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COLORADO
March 31, 2009
Senator Michael Bennet
702 Hart Senate Office Building
Washington D.C. 20510
Congresswoman Betsy Markey
1229 Longworth House Office Building
Washington D.C. 20515
OFFICE OF BOARD OF COMMISSIONERS
PHONE: 970-336-7204
FAX: 970-352-0242
915 10TH STREET
P.O. BOX 758
GREELEY, COLORADO 80632
Senator Mark Udall
521 Dirksen Senate Office Building
Washington D.C. 20510
Re: Concern Regarding Prescribed Bums on the Pawnee National Grassland
Dear Senators Salazar and Udall, and Congresswoman Markey:
The Board of County Commissioners of Weld County, Colorado, continues to be
concerned
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the prescribed bums taking place on the Pawnee National Grassland ("PNG"). Approximately
3,000 acres were burned during the week of March 16, 2009. A U.S.D.A. Forest Service
("USFS") Briefing Paper ("Briefing Paper"), dated March 19, 2009, attempts to allay concerns
previously expressed by the Board. A copy of the Briefing Paper is enclosed. Our concerns
include the following:
1. The cost of conducting the PNG prescribed burns at a time in which revenues
are limited appears inappropriate when other missions, such as bark beetle
control, should be receiving higher spending priority. According to the Briefing
Paper, the cost of the PNG prescribed bums was $20 per acre (total cost of burning
3,000 acres equals $60,000). The Board of County Commissioners doubts this
figure is correct. Does it include all of the costs of planning and execution incurred
by the USFS administrative staff over the past year? Does it include all of the costs
associated with bringing the 35 South Dakota firefighters to Colorado to conduct
the bums, including equipment, training and personnel costs? Does it include all of
the costs associated with coordinating with local fire district personnel during the
days of the burns? The Board asks that you request a full accounting and
report on the costs incurred in the PNG prescribed burns of March 17-19,
2009, from the General Accounting Office, Inspector General, or an
ombudsman. We believe that these costs, when fully accounted for, will he well in
excess of $20 per acre. At this time of limited revenues, using this money for
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2009-0828
Letter, PNG Prescribed Bums
March 31, 2009
Page 2
prescribed burns on the PNG, when bark beetle infestation in the mountain forests
is rampant, is out of priority. The money should be spent on bark beetle control,
especially when one considers that the PNG prescribed burns are an inefficient
method of managing vegetation buildup, as detailed below.
2. Prescribed burning is an inefficient method of managing vegetation on the
PNG as compared to the use of grazing contracts. The purposes for prescribed
burns which are listed in the USFS Briefing Paper include "promoting diversity in
vegetation type, structure, composition, and successional stages," "managing
vegetation to provide for wildlife habitat," improving rangeland forage, and
reducing grassland fuel hazards. The USFS claims it has accomplished these
purposes through prescribed burns at a cost of $20 per acre (total cost of $60,000).
The Board of County Commissioners points out that all of these purposes could
have been accomplished through grazing contracts. Grazing contracts generate
revenue to the USFS in the form of rental payments at little cost to the USFS.
Grazing does not involve the hazards posed by the prescribed burns, thereby
eliminating the cost of bringing in 35 firefighters. The use of grazing contracts to
manage vegetation appears to be much more efficient than prescribed bums.
3. The extremely dry weather conditions that Northern Colorado is experiencing
have significantly reduced soil moisture at the 36 to 48 inch depths and will not
sustain revegetation as a result. Although the Briefing Paper reports that USFS
scientists took soil moisture measurements on units planned for burns and found an
average of 9 to 14 percent moisture within the upper 12 inches of surface soils, such
moisture is unable to sustain revegetation into the summer months, when high
temperatures typically reduce soil moisture in the top 12 to 24 inches. In those
months, what sustains the new growth is soil moisture at depths of 36 to 48 inches.
Plants that are successful through the summer months have roots that tap into these
lower soils. If that moisture is not present, then the new growth will have little
sustainability. The Board is very concerned that, with the past few years of
continued dry conditions, the soil moisture at 36 to 48 inch depths is insufficient to
sustain revegetation that typically occurs shortly after the prescribed burns. If the
new growth is unable to sustain itself, the ground will be left bare and will be
susceptible to wind and water erosion through the remainder of the year.
4. Local input as to if and when the PNG prescribed burns would occur this year
was not sought by the USFS. Input was not sought by the USFS from the Board
of County Commissioners or from adjacent landowners in the decision regarding if
and when the PNG prescribed burns would occur this year. Section 36 C.F.R.
219.9(a)(2) requires coordinated planning between local governments and the
USFS. That Federal Regulation states that the "responsible official must provide
opportunities for the coordination of Forest Service planning efforts undertaken in
accord with [36 C.F.R. 219] with those of other resource agencies. The responsible
official also must meet with and provide early opportunities for other government
Letter, PNG Prescribed Burns
March 31, 2009
Page 3
agencies to be involved, to collaborate, and to participate in planning for NFS
lands." No such local coordination was sought from the Board of County
Commissioners regarding the March 17-19, 2009, burns. Additionally, it is our
understanding that adjacent landowners did not have input into these decisions.
Because of the pattern of incongruous land ownership on the PNG, the risks of soil
erosion and wildfire escape are borne by adjacent landowners without
compensation or insurance supplied by the USFS. They are at risk of loss if the
prescribed burns leave soil unexposed and subject to blowing, or if the prescribed
burns run out -of -control and onto the adjacent lands. As a result, they should have
had a say in the decision making process regarding the PNG prescribed burns.
The Board has been consistent in expressing these concerns and opposition to prescribed burns on
the PNG. Enclosed is a copy of the letter the Board of County Commissioners submitted in
August, 2008, to the USFS regarding the Environmental Assessment for Prescribed Fire
Management on the Pawnee National Grassland.
If you wish to discuss this letter, please contact either Commissioner David Long at (970) 356-
4000, ext. 4200, or Mr. Bruce T. Barker, Weld County Attorney, at (970) 356-4000, ext. 4390.
Sincerel
William F. Garcia, Chairman
Board of County Commissioners
Of Weld County, Colorado
pc: Bruce Barker, Weld County Attorney
Lori Bell, Pawnee National Grassland
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