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BLM photos (top, then clockwise): a fuel break along a road; a mower chopping down vegetation for same; a “green strip” fuel break of reseeded vegetation, in this case non-native Crested Wheatgrass for cattle.

If there’s one thing we can count on when it comes to the Bureau of Land Management (BLM), it’s that they’ll say whatever they need to in order to serve their primary constituents: the ranching and resource extraction industries. Not for nothing are they known as the Bureau of Livestock and Mining. On February 14th, they released their latest con: the “Final Programmatic Environmental Impact Statement for Fuel Breaks in the Great Basin” (hereinafter, “the PEIS”).

“Fuel breaks”? Must have something to do with fighting wildfires, and we all know what a problem those have been lately, so this must be a good idea, right? Moving right along, then…

Wait—not so fast! Even a cursory look with an environmental eye reveals the act of wanton destruction that this project actually is, and a practical appraisal shows that it won’t even be effective in fighting the big wildfires that are becoming the new normal under Climate Change.

The basics of the plan: Create “fuel breaks” by clearing vegetation along 11,000 miles of BLM roads and rights-of-way, to a width of 500 feet (250 feet on each side). The total potential area affected directly is just over 1,000,000 acres.

This is a big project and a big fraud.

I’ve spent time camping on BLM land in various parts of the Great Basin and some of the “roads” are just two ruts with greenery between. They’re no more than ten feet across, so they would be widened by a factor of fifty. What are now in many cases relatively minor disturbances will become quite significant.

I am reminded of the “roadside hazard reduction” that the Forest Service implemented in the wake of forest fires in southern Oregon, where all trees were removed on both sides of the road in wide strips. The excuse was that burned trees could fall into the road and pose danger to public safety. The Forest Service never explained how this could possibly apply to trees on the steep slopes far below the roadways, which they also removed.

As for the “fuel breaks” project, it will be executed with a variety of means, according to the PEIS:

* Prescribed burns, both aerial and hand ignited

* Mechanical treatment

* Chemical treatment

* Targeted grazing

* Seeding

* Conifer removal

Some details on these methods follow, below.

(In researching this article, I communicated by email with Katie Fite, Director of Public Lands for Wildlands Defense, and by phone with Laura Cunningham, California Director of the Western Watersheds Project (WWP). Cunningham also forwarded to me the 73 page letter that was submitted to the BLM during the comment period for this project by the WWP, the Center for Biological Diversity, the Oregon Natural Desert Association, the Southern Utah Wilderness Alliance, Basin and Range Watch, the Grand Canyon Trust, and Defenders of Wildlife. I will cite this document as “comment letter.”)

Mechanical Treatment

From the PEIS:

“Mechanical treatment methods are for vegetation reduction or removal, seedbed preparation, seeding, and special uses… Vegetation removal equipment includes agricultural mowers and masticators. An agricultural mower can be used to reduce the height of herbaceous vegetation. Masticators can also be used to cut and chop or grind vegetation which is usually left in place as mulch. Debris will be removed from the road surface to allow for access through the treatment area. A common type of masticator uses a rotary drum equipped with steel chipper tools to cut, grind, and clear vegetation… Seedbed preparation equipment includes disks and plows, chains and cables, pipe harrows, rails and drags, land imprinters, and root plows. Equipment used for seeding includes drills, broadcast seeders, seed dribblers, brillion seeders, surface seeders, interseeders, and hydro seeders. Finally, mechanical tools for special uses includes transplanters, roller choppers, dozers and blades, trenchers, scalpers and gougers, fire igniters, chemical sprayers, and steep-slope scarifier seeders.”

That’s a lot of heavy, motorized, pollution-spewing equipment ripping up the landscape. Not only plants are removed by their activity; burrows and nests of mammals and birds are buried and smashed, eggs and larvae of insects are killed, and delicate living soil crusts are destroyed. It’s virtually impossible to tally up all the victims of such an assault. The area left behind is susceptible to erosion and is an ideal setting for non-native annual grasses that are themselves fire hazards. In this case, “mechanical treatment” is another way of saying “massive disturbance.”

Chemical Treatment

This means “herbicides.” The PEIS provides a list of substances and describes their means of dispersal:

“2,4-D, bromacil, chlorsulfuron, clopyralid, dicamba, diuron, glyphosate [the active ingredient in Monsanto’s notorious Round-Up], hexazinone, imazapyr, metsulfuron methyl, picloram, sulfometuron methyl, tebuthiuron, triclopyr, imazapic, diquat, diflufenzopyr (in formulation with dicamba), fluridone, aminopyralid, fluroxypyr, and rimsulfuron. Chemical treatment application methods can be applied on the ground with vehicles or manual application devices or aerially [!] with helicopters or fixed-wing aircraft. The success of any method or tool is subject to a wide variety of environmental factors; given this complexity, it is sometimes necessary to treat an area multiple times to achieve the desired objectives.”

