Into the Fire: Problems with the Plan
If you’re interested in a more detailed analysis of the proposed fire management plan, here are several important changes that are needed:
● A detailed analysis of the various island habitats along with their relationship to fire needs to accompany the plan for prescribed burning. The island communities respond quite differently to fire, so one plan does not fit all, as proposed in the EA. The location of “unique” habitats should be mapped and available for NEPA analysis.
● A list/map of approved water sources for dipping should be provided and the possible effects of retardant and foam on the individual sources listed. Dipping a bucket in the brackish river is quite different from dipping it in a natural freshwater source on the island or from a tank.
● A map showing where the dumping of salt/brackish water is acceptable must be provided. The false statement on page 63 should be embarrassing to the NPS: “The plants are presumed to have adapted to higher salt levels and should not exhibit signs of salt impact…. Thus, brackish water… should have no adverse impacts….” Wetlands are scattered throughout the northern half of the island, so the precision of drops must be included for NEPA analysis.
● An analysis of salt/brackish water impacts on island vegetation should be provided here if it is to be used.
● The location (map) of intended herbicide use should be included in the EA. Such locations must be identified ahead of time for NEPA analysis. Also the proposed treatment plan should be available for analysis.
● The potential impact of the herbicide on amphibians, reptiles, and insects is not mentioned and should be, especially if the “pesticide use proposal” is approved (page 22).
● Areas where chemical retardants and foam may be used must be clearly identified on a map so analysis is possible. The impact of retardants and foam, each containing different substances toxic to some organisms, must be considered on all island life occurring in the area it is to be used.
● The time of year (months) prescribed fire is to be used in each of the various habitats should be presented for analysis, as well as the frequency of burns on individual areas. There are definite seasonal effects of prescribed burning in Florida. Short cycles can enhance Saw Palmetto dominance and eliminate some seed species, and reduce bird density. Winter burns stimulate vegetation spread and may result in hardwood encroachment over time. Winter burns also are a threat to young animals and dormant amphibians and reptiles. Early spring burns (March) may expose small birds to predation pressure from migrating raptors, and also cause nestling mortality. The timing of introduced fire definitely needs NEPA analysis.
● No minimum tool analysis is provided for scrutiny under the NEPA process. A list of tools possibly used is available, but where and under what conditions is not given. A chart outlining the process simply states that at some point the minimum requirement will be “determined” and the minimum method and tools be “defined.” It leaves every door open and circumvents the NEPA analysis. Where in Wilderness is the use of mastication to be allowed? That decision should be put forth in the proposed plan so it can be subject to the NEPA review, and not just the vague promise made that it will be analyzed at a later date. In Wilderness, a NEPA analysis of tools allowed in various areas is critical to maintaining Wilderness character and integrity. The determination needs to be made NOW so it can be analyzed and not done at the last minute under duress. For example, under what conditions are off-road vehicles “required?” In the past, they have been used in and across wetlands and on every Wilderness trail. How far from a structure may chainsaws, masticators and other motorized equipment be used in the Wilderness, i.e. what size of defensible space is needed? Or is the area designated Wilderness treated with no distinction, as it appears? Protection of structures is understandable but the plan should “plan” a response to fire when it does not threaten structures, one based on the various plant communities and how they respond to fire, so all wildfires are not emergencies.
● The use of Minimum Impact Suppression Tactics (MIST) are mentioned throughout this EA but never listed for NEPA analysis. What tactics would be used in what area/community is important for the integrity and character of the Wilderness, and needs to go through NEPA analysis.
● The NEPA requires that reasonable alternatives, especially the best one for the resource, be provided for analysis. That has not been done in this EA. The most reasonable alternative and the one best for the resource is Alternative 4, which was written so as to be rejected. This alternative would allow natural fire to burn under appropriate conditions decided ahead of time, however the authors added, “…even in Seashore developed areas.” That addition rendered the entire Alternative unacceptable. Where no “important values” (cultural resources, infrastructure, private structures) are located, as is the case with most of the island Wilderness, a management plan could/should outline the conditions under which natural fires would be allowed to burn. What we have here is the transparent, easy way out for the agency to the detriment of the resource.