For example, I received an article from the Forest Service titled “Multiple treatments are key to resilient Western Forests. In the opening paragraph, the article asserts: “Forests in the West used to be a lot more open, so wildfires were much less severe.”

The problem with this characterization is that only about 10% of western conifer forests were historically “park-like”, dominated by frequent low-severity blazes.

The primary tree that fits this model is ponderosa pine. However, even in these pine forests, high-severity blazes occurred, leaving many trees dead.

Most western forest types (and most non-forested areas like chaparral) tend to have much longer fire intervals, often many decades to hundreds of years between significant ignitions.

These trees include fir and spruce, hemlock, cedar, Douglas fir, western larch, some pines like lodgepole pine, whitebark, Bishop pine, Monterey pine, and white pine, as well as aspen. None of these trees fit the high-frequency-low-severity model. When these forests burn, they exhibit significant high-severity mortality.

In addition, most non-forest plant communities, like sagebrush and chaparral, are burned at long intervals and are not adapted to frequent fires.

In between these major fires, down logs, snags, and ground litter accumulate. However, this is all within the natural historical conditions, not some aberration as often suggested by the Forest Service.

And many national forests had few, if any, ponderosa pine. In the Northern Region of the Forest Service, which includes northern Idaho and all of Montana, only 4% of the forest type is ponderosa pine and other “dry conifer” forests.

For instance, ponderosa pine occurs only in the most eastern low-elevation portion of the Custer Gallatin NF (CGNF) in Montana. The CGNF typically characterizes all of its forest types as high-frequency, low-severity stands to justify logging.

A further problem, right up front in the opening paragraph, goes on to say, “We can actually see scars from old wildfires in cross-sections like this one. By cross-dating fire scars from multiple trees, scientists can reconstruct what past forests looked like, including how dense forests were.”

The problem ignored by pro-deforestation agencies to justify thinning and logging the forest is that there are serious methodological issues with such fire-scar studies that tend to exaggerate fire frequency.

For instance, the main way scientists obtain fire scars is by wandering through the forest in search of scarred trees. But this is not a random selection, which biases the studies from the very beginning.

For instance, if all your scarred trees are on a dry south-facing slope and more prone to burning, they may not represent the general forest condition.

It is analogous to going into a bar on a Saturday night, asking the crowd how many people like to drink alcohol, and getting nearly 100% agreement from the patrons that alcohol is good—then extrapolating that percentage to the community’s overall population.

Many fire-scar studies use a very small sample of trees to characterize entire national forests. One study of ponderosa pine found that nearly half of the fire-scar research examined only 1–2 trees, yet used these to characterize the landscape’s fire history. There are other problems that you can read about here.

By contrast, the use of other methods to determine past forest stand composition and fire frequency, including photo interpretation, sediment flow studies, pollen studies, charcoal studies, evolutionary evidence and government land office reports, nearly all report longer fire intervals and high-severity blazes as natural events rather than aberrations.

A study of “Spatially extensive reconstructions show variable-severity fire and heterogeneous structure in historical western United States dry forests” concluded that: “Park-like stands of large trees maintained by low-severity fire predominated only in parts of the study landscapes.” The main conclusions were: “forests were structurally variable, including areas of dense forests and understory trees and shrubs, and fires varied in severity, including 15–65% high severity fire.”

The typical justification given for the alleged departure from open forest is fire suppression and lack of Indian burning. However, neither of those explanations applies to most Western landscapes.

Native American burning was primarily localized and did not have a major landscape-scale influence, and fire suppression was only successful when climate/weather permitted it.

During the middle of the last century, the overall climate was cooler and moister, permitting glaciers to grow in the western mountains. At the same time, there were fewer ignitions and far less acreage charred by wildfires. In contrast, throughout the early part of the century, including 1910, we had the 3.5 million acres burn, and the dry 1920s, when as much as 50 million acres burned—all due to climate conditions. More recently, since the 1980s, as climate change has promoted more wildfires, fire suppression effectiveness has been overwhelmed.

In short, high-severity blazes are not an indication of “unhealthy” forests, but rather of natural evolutionary processes at work. The idea that most western ecosystems are frequently burnt, were characterized by open, park-like stands, and were “healthy” ignores both evolutionary and ecological realities. It is a narrative promoted to support more logging of our forests.

The way to protect homes and communities is to reduce the flammability of structures through home hardening. Home hardening is by far the most cost-effective means of reducing wildfire risk and has the fewest ecological and environmental impacts.

Janet Eastman, Oregonian, Portland, OR

Dear Janet

Just read the piece in the Oregonian about Indigenous burning and how it “fixes” forests and prevents large wildfires. I believe your piece promotes the myth that fuel treatments can preclude large, high-severity blazes, and it relies on the underlying assumption that preventing such blazes produces “healthy” forest ecosystems.

I’ve written dozens of articles on fire ecology and two books (Wildfire: A Century of Failed Forest Policy). I do not work for the Forest Service, timber industry, or tribes. Thus, my view is not compromised by financial or political considerations.

The science (as opposed to oral tradition) does not substantiate claims that tribal burning had any large influence on plant communities, fire spread, or “forest health.” Even in the Willamette Valley, which had some of the highest Native American populations, tribal burning had a localized influence around villages and other congregation locations. It did not impact the landscape-scale ecological function.

Regarding Indigenous ignitions in the Willamette Valley, Whitlock notes: “The idea that Native Americans burned from one end of the valley to the other is not supported by our data … Most fires seem to have been fairly localized, and broad changes in fire activity seem to track large-scale variations in climate” (Fire Science 2010).

In a charcoal study of Washington’s Battle Ground Lake, Megan Walsh (Walsh et al. 2008) concluded that fire frequency was highest during the middle Holocene when oak savanna and prairie were widespread near Battle Ground Lake. She suggests: “The vegetation and fire conditions were most likely the result of warmer and drier conditions compared with the present, not from human use of fire” (Fire Science 2010).

Regarding the assertion in your piece that settlement stopped these tribal burns, leading to today’s large blazes: Again, the science does not support such claims.

For instance, a 2000-year study of the same area, the Siskiyou Mt. area, contradicts the Lomakatsi folks’ claim that current high-severity burning is due to fire suppression. Colombaroil and Gavin (2002) documented that large fires always occurred in the Siskiyou Mountains of northern California and southern Oregon, primarily due to climate/weather, even during the pre-European period. “Fire is a primary mode of natural disturbance in the forests of the Pacific Northwest. Increased fuel loads following fire suppression and the occurrence of several large and severe fires have led to the perception that in many areas there is a greatly increased risk of high-severity fire compared with pre-settlement forests. To reconstruct the variability of the fire regime in the Siskiyou Mountains, Oregon, we analyzed a 10-m, 2,000-y sediment core for charcoal, pollen, and sedimentological data. The record reveals a highly episodic pattern of fire in which 77% of the 68 charcoal peaks were before Euro-American settlement…”

You can read more about these issues with scale here.

Beyond that, keep in mind that nearly all plant communities in the West did not burn at “low severity and high frequency. Most trees and other communities, like chaparral and sagebrush, have (had) long fire intervals. They did not burn frequently, and when they did, they burned with high severity.

This provides evolutionary evidence that tribal burning was insignificant at the landscape scale. The fact that we have extensive areas of sagebrush (hundreds of millions of acres) and chaparral (the single largest CA plant community by percentage)—both of which lack adaptation to frequent fire and are actually harmed if burned too often—suggests that Indian burning did not influence a major portion of the landscape.

Also consider that most plant communities in North America existed for millions of years before humans arrived. Were they “unhealthy” and a real mess for millions of years before people arrived to “fix” them? They did just fine without human intervention. Ponderosa pine, one of the species that is often cited as “needing” frequent fire from Indian burning to be “healthy,” has existed for 60 million years (i.e., about since the Dinosaurs went extinct) as a separate species. It would be absurd for anyone to suggest that, prior to human burning, the ponderosa pine was “unhealthy” for many millions of years. That’s pure human arrogance, but it certainly doesn’t jibe with science.

Finally, there is the issue of effectiveness.

All megafires—and I mean all—are climate-driven events. Climate, not fuels, regulates large fires, and fuel treatments ultimately have no significant influence on wildfire spread and severity. As an additional note, large, high-severity blazes are critical for creating snag habitat, which is essential for many species, not some kind of abnormal or “catastrophic” event. It is only a slight bit of hyperbole to suggest that many plant and animal species live in mortal fear of green forests. They depend on the snags, downed logs, and other special habitat conditions created by large-scale “mega fires” that less-informed people call “catastrophic.”

High temperatures, low humidity, drought, and high winds are the factors that create these large blazes. It is not fuel. That is the myth. Thus, small fuel reductions, whether from logging or prescribed burns, cannot and do not stop large-scale wildfires. High winds simply blow embers over, around, and through any fuel treatments. These kinds of treatments might work under less-than-extreme fire weather conditions, but under moderate fire weather, fires simply don’t burn well anyway. The vast majority will simply extinguish if left alone. The important thing is that these treatments offer little benefit except perhaps in the immediate area around a house or community.

