CHAPTER TWO

ALTERNATIVES Part 2

Actions Common to All Action Alternatives

Public Safety

Public and firefighter safety is the number one priority of all alternatives.  The Federal Fire Policy states: “Firefighter and public safety is the first priority, and all fire management plans and activities must reflect this commitment.” National Park Service Wildland Fire Policy (Director’s Order 18) echoes this direction: “The NPS is committed to protecting park resources and natural ecological processes, but firefighter and public safety must be the first priority in all fire management activities.” The Yosemite Fire Management Plan, regardless of what alternative is selected, will enact the following directions to ensure the safety of firefighters and the public:

¨       Every firefighter and fire line supervisor, the fire program manager, and the park Superintendent will take positive actions to ensure compliance with safe fire management practices.

¨       Experience, training, physical fitness, and knowledge of safety practices will be required of all people in leadership roles in fire operations.

¨       All wildland fire safety standards [including the 10 Fire Orders, 18 Watchout Situations, Downhill/Indirect Line Checklist, Four Common Denominators of Fatality Fires, Lookouts-Communications-Escape Routes-Safety Zones (LCES), and Risk Management/Situational Awareness] will be required annual training for all personnel involved in wildland fire operations. 

¨       Annual hands-on fire shelter deployment training will be mandatory.

¨       The safety training requirements listed in Chapter 3 of National Park Service Reference Manual 18 (RM-18 NPS 1999b) will be adopted and adhered to.

¨       Qualifications standards for ICS (Incident Command System) positions as listed in National Wildfire Coordinating Group 310-1 “Wildland Fire Qualification Subsystem Guide” will be adopted. 

¨       All project plans will address safety concerns in an attached job hazard analysis (JHA).

¨       A safety briefing will be given prior to initiating work on any project.

¨       All Type 3 fire incidents and all prescribed burns will have an Incident Action Plan (IAP) developed for each operational shift.  Every IAP will include a safety message. 

¨       Every project or incident will have at least one person charged with incident safety oversight; complex situations will require multiple safety officers.

¨       All personnel will be authorized and obligated to exercise emergency authority to stop and prevent unsafe acts.

¨       All employees will have the right to turn down unsafe assignments; they will also have the responsibility to identify safe alternatives to accomplish the mission.

¨       The use of SAFE NET ground-based safety incident reporting system will be adopted and implementation procedures will be included in the employee handbook.

¨       After Action Reviews (AARs) will be conducted by the project leader or incident commander after each shift of a project or incident to evaluate safety and effectiveness of work performed and identify and discuss encountered hazards. 

¨       All wildland fire incidents that result in human entrapment, fatalities, or serious injuries, or that have the potential to result in such, will be reported and investigated as required by RM-18, Chapter 3.

¨       The park Superintendent (or designee) will manage critical incidents following checklists and processes contained in the National Wildfire Coordinating Group’s “Agency Administrator Guide to Critical Incident Management.”

¨       All personnel on wildland fires will be equipped with proper personal protective equipment (PPE) as described in Chapter 3 of RM-18.  All personnel will carry a fire shelter on wildland fires at all times unless in a designated safety zone.

¨       All personnel on projects or fire management activities will adhere to special PPE requirements specific to those operations, i.e., power saws, helicopters. 

¨       All visitors to wildland fires in Yosemite will be equipped with Nomex clothing, gloves, hardhat, and fire shelter, and will be accompanied by an operationally qualified person that can maintain communications with the incident management team and recognize potential problem fire behavior.

¨       All vehicles and drivers engaged in fire management activities will meet Government Services Administration (GSA) and agency standards, as well as state licensing requirements.

¨       All personnel engaged in wildland fire activities in Yosemite will adhere to the health screening/medical surveillance and fitness requirements of RM-18, Chapter 3.

¨       All fire management personnel will be provided three hours per week of duty time to achieve and maintain physical fitness levels as prescribed in RM-18, Chapter 3.  Firefighters whose full-time duties are 100% arduous duty-related (helitack, handcrew, engine crew, prescribed fire) will be provided one hour per day for fitness training when circumstances allow.

¨       Radios will be assigned to all fire crews and monitors when working on wildland fires.  Special permission must be obtained from the incident manager for individuals to work alone on actively burning fires. 

¨       Perimeter control will be assigned on all fire management projects and incidents to prevent non-fire personnel from entering the project/incident area without escort or proper personal protective equipment (PPE).  The intent of perimeter control is to prevent injury to the public from unmitigated hazards of smoke, heat, falling debris, and machinery.

