís health as well as to protect human resources. Accordingly, areas in any 

of the condition classes may be suitable candidates for treatment. Conditions that 

indicate the need for treatment may be divided into two broad categories 

! An ecosystem in which the fire regime has been altered, increasing the risk 

of fire that could result in loss of ecosystem elements as well as in 

destruction of human life or property. 

! An ecosystem in which the fire regime is naturally severe and requires 

treatment to protect human life or property. 

When an ecosystem has been altered from its historic regime, efforts to restore 

that regime are indicated; in other words, the management objective is to modify 

a condition class 2 or 3 ecosystem into a condition class 1 system. If ecosystem 

health is the object, such a strategy is considered to be a restoration activity. 

However, whether or not the fire regime has been altered, risk of wildfire must be 

addressed in areas near human resources. In the case of condition class 1 habitats 

(presumably those with naturally severe fire regimes), the treatment would 

assume a different strategic character than a restoration activity; for example, 

treatment might entail creation of fire breaks or home protection zones. 

An Overview of Prescribed Burning 

If one accepts the proposition that the restoration of natural fire regimes is a 

legitimate management objective for the preponderance of western wildlands, 

then it is important to understand the distinction between prescribed burning and 

natural fire. Although prescribed burning has been widely used in recent decades 

as a vegetation and fuel load management tool, and despite the acknowledged 

virtue of prescribed burning to restore natural fire regimes, the mechanisms of 
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Vegetation Management: To Burn or Not To Burn 

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prescribed burning and natural fire are widely divergent. For instance, naturally 

occurring wildfires tend to occur during fire season (i.e., summer through fall), 

while prescribed burning is generally implemented under precisely those 

conditions that would most likely preclude the spread of a naturally occurring 

fire. This difference in timing is a necessary precaution against the risk of 

escape; indeed, the disparity between natural and prescribed fire is intimately 

linked with the fact that it is the unnatural conditions created by past 

management decisions that necessitates treatment in the first place. It should be 

borne in mind throughout the ensuing discussions that those areas that are most 

difficult to treat are the areas in greatest need of treatment. 

The Functions of Fire 

Naturally occurring fire in western ecosystems serves several ecosystem 

functions. Fire can eliminate invasions of species from outside the ecosystem, 

thin vegetation to facilitate establishment of young plants, eliminate fuel loads 

before they attain potentially catastrophic proportions, and recycle nutrients. Fire 

is an integral component of many western habitat types. 

Prescribed fire can accomplish many of the same functions as naturally occurring 

fire; however, as discussed above, the context of prescribed fire differs from that 

of naturally occurring fire. Because of its controlled nature, prescribed fire does 

not entirely duplicate the ecological function of fire in the west, nor does it 

necessarily address all hazardous fuel conditions. 

As suggested by the interviews and literature reviews conducted for preparation 

of this document, the reasons for implementing prescribed burning can be 

assigned to three broad categories: hazardous fuels reduction, habitat 

management, and ecological restoration. The functions listed below are those 

that land managers are most likely to cite for using prescribed fire. 

! Reduction of fine fuels. 

! Reduction of surface fuel loading. 

! Mortality of ladder fuels. 

! Release of nutrients. 

! Improvement of wildlife habitat through stimulating regrowth and seeding. 

! Control of some invasive species, pests, and diseases. 

Use of prescribed fire in wildlands falls into two broad categories. 

! Vegetation management. Objectives include the reintroduction of fire into 

fire-adapted ecosystems, stimulation of regrowth of species desired for 

browse, creation of openings for early successional species, control of 

invasive species, and nutrient recycling. 
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Vegetation Management: To Burn or Not To Burn 

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! Fuels management. Objectives include cleaning up post-silvicultural 

residues, maintenance or creation of fuel breaks to protect resources, and 

preventing losses from catastrophic wildfire. 

These objectives are not mutually exclusive, and often several objectives can be 

achieved through a single treatment strategy. For example, treatments designed 

to make natural stands of forestland more fire resistant can facilitate the return of 

fire into the ecosystem while protecting houses or other adjacent resources. 

Challenges to Burning 

Because fire is such an integral component of many western ecosystems, and 

because a key objective of many vegetation and fuel management programs is to 

restore habitats to an approximation of the ecosystemís natural fire regime, it is 

often assumed that prescribed burning is the most natural method to achieve such 

an objective. However, as mentioned above, the conditions under which 

prescribed burns are implemented differ significantly from the conditions under 

which naturally occurring fires enter the ecosystem. For example, naturally 

occurring fires are likeliest during the summer or fall under conditions of low 

humidity, high temperatures and, frequently, high winds; prescribed burns, to the 

contrary, are generally implemented under carefully monitored conditions of 

specific levels of fuel moisture, higher atmospheric humidity, moderate 

temperatures, and relatively low winds to minimize the risk of escape. 

Despite the virtues of prescribed burning for vegetation and fuel load 

management activities, it must be recognized that fire carries negative impacts 

and risks as well. Disadvantages of burning include: 

! smoke and other emissions that contribute to air quality problems and 

visibility impacts, 

! potential loss of resources from escapes, and 

! loss of material that might otherwise be utilizable. 

Some of these impacts violate the regulatory requirements of the Clean Air Act, 

while others entail risk to resources and to the safety of landowners and 

firefighters. Moreover, there are logistic disadvantages to the use of burning, 

many of which can be avoided by the use of nonburning alternatives. 

Air Quality 

The Clean Air Act (CAA) of 1970 established national ambient air quality 

standards (NAAQS) for six pollutants, known as criteria pollutants: carbon 

monoxide (CO), ozone, particulate matter with a diameter less than 10 microns 

(inhalable particulate matter or PM10), nitrogen oxides (NOx), sulfur dioxide 

(SO2), and lead. Most standards were set to protect public health; however, for 
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some pollutants, standards are based on other values, such as protection of crops, 

protection of materials, and avoidance of nuisance conditions. Except for ozone, 

NAAQS represent short-term (24 hours or less) concentrations that may be 

exceeded no more than once per year and annual concentrations that may never 

be exceeded. NAAQS for ozone may be exceeded no more than 3 days in 3 

years. 

In July 1997, EPA promulgated a NAAQS for PM2.5, making it the seventh 

criteria pollutant. EPA asserts that these fine and ultrafine particles are closely 

related to significant adverse health effects. Accordingly, EPA has established a 

24-hour average limit of 65 micrograms per cubic meter and an annual average 

limit of 15 micrograms per cubic meter. Controls for PM2.5 will probably not be 

established until 2005−2008. 

The smoke released by wildland fires contains large quantities of fine particulate 

matter, as well as many of the same chemical constituents found in urban smog. 

Wildfire smoke also contains organic compounds, known as polycyclic aromatic 

hydrocarbons, some of which are toxic and potentially carcinogenic. Because 

fine particles are readily inhaled and retained in the lungs, and because wildfires 

release fine and medium (i.e., <2.5 micron and 2.5−10 micron) particles, these 

emissions represent a potential to human health and the environment. 

Moreover, authorities estimate that every 1,000 acres that burn in a wildfire 

generate a quantity of fine particulate emission equivalent to that produced by all 

the motor vehicles in southern California in a day. Accordingly, the contribution 

of prescribed burning to preexisting air quality conditions can be seen to be 

significant. 

Risk of Escape 

Fire by its very nature is characterized by an inherent lack of control. This is of 

particular concern when using fire as a vegetation or fuel load management tool 

(remember: those areas that are most difficult to treat are the areas in greatest 

need of treatment). While this characteristic of unpredictability can contribute to 

results that mimic natural processes, it can also have serious consequences in the 

real world of land ownership boundaries, adjacent infrastructure, unnatural fuel 

load conditions, and political and financial liabilities. 

The difficulty of confining fire to a prescribed area bears an associated risk; the 

degree of this risk is influenced by the nature of adjacent resources that might be 

susceptible to damage or loss, as well as by the kinds of conditions that influence 

fire behavior (e.g., weather, topography, fuel characteristics). In recent years 

several large wildfires have begun as prescribed burns, but upon escaping control 

they destroyed infrastructure, natural resources, watersheds, and peopleís homes. 

In addition to the costs of these losses, a huge amount of money was expended in 

fighting the fires. Financial liability can fall in many directions depending on 
 Chapter 2 

Vegetation Management: To Burn or Not To Burn 

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location and jurisdiction; whoever must bear the cost, it is clear that escape of 

prescribed fire carries the potential for serious calamity. 

Loss of Materials 

Burning of material that might be used as a source of fiber for pulp, 

particleboard, or energy generation may not be the most efficient or judicious use 

of our natural resources. The demand for wood and wood products is becoming 

increasingly difficult to satisfy due to limitations of timber harvest activities on 

National Forest System lands. Additionally, the use of such submerchantable 

material might also offset the demand for material that is traditionally derived 

from large, merchantable trees harvested on public as well as private lands. 

Logistic Disadvantages 

Because of concerns associated with the risks of escape, prescribed burning is 

necessarily constrained by rigorous conditions. For instance, burn plans specify 

very precise parameters of humidity, wind conditions, temperature, and moisture 

content of both live and dead fuel within which the burn may be implemented. 

These parameters, as well as regulatory restrictions, can narrow the window of 

feasibility for a particular burn plan to as little as several days in an entire season. 

If for some reason those days are precluded, the window might close until the 

next season. As such opportunities are missed, fuel conditions can continue to 

worsen. Furthermore, the local air quality management agency may impose 

stringent requirements to ensure acceptable levels of emissions. For example, the 

presence of a stable air mass, which is the safest condition under which to initiate 

a burn, is also the least desirable condition for air quality concerns. Constraints 

such as these can combine and overlap to frustrate the most well-conceived 

projects. 

It should be remembered that many areas in greatest need of treatment are areas 

of condition class 2 or 3; in such areas the vegetation structure and composition 

have been so modified that fire cannot likely be introduced under uncontrolled 

conditions. By definition, areas of these condition classes are at risk of losing 

ecosystem components in the event of fire. Consequently, treatment necessitates 

a managed burn that is coolerthat is, less intensethan a naturally occurring 

fire would be. While such a managed burn poses less risk of escape than a 

naturally occurring fire would pose, it is also unlikely to achieve the desired 

future condition of the treatment area; to the contrary, such a burn is an 

intermediate step, presumably establishing conditions that would permit a 

subsequent entry, or entries, with fire to attain the desired condition. Each entry 

entails repeated risk of escape as well as additional emissions of pollutants. 
 Chapter 2 

Vegetation Management: To Burn or Not To Burn 

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Evaluating Nonburning Alternatives 

In view of the disadvantages to prescribed burning discussed above, there are 

strong arguments to be made in favor of a careful evaluation of nonburning 

alternatives when developing a vegetation or fuel load management strategy. 

Specific nonburning alternatives are discussed in greater detail in Chapter 3 

(Nonburning Alternatives: Variables, Criteria, and Definitions); for the purpose 

of the current discussion, nonburning alternatives can be broadly defined as 

treatments employing manual, mechanical, chemical, or animal (i.e., managed 

livestock grazing) methods to address management of vegetation or fuel loads. 

Nonburning alternatives must, if they are to be satisfactory treatments, mimic at 

least some of the effects for the achievement of which prescribed burning is 

typically implemented. Table 1-2 shows a comparison between the effects of 

potential nonburning alternatives and the effects of prescribed fire. 

In assessing nonburning treatments and the relative reasonableness of various 

alternatives, one must consider a spectrum of criteria to evaluate the potential 

impacts on fuels, the environment, and society. Often, an initially promising idea 

can have unforeseen consequences. The practice of fire suppression is a case in 

point: for many years, fires were suppressed with the objective of protecting 

forest resources. However, as current understanding teaches, this practice has 

instead produced an increase in catastrophic wildfire, thereby threatening the 

very resources it was intended to protect. 

