FEMA Rule Change Could Make Tree-felling Easier
August 14, 2014
Very often, land managers seeking funding for a project look to the Federal Emergency Management Agency (FEMA) for funds. FEMA provides money for fire hazard reduction, and if the project can be presented in those terms, the land managers can apply for a grant.
Until now, if a project seeking FEMA funding was large enough, FEMA asked the project sponsors for an Environmental Impact Report. This made a lot of sense: Fire hazard reduction projects have massive impacts on the landscape and habitat, much of it negative.
BUT THERE’S A NEW PLAN
Now, FEMA plans a “programmatic environmental assessment (PEA) to evaluate the potential beneficial and adverse impacts from eligible wildfire mitigation activities funded under the Hazard Mitigation Grant Program (HMGP) and Pre-Disaster Mitigation (PDM) Program.” What this amounts to is that fire hazard reduction projects would be “pre-cleared” from an environmental standpoint. FEMA is planning to make this a nationwide measure.
It would apply to three types of wildfire mitigation projects to protect buildings and structures on the Wildland-Urban Interface (i.e. where structures are within 2 miles of a wildland):
- “Defensible space—The creation of perimeters around residential and non-residential buildings and structures through the removal or reduction of flammable vegetation;
- “Structural Protection through Ignition-Resistant Construction—The application of non-combustible building envelope assemblies, the use of ignition-resistant materials, and the use of proper retrofit techniques in new and existing structures; and
- “Hazardous Fuels Reduction—Vegetation management to decrease the amount of hazardous fuels; vegetation thinning; and reduction of flammable materials to protect life and property beyond defensible space perimeters but proximate to at-risk structures.”
The first two measures are not controversial, and can reduce hazard with a relatively minor environmental impact. However, the third one – Hazardous Fuels Reduction – is much more problematic for the environment.
WHY IS THIS A PROBLEM?
Tree removal – for whatever reason – is one of the costliest activities for a land manager. This makes any potential source of outside funding attractive. FEMA is one such source. So if any tree-felling project can be presented as hazard reduction, it has a chance of obtaining such funds. Not having to do an environmental impact report would make the money more easily accessible.
However, removing trees also has a significant environmental impact, which can be greater or lesser depending on the size of the project, the topography of the site, and the ecological system that would be affected. Some of the impacts:
- Hydrology: Removing trees affects water flow and can lead to problems with erosion
- Slope stabilization issues: The root systems of trees – especially older, mature trees that may have intergrafted roots – stabilize slopes. Removing trees can contribute to slope failures years – even decades – later.
- Carbon sequestration: Trees capture and store carbon, fighting global warming. Felling trees stops them from collecting the carbon, and returns it to the atmosphere.
- Toxic herbicides: In many of these projects, managers plan to use large amounts of herbicides to prevent tree regrowth. This can end up in the soil and water, and also affect people, pets and wildlife using the lands.
- Pollution: Trees and vegetation help fight pollution, particularly particulate pollution, by trapping particles on their leaves until they’re washed to the ground by rain.
And of course, removing trees affects the beauty and recreational value of these areas. It’s only by evaluating the environmental impact of individual projects that FEMA can determine if the negative environmental impact would be worth the hazard reduction – if any. Ironically, many of these projects would actually increase fire hazard, because removing the trees encourages growth of scrub and grass that ignite more easily and support fast-moving fires.
We’ve been concerned because we think that Native Plant “restoration” projects are often presented as hazard reduction projects. In 2008, FEMA received such an application for tree-felling in Sutro Forest. More recently, FEMA was asked to fund the removal of hundreds of thousands of trees in the East Bay.
HOW AND WHERE TO COMMENT
FEMA is accepting comments until August 18th, 2014 – this coming Monday. The comments have to be submitted at their website (not by email). Here’s how:
- Go to the Federal eRulemaking Portal: http://www.regulations.gov
- In the Search space that comes up, input FEMA-2014-0021
- Then click on Open Docket folder at the right.
They’re not interested in comments that look like a mass mail campaign, so to have an impact, you would have to write a the comment individually.