¨       Trails and roads providing access to mechanical fuel reduction projects, managed wildland fire fires, unwanted wildland fires, or prescribed fires will be closed if such fires and/or projects present unacceptably hazardous conditions to park visitors.  Wilderness permits will not be issued for trailheads leading to hazardous areas.  Roads and trails will remain closed until the hazard is abated.

¨       Smoke warning signs on roadways and/or traffic control will be instituted during wildland fires as conditions warrant and at the direction of the Burn Boss, Incident Commander, Safety Officer, or a visitor protection representative.

¨       Portions of the park or the entire park may be closed by order of the park Superintendent when there is any threat to the public or firefighter safety from wildland fire or fire management activities.  When and if such an action occurs, adjacent agencies and authorities will be notified as soon as possible to help manage or evacuate the closure. 

¨       Areas of hazardous fuels adjacent to publicly or privately owned structures or along likely evacuation routes will be kept clear of debris.  This requirement will fall on the owner or the agency having jurisdiction, or the renter.  The minimum requirement for creating defensible space is a 30-foot radius around any structure and 10 feet on either side of a roadway.  These specifications will provide only the minimum degree of safety for firefighters and the public and are the same as prescribed by California Public Resource Code (PL 4290 and 4291). 

Public Information and Education

There would be an active partnership among Fire Management, Interpretation, and Resources Management staff to promote in fire education among park staff and visitors.  Fire education would be a component of interpretive staff training.  Throughout the year, interpreters would incorporate wildland fire management and the role of fire in ecosystems into interpretive walks and evening programs.  An exhibit would be located in the Valley Visitor Center to provide education regarding wildland fire and its role in parks and wilderness.

During fire season, as staffing allows, interpreters would staff significant prescribed fires or managed wildland fires near visitor use areas, to provide educational services.  Where fires are particularly visible from major park scenic overlooks or traditional high use visitor areas (such as Glacier Point), roving Fire Information Officer qualified personnel or trained park interpreters would give talks about fire and smoke. 

The Office of Media Relations would notify adjacent communities by press release before some prescribed fires are implemented.  Media Relations would work closely with visiting Fire Information Officers, who may be part of an Incident Management Team or Fire Use Management Team, to assure that information is delivered effectively.  Prompt reply to all media and public queries would be an essential element of public information.  Information about wildland fire and smoke would be readily available, as would information about the fire management plan and ecosystem restoration if appropriate.

During emergency wildland fire situations, park interpretive staff could be brought in from other districts to assist in providing information to visitors and assisting the incident information officer.  A smoke communication strategy (Appendix 4) would be used during fire management activities as a blueprint for managing smoke events and communicating with communities and other agencies. 

Utility Corridor Treatments

Wildland fires caused by electric power transmission and distribution lines have a propensity for becoming much larger and more damaging than fires from any other cause in California.  Power line-caused fires become conflagrations because during the long, hot, and dry fire season commonly experienced in California, the high winds and high temperatures that cause power line faults (unwanted short circuits for electric current) also lead to rapid spread and high resistance to control of wildland fire.  Almost all of the aerial utility lines in Yosemite are in the lower elevations (lower montane forests and woodlands vegetation types) where fire return intervals and the fuel accumulations are at hazardous levels.

Vegetation under aerial utility lines including electric transmission and distribution lines within the park (map 2-18 and table 2.10) would be thinned to reduce potential for fire starts and meet code requirements.  Trees growing or anticipated to grow within ten feet of the lines, and trees which show signs of falling on lines would be trimmed or taken down.  Limbs, shrubs, and ground fuels beneath hazardous areas would be removed.  Vegetation cut along these corridors would be removed to protect the utility infrastructure in the event of wildland fires (planned or unplanned) and to facilitate fire control.  In accessible areas, woody debris would be removed to landings or wood yards and in inaccessible areas it would be piled and burned   In heavily wooded inaccessible areas, clearings would have to be created for burn piles.  Large tree boles in inaccessible areas would be limbed and bucked for maximum soil contact to increase moisture and accelerate natural decomposition.  Utility workers would access power lines directly in areas accessible by road, and be confined to specified service roads in roadless areas.  Off-road or over-the-snow equipment would generally not be used for routine tree work.  Tree work in potential wilderness additions would be subject to the wilderness minimum tool requirement decision process.

