BUTCHERKNIFE/SLATE VEGETATION 

MANAGEMENT PROJECT

Wild Rivers Ranger District, 

Rogue River-Siskiyou National Forest 

Josephine County, Oregon 

Fire/Fuels/Emissions Analysis 

Typical Stand Condition Within Butcherknife/Slate Project Area 

November 24, 2008 

By Don Bellville 

Fire/Fuels Planner/R-6 Certified Silviculturist 

1
I. GENERAL PROJECT DESCRIPTION

The Forest Service proposes various vegetation density and hazardous fuel reduction, wildlife and 

botanical habitat and fish and watershed maintenance/improvement treatments within an approximate 

5,834 acre area of National Forest. 

The primary proposed treatment is vegetation density reduction (e.g. ‘thinning from below’) where the 

typical leave trees are those that have already demonstrated their ability to ‘out compete’ nearby trees by 

exhibiting larger diameters, greater crown lengths/fullness or are taller (dominance). In this type of 

thinning, the first choice for removal are those trees that show a relative inferiority to nearby trees in that 

they generally have smaller diameters, less height, shorter crown lengths or volume, evidence of disease 

or insect attack, or poor stem quality (forked trees, crooks, broken tops, etc.). This tends to result in the 

larger, taller, more vigorous trees being left. In some cases, when two or more trees that are growing 

close to each other show little difference in overall quality (diameter, height, etc), a choice is made to cut 

one or more in order to provide the other(s) with increased opportunities to utilize the site’s resources 

(sunlight, water, etc) in order to increase growth and vigor. The larger diameter ‘legacy’ remnants from 

the previous generation will typically be left. Such thinning will include both commercial and noncommercial activities and associated fuel/slash reduction treatments such as biomass removal, 

piling/burning, sectioning/scattering, pruning (ladder fuel), underburning, etc. See following photo: 

Post-Treatment Example of ‘Thinning from Below’ (prior to slash disposal) 

2
Another proposed density reduction treatment is termed ‘radial thinning’. This treatment involves 

removing all vegetation from under an individual tree crown (or clump of trees) and for a specified 

distance out from the tree crown’s ‘drip line’. This treatment significantly reduces competition to the tree 

(or trees) being left and will be used in order to help maintain species such as ponderosa pine, sugar pine, 

white oak and black oak within these landscapes. Such species are being lost from these stands because 

of competition-related mortality or increases in insect and disease attacks. Such species are particularly 

sensitive to high vegetation density. See following photo examples. 

Pretreatment Example of Black Oak with Significant Adjacent Vegetative Competition 

Pretreatment Example of Sugar Pine with Significant Adjacent Vegetative Competition

3
Post-Treatment Example of Sugar Pine with Adjacent Vegetative Competition Removed (prior to slash disposal) 

4
Another proposed vegetation density reduction/maintenance treatment is underburning. This treatment 

involves implementing prescribed fire treatments to reduce vegetation density, ladder and down fuels, 

recycle nutrients, restore this primary landscape disturbance agent on these sites, and maintain lowmoderate fuel conditions to reduce the potential for large scale, high intensity wildfires to destroy natural 

resources, structures or take human lives. 

Lastly, wildlife and botanical habitat and fish/watershed/riparian areas are proposed for 

maintenance/improvement through treatments such as: 

-noxious weed control (examples= pulling, covering, burying, etc.), 

-snag and down woody material habitat creation (examples= girdling, topping, felling, etc.), 

-fish habitat improvement (examples= structure creation, cover development, thinning, planting, 

etc.), 

-riparian vegetation density reduction (examples= thinning, fuel piling/burning, underburning, 

etc.), 

-serpentine meadow restoration (examples= thinning, fuel piling/burning, underburning, etc.), and 

-watershed restoration (examples= road reconstruction/maintenance, road stability improvement, 

erosion control, culvert cleaning/replacement, road closures, etc.). 

Harvest (removal) of merchantable cut trees or biomass is planned to occur by a variety of harvest 

systems including ground based (rubber-tired skidders, tractors, or various mechanical tree sheers or cutto-length processors, excavators, etc) or cable (skyline, etc). Such considerations as road access, cost, 

resource management standards and guides, etc. influence the choice of harvest system. 

5
6

Harvesting and wood product haul will require use of existing roads, the reopening of old roads that 

previously were closed by vegetation growth, waterbars, etc. and construction of some, new, ‘stubbie’ 

roads (e.g. temporary roads). No new, permanent roads will be constructed. 

II. LOCATION

This project is located approximately 8 air miles west/southwest of Grants Pass and 2 miles southwest of 

the community of Wonder. The project area lies within portions of the Clear Creek., Slate Creek, Ramsey 

Creek and Butcherknife Creek watersheds. Butcherknife and Ramsey Creeks are both tributaries to Slate 

Creek, which is a tributary to the Lower Applegate River. Clear Creek is a tributary to Deer Creek.The 

project area is located immediately west and north of the eastern and southern boundaries of the Wild 

Rivers Ranger District, Rogue River-Siskiyou National Forest in T37S, R8W, Sections 1, 2, 11, 12, 13, 

14, 24, 25 and T36S, R8W, Section 36, W.M. All proposed treatment areas are within the WUI of the ‘At 

Risk’ community of Wonder/Wilderville. Private residences occur both adjacent to the project area and 

within private land ‘inholdings’ inside of the National Forest boundary. 

III. PROPOSED DATE(S) OF ACTION

This project is to be implemented over a fifteen (15) year period beginning in 2009. 

IV. NEED FOR ACTION

This project area contains moderate to high-density natural stands (no previous vegetation management) 

and various types of plantations resulting from previous vegetation management. Some stands have a 

diverse conifer and hardwood species composition. Other stands are dominated by one or two conifer 

species with some associated hardwoods. Still other stands are dominated by various hardwood species 

with occasional conifers. At least one stand is an old test plantation for planted knobcone pine/Monterey 

pine. 

Since the early to mid 1900's, when wildfires began to be aggressively controlled, fire has not played its 

natural role in these forests. Historically, these frequent, low intensity fires would have consumed down 

fuels, killed small trees, reduced the amount of brush and hardwood tree vegetation, killed the lower 

branches on trees, stimulated or maintained grass/forbs in meadows and the forest understory, and 

generally reduced forest stand densities by killing individual or clumps of trees. These fires likely tended 

to maintain forest stands that consisted of large diameter but relatively wide spaced trees (20- 50 trees per 

acre) with a relatively open understory with little ladder fuel. Dominant species on these landscapes 

probably included sugar, ponderosa and Jeffery pine, with some Douglas-fir, incense cedar, black 

oak/whiteoak, Pacific madrone and tanoak. Grass/forbs and needle/leaf litter likely dominated surface 

fuels. Large down logs were probably limited in number because of the frequency of fire. Nonserpentine meadows would have tended to be larger and the Jeffery Pine/oak savannah serpentine 

meadows might have contained fewer, more widely spaced trees and a less continuous shrub layer. Such 

serpentine meadows were likely better habitat than currently for certain dependent plant and animal 

species. 

Because of wildfire exclusion, these forest stands have undergone ecological succession without the 

benefit of this primary change (disturbance) agent. Un-thinned portions of the proposed treatment area 

and all of the surrounding watersheds have denser vegetation than likely existed in these forests prior to 

European settlement. This increase in the density of vegetation also increases tree-to-tree moisture stress 

and competition for light. This, in turn, results in lower tree vigor and the susceptibility of conifer trees 

(particularly pines) to bark beetle attacks. The usual result is increased tree mortality and higher amounts 

of standing and down dead fuel. Low growing plants such as forbs and grass are decreasing as the tree 

canopy closes. The amount of brush, hardwood trees such as tanoak, and Douglas-fir, as well as the 
7

quantity of ground and ladder fuel, is very high. In addition, the number of shade intolerant species such 

as pine or black oak is decreasing as a result of increased mortality from overcrowding and 

insects/disease. In turn, this mortality is increasing the amount of standing and down dead wood. 

Our desire to reduce stand density exists because these stands are showing moderate-high stem densities, 

which is causing diameter growth to slow as the tree crowns close and individual tree crowns compete for 

sunlight. As the amount of light available to individual tree crowns decreases, the affected crowns 

shorten (‘recede’) and less photosynthetic surface (green needles) is available for the tree to produce food. 

As a result, the vigor of the tree further deteriorates in a continuing cycle. The ultimate result is that those 

trees that do not compete well with other trees either die or become more and more unhealthy and more 

susceptible to mortality caused by either disease pathogens or insects because they lack the resources to 

‘fight off’ these agents. 

Thinning reduces the number of trees on the site (density) which permits more sunlight to reach the 

crowns of remaining trees. This permits these trees to grow larger crowns, which increases the potential 

for the tree to generate food for itself. This, in turn, increases the vigor of the tree and the tree can grow 

faster in diameter and be more capable of defending itself against disease and insect attacks. 

This unnaturally dense vegetation could also ‘feed’ a high intensity wildfire that would consume most 

ground fuels, including smaller trees, shrubs, down woody debris, and kill even the large trees. 

Moreover, under hot and windy weather conditions, there is a substantial likelihood that such a high 

intensity surface fire could move into the tree crowns and create a crown fire that would kill even the 

largest trees. Under worst-case burning conditions, such fires could cause 90 to 100 percent mortality of 

all vegetation present. Obviously, successful suppression of such a large wildfire would be very difficult, 

if not impossible to accomplish, and would likely be very costly. 

Such a wildfire could pose a serious threat to nearby private homes and property as well as to resource 

values within these or adjacent watersheds. Such high intensity wildfires could send burning embers 

hundreds if not thousands of feet out from the edge of the fire. Ignition of new fires from these embers 

could trap Ramsey/Slate Creek residents who have only one route of ingress/egress to their property 

(Slate Creek Road # 3690). If fire should cut off vehicle egress, residents would be trapped with their 

only option being escape on foot. . 

The need for this project, therefore, stems from this gradual increase in vegetative density and available 

fuel, which have combined to increase overall stand combustibility after years of wildfire exclusion. 

Previous density reduction and fuel hazard reduction efforts in this area are of limited extent and would 

have little overall impact to wildfire intensity and spread. The proximity of homes in the area that have 

one-way ingress/egress makes treatment of this and adjacent areas a priority. 

