Intentionally burned in 2014 and now mastication, cutting and pile burning are planned – N of FR 76 near FR 171 Photo: Public Journal.
Why a Comprehensive Cost/Benefit Framework is Needed
In April of 2022, the largest wildfire in New Mexico history, the Hermits Peak/Calf Canyon Fire, was ignited by two separate escaped prescribed burns during implementation of a U.S. Forest Service fuels reduction project. One prescribed burn escape was ignited by a broadcast burn, and the other by spreading fire from smoldering slash piles. This project, called the Gallinas Municipal Watershed Wildland Urban Interface Project, was located on the far east side of the Santa Fe National Forest.
The two escaped burns ran side-by-side at first, and then merged into a massive conflagration that ultimately burned through three counties, destroyed hundreds of homes, and forever altered a traditional community’s way of life. The severe post-fire flooding killed three people. Since then, ash by-products and heavy metals associated with fire retardants used to fight the fire have been found in local wells, streams and watersheds. Almost 84,000 acres, or 130 square miles, of the 341,471-acre fire burned at high severity, which meant most trees were killed in an area where post-fire conifer regeneration is often delayed or may not occur at all. This fire was truly an agency-initiated disaster, and it has cost over 5 billion dollars.
Following the fires, the Forest Service completed an analysis of each fire, focusing on a number of operational shortcomings and inadequate agency capacity. The agency implemented new operational procedures and safeguards intended to reduce the risk of prescribed burn escapes. However, no meaningful analysis was done to determine to what extent the new procedures and safeguards would actually reduce burn escapes, especially in dry forests.
The 2006 Gallinas Municipal Watershed Project decision notice acknowledged the need to consider project risks, costs, and benefits more directly than was required, due to the potential for escaped prescribed burns. However, it did not employ a comprehensive cost/benefit framework, one that systematically and comprehensively assesses the ecological, social, and economic costs and risks of a proposed project against its expected benefits. Such an approach was later recommended in the Forest Service’s 2013 framework for improving ecosystem resiliency in southwestern dry forests, which identified a need for an “assessment of ecological, economic, and social benefits and costs of different restoration methodologies and implementation practices.”
Analyzing the Gallinas Municipal Watershed Project within a systematic and comprehensive cost/benefit framework might have led to a different project design. The analysis might have concluded that spring prescribed burning was unjustified under the dry, windy conditions that often occur in the Santa Fe National Forest, that reducing canopy cover to the proposed extent created unacceptable ecological and wildfire risks, or that the volume of slash generated by the project could not be safely burned.
Such a framework might have guided the determination of the optimal timing, size, and frequency of treatments, as well as conditions under which to implement them. The project might have been designed to meet the objective of maintaining ecosystem integrity by supporting the ecosystem’s capacity to retain moisture, while avoiding treatments that degrade soils and waterways, damage trees and understory vegetation, and disrupt wildlife habitat.
The Forest Service currently utilizes an “effects analysis” which identifies and evaluates the reasonably foreseeable beneficial and adverse effects of a project. Occasionally, the language of weighing costs and benefits is included. However, this type of analysis does not provide a systematic and comprehensive framework for meaningfully weighing those effects against one another to determine whether the expected benefits justify the ecological, social, and economic costs and risks of the proposed action. Meaningful weighing requires first sufficiently determining the magnitude and probability of the expected benefits, costs, and risks.
Throughout the project design and analysis process, the central question should always be: given the magnitude and probability of the presumed benefits and the potential harms, is each particular action justified? And if so, under what conditions? For example, at what time of year, and under what weather, vegetation, or soil conditions?
A comprehensive cost/benefit framework should inform every stage of project planning and analysis — from gathering reliable information about existing conditions, to evaluating ecological, social, and economic consequences, to monitoring outcomes, and to incorporating what is learned into future management decisions. Such a framework naturally creates a discipline of thinking that questions assumptions and holistically evaluates the full range of consequences of proposed project actions, recognizing that these factors interact in complex ways and can create cascading effects.
The Encino Vista Project: A Case Study
The Encino Vista Landscape Restoration Project, located in the Jemez Mountains on the west side of the Santa Fe National Forest and northwest of Los Alamos, was proposed by the Forest Service in 2019. The project analysis was delayed, so the final decision wasn’t released until 2025. The project includes 26,700 acres of “thinning” (cutting of trees up to 24 inches in diameter), 7,200 acres of commercial logging that includes effective clearcut logging, and 74,700 acres of prescribed burning.
