The Houston Regional Group and the Lone Star Chapter of the Sierra Club (Sierra Club) submitted comments to the U.S. Forest Service (FS) about its proposed 10-Year Prescribed Burn Project (10-Year Project) in Sam Houston National Forest (SHNF).
The Sierra Club supports the use of prescribed fire so that it affects forests in a manner that is similar to what occurred before Anglo settlers came to East Texas in the 1800’s. The Sierra Club supports the management of SHNF for the federally endangered Red-cockaded Woodpecker (RCW) on uplands. The Sierra Club is concerned the proposed 10-Year Project will not be as effective as it should. The Sierra Club urges the FS to provide an analysis about how well the present prescribed burning program has been implemented in SHNF.
The Sierra Club expressed concern that the FS insists all RCW clusters (homesites) and foraging areas have a grass and herbaceous groundcover. The Sierra Club stated that in some places this groundcover exists but in other places, particularly on the East Side of SHNF, it does not. The FS must tell the public why grass and herbaceous groundcover has not grown in all parts of SHNF after almost 30 years of prescribed burning. The FS must analyze how the prescribed burning program can work better in the future.
The failure to achieve grass and herbaceous groundcover may be soil related. In some places on uplands or slopes, mesic (intermediate moisture holding) soils are found which allow hardwood trees to compete better with pine trees. Some RCW goals have pushed management (burning and logging) into areas where hardwood tree, not pine tree, dominance naturally occurs.
The Sierra Club encouraged the FS to conduct late growing season burns (June, July, August, and September). The literature documents that late growing season burns occur when natural lightning fires occur and reduce the growth and survival of woody plants.
The Sierra Club told the FS that there is not the commitment to collaboration that there use to be. The 10-Year Project covers 124,200 acres of SHNF’s 163,045 acres. This is about 76.18% of SHNF. This is a huge project area and is long-term because it will be in effect for 10-years, with no additional public review, comment, collaboration, participation, and input. The lack of public participation concerns the Sierra Club.
The Sierra Club is opposed to “categorically exclusion” that the FS proposes for the 10-Year Project. The Sierra Club believes the 10-Year Project is a “major federal action significantly affecting the quality of the human environment” and requires an environmental impact statement be prepared.
In some places the FS wants to burn on a one-year rotation. This will result in forest over-burning. The Sierra Club believes that use of a one-year burn rotation will force too much fire where it does not belong as frequently in areas where woody plants are the natural understory and yearly forest debris will not support an adequate burn.
The Sierra Club expressed concern about “sensitive areas”, like baygalls (sensitive forested wetlands), that could be damaged by bulldozers that create fire lines; use of heavy equipment in “exclusion zones” along streams; the need to control non-native invasive plant and animal species (like feral hogs); and spoke for the protection of the Lone Star Hiking Trail so it is not plowed up by bulldozers and other heavy equipment during the preparation, implementation, and mop-up of prescribed burns.
The Sierra Club will continue to monitor the progress of the 10-Year Project. For additional information contact Brandt Mannchen at 832-907-3615 or brandtshnfbt@juno.com.