V. LAND MANAGEMENT ALLOCATIONS

The proposed treatment areas include the following land management allocations: 

-Applegate Adaptive Management Area (AMA) (Northwest Forest Plan, April 1994), 

-Riparian Reserves (Northwest Forest Plan, April 1994), 

-Matrix (Northwest Forest Plan, April 1994), 

-Management Area 9- Special Wildlife Site (Siskiyou Forest Plan, 1989), and 

-Management Area 3- Research Natural Area (Siskiyou Forest Plan, 1989). 

Each of the land management allocations have different standards and guides for what might be cut in 

order to maintain or enhance its’ resource objectives. This generally means that certain land management 

allocations may limit tree cutting or specify under what circumstances such cutting may occur. 
8

The primary management emphasis for those lands identified as AMA is timber management as well as 

development and testing of forest management practices including partial cutting, prescribed burning, and 

low impact approaches to forest harvest that provide for a broad range of forest values including latesuccessional forest and high quality riparian habitat. (pg. D-12, Northwest Forest Plan, April 1994. 

VI. AFFECTED ENVIRONMENT

A. FIRE

1. FIRE REGIMES

A fire regime is a categorization of historical wildfire activity. It has two components (1) 

frequency of occurrence (e.g. average number of years between fire occurrences) and (2) 

‘severity’ (e.g. how significant of an effect did fire have on existing vegetation/soils/etc). 

Based on a draft fire regime map for the Siskiyou National Forest, the Clear, Butcher 

Knife, Ramsey and Slate Creek watersheds are identified as primarily having a 

combination of Fire Regime I (0-35 years, low severity) and Fire Regime IIIA (less than 

50 years, mixed severity). There are also small areas of Fire Regime IIIB (50-100 years; 

mixed severity) and Fire Regime IIIC (100-200 years; mixed severity). Because of this 

areas’ proximity to the drier valley floor, it is likely that this area experienced fire even 

more frequently than this map indicates (possibly a 15- 25-year return interval). 

FIRE REGIME FIRE REGIME EXPLANATION 

PERCENTAGE 

(%) OF PROJECT 

AREA

I (0-35 YEARS, Low 

severity) 

Frequent, low intensity fire is the dominant 

characteristic 70% 

IIIA (<50 Years, 

Mixed Severity) 

This regime tends to create heterogeneous 

landscapes with rare, large, stand replacing fire 

events and subsequent, mixed severity, events 

creating the landscape heterogeny. Lower fire 

severity tends to predominate in many events. 

More frequent fire occurrence than IIIB. 

25% 

IIIB (50-100 Years, 

Mixed Severity) 

This regime tends to create heterogeneous 

landscapes with rare, large, stand replacing fire 

events and subsequent, mixed severity, events 

creating the landscape heterogeny. The relative 

amounts of lower and higher severity patches 

within a given event are intermediate between 

IIIA and IIIC. 

4% 

IIIC (100-200 Years, 

Mixed Severity) 

This regime tends to create heterogeneous 

landscapes with rare, large, stand replacing fire 

events and subsequent, mixed severity, events 

creating the landscape heterogeny. Higher 

severity fire tends to dominate inmany events. 

1% 

Historically, these frequent, generally low intensity fires would have consumed down 

fuels, killed small trees, reduced the presence of brush and hardwood tree vegetation, killed 

the lower branches on trees, stimulated or maintained grass/forbs in meadows and the 

forest understory, and generally reduced forest stand densities by killing individual or 

clumps of trees. These fires likely tended to maintain forest stands that consisted of large 

diameter but relatively wide spaced trees (30- 60 trees per acre) with a relatively open 

understory having lower amounts of ladder fuels. Dominant species were probably sugar, 

ponderosa and Jeffery pine, Douglas-fir, black oak, Pacific madrone and some tanoak in 
9

the lower elevation areas. Higher elevations would have had more Douglas-fir, PortOrford-cedar, incense cedar, white fir and tanoak and less pine, Pacific madrone and black 

oak. Grass/forbs and needle/leaf litter likely dominated surface fuels. Large down logs 

were probably more limited in lower elevations than in upper elevations because of the 

more frequent fires affecting the lower elevation areas tended to consume down wood.. 

Non-serpentine meadows would have tended to be larger and the Jeffery Pine/oak 

savannah serpentine meadows might have contained fewer, more widely spaced trees and a 

less continuous shrub layer. Such serpentine meadows were likely better habitat than 

currently for certain dependent plant and animal species. 

 

2. FIRE RISK/HISTORY

Fire risk is the ‘probability or chance of a fire starting determined by the presence and 

activities of causative agents’ (www.borealforest.org/nwgloss4). Fires historically affected 

this area with frequent (less than 15-35 year return interval), generally low intensity, fire. 

A number of these ‘fire cycles’ have been missed. The vegetative condition within 

unmanaged and natural stands both within and outside of this project area is that of very 

high density. Such densities are reducing the numbers of certain tree species such as sugar 

and ponderosa pine, black and white oak, and madrone. These unnatural densities 

resulting from fire exclusion have also increased insect activity and tree mortality, 

increased fuel availability, and decreased the size of meadows and small forest openings. 

Based on fire behavior in areas of similar high vegetative density, large-high intensity 

wildfires are possible that can and do destroy homes, property and natural resources that 

are in their path (for example the 2002 Biscuit Fire). 

The primary factors affecting whether a given stand/area is at a higher or lower risk of 

human caused fire are any of those things that result in higher human use such as 

proximity to residential areas, roads, mining, timber harvest, recreation sites, trails, prime 

hunting areas, etc. In general, the greater the number of people who frequent the area, the 

greater the potential there is for a human caused fire. 

According to Siskiyou fire history records, since 1970 (38 years) this project area has had 

16 fires (0.4 fires per year). There is one documented larger fire (162 acres) in 1959. Of 

these 17 fires, 5 (29%) were lightening ignitions. The remaining 12 fires (71%) were 

human-caused. All of these fires except one in 1959 were small fires (less than 3 acres). 

Fire suppression efforts kept the area burned small.

Except for most of the plantations (e.g. old clearcuts) and a portion of the Cedar Log 

Research Natural Area, this area has not experienced any prescribed firessuch as 

underburning or broadcast burning within the past 60 years. Such fires can mimic the 

effects of wildfires if appropriately implemented. Almost all of the plantations had a 

broadcast burn right after their harvest, which probably was a broadcast burn to eliminate a 

substantial portion of harvest slash and to prepare site for planting. Such prescribed fire 

treatments only affected an estimated 800 acres (14%) of this area. 
10

B. FUELS

1. FUEL HAZARD

All of the stands proposed for treatment are located within the wildland urban interface 

(WUI). WUI is a term ‘used to describe an area where various structures (most notably 

private homes) and other human developments meet or are intermingled with forest and 

other vegetative fuel types’ (Runesson, 2007) 

USDA Forest Service wildfire management priorities are to (first) protect human life, 

(second) protect property and (third) protect natural resources. Therefore, wildfires within 

the WUI are of special concern because of their proximity to human developments and, 

therefore, the potential to kill or injure people or destroy property. 

Prevailing winds are generally from the northwest and these would tend to move wildfires 

towards human developments, which are generally east of the proposed treatment areas. 

Hazard is a ‘state that may result in an undesired event, the cause of risk. Hazard can 

apply to the probability of tree mortality or damage by an insect or disease and also 

represents material or fuel that will ignite and burn’ (Runesson, 2007). Fuel is any organic 

material that is living or dead, that can ignite and burn (NWCG, 1994). Therefore, fuel 

hazard is the answer to the question: How does the burnable organic material in the project 

area contribute to the potential for an undesirable wildfire event?. 

 

The proposed treatment areas have a diversity of vegetative and structural conditions that 

can influence wildfire spread and intensity. Frequently, these stands have significantly 

different vegetative and structural characteristics than areas outside these standsparticularly if these adjacent stands are natural. 

 

The three (3) factors affecting fire behavior are fuels, topography, and weather (NWCG, 

1994). Down fuels and small green vegetation contribute to the spread of fire along the 

ground (a surface fire). Smaller fuels generally less than 9 inches in diameter and 

particularly fuels less than 3 inches in diameter affect the intensity and spread rates of such 

fires. Fuel characteristics such as size and shape, loading (tons/acre), moisture content , 

compactness, horizontal continuity, vertical arrangement, and chemical content influence 

fire behavior (NWCG, 1994). Larger diameter fuels generally do not significantly affect 

spread rates of surface fires but they do influence the length of time the fire burns in an 

area (burnout time) and significantly affect the difficulty of suppressing a fire. 

Down fuels can influence whether a crown fire is initiated or propagated. Crown fires are 

those that move through the crowns of overstory trees either dependent on or independent 

of a surface fire. They are the most destructive of wildland fires, frequently unpredictable, 

and have the greatest fire intensities and rates of spread. 

Down fuels and standing, small, green or dead vegetation can influence the development of 

a crown fire. A high intensity surface fire combined with significant ladder fuels can 

provide a vertical link between a surface fire and the canopy of the overstory. For 

example: A surface fire can ignite the lower dead or live branches of smaller trees that 

extend into the lower crown of the overstory and this flame front can then be carried 

vertically into the crowns of the overstory. If only a few trees are involved this is called 

‘torching’. 
Once a fire is in the crowns of the overstory trees, the fuel characteristics of the crown are 

one of the factors influencing whether a crown fire can be sustained. Crown fires can 

generally be sustained under the following conditions: 

--low fuel moistures 

--a close crown spacing (bulk density of crown foliage is over a certain threshold 

based on species) 

--there are strong winds or steep slopes 

--there is an ability to spot ahead in discontinuous fuels (NWCG, 1994) 

The proposed treatment area has a variety of existing fuel conditions. The majority of the 

proposed treatment area has stands with a dense overstory and understory (e.g. ladder fuel) 

and moderate to heavy down fuel similar to a Fuel Model 10 (Timber- litter and 

understory) (Anderson, 1982). A fire in such stands would have the potential to climb into 

the overstory crowns because of significant ladder fuels and heavier down fuels which 

under the right environmental conditions could result in a crown fire. Other proposed 

treatment areas have low levels of down fuels but significant live and dead ladder fuel that 

might permit a surface fire to reach the overstory crowns during periods of high fire danger 

conditions. If a fire should reach the crowns through torching trees or clumps of trees, a 

combination of a 10-30 mph wind speed coupled with a dense stand and steep slopes 

would be necessary in order to sustain a crown fire. Lastly, a few proposed treatment areas 

have both significant down fuels as well as ladder fuels that would tend to increase surface 

fire intensity as well as aid a surface fire in reaching the overstory crowns especially 

during high fire danger conditions. These stands would have the greatest potential for a 

surface fire gaining access to the crowns and a crown fire developing under approximately 

a 10-30 mph wind speed, coupled with a dense stand and steep slopes. 