The use of herbicides in any setting is deeply problematic, but especially so in the wild. Collateral damage to non-target plants is virtually guaranteed, especially when applied from the air. Even if applied by people at ground level, wind will invariably carry the chemicals outside the 500 foot wide zone. I could write an entire article just about this list of toxins, so suffice it to say that they’re all bad news.

The comment letter notes: “The herbicide Plateau (active ingredient imazapic) kills a wide range of native plant species and often completely wipes out all native species on a site.” Brutal.

Further, they note: “The impacts of these dangerous chemicals on specific locations mapped in this PEIS, in sensitive habitats in such places as the Eastern Sierra of California, and high-value native plant communities and species at risk in many other states.” The BLM is definitely under-playing the deleterious effects of chemical treatment.

Targeted Grazing

The BLM plans call for inviting ranchers to bring their cows and sheep to help clear the fuel breaks of vegetation. States the comment letter: “This is an untested method that has the potential to create its own resource damage, including increasing the very exotic plants it is supposed to reduce.” Furthermore:

“Targeted grazing on mowed strips introduces an unpermitted use of public lands, apparently without Annual Operating Instructions or grazing fees, and with vague targeted grazing plans that would be site-specific and apparently outside of the NEPA review process. Livestock will preferentially graze native perennial grasses in these vegetation communities, over Cheatgrass, so any use of targeted grazing in these plant communities will lead to degradation of native perennial grasses and trampling of biological soil crusts, reducing resistance to non-native species invasion.”

Also, bringing domesticated sheep into new areas risks spreading disease to wild Bighorn sheep, whose populations have already been hammered this way. (See “Here are the Facts: Bighorn Sheep vs Domestic Sheep” in the Wildlife News.)

Seeding

After the 500 wide strips is cleared of vegetation, it will then be—get this—reseeded. Will the BLM plant native species, which would be appreciated by native animals and insects? Yes, but not exclusively. States the PEIS: “Requiring native seeds for reseeding fuel breaks could limit the viability of reseeding and the effectiveness of the fuel breaks to modify fire behavior.” The BLM will follow the guidelines set forth in their own “Integrated Vegetation Management Handbook.”

These guidelines allows for the use of “Non-native Plant Materials” if [quoting directly]:

* Suitable native species are not available,

* The natural biological diversity of the proposed management area will not be diminished,

* Exotic and naturalized species can be confined within the proposed management area

* Analysis of ecological site inventory information indicates that a site will not support reestablishment of a species that historically was part of the natural environment and,

* Resource management objectives cannot be met with native species

What does this mean in practice? According to Fite:

“When the BLM says “integrated” weed management, the phrase is meaningless. It is largely a spray, spray, spray, treat, treat, treat at-all-costs mentality. For example, under the “integrated” strategy, BLM could beat the land to death with cows instead of mowing it each year as Fuel Break “maintenance.” The BLM ignores passive restoration, which should be the #1 action in any integrated strategy. What good does it do to have these ugly strips if everything surrounding them gets beaten to death and becomes a Cheatgrass hellhole too? The conditions of lands before fires often greatly affects how they recover after fires. So ending grazing to recover native understories before a fire “crisis” happens should be the foremost action undertaken. Instead, BLM has designed the perfect storm of actions for spreading Cheatgrass and other weeds at warp speed across the landscape: 11,000 miles of torn up country, right by roads where vehicles will be transporting weed seeds, and where cows get trailed along and loaf.”

Said Cunningham, on the subject of which non-native seeds might be planted:

“It’s totally for livestock forage. Crested Wheatgrass and Russian Wildrye are two very common grasses from Eurasia that are coarse perennial grasses brought over for cattle forage. They have zero use for Sage Grouse. Sage Grouse avoid these. So they’re going to create these monocultures… That’s not creating wildlife habitat. But it’s also fuel, so how is that going to stop a fire if you’re planting Crested Wheatgrass in a 500 wide swathe of linear land? It’s a giveaway to livestock operators.”

The comment letter posited:

“We believe the agencies will be using livestock forage plants such as Crested Wheatgrass, Russian Wildrye, and forage Kochia, which will invite the use of livestock to graze them in a giveaway of public lands to private interests. A vicious cycle may result, where, as targeted grazing occurs over the years, with unanalyzed stocking rates and seasons of use, the soils will be further disturbed and Cheatgrass will increase.”