Traditional communities, similar to those surrounding the Gallinas Municipal Watershed Project area, are located nearby. The project proposal was highly controversial to both locals and to conservationists interested in protecting the Santa Fe National Forest. According to long-time Jemez Mountains conservationist and president of the Santa Fe Forest Coalition, Sam Hitt:
The accessible terrain [of the project area] has been repeatedly logged and nearly all the large trees have been felled for saw timber. For decades, the area was situated halfway between two old-growth timber mills (in Cuba and Espanola). There are over 100 miles of old logging roads, many of which bleed sediment into nearby streams. Now they [the Forest Service] want to cut the mature timber and open/reconstruct the road network that is blending back into the landscape. In other words, they are trying to maintain the area as a timber plantation instead of allowing a functional forest to develop.
Additionally, the project area is heavily grazed by cows, so the natural understory is largely denuded or shifted to uncharacteristic or invasive plants, some of which are highly flammable. But the area is still viable enough to recover to at least a version of the majestic forest it once was, adapted to current climatic conditions. This would require careful, ecologically sound, and holistic management that considers the forest as worth preserving as an intact ecosystem, while also considering the needs of local communities.
The Encino Vista Project is very similar to a series of previously approved Santa Fe National Forest projects — a formulaic fuels reduction plan based on a specific forest management strategy that has resulted in substantial ecological damage and sometimes disasters for communities. The following examples illustrate several of the areas in which applying a comprehensive cost/benefit framework during project planning and analysis could have better achieved the Forest Service’s stated objectives of restoring forest health, reducing the risk of uncharacteristically severe wildfire, improving watershed health, and protecting wildlife habitat.
Mexican Spotted Owls
The Encino Vista Project area contains significant populations of two threatened or endangered species: the Mexican spotted owl and the Jemez Mountains salamander. The presence of these populations in this area is indicative of ecosystem integrity.
The Endangered Species Act requires that the Forest Service promote recovery of listed species by managing habitats, avoiding actions that jeopardize listed species, and consulting proactively with federal wildlife agencies. In order to know if populations are recovering, the agency must understand current population trends. Decades after the Mexican spotted owl was listed, the Forest Service still does not have region-wide population data. The Forest Service, along with the U.S. Fish & Wildlife Service, has stated that they need more data to understand the impacts of fuels treatments on owls. Yet at the same time the agencies seem to be ignoring data from the 4FRI project in Arizona suggesting that thinning and burning have significant adverse effects on the owls. Without region-wide population data, there is no way to determine whether the reductions in canopy cover are helping or hindering owl recovery.
Even though the Forest Service hasn’t yet complied with existing Endangered Species Act regulations, the Encino Vista Project decision allows for fuels reduction treatments in owl habitat. In a cost/benefit analysis framework, the agency would ask, after obtaining reliable baseline data: do the anticipated benefits of the intended fuels treatments outweigh potential damage to Mexican spotted owl populations and habitat?
Meaningful cost/benefit analysis requires reliable baseline information about the condition of the resources being managed.
Escaped Prescribed Burns
During the past quarter century, the majority of acres burned by wildfire in and from the Santa Fe National Forest were ignited by land management agency intentional burns that escaped control. This included substantial high-severity fire. This fire history was not meaningfully considered in the Encino Vista Project analysis. It should be fully acknowledged that prescribed burning creates significant risk of igniting major wildfires, even with improved operational procedures and efforts to address agency capacity. A comprehensive cost/benefit framework would quantify the acres that have burned due to escaped intentional fires, and would weigh the risks against realistically determined estimates of the high-severity wildfire reduction expected from the proposed treatments. As with the case of the Gallinas Municipal Watershed Project analysis, the discipline of balancing costs with benefits might have led to the development of a much less risky project design.
A systematic and comprehensive cost/benefit framework requires that agencies learn from past project outcomes and weigh those lessons against presumed benefits in current project design and analysis.
Slash Piles
A multitude of piles of slash from logging and thinning operations exist across the Santa Fe National Forest, some from many years ago, creating an ongoing fire hazard. The recent McCauley Springs Fire in the Jemez Mountains was initially spread by logging slash, and the fire came close to igniting slash piles. The 2022 Calf Canyon and Cerro Pelado fires were ignited due to “sleeper” slash piles, which can smolder for months deep within the piles or even underground, sometimes underneath snow.
Once trees are cut, slash must be managed. Managing slash piles carries significant risk. The burning of slash piles tends to leave damaged soils. The Encino Vista Project analysis should have quantified the existing slash piles, given that the project could produce on the order of 718,000 additional slash piles to burn (calculated at 20 piles per acre cut). It should be considered to what extent the risks and costs of creating so many slash piles that must be burned would be justified by the demonstrable benefits of wildfire mitigation and increased forest health.
Such an analysis might lead to substantially reducing the amount of tree cutting and the resulting number of slash piles, and requiring existing slash piles to be burned before new ones are created. More stringent guidelines might also be considered to prevent pile burn ash from leaching into waterways.