But research by the FS itself shows that any fuel treatment more than about 100 feet from a house has no value. It doesn’t make a house safer. The only thing that works is reducing the house’s flammability. You should watch the video created by Jack Cohen, who recently retired from the Missoula Forest Service lab. He’s the nation’s expert on how wildfires influence and burn homes. Cohen has many good videos that explain why homes burn, and it’s almost always due to wind-driven embers, not direct contact with a fire front.

Cohen’s decades of research, including lab and field experiments, found that most homes ignite from embers (firebrands) carried by wind, not from direct flame contact with distant vegetation www.californiachaparral.org+1. These embers can travel miles ahead of the main fire front, so the most critical protection is within the Home Ignition Zone (HIZ) — typically defined as 0–100 feet from the home, or 0–200 feet on slopes NFPA+1.

I would be happy to chat with you about this issue and can put you in touch with other scientists who may be able to provide additional insights. Keep in mind that the FS and tribes both have a financial vested interest in promoting the idea that these fuel treatments work. You need to seek out other sources of information. Hope you will reach out to me.

For several years, I have advocated for expanding Yellowstone National Park to create a Greater Yellowstone Ecosystem National Park (GYENP).

There are many reasons to expand Yellowstone’s boundaries to include much of the surrounding national forest and other public lands that make up the Greater Yellowstone Ecosystem.

The Greater Yellowstone Ecosystem has global significance. Yellowstone is a UNESCO Biosphere Reserve, recognized for its ecological diversity, conservation efforts, and significant geological features.

If Yellowstone and the surrounding lands are to survive as a functioning ecosystem, we must recognize that the entire region is under multiple stressors.

Climate change is the greatest long-term threat. Climate change may make it impossible for many of the ecosystem’s plant and animal species to continue inhabiting the area.

Growing recreational use can harm and disturb sensitive wildlife.

Mining, logging, and livestock grazing all affect ecosystem function.

Enlarging the National Park Service’s administration of the ecosystem would eliminate ongoing threats from mining, logging, and livestock grazing, since all are prohibited in national parks.

Finally, growing population growth in the region brings its own challenges.

What would be part of a Greater Yellowstone Ecosystem? Recognizing what would be included will be determined by future discussion. However, I would suggest the following areas for national park administration.

In the north-west corner of the ecosystem, the Gallatin Range up to Bozeman, the Madison Range north to Big Sky, the Gravelly Range to Virginia City, the Centennial Valley and Mountains, and the Lionhead Area would be under NPS management.

In Idaho, the west slope of the Teton Range and the Palisades would be included in the new park.

In Wyoming, the following areas would be part of the new Greater Yellowstone Ecosystem National Park: the Wyoming Range, Salt River Range, Commissary Ridge, Mt. Leidy Highlands, Wyoming High Lakes, plus add-ons to Gros Ventre Wilderness, Teton Wilderness, and Washakie Wilderness, and the Upper Green River area.

In Montana, roadless lands adjacent to the Absaroka-Beartooth Wilderness and the Pryor Mountains would be part of the park area.

Any lands that qualify for wilderness designation, as identified in the Northern Rockies Ecosystem Protection Act, would be included in the new park.

So why expand Yellowstone?

First, the mission and general goal of the National Park Service management is to preserve ecosystem function by minimizing human impacts. Compared to other state and federal agencies, the Park Service has a natural tendency to protect biodiversity and ecological integrity.

Creation of a Greater Yellowstone Ecosystem National Park would provide greater protection for predators, as trapping and hunting are not permitted in park units.

Expansion would allow bison to expand their population into suitable habitat. Even if bison were hunted beyond the expanded boundaries, the larger bison population would suffer less from genetic and other harm resulting from hunting, trapping and slaughter.

In other areas, like the Upper Green River Allotment in Wyoming, where livestock grazing has led to the killing of dozens of grizzly bears, expansion would eliminate livestock and thus conflicts.

The NPS administration favors native wildlife and plants. For instance, restoring native fish to the degree possible is a goal of NPS management.

NPS management generally favors maintaining natural ecological processes. Processes like insect outbreaks, wildfires, drought, flooding, predation, and harsh winter weather are allowed to operate without human interference.

I am aware that achieving an expansion of Yellowstone under the present administration is unlikely, but we need to advocate for the future.

We have an obligation and responsibility to preserve the Greater Yellowstone Ecosystem. Creation of a Greater Yellowstone Ecosystem National Park would be a major step towards achieving that goal.

For example, I received an article from the Forest Service titled “Multiple treatments are key to resilient Western Forests. In the opening paragraph, the article asserts: “Forests in the West used to be a lot more open, so wildfires were much less severe.”

The problem with this characterization is that only about 10% of western conifer forests were historically “park-like”, dominated by frequent low-severity blazes.

The primary tree that fits this model is ponderosa pine. However, even in these pine forests, high-severity blazes occurred, leaving many trees dead.

Most western forest types (and most non-forested areas like chaparral) tend to have much longer fire intervals, often many decades to hundreds of years between significant ignitions.

These trees include fir and spruce, hemlock, cedar, Douglas fir, western larch, some pines like lodgepole pine, whitebark, Bishop pine, Monterey pine, and white pine, as well as aspen. None of these trees fit the high-frequency-low-severity model. When these forests burn, they exhibit significant high-severity mortality.

In between these major fires, down logs, snags, and ground litter accumulate. However, this is all within the natural historical conditions, not some aberration as often suggested by the Forest Service.

And many national forests had few, if any, ponderosa pine. In the Northern Region of the Forest Service, which includes northern Idaho and all of Montana, only 4% of the forest type is ponderosa pine and other “dry conifer” forests.

For instance, ponderosa pine occurs only in the most eastern low-elevation portion of the Custer Gallatin NF (CGNF) in Montana. The CGNF typically characterizes all of its forest types as high-frequency, low-severity stands to justify logging.

A further problem, right up front in the opening paragraph, goes on to say, “We can actually see scars from old wildfires in cross-sections like this one. By cross-dating fire scars from multiple trees, scientists can reconstruct what past forests looked like, including how dense forests were.”

The problem ignored by pro-deforestation agencies to justify thinning and logging the forest is that there are serious methodological issues with such fire-scar studies that tend to exaggerate fire frequency.

For instance, the main way scientists obtain fire scars is by wandering through the forest in search of scarred trees. But this is not a random selection, which biases the studies from the very beginning.

For instance, if all your scarred trees are on a dry south-facing slope and more prone to burning, they may not represent the general forest condition.

It is analogous to going into a bar on a Saturday night, asking the crowd how many people like to drink alcohol, and getting nearly 100% agreement from the patrons that alcohol is good—then extrapolating that percentage to the community’s overall population.

Many fire-scar studies use a very small sample of trees to characterize entire national forests. One study of ponderosa pine found that nearly half of the fire-scar research examined only 1–2 trees, yet used these to characterize the landscape’s fire history. There are other problems that you can read about here.

By contrast, the use of other methods to determine past forest stand composition and fire frequency, including photo interpretation, sediment flow studies, pollen studies, charcoal studies, and government land office reports, nearly all report longer fire intervals and high-severity blazes as natural events rather than aberrations.

A study of “Spatially extensive reconstructions show variable-severity fire and heterogeneous structure in historical western United States dry forests” concluded that: “Park-like stands of large trees maintained by low-severity fire predominated only in parts of the study landscapes.” The main conclusions were: “forests were structurally variable, including areas of dense forests and understory trees and shrubs, and fires varied in severity, including 15–65% high severity fire.”

The typical justification given for the alleged departure from open forest is fire suppression and lack of Indian burning. However, neither of those explanations applies to most Western landscapes.

Native American burning was primarily localized and did not have a major landscape-scale influence, and fire suppression was only successful when climate/weather permitted it.

During the middle of the last century, the overall climate was cooler and moister, permitting glaciers to grow in the western mountains. At the same time, there were fewer ignitions and far less acreage charred by wildfires. In contrast, throughout the early part of the century, including 1910, we had the 3.5 million acres burn, and the dry 1920s, when as much as 50 million acres burned—all due to climate conditions. More recently, since the 1980s, as climate change has promoted more wildfires, fire suppression effectiveness has been overwhelmed.

In short, the idea that most western ecosystems frequently burnt, were characterized by open, park-like stands, and were “healthy” ignores both evolutionary and ecological realities. It is a narrative promoted to support more logging of our forests.

The way to protect homes and communities is to reduce the flammability of structures through home hardening. Home hardening is by far the most cost-effective means of reducing wildfire risk and has the fewest ecological and environmental impacts.

According to Secretary of the Interior Doug Burgham: “For too long, ranchers and land managers have been forced to work under outdated rules that do not match today’s challenges.”

The Secretary goes on to assert that “President Trump has made it clear that we must cut red tape, support the people who feed our Nation, and ensure our public lands remain healthy for future generations. These updates will help us do exactly that.”