As if that isn’t bad enough, GMO could also be a component of the BLM’s reseeding. From the comment letter:

“We do not agree with using genetically altered native grasses that are bred for livestock forage more than they are for restoring sage-steppe habitat. Seeds should be collected locally from native grasses, forbs, and shrubs, and reseeded into wildfire burns or fuel breaks.”

Conifer Removal

Lastly, and tragically, Pinyon-Juniper woodlands will be targeted by this project. The PEIS claims this project will be remedying “pinyon-juniper encroachment” but there’s no such thing. From the comment letter:

“Boundaries of these species have been fluctuating through thousands of years, according to woodrat midden studies, so “encroached” areas may actually be within the range of natural vegetation. Lyford et al, (2003) recorded long distance dispersal of Utah juniper into northern Utah and Wyoming in the early Holocene 7,500-5,400 years ago, based on sampling of woodrat midden subfossil plant material that was radiocarbon-dated. A subsequent wet climatic phase delayed expansion, and then a following dry phase 2,800 years ago lead to a rapid expansion of juniper across the area. Thus juniper “encroachment” may simply be part of this long-term Holocene expansion and fluctuation. Pinyon-juniper communities should be managed as native plant communities, and not “excessive fuel” or “invasive species.””

One doesn’t have to go that far back, though. A dirty trick that the BLM and other federal agencies play is setting the date for the extent of the “natural” Pinyon-Juniper range at the beginning of the 20th Century. In actuality, the original assault on these woodlands by Europeans took place in the second half of the 1800s, when thousands upon thousands of acres of trees were cleared to provide fuel for charcoal kilns as part of the mining industry, and also to carve out pasture for cattle. These actions reduced the range of Pinyon-Juniper significantly. Regrowth into these areas is then called “encroachment.” (For details, including a critique of the perverse term, “native invasive,” see “The senseless destruction of the Pinyon-Juniper forests as “native invasives”” which I co-wrote with Nicole Patrice Hill.)

Cunningham flatly stated: “If it’s native, it’s not ‘encroaching.’”

Fite recommended:

“The BLM should be spending every penny it’s going to waste on the fuel breaks in destroying native plant communities and making the weed problem much worse across six western states in restoring native Pinyon-Juniper and Sage communities. The first step there is terminating grazing, and then replanting Sage and Pinyon-Juniper.”

That’s right: remove the cattle entirely. There can be no restoration or rejuvenation for native habitats on public lands in the West until ranching is removed.

Overall Impacts

The Fuel Breaks project will have the effect of slicing-and-dicing millions of acres into pieces. This is territory that in many cases has been negatively impacted, to greater or lesser degrees, by ranching, mining, fracking, clear-cutting, irrigation, and other commercial activities. Many species are already under stress.

Said Cunningham:

“One of the things in conservation biology is that you don’t want to fragment habitat. Sage Grouse in particular need large chunks of undisturbed Sagebrush… So when you start cutting these giant new fuelbreaks with bulldozers and masticators and mowing machines, 500 feet wide, that’a a huge fragmenting of an old growth Sagebrush habitat. And they want to have ‘targeted grazing’ which is just bringing cattle in from a rancher without even a permit, to reduce the Cheatgrass. Well, the Cheatgrass comes in with the cattle; Cheatgrass likes the disturbed ground. So then they’ll have to do herbicides to get rid of the Cheatgrass. So now you’re just creating this huge, ruined, disturbed, poisoned piece of land where there was just a trail before or even just a right of way.”

“Even just a right of way”: That’s right. The PEIS names “BLM ROWs” (rights of way) as targets for the fuel break treatment, not just along already established roads. According to Cunningham, this could include “lines on a map” where, for example, transmission wires or pipelines are merely planned but have not (and might never be) constructed. There are cases where the land “might not even have ever been touched” but now a 500 foot wide swath of destruction will be forced through. That’s horrendous.

Fite mentioned that the BLM is planning to upgrade many of their minor roads, and that the easier access will bring more human disturbance to the area, including human-caused fires. She also anticipates that fewer trees and shrubs along motorized routes will encourage more off-road driving, which is another source of habitat destruction.

And BTW, the Fuel Breaks Won’t Even Work

The worst part is that the entire project is unlikely to be effective in stopping or slowing wildfires, especially the severe blazes that are becoming more frequent with climate change.