Accordingly, it is important to evaluate the reasonableness of potential 

nonburning alternatives. Reasonableness can be taken to reflect the likelihood of 

a treatment to achieve desired results; the relative absence of risk that 

unanticipated adverse effects will ensue; and the alternativeís conformance to 

practical, technical, political, and economic constraints. 

A variety of criteria can be applied during the evaluation process. This 

document emphasizes those criteria that identify generalized effects of specific 

treatment types. Criteria that can be evaluated only when considering sitespecific information are not useful for the generic assessment of reasonableness 

that falls within the purview of this document. For example, potential impacts on 

wildlife, while extremely important to consider, are far too site-specific to 

address generally. All treatment types impact wildlife habitat; the degree and 

character of the impact, however, varies with existing conditions, desired future 

conditions, and the community of species that occurs on the target site. 

A myriad of factors must be considered in developing any vegetation or fuel load 

management strategy. This document adopts a simple division of the issues that 

land managers must address; however, as in all activities involving resource 

management, it is important to remember that the different issue areas are 

interconnected and that systems of organization are merely tools for the 

convenient processing and assimilation of information. The four issue areas used 

in this manual are: 
 Chapter 2 

Vegetation Management: To Burn or Not To Burn 

Nonburning Alternatives for 

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November 2002 

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! technical considerations, 

! environmental considerations, 

! economic considerations, and 

! sociopolitical considerations. 

The evaluation of nonburning alternatives should include a comparison of the 

effects of the nonburning treatment method under consideration with the effects 

that would be achieved through the use of burning. 

Finding Innovative Solutions 

The interviews conducted in preparation of this report suggested three broad 

trends regarding the choice of prescribed burning versus that of nonburning 

alternatives. Respondents inclined towards burning when cost was the 

determining factor; nonburning alternatives gained support in situations where 

burning could not be conducted safely, such as in the urban-wildland interface 

and in areas where pretreatment activities must be carried out prior to burning. 

Another consideration was the potential marketability of materials on the site. 

Traditionally, vegetation and fuel load management has been accomplished by 

one of two methods: harvesting and burning. Each method has gained staunch 

adherents and dedicated opponents; consequently, the entire issue has become 

tangled in emotional response and highly charged rhetoric. Nevertheless, it is 

generally understood that action must be taken to address a problem that has been 

a century and more in the making and that is becoming yearly more critical. It 

will be necessary for groups on all sides of the issue to suspend their 

preconceptions and examine possible alternatives objectively if the fuel load 

crisis is to be addressed in a safe and timely manner. It must be borne in mind 

that the situation as it exists in much of the western wildland habitats is not a 

natural situation; it will, consequently, require decisive actions to correct it. 

However, with creative thinking, good will, and clear intentions, there is no 

reason that all parties concerned cannot arrive at mutually acceptable approaches 

to address acknowledged problems.
Nonburning Alternatives for 

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Chapter 3 

Nonburning Alternatives: 

Variables, Criteria, and Definitions 

The task of restoring natural communities to a semblance of historic conditions is 

one that cannot be accomplished by the simple reintroduction of fire into the 

ecosystem. In many western ecosystems, in fact, such a reintroduction is no 

longer an option due to the overaccumulation of fuel loads. While it is important 

to recognize that fire is an integral component of ecosystems in the western 

United States, it is equally important to recognize the merits of nonburning 

alternatives to address vegetation and fuel load management issues. At the same 

time, it must be emphasized that implementation of a nonburning alternative does 

not preclude subsequent use of burning; indeed, prescribed burns are often 

predicated on preliminary nonburning pretreatments. 

The need to reduce fuels increases every year, and proper use of mechanical 

equipment or other nonburning alternatives can be instrumental in reducing the 

impact of wildfires in the west. Many of these alternatives have a broader 

window of opportunity and a much lower level of associated risk than prescribed 

fire. 

In developing the appropriate strategy for any proposed treatment area, it is 

necessary to proceed through a multilayered evaluation of the issue areas 

introduced in the previous chapter. Moreover, it is critical to establish the criteria 

by which one must evaluate various treatment options in order to make an 

informed decision. Again, it must be emphasized that every situation is unique 

and that superficially similar treatment areas may be subject to markedly 

differing constraints. Preparation of a worksheet or checklist similar to that 

presented in Appendix A should assist decision makers in reaching an informed 

decision regarding the most appropriate treatment method for the area under 

consideration. 

Technical Considerations 

Technical considerations entail the activities that can be conducted within the 

parameters of physical conditions (e.g., topography, habitat type, fuel 

conditions), regardless of other considerations. For example, if the terrain is too 
 Chapter 3 

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Nonburning Alternatives for 

Vegetation and Fuel Management 16 

November 2002 

J&S 01-562 

steeply sloped to use heavy equipment safely, then the range of treatment options 

that depends on the use of such equipment is clearly excluded. 

When options have been screened on the basis of feasibility, it is important to 

consider the effects that the various treatment options will have on fuels and fire 

behavior. The evaluation of nonburning alternatives should address: 

! changes to be made to the fuel structure; 

! whether the treated area will exhibit increased resistance to fire; 

! a comparison between the anticipated results of the nonburning alternative 

with the results of prescribed burning. 

Land managers should become conversant with the habitat types in their areas of 

responsibility, as well as with the basic concepts and common terminology 

relating to fuel structure and characteristics. Only with a basic working 

knowledge of the technical aspects of fuel load management can reasonable 

strategies be developed. 

Physical Conditions 

Habitat Types 

As Map 1 shows, the western United States is a complex amalgam of vegetative 

communities. These communities have evolved in response to varied 

characteristics of topography, climate, soil conditions, hydrologic regime, and 

other physiographic as well anthropogenic conditions. Each community is 

characterized by a suite of fuel conditions and fire-related traits and responses. 

For the purposes of the generalized approach of this document, many of these 

communities can be grouped into broad categories that share common fuel 

characteristics and types of resources that can be exploited for similar uses. 

Map 2 shows the simplified categories that this document uses to address the 

issues of vegetation and fuel load management. The habitat categories that might 

be candidates for vegetation and fuel load management strategies are: 

! grassland, 

! shrubland, and 

! forested habitat. 

These three habitat categories can be roughly correlated with appropriate 

equipment types and material resources with utilization potential. As has been 

discussed elsewhere, site-specific characteristics will have to be addressed in 

some detail for each proposed treatment project. 
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Nonburning Alternatives for 

Vegetation and Fuel Management 17 

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Grassland: The dominant fuel type and predominant carrier of fire is grass or 

forbs. This category includes many oak woodland and savanna communities; 

because these communities generally exhibit no vertical continuity of fuels, fire 

is usually limited to surface grasses. 

Shrubland: The primary carrier of fire in these vegetation types is a fairly 

contiguous shrub layer. Fire behavior tends to be more intense than in grassland 

habitats because the vegetation is typically characterized by greater height and 

density, larger diameter stems, and (frequently) higher levels of volatility 

resulting from resins and oils. Surface fuels are limited because the shrubsí 

density inhibits growth of other plants and the vegetation type does not produce 

large quantities of litter. Some trees can be present, but not usually in sufficient 

density to inhibit the growth or continuity of the shrubs. 

Forested habitat: The primary carrier of fire in this vegetation type is litter 

from the trees in the form of needles/leaves and dead branches. Younger trees, 

shrubs, or low branch growth can provide vertical continuity of fuels. In the case 

of severe wildfire, dense canopies can become carriers. 

[2 Sets of photos showing historical changes in fuel conditions] 

[1 photo of excessive fuel load in grass] 

[2 photos of excessive fuel loads in shrub] 

[3 photos of excessive fuel loads in forest] 

Fuels 

Fuels can be defined as both living and dead vegetation that is available to burn 

during a fire. The difference between vegetation type and fuel is that while a 

vegetation community is defined by species composition, a fuel type is 

determined by how a given area will burn. The manner in which a given area 

will respond to fire is a function of the continuity of living and dead vegetation, 

the height and layers of vegetation, the volume and availability of different sizes 

of fuels, and weather conditions. 

Three categories of fuels are critical in understanding fire behavior and the theory 

of vegetation and fuel load management: 

! surface fuels, 

! ladder fuels, and 

! aerial fuels. 
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Nonburning Alternatives for 

Vegetation and Fuel Management 18 

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The role of each category in fire behavior must be understood, and the treatment 

selected must be appropriate to the category or categories of fuels that represent 

the primary risk in the treatment area. 

Surface fuels are those fuels that are in contact with the surface of the ground. 

They can, depending upon the particular vegetation community, extend up to 5 

feet above the ground. Surface fuels include detritus such as fallen leaves or 

needles, twigs, bark, cones and small branches, heavier branchwood, and downed 

logs. Surface fuels can also include understory growth such as grasses, forbs, 

low and medium shrubs, and tree seedlings. These fuels are important because 

they are the primary carrier of fire. Their specific characteristics influence such 

aspects of fire behavior as rate of spread, flame length, and residence time. 

Ladder fuels include taller surface fuels. These fuels generally lie between 5 

and 15 feet above the ground. They provide vertical continuity between 

vegetation layers, conducting fire from surface fuels into the crowns of shrubs or 

trees. Ladder fuels can initiate and spread crown fires, which lead to increased 

resource damage, pose high levels of risk, and are very difficult to contain. 

Aerial fuels include both live and dead material in the forest or shrubland 

canopy. These fuels are typically more than 15 feet above the surface. They 

include tree branches, twigs and cones, snags, moss, and high brush. Aerial fuels 

are the fuels available for supporting a crown fire. 

All fuel types have characteristics that are important to evaluate when developing 

the most appropriate strategy for any given area. These characteristics include 

fuel volume, fuel size, arrangement and continuity of fuels, and fuel 

compactness. 

Fuel volume is the quantity of a given fuel type, typically measured in tons per 

acre. This measure is meaningful only if is contextualized; for instance, it can be 

compared with a historical or natural condition, or a desired target volume. 

Fuel size affects the rate of spread and residence time of fire. The size of the 

material determines the speed of ignition and rate of consumption. For example, 

in selecting kindling for a cooking fire, smaller, lighter materials are used to start 

the fire and to generate enough heat to ignite the larger, longer-lasting material. 

Fuels are normally categorized into two size classes: fine and heavy. Fine fuels 

are generally those less than o inch in diameter; these include grasses, pine 

needles, twigs, and smaller branches. Heavy fuels have larger diameters, are 

more difficult to ignite, and are consumed much more slowly. In general, fine 

fuels determine how easily a fire ignites and how fast it spreads, and heavy fuels 

determine how long the fire persists in a given area (residence time). 

Arrangement and continuity describe how fuels lie in relation to one another 

on both horizontal and vertical axes. On the horizontal axis, conditions are 

described as patchy or uniform. On the vertical axis, conditions are described in 

terms of the presence and condition of ladder fuels. Uniform distribution of fuels 
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Nonburning Alternatives for 

Vegetation and Fuel Management 19 

November 2002 

J&S 01-562 

facilitates a complete, rapid burn. Laddering creates conditions for fire to spread 

into the crowns, where it can move faster and be more difficult to control. 

Fuel compactness generally refers to surface fuels. Fire burns more rapidly in 

loosely compacted fuels because of the availability of oxygen. Compacted fuels, 

such as piled logging debris or duff, burn more slowly due to lack of available 

oxygen. 

Topography 

Topography is the relief of the proposed treatment area. It describes the angle of 

slopes, the narrowness of canyons, and the elevational variations within a given 

area. Topography affects fire behavior in several ways; it can influence regional 

airflow patterns, and fire itself can respond to steep slopes because of heatís 

propensity to rise. Moreover, the character of the terrain serves as a criterion to 

evaluate the reasonableness of treatment options. For instance, slopes steeper 

than 40% are considered (in the context of this document) too steep to use 

mechanical equipment safely; accordingly, mechanical treatment must be 

excluded as a treatment option. 