First, the assertion that public land grazing “feeds our nation” is a huge exaggeration. Less than 2-3% of the forage consumed by the Nation’s livestock comes from public lands.

Livestock grazing is already the dominant use on the majority of public lands, primarily Bureau of Land Management (BLM) or Forest Service lands. However, domestic animals graze some national wildlife refuges and even some national parks.

The most recent data analyzed by Public Employees for Environmental Responsibility (PEER) show that millions of acres grazed by the Bureau of Land Management fail basic land health standards, with livestock grazing identified as the leading cause. Ultimately, the taxpayers pay to fix or restore damaged rangelands.

Altogether, an estimated 248 million acres are used for livestock. To put this into perspective, California is the third-largest state, covering 103 million acres. So, imagine an area the size of two and a half Californians under livestock use, or more accurately, abuse.

Grazing on public lands is highly subsidized in multiple ways, including below-cost grazing fees, numerous other appropriations, and the copious ecological/environmental impacts that are ignored or transferred to taxpayers to fix.

The grazing fee for 2026 is $1.69 per Animal Unit Month (AUM), which is defined as one cow and calf. You would be hard-pressed to feed a hamster for a month for $1.69. The fees paid by ranchers don’t even cover the oversight and management of federal grazing allotments, much less the environmental costs.

On public lands, one cow-calf pair grazing for one month (an “animal unit month” or “AUM”) produces 875 kg CO2e through enteric fermentation and manure deposition with a social carbon cost of nearly $36 per AUM.

Recently, the EPA loosened Clean Water Act requirements for meat and poultry producers, which ultimately means dirtier water and higher costs to taxpayers to clean it up.

The Forest Service and BLM together administer more than 23,000 permits and leases held by ranchers who graze their livestock on approximately 29,000 allotments. To put this into perspective, there are 882,693 beef producers in the US, and nearly all of them raise their livestock exclusively on private land. Thus, the small subset of producers who have access to public land forage receive numerous benefits unavailable to livestock producers who use private lands exclusively.

For instance, one obvious benefit that public-land ranchers enjoy is the use of public allotment lands without paying property taxes, while private ranchers contribute to funding public infrastructure.

The recently passed House Farm Bill, or 2026 Agricultural Act (HR 7567). Like previous iterations of this legislation, it includes numerous giveaways to the timber and livestock industry, while eliminating or reducing environmental review and protections.

The Secretaries of Ag and Interior are to develop a grazing fuel reduction strategy within 18 months: “to utilize livestock grazing as a wildfire risk reduction tool”.

The idea that grazing can reduce wildfire risk on a landscape scale is unfounded. At best, it can be used on very localized sites at great cost and even more subsidies. Consider that the Smokehouse Fire, the second-largest blaze in recent history, which raged across northern Texas in 2024, burned almost 1.5 million acres, all of which was under domestic livestock grazing.

New grazing rules encourage targeted grazing to address wildfire risk. The proposed definition would make explicit that such actions include creating strategic linear fuel breaks, reducing fine-fuel height and fuel loading, and maintaining fine-fuel reductions.

One review of fuel breaks concluded that they (1) directly alter ecosystems, (2) create edges and edge effects, (3) serve as vectors for wildlife movement and plant invasions, (4) fragment otherwise contiguous sagebrush landscapes, and thus have questionable utility if all ecological impacts are considered.

In addition, livestock grazing would be promoted “as a restoration strategy and for post-fire recovery, as appropriate.”

Again, grazing, especially after a fire, tends to promote the establishment of weeds and flammable grasses like cheatgrass. It hardly contributes to restoration. The best restoration is to rest the allotment or eliminate grazing.

Range permittees would be allowed, under regulations to be developed within one year, to conduct “minor range improvements” on national forests and grasslands. If the Forest Service did not respond to a request for minor improvements within 30 days, the request would be automatically approved.

Minor Range improvements are defined as “improvements to existing fences and fence lines, wells, water pipelines, and stock tanks.” All of these affect other public values. Fences can block wildlife migration corridors. Stock tanks and pipelines remove water from springs and streams that would otherwise support native species, and so forth.

Given the reduction in federal agency staffing resulting from DOGE and employees who voluntarily retired or quit, federal agencies have few individuals to oversee such requests. They are almost guaranteed to be approved without any oversight or review.

The Department of the Interior (which manages BLM, Fish and Wildlife Refuges, and National Parks) proposes what it terms “modernization” of grazing regulations. Read: eliminate any concerns about ecosystem function or other impacts to public lands.

One provision is to provide more “flexibility” to permittees—meaning less regulation and oversight. The change in regulation essentially makes the economic interests of ranchers the dominant policy of BLM grazing management.

The new regulations suggest that: “BLM grazing permittees require flexibility to run their operations in the most efficient manner that is responsive to their business needs and that can be adjusted to account for changes on the landscape year to year and over time. While the operative regulations allow the BLM to facilitate some degree of flexibility within the terms and conditions of grazing permits, the proposed Rule is intended to expand and otherwise make concrete and explicit in regulation those opportunities for flexibility.”

Recently, the Department of the Interior rescinded the BLM’s Public Lands Rule, formerly known as the Conservation and Landscape Health Rule, which the administration suggests will “restore balance” in federal land management by prioritizing multiple use and supporting “responsible” energy development, ranching, grazing, timber production, and recreation.

According to the Trump Administration, the 2024 Public Lands Rule “removes any thumb on the scale in favor of conservation at the expense of productive use and development of the public lands and their many important resources.” And that the Rule had elevated conservation, or what they considered as “no use,” to the same level as other uses outlined in the Federal Land Policy and Management Act.

Needless to say, conservation is not “no use” but a “productive use” that often prevents what turns out to be costly damage to the development of public lands.

I don’t think the Conservation and Landscape Health Rule really changed much in terms of public land management on the ground; nevertheless, it did represent a slight shift in values, suggesting that conservation should have equal standing among the “multiple uses” (or abuses, as it should more accurately be termed).

The proposed new grazing rules would rescind existing standards that address water or air quality regulations.

The new rules appear to explicitly exclude grazing for conservation purposes, such as the American Prairie Reserve’s efforts to graze bison on BLM allotments by requiring that all use must be “production-oriented livestock.”

The new regulations suggest: “It is not appropriate, therefore, for the BLM to entertain applications for grazing permits from individuals or organizations who aim to compete with ranchers for valuable public forage, but who have no intention of using that forage to support a commodity-producing operation, as the TGA originally anticipated.”

Another onerous provision is the opening of closed grazing allotments.

“The MOU states the agencies will seek to avoid permanently reducing animal unit months (AUMs) or vacating allotments whenever possible, instead pursuing mitigation strategies like allotment reconfiguration or expanded management flexibility.”

The plan specifically calls for grazing vacant allotments available ahead of wildfire season to help reduce fuel loads.

This provision ignores the fact that soil disturbance and destruction of soil crusts from livestock grazing often exacerbate the establishment of cheatgrass and other highly flammable plants.

Many of these allotments have not been grazed in decades and are in various stages of recovery. They also provide good control to evaluate the impacts of livestock grazing. For example, a recent attempt to open six closed allotments (East Paradise) on the Custer Gallatin National Forest in Montana was successfully appealed.

Perhaps the most egregious aspect of the new plans is the expansion of CE or categorical exclusions and emergency authorities under the National Environmental Policy Act (NEPA), the US Endangered Species Act (ESA), and the National Historic Preservation Act (NHPA) to speed grazing authorizations.

The Trump administration considers public participation to impede the promotion of livestock interests (private businesses using public resources) on public lands.

Ultimately, this reduces the ability of the public who own these lands to voice their concerns about public land decisions.

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Once more, we are seeing the livestock industry, as well as both Republican and Democratic legislators, promoting the idea that livestock grazing can reduce wildfire risk and spread.

All of this assumes that grazing can preclude large wildfires (as opposed to small, easily suppressed fires). More fundamentally, the idea is that large high-severity blazes are undesirable and should be controlled even though they have tremendous ecological value.

The Farm, Food and National Security Act of 2026, which recently passed the House, advocates “targeted grazing to reduce hazardous fuels” and would encourage renewed grazing of vacant grazing allotments as a wildfire mitigation strategy.

The Public Lands Council, which promotes agricultural industry initiatives, makes its case in a new website: grazingpreventswildfires.org. It cites research (all by range scientists who are advocates of grazing) that purports to demonstrate that livestock grazing can reduce fire spread and severity.

A widely cited research paper, “Targeted grazing in southern Arizona: using cattle to reduce fine fuels,” was published by the range department at Arizona State University. The study asserts that grazing can reduce wildfire spread. However, in the next-to-last paragraph, they acknowledge: “Targeted grazing treatment did influence fire behavior in grass/shrub communities, but its effects were limited. Although it is a promising tool for altering fire behavior, targeted grazing will be most effective in grass communities under moderate weather conditions.”

Why is this an important qualifier?

Because under low to moderate fire weather conditions, wildfires are easy to suppress or even self-extinguish. The fires that burn tens of thousands of acres occur during extreme weather conditions where grazing fails to alter fire spread.