Maddeningly, the PEIS itself admits as much, but due to Trump-era dictates, is not allowed to mention “climate change,” though in this passage, it describes the effects of exactly that:

“For much of the past several decades, most of the project area has experienced multi-year droughts and changes in the type, seasonality, and distribution of precipitation. Lower than average precipitation and higher than average temperatures in winter and spring can result in vegetation becoming cured earlier in the fire season and over a broader area. This increases the risk of wildfire ignition and spread. Surface disturbance, including in burned areas, has contributed to an upward trend in the distribution of invasive annual grasses, which is expected to increase the spread of wildfires and the subsequent reestablishment of invasive annual grasses. This is expected to perpetuate the trend toward shorter fire return intervals.”

From the comment letter:

“Moreover, fuel breaks are generally ineffective in the hot, windy, dry conditions in which most large fires burn. Many wildfires that sweep across Great Basin landscapes are driven by high winds and embers would be carried beyond fuel breaks, making these artificial features useless. Fuel breaks would not help stop these natural processes, only further fragment sagebrush communities.” “Extreme wind-driven fires due to climate change will not be halted by even 500-foot wide fuel breaks. The Martin Fire, for example, burned across 435,569 acres with high winds at 25 mph carrying embers and sparks horizontally across shrub and grass fuels. The fire was carried quickly across many roads and highways. It is therefore doubtful whether 500-feet fuel breaks could stop such a fire. In any case, wildfires have been observed spotting over large natural fuel breaks, such as interstate highways and the Columbia River. Given the ability of large, weather-driven fires to overcome such barriers, it is highly unlikely that any type of fuel break would be effective under similar conditions.” “There is no science to support the efficacy of the proposed fuel breaks. There is science showing that Sage Grouse are harmed by fragmentation of their sagebrush habitat, including via linear features like roads.”

Cui Bono?

So why is the Bureau of Livestock & Mining pushing ahead with this project if it’s not even going to work as advertised? Who benefits?

Fite minced no words in answering this question:

“Welfare Ranchers. And the BLM, so it can keep sucking in huge congressional appropriations under the guise of “fuels” management and pretend it is doing something to save Sage Grouse and siphon $$$ off for other things at times, too. The distraction of fuel breaks provide more ’space” for oil and gas development, mining, etc. to continue to plunder public lands. “Oh, look we’re solving the fire problem. No need to worry about eating into more habitat.” Private contractors with heavy equipment benefit. Herbicide spray plane contractors and herbicide corporations benefit. The fuel breaks, like the Pinyon-Juniper killing and Sagebrush “treatments” are in part aimed at creating the illusion that BLM is doing something to save Sage Grouse, and that the BLM can “control” climate driven fires, which they cannot.”

Fite went on to explain that not only are the fuel breaks sacrifice zones where native flora is removed and replaced by exotic cow forage, but that additionally, the chunks between are thereby isolated and more easily turned into the “equivalent of feedlots.”

This is the Continuing Legacy of Agriculture

The BLM’s latest project—“fuel breaks” in the increasingly fire-prone Great Basin—superficially sounds like something reasonable and responsible, but it is anything but. Rather, it’s yet another land grab for the ranchers and their invasive cows and sheep. Apparently, that ravenous industry will not be satisfied until every last acre of wilderness is converted into pasture on the public dime.

It would be easy to blame the Trump administration for this, and though its roll-backs of environmental regulation are indeed both far-reaching and unprecedented in modern US history, its crimes are merely the latest in a legacy that goes back centuries on this continent. After all, it was Spanish missionaries who first introduced cattle to the arid west, long before the area was part of the US.

And, we must remind ourselves, humans instituted such ecocidal behavior in the Middle East eight to ten millennia ago with the Agricultural Revolution, where they deforested and desertified entire regions long before the Americas were “discovered” by Europeans.

As with all agricultural endeavors, a habitat of native flora and fauna thriving in the natural commons is wiped out and replaced by domesticated species for generating profit and power for private parties. It’s nothing new, and we should have learned our lesson by now, but it’s only too obvious that we have not.

What we must choose at this point is a return to healthy relationships with life on this planet, in attitude and action. At one time we lived that way. It is not beyond us. We have no excuse beyond our own stubbornness.

What Can We Do?

Unfortunately, all public comment periods for this project have passed. With this PEIS, the BLM is announcing its final plans. One or more environmental organizations might file suit, which would delay implementation.

Regardless, people can still contact the BLM, especially local offices, to make their feelings known. It’s also possible that particular portions of this project will still need to pass their own regulatory hurdles, which would provide further opportunities to slow down or stop some of the destruction. Keep your eyes open, and follow the alerts released by environmental groups like Wildlands Defense and the Western Watersheds Project.