A cost/benefit framework requires that existing conditions be weighed when determining whether additional project impacts are justified by their presumed benefits.
Tracks from logging equipment that have damaged the soil in the Encino Vista Project area. 96 Fuelwood area. Photo: Sam Hitt.
“Healthy” Forests vs. Wildfire Risk Reduction
The Encino Vista Project’s stated purpose is to both reduce the risk of high-severity fire and to increase forest health. If the primary means of reducing fire risk is intensive logging and thinning, followed by intentional burning, then the extent to which such treatments are executed must be reconciled with the requirements for ecosystem integrity. Especially in dry forests, overly opening up tree canopies can set off a cascade of ecological changes that degrade ecosystems. Given the Santa Fe National Forest’s history of ecological damage from fuels reduction treatments, the boundary between potential fire mitigation and ecosystem damage appears to be repeatedly crossed. Many treated areas have few trees left standing, damaged soils, and invasive weeds and uncharacteristic shrubs replacing the prior more natural understories.
Determining the optimal balance between treating forest ecosystems and allowing them to thin themselves naturally is complex and will require much more ecological research. Within the Encino Vista Project analysis, the Forest Service considers impacts to soils, vegetation, and wildlife habitats in a limited way, but does not comprehensively consider the tradeoffs between potential ecosystem damage from the treatments and potentially decreasing high-severity fire,
A cost/benefit framework requires weighing a range of interrelated effects within a complex system.
The question should be asked: is potentially creating degraded and dried-out ecosystems, possibly in perpetuity, from aggressively and repeatedly cutting and burning justifiable for the amount of reduction of high-severity fire that might be achieved? Or would a much more light-handed approach provide a better balance of effects?
Economic cost/benefit analysis
Environmental law does not require an economic cost/benefit analysis as part of Forest Service project analysis. But given the currently more limited funding allocated to the Forest Service, shouldn’t the financial costs relative to resource benefits be at least estimated so funds could be spent effectively?
Within a cost/benefit framework, the cost of implementing fuels reduction treatments relative to the cost savings from the reduction of high-severity fire should be considered. Logging, thinning, and prescribed burning carry a substantial cost per acre to implement (with thinning estimated by the Forest Service to be $3,428 per acre), so it should be determined whether, in any particular context, the potential outcomes justify the expense. In 2017, Forest Service researchers were the lead authors of a paper focused on the Sierra National Forest that weighed the financial costs and benefits of fuels reduction treatments. The paper concluded: “Modeling results generally confirmed that fire-treatment encounters are rare, such that median suppression cost savings are zero, but in extreme years, savings can more than offset upfront investments.” That kind of analysis should be conducted for a variety of forest types. The costs of building and maintaining roads to access treatment areas should also be included in estimates of project financial costs. The costs of timber sales should be included. According to Forest Service analyses, logging sales often result in substantial net financial losses. Additionally, the broader costs of carbon emissions from project activities should be considered.
Such an analysis would include considering the costs of managing project risk outcomes, such as wildfires ignited by escaped prescribed burns. Costs outside the Forest Service budget should also be considered, including local residents’ costs resulting from agency-caused wildfires — such as medical costs from smoke exposure and the costs of potentially compensating residents if their homes are burned and/or their property damaged.
The optimal allocation of limited economic resources is an important aspect of considering a project within a cost/benefit framework.
Conclusion
Currently, the Forest Service claims it is not explicitly required by environmental law to perform any type of cost/benefit analysis of fuels treatment projects despite such projects potentially impacting forests for generations and impacting communities in a multitude of ways. The Encino Vista Project decision does not even sufficiently comply with existing environmental law. Three conservation organizations, WildEarth Guardians, the Santa Fe Forest Coalition, and The Forest Advocate have submitted to the Forest Service a notice of intent to sue concerning the Encino Vista Project decision, and also concerning the 2022 Santa Fe National Forest plan revision that provided the overall parameters for the Encino Vista Project logging and other fuels treatments. The purpose of the legal challenge is so that the analytical basis upon which the project decision and forest plan revision were made will be strengthened, and both will be reconsidered.
Given the stresses forest ecosystems are undergoing in a warming and drying climate, it is imperative that the agency genuinely weigh the costs and benefits of forest management actions to limit the damage they are causing. This is not over-analysis – it’s the rationality and due diligence required for managing our public lands. Whether or not environmental law currently requires a systematic and comprehensive cost/benefit framework, the potential consequences of fuels reduction projects are so profound that such a framework is essential for guiding responsible forest management and preserving our irreplaceable climate-transitioning forests – while also protecting communities.
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