There are other economic considerations for targeted grazing operations, such as transporting livestock to the site, controlling grazing animals with riders or electric fencing, protecting livestock against predators, and other costs that make it only economical in very small, localized situations.

Even under less severe fire weather conditions, livestock grazing results in significant collateral damage to the land, water, and wildlife. Most of our public lands are already degraded by existing livestock grazing.

To affect wildfire, grazing must be severe, often cropping grass to only several inches tall to affect fire spread.

What industry advocates do not acknowledge is the tremendous collateral damage from domestic livestock grazing that is overlooked or minimized.

The impacts are numerous. Trampling can damage soil crusts, which are essential for holding soil together and reducing erosion. Soil crusts may also resist fire spread. Livestock trampling of soil crusts can promote cheatgrass invasion.

Grazing desirable grasses promotes the growth of weedy species such as cheatgrass. Cheatgrass is particularly pernicious because, as an annual, it greens up earlier than native perennial grasses and dries out earlier, making it particularly susceptible to wildfire ignition.

Consequently, cheatgrass fires are the biggest threat to the sagebrush steppe across the West. The idea that fuel breaks are effective has been questioned. For instance, a review of fuel breaks concluded: “Fuel breaks were the least successful in areas classified as having low resilience to disturbance and low resistance to invasion, in areas composed of primarily woody fuels, and when operating in high temperature and low precipitation conditions.” In short, places favorable to colonization and dominance by cheatgrass are unlikely to benefit from fuel reductions.

Numerous ecological costs of livestock grazing that grazing advocates seldom consider.

 Livestock grazing also damages riparian areas, socially displaces native wildlife like elk, consumes forage that would otherwise support native herbivores, compacts soils, which increases runoff and thus erosion of waterways, while fences used to control livestock can hinder wildlife migrations. Domestic livestock can also transmit disease to wildlife. For instance, domestic sheep are often the cause of pneumonia in wild bighorn sheep.

Of course, there is also the issue of methane emissions from livestock, which are among the major causes of climate change.

Given that most of the public lands that can be grazed are grazed, and we continue to have large, high-severity fires, one must wonder how anyone can suggest that grazing is a panacea.

Some recent wildfires that raced across grazing lands, including the 640,000-acre Morrill Fire that charred Nebraska this past year and the 1.5 million-acre Smokehouse blaze, the second -largest wildfire in recent history, that burned across the Texas panhandle in 2024, would suggest that livestock grazing is not a deterrent to fire spread.

There is, as with many such claims from industry, a bit of truth: livestock grazing under very strict, localized conditions can influence fire behavior. Using domestic animals to graze immediately adjacent to structures or at the edge of a community might affect fire spread. However, at the landscape scale, it doesn’t for a host of reasons.

As with any grazing fuel reductions, to the degree they do influence fire behavior, they can only change fire spread if a blaze encounters a recently grazed field or pasture. Since the vast majority of  “fuel treatments” never encounter a fire when they might be effective, we get all the negatives without any benefit—if any exists at all.  

Like all advocacy for fuel treatment, whether logging or grazing, one must look closely at the full ecological costs, as well as the assumption that high-severity blazes are undesirable. From the perspective of ecosystem health, eliminating livestock grazing from public lands is by far the most cost-effective and best public policy solution.

The Gallatin Range is a spectacular glaciated mountain range that runs south from Bozeman to Yellowstone National Park. These mountains are the last major unprotected landscape in the northern Greater Yellowstone Ecosystem. A minimum of 250,000 acres of the Gallatin Range, as advocated by the Gallatin Yellowstone Wilderness Alliance, should be designated wilderness under the 1964 Wilderness Act.

GYC is among the members of the Gallatin Forest Partnership, which includes mountain bikers, ORV users, hunt and fishing organizations, the Blackfeet Tribe, and the big three conservation groups in the Bozeman area: GYC, The Wilderness Society, and Montana Wildlands (formerly Montana Wilderness Association), among other organizations.

The ad features a series of recreational users, including a speeding mountain biker, a fly fisherman, a couple on horses, and a runner. The ad says the GFP legislation will protect access to the range.

Given that the proposed legislation names recreation as one of its key features, it’s not surprising that GYC says nothing in the ad about preserving non-human values such as wildlife habitat, biodiversity, carbon storage, or wildlands. It’s all about human recreational use.

Though GYC’s name mentions the ecosystem, this ad says nothing about ecosystem integrity or wilderness or how protecting roadless lands from all forms of exploitation is critical considering climate change. The Greater Yellowstone all about making the Gallatin Range a playground.

The ad shows how far the organization has strayed from its initial origins and mission. Back in the early days, GYC focused primarily on real threats to the ecosystem, such as logging, mining, oil and gas development, rural subdivision, and, to a limited degree, even livestock grazing.

Nevertheless, back then, the organization consistently advocated for scientific analysis to portray the ecosystem’s ecological values. One of its primary messages was that the cumulative effects of all these activities pose a threat to the ecosystem’s landscape integrity.

Today, one of the most troubling cumulative impacts comes from recreational use—and yet this is the very activity featured in their ad. No mention of how this might affect sensitive wildlife, such as grizzlies or elk. Nothing about the cumulative effect of new trails or the new roads being built for forest logging in Hyalite Canyon and elsewhere.

And, of course, there is nothing about how the proposed legislation will diminish wild land protections. The 1977 Montana Wilderness Act (S. 393) protected the Gallatin Range by designating the 155,000-acre Hyalite-Porcupine-Buffalo Horn Wilderness Study Area, which requires the Forest Service to manage the landscape for potential inclusion in the national wilderness system.

The legislation says, “The Wilderness Study Areas designated by this Act shall, until Congress determines otherwise, be administered by the Secretary of Agriculture to maintain their presently existing wilderness character and potential for inclusion in the National Wilderness Preservation System.”

The term “shall” is critical language. It means the Forest Service has no discretion but to preserve the wildland character of the area. In my view, the Custer Gallatin Forest Service has violated this mandate repeatedly by allowing motorized and mountain bikes (wheeled vehicles are prohibited in wilderness) in the Gallatin Range.

In recognition of its wildlands values, the Gallatin Range was initially included in the legislation creating the Lee Metcalf Wilderness in the Madison Range in the 1980s. However, during the legislative debate, the Gallatin Range was removed due to a legacy of railroad checkerboard alternative sections of land that some felt would complicate wilderness protections.

In the 1990s, this issue was resolved by several legislative efforts that led to the removal of railroad checkboards with the express purpose that the roadless lands would eventually be designated wilderness.

The range contains some of the best wildlife habitat in Montana. In particular, the Buffalo Horn and Porcupine drainages are critical lands for elk migration, grizzly bears, and numerous other species. In the northern part of the range, the South Cottonwood drainage is an essential northern extension and wildlife corridor of the larger wildlands.

All of these drainages are removed from the original S. 393 WSA boundaries by the Gallatin Forest Partnership legislation supported by GYC.

For more on the biological values of the Gallatin Range, see Lance Craighead’s report.

Apparently, GYC has not bothered to consult any ecologists or biologists, or it would have a difficult time rationalizing why it is proposing that the best wildlife habitat in the entire range be open to more recreational uses.

The proposed Greater Yellowstone Conservation and Recreation Act would only include the 102,000-acre as wilderness of the potential 250,000 acres that qualify for wilderness designation. And this significantly reduces the 155,000 Hyalite-Porcupine-Buffalohorn WSA (HPBH) by 53,000 acres.

Red shows the areas that are currently in the WSA, but would be removed if the proposed Greater Yellowstone Conservation and Recreation Act were passed.

Even more egregious, legislation removes WSA status for the Buffalohorn and Porcupine drainages, the most important wildlife habitat in the entire range, and creates weak protection as a “wildlife and recreation management area.”

It also removes another portion of the original HPBH WSA in West Pine by designating it a West Pine Wildlife and Recreation Management Area.

Finally, it removes WSA status for the South Cottonwood drainage by creating a 70,000 Hyalite Canyon watershed and recreation area that includes the Cottonwood drainage.

The Act also adds 22,000 acres of wilderness designation to the Lee Metcalf Wilderness and 15,000 acres in the Cowboys’ Heaven area of the Madison Range. Though I am advocate for maximum wilderness everything—neither of these areas are seriously in jeopardy from any resource exploitation.

The problem with all these “new” designations is that we have little idea how well they would work — or not — to preserve wildlands and wildlife, despite their names. What we do know is that designation as wilderness under the 1964 Wilderness Act is the Gold Standard for Conservation. Anything less than a wilderness designation is a diminishment of protection.

We aren’t creating any more large roadless areas. Indeed, due to the Trump administration’s many recent management decisions, including rescinding the Roadless Rule, advocating for more logging, reopening closed grazing allotments, and other executive decisions, we need wilderness designation more than ever.

The emphasis on recreation rather than biological protection is emblematic of the shift in values and mission that many so-called conservation organizations have undergone over the past couple of decades. Biodiversity and wildlands preservation are secondary to other values, including advocacy for recreational access, which apparently is now the main goal of GYC.

