Response

Fire/Prescribed Fire
Comment
The proposed uneven aged management of 144,000 acres of ponderosa pine forests on former tribal
lands is a good starting point for maintaining vegetation diversity on this portion of the Forest but the
practice needs to be coupled with a prescribed burning program to insure that the stands do not convert
to pine associated or fir dominated forests. Prescribed burning should in fact be instituted across the
Forest to help return the vigor to some of the stands and to assist in the control of forest pests.
Re-introduction of fire into the east Cascades forests will also help return the composition of the forests
to more Ponderosa pine dominated stands, which more closely simulates the natural composition of
the forest and which is the preferred species by timber interests and local economics.
Response
The 144,000 acres of ponderosa pine forest that is planned for uneven aged management has ponderosa
pine as the climax species. Therefore there is no need to use fire to assure maintenance of ponderosa
pine. It is planned to manage some of the pine associated in uneven aged management favoring
ponderosa pine. This will be accomplished through various silvicultural practices that will favor ponderosa
pine.
Based on some current research there is some question on the desirability of a prescribed burning
program on pumice soils to maintain stocking or reduce natural fuels. There appears to be a reduction
of site productivity as the result of the burning. There is a indication that the greater the intensity of
the burn the greater the loss of site productivity.
Comment
The Department of Forestry supports a policy of applying aggressive suppression action to wildfires
that threaten life, private property, public safety, improvements, or investments. Unplanned ignitions
should be used as prescribed fires only if compliance with the Oregon Smoke Management Plan can
be assured (protection of Class I viewsheds--Wilderness). The Winerna should more clearly emphasize
compliance with this plan since the Environmental Protection Agency (EPA) has approved Oregon's
plan as meeting the requirements of the Clean Air Act as amended in 1987. Coordination of protection
planning and suppression efforts with other protection agencies, including this Department, should be
included as an integral part of these guidelines.
Response
On page IV-53, Forest Management Direction, of the "PROPOSED LAND AND RESOURCE MANAGEMENT
PLANO it is stated that the Forest will comply with all applicable air quality laws and regulations and
coordinate with appropriate air quality regulating agencies. Currently, and in the future, all planned
ignitions are, and will be, conducted according to the OOPERATIONAIL GUIDANCE FOR THE OREGON
SMOKE MANAGEMENT PROGRAM' which is administered by the Oregon State Forester.
In addition, the Forest has agreed to comply with the the voluntary smoke management advisories
issued by the Salem office of Oregon Department of Forestry.
Since the Forest has no approved prescribed natural fire program all unplanned ignitions will be treated
as a wildfire. Each wildfire will receive an appropriate suppression response. When a prescribed natural
fire program is developed it will allow for participation by the public and other protection agencies.
One of the requirements will be that prescribed natural fires will be in compliance with the Oregon
Smoke Management Plan. It should be noted that only one of the Forest's wildernesses is a Class I
area, that is the Mountain Lakes Wilderness. On page 111-9 states that the Forest operates under the
policy and standards established in Federal and State air quality rules and regulations.
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