 FM10 Timber (litter and understory) 

11

Other portions of this area have stands with a dense overstory but little ladder fuel or 

understory similar to a Fuel Model 8 (Closed Timber Litter) or 9 (Hardwood Litter)

(Anderson, 1982). Existing down fuel loading tends to be light to moderate but increasing 

as the stands are beginning to ‘fall apart’ (e.g. density related mortality). Generally, the 

lower branches of the trees are dead because of a lack of sunlight with larger diameter trees 
generally having the fewest number of lower branches and smaller diameter trees having 

the greatest. As a result, the ladder fuel that would aid a surface fire to reach the overstory 

crowns is generally absent except in isolated pockets. In these stands, flame lengths and 

spread rates would tend to be low and relatively slow. This does not mean that a crown 

fire could not move through the crowns of such stands given certain crown density, 

flammability, wind speed, etc conditions. However, such a fire would have to somehow 

reach the overstory and then be sustained by winds/steep slopes/low fuel moistures/high 

crown bulk densities.

 FM8 (Closed Timber Litter) 

 FM9 (Hardwood Litter) 

12
Still other areas contain dense, tall, brush fields primarily consisting of manzanita or 

ceanothus species Fuel Model 4 (Chaparral) (Anderson, 1982). Such areas are very prone 

to high intensity wildfires fueled by dense vegetation conditions, flammable foliage and 

dead stems. 

 FM4 (Chaparral) 

13
Lastly, there are areas with an open overstory and a moderate understory consisting of 

brush and small trees with an herbaceous ground cover similar to a Fuel Model 2 (Timbergrass and understory) (Anderson, 1982). In these stands, flame lengths and spread rates 

would tend to high and fast because of suitable, highly flammable light fuels. A crown fire 

generally would not occur because of lower crown density although torching of clumps of 

trees/brush might occur. Some of these areas would have fire behavior similar to a Fuel 

Model 1 (short grass- 1 foot) (Anderson, 1982) because of the lack of understory and 

greater dominance of short grass.

 FM2 Timber (grass and understory) 

 (Modified) FM2 Timber (grass and understory) (would likely behave similar to a FM1 (Short Grass)) 

14
15

2. FIRE BEHAVIOR

Fire cannot exist without three basic elements: heat, fuel, and oxygen. Once a fire occurs, 

“wildland fire behavior is shaped by its’ physical environment. Fire spread rates, fire 

intensity, and other characteristics of the fire behavior respond to unique and ever changing 

combination of fire environment components”. These fire environment components are: 

fuels, topography, and weather (NWCG, 1994). 

In order to predict fire behavior within the stands proposed for treatment, a fire behavior 

computer simulation program called BEHAVE (Andrews 1986) was used. This fire 

behavior program uses mathematical fire behavior models developed by Richard 

Rothermel (Rothermel 1972) and fuel models developed by Hal E. Anderson (Anderson 

1982) and various site, weather and fuel conditions. 

 

In order to accomplish this prediction, a knowledgeable fuel/fire behavior person evaluates 

the site where a fire behavior prediction is needed to determine which of fuel models 

(Anderson 1982) would best model expected fire behavior for the site. In addition, 

information on local site characteristics and expected weather and fuel conditions at the 

time of ignition is also determined. 

 

Using “Aids to Determining Fuel Models for Estimating Fire Behavior” (Anderson 1982), 

most of the proposed treatment stands would be classified as either a Fuel Model 8 (timber 

litter), Fuel Model 9 (hardwood litter) or Fuel Model 10 (timber- litter and understory). In 

some stands with little surface fuel but a significant amount of ladder fuel, expected fire 

behavior (intensity) might be more than a FM 8 or 9 but less than a FM10. 

 

BEHAVE fire program computer simulations were ‘run’ using 90th percentile weather and 

fuel conditions (e.g. only 10% of days with ‘worse’ conditions) and typical site 

topography. These are: 

 

Temperature (o F) = 86.3o F

Relative Humidity (%)= 22% 

Fuel Moisture (%)

1 Hr Fuels (<0.25” diameter)= 3.2% 

10 hr fuels (0.26- 1.0” diameter)= 4.6% 

100 hr fuels (1.1- 3.0” diameter)= 8.9% 

1000 hr fuels (3.1- 9.0” Diameter)= 10.6%

Herbaceous fuels= 37.3%

Woody fuels= 75.5%

Wind Speed (mph)

 20 ft winds= 8.3 mph

Midflame winds= 2.5 mph

Slope (%)= 50 %

 
16

The table below shows the predicted surface fire characteristics if a fire ignites under these 

conditions. Note: This model does not model crown fire. 

POTENTIAL SIZE OF 

WILDFIRE (ACRES) 

(Assuming The Indicated Delay 

In Arrival Of a 20 Person Fire 

Suppression Crew) 

FUEL 

MODEL 

TIME of 

OCCURRENCE 

of CONDITION 

FLAME 

LENGTH 

(FL) (Feet) A/ 

RATE OF 

SPREAD (ROS) 

(Feet/Hour) 

1 HR 2 HR 

1 4.6 (Cannot 

direct attack fire 

with hand 

crews)

5,610 312.6 1,250.6 

2 7.0 (Cannot 

direct attack fire 

with hand 

crews)

2,574 67.2 268.8 

4 22.0 (Cannot 

direct attack fire 

with hand 

crews)

5,550.6 309.4 1237.6 

8 1.2 145 0.2 0.8 

9 3.2 574.2 3.3 13.3 

10 

EXISTING 

5.9 (Cannot 

direct attack fire 

with hand 

crews)

660 4.2 16.9 

A/= Fires with flame lengths greater than 4 feet cannot be fought by fire crews building firelines 

immediately adjacent to the fire. A dozer can fight fires with flame lengths up to 8 feet. Fires with 

flame lengths over 8 feet can only be fought by indirect means such as aerial retardant. 

As can be seen in the table, a fire burning in either the Fuel Model 8 or 9 stands would be a 

fire that hand crews could successfully attack because of generally low flame lengths. The 

rate of spread is significantly different between the two models but within the capabilities 

of a sufficient number of hand crew personnel. 

FM 1 stands are expected to generate flame lengths that are beyond the capabilities of a 

hand crew to directly suppress. Even though FM 1 fires tend to have flame lengths greater 

than those that can be directly attacked by hand crews, they also have little smoldering 

time because the fuel is grass. They essentially burn rapidly but go out rapidly. 

FM 2, 4, and 10 are difficult to suppress because of both flame lengths, rate of spread and 

fire intensity and likely would require dozers for slopes less than 40% or indirect methods 

(aerial attack or burnout from watershed divides, etc) for steeper areas. 

3. CONDITION CLASS

Condition Class is a ‘relative measure describing the degree of departure from the 

historical fire regime’ (Hann et all, 2003). Because of wildfire exclusion, these forest 

stands have undergone ecological succession without the benefit of this primary change 

(disturbance) agent. All of the proposed treatment areas and their surrounding watersheds 

have denser vegetation than likely existed in these forests prior to European settlement. 

For a period after a stand replacement type wildfire, the susceptibility of the site to another 

large-scale wildfire is limited because of a lack of fuel. However, within most of the plant 
17

associations (PAGs) in the proposed treatment areas, brush and hardwood tree growth after 

disturbance is aggressive. Within 15 years and without density reduction management 

activities, many areas can have brush and hardwood tree densities so great (thousands of 

stems per acre) that physical movement through them can almost be impossible. During 

high fire danger conditions, a subsequent wildfire ignition in such stands can result in 

another stand replacement fire, which can result in such areas becoming dominated by such 

species for decades (Agee, 1993). 

If such areas escape another severe wildfire event and as the hardwood trees and conifers 

begin to dominate the site and their canopies begin to close, the amount of light reaching 

the forest floor diminishes and this, in turn, reduces the amount of live understory brush, 

hardwood, conifer trees, and low growing plants such as grass and forbs. In addition, the 

diminished light kills the lower branches of light-loving conifers such as pine and Douglasfir. Under these conditions, a wildfire burning through such a stand may have little surface 

fuel to burn and as long as such a fire stays on the surface, little damage to the stand may 

result. 

However, as these stands continue to close their canopies, this increased density begins to 

cause increased mortality in trees that do not complete well for available light, nutrients 

and water. These trees eventually fall over, increasing down fuels and providing small 

gaps in the overstory, which permits more light to reach the forest floor, which restimulates brush growth in the understory. The net effect is a general increase in the 

amount of live understory vegetation and dead fuels. A wildfire ignition under these 

conditions can result in a stand replacement or even a crown fire because the increased 

down fuel provides higher fire intensity and the increased brush and dead lower limbs on 

trees provides increased ladder fuel for the surface fire to move into the tree crowns. 

Based on an evaluation of current vegetative conditions compared with expected 

conditions under an un-modified fire regime, we consider most of the project area as 

having a high departure (Condition Class 3) from the historical regime (15-35 year fire 

return interval) considering existing and historical vegetation, fuel composition, landscape 

position, elevation, and fire severity and pattern. However, the managed stands (e.g. old 

clearcuts) within this area likely were treated with a prescribed fire within a few years after 

harvest. Such areas we consider as having a moderate-high departure (Condition Class 

2/3) because almost all have experienced a prescribed fire within the past 35- 50 years.