Accessibility 

Accessibility generally addresses the existence of roads in or near the treatment 

area as well as the degree to which the area admits movement within it. Roads 

are necessary for transportation of mechanical equipment, workers, and any 

materials that may be transported offsite for utilization or disposal. While 

presence of a road system does not automatically qualify a mechanical treatment 

option as reasonable, the absence of roads generally precludes mechanical 

treatment as a viable option. Moreover, particularly rugged terrain or extremely 

dense vegetation must be considered in determining whether specific kinds of 

equipment, or even work crews, can navigate the treatment area. 

Theory of Fuel Load Management 

The fundamental objective in developing a vegetation and fuel load management 

strategy is to modify the behavior of fire that may enter the proposed treatment 

area. As discussed in Chapter 2 (Vegetation Management: To Burn or Not To 

Burn), the fuels can be modified by either removing them or redistributing them. 

Initial activities are generally directed towards the surface and ladder fuels, 

because these are the fuel types where fires typically ignite and spread. 

Treatment of surface fuels can reduce risk of ignition, particularly in areas of 

high levels of human use or where the surface fuels exhibit a high degree of 

continuity. Treatment of ladder fuels helps to decrease the risk of a more 
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Nonburning Alternatives for 

Vegetation and Fuel Management 20 

November 2002 

J&S 01-562 

dangerous crown fire. However, the sequence and methods of treatment are 

wholly dependent on site-specific conditions. 

In any case, the initial target of any treatment program will typically be the fine 

fuels, because these pose the highest risk for ignition and spread of fire. Whether 

material is modified and left on site or removed depends upon site-specific 

conditions, both technical and financial; however, it should be borne in mind that 

fuels left on site remain fuels, and may require additional treatment to achieve the 

desired future condition. For example, if ladder fuels require aggressive 

treatment and are cut and scattered on site, they are merely transformed into 

surface fuels. Depending on the preexisting conditions, additional treatment 

might be required to alleviate the resultant excessive surface load. 

Treatment Options 

Four categories of treatment options are available: manual/hand, mechanical, 

grazing, and chemical. These four categories are not mutually exclusive, and 

treatments frequently entail a combination of methods. Each category includes 

specific techniques appropriate to various conditions and situations. 

Manual/Hand 

Hand work involves picking up and moving limbs and brush, as well as cutting 

downed and standing materials using hand tools or chainsaws. The required 

levels of skill range from unskilled to skilled (e.g., the ability to use a chainsaw 

safely). Manual methods usually entail a fairly large crew. Constraints on 

manual methods are: fuel size (up to 9 inches in diameter); accessibility of the 

site (e.g., slope, density of understory, rocks, safety); limited opportunity to 

utilize materials; slow production rate (defined as the acreage that is treated per 

unit of timefor example, acres per day); and needs (support, safety, sanitation) 

of personnel. 

Manual worklifting, cutting, and carrying forest materialsis generally 

limited to materials of roughly 9 inches or less in diameter. Larger materials can 

be handled, but efficiency, production rate, and safety decrease rapidly as size 

increases. If the fuels requiring treatment exceed the 9-inch-diameter threshold, 

hand work is not a good option. 

Although hand crews are not subject to the same constraints of access and 

mobility as mechanical equipment, such constraints must nevertheless be 

considered. Steeper slopes become decreasingly efficient and increasingly 

hazardous. Density of vegetation can impede access to the work site and 

movement within it. 
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Vegetation and Fuel Management 21 

November 2002 

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Hand work rarely generates material for utilization. It is difficult and inefficient 

to carry material to a location where it can be transported off site. Firewood is 

often collected manually, but most other types of utilization require machinery to 

enter the area being treated. 

Hand treatments usually address rearrangement as opposed to removal of fuels. 

While this can be an effective treatment in certain conditions, it is typically a 

short-term solution. Alternatively, it can be used as a primary treatment that is 

followed by burning to consume residual material; the site is subsequently 

managed by prescribed maintenance burns. 

Production rate is determined by the structure of the fuels being treated; for 

example, a dense stand takes much longer to treat than an open stand. Moreover, 

a fairly large workforce is required to treat areas in excess of a few acres; a larger 

workforce, if it is to be efficient, requires close coordination and a structured 

organization system. 

Advantages of hand work include the low level of ground disturbance, the ability 

to work on steeper slopes than is feasible for many kinds of mechanical 

equipment, and the ability to treat sensitive habitats such as riparian areas. 

Cut and Scatter 

Hand crews cut and scatter material to change the vertical and horizontal 

continuity of the fuel load. This technique increases the surface fuel load by 

redistributing ladder fuels onto the ground surface. It is appropriate where stand 

density is generally low and existing surface fuels are shallow. An upper depth 

limit for scattered material is generally prescribed. 

Pile 

Cut material can be piled either by hand or using mechanical equipment. As in 

the cut and scatter method, the fuel load is redistributed rather than reduced. 

Piling of materials disrupts horizontal continuity to a greater degree than does 

scattering; it is frequently used as a secondary treatment for material left from a 

primary treatment method. Piling can be used in denser stand conditions than 

can scattering because the piles can be situated to avoid fuel loading problems. 

Because continuity of the surface load is disrupted, increased surface loading is 

of less concern than it is with the scatter method. However, there are drawbacks 

to the piling of cut material: piled material decomposes more slowly than 

scattered material, piling can be quite labor intensive, and dense stand conditions 

can result in a high number of piles. 
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Nonburning Alternatives for 

Vegetation and Fuel Management 22 

November 2002 

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Mechanical 

Mechanical treatments employ equipment as the primary method of modifying or 

removing fuels. Mechanical treatments include mowing and masticating as well 

as traditional harvest operations. A common feature of mechanical treatments is 

the need for access. Generally, treatment areas must be within approximately o 

mile of an existing road system. 

In general, mechanical equipment consists of two components: the prime mover

and the head. The prime mover is the power source and carrier; it can be rubber 

tired, rubber tracked, steel tracked, or stationary. The head is attached to the 

prime mover; heads can be fixed mounted, limited movement mounted, or 

attached to an articulating arm. A wide variety of permutations are available for 

use on different kinds of terrain and to address different fuel types and structures; 

a detailed catalogue of specific equipment types is provided in Appendix __. 

In recent years the array of equipment available for vegetation and fuel load 

management has expanded dramatically. Many innovative methods and designs 

have evolved from technology that was developed for the logging and heavy 

construction industries. For example, an excavator developed for heavy 

construction is often employed as the prime mover for a head designed to shred 

or chip large-diameter fuels. 

Pile 

Material can be piled mechanically as well as by hand. See the discussion above 

for a description of this techniqueís advantages and disadvantages. 

Fuel Modification 

In this suite of techniques, machinery is used to process the material into smaller 

pieces that can then be redistributed on the ground surface or removed from the 

site. Because materials processed in this fashion can be much more densely 

packed than materials that are scattered by hand or piled, the available oxygen 

supply is reduced, thereby inhibiting spread of fire and flame height. 

Fuel modification falls into three broad categories. The first, Masticate/Mow, 

involves the reduction of material on site and in place; such material is intended 

to be left. The second, Chip/Grind, involves a piece of equipment into which 

material is placed for processing, and from which material is discharged through 

a chute. Chip/grind methods are more appropriate for biomass removal because 

the system lends itself to placing processed material directly into a conveyance 

vehicle. The third, Crush, involves crushing and compaction of smaller materials 

(e.g., brush, slash, small trees) on site. 
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Nonburning Alternatives for 

Vegetation and Fuel Management 23 

November 2002 

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Masticate/Mow 

Mastication involves the processing of standing or downed material where it 

occurs; generally a blade or other mechanism is applied to the fuel. This 

approach is suitable for denser stand conditions than is scattering or piling, and 

the redistributed fuel load decomposes more rapidly than scattered or piled 

materials. It is most appropriate for treating both green and dead ladder fuels and 

the higher surface fuels; however, it should be borne in mind that mastication is 

generally constrained from operating with a foot or two from the ground. Like 

other mechanical treatments, mastication is restricted to areas with suitable 

access and slopes less than 40%. The distribution of masticated material may 

inhibit plant growth. The effects of fire on areas that have been treated with 

mastication are not well documented; it is possible that such areas may be subject 

to increased residence time if fire does occur. 

Mowing is primarily appropriate to treat grassland and light shrubland habitats. 

It is grouped with mastication because, like mastication, mowing processes the 

vegetation material on site and in place. 

Chip/Grind 

Chipping/grinding, like mastication, reduces materials into small pieces. 

However, as mentioned above, in this group of methods, material is placed into a 

piece of equipment and discharged, often through a chute; because of this feature, 

material can be processed more selectively and transported off site for either 

disposal or utilization. Chipping/grinding can be employed in conjunction with 

other treatment methods, both manual and mechanical, that create smaller 

materials as a byproduct (e.g., tree removal, hand cut and pile). It is the method 

of choice when utilization of biomass is an option. 

Crush 

Crushing is another form of mastication; this technique is useful primarily in 

shrubland habitats dominated by brittle species, such as some of the manzanitas. 

Some specialized applications have been developed facilitating treatment on 

steep slopes, making this option particularly suited for habitat types that occur in 

arid and semi-arid portions of southern California. 

Tree Removal 

Numerous approaches to tree removal have been developed as the timber 

industry has evolved to operate in a variety of habitats and under myriad political 

and economic constraints. This document addresses three broad categories of 

tree removal for possible inclusion in development of nonburning fuel 

management strategies: bole removal, whole tree yarding, and cut-to-length 

logging. 

Bole Removal 

This is traditional harvesting. Trees can be felled either by hand or mechanically; 

the bole is then removed by a variety of mechanical systems, depending on the 
 Chapter 3 

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Vegetation and Fuel Management 24 

November 2002 

J&S 01-562 

conditions, and transported off site for processing. Bole removal eliminates the 

vertical continuity of the fuel load, but increases surface fuels with the addition 

of leaf/needle and limb materials. Overall biomass is reduced. Bole removal, 

because of its dependence on mechanical equipment, is restricted to areas near 

roads and on relatively shallow slopes. Moreover, this technique removes that 

portion of the forest structure that is at least risk from fire, while leaving the 

components normally addressed by fuel management programs (i.e., leaf/needle 

and limb material). However, a wide variety secondary treatments can succeed 

bole removal as fuel management activities. The critical point is that the 

subsequent treatments determine the efficacy of bole removal as a component of 

a fuel management activity. Accordingly, although bole removal in and of itself 

can in some instances be employed to accomplish specific fuel management 

objectives (e.g., creation of firebreaks, home protection, disruption of canopy 

continuity), it is not generally accepted as a vegetation or fuel load management 

technique, and is not addressed as such in this document. 

Whole Tree Yarding 

Trees can be felled either by hand or mechanically; the entire tree is then brought 

intact to a staging area, where it is processed into a variety of products. This 

method removes the vertical continuity of the fuel load, removes biomass, and 

adds very little to the surface fuel load; moreover, the removal of leaf/needle and 

limb material is more important than bole removal in the context of fire behavior. 

Material more than 9 inches in diameter can be utilized. However, because 

branch scarification resulting from removal of larger diameter materials (e.g., 

>18−24 inches, depending on species) can damage soils and adversely affect 

water quality, this technique is only appropriate for trees of moderate diameter 

(e.g., 9 to approximately 18 inches). 

Cut-to-Length Logging 

Cut-to-length logging utilizes specialized equipment to cut and process entire 

trees on site in the forest. While much of the biomass either remains onsite or 

must be addressed through secondary treatments, an important advantage of this 

technique is its efficacy in treating material of very small diameter. Moreover, 

the nature of the equipment renders it less likely to inflict ground damage in 

treatment areas, and the removal of small, dense trees can be conducted to 

improve health and vigor of remaining trees. While cut-to-length logging is 

more expensive than whole tree yarding, it is suitable for stand conditions that 

preclude use of the latter method. 

Chemical 

Chemical treatments entail the application of herbicides. It should be 

emphasized that chemical treatments do not remove fuels, but either kill existing 

vegetation or inhibit growth. In general, chemicals are appropriate to treat 

flashy, understory growth such as the weedy vegetation under power 

transmission lines or along railroad rights-of-way. Alternatively, chemical 

treatments can be used in conjunction with other treatment types, including 
 Chapter 3 

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Vegetation and Fuel Management 25 

November 2002 

J&S 01-562 

prescribed burning, to extend the period between necessary management 

activities. 