Table 2.10   Utility Corridors Subject to Tree Hazard Mitigation and Vegetation Management Activities

Mitigation Measures

To ensure that the action alternatives protect natural and cultural resources and the quality of the visitor experience, a consistent set of mitigation measures would be applied to actions proposed in this plan.  The National Park Service would prepare appropriate environmental review (i.e., those required by NEPA, the National Historic Preservation Act, and other relevant legislation) for future actions not covered in the Yosemite Fire Management Plan/EIS.  As part of the environmental review, the National Park Service would avoid, minimize, and mitigate adverse impacts when practicable. 

Natural Resources   During the planning phase of any fire management activity, the presence or absence of special-status species in the area would be determined.  Park subject matter experts would evaluate existing databases and maps, and, if necessary, request additional surveys or field verification.  Site-specific mitigations would be developed and implemented.  If a project could cause an adverse impact on federally listed species, consultation with the U.S. Fish and Wildlife Service is required.  Managed wildland fires would be constrained if they pose undesirable disturbance to important habitat for special-status wildlife or threaten significant populations of special-status flora.

During any fire management activity, impacts to soils would be minimized by utilizing the best available technology and rehabilitation of disturbed soils.  If mechanical treatments were prescribed, methods and equipment as described in “Understory Biomass Reduction Methods and Equipment” (U.S. Forest Service 2000b) would provide guidance.  Disturbed soils would be rehabilitated by restoring slope contour and using other best practices.  Areas with a high probability of erosion would be stabilized using best available methods, as determined by the park resource management staff. 

Recognizing that fire management activities are a disturbance process, there is potential that fire projects would result in opportunities for non-native plant species to colonize disturbed areas.  Sites would be surveyed before and after prescribed fire and mechanical fuel reduction to determine the presence or absence of non-native plant species.  If non-native plants were discovered on a project site, the Fire Ecologist and park Vegetation Management Specialist would develop appropriate mitigation measures. 

Snags and Slash   Generally, snags and other standing vegetation would not be cut during fire management activities unless they presented a threat to human life or safety or presented a hazard to property or a valued resource.  They may also be cut to control a wildland fire.  In the event that a snag or live vegetation must be cut down, the stump would be cut flush with the ground (as close to the ground as possible).

Debris from cut vegetation would be either lopped and scattered to a depth of no more than 18 inches and burned during a subsequent prescribed fire, piled and burned outside of fire season, or chipped on site.  If chipped, the chips would be spread on site at a depth of no more than one inch, hauled for use elsewhere in the park, or transported to a commercial plant for processing.  Disposal methods would depend on the amount of material to be disposed of, land use regulations, proximity to existing roads, and need for chipped wood outside or inside the park.

Air Quality   All proposed prescribed burns would adhere to requirements of Title 17 California Code of Regulations regarding Agricultural Burning Guidelines, as well as regulations developed by Tuolumne County Air Management District, Mariposa County Air Management District, and/or San Joaquin Unified Air Management District, all of which have jurisdictional boundaries within Yosemite National Park.  Additionally, park staff would monitor air quality adjacent to project areas and within developed areas of the park.  Unhealthy or hazardous accumulations of smoke would trigger an aggressive suppression action that includes mop-up and which would persist until the air quality is no longer unhealthy or hazardous.  When adjacent land management agencies are managing prescribed fires or wildland fires, cooperation and coordination would be initiated to minimize cumulative smoke impacts.  The Smoke Communication Strategy would be employed if fire management activities might produce smoky conditions near populated areas (Appendix 4).  This strategy outlines a series of steps that the agency would take to notify the public and other agencies of increasing degradation of the air.

Cultural Resources   During the planning phase of any fire management activity, cultural resource specialists would review available information to determine the presence, absence, or likelihood of occurrence of significant cultural resources.  Consultation would be initiated with park-associated American Indian tribes if there is potential for occurrence of resources of traditional significance.  If little or no data are available, and if there is potential for significant resources to occur within the fire management area, additional inventory would be conducted. 

Significant resources that could be impacted by fire or fire management activities would be assessed for risk conditions and site-specific mitigation measures would be developed.  These mitigations include such techniques as manually reducing fuel loads on or adjacent to resources, documenting flammable resources, identifying and avoiding archeological sites during ground-disturbing activities, and collecting at-risk artifacts or materials.  For traditional resources, mitigation would include measures such as coordinating fire management activity to allow for traditional gathering prior to burning, developing burn prescriptions to foster desired plant characteristics, or protecting sensitive resources from fire.  Managed wildland fires may be constrained if they have the potential to significantly impact or destroy important cultural resources.  Given the limited response time and potential for loss or damage to significant cultural resources in wildland fire situations, a proactive program of inventory, hazard assessment, and fuel reduction would be implemented.