C. EMISSIONS

Wildland fire is mentioned in numerous historical accounts of life in Southwest Oregon in 

reference to burning, burned landscapes, or smoke. Wildland fires were a common event in this 

area, as was the smoke they created. As an ecological process, wildland fire is essential in 

creating and maintaining functional ecosystems. As a decomposition process, wildland fire 

changes vegetative materials into its’ basic components including carbon, chemical compounds, 

gases, particulates, nutrients, etc. Some of these combustion products can be harmful to human 

health and welfare (NWCG, 2001). Air pollution can be defined as unwanted chemicals or other 

materials found in the air that can harm health, the environment and property. Many air pollutants 

occur as gases or vapors, but some are very tiny solid particles: dust, smoke or soot (EPA, 2007) 

The Clean Air Act established two types of National Ambient Air Quality Standards. "Primary" 

standards are designed to establish limits to protect public health, including the health of 

"sensitive" populations such as asthmatics, children, and the elderly. Primary pollutants are those 
18

emitted directly into the air. "Secondary" standards set limits to protect public welfare, 

including protection against decreased visibility and damage to animals, crops, vegetation, and 

buildings (EPA, 2006A). Under certain conditions, primary pollutants can undergo chemical 

reactions within the atmosphere to produce new substances which are secondary pollutants. 

Smoke from prescribed burning and wildland fire is a primary pollutant. 

The Environmental Protection Agency has established National Ambient Air Quality Standards 

(NAAQS) for specific pollutants emitted in significant quantities throughout the country that may 

be a danger to public health and welfare. These pollutants are called “criteria pollutants” and 

include the following: lead, sulfur dioxide, carbon monoxide, nitrogen oxides, ozone, and 

particulate matter. The standards for these criteria pollutants are not to be violated anywhere in 

the United States. If they are violated, the area is referred to as a “non-attainment” area. The 

following six “criteria” pollutants are described below. 

Lead

The principle source of lead emissions is the combustion of gasoline containing lead alkyl 

additives. Particles deposited on vegetation over decades can become re-emitted if the vegetation 

is burned. However, the lead content of forest fuels is negligible and is not a concern as an air 

Sulfur Dioxide 

Humans react to sulfur dioxide exposure with an increase in airway resistance. Excess sulfur 

dioxide can also cause cellular injury to sensitive plant species. Most forest fuels contain less than 

0.2 percent sulfur; therefore, sulfur dioxides would be produced only in negligible quantities 

during prescribed burning. 

Carbon Monoxide

Carbon monoxide is a poisonous inhalant that deprives the body tissues of necessary oxygen. 

Extreme exposure (usually occurring in non-ventilated enclosures) to CO can cause death or 

central nervous system reactions such as impairment of visual acuity, brightness discrimination, 

and psychomotor functions. 

Large quantities of carbon monoxide (CO) can be produced from prescribed burning. Exposure to 

carbon monoxide may be high for fireline workers. However, carbon monoxide is quickly dissipated 

where emissions are irregular and there is no atmospheric confinement. Since carbon monoxide 

dilutes very rapidly in the atmosphere, it is not likely to be a concern to urban or rural areas even a 

short distance down wind from prescribed burning activities. Studies on the effects of smoke exposure 

on the respiratory systems of wildland firefighters indicate that long exposure to carbon monoxide 

during a fire season may result in small changes in lung function. The health implications of shortterm exposure and potential long-term effects have not been quantified (Mangan 1994). 

Nitrogen Oxides

The formations of oxides of nitrogen occur at temperatures not normally found in prescribed 

burning. Generally, wildland burning is considered an insignificant contributor of nitrogen oxide 

emissions. 

Ozone

Ozone is a secondary pollutant formed from the reaction of volatile organic compounds with 

oxides of nitrogen in the presence of sunlight. Prescribed burning emits volatile organic 

compounds, which can react with urban sources of nitrogen to form ozone. In sufficient quantities, 

ozone can cause eye, nose, and throat irritation in humans. 
19

Particulate Matter

The primary air quality concern for this project is particulate matter emissions. Smoke from the 

combustion of wildland fuels is the primary source of particulates from management activities. 

Prescribed burning methods being considered are broadcast, underburning and pile burning. 

These treatments can have offsite impacts. 

The major pollutant of concern in smoke, whether from wildland fire or prescribed fire, is fine 

particulate matter. National Ambient Air Quality Standards (NAAQS) have been established for 

this fine particulate matter described as: 

 PM10 (particulates 10 micrometers and smaller in diameter) 

PM2.5 (particulates 2.5 micrometers and smaller in diameter) (EPA, 2006A) 

The EPA revoked the annual average NAAQS for PM10 particles on December 17, 2006 because 

of a lack of evidence linking health problems to long-term exposure to coarse particle pollution. 

However, the 24-hour primary standard remains at 150 micrograms per cubic meter (which is not 

to be exceeded more than once per year on average over 3 years). There are no secondary 

standards. (EPA, 2006A) 

For PM2.5, the primary annual average standard is 15.0 micrograms per cubic meter which requires 

that the 3-year average of the weighted annual mean PM2.5 concentrations from single or multiple 

community-oriented monitors must not exceed 15.0 μg/m3. The 24-hour primary standard is 35 

micrograms per cubic meter, which requires that the 3-year average of the 98th percentile of 24-

hour concentrations at each population-oriented monitor within an area must not exceed 35 μg/m3. 

The secondary standards are the same as the primary standards (EPA, 2006A). 

Studies indicate that over 90% of smoke particles emitted during burning of wildland fuels is PM10 

and about 80-90% of the PM10 is PM2.5. (Ottmar in NWCG 2001). Recent studies (Dockery and 

Others, 1993; EPA 1996 in NWCG 2001, NWCG, 2001, pg 23).of the effects of particulate matter 

indicate that it is the finer particles especially PM2.5, that is largely responsible for health effects 

of concern and regional haze. 

 

Another provision of the Clean Air Act that relates to wildland fire and prescribed burning 

activities is the Prevention of Significant Deterioration (PSD). The goal of PSD is to prevent 

deterioration of areas that are currently ‘cleaner’ than the minimum NAAQS from being polluted 

to the maximum ceiling established, or the prevention of any future impacts, and the remedying of 

any existing impairment of visibility. (EPA, 2006B) 

PSD provisions established three air quality classes. Class I areas include Forest Service 

Wilderness Areas and National Memorial Parks over 5,000 acres, National Parks over 6,000 acres 

and International Parks all of which must have been in existence prior to August 7, 1977 plus any 

later expansions of these areas. No area within this project is classified such. Class II applies to 

all other lands. No Class III areas were designated. (EPA, 2006B) 

 

The Oregon Smoke Management Plan (OAR 629-43-043) (Oregon Smoke Management Plan, 

2002) is the key link between fire management practices and the Clean Air Act. The objective is 

to “prevent smoke resulting from burning on forest lands from being carried into or accumulating 

in designated areas...or other areas sensitive to smoke, and to provide maximum opportunity for 

essential forest land burning while minimizing emissions; to coordinate with other state smoke 

management programs; to conform with state and federal air quality and visibility requirements; to 

protect public health; and to encourage the reduction of emissions.” The closest Designated Areas 
20

to this project are: Grants Pass, OR (7-9 miles NNE-NE), Medford, OR (33 miles E), Kalmiopsis 

Wilderness (10 miles W). 

 

The city of Grants Pass was identified by the Oregon DEQ as a Non-Attainment Area (Moderate 

Classification) for PM10 in the past. However, during the past several years, this area has been in 

compliance. The Rogue Valley has met and will continue to meet PM10 emission standard 

through at least the year 2015 according to the Medford-Ashland Air Quality Maintenance Area 

(Oregon DEQ, 2006) 

Fuel treatments by manual methods generally do not degrade air quality (human health or 

visibility) except by potentially creating localized, dusty conditions or physical injuries to 

personnel in the area. Such possible impacts are generally not experienced off the activity site. 

Untreated slash on a site after harvest is generally a considerable hazard for sustaining a wildfire if 

an ignition occurs. Disposal of slash in order to reduce or eliminate emissions associated with 

prescribed burning usually requires removal of the slash from the site for conversion into biomass 

for composting, heat/electricity generation, etc. or on-site mechanical chipping. Use as biomass 

significantly reduces emissions compared to prescribed burning because natural decomposition 

processes (composting) result in a slow release of emissions and biomass use facilities generally 

have significant pollution control equipment to minimize emissions. On-site mechanical chipping 

can also eliminate the slash hazard and it does not generate any significant emissions. 

However, avoidance of prescribed burning has its negative effects. Fire is the primary historical 

disturbance mechanism in these forests and current forests owe their distribution, structure, species 

composition, etc. to this disturbance mechanism either because of its occurrence or (more 

recently) because of its lack of occurrence. Without this disturbance mechanism, future wildfire 

occurrence and severity is likely to be significant. This is the classic ‘pay me now or pay me later’ 

scenario. Fire will always affect these landscapes whether in a controlled situation via prescribed 

burning or an uncontrolled situation via wildfire. Both create emissions. However, with 

prescribed fire one can select how much, when, where, under what conditions, etc such emissions 

occur. With wildfire, emissions are typically at the ‘whim of mother nature’. 

VII. PROPOSED FUEL TREATMENTS

A. OBJECTIVES

The primary objectives (purposes) of this project at the landscape level are to: 

1. reduce and maintain the fuel hazard (vegetative density, ladder and down fuel loading) to 

an acceptably low level such that the area can provide reasonably safe locations for 

personnel to implement either prescribed fire or fire suppression actions as well as 

reducing the area’s potential to sustain a high intensity/severity wildfire that could kill 

people or destroy structures and vegetation 

2. re-introduce fire as an essential, periodic, ecological process and natural change agent; 

3. increase the relative abundance of fire-adapted species (such as pine) and seral species 

such as black/white oak and reduce their potential loss from insect/disease or high 

vegetation density 

4. improve the growth and vigor of conifer and hardwood trees such that the number of 30”+ 

diameter trees will be significantly increased across the landscape within 30 years. (It is 

desired to develop 20-50, large (30+” DBH) trees per acre on lands capable of sustaining 

such numbers (non-ultra-mafic sites).) 
21

5. maintain or increase the abundance or acreage of special habitats such as pine/oak 

savannahs, meadows, etc 

6. maintain or improve watershed or fishery conditions

7. provide resource outputs (timber, firewood, post/poles, biomass, etc) consistent with the 

above objectives in order to provide jobs, support the local economy, and provide income 

to pay for other desired resource management projects 

B. FUEL TREATMENT STANDARDS & GUIDES 

1. Fuel Reduction Objectives

Following is a table of acceptable, post harvest, fuel conditions prescribed in the Siskiyou Forest 

Plan Standards and Guides. Each has a picture and numerical summary. See Appendix.