A widely-used chemical treatment in vegetation and fuel management programs 

is called brown-and-burn. In this technique, pesticides are used to kill target 

species of understory vegetation, converting live fuel to dead fuel. The chemical 

treatment can be applied in spring, when nontarget species remain green, thereby 

facilitating a prescribed burn to remove the vegetation that has been rendered 

flammable. However, because this technique is properly a preburning procedure, 

it cannot be considered a nonburning alternative. 

The utility of the growth-inhibiting function of chemical treatment types is 

exemplified in the maintenance of defensible fuel profile zones (DFPZs). DFPZs 

are shaded firebreaks, typically along ridgetops, where mechanical or manual 

treatments have been applied to reduce fuel loads and create an area where, in the 

event of a wildfire, the decreased fuel load will retard the spread of the fire and 

fire crews can work at containment and control of blaze. Periodic chemical 

treatments could be used to maintain the desired fuel characteristics within the 

DFPZ, obviating mechanical or prescribed burning treatments for many years. 

The drawbacks to chemical treatment methods include very stringent regulatory 

requirements, the possibility of adverse impacts on water quality, destruction of 

species that are not target species, toxicity levels, and negative public opinion. 

Because chemical treatments have limited efficacy in directly addressing existing 

fuel load management problems, they are not discussed further in this document. 

However, under certain site-specific conditions they remain potentially useful 

options. 

Grazing 

Grazing involves the use of livestockprimarily cattle and goatsto manage the 

growth and composition of brush and grasses. While it is of limited utility in 

forested habitats, it can be an effective technique in rural residential areas, in the 

urban-wildland interface, and in selected grassland and shrubland habitats. 

Moreover, research has shown that in some habitats, carefully managed grazing 

programs can be used to restore degraded ecosystems to historical conditions. 

For example, in dry rangeland areas, grazing has been used to convert nonnative 

annual grassland habitat to perennial bunchgrass communities. While the 

applications of grazing are limited within the scope of habitats addressed in this 

document, it is nevertheless a technique that enjoys little political resistance and 

requires a minimum of financial investment. 
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Environmental Considerations 

The primary goals of promoting nonburning alternatives for wildland regions are 

to avoid the environmental impacts of burning on visibility and air quality and to 

eliminate the risk of escapes, which can threaten human life and property as well 

as natural resources. While nonburning alternatives may achieve the desired 

results in terms of air quality, attention must be given to other environmental 

impacts. For example, use of heavy equipment on sensitive soils can result in 

soil compaction, and the resultant erosion can lead to ecosystem damage as well 

as degradation of water quality. Consideration of such potential impacts should 

constitute part of any analysis of alternatives. 

The criteria by which to evaluate potential environmental impacts are frequently 

too site-specific to fall within the scope of this document. However, 

environmental impacts should be examined in the context of the resource areas 

listed below. It should be borne in mind that any given criterion might be 

decisive in a given situation; in a different situation, however, the same criterion 

might be irrelevant. 

! Adverse impacts on air quality. Although a primary motivation for 

selecting nonburning over burning treatment options is the vast reduction of 

adverse impacts on air quality, it must nevertheless be understood that even 

nonburning alternatives may create some adverse effects. For instance, 

mechanical equipment produces vehicular emissions, and the movement of 

heavy equipment can give rise to fugitive dust emissions. These effects 

should be considered during any environmental review process necessary to 

approve a vegetation and fuel management plan. 

! Soil compaction. Soil compaction is of particular concern when conducting 

mechanical treatments. Passage of heavy equipment can compact soils; 

compaction can impede permeability, which in turn can reduce groundwater 

recharge and increase surface runoff. Moreover, the removal of air spaces in 

the soil can impair the soilís ability to support root development. 

! Water quality degradation. Soil compaction can increase runoff, posing 

potential threats to water quality. Additionally, removal of vegetative growth 

can, by eliminating demand for surface and shallow subsurface water, also 

increase surface runoff. Increased surface runoff can exacerbate erosion, 

degrade riparian habitats, and discharge damaging quantities of sediment into 

watercourses. 

! Removal of nutrients from site. An important component of any ecosystem 

is the recycling of nutrients back into the soil. In fire-adapted habitats, 

periodic naturally occurring fire is a significant mechanism of nutrient 

recyling; the complex processes of decay and deterioration are also 

important. Prescribed burning can mimic the role of naturally occurring fire 

in nutrient recycling; however, nonburning alternatives that remove 

substantial quantities of biomass can interrupt this cycle. It is important to 
 Chapter 3 

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Nonburning Alternatives for 

Vegetation and Fuel Management 27 

November 2002 

J&S 01-562 

consider the impacts of various treatment options on nutrient recycling when 

developing a vegetation or fuel management strategy. 

! Undesirable impacts on wildlife habitat. Many materials that constitute 

potentially problematic fuels can also serve as important components of 

wildlife habitat. For example, snags provide breeding habitat for a variety of 

species; surface vegetation provides cover for birds, mammals, reptiles, 

amphibians, and invertebrates; and surface litter can provide an important 

substrate for small vertebrates and invertebrates. Although any habitat 

modification can adversely affect wildlife habitat, well-designed vegetation 

and fuel management programs should, in the long term, have generally 

beneficial effects on habitats on the landscape scale. 

! Threatened and endangered species. While it must be accepted that any 

habitat modification will affect plant and wildlife habitat, particular care 

must be given to habitat that supports or that could support threatened or 

endangered species. In some cases, even seemingly insignificant 

modifications can have far-reaching effects on certain species. A careful 

review should be made of special-status species that could occur in the 

treatment area, and a thorough evaluation of the impacts of alternative 

treatments on such species should be conducted. 

! Augmented spread of undesirable species. Many invasive plant species 

exploit areas of soil disturbance; such areas can be created by 

implementation of various treatment methods, especially mechanical 

methods. Additionally, equipment can transport seeds of invasive species on 

tires and treads. Practices and procedures incorporated into the vegetation 

and fuel management plan can reduce the effects of this impact. 

! Augmented disease/pest impacts. The process of cutting trees and brush 

precipitates vegetative production of pheromones that serve as attractants to 

pests such as woodboring beetles. An influx of such pests can cause damage 

to remaining vegetation, particularly if stands have been compromised by 

earlier conditions. This potential impact must be carefully addressed in the 

development of a vegetation and fuel management strategy. 

! Adverse impacts on cultural resources. The potential of inflicting adverse 

impacts on cultural resources is largely associated with mechanical treatment 

optionsthat is, the risk of mechanical equipment crushing resources that 

may be present on or immediately beneath the surface. The environmental 

review process to which most treatment plans (particularly those on public 

lands) are subject should address the likelihood of such resources being 

present in the treatment area.

Economic Considerations 

Conventional wisdom suggests that, as a rule, nonburning alternatives are more 

expensive than burning. While there are arguments both to support and to refute 

this contention, there is another perspective that is perhaps more pressing to 
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Nonburning Alternatives for 

Vegetation and Fuel Management 28 

November 2002 

J&S 01-562 

consider: namely, that the fuel load crisis facing western wildlands is far too 

acute to relegate to the marketplace. The management actions that are the subject 

of this report comprise a response to conditions that have resulted from more 

than a century of unfortunate management decisions. The condition of the 

western wildlands will not dissipate if left to its own devices, and each year that 

passes without significant action to address the problem increases the extent and 

risk of catastrophic wildlife. While any revenues that can be generated from 

vegetation and fuel management activities should be welcomed as offsets to the 

costs, the driving intent of such programs should not be financial but rather 

should be based upon the desired future conditions of the wildland habitats 

subject to the management actions. 

In examining the question of burning versus nonburning treatments, several 

financial considerations come to light. First is the direct cost of the treatment 

method; as stated above, it is generally accepted that burning is less expensive 

than nonburning alternatives. Second, though, one should consider the indirect 

costs; for example, the societal costs of impaired air quality in increased health 

care expenditures, reduced tourist revenues, and resource loss. Third, and 

perhaps most compelling, is the risk of escape which, as has been discussed 

previously, can lead to catastrophic and unanticipated costs. 

However, such a discussion is beyond the scope of this document, and would 

likely require intensive data collection and analysis. Accordingly, this report 

focuses on those financial considerations associated with fuel treatment. These 

considerations are cost per unit of production, production rate, labor 

requirements, skill requirements, risks of collateral damage, and the potential 

generation of revenue from materials produced through the treatment method 

selected. 

Because nonburning alternatives may be more expensive and logistically 

complex than burning, they can present greater challenges in securing financing. 

The potential of an alternative to generate revenues, the availability of funding 

mechanisms, and access to professional advice and guidance should be examined 

during development of the most appropriate fuel management strategy. After 

considering the types of fuels present and the treatment options available, the 

land managers must then consider funding sources and access to technical 

assistance or expertise. 

Costs of Treatment 

As discussed above, the direct costs of nonburning alternatives tend to exceed 

those of prescribed burning. Hand crews can be less expensive than other 

options, but they tend to be most useful in treating rather restricted areas. The 

cost of mechanical treatments vary widely; regional availability of equipment and 

personnel can vary tremendously depending upon a given areaís economic base. 

Techniques such as mastication that require specialized equipment and produce 

no utilizable material tend to be the most costly, but even conventional tree 
 Chapter 3 

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Nonburning Alternatives for 

Vegetation and Fuel Management 29 

November 2002 

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removal techniques can be prohibitively expensive if it is necessary to transport 

equipment and personnel from out of state. 

Infrastructure Conditions 

Infrastructure essentially refers to existing facilities, equipment, labor, and 

transportation that might be available to implement a desired treatment option. 

Accordingly, the economic implications of infrastructural constraints are sitespecific; if the treatment area is in a region that traditionally supportsor until 

recently did supporta forest products industry, then the infrastructure will 

likely be available to support mechanical nonburning alternatives. Perhaps the 

most critical consideration in this context is the cost of transporting either labor 

and equipment to the treatment area or generated materials to the facilities 

necessary to process them. This is discussed at greater length in Chapter 4 

(Getting to Work: How to Build a Nonburning Strategy). 

Utilization 

Definition of Utilization 

Vegetation management activities associated with fuel reduction can result in the 

generation of usable materials, which in turn can be sold for profit. For the 

purposes of this document, utilization refers to the use of materials that are 

generated by treatment activities. 

When evaluating the feasibility of utilization as a component of a treatment 

option, it is necessary to consider the costs of generating the material and 

transporting it off site, the cost of remanufacturing the material into a form that 

generates revenue, and the potential of selling the product to the end user. 

Another consideration can be additional support outside of market interactions, 

generally referred to as subsidies or price supports; these can be used to offset 

costs when market prices do not equal production costs. The feasibility of 

utilization is determined by these costs and by market conditions such as industry 

capacity, capitalization, and labor. This document addresses the utilization 

process from the generation of raw material to its sale to the remanufacturer. 

Utilization Benefits 

As has already been discussed, the primary objective of any vegetation or fuel 

management program should be achievement of the desired future condition. 

However, when the appropriate treatment option is likely to produce utilizable 

material, or when production of such material might be the decisive factor in 

selecting between alternative methods, then such potential should be considered 
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in the decision-making process. Utilization can be undertaken to generate profit 

or to offset the cost of the treatment program. 

! Profitable transactions occur when (a) useful materials are generated and (b) 

the resultant transactions cover all extraction and transportation fees and 

produce a margin of profit for the landowner/manager. Profitable 

transactions are generally market driven. 

! Cost offset transactions reduce the cost of treatment that is undertaken to 

attain condition goals rather than to generate profit. 

When generation of useful material is not the primary motivation, cost offset 

transactions can be important to implementing the necessary fuels management 

program. Such transactions can comprise a combination of product sales, cost 

sharing, price supports, and grants that provide monies to offset the costs of 

extraction and transportation not covered by market transactions. 