Given that nearly all other bison herds are managed as domesticated animals, usually fenced in, inoculated for disease, selectively killed, and protected from predators, starvation, and diseases, only increases the overall ecological value of the Yellowstone herd. As such, the bison deserve special treatment that recognizes their extreme value.

The following video is a discussion by Dr. James Bailey on bison genetics and other topics.

Several things should be considered. Below are the highlights; more details are available on the Montana Wild Bison Restoration Council website.

Bison should be managed to maintain their evolutionary and ecological values. As one of the least domesticated bison herds in the nation, activities like human-initiated population removal should be discontinued.

One of the main evolutionary adaptations of bison is migration. Maintaining the migratory behavior of the Yellowstone bison should be a primary management goal. Wild buffalo need to be free to roam, as do deer, elk, and all other wildlife.

To quote from a recent paper, “Captivity may broadly impede bison ecological function: space, season and management.” Our results demonstrate that captivity likely prevents bison from using their available landscape seasonally at broad scales, which could have ecological consequences for this historically nomadic herbivore. Although sociopolitical realities prevent bison restoration at a continental scale, increasing the amount of space available to bison where possible has the potential to replicate previous ecological processes.”

However, current management is harming bison migration tendencies. Both capture and slaughter near the northern boundary of the park, as well as tribal hunting outside of the park, are selectively killing the very bison most likely to migrate.

In previous iterations of the bison management, the NPS has suggested that one of its goals is to provide bison for tribal members to kill outside the park to preserve cultural values. Preservation of cultural values is not a NPS mission, but preserving ecological values is. Essentially, the NPS has made the park bison into hatchery animals, being produced for the consumption of humans. That is not a means of preserving the unique genetics of park bison.

Furthermore, whether through capture and slaughter or tribal killing, bison are being removed from the Yellowstone ecosystem with serious consequences for the ecosystem’s integrity. Reducing numbers has several consequences. It removes bison that would otherwise die, providing food for predators and scavengers.

Also, reducing the population affects evolutionary processes that select the weaker animals or more susceptible animals. Higher populations would likely lead to more starvation, disease, and harsher weather. Plus, weaker animals are more vulnerable to predators, and so forth.

Thus, promoting bison removal jeopardizes the bison genome and other wildlife in the park that rely on living or dead bison for sustenance.

Therefore, the MWBRC supports a policy that recognizes the ecological and evolutionary values of wild migratory buffalo. Yellowstone bison do not need management by human interference – let their “managers” be themselves, the wolves, the grizzlies, and the weather.

The NPS should rely on natural selection and bison dispersal as the primary tools to regulate bison numbers. Yellowstone’s lead bison biologist has publicly stated that the park alone can sustain 10,000 to 11,000 buffalo.

Trapping for shipments to slaughter and quarantine should immediately cease for the reasons mentioned above.

Quarantine, or the greenwash-titled Bison Conservation Transfer Program, is just another way to remove buffalo from the wild population through domestication and relocation. The transfer of Yellowstone bison to tribes or private ranches effectively privatizes Yellowstone’s wildlife. To the degree that any transfer occurs, it should only be permitted if the bison remain on public lands. The Charles M. Russell NWR and the Missouri Breaks NM are suitable locations for bison transfer.

Thus far, the NPS has justified the Conservation Transfer Program and the production of bison to provide targets for tribal members outside the park, based on the MDFWP’s interpretation of treaties. However, there are numerous reasons why this interpretation may be incorrect. The basic issue is that no tribes actually have treaty rights to kill bison north of Yellowstone. It’s a nuanced issue, but the NPS should conduct its own due diligence and not rely on the tribes’, the state’s, or anyone else’s interpretation of treaties. See my commentaries on tribal treaty hunting rights here.

Even if the NPS agreed with the tribes that they had a right to kill bison north of Gardiner, under current legal interpretations, treaty “rights” can be modified or restricted in the interest of conservation. Given the international value of Yellowstone bison, it would seem that invoking such an interpretation is justified.

Human barriers and behavior must change. The burden has been placed on wild buffalo for far too long, and it is time for humans to change their behavior and learn to coexist. That includes amending fencing that chokes migration corridors, implementing safe-passage infrastructure along roads and highways, restoring native vegetation, and removing harmful, invasive species (e.g., cattle) that are blocking wild bison restoration.

Yellowstone should start labeling and promoting the concept that the park’s bison are an international treasure, just as the park’s geothermal features are of international significance. Yellowstone should manage bison as the ecological and evolutionary heritage they represent.

To comment please use this https://parkplanning.nps.gov/document.cfm?documentID=150904

The Deschutes National Forest in Oregon has one of the highest road densities of any national forest in the country. A map of the forest (outside designated wilderness) looks like spaghetti spilled across the ground.

In the summer, numerous individuals camp in dispersed campsites outside Bend and other communities, posing a wildfire threat simply by their presence in the forest. Beyond the obvious ways that humans can ignite wildfires, such as leaving campfires unattended or tossing a cigarette out on the ground, there are other “black swan” events, like driving over grass with a hot exhaust pipe or a spark from a chainsaw hitting a rock, that can start a blaze.

I was pleased to see that the Deschutes National Forest is beginning to take this threat seriously by closing roads. Effectively closing a road requires more than merely putting up a sign or even gating access.

The following photos show how one can create a serious barrier to motorized access. The Deschutes NF has barely made a dent in road closures, but the ones I’ve seen are effective. Hopefully, other national forests can begin closing unnecessary roads.

In addition to reducing human ignitions, road closures have numerous other ecological benefits, such as reduced disturbance to wildlife, erosion, weed spread, and disease.

Of course, the best way to reduce human pollution and other environmental impacts is to avoid building the roads in the first place. One of the increasing problems associated with fuel treatments like thinning is that they often require new road construction.

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I have followed the Bozeman-based Property and Environment Research Center (PERC) for years. They claim to be a “free market environmental” think tank, but in most matters, they are nothing more than a shill for resource exploitation and privatization of public resources. Repeatably, they advocate for “free markets” but neglect to account for real costs.

People cannot make informed decisions if the real costs of any activity are ignored. And when it comes to ecosystems and wildlands, we cannot articulate the real values. Relying only on “free market” solutions, we ignore or miss the importance of intact ecosystems.

The report is full of numerous assumptions that can be challenged.

First, the report assumes that prescribed burns will reduce air pollution and, in turn, health risks from smoke. The problem with this assumption is that wildfire smoke often originates hundreds to thousands of miles away from communities. For example, in 2023, New York had the worst air quality in the country—but the smoke originated with wildfires more than a thousand miles away in Canada. Thus, local fuel reductions, even if they reduced wildfires, may have little actual impact on community smoke issues.

By contrast, air pollution from prescribed burns can significantly add to local smoke pollution. For instance, one study of prescribed burning found that it contributed to an additional 15% in pollution in 10 southern states.

Since smoke from distant fires does not affect individual communities every year, prescribed burns can cause air pollution every year and thus are often additive to the smoke that otherwise originates from wildfires.

Furthermore, since most prescribed fires are conducted during periods less favorable for complete combustion, they often produce more particulate matter than a high-severity fire, which, due to higher burn temperatures, results in more complete combustion. Though, admittedly, due to the greater size of high-severity burns, overall smoke emissions may be greater.

A common problem associated with prescribed burns is that while they might have some influence on fire spread and wildfire smoke immediately after treatment, over time, fuels grow back. The key factor is time since treatment. One review suggests that the effectiveness of prescribed burns on fire hazard reduction lasts only about 2–4 years.

In many instances, prescribed burns can increase the biomass of flashy fuels like grasses and even lead to vegetation conversions that are far more susceptible to ignition and fire spread than the original vegetation.

A common result of prescribed burning in many ecosystems is cheatgrass invasion. Cheatgrass is a highly flammable animal that increases the probability of future fire ignition and spread. Unless the site is continuously retreated to reduce fuels (i.e., forever), prescribed burns may increase the likelihood of a greater fire hazard.

Another problem with the PERC paper is that it fails to consider the probability that a wildfire will encounter any fuel treatment. Most estimates suggest that wildfires occur in 1–2% of treated areas (prescribed burns and thinning), where they might influence fire behavior.

A study of the Sierra Nevada, where there has been extensive fuel reduction, nevertheless found: “Modeling results generally confirmed that fire-treatment encounters are rare, such that median suppression cost savings are zero.”

Yet the PERC study only included wildfires that intersected fuel treatments to conclude that fuel treatments are cost-effective.

You can’t have any “savings” in firefighting costs if the fires never encounter a fuel treatment.

Another issue with the assumptions behind the PERC is that it repeats the same argument that fire suppression has led to the observed increase in fire severity and size. Yet there is abundant evidence that the influence of fire suppression may be exaggerated.

Plus, climate change is the main driver of increasing wildfires. Changes in fire size and spread due to increases in temperature, drought, wind, and other climate factors are not linear. Rather, they are exponential.