SISKIYOU LRMP MAXIMUM ACCEPTABLE FUEL LOADINGS 

TYPE OF 

TREATMENT DIAMETER RANGES 

Partial Cuts .26-1.0” 1.1- 3.0 TOTAL 

0- 3” (tons/ac) 3.1- 9” TOTAL 0- 9” (tons/ac) 

1DF4PC (pg 32/33) 1.1 2.3 3.4 2.3 5.7 

3DF4PC (pg 36/37) 1.6 2.7 4.3 5.7 10.0 

1DF3PC (pg 52/53) 1.3 2.8 4.1 4.8 8.9 

2DF3PC (pg 54/55) 2.0 2.1 4.1 10.8 14.9 

1DFHD4PC (pg 92/93) .7 3.4 4.1 4.0 8.1 

 RANGE .7- 2.0 2.1- 3.4 3.4- 4.3 2.3- 10.8 5.7- 14.9 

AVERAGE 1.3 2.7 4.0 5.5 9.5 

Standard 

Deviation/Range 

+/-.4 

(3.6- 4.4) 

+/- 3.4 

(6.1- 12.9) 

Pre-commercial 

Thinning (roadside 

and fuel breaks only) 

1DF1TH (pg 66/67) .4 .4 .8 1.4 2.2 

2DF1TH (pg 68/69) .7 .9 1.6 2.2 3.8 

 RANGE .4- .7 .4- .9 .8- 1.6 1.4- 2.2 2.2- 3.8 

AVERAGE .6 .6 1.2 1.8 3.0 

Standard 

Deviation/Range 

+/-.6 

(.6- 1.8) 

+/- 1.1 

(1.9- 4.1) 

C. FUEL TREATMENT LOCATIONS

Fuel treatments may occur: 

--within the map identified treatment areas and 

--within approximately 200 feet of the above boundaries in order to provide a reasonably 

safe fire control line locations in order to prevent fire escapes during any planned 

underburn. 

‘Fire control lines’ are locations where either human-constructed or natural features will help a fire 

manager contain a prescribed fire within a treatment area. Typically, fire managers try to utilize 

landscape features such as roads, skid trails, walking trails, rock outcrops, water, etc. 

Unfortunately, sometimes these features are not always located in suitable locations or are absent 

entirely. In these circumstances, fire control lines must be constructed. These are usually either 

hand or machine constructed firelines. In some cases, they are constructed by explosives. 

However, in order for these firelines to be effective at halting the spread of a prescribed fire, they 

must be appropriately located. The most effective locations for these constructed firelines are 

along terrain breaks where either slope or aspect significantly changes (such as ridgetops). 
22

Unfortunately, these terrain features may not be immediately adjacent to a treatment area. 

Therefore, fire managers often must look for such features either inside or outside of a thinned 

stand. If such a feature can be located a short distance inside a thinned stand and the portion of the 

thinned stand that is outside this fire control line is inconsequential, a fire manager may choose to 

construct the line in that location. However, if no suitable control line location exists within a 

thinned stand or a significant portion of the thinned stand is located outside of a possible control 

line location, then the fire manager looks for a suitable control line location outside of the actual 

thinned stand. Sometimes these suitable locations can be a substantial distance from the thinning 

boundary. 

Therefore, for purposes of this analysis and implementation, we will consider that underburns may 

occur on any adjacent lands up to 200 feet outside of proposed treatment areas in order to provide 

reasonably safe fire control line locations. 

D. TYPES OF FUEL TREATMENTS

Numerous methods of fuel reduction treatments are proposed. These include: 

-overstory and understory thinning, 

-radial thinning, 

-fuel extraction, 

-pruning, 

-sectioning and scattering, 

-hand or machine piling/burning, 

-machine chipping/mastication, and 

-underburning/broadcast burning. 

See the Proposed Action for descriptions of these fuel reduction activities and estimated acres by 

treatment type. 

In addition, it is expected that following commercial thinning, a number of treated stands will have 

a vegetative structure and down fuel loading that is suitable for immediately initiating a prescribed 

understory fire. However, usually, some fire preparatory work is needed prior to initiating a burn. 

This work consists of actions deemed necessary to control the fire, minimize unwanted damage to 

natural resources, or to help ensure a satisfactory burn. Such activities ultimately could be 

required on 100% of the area planned for underburning. These activities might precede 

underburning by days to months. These activities include:

-fireline construction/maintenance, 

-fuel pullback from leave trees, no treatment areas, etc, and 

-slashing 
23

IV. ENVIRONMENTAL CONSEQUENCES

A. FIRE RISK

1. Alternative (No Action)

Direct Effects

There would be no changes regarding fire risk if no project is implemented. Neither 

lightening occurrence nor human use would be affected. 

Alternative (No Action)

Indirect and Cumulative Effects

None 

Alternative (Proposed Action)

Direct Effects

There would be no change in lightening occurrence. However, there will be an increase in 

the number of people and equipment using these areas to thin, remove timber products, 

build/obliterate roads, conduct inspections, and chip and haul wood products. 

One could make the argument that the presence of more people increases the potential risk 

because of such things as smoking, campfires/warming fires, etc. In addition, the use of 

mechanized equipment may also increase the potential risk because of machine backfires, 

vehicle accidents, cable friction, chainsaws, etc. In addition, fuel treatments themselves 

will increase the potential risk because of the chance for an escaped prescribed burn. 

However, one could also make the argument that even though there is increased use by 

people and equipment, such people and equipment are more regulated than the typical 

recreational user because of contracts or burn plans authorizing such work. In other words, 

more people are watching what they do and how they do it and these contracts and burn 

plans themselves typically require that certain types and amounts of fire suppression 

equipment/resources be on hand in the event of a fire start. In addition, there tend to be 

significant contractual penalties if a contractor starts a fire. 

Regardless, more people and equipment generally result in increased risk of fire starts. 

However, because of contractual or burn plan requirements, the potential for a fire to 

actually occur is expected to be low. 

2. Alternative (Proposed Action)

Indirect Effects

None 

Alternative (Proposed Action)

Cumulative Effects

The Forest Service and Bureau of Land Management (BLM) have ongoing timber 

management and hazardous fuel reduction programs in these watersheds. 

The Forest Service burns an average of approximately 500 acres/year within the Lower 

Applegate Watershed. This burning includes both underburning and pile burning. The 

BLM estimates that they burn an additional 500 acres/year in the same watershed. 
24

Therefore, the proposed project increases the potential risk of human caused fire ignitions 

(risk) over and above that which already exists because of these on-going activities. Since 

the types of on-going treatments are similar or identical to those proposed, the increased 

risk would be proportional to the acres treated. 

B. FUEL HAZARD & FIRE BEHAVIOR

1. Alternative (No Action) 

Direct Effects

Fuel Hazard. Fuel hazard is defined in terms of fuel loading (type, amount, size, 

horizontal and vertical distribution, etc) and topography of an area. Fuel hazard (and 

ladder fuel) is evaluated in order to determine the potential for a significant fire to result 

after an ignition occurs. (Siskiyou National Forest, 1998) 

Over the next 10 years, the amount of down dead fuel should be relatively constant as 

would the density of standing vegetation. In most stands, the existing fuel loading is 

significantly less than would exist after thinning, pruning, etc IF there were no fuels 

reduction efforts. However, this is not to say that the current fuel hazard is low. 

Current stands fuel models include FM 1, 2, 4, 8, 9, and 10. FM 8 and 9 have average 

flame lengths of less than 4 feet. The 1st table displays expected mortality based on 1 to 4 

foot average flame lengths typical of a FM 8 or 9. The 2nd table displays expected 

mortality based on a 6 foot flame length typical of a FM 10. 

ESTIMATED MORTALITY (1 to 4 ft Average Flame Length) 

DBH 

SPECIES 2” 4” 6” 8” 10” 12” 

Ponderosa/Jeffrey 

Pine 

81-100% 69-99% 56% 43% 33% 25% 

Sugar Pine 79-100% 74-98% 68% 63% 57% 51% 

Douglas-fir 76-100% 62-100% 48-91% 35-61% 25-34% 19-21% 

Port-Orford 

cedar 

72-100% 66-100% 60-94% 55-75% 49-57% 44-46% 

White fir 81-100% 72-99% 62-85% 53-60% 43-44% 35% 

Incense cedar 81-100% 72-99% 62-85% 53-60% 43-44% 35% 

Note: The lower mortality would be from a 1’ flame length and the higher from a 4’ flame length. 

Hardwoods may be killed back to the root color but are expected to re-sprout. (Reinhardt et al., 1997) 

ESTIMATED MORTALITY (w/6’ Average Flame Length) 

DBH 

SPECIES 2” 4” 6” 8” 10” 12” 

Ponderosa/Jeffrey 

Pine 

100% 100% 100% 98% 72% 30% 

Sugar Pine 100% 100% 100% 94% 69% 52% 

Douglas-fir 99% 99% 99% 99% 94% 82% 

Port-Orford 

cedar 

100% 100% 100% 99% 97% 91% 

White fir 100% 100% 100% 98% 88% 69% 

Incense cedar 100% 100% 100% 98% 88% 69% 
25

Obviously, the 6-foot average flame lengths result in significantly higher mortality than the 

1-4 foot flame lengths. Likewise, the even higher flame lengths typical of FM 2 and 4 

would result in even greater mortality. 

Ladder Fuel. Ladder fuels are combustible fuels that provide a fuel ‘ladder’ (connection) 

between a ground fire and tree crowns. Such fuels are typically smaller trees, shrubs, 

brush, and dead or live tree branches. The greater the distance between surface fuels and 

the average bottom of tree crowns, the longer the required flame length to ignite the crown. 

Therefore, the objective in reducing ladder fuel is to increase the relative separation 

between the crown and the ground. 

Many of these overstocked stands have areas with significant ladder fuel and most stands 

have a continuous overstory canopy cover. Such stands are at a significant risk of loss 

during high fire danger conditions. Under such conditions and coupled with high winds, a 

surface fire within these stands might develop into a crown fire that would cause 

significant conifer mortality both inside and outside the stand. 

 

In the short run, the No Treatment alternative would maintain the current condition of 

significant fuel ladders within some of these managed stands. As a result, under the right 

set of conditions, it would be relatively easy for a ground wildfire to access treetops and 

potentially become a crown fire. 