In addition to useful products generated directly by fuel reduction activities, 

indirect benefits, such as increased revenue from recreation (e.g., camping, 

hunting, fishing), can result from fuel reduction activities. However, because 

such indirect benefits are difficult to describe and quantify and are generally very 

case- or site-specific, they are beyond the scope of this document. 

Types of Products Generated 

Products that may be generated by nonburning treatment activities can be broadly 

divided into two categories: industrial and nonindustrial. Industrial products are 

those that are available in large quanitities, consistently, or over large 

geographical areas. Nonindustrial products are generally associated with 

lifestyle-related or aesthetic enterprises; these tend to be used in producing 

specialty or value-added products. 

Industrial Products 

Below is a general list of industrial products than can be generated by some 

vegetation and fuel load management programs. 

! Whole logs 

" lumber of varying grades 

" molding and finish pieces 

" engineered wood products (e.g., glued laminates, finger jointed material) 

" peeled veneers (e.g., finish veneers, plywood) 

! Round wood 
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" fencing material 

" vertical support elements (poles) 

" beams, joists, and truss elements 

! Cord wood 

" firewood 

" low-grade fencing material 

" pulp for paper 

" extractive products (e.g., mineral spirits, alcohol) 

! Clean chips 

" high BTU combustible uses (steam generation for power) 

" engineered wood products (e.g., flake board, oriented strand board) 

" pulp for paper 

" extractive products (e.g., mineral spirits, alcohol, sugars) 

! Dirty chips 

" lower BTU combustible uses (e.g., drying operations, heating) 

" mulch 

" animal bedding 

Energy-related products include firewood, fuel for drying kilns, and fuel for 

cogeneration plants. Energy products typically yield the lowest return of the 

spectrum of forest products that can be produced by vegetation and fuel 

management programs. In general, market decisions are based on site-specific 

and regional market conditions. 

Nonindustrial Products 

Nonindustrial products typically entail a high value-added component because of 

the skill required to create them, the inherent attractiveness of the material used, 

or limited availability. Examples include musical instruments, turned wood 

products, specialty cooking woods or charcoals, canes and walking sticks, and 

basket materials. While they generally do not produce industrial-scale benefits, 

these products may cumulatively provide substantial incentive because of the 

high value added; moreover, they offer some intriguing opportunities for creative 

entrepreneurial undertakings, particularly in areas that have suffered economic 

depression as a result of the flagging timber industry. 
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November 2002 

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Utilization Constraints 

Although useful material may be generated by vegetation management activities, 

there are often constraints to successful utilization. For instance, lack of demand 

or global competition can depress prices beyond the threshold of practicality. 

The material recovered may not meet industry standards in either the quality or 

quantity required to warrant commercial exploitation. The infrastructure 

necessary to extract, transport, or process recovered materials may be lacking due 

to mill closures, suppression of the lumber industry, or a shortage of skilled 

labor. Regulatory requirements can create costly and time-consuming constraints 

to pursuit of management activities. These issues are discussed in greater detail 

in Chapter 4 (Getting to Work: How to Build a Nonburning Strategy). 

Funding Sources and Fuel Management Programs 

Because nonburning alternatives may be more expensive than burning, greater 

effort may be necessary to secure funding to implement them. Potential sources 

of funding for nonburning alternatives generally fall into two categories: 

utilization earnings and program grants. Utilization has been discussed above. 

Program grant monies are acquired by applying to agencies or nonprofit 

organizations for financial assistance with fuel reduction efforts. 

The NFP, the most notable grantmaking program associated with vegetation and 

fuel load management, has significantly changed the nature of fuel management 

funding. The NFP has in the last few years greatly increased the amount of 

funding available for firefighting, restoration, hazardous fuels reduction, and 

community assistance. This availability of funds has in turn increased the 

number of fuel management projects currently being implemented in the western 

United States and nationwide. 

The USDA Forest Service and the Department of the Interior are currently in the 

second year of implementing the NFP. Congress provides substantial support, as 

evidenced by more than $2.26 billion allocated for the NFP in the Interior and 

Related Agencies Appropriations Act for fiscal year 2002. This amount includes 

$1,590,712,000 for the Forest Service and $678,421,000 for the Department of 

the Interior. 

The NFP facilitates collaboration of federal, state, tribal, and local governmental 

and nongovernmental representatives for the purpose of improving the 

management of wildland fire and hazardous fuels, as well as meeting the need for 

ecosystem restoration and rehabilitation on federal and adjacent state, tribal, and 

private forest and rangelands. The NFPís 10-year comprehensive strategy 

outlines a new collaborative framework to facilitate implementation of proactive 

and protective measures that are appropriate to reduce the risk of wildland fire to 

communities and the environment. 
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November 2002 

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While NFP funds dominate fuel management funding options, other sources are 

available. Appendix B provides a partial list of funding sources available for fuel 

management efforts. 

Many programs dedicated to fuel management and other fire-related issues have 

evolved in recent years, both independently and as a result of the NFP. In 

addition to national programs such as the NFP and Firewise, many western states 

have instituted programs to assist private landowners and public land managers 

in managing and reducing fuel levels. Some communities have also initiated 

programs to manage local resources (e.g., Kootenai County, Idaho). 

National, state, and local fuel management programs offer assistance to fuels 

managers in a multitude of ways. Fuels management programs may provide 

technical assistance to land managers. Program representatives can impart 

knowledge and guidance in project design, financing, and implementation. 

Appendix C provides a partial list fuels management programs currently 

operating in the western states. This list was compiled from interviews with state 

representatives and from internet research. The list is not exhaustive; rather, it is 

representative of the array of national, state and local programs available to land 

managers. 

Labor Sources 

The availability of labor sources to perform fuel management work is an element 

of project implementation that should be considered following the identification 

of fuel conditions and treatment options. Landowners and land managers should 

assess the availability of manual and specialized laborers. Certain treatments, 

such as hand piling, require unskilled manual labor by a relatively large work 

force. Other treatments require specialized skills in operating machinery or 

equipment. 

Some areas may suffer a shortage of available labor; others may have a surplus 

due to an expanding pool of unemployed loggers or other laborers. In some 

cases, land managers may need to hire out-of-state contractors to perform fuel 

reduction and removal activities. 

Appendix D provides a list of some labor sources available in western states. 

While some states may currently rely on only a few of these sources for fuel 

management labor, all of them should be considered by landowners and land 

managers when seeking new labor. Land managers of new and future projects 

are encouraged to consider all potential labor options and to investigate which are 

available in their local areas. 
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Nonprofit Organizations 

Nonprofit organizations can often provide support to landowners and land 

managers in planning and implementing projects. For example, local university 

extension programs may offer technical assistance and professional expertise in 

developing fuel management projects. Some nonprofit organizations may 

provide volunteers to participate in labor-intensive activities such as hand piling. 

There are also opportunities for partnering with nonprofits to secure project 

financing and to share the responsibility for project implementation and success. 

Appendix E provides a partial list of nonprofit organizations throughout the 

western United States that could have an interest in fuel management projects. In 

addition to the obvious practical advantages, obtaining nonprofit participation 

can help to involve the local community in project planning, thus aiding in 

building popular support for the project. 

Sociopolitical Considerations 

Social and/or cultural considerations can play a critical role in developing a 

viable nonburning strategy. Some alternatives may have implications for certain 

groups, such as small landowners or residents of tribal land. Others are likely to 

provoke heated responses from certain community groups. Community groups 

that are predisposed in opposition to a particular type of treatment may have the 

organizational and financial resources to prevent or delay implementation. 

Even when the decision maker has evaluated a treatment option in the context of 

technical feasibility, environmental appropriateness, and affordability, another 

suite of potential constraints remain to be addressed. These less concrete but no 

less real sociopolitical considerations can include: 

! Health and safety concerns 

! Tribal concerns 

! Social justice 

! Resistance by resource agencies 

! Resistance by environmental groups 

! Resistance by industry groups 

! Resistance by community groups 

! Regulatory constraints 
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Barriers to Nonburning Alternatives 

There are numerous barriers that may discourage or prohibit the use of 

nonburning alternatives to manage fuels in the west. Table XX in Appendix XX 

lists barriers that were identified by respondents to the interviews conducted 

during preparation of this report. For this discussion, these barriers have been 

categorized in accordance with the four issue areas used throughout this 

document. 

1. Technical Constraints. These barriers include inhibited access to project 

areas due to topographical or climatic conditions or the absence of roads; 

proximity to residential or other developed areas; and lack of available 

infrastructure, equipment, or labor. 

2. Environmental Constraints. These barriers include presence of sensitive 

natural resources and the potential impacts of fuel treatments on these 

resources (e.g., sensitive soils, sensitive vegetation communities, presence of 

threatened or endangered species, water quality concerns); the potential for 

introduction or spread of invasive nonnative plant species or pathogenic 

organisms; and the presence of cultural resources. 

3. Economic Constraints. These barriers include lack of funding to perform 

fuels management treatments; lack of markets for utilization of material; cost 

of equipment and labor; cost of transporting utilizable material; and the need 

to generate profit from activity (required by some jurisdictions). 

4. Sociopolitical Constraints. These barriers include public opposition to 

specific treatment types; institutional resistance to new approaches; lack of 

available staff at relevant resource agencies; regulatory requirements; and 

non-statutory administrative obstacles to nonburning alternatives (discussed 

further below.

In its 1996 report to the EPA, the GCVTC provided emission management 

recommendations for area sources, including recommendations regarding fire. 

One of these recommendations suggested that the federal land management 

agencies and their state, tribal, local, and private counterparts should identify and 

remove non-statutory administrative barriers to emission reduction strategies by 

the year 2000, to the maximum extent feasible. 

The majority of activities on wildlands are regulated by agencies that plan, 

approve, and implement projects within an administrative framework. The 

administrative framework includes statutory and non-statutory barriers. Statutory 

barriers are laws, codes, and regulations. Non-statutory barriers are internal 

policies defined in an agencyís handbooks and manuals or formalized in 

approved land use or resource management plans or environmental documents. 

Non-statutory administrative barriers may be influenced by social, economic, 

cultural, or political factors. 

Non-statutory administrative barriers can include requirements for compliance 

with best management practices (BMPs), mitigation measures incorporated into 
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November 2002 

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National Environmental Policy Act (NEPA) documents or memoranda of 

agreement (MOAs), and policy-level decisions identified in resource and land 

management plans. For example, a BMP for use of mechanical equipment on the 

Plumas National Forest in northern California specifies a slope limitation beyond 

which use of mechanical equipment is prohibited. However, as new equipment is 

developed, it might become advantageous to allow mechanical treatments outside 

the parameters of the BMP, particularly under specific fuel conditions. In 

another example, BMPs incorporated into the MOA between the USDA Forest 

Service and the Tahoe Regional Planning Agency prohibit the use of mechanical 

equipment within the 100-year floodplain. However, if fuel load considerations 

warrant such work, it might be advantageous to suspend such prohibitions to 

reduce the greater risk of catastrophic wildfire. 

In conclusion, it should be emphasized that despite the many barriers that 

currently exist, there is great opportunity in the growing field of nonburning 

alternatives. Many of these barriers can be overcome by the simple expedient of 

communication and education; others may require adjustments to the 

administrative and regulatory framework within which fuel management 

programs must operate. In any case, the increasing degradation of air quality and 

the continuing crisis of overaccumulated fuel loads clearly warrant concerted 

efforts in promoting the development and implementation of nonburning 

alternatives to prescribed burning.
Nonburning Alternatives for 

Vegetation and Fuel Management 37 

November 2002 

J&S 01-562 

Chapter 4 

Getting to Work: 

How to Build a Nonburning Strategy 

Developing Alternatives 

There is, as has been asserted elsewhere in this document, no ìone-size-fits-allî 

approach to developing a vegetation and fuel load management strategy. In 

assessing the array of nonburning alternatives and designing a program, the land 

manager must evaluate the categories of considerations described in the 

preceding chapter in light of regional and site-specific conditions. This chapter 

discusses in greater detail the chains of reasoning that one might follow in 

proceeding through the analysis of possible alternatives. 