Cultural resource specialists would participate in fire management activities where necessary to reduce or avoid impacts to cultural resources, and where there is potential for resources to be discovered during activity.  Post-burn assessments would be made to document the changed condition of known resources.  In some cases post-burn inventory would be conducted to document newly exposed resources. 

Since data are limited on effects of fire to cultural resources, fire effects research and monitoring will be developed in conjunction with regional and National Park Service initiatives.  Information resulting from cultural resource activities conducted in support of fire management would be incorporated into existing resource information systems.  These activities would be reported as part of the annual program or as project-specific documentation. 

Visual Impacts   Aesthetic impacts would be judged on a case-by-case basis; any mitigation measures would be approved by the park Superintendent.

Safety and Human Impacts   Impacts to visitors, employees, and park residents would be minimized by planning fire management activities during daylight hours and on workdays whenever possible.  Before starting any project, the public and employees would be notified of proposed activities through road signs, trail signs, postings at visitor centers, entrance stations, post offices, or other areas of frequent use. 

Communication/Coordination   Communication, cooperation, and collaboration with neighboring agencies and communities, park partners, visitors, residents, and employees would be an essential component of all plans for fire management activities.  Communication with adjacent agencies would be conducted when projects occur at or near their boundaries or there is an identified impact that might or would affect park neighbors. 

Protection of Sensitive Resources

Yosemite National Park has a variety of special places and sensitive cultural and natural resources.  If known sensitive cultural resource sites or habitats for a special-status species are within any proposed prescribed fire or managed wildland fire area, the area would be evaluated and suitable mitigation measures would be applied if necessary. 

Prescribed fires are planned and normal protocols require that resource specialists are involved in the review process.  On-the-ground inventories of prescribed fire units would take place as necessary.  If inventories are required, burning would be delayed until the inventory and suitable mitigation was completed.  If a prescribed fire unit has the potential to provide habitat for special-status species, steps would be taken to work around nesting season and other sensitive periods of time for animals and plants.  This would be done by altering the time of burning, providing direct protection of certain areas such as nesting trees, or simply not allowing fire into parts of the unit. 

With wildland fires, which are unplanned events, the resource advisors would be notified of the intent to manage a fire in a certain part of the park.  The location of the ignition would be reported and efforts would be made to get specialists into the area to perform basic inventory work as part of the cost of the incident.  Again, if features are located that require some mitigation, action points (geographic locations at which, if the fire reaches them, an action to mitigate is triggered) would be established and mitigation plans would be developed.  Once the fire reached the action point the mitigation plan would be implemented.  It could take several days to weeks before these actions were needed and the fire may not ever reach the identified resource at risk.

Non-Native Species Management Activities

Non-Native Species Control   Fire can be an effective tool in managing some non-native species.  However, the Yosemite Fire Management Plan is not the primary planning instrument for control of non-native species.  If the resource management division prepares a non-native species control plan that recommends the use of fire, the fire management office would prepare a prescribed fire plan.  This plan would include fire prescriptions, site preparation plans, and monitoring needed to help carry out the non-native species control plan. 

 Non-Native Species Invasion and Fire Management Activities   There are occasions when fire management activities contribute to the invasion of non-native species.  For example, in some areas the timing of prescribed burns has contributed to the invasion of non-native thistle.  As a result of knowledge gleaned through monitoring, prescribed burns in these areas are now scheduled for seasons when invasion is not enhanced by fire.  Monitoring for non-native species would continue and, as the Resource Management Division identifies practices in the prescribed fire program that require modification, changes would be made. 

Air Quality/Smoke Management

With all actions in Yosemite National Park or the El Portal Administrative Site involving prescribed or managed wildland fire, there would be strict adherence to state and federal regulations.  This process mandates consultation with California Air Resources Board (CARB) and local (county) Air Pollution Control Officers (APCO), and other federal and state agencies that are involved with similar land treatments.  Ignition of prescribed fires would only be done on “burn days” or would be allowed by a variance from the county air pollution control officer.  Visual aspects of the smoke column and/or particulates would be monitored for all prescribed fires.  Air quality monitors would be placed at strategic locations and smoke sensitive areas when appropriate.  This data would be available to the county air pollution control officers upon request.  A Prescribed Fire Plan, including smoke management, would be provided to the air pollution control officers prior to a burn so that a burn permit can be issued.  Coordination with neighboring agencies would assure that the air shed is shared.  This would normally mean that Yosemite would not be burning the same day as a neighboring agency, or that there would be adequate distance between the burn units for smoke dispersion. 