 

Crown Fire Potential. The initiation of a crown fire is a function of flame length and 

critical parameters of the tree crown layer- height above the ground and moisture content. 

Once a crown fire is initiated, conditions that permit crown fire spread depend on (1)crown 

bulk density (lbs of vegetation per unit volume) and (2)a mass flow rate (rate at which the 

fire moves through the crowns) (Agee 1996). For example, crowns with 75% moisture 

(typical of late fall) and a base height of ten feet would ignite if flames from a surface fire 

exceed 5 feet. (Russel et al, 1999). 

 

Once initiated, crown fire sustainability and spread are determined by the mass flow rate 

and crown bulk density, which are related to tree species, structure uniformity, size, wind, 

slope, fire intensity, etc. In stands such as these plantations, crown fires are likely, given 

the right weather and slope conditions. Any area burned by a crown fire would result in 

significant tree mortality. 

In the short run, the large serpentine savannah area along the W/NW edge of the project 

area would likely slow a wildfire coming from this direction because of the lack of 

overstory canopy closure and the scattered, low-moderate amount and density of the 

surface and ladder fuels within this area. This area would not sustain a crown fire because 

of large of overstory crown closure. Similarly, portions of the narrow serpentine savannah 

that is oriented NNE through the center of the project area. However, this area is so 

narrow that it would not slow a crown or surface fire advance for a significant period and 

spot fires could be easily ignited beyond this narrow strip. In addition, various managed 

and natural stands scattered throughout the project area could slow a surface fire because 

of the absence of significant surface and ladder fuels within them. 

In the short run, the No Treatment alternative would maintain the current condition of high 

crown closure (high crown bulk density). Ladder fuels in some stands could provide a link 

for a surface fire to reach the crowns. In other stands, the lack of ladder fuel and 
26

significant surface fuel would not provide a mechanism for a surface fire to reach the 

crowns. However, even in stands without significant surface and ladder fuel, a crown fire 

could be sustained through the overstory crowns during high fire danger and wind 

conditions because of the dense, generally continuous, canopies. Such a fire might 

originate either at a nearby location or within this area but could still overrun this area. 

Considering that the prevailing winds are from the NW, such fires would tend to spread 

towards the private lands east of this project area. 

1. Alternative (No Action) 

Indirect Effects

Fuel Hazard, Ladder Fuel and Crown Fire Potential:

In the short and long term, the amount of down dead fuel will increase as competitioninduced mortality increases and these dead stems fall increasing surface fuel hazard and 

small openings, which will increase the amount of light reaching the forest floor resulting 

in more understory vegetation (hardwoods/conifers) and, therefore, development of 

additional ladder fuel. 

Tree mortality from a surface wildfire will tend to increase over time as both down fuel 

and understory vegetation increase. The potential for crown fire initiation from a surface 

fire within the stand will increase with increasing down fuel loading and understory 

vegetation because of resulting increases in fire intensity and flame lengths. Once 

initiated, crown fire spread is likely given appropriate weather and slope conditions. 

Another long-term effect of the No Treatment alternative would be reduced crown height 

differences between adjacent managed and natural stands within this area. This would 

potentially provide an easier opportunity for crown fires to move from managed stand to 

natural stand or vice versa. 

 

1. Alternative (No Action)

Cumulative Effects

Fuel Hazard, Ladder Fuel and Crown Fire Potential

No effect 

2. Alternative (Proposed Action) 

Direct Effects

Following are some assumptions that are necessary in order to determine direct effects of 

implementation of the Proposed Action alternative: 

A. Manual and mechanical understory treatments such as understory 

thinning/slashing, hand piling, etc will occur either within the contract period 

(stewardship contract) or within approximately 1-2 years after contractual 

acceptance of the harvest unit. 

B. Biomass removal will typically occur during the harvest contract and will 

involve the removal of the treetop attached to the last log or the entire tree 

(including branches and top). The top/branches will be chipped at the landing or 

hauled to a suitable chipping location. 

C. Landing pile burning will occur after 1-2 field seasons of pile drying 

D. Handpile burning will occur after at least 3 summer months of pile drying. 

E. Construction of firelines will usually occur within 1 year- prior to an underburn 
27

F. Slashing to prepare site for underburning will occur at least 3 summer months 

prior to initiating an underburn. 

G. The 1st underburn will occur within 1-2 years following pile burning when 

weather and fuel moisture conditions are suitable. 

Fuel Hazard: In the short term, after harvest and without biomass removal, the harvested 

stand will likely be a Fuel Model 11 or 12 (Anderson 1982). With biomass removal, Fuel 

Model 11 will likely characterize the treated area. For a FM 11 stand, after harvest and 

before fuel treatment, expected potential flame lengths would be greater than prior to 

harvest for any FM 8 or 9 stand and less than FM 10 stands. For a FM 12 stand, after 

harvest and before fuel treatment, expected potential flame lengths would be greater than 

prior to harvest for all stands. (Andrews 1986). 

When thinning is followed only by sectioning and scattering, a higher fuel hazard would 

exist because of this down, dead slash. It is expected that this would approximate a FM 12 

for the first year or two and a FM 11 for next 3- 5 years until snow compacts the fuel bed 

and/or it decomposes or it is underburned. (Anderson 1982). If a wildfire occurred during 

this time, flame lengths would be higher than if the fuel had been hand piled or chipped: 

9.4’ for a FM 12 and 3.9’ for a FM 11. Therefore, sectioning and scattering as a stand 

alone fuel treatment, will only be used in very limited situations such as where: 

 small isolated units, 

 underburning or piling would be prohibitively expensive and, or 

 the unit meets Siskiyou Forest plan standards and guides for fuel loading after 

this treatment. (Siskiyou National Forest, 1989). 
28

POTENTIAL SIZE OF 

WILDFIRE 

(Assuming The Indicated 

Delay In Arrival Of a 20 

Person Fire Suppression 

Crew) 

FUEL 

MODEL 

TIME of 

OCCURRENCE of 

CONDITION 

FLAME 

LENGTH 

(FL) (Feet) A/ 

RATE OF 

SPREAD 

(ROS) 

(Feet/Hour) 

1 HR 2 HR 

1 4.6 (Cannot direct 

attack fire with 

hand crews)

5,610 312.6 1,250.6 

2 7.0 (Cannot direct 

attack fire with 

hand crews)

2,574 67.2 268.8 

4 22.0 (Cannot 

direct attack fire 

with hand crews)

5,550.6 309.4 1237.6 

8 1.2 145 0.3 1.0 

9 3.2 574 9.0 36.2 

10 

EXISTING 

5.9 (Cannot direct 

attack fire with 

hand crews)

660 4.2 16.9 

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 

11 3.9 455 4.1 16.5 

12 

POST HARVEST but

PRIOR TO FUEL 

TREATMENT 

9.4 (Cannot direct 

attack fire with 

hand crews)

1049 10.3 41.1 

xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 

1 4.6 (Cannot direct 

attack fire with 

hand crews)

5,610 312.6 1,250.6 

8 1.2 145 0.3 1.0 

9 

POST HARVEST and 

AFTER FUEL 

TREATMENT 

3.2 574 9.0 36.2 

A/ Any fire with flame lengths greater than 4 feet cannot be fought by fire crews building firelines 

immediately adjacent to the fire. Fires with flame lengths less than 8 feet can be fought by a tractor 

(dozer). Any fire with flame lengths over 8 feet can only be fought by indirect means such as aerial 

retardant. 

As also can be seen in the table, the potential to suppress a wildfire ignited after harvest 

and before fuel treatment would depend on fuel loading and fuel bed depth. If fuel loading 

(1 hr to 100 hr fuels= .25 to 3.0” diameter) was 11.5 tons/acre or less and fuel bed depth 

was 1 foot or less, then fire crews could potentially directly suppress such a fire. However, 

if 1 to 100 hr fuel loading was heavy (34.6 tons/acre) and fuel depth was 2.5 feet and less, 

then only indirect methods such as aerial retardant or burnout from watershed divides 

would be the options. 

With a fire burning under expected post-treatment conditions (Fuel Models 8 or 9), it 

would be possible to suppress with hand fire crews since both FL and ROS are 

significantly lower and within the capabilities of hand crews to suppress. However, in 

those stands that develop a grass understory, FL and ROS would be such that direct attack 

would not be appropriate. However, because of the light fuels (grass) that would burn, the 

fire would tend to be a ‘woof....puff’- e.g. little residual burning. 

In the long term, the amount of down dead fuel would decrease as any remaining slash 

following fuel treatment decomposes. In the same period of time, the amount of live fuel 

would increase as brush and hardwoods resprout and tree crowns grow taller and wider. 
29

This gradual increase in live fuel would result in a gradual increase in fire hazard but only 

in the highest fire danger situations. These stands should continue to act as FM 5, 8, and 9 

during this time. In addition, the leave trees in these stands will significantly increase in 

diameter and will become less susceptible to low intensity, cambium-killing wildfire 

(Andrews 1986). Depending on the initial leave tree spacing, crown closure would occur 

in 15-20 years. 

Ladder Fuel. In the short term, ladder fuels would be significantly reduced because of the 

separation of crowns and boles by the proposed ‘thinning from below’ as well as any 

subsequent understory thinning for the less than 7” DBH material. Therefore, the risk of 

within stand crown fire ignition and spread or tree torching would be reduced. Pruning 

would further reduce the risk even more. Pruning typically treats the lower 8, 12, or 16 

feet of the tree bole. Ten feet of crown to ground separation would likely prevent a 5-foot 

flame from accessing the tree’s crown. (Alexander, 1988) 

Over the long term, the amount of ladder fuel will increase as hardwoods and brush 

resprout and new conifers become established (‘ingrowth’). Primary factors determining 

ladder fuel development include site quality, thinning spacing, species present (hardwoods, 

brush, conifers, etc), mineral soil exposure, size of seed crops, speed of stand re-closure 

after thinning, etc. Ladder fuels develop faster with better site quality, wider thinning 

spacing, more brush or hardwoods, greater mineral soil exposure, larger seed crops, and 

slower stand closure. Particularly those shrubs and hardwoods that were ‘cut back’ during 

thinning will resprout and grow aggressively from an existing root system. This 

‘ingrowth’ is a primary consideration in determining thinning spacing as well as 

underburning timing. Too wide a spacing frequently means the site is not optimally 

stocked (Matrix lands) and too much ‘ingrowth’ is permitted. However, too narrow a 

spacing results in poor growth response to leave trees but less ‘ingrowth’. This requires 

‘balance’. 