As one recent publication concluded: “As aridity increases linearly, the potential for growth of large fires accelerates, leading to exponential increases in AFAB (Annual Forest Area Burned).”

Another “cost” not addressed by the PERC analysis is that most fuel treatment operations require additional road access. This is particularly true of logging operations. Yet there is abundant evidence that the majority of human-caused ignitions occur within a few hundred feet of roads. More roads. More fire.

The PERC report also repeats the myth that Indian burning somehow resulted in a significant change in fuel composition. This ignores numerous studies that conclude that pre-settlement Indian burning had little influence on landscape fire. Most of these fires were localized. In nearly all instances, the major factor in historic and current wildfire size and spread is climatic conditions.

Most wildfires, whether ignited by Native Americans or by natural processes like lightning, are small and often self-extinguish, even if they are not suppressed. i.e., nature (climate and weather) does a pretty good job of limiting wildfire spread under most conditions.

The main method used to calculate past historical fire conditions relies on fire scars. However, all this does is count the number of fires (which, overall, were small) rather than the ecological footprint of the blazes.

You can have numerous wildfires, but if they burn only a few acres, even hundreds of wildfires across a landscape do not amount to a hill of beans. It is the relatively rare ignitions that burn thousands of acres that influence landscape-scale vegetation and fire rotations.

The problem with all the assumptions about fuel treatments is that while they may be effective in slowing or suppressing wildfires under moderate fire weather conditions, only those burning under extreme wildfire weather pose a serious threat to communities. These fires are less than 1% of all wildfires.

One paper concludes: “Fire season climate variables were correlated with the annual number of extreme events and area burned.”

Under extreme fire weather conditions, drought combined with higher temperatures, lower humidity, and extreme winds are the ingredients for significant wildfires that are virtually impossible to stop. Embers tossed by the wind are blown over, around, and through fuel treatments.

One study concluded: “Airborne embers within plumes can ignite spot fires ahead of a fire front, which, along with direct progress of the fire front, can contribute to wildfire growth. Embers can fly over firebreaks and other containment methods – like back-burning and aerial fire retardant.”

Indeed, there is evidence that fuel treatments like thinning can increase fire spread by opening the forest to greater solar penetration, which dries fuels and soils, and to greater wind penetration, which assists spotting and fire spread.

There are numerous negative consequences of fuel treatments that the PERC report ignored. For example, logging and wood processing tend to increase carbon emissions, even those from wildfires. In Oregon, the wood products industry accounts for 35% of all carbon emissions—more than all transportation in the state.

Most studies, including PERC, fail to consider the loss of trees removed as a consequence of fuel treatments. One recent study found that when you combine the tree mortality from wildfire, along with those killed by chainsaws, the overall forest loss is greater. This has serious implications for carbon storage.

Many wildlife and plant species depend on high-severity blazes, which fuel reductions that aim to limit them.

The effort to reduce fuel by logging can impact the genetics of forest stands. A logger with a chainsaw cannot tell which trees have resistance to drought, insects, disease, or wildfire.

A further problem with the PERC paper is that it fails to compare the cost of fuel treatments with the likelihood that such treatments will result in home losses. Numerous studies demonstrate that home hardening is a far more effective use of funds.

There is a role for strategic prescribed burning and fuel treatments, typically near communities. However, given the significant variability in climate, terrain, vegetation communities, and other factors, combined with the negative impacts associated with logging and ‘active forest management” the conclusion that fuel treatments are cost-effective needs greater scrutiny, and the PERC report fails to do so.

ADDITIONAL SUPERB COMMENTARY ON PERC REPORT BY DICK HUTTO Author of the Beauty of the Burnt Forest

I agree with George Wuerthner that the recent PERC piece entitled “Beyond Wildfire Suppression:
The economic case for fuel treatments on national forests” is deeply flawed. The piece left plenty of room for some deeper and more accurate ecological thought. I would add the following thoughts to Wuerthner’s excellent points:

1. The “environmental challenge” referred to in the first sentence of the PERC web post (https://www.perc.org/2026/05/07/beyond-wildfire-suppression/) is a challenge only in that the public doesn’t understand anything about the ecology of disturbance-dependent systems—we have an educational challenge, not an economic challenge. Tallying costs related to wildfire “damage” is misleading because we could avoid most of those costs altogether if we wanted to. Wildfires will occur, and if humans are unprepared then, yes, there will be economic costs, but don’t blame the fires for those costs! You can incur surgery costs for sun damage too, but that doesn’t mean you should blame the sun—maybe a little sunblock might have helped! In a similar vein, we can erase most property loss costs due to fire through preparedness, and we can eliminate firefighting costs altogether if we just let fires burn. Ecosystems are not “disrupted” by fire in a bad way; they are transformed into magical places that anyone who has taken the time to look can see for him or herself! Also, wildfires would not produce “disruptions to local economies and ecosystems” if local communities took advantage of the ecotourism possibilities that burned forests bring.
If you’re really concerned about health risks associated with fire, then consider that fires have burned everywhere in the West for millennia. Consider also that we are adding unnecessary and excessive smoke from low-severity understory burning well outside the normal burning seasons in the name of forest restoration, even when the vast majority of forests are well within their natural range of variation and in no need of “restoration.”

2. I get so tired of the misleading information presented in the second paragraph. Most (>85%) of our western conifer forests are well within their historical range of natural variation and have not experienced a “buildup of fuel loads.” Yes, the authors then clarify that they’re referring specifically to the “semi-arid and pine-dominated” forests, but they don’t acknowledge that those forests occupy less than 10% of the conifer forests out there! Most mature western mixed-conifer forests have always had dense understories. The dense understory problem we all read about is associated with a small fraction of our forests—they are not typical most western forests. Thus, even though the USFS has targeted 50 million acres for fuels treatment, such treatment is misguided for most of those forest acres. It’s time to help the public learn something about the ecology of disturbance-dependent forests, and how necessary severe crown fires are for maintaining the entire successional process which, in turn, supports plant and animal species that depend on blackened, burned-forest conditions for their very existence!

3. The third paragraph starts with a false dichotomy. By noting that we skew resources toward suppression rather than prevention, the implication is that those are the only two alternatives, and that prevention is the better way to go. Not only are there more than two possibilities here (we could, and should, do neither!), but saying that there are “broad societal benefits” and few incentives to invest in thinning and burning misses the bigger point entirely. The authors are sidestepping what is involved in maintaining the ecological integrity of a disturbance-dependent forest entirely—we must support management that encompasses tolerance for a natural process that is not all that risky if we prepare our homes and communities in advance. The data out of the fire lab in Missoula are clear on that—risk is associated almost entirely with the home itself and its immediate surrounding.

4. When it is stated in paragraph 6 that fuel treatments are “ecologically effective,” what in the world do you mean? Such treatments are totally inappropriate for >85% of our western forests, as I note above—most western forests were born of, and are maintained by, mid- to high-severity fire regimes. Numerous plant and animal species have evolved to now depend on blackened forest conditions, so please explain how “fuels treatments” provide necessary conditions for ANY plant or animal species. Name one species…you can’t!
5. Regarding the summaries of those two studies, whether fuel treatments lower suppression costs or not is an irrelevant question if one includes the real possibility that we need neither! The forests are fine as is, and fire only restores natural successional processes to the forest system. The one study (Study two) may find that fuel treatments reduce fire spread and severity, but that is true only under mild fire conditions; under severe conditions (which are responsible for 98% of the land burned in any year), they don’t do squat. When those treatments do work, they introduce understory fire into systems that evolved with overstory fire so they compromise the integrity of our disturbance-dependent forests. Fuel treatments may reduce property loss by $2.8 billion and cost only a third of that, but a focus on home hardening would eliminate home loss costs altogether! Your whole focus on comparing costs and benefits associated with a false sense of choices makes the whole economic exercise meaningless.

Thus, from a pure climate perspective, preservation of boreal forests is the best strategy from both an ecological and economic perspective. Yet across the globe, there are increased efforts to log these forests.

The boreal forest stretches across much of Siberia, Northern Europe and the majority of Canada and Alaska. These spruce, fir, and pine forests make up 17% of the forested area of the planet, and thus are a significant carbon storage system.

Storing carbon is particularly important today because of climate warming. CO2 is well established as an agent that can trap significant amounts of heat and the burning of fossil fuels by humans has led to global climate warming.

Collectively, boreal forests store approximately 1/3 of the carbon found in global forests.

Much of that carbon is stored in boreal forest soils. One of the reasons boreal forests store so much carbon has to do with the cold climate that dominates these regions. In many areas, biological breakdown of plant material, including roots, is slow due to the short summers when decomposition can occur, along with the often waterlogged and cold soils, which limits fungi and bacteria activity necessary for decomposition.

The same basic principle of slow decomposition applies to a degree to the coastal temperate old-growth forests that lie along the Northern Pacific Ocean in northern California, Oregon, Washington, British Columbia and Southeast Alaska, as well as many higher elevation spruce-fire forests of the West.