Technical Feasibility 

When beginning to develop a strategy for vegetation or fuel load management, 

the land manager must first consider what is technically feasible. Clearly, there 

is no virtue in navigating the sociopolitical hurdles for activities that either 

cannot be conducted or will not achieve the desired results. The first step in 

determining the appropriate methodology is to understand the fundamental 

relationship between vegetation structure and the various types of treatment 

options available. 

Methodology and Vegetation Structure 

Every methodology, burning and nonburning, is constrained by parameters 

which, in turn, are associated with the physical conditions of the proposed 

treatment area. To assist in the decision-making process, the authors have 

developed a conceptual model that illustrates the relationships of various 

treatment types with vegetation structure and with one another. 

This model simplifies the description of vegetation into two components: 

volume/density (measured in tons per acre) and average stem diameter. For 

analytical purposes, volume/density is represented on the x-axis of a simple 
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November 2002 

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graph, and stem diameter on the y-axis. It should be understood that the figures 

illustrating this model are merely schematic, and are not intended to accurately 

depict real-world situations. Similarly, the designation of average stem diameter

is a conceptual descriptor; for real-world application, the model must be adjusted 

to take into account relative densities of various diameters in the context of the 

specific vegetation types to be treated. 

Although there are many exceptions, this model suffices to describe the spectrum 

of vegetation structures. For instance, grassland habitat measures very low on 

both stem diameter and on volume/density; it is, accordingly, represented in 

Figure 4-1 as Prairie. A grazed field might be represented at a still lower 

volume, whereas a pampas of shoulder-high grasses would be depicted higher on 

the graph. Shrublands exhibit higher stem diameter, although sparse habitats 

supporting small shrubs might contain less volume/density than a tallgrass 

prairie. Forested habitats might exhibit dense stands of small-diameter trees 

(e.g., lodgepole pine) or sparse stands of large-diameter trees (e.g., eastside 

Sierran pine). 

The graphs reflect a schematic representation of the parameters within which 

treatment types are typically selected. It should be understood that the 

graphically depicted limitations are not absolute, but can be artificially forced 

beyond normal bounds. For instance, the lower limit of harvesting is determined 

by the economic feasibility of carrying out operations within a certain range of 

density and diameter of materials. It should not be inferred that tree removal 

cannot be implemented under conditions of lesser diameter or volume; rather, the 

implication is that such an operation would not be profitable and would, 

consequently, require a source of funding beyond the revenue generated by 

extracted materials. 

Traditional Treatments 

Burning 

The two vegetation management strategies traditionally employed on wildlands 

are harvesting and burning. Harvesting is associated with commodity 

production; burning is not. The conceptual model can be used to plot the 

boundaries of desirable, effective, and efficient conditions for each of these 

strategies. 

The plot for burning (Figure 4-2) shows that burning is an effective and 

controllable method for almost all volumes of small-diameter vegetation 

arrangements. As stem diameter increases (e.g., ~4−10 inches), the volume for 

which burning is a reasonable method decreases. This is because fire behavior 

intensifies; the fire is likelier to escape control and, as temperatures increase, may 

cause undesirable levels of mortality in the vegetative structure. However, fire 

regains practicality with further increase of stem diameter because substantially 

larger stems are likely to survive fire, particularly in more open stands. The 

upper limit for fire is primarily defined by controllability and potential resource 
 Chapter 4 

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November 2002 

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damage, although some areas outside the plot reflect conditions under which 

burning would be either inefficient or unnecessary. 

As mentioned above, it would be possible to implement a burning program above 

the area delimited on the graph; such a program, however, would necessitate 

artificial modification of one or more parameters. For example, a burning 

program under such conditions would likely require multiple entries, with 

primary treatments being conducted under such restrictive circumstances that 

only minimal treatment would be accomplished. Subsequent burns would be 

necessary to achieve desired final conditions, and each burn would extend the 

time required to accomplish the goals, increase the risk of escape, and further 

contribute to air quality impacts. 

Because the upper limit of the burning plot is essentially a function of risk, this 

boundary is, in a sense, a ìsoftî one. Especially in matters as difficult to quantify 

as natural systems and fire, risk is by its very nature a particularly subjective 

descriptor. Risk that is acceptable to a land manager might be out of the question 

to a small landowner. Moreover, a vegetation structure that would be too 

dangerous to burn under certain weather conditions could be reasonable to burn 

under others. Such variability and subjectivity can suggest that burning is a 

reasonable treatment for virtually all vegetation conditionsat least under 

certain circumstances. 

Such a perception can have dangerous implications. Land managers might, by 

waiting for a certain set of conditions, decide to use prescribed fire on vegetation 

structures for which such treatment would normally not be indicated. The 

decision might be driven by short-term financial considerations and could, 

consequently, have unfortunate results. The requisite conditions could so 

minimize the effects of fire that only limited benefits would be realized. 

Alternatively, while waiting for the optimum conditions to align, habitat 

conditions could alter enough that unwanted resource damage could occur; in 

extreme cases, such changes could lead to escape. Also, as discussed in Chapter 

2 (Vegetation Management: To Burn or Not To Burn), the constraints on 

requisite conditions could be so restrictive that the burn window might never 

open. 

Harvesting 

The plot for harvesting (Figure 4-3) is bounded by financial considerations. The 

bottom threshold represents the volume/density of material below which the 

mobilization of equipment and labor becomes economically unfeasible. The left 

boundary represents the weak market for small-diameter materials and, to a lesser 

extent, the limitations of equipment and technology for harvesting such materials. 

The plot illustrates that as diameters increase, the overall volume/density of the 

material can decrease; this reflects the fact that very large trees have more value 

per unit of volume than smaller trees. Accordingly, if the land manager chooses 

to implement a harvesting program on forestland of low volume/density, the 

financial equation must be modified: the material must have higher than normal 
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November 2002 

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value, cost of extraction must be lower, or supplemental funding must be 

secured. 

It should be noted that the left boundarythat reflecting a threshold of smaller 

diameter stemshas shifted towards the left over the last few decades. This is 

because the demand for wood and wood products has increased even as the 

number of available large trees has decreased; at the same time, mills that had 

been designed for large diameter logs have been retooled to accommodate 

smaller diameter materials. New harvesting equipment has also facilitated the 

shift. 

The Burn/Harvest Disconnect 

Figure 4-4 overlays the plots depicting harvesting and burning. Cursory 

examination reveals a significant gap in the range of vegetation structures 

suitable for treatment by the two traditional methods; in many cases, the 

vegetative structures represented by this gap are those most in need of treatment. 

The unavoidable implication of this gap is that either the limits of the traditional 

treatment paradigms must be forced to encompass the deficit, or a nontraditional 

paradigm must be developed to address those conditions beyond the bounds of 

traditional methodologies. 

Mastication and Biomass Removal 

Mastication 

Mastication in its simpler forms is far from a new concept. Mowing of grass and 

even larger shrubs has been used to manage vegetation in situations ranging from 

lawns and gardens to railroad rights-of-way. Only recently, however, has 

mastication been applied to forest habitats. 

The boundaries of mastication (Figure 4-5), and the factors those boundaries 

represent, are quite different than those of burning or harvesting. As in the case 

of harvesting, there is no risk factor limiting the level of volume/density for 

which mastication is appropriate. Mastication is suitable for even the finest 

fuels; the upper (right) limit of stem diameter corresponds almost precisely with 

the lower limit for harvesting. There are two reasons for this correspondence: 

first, the equipment used for mastication is not designed for large-diameter trees; 

second, larger trees have greater value when either left in the environment or 

harvested for market. Because mastication is a treatment option that is not 

intended to address market considerations, there is no lower limit of 

volume/density. 

Biomass Removal 

Biomass removal can be similar to mastication except that the material is 

removed from the site to be disposed or utilized. It can entail creation of 

chipping or mulching as well as whole tree yarding and, as discussed earlier, it 

entails a different suite of equipment. Depending on the particular type of 

biomass removal selected for the specific site, the boundaries can be the same as 
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November 2002 

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those for mastication (Figure 4-5) or can reflect whole tree yarding (Figure 4-6), 

which accommodates much higher stem diameters than mastication. The critical 

difference between mastication and biomass removal is that the material 

generated by mastication remains on site, whereas the material generated by 

biomass removal is transported from the site for disposal or utilization. 

If whole tree yarding is the selected method of biomass removal, and if the 

treatment is undertaken as a commercial venture, then the boundaries to left and 

bottom are roughly congruent with the boundaries depicted for harvesting. 

However, the upper limit of stem diameters is lower, because very large trees 

cannot be removed intact without causing severe scarification to soils. 

Site-Specific Considerations 

The general nature of the foregoing discussion, once again, should be used as a 

filter through which to evaluate available options. Specific project design must 

begin with site-specific conditions that have been previously discussed: 

topography, habitat type, fuel load conditions, road accessibility, and existing 

infrastructure. In the second part of this chapter, Assessing the Alternatives, a 

framework is provided for eliminating inappropriate techniques and making the 

most informed selection of those that remain. 

Environmental Feasibility 

When the field of possibilities has been narrowed, the land manager must 

consider the environmental impacts associated with treatment options that have 

been found to be technically feasible. Because the environmental considerations 

are so intimately connected with the location and character of the project site, it 

is impossible to address them in other than a very general fashion in this 

document. 

The treatment area should be thoroughly reviewed (through both literature 

reviews and field surveys, as appropriate) to inventory any sensitive resources 

that might be present on or adjacent to it; the proposed activities should then be 

evaluated to identify impacts that could result. Clearly, if listed species or other 

sensitive resources are identified, specific regulatory constraints can come into 

play; these must be addressed in keeping with the requirements of the jurisdiction 

that has authority over the site as well as with federal regulatory requirements 

(e.g., the Endangered Species Act, the Clean Water Act, the Migratory Bird 

Treaty Act). 

In some respects, the regulatory constraints might be more easily navigated than 

other environmental influences. As has been stated previously, any vegetation or 

fuel management program will have environmental effects. Some of these will 

inevitably be adverse effectsat least from certain perspectives. For instance, 
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November 2002 

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any mechanical treatment is likely to result in some degree of soil compaction. 

The land manager must objectively weigh both the short- and long-term impacts 

and benefits and be willing to make sometimes difficult decisions. Do the shortterm impacts of soil compaction and the temporary degradation of local water 

quality that might result from excess surface runoff outweigh the impact on air 

quality that would result from prescribed burning? Does the temporary loss of 

nesting habitat for raptor species outweigh the risk of catastrophic wildfire? In 

some instances the answer will be virtually self-evident; in others the decision 

might be driven not by clinical scientific analysis but by local political 

considerations. 

With this in mind, it should be pointed out that environmental have driven the 

preponderance of the changes in land management in recent decades. 

Environmental regulation has profoundly altered the timber industry; 

environmental concerns have also precipitated many of the technological 

modifications that have increased the range of treatment options discussed in this 

document. For instance, a shift from wheeled to tracked vehicles has been 

fostered by concerns over soil compaction (tracked vehicles are less damaging 

because the vehicleís weight is more widely distributed than that of wheeled 

vehicles). 

In all cases, the land manager must carefully evaluate the options, their relative 

costs and benefits, and the strategy that may be necessary to promote the desired 

program. The environmental feasibility is inextricably linked with sociopolitical 

considerations; this is discussed further in Sociopolitical Feasibility below. 

Economic Feasibility 

The cost of implementing nonburning alternatives is the single most challenging 

financial consideration to overcome; the previous chapter discussed potential 

funding mechanisms and fuel management programs, and Appendices _ and _ 

provide lists of these sources and programs. However, in cases where there is 

reason to consider utilization as a means to fund or offset the cost of treatment, it 

is necessary to examine barriers related to industry infrastructure. 