The species, size, amount, etc. of hardwood/brush regrowth is considered when 

determining the time to implement an underburn. Typically, such burns are implemented 

within 1-2 years after harvest and then again approximately 5 years after the 1st underburn. 

The objective is to ‘rob’ these resprouts of their viability by limiting the amount of time in 

which they can create and store nutrients to sustain their growth and burning after these 

species expend significant resources in growing or putting on leaves. 

Crown Fire Potential. In the short term, crown fire potential would be significantly 

reduced because tree crown separation would reduce crown bulk density in the treated 

stand. Following thinning and fuels treatment, significantly higher fire intensities and rates 

of spread would be needed to sustain a crown fire. (Graham et al. 1999) 

However, a confounding effect of thinning in relation to flame length, rates of spread, and 

crown fire potential is that ‘within’ stand wind speeds tend to be higher in thinned versus 

unthinned stands because of increased openings. In general, increased wind speeds result 

in increased flame lengths and rates of spread. For example, a 50 mph (20 ft wind speed) 

would create a 5 mph mid-flame wind speed in a closed stand. However, it would only 

take a 16-25 mph (20 ft wind speed) to create a similar mid-flame wind speed in a thinned 

stand. Therefore, if ladder fuels remain following thinning, the higher flame lengths could 

ignite crowns even higher from the ground (Graham et al. 1999). 
30

Over the long term, crown fire potential will increase as leave tree crowns re-close and 

ladder fuels increase. However, it is not expected that crowns will re-close for 10- 20 

years depending on the thinning prescription. In addition, the removal of ladder fuels at 

the time of thinning will have increased the vertical separation between the leave tree 

crowns and the ground. Even though shrub and hardwood ladder fuels will probably grow 

more aggressively than the leave tree conifers due to resprouting, it is still expected that 

there will be less ladder fuel and crown fire potential over the long-term than would have 

existed without thinning and fuel treatment. 

2. Alternative (Proposed Action) 

Indirect Effects

Fuel Hazard, Ladder Fuel and Crown Fire Potential: These thinning and fuel 

treatments could provide a short-term, indirect benefit to surrounding stands in the event 

that a wildfire starts in a treated area and moves toward untreated adjacent stands due to 

generally lower wildfire intensity and easier control. Flame lengths will likely be less than 

4’ permitting direct attack by hand crews. In addition, ladder fuel will be reduced adjacent 

to the edges of the treated stand. As a result, fire moving to adjacent stands and becoming 

a crown fire is less likely. 

 

There would be beneficial short-term, indirect effect on wildfire spread and crown fire 

potential because of associated timber sale activities. Temporary road construction, 

reconstruction and maintenance will improve wildfire suppression access (and speed of 

access). In addition, these roads will provide additional fire suppression and control 

locations regardless of fuel loading, ladder fuel or crown fire potential. Improved access 

and additional control-line locations provide more options in suppressing a wildfire 

regardless of fire behavior. 
2. Alternative (Proposed Action) 

Cumulative Effects

The Forest Service is currently implementing a NEPA approved fuel hazard reduction 

project within the Lower Applegate watershed in Waters, Round Prairie, and Newt Gulch 

Creeks called Waters #2 and Round Prairie Creek Hazardous Fuel Reduction CE,

approved February 5, 2007. The approved treatments only treat vegetation that is 9” DBH 

and less. Commercial harvest, mechanical treatment and road building is not authorized. 

That project has identical treatments to those proposed in this project with the exception of 

commercial harvest, mechanical treatment and road construction/maintenance. The SW 

corner of this project area abuts the NE corner of the Butcherknife/Slate project area. See 

map. 

These treatments will be implemented over approximately 10 years on 2,164 acres. For 

purposes of this analysis, I assumed that an average of 500 acres of understory treatments 

will be implemented per year (note: some acres will be treated more than once). 

31
The BLM is in the process of completing a NEPA analysis project called Cheney/Slate 

which is also in the Lower Applegate Watershed. This project proposes to commercially 

treat the following acres by harvest method: 

1 Density Management/Group Selection= 663 acres 

2 Density management/Understory Reduction= 805 acres 

3 Regeneration Harvest= 535 acres 

4 Restoration Thinning= 108 acres 

5 Variable Density Thinning= 314 acres 

6 Hardwood Conversion= 55 acres 

Total Treatment Acres= 2,490 

32
In addition, the BLM also proposes an additional 5,751 acres of non-riparian, noncommercial, understory treatment and 1,869 acres of riparian, non-commercial, understory 

treatment with activities similar to those proposed in Butcherknife/Slate. See following 

maps. 

33
34

Fuel Hazard, Ladder Fuel and Crown Fire Potential: The greatest cumulative effects 

of these treatments and the other identified treatments by the Forest Service and the BLM 

in reducing fuel hazard, ladder fuel and crown fire potential will be in those subwatersheds where: 

--the most acres are treated, 

--the most acres are treated along strategically important, wildfire suppression, 

topographic locations, 

--treated stands are close together, 

--treatment units are large, 

--treatment units are laid out perpendicular to the prevailing wind direction and are 

of such width as to provide a significant impediment to wildfire movement, 

--treatment units are relatively regularly scattered over the landscape, 

--large areas of recent (within 5-10 years), previously treated stands occur in area, 

and 

--recent wildfires underburned the area (within 5-10 years). 

The magnitude of this effect would be directly proportional to the acres treated by 

category. 

C. PARTICULATE EMISSIONS (e.g. Smoke) 

Computer modeling using the Forest Vegetation Simulator (FVS) estimated particulate emissions 

(smoke). This model used the results of the stand examinations completed in this area in 2008. 

NOTE: An alternative computation method to estimate wildfire or prescribed fire, particulate 

emissions (PM10 and PM2.5) is via the use of the following formula (USDA et al, 2001): 

E= EF x L x A 

Where: E= Total emissions of the pollutant (mass of the pollutant in tons) 

EF= Emission factor for the pollutant (mass of the pollutant/mass of forest 

fuel consumed, in lbs/ton). 

L= Fuel consumed (mass of fuel consumed per unit area of land burned in 

tons/acre) 

A= Land area burned in acres 

 Where emission factors for burning are as follows: 

a. Mixed conifer= 20.5 #/ton of consumed fuel (PM10)

b. Mixed conifer= 18.8 #/ton of consumed fuel (PM2.5) 

c. Hardwood= 25.0 #/ton of consumed fuel (PM10)

d. Hardwood= 22.4 #/ton of consumed fuel (PM2.5) 

This analysis assumes the following: 

1. Harvest in 2009, Pile Burn in 2009, Underburn in 2011 (serpentine and non-serpentine areas), 

Underburn in 2015 (non-serpentine areas and small meadow serpentine area only) 

2. Pile burning consumption= 90%

3. Serpentine underburns will be produce emissions comparable to 2nd underburn (21015) of nonserpentine areas 
35

4. Year 2009 pile burning emission production (From computer modeling using Forest 

Vegetation Simulator (FVS)): 

PM2.5 

-0.38 tons/acre of PM2.5 

PM10 

-0.44 tons/acre of PM10 

5. Underburning emissions production (From computer modeling using Forest Vegetation 

Simulator (FVS)): 

PM2.5 

-0.07 tons/acre in 2011 

-0.07 tons/acre in 2015 

PM10 

-0.08 tons/acre in 2011 

-0.08 tons/acre in 2015 

1. Alternative (No Action)

Direct Effects

There would be no emissions of particulates or smoke. 

1. Alternative (No Action)

Indirect & Cumulative Effects

None 

2. Alternative (Proposed Action)

Direct Effects

The following table displays projected total smoke emissions from pile and underburning 

over the life of this project. 

ESTIMATED EMISSIONS FROM PROPOSED ACTION

FUEL 

TREATMENTS

PM2.5 (tons) PM10 (tons)

Pile Burning (2009) 

(2,134 ac) 

811 939 

Underburning (2011) 

(all serpentine areas) 

(1,934 ac) 

136 155 

Underburning (2011) 

(non-serpentine 

areas) (2,712 ac) 

190 217 

Underburning (2015) 

(small serpentine 

meadow area) (122 

ac) 

9 10 

Underburning (2015) 

(non-serpentine 

areas) (2,093 ac) 

147 168 

TOTAL 1,293 TONS 1,489 TONS 

All internal combustion engines including skidders, yarders, road maintenance equipment, 

mechanical chippers, mechanical timber harvesters, chainsaws, etc. produce some 
36

incidental emissions (primarily smoke) associated with their use. Such equipment 

produces emissions that primarily affect the immediate area because of their limited 

numbers, engine design, limited fuel consumption per hour, fuel chemistry and exhaust 

design. 

Some portion of the slash material that would be created by this project is likely to be 

removed as biomass (probably chips), which will likely be used in co-generation power 

plants. This directly reduces the total fuel loading that would be burned without the use of 

some sort of pollution control device such as would be used in a co-generation plant. This 

reduces the smoke emissions of PM2.5 (tons) and PM10 (tons) proportional to the 

proportion of total fuel removed as biomass and the acres affected. 

We are required to manage all smoke emissions according to the requirements of the 

Oregon Smoke Management Plan by implementing projects when conditions are favorable 

for: 

--low smoke emissions (dry fuels), 

--low duration of emission and, or 

--smoke traveling away from populated areas. 

Factors that influence the type and amount of emissions, their longevity in atmosphere, and 

their potential to affect populated areas include such things as: 

--wind speed and direction (low level), 

--wind speed and direction (upper level), 

--atmospheric instability (i.e. the tendency for smoke to rise in the atmosphere), 

--relative humidity (lower is better), 

--fuel moisture (lower is better), 

--fire intensity (higher is better), etc. (Note: Fire behavior (broadcast or underburn) 

can be adjusted within certain limits to limit emissions by way of changes in fire 

intensity.) 

 

We will appropriately consider and utilize these factors when implementing these projects 

in order to keep any emissions away from the Smoke Sensitive Receptor Areas (SSRA) of 

Grants Pass, Medford and the Kalmiopsis Wilderness (Class 1 airshed). For other 

populated areas, we will attempt either keep smoke from these areas or limit the amount or 

longevity utilizing the same types of mechanisms. 