The researchers compared sites that were near each other to control for site differences. Then they measured the carbon stored in primary forests, soils and dead wood that may have mortality from natural processes like wildfire, with managed stands cut in 60-120 year rotations. The researchers also included in their comparison the carbon that may be stored in wood products produced by active forest management, such as paper and wood, as well as any wood residue left on site, such as roots, down wood, etc.

They found that primary forests stored more than 72% more carbon than managed forests, and this number increased to 83% if the carbon in wood products and paper were excluded from the comparison.

Unlike tropical forests where much of the carbon is found in the above ground trees and other vegetation, in these colder forests, the bulk of the carbon is located in the soils. The breakdown is 30% in live trees, 64% in soil, and 8% in dead wood.

The same basic concepts apply to many western forests. For instance, in Oregon, the wood products industry is responsible for the biggest carbon emissions in the state, more than all cars, airplanes, and other forms of transportation.

Even when burned, most of the carbon remains on the site. What burns in forest fires are the needles, small branches and other “fine fuels” while the bulk of the carbon remains on site in the soils, snags and down wood.

This is why preservation of primary forests and proforestation (regrowth of forests) makes sense from a climate warming perspective, not to mention all the other reasons we need intact forests, including watershed protection, wildlife habitat, and the preservation of evolutionary processes.

A new paper in Nature Communications documents the advantages of home hardening. In recent decades, home losses across the West have tripled.

But they determined three factors could substantially lower home wildfire losses. None of these are based on thinning/logging or prescribed burning large tracts of public lands, as proposed by the Fix Our Forest legislation and other “solutions” that involve degrading public lands.

The researchers studied five major California wildfires with substantial structure losses: 2017 Tubbs, 2017 Thomas, 2018 Camp, 2019 Kincade, and 2020 Glass Fires. This research demonstrated that home hardening, defensible space, and spacing could increase home survival from nearly zero to 50%.

The main threat to communities comes from embers, not a wall of flames. Wind-blown embers are the number one cause of wildfire home losses.

The fuel that threatens your home comes from your neighbor’s house, not the woods. Dense housing developments can protect themselves only if every neighbor does the same work. In other words, these fire-wise practices are like a vaccine: the more homes that reduce home ignitability, the greater protection for all residents.

One should start with the home. Hardening the home requires changes in construction materials and in the flammability of the house itself. Replacing wooden shingles with metal roofs, screening vents, cleaning gutters, replacing old windows with heat-resistant windows, installing concrete fiberboard on the outside of the home, and other measures can all make it less likely a house will burn.

Next, beyond the house, creating defensible space around structures by removing flammable materials adjacent to homes is key. Starting from home outward up to 100 feet from the home significantly reduces the chances of an ignition.

The first five feet should have no flammable materials, such as grass or flammable shrubs. The goal is to keep this zone completely free of combustible materials. This includes keeping wooden fences and gates away from the home.

Beyond the five-foot perimeter, a 30-foot zone around the house may feature a manicured lawn, trees, and other vegetation. Keep dead branches, pine needles, and weeds from accumulating in this area. Trim all tree branches below 6 feet above the ground.

Note that studies have demonstrated that fuel reductions of more than 100 feet add little to home protection, which is why Forest Service logging proposals, often miles from a community or home, provide no decrease in structure flammability.

You can create fire buffers using stone walls (which can stop a grass fire), driveways, and cement patios, all of which can reduce the chances of a fire ignition.

There is a minimum number of homes that must practice home hardening and defensible space to maximize community protection. Even if you implement firewise practices, if your neighbor fails to do so, you may still lose your home. This is why such measures are community-wide investments.

The current emphasis on fuel reduction in the hinterlands misses the mark. Embers can travel 1-5 miles and ignite homes. We need a paradigm shift in public policy from degrading forests through logging and other fuel-reduction measures to a focus on the home and community.

Funds are finite. So, where do you get the most bang for your buck? A shift to investments in home hardening and defensible space would yield far greater benefits for community safety than continued forest destruction, which primarily benefits the timber industry, not homeowners.

If you want to understand why we are seeing larger wildfires, severe drought, and higher temperatures, I suggest the mantra should be “it’s the climate, stupid.”

Yet, it appears that most agencies, many scientists (who are paid by the Forest Service and timber industry), and far too many conservation groups, blame recent large blazes on “over dense” forests that are “unhealthy” and in need of thinning (read logging).

To these folks, tree mortality from natural processes like drought, insects, or wildfire is an indication of “unhealthy” forests. This paradigm drives all federal and state forest policy.

The driving force in all large fires is climate and weather, not fuel. I am always astounded that advocates of logging can seemingly ignore the fact that most of the West (and other parts of the country) are in severe drought. The historic conditions that created the forests we have today no longer exist. Our forest ecosystems are operating under a new climatic regime. And yet it does not seem to occur to people that this might have something to do with the large blazes we are experiencing.

Drought, high temperatures, low humidity, and wind are the key factors in all large blazes. The ongoing climate conditions that began in the 1980s have exacerbated all of these factors.

It doesn’t matter how much fuel you have; if you don’t have the right climate/weather conditions, you will not have a significant blaze. That is why wildfires are almost non-existent in wet, cool places like the Tongass National Forest in rainy Southeast Alaska. You could use a blowtorch to ignite the forest, and you would not get a large conflagration.

We have many climate/fire studies that demonstrate that, under severe drought conditions, wildfires are larger and more frequent—regardless of fuel type. By contrast, if you have decades of wet, cool conditions, the acreage burned and the size of wildfires decrease.

We have recent evidence of this trend from the last century. In the early 1900s, we experienced a significant drought. Remember the Dust Bowl? Indeed, in 1929, more than 50 million acres were charred across the West.

To put that into perspective, today, if 10 million acres burn, it is considered a “record” year.

Then, in the late 1930s, the climate shifted due to the Pacific Decadal Oscillation (PDO), which controls climate conditions along the West Coast. Throughout the 1940s through the early 1980s, the climate was considerably cooler and moister. The number of ignitions declined; even those that managed to burn did not impact large areas.

During this period, glaciers grew in the Sierra Nevada, the Cascades, and the Rockies. Some scientists were predicting a new Ice Age.

In addition to fewer large fires, the cool, moist conditions favored tree establishment and survival, leading to denser forest stands.

While most logging and prescribed burn advocates attribute denser forests to “fire suppression,” it ignores how many natural conditions influence fire suppression efforts. It is easy to suppress fires when it’s cool and moist, but the supposed success of fire suppression was more a consequence of natural conditions that hindered ignition and spread.

Nature did a fine job of suppressing fires and increasing forest density.

The other reason given for larger blazes is the presumed cessation of “Indian burning.” According to this idea, before the spread of Euro-American control over wildfires, native people kept forest fuels low, forests healthy, and everyone happy by regularly burning the woods. Here is a recent paper promoting the idea that Indian burning kept fuel loading low and prevented large fires.

There are many problems with this concept.

First, while tribal people did burn the landscape, the influence was primarily local. In other words, Indian burning was localized and did not have a landscape-scale effect. We have numerous studies documenting the negligible influence of tribal fire, including evolutionary evidence.

For instance, Vachula et al. (2019) did a study of what is now Yosemite National Park where, historically, large Indigenous communities resided. Their research found a direct correlation between climate and the amount of burning on the landscape.

“We analyzed charcoal preserved in lake sediments of Yosemite National Park and spanning the last 1400 years to reconstruct local and regional area burned. Warm and dry climates promoted burning at both local and regional scales…

For instance, sagebrush ecosystems are among the most widespread vegetative communities in the West, yet are not adapted to fire. If tribal burning were as widespread and influential as claimed, we would not have sagebrush-adapted species like sage grouse, sage thrashers, pygmy rabbits, and a host of other species specifically adapted to sagebrush landscapes.

A further problem with the idea that fire suppression and Indian burning reduced large blazes is that most plant communities in the West burned at long fire intervals, during which fuel naturally built up.

Finally, you have to ask yourself, how did forests survive and remain healthy for millions of years before there were any humans in North America? For example, ponderosa pine forests, a tree species that many suggest only remain healthy if they experience frequent fires set by humans, have existed as a separate species for 55–60 million years. Yet, tribal people only colonized North America in the last 15,000 years or so.

Fire suppression is not the issue. Climate change is what is driving large blazes. And solutions like increased logging or even prescribed fires are not going to significantly reverse the ongoing effects of severe drought and climate change.

The change in wildfire spread and size began in the late 1980s, as the cumulative influence of greenhouse gases began to create warmer, drier conditions, which in turn led to more wildfires.

The ultimate cause of larger blazes is warming climate. Until we, as a society, seriously address climate change and work to reduce greenhouse gas emissions, no amount of logging or prescribed burning will result in fewer large blazes.

In the meantime, the only viable way to protect homes and communities is to ramp up home hardening to reduce the vulnerability of structures to ignition.

The Forest Service claims its “treatment” (euphemism for logging) is necessary because the area is at “risk” of disease, insects, and wildfire—all natural evolutionary processes necessary for healthy forest ecosystems. It behooves me to understand how killing trees this year by cutting them down “saves” them.