Air Quality Watershed Strategy   Smoke movement patterns have a direct relationship to watersheds, especially below 7,500 feet.  Air-quality watersheds of Yosemite are shown on map 2-16.  Smoke from lower elevation fires (below 7,500 feet) can be intense and tends to move down slope, settling and concentrating down valley from a fire.  Fires above 7,500 feet rarely cause smoke problems because of different fuel types that tend to have a slow rate of fire spread.

If several fires were burning simultaneously in the same air-quality watershed, down-valley smoke might be extreme.  Because of this, the park would potentially control additional starts within an air-quality watershed that already had a wildland fire being managed within it.  The boundary of an air-quality watershed is determined by a defined area where multiple wildland fires could burn which might affect a common area.  For example, if a fire is burning in the Illilouette Creek drainage, it is possible that no other fire in that drainage would be authorized.  Fires may not even be authorized in the adjacent Merced River, Tenaya Creek, or Yosemite Creek drainages.  The common area for these sub-watersheds is Yosemite Valley.  Similar relationships exist for the Bridelveil Creek area, the area around Hetch Hetchy Reservoir, and the South Fork of the Merced River. 

If a wildland fire became established and showed potential to become large, attempts would be made to limit the number of additional starts in the same air-quality watershed.  Coordination with neighboring agencies would be initiated within three working days of authorization to manage a wildland fire to determine if the other agency also has a wildland fire in the same watershed.  If two agencies had wildland fires that had the potential to cause significant smoke problems, then a decision would be made to either control one or more of the fires or to mitigate the amount of emissions that would be produced.  Mitigation has been successfully in the past.  For example, holding actions applied to one or more flanks of a fire will herd it into higher country where fire activity, and thus smoke production, is not as intense.

Smoke Problems   A smoke problem would be defined as any level of smoke that generates complaints.  It is the park’s intent to try to avoid smoke problems and to inform the public if they are likely to occur.  Smoke is a byproduct of fire, but under favorable and predictable atmospheric conditions (an unstable atmosphere) vertical movement in the atmosphere will raise and disperse the smoke from a fire.  During poor atmospheric conditions (a stable atmosphere), smoke tends to spread out at lower elevations, accumulating down valley from the fire.  Because of the variable effects of the atmosphere on smoke, “burn day/no burn day” determinations are made by meteorologists at the California Air Resources Board and passed on to the county Air Pollution Control Officers and fire personnel.  It is not uncommon for a burn to be ignited during excellent conditions and then a day or two later have the atmosphere stabilize and cause a smoke problem.  In the event of heavy smoke accumulations, the public would be notified as per the Smoke Communication Strategy (Appendix 4). 

Roads and Trails Used for Fire Protection

Road, trails, and utility corridors within the park would provide access for monitoring and control of wildland fires (map 2-17).  Roads and trails would be used as boundaries for prescribed burns, anchor points for constructing fire line, and as fire line.  They would provide access for engines and crew transports trying to get to a fire rapidly.  To be thoroughly useful, maintenance would be done to keep these corridors free from fuel accumulation so that they provide optimum defensibility as fire lines. 

Removing fallen trees and limbs and trimming trees and shrubs immediately adjacent to a road or trail would allow fire crews to quickly and safely use the road or trail.  Removing brush and downed trees would also reduce the risk of a fire crossing a road and threatening another area or becoming established below firefighters.  Since many of the roads and trails are important cultural resources, maintenance activities would be designed to preserve important historic characteristics and avoid impacts to contributing features.  Work along utility corridors would also be conducted in a manner that avoids impacts to cultural resources.  Table 2.11 displays roads and trails that are commonly used as fire access for both summertime wildland fires and for use as control lines for prescribed fires.  Maintenance would be done as needed: annually on some fire roads and every five to eight years on others.  Most park trails are periodically maintained to permit horse traffic and hiking access, and some of them are used as fire breaks when the need arises. 

Table 2.11   Roads and Trails Used for Fire Management Activities