In many areas of the western United States, adequate industry infrastructure is no 

longer available. Mills were at one time abundant throughout the country; now, 

however, only certain areas remain capable of processing forest products. Mill 

closures over the last several decades dismantled infrastructure beyond the loss 

of the mills themselves. Once a mill closes down the equipment is sold, industry 

experts relocate, associated businesses fail, and the communityís ability to 

reengage in the processing of forest products is severely compromised. 

Additionally, mechanical equipment used for treatment activities is likely to be 

sold or relocated to regions where the industry is still viable. 

The location of a project area is perhaps the most critical variable in assessing the 

cost of undertaking the project. The proximity of a treatment site to processing 
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facilities can determine the feasibility of utilizing materials generated by 

nonburning alternatives. Presence of a pulp mill or cement plant (cement plants 

represent a potential market for dirty chips) within 100 miles of a project site can 

encourage the use nonburning methods because generated materials can be 

readily sold. In areas such as the Pacific Northwest where numerous mills still 

exist, the utilization of materials tends to be relatively affordable and practical. 

On the other hand, if processing facilities are not reasonably accessible, the cost 

of transporting the material can exceed the revenue generated by its sale. 

Moreover, in regions where mills have been retired or where the forest products 

industry has never become established, land managers can be forced to hire 

contractors from as far as two states away to carry out nonburning treatment 

activities. The cost of nonburning alternatives soars when material must be 

transported great distances or when contractors must be recruited from outside 

the region. 

One hopeful solution to the financial quandary is the cogeneration industry, 

which could provide a viable market for biomass removed from treatment areas. 

Cogeneration entails combustion of biomass to produce both electricity and heat; 

cogeneration plants are typically designed and built close to the source of fuel 

and the site where the energy and heat will be consumed. Unfortunately, this 

industry is still in its infancy; accordingly, it is currently a reasonable option only 

in certain areas. Other biomass utilization technologies, such as biomass 

gasification and the production of ethanol, also suggest a promising future, not 

only in increasing the economic feasibility of nonburning alternatives but also in 

further reducing air quality impacts. 

Sociopolitical Feasibility 

The sociopolitical hurdle should probably be the last one crossed, because the 

outreach, education, and negotiations involved in crossing it would all be wasted 

if the selected nonburning alternative were found to be impractical or infeasible 

for some more prosaic reason (e.g., technical constraints or presence of a highprofile endangered species). Nonetheless, the sociopolitical considerations are 

quite serious, and many projects meet their demise because the proponents fail to 

pay sufficient heed to the human factor. 

Public Management Barriers 

The tendency of agencies to endorse only those fuel management methods with 

which they have experience and knowledge inherently limits the options 

customarily utilized. A public resource agency that has always used fire to 

manage fuel loads and that has no desire or incentive to do otherwise is likely to 

continue to use fire and to neglect the use of nonburning alternatives. At the 

same time, many agency staffpersons with a knowledge of specific management 

techniques (e.g., timber sales) have retired or left the field. This emigration of 
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traditional expertise leaves in place a new generation of land managers who 

endorse land management philosophies that deemphasize the commodification of 

resources. 

Many natural resource agencies lack the funds and staff to treat all the areas and 

fuels requiring treatment. The shortage of personnel, equipment, and expertise 

may discourage resource managers from considering more expensive or laborintensive nonburning alternatives. This shortage of resources forces some natural 

resource managers to select which areas will be treated and which will be 

neglected. 

Some jurisdictions are constrained by such restrictive operational mandates that 

deviation from the status quo is virtually impossible. For example, the Montana 

Department of Natural Resources and Conservation is charged with generating 

profit from management of the stateís natural resources; these profits are an 

integral funding source for Montana schools. This primary agency goal drives all 

decision-making and management actions. In turn, the fuel management 

alternative that is least expensive or that generates the greatest profit is and has to 

be the technique employed. 

The interviews conducted during the preparation of this document suggested that 

vegetation and fuel management programs undertaken on private lands are 

subject to minimal regulatory requirements unless some commodity is to be 

generated. If a commodity is to be generated, some administrative process is 

likely to be required; however, this process varies greatly from state to state. 

On public land, however, the planning and documentation efforts are frequently 

the most time-consuming portion of any treatment project. The costs of these 

efforts can weigh heavily in the selection of treatment type; even, sometimes, to 

the extent of outweighing considerations of ecological outcomes and levels of 

risk. 

Because so much habitat in need of treatment lies on federal lands, NEPA is the 

regulatory mechanism most frequently addressed by land managers. The 

interviews indicated that while prescribed burning treatments can generally be 

implemented with preparation of an environmental assessment (EA) or can even 

be eligible for categorical exclusion (i.e., a designation exempting projects from 

the NEPA review process), nonburning treatments usually require at least an EA, 

if not an environmental impact statement (EIS). Moreover, the general level of 

evaluation in EAs prepared for nonburning treatments tends to be considerably 

higher than that in EAs prepared for prescribed burns. In addition to the 

increased efforts for NEPA compliance associated with nonburning alternatives, 

the nonburning alternatives are more likely to be appealed by opponents of the 

proposed action, causing additional delays and increased costs. 

These NEPA-related considerations, while anecdotal, have several implications. 

They support the likelihood of many agencies to be predisposed in favor of 

prescribed burning over nonburning alternatives. Furthermore, many EAs limit 
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the alternatives analysis required by NEPA to a comparison of the Proposed 

Action and the No-Action Alternative. This is an important point, because it is in 

the EA that the purpose and need statement for a Proposed Action is developed. 

The purpose and need statement can be articulated to limit the scope of 

alternatives that must be analyzed. If the scope of the EA is narrowed in this 

manner, potentially feasible nonburning alternatives can be eliminated altogether 

from the public discourse that is part of the NEPA process. 

Public Opinion Barriers

Public opinion regarding fuel treatments varies widely and can be influenced by a 

myriad of factors. In New Mexico, for instance, the public had long supported 

fire as the fuel treatment method of choice. In the summer of 2000, the Cerro 

Grande wildfire, which was caused by the escape of a prescribed burn, swept 

across the Bandolier National Monument in the Jemez Mountains. Following 

this event, public opinion shifted in support of nonburning alternatives. 

Public opinion is highly localized and can vary widely within a relatively small 

geographic area. Numerous conflicting opinions may be expressed within the 

same state, region, or municipality. Public opinion on fuel treatments and their 

respective effects, particularly those effects related to aesthetics, can exert 

tremendous influence on the selection process. For example, some communities 

may resent the presence of cattle grazing on fuels, while other communities find 

the visual results of mechanical treatment unacceptable. Trends among public 

attitudes, particularly on a small geographic scale, are difficult to predict; it is 

therefore advisable to assess the opinions and sensibilities of the local 

community prior to any fuels management project. When possible, inclusion of 

the local community in the decision-making process helps to ensure popular 

support. 

Perception, of course, is critical to bridging the gaps between various stakeholder 

groups in the arena of public opinion. For example, the most environmentally 

beneficial treatment in a particular situation might be a tree-thinning operation 

that will, if effectively implemented, increase forest health, reduce the risk of 

catastrophic wildfire, result in minimal air quality impacts, and potentially 

generate some revenue to fund the operation wholly or in part. However, such an 

operation uses similar equipment and techniques to traditional harvest operations, 

which can be perceived to be environmentally irresponsible. Such perceptual 

barriers present challenges, but also offer opportunities for innovative 

collaborative efforts. 

Environmental Groups 

Local environmental groups can be highly visible and influential in dictating the 

fuel management methods used in a given area, particularly on public lands. 
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Such local groups can often be brought into a participatory role through proper 

outreach and communication efforts. However, fuel management projects that 

have been developed through such a collaborative process can nevertheless be 

jeopardized by opposition from outside environmental efforts, particularly those 

initiated by national organizations headquartered elsewhere. These groups may 

convey their opinions through the scoping process and public comment 

requirement specified by NEPA. They may express their opposition through the 

courts, bringing lawsuits or appeals to delay or kill projects. Legal involvement 

is frequently initiated long after project development, and can severely limit fuel 

management options and impede implementation. Often, the level of resistance 

from national environmental organizations is closely correlated with the visibility 

and political sensitivity of a given project. Such resistance, when it obstructs 

projects that have been developed through successful collaboration of 

stakeholders at the local level, is particularly disheartening because it increases 

the level of frustration and disenfranchises the participants. In some cases, such 

reversals can reopen philosophical or ideological rifts that have begun to heal 

through the advent of a successful local collaboration. 

Assessing the Alternatives 

For the purposes of this discussion, it is understood that the primary goal of any 

vegetation or fuel load management action is to treat as many high-priority acres 

as possible with a minimum of onsite emissions. In examining the constraints on 

specific treatment options, the following discussion focuses on forested habitats. 

Once again, because of the very generic nature of this document, the authors 

have chosen to adopt a convention likely to enjoy the widest applicability. 

Because the preponderance of areas requiring treatment in the western states lie 

in forested habitats; because the widest variety treatment methods are potentially 

suitable to such habitats; and because the more controversial treatment 

methodsi.e., harvesting and tree removalare specific to those habitats, 

shrubland and grassland are excluded from this discussion. Similarly, because 

grazing and chemical treatment options have rather restricted applications, they, 

too, have been excluded. 

Overcoming Obstacles 

This analysis compares burning with four categories of nonburning alternatives: 

hand work, mastication, tree removal, and biomass removal. The graphic 

comparison in Figure 4-8 is, like the other figures in this chapter, a conceptual 

illustration of relationships and not a representation of quantitative data. Rather, 

the figure illustrates conclusions based on the professional experience of the 

authors and on the collation of the results of the interviews conducted in the 

preparation of this document. 

The analysis compares the treatment types in the context of five key obstacles: 
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! Gross capitalization: the full amount of expenditures that have to be made 

before any fuel is treated. This includes equipment and facilities acquisition, 

staffing, marketing, and planning. 

! Post-treatment fuel residue: the fuel that remains on site after the 

treatment action has been completed. This should be evaluated in the context 

of the residual fuelís conditions and arrangement. 

! Administrative resistance: the level of resistance exhibited by resource 

agencies. Administrative resistance can also involve the level of 

environmental documentation that is required for a particular treatment 

project. 

! Production inefficiency: the amount of money/labor required to treat a unit 

measure of habitat. 

! Interest group resistance: the level of resistance exhibited by particular 

interest groups (e.g., environmental and community groups). 

Figure 4-8 illustrates the relative weight of these five obstacles in the context of 

various treatment options. In selecting an approach, one should determine which 

technique is most appropriate for achieving the desired future conditions and 

which has the greatest potential to be implemented. 

Hand treatments require the least gross capital investment, but are also the least 

efficient of the nonburning treatment options. They tend to leave high levels of 

post-treatment fuel residues. Though time-consuming and relatively 

unproductive, hand treatments face very little interest group opposition or 

administrative challenge. 

Mastication requires specialized equipment that is often less common and more 

expensive than traditional logging equipment. However, transportation and road 

systems are not as critical for mastication operations. Additionally, there is no 

need for markets or the associated infrastructure (e.g., processing facilities, 

transportation system) necessary to exploit them. These factors combine to limit 

the gross capitalization requirement for mastication. Because it creates limited 

environmental impacts, mastication encounters little resistance from the 

environmental and administrative sectors. Mastication experiences only 

moderate production inefficiency and produces moderate amounts of posttreatment fuel residue. 

Tree removal also requires specialized equipment, much of which is readily 

available and consequently more affordable than mastication equipment. The 

gross capitalization requirement is higher than that for mastication, however, 

because of the dependence upon a comprehensive transportation system (i.e., 

roads and available logging trucks). Moreover, tree removal produces the 

highest level of post-treatment fuel residue of any treatment option. Perhaps the 

greatest hindrance to tree removal is environmental and administrative resistance. 

Some interest groups are strongly opposed to tree removal and the perceived 
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commodification of public lands. Regulatory compliance requirements and other 

administrative barriers are significant for tree removal operations. 