 

It is my professional opinion that prescribed burning smoke will not result in any 

unacceptable impacts to the Smoke Sensitive Receptor Areas (SSRA) of Grants Pass or 

Medford based on: 

--our successful, past experience in conducting many prescribed burns in similar 

areas affecting similar acreages, 

--our consistent use of the various smoke avoidance, reduction, or minimizing 

mechanisms 

--our consistent coordination with the Oregon State Smoke Management office and 

the weather service, 

--the estimated tons of particulates to be created, and 

--the general prevailing wind direction. 

The same conclusion is true for the Kalmiopsis Wilderness (Class 1 airshed) because of 

these factors and the distance (10 miles) to this area. Any smoke impacts are expected to 

affect a limited, local area and to be of short duration. 
37

2. Alternative (Proposed Action)

Indirect Effects

None 

2. Alternative (Proposed Action)

Cumulative Effects

The average, annual burning program for the Wild Rivers Ranger District is approximately 

1,000 acres. I estimate that an average of 500 acres/year of this occurs within the 

watersheds affected by this project. In addition, the Bureau of Land Management (BLM) 

has a proposed project called Cheney/Slate that has similar activities to those in this 

project. The BLM (A. Mitchell) estimated that approximately 500 acres/year of similar 

timber sale and hazardous fuel reduction projects would occur on BLM lands within these 

affected watersheds. 

One can assume that these existing, ongoing projects probably produce similar emissions 

to those in the table if adjusted for the acreage difference between these projects. In 

addition, we might also assume that these current projects have NOT had biomass removed 

because of few local users of such material. 

The other Forest Service and BLM prescribed burning projects would likely generate 

similar emissions to those calculated by the Forest Vegetation Simulator (FVS) analysis 

for the Butcherknife/Slate project (because of similar prescribed burning activities in these 

other projects). Therefore, I used the weight average emission factors for the 

Butcherknife/Slate project to estimate the total emissions from these other projects. 

ESTIMATED EMISSIONS FOR OTHER ON-GOING FOREST SERVICE and

BLM PROJECTS BASED ON AVERAGE EMISSIONS FROM 

BUTCHERKNIFE/SLATE PROJECT (FVS ANALYSIS)

FUEL 

TREATMENTS

Acres PM2.5 (tons) 

Emission 

Factor 

Acres x 

Emission 

Factor 

PM10 (tons) 

Emission 

Factor 

Acres x 

Emission 

Factor 

Pile Burn (2009) 2134 0.38 810.92 0.44 938.96 

Underburning 

(2011) 

1934 

0.07 135.38 0.08 938.96 

Underburning (2011 2712 0.07 189.84 0.08 154.72 

Underburning 

(2015) 

122 

0.07 8.54 0.08 216.96 

Underburning 

(2015) 

2,093 

0.07 146.51 0.08 9.76 

TOTAL 8995 n/a 1291.19 n/a 1487.84 

Weighted Average 

Emission Factor by 

Acres n/a 0.14 n/a 0.17 n/a 
38

Displayed in the following table is the total, cumulative, tons of smoke emissions for the 

Butcherknife/Slate project and the other on-going Forest Service and BLM projects. This 

table assumes that the other Forest Service and BLM project treatment acres would 

continue for 10 years. 

ESTIMATED TOTAL EMISSIONS (Tons) FROM PROPOSED ACTION and 

OTHER ON-GOING FOREST SERVICE and BLM PROJECTS OVER A 10 YEAR 

PERIOD OF TIME (see above table)

Forest Service (500 acres/year) BLM (500 acres/year) Project PM2.5 tons PM10 tons PM2.5 tons PM10 tons

Butcherknife/Slate 

Project 1,293 1,489 0 0 

Other Projects 

(assuming 10 year 

total timeframe) 

700 850 700 850 

TOTAL 1,993 tons 2,339 tons 700 tons 850 tons 

GRAND TOTAL 5,882 TONS or 588 TONS/YR. 

Again, it is my professional opinion that prescribed burning smoke will not result in any 

unacceptable impacts to the Smoke Sensitive Receptor Areas (SSRA) of Grants Pass or 

Medford based on: 

--our successful, past experience in conducting many prescribed burns in similar 

areas affecting similar acreages, 

--our consistent use of the various smoke avoidance, reduction, or minimizing 

mechanisms 

--our consistent coordination with the Oregon State Smoke Management office and 

the weather service, 

--the estimated tons of particulates to be created, and 

--the general prevailing wind direction. 

The same conclusion is true for the Kalmiopsis Wilderness (Class 1 airshed) because of 

these factors and the distance (10 miles) to this area. Any smoke impacts are expected to 

affect a limited, local area and to be of short duration. 
39

 Literature Cited

Agee, James K, 1993. Fire Ecology of Pacific Northwest Forests. Island Press. 493 pages. 

Alexander, Martin E., 1988. Help with Making Crown Fire Assessments. In: Fischer, 

William C.; Arno, Stephen F.; comps. Protecting people and homes from wildfire in the 

Interior West: Proceedings of the symposium and workshop; October 6-8, 1987; Missoula, 

Montana. General Technical Report INT- 251. Ogden, Utah: USDA, Forest Service, 

Intermountain Forest and Range Experiment Station: 147-156 

Anderson, Hal E. 1982. Aids to Determining Fuel Models for Estimating Fire Behavior. 

National Wildfire Coordinating Group. NFES 1574; Gen. Tech Report INT-122. 

Anderson, Hal E. 1982. Aids to Determining Fuel Models for Estimating Fire Behavior. 

National Wildfire Coordinating Group. NFES 1574; Gen. Tech Report INT-122. 

Andrews, Patricia L., 1986. BEHAVE: Fire Behavior Prediction and Fuel Modeling 

System—BURN Subsystem Part 1. National Wildfire Coordinating Group. PMS 439-2 

(NFES 0276) 

Andrews, Patricia L.and Chase, Carolyn H. 1989. BEHAVE: Fire Behavior Prediction and 

Fuel Modeling System—BURN Subsystem Part 2. National Wildfire Coordinating Group. 

PMS 439-3 (NFES 0277) 

Environmental Protection Agency. 2007. (January 22, 2007 update) The Plain English Guide 

to the Clean Air Act: Glossary. Available Online: www.epa.gov/oar/oaqps/peg_caa/pegcaa10

(Accessed January 22, 2007)

Environmental Protection Agency. 2006A. (December 16, 2006 update) National Ambient Air 

Quality Standards (NAAQS). Available Online: (www.epa.gov/air/criteria) (Accessed January 

22, 2007)

Environmental Protection Agency. 2006B. Clean Air Act: Part C - Prevention of Significant 

Deterioration of Air Quality, SUBPART 1 - Clean Air. Available Online: 

www.epa.gov/air/caa/title1 (Accessed January 22, 2007)

Final Environmental Impact Statement, The Biscuit Fire Recovery Project, Rogue RiverSiskiyou National Forest, Josephine and Curry Counties, Oregon, Volume 1, June 2004. 

Hann, Wendel, Havlina, Doug, Shlisky, Ayn, et al. 2003. Interagency and The Nature 

Conservancy fire regime condition class website .USDA Forest Service, US Department of the 

Interior, The Nature Conservancy, and Systems for Environmental Management [frcc.gov]. 

Fire Regime Condition Class Definition; Available Online: 

www.frcc.gov/docs/FrccDefinitionsFinal (Accessed: January 22, 2007). 

National Wildfire Coordinating Group (NWCG), July 1994. Intermediate Wildland Fire 

Behavior (S-290). NFES 2378. 360 pages. 
40

Oregon Smoke Management Plan ORS 477.013, 477.515, ORS 477.552 through 562, OAR 

629-043-0040, OAR 629-048-0001 through 629-048-0500. (Draft Directive January 2008). 

Available Online: www.odf.state.or.us/DIVISIONS/protection/fire_protection/smp/629043 or 

other pertinent links at www.odf.state.or.us/DIVISIONS/protection/) (Accessed: November 

17, 2008) 

Oregon Department of Forestry and Oregon Department of Environmental Quality, March 

2005. Memorandum of Understanding to Establish New Requirements Related to Reducing 

Smoke from Slash Pile Burning on Forest Lands in Oregon, and to Clarify Provisions in DEQ 

Open Burning Rules Related to the Burning of Prohibited Substances. 

Oregon Department of Environmental Quality (DEQ), Updated 2006. 2005 Oregon Air 

Quality Data Summaries. Available Online: www.deq.state.or.us/aq/forms/2005ar/trends. 

(Accessed: January 23, 2007) 

Reinhardt, Elizabeth D; Keane, Robert E.; Brown, James K.; January 1997. First Order Fire 

Effects Model: FOFEM 4.0 User’s Guide. USDA Forest Service, Intermountain Research 

Station; Gen Tech Report INT-GTR-344. 

Runesson, Ulf T., 2007. Glossary of Forestry Terms. Faculty of Forestry and the Forest 

Environment,Lakehead University, Ontario, Canada . Available Online: 

http://www.borealforest.org/nwgloss4 (Accessed January 22, 2007) 

Russel, Graham T; Harvey, Alan E.; Jain, Threasa B.; Tom, Jonalea T.. September 1999. The 

Effects of Thinning and Similar Stand Treatments on Fire Behavior in Western Forests. 

USDA Forest Service, Pacific Northwest Experiment Station and USDI Bureau of Land 

Management, General Technical Report PNW-GTR-463. 27 pgs. 

Siskiyou National Forest, USDA Forest Service, 1998. Wildfire Prevention Analysis and 

Plan- Siskiyou National Forest. 

Siskiyou National Forest, USDA Forest Service. 1989. Land and Resource Management Plan 

– Siskiyou National Forest. Pacific Northwest Region. 

USDA Forest Service and USDI Bureau of Land Management. April 1994. Record of 

Decision for Amendments to Forest Service and Bureau of Land Management Documents 

within the Range of the northern Spotted Owl and Standards and guidelines for Management 

of Habitat for Late Successional and Old Growth Forest Related Species within the Range of 

the Northern Spotted owl. Portland, Oregon 

USDA, USDI, NWCG, National Wildfire Coordination Group, Smoke Management Guide for 

Prescribed and Wildland Fire, eds 2001. PMS-420-2, NFES # 1279, Boise, ID December 

2001.)