Biomass removal requires very specialized equipment and operational skills, a 

well-developed transportation network, and a market for generated materials. 

This industry, contrasted with both standard tree removal and hand treatments, is 

in its infancy, suggesting that, to achieve a substantial level of efficiency, 

development would be necessary on a whole-industry scale. Such expansion 

would result in a very high gross capitalization requirement; this could, for the 

present, effectively eliminate biomass removal as a regionally applicable 

approach to solving the fuels problem. 

Comparing Effectiveness 

The effectiveness of nonburning treatment techniques can be compared by 

examining a common goal of land managers: the reduction of fine fuels. A 

principal indicator of elevated fire risk is the availability of large quantities of 

fine fuels in particular arrangements. 

Hand operations are typically used in treating fine fuels; these operations change 

the arrangement by moving large quantities of surface and lower ladder fuels 

closer to the ground surface; hand treatments do not, however, actually reduce 

the volume. 

Mastication (including crushing and mowing,) does not reduce volume, but alters 

the vegetation structure even more radically than does hand treatment. The use 

of vehicles to grind the masticated material into the soil surface enhances this 

effect. 

Chipping and grinding, particularly when conducted in concert with biomass 

removal, transports significant quantities of fine fuels either to a central location 

or completely off site. Whole-tree yarding, although properly considered a tree 

removal technique, achieves the same end. 

Logging operations are generally focused on extraction of commercial materials 

and not on treatment of fine fuels. Slash operations (as a post-silvicultural 

treatment) can include hand lopping; however, the intent is rather to comply with 

regulatory requirements than to perform fuel treatments, and these operations are 

not as effective as operations in which fine fuels reduction is the monitored 

success indicator. 

Figure 4-8 shows that mastication/mowing operations may offer the greatest 

potential for success in the context of both desired future conditions and 

likelihood of implementation. However, mastication requires an industry that is 

still in development and does not yet generate useful materials. It is possible that 

mastication could be the best first step towards other more market-driven 

methods such as biomass removal. Consideration should be given to developing 
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a subsidized program that effectively builds industry capacity and aids 

landowners/managers in offsetting planning elements of the gross capitalization 

element. 

Making the Decision 

[Diagrammatic representations of the decision-making process are in 

development. These figures and explanatory narrative will be inserted here for 

the next iteration of this document. Weíve experimented with a number of 

options and have finally focused on an approach that seems both clear and userfriendly; again, as weíve emphasized, because there is no ìone-size-fits-allî 

solution to fuel load management, it is also not possible to develop an exhaustive 

ëdecision treeí that addresses the spectrum of variables and site-specific kinds of 

issues with which land managers must grapple. Accordingly, we are creating a 

schematic depiction of the sequence and relationships of issue areas; this will be 

followed by a matrix evaluating the advantages and drawbacks of a range of 

mechanical treatment types.]
Nonburning Alternatives for 

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Chapter 5

Conclusions and Recommendations 

Discussion 

Clearly, there is a need to address with determination the fuel load crisis that has 

developed in the western United States through a century of fire suppression 

policies. No less pressing are concerns over the deteriorating air quality that 

plague urban areas and wildlands alike. Although the promotion of nonburning 

alternatives cannot alone resolve these issues, the reduction of prescribed burning 

where nonburning alternatives will adequately address the fuel load situation can 

certainly contribute to advances in both areas. 

The investigations conducted during the preparation of this document suggest 

several salient points. 

1. A sound range of nonburning alternatives to prescribed burning currently 

exists, and emerging technologies await exploitation. While there are 

obstacles to implementation of many of these alternatives, few of the 

obstacles are insurmountable; indeed, the greatest challenge is that of 

stepping beyond the confines of conventional wisdom to explore innovative 

and creative solutions. 

2. Perceived regulatory and administrative barriers to use of nonburning 

alternatives, while very real, can perhaps be more readily overcome through 

education and training on the part of land managers and air quality 

management officials than through an assault on the existing regulatory 

infrastructure. For example, as discussed in the preceding chapters, the 

NEPA process can be initiated in such a fashion that nonburning alternatives 

are excluded from the onset. However, with a relatively cursory amount of 

training, proponents of nonburning alternatives could be instructed to use the 

existing procedural requirements of the NEPA review process to ensure that 

such alternatives are addressed. 

3. Very limited accountability mechanisms are in place to promote the use or 

ensure the consideration of nonburning alternatives. This has been partially 

addressed in item 2 above; but the issue of accountability is also tied to the 

fact that traditional treatment programs are evaluated on the basis of numbers 

of acres treatedand in many cases, treated can be considered as 

synonymous with burned. Such mechanisms obviously preclude 

consideration of nonburning alternatives. Situations of this sort, however, 

are more appropriately addressed at the level of agency policy or land 
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November 2002 

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management plan development (e.g., individual forest plans, resource 

management plans) than at the level of legislative action (e.g., NEPA). 

4. Because many of the obstacles to nonburning alternatives are economic, 

there is a substantial need to develop technologies to encourage use of these 

alternatives. While capitalization costs may in some cases be high, these 

costs should be weighed not only against the costs of prescribed burning, but 

also against the potential savings and revenues that could be realized by 

development of new industries that produce energy, reduce air quality 

impacts, create job opportunities, and reduce dependence on imports of fossil 

fuels. 

5. Despite the advantages of nonburning alternatives in the context of air 

quality impacts, it is evident that prescribed fire will remain a critical 

component of many vegetation and fuel load management programs. 

Accordingly, the object should be not to replace burning with nonburning 

alternatives, but to design programs to include a greater proportion of 

nonburning techniques, such that air quality impacts are substantially 

reduced. 

Air quality and risk of wildfire are subject to influences far beyond wildland 

management policies. The energy industry, transportation policy, regional 

economics, technology, environmental protection, and social justice are all 

interconnected with both issues and the decisions that are made to address them. 

Consequently, communities and decision makers should look beyond the 

immediate boundaries of vegetation and fuel load management programs for 

comprehensive solutions to the problems. 

Finally, the increased acceptance of nonburning alternatives is dependent upon a 

change of mindset. Resource agencies, industry groups, environmental groups, 

and community groups must all be willing to reassess their preconceptions if 

significant progress is to be made in combating the dual problem of air quality 

and fire risk. 

Recommendations 

A number of recommendations emerged from the process the authors followed in 

preparing this report. Although some of these recommendations arguably lie 

outside the initial scope of this document, they have nevertheless been included 

because the authors feel them to be germane to the matter at hand. Because the 

recommendations in many cases cross the organizational structure followed in 

previous chapters, that structure has been forgone for this discussion. 

! Promote consideration of nonburning alternatives within agencies. This 

should be undertaken at the agency policy or land management plan level. 

For instance, every federal agency as its own set of guidelines for NEPA 
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compliance; proponents of nonburning alternatives could suggest relevant 

agencies to adopt measures requiring consideration of nonburning 

alternatives in the process of developing vegetation and fuel load 

management plans. 

! Promote proactive participation in the NEPA review process. The 

WRAP could disseminate educational materials to proponents of nonburning 

alternatives to enable them to engage in the NEPA scoping and review 

process early on. Where appropriate, the purpose and need portion of the 

project description should be broadened such that nonburning alternatives are 

not precluded. 

! Initiate an outreach and education program. This is a two-pronged 

recommendation. One area of outreach should be directed to the public, 

promoting acceptance of nonburning alternatives as environmentally 

responsible; this program should emphasize that protection of air quality, like 

protection of wildland habitat, is a critical component of responsible 

environmental stewardship. 

A parallel outreach program should be developed for resource agency staff to 

promote acceptance of nonburning alternatives and to encourage inclusion of 

such alternatives in analyses conducted during development of planning 

documents. 

! Provide administrative and economic support to development of 

infrastructure. If nonburning alternatives are to be successful, additional 

infrastructure will be necessary. As discussed above, this infrastructure need 

not be a recapitulation of traditional timber industry infrastructure; indeed, 

the political climate precludes such a course of action. Rather, attention 

should be paid to promoting the development of local and regional biomass 

utilization programs. Such programs offer intriguing opportunities for 

entrepreneurial innovation; economic redevelopment of depressed rural 

communities (particularly those impacted by the contraction of the timber 

industry); reduction of dependence on imports of fossil fuels; reduction of 

increasing waste disposal problems; and reduction of air quality impacts. 

! Encourage nonindustrial utilization programs. In concert with the 

preceding item, opportunities for development of value-added enterprises 

abound. In the Pacific Northwest, where traditional logging communities 

have suffered mill closures and high unemployment, innovative value-added 

businesses have offered examples of the potential of this approach. For 

instance, a small company on Vancouver Island produces spruce and cedar 

guitar tops. The company anticipates gross revenues of $Canadian 1 million 

in 2002. It provides 14 year-round jobs utilizing 3,600 cubic meters of 

timber annuallyan amount that would support 2.5 mill workers in the 

industrial timber business. Moreover, leftover material that is unsuitable for 

guitar tops is used by another local business to craft gift boxes for exporting 

smoked salmon. 

In another example, homesteaders in a forested region of northern California 
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cut limbs and small trees both to reduce the risk of wildfire and to provide 

themselves with firewood. However, realizing that much of the hardwood 

left behind by the previous harvest operations could have intrinsic 

commercial value of its own, they created a small-scale logging and milling 

system. Harvesting hardwood trees on the basis of promoting forest health, 

they market hardwood to local craftspeople, who create value-added 

products. Their harvest techniques, employing pickup trucks, portable 

sawmills, and preexisting logging roads, reduce the risk of catastrophic 

wildfire, minimize air quality impacts, promote forest health, and contribute 

to the local economy. 

Programs such as these, while in themselves not able to address vast tracts of 

wildlands in need of treatment, can certainly contribute to the promotion of 

nonburning alternatives. Perhaps more importantly, they can help to bridge 

the gap between traditional forest practices and those who are 

unconditionally opposed to any form of commodification of forest products. 

! Develop a comprehensive vegetation and fuel management manual. This 

report fundamentally addresses and promotes nonburning alternatives. 

However, as has been discussed above, prescribed burning is not likely to be 

removed from the repertoire of treatment options. With that in mind, it is 

recommended that the contents of this be expanded, or combined with 

existing materials, to provide a comprehensive guide to program 

development. Such a manual would begin with the earliest planning stages 

and would include prescribed burning techniques, but would emphasize 

incorporation of emission reduction techniques. It must be emphasized that 

many of the nonburning alternatives described in the previous chapters can in 

fact be considered emission reduction techniques, because they are 

frequently used as parts of larger programs that also entail prescribed 

burning. 

A Final Word 

In conclusion, perhaps the most important lesson to learn from the forest 

management issues that confront us is that single solutions rarely suffice. The 

present crisis developed because those involved in making management 

decisions failed to understand the complexity of the natural systems they were 

attempting to manage, and because they did not consider the myriad 

consequences of their actions. So, too, we must bear in mind that a great deal 

remains to be discovered about the mechanics of ecosystems, the 

interrelationships of seemingly disparate occurrences, and the unanticipated 

consequences of solutions we undertake. It is imperative, therefore, as both fuel 

load and air pollution conditions continue to worsen, that we consider a range of 

solutions as broad and interconnected as the factors that gave rise to the problems 

in the first place. 

Comparison of Gross Capitalization 

Requirements 

Among Treatment Types Burn

Hand

Mastication

Tree

Removal

Biomass

Removal

Comparison of Interest Group 

Resistance Among Treatment Types

Burn

Hand

Mastication

Tree

Removal

Biomass

Removal

Comparison of Administrative 

Resistance Among Treatment Types

Burn

Hand

Mastication

Tree

Removal

Biomass

Removal

Comparison of Post-treatment Fuel 

Residue Among 

Treatment Types

Burn

Hand

Mastication

Tree

Removal

Biomass

Removal

Comparison of Production Inefficiency

Among Treatment Types

Burn

Hand

Mastication

Tree

Removal

Biomass

Removal