In reality, the Bear Palmer area forests are at far more risk of mortality from chainsaws than from any natural source of mortality.

Of course, the forests have lived with disease, insects, and wildfire for millions of years, but not chainsaws. However, the Forest Service has never seen a tree that couldn’t benefit from being cut down with a chainsaw so that it wouldn’t die from natural causes such as disease, insects, or wildlife.

The probability that these forests will “suffer” the cruel fate of dying from disease, insects, or wildfire is extremely low, while the chances that chainsaw medicine will kill them are nearly 100%.

Under the Forest Service Forest “Health” project, more than 800 acres would be clearcut, another 800 would be commercially thinned, and 500 acres would have groups of trees removed to create random openings in the forest, just like disease, insects, or wildfire would do, since all of these natural processes usually create a mosaic pattern.

In addition to commercial logging, 565 acres of small trees will be cut, and more than 1,400 acres will be thinned by hand. Prescribed fire would be set to about 260 acres.

Chainsaw medicine creates many ills for the forest ecosystem. The logs taken to the mill remove carbon storage from the area. Even dead trees resulting from wildfire, insects, or disease store carbon for decades, helping to reduce climate change.

The deforestation proposal calls for 9 miles of temporary roads and 7 miles of newly constructed routes.

Roads necessary for tree retrieval are a major source of sedimentation in streams, harming fish and other aquatic life and impacting Bear Creek, a tributary of the nationally famous Yellowstone River.

Roads also reduce security for grizzly bears and wolves, which are the main sources of mortality for them.

Logging also interrupts evolutionary processes. No logger or forester knows which trees have genetic features that help them survive insects or disease. While natural processes select for the fittest, loggers select for timber value—something that doesn’t benefit the forest.

Deforestation of trees that would potentially die of natural causes harms wildlife and plants. For instance, 45% of the bird species in the northern Rockies use snags in some way during their lifetimes. Native bees, important pollinators of flowers and shrubs, rely on dead logs for nest habitat. About 40% of Montana’s mushroom species are most abundant after a wildfire. And so it goes. Chainsaw medicine does great harm to forest ecosystems.

To add insult to injury, almost 800 acres of the project are within the North Absaroka Inventoried Roadless Area and will be “treated” (read: logged).

All of these impacts are even more abhorrent because they are being proposed adjacent to Yellowstone National Park. Apparently, maintaining the ecological integrity of the Greater Yellowstone Ecosystem, the largest relatively intact temperate ecosystem, is not a priority of the Custer Gallatin National Forest.

It’s time for the Custer Gallatin National Forest to recognize that it’s not the Nation’s wood box and that its most valuable features are clean water, outstanding scenery, exceptional wildlife habitat, intact functioning ecosystems, and some of the finest wildlands in the United States. The Bear Palmer, along with the Cooke City deforestation project, are both based on flawed justifications.

Ironically, although the claim that logging justifies the deforestation proposal will reduce wildfire threats, the opposite is true. Logging opens the forest to both drying and wind penetration. Wind is the primary factor in nearly all high-severity fires. And last time I looked, logging didn’t stop the wind.

Wind blows embers over, around, and through “thinned forests” and prescribed burns. Worse for taxpayers who subsidize this destruction, the probability that a fire or other “calamity” occurs is usually less than 1%, yet we have 100% certainty that deforestation will harm the forest ecosystem.

Rather than degrade the Greater Yellowstone Ecosystem, the Custer Gallatin National Forest must begin to preserve and protect our Nation’s finest natural heritage.

The public can submit comments on the proposed deforestation project before May 9, when the comment period closes.

One study concluded that, among wildfires that burned from 1990 to 2020 in the conterminous US, grassland and shrubland covered 64.0% of the area burned, whereas only 27.3% was forest.

From 1990 to 2020, wildfires in grasslands and shrublands burned 80 percent of the homes and structures lost to wildfire in the conterminous United States. To quote from the study: “We found that more houses are exposed to and destroyed by grassland and shrubland fires than by forest fires in the United States.”

Most community destruction is caused by wind-driven fires during extreme fire weather, exacerbated by climate change. The fastest-moving 3% of wind-driven fires account for 88% of the damage to homes.

While most wildfires in the West typically occur in the summer and fall months, in dry winters, the opportunity for grassland fires increases, as most grasses go dormant in the fall and dry out. If not covered by snow, they can carry wildfire, thus lengthening the burn season to nearly year-round.

The focus on forest thinning ignores that many of the most destructive wildfires — such as the January fires in the Los Angeles area — have burned in shrublands and grasslands, not forests, making thinning irrelevant in those cases.

Obviously, wildfire in non-forested areas poses a far greater threat to communities than forest blazes, yet the vast majority of funding is aimed at “fuel reductions” in forests.

I will discuss why we may see an emphasis on “treating forests” later, but there are several reasons why ignoring wildfire in non-forest areas may pose a greater threat to homes and communities.

The first is that grass and shrublands consist of “flashy” fuels. That is, they dry out faster than, say, branches or logs in a forested area. Due to the “flashy” nature of these grasses, they burn readily, especially if wind-driven.

The recent wind-driven Morrill Fire in Nebraska covered more than 70 miles in the first 12 hours. Trying to stop such blazes is impossible.

The second problem with non-forest ecosystems is that after a burn, grasslands/shrublands grow back rapidly. Grasses, in particular, can often regrow with higher fuel biomass than existed before a fire.

This is one reason why prescribed burns can sometimes exacerbate fire threat. Unless you repeatedly reburn grasslands (forever), fuel treatments can often make the area more susceptible to fires.

Third, one of the growing issues with grassland blazes, in particular, is the shift from native grasses to exotic annuals. For instance, across much of the Great Basin region, millions of acres have been converted from native perennial grasses and shrubs, such as sagebrush, to cheatgrass.

Cheatgrass greens up earlier than the native grasses, often using up scarce water resources before the native grasses “wake” from dormancy. They then dry out earlier, creating a highly flammable fuel bed. Unlike native perennial grasses, which require a fire-free period to recharge their stored carbohydrates (necessary for plant growth), cheatgrass sites can burn every year because the seeds are available to regrow.

A similar situation exists in California, where non-native wild oats have replaced native grasses over vast acreages.

Repeated burning, as with prescribed fires or “cultural burning,” can destroy native shrublands like chaparral and sagebrush, which, like perennial grasses, cannot readily recover from repeated burns.

Although the spread of exotic grass has many causes, one of the most significant is cattle grazing, particularly concerning cheatgrass. There are several ways that domestic livestock gives cheatgrass a competitive advantage over native perennials.

In general, cattle prefer to eat native perennial grasses, largely ignoring cheatgrass except for a short period in the spring when cheatgrass is green. As a result, the native grasses are repeatedly grazed and don’t have sufficient time to recover their stored energy from grazing events.

Secondly, across most of the arid, cryptogrammic crusts consisting of lichens, algae, and bacteria, the soil between grasses is covered. These crusts make it more difficult for grass seeds to sprout. Disturbance favors cheatgrass establishment. Cattle hooves destroy these crusts, making it easier for cheatgrass to reseed an area. As an annual, cheatgrass has to reseed itself frequently to maintain its presence on a site, while a perennial grass can go years between successful germination and remain on the site.

Third, as cheatgrass and wild oats burn year after year, they gradually kill off any shrubs that are growing on the same site. For instance, sagebrush has no adaptation to frequent fire, and if burned repeatedly, it will disappear from the area. The loss of sagebrush due to wildfires sustained by cheatgrass is a factor contributing to the decline of sage grouse.

Removal of domestic livestock from western rangelands would, over time, significantly reduce the spread of exotic grasses contributing to massive wildfires across the West.

Some livestock advocates suggest that “targeted” livestock grazing can reduce fuels and thus reduce wildfire spread. However, such proposals ignore the multiple and significant ecological impacts of livestock grazing.

First, targeted grazing can only affect small areas. By contrast, livestock grazing on public and private lands usually involves large cropped parcels.

Since all large wildfires are wind-driven events, no matter where and how much you graze, wind can easily blow embers over areas where grazing has reduced fuel. Indeed, one commonly cited paper that claimed to show how grazing could reduce wildfire (all by modeling—not actual on-the-ground evidence) concluded in its next-to-last paragraph that grazing did not work under extreme fire conditions.

Quoting from the paper:

“Targeted grazing treatment did influence fire behavior in grass/shrub communities, but its effects were limited. Although it is a promising tool for altering fire behavior, targeted grazing will be most effective in grass communities under moderate weather conditions.”

Some advocates for fuel breaks in grassland/shrublands. However, as with targeted grazing, such solutions are ineffective when high winds can blow embers miles and easily cross any fuel break.

One review of fuel breaks concluded that they (1) directly alter ecosystems, (2) create edges and edge effects, (3) serve as vectors for wildlife movement and plant invasions, (4) fragment otherwise contiguous sagebrush landscapes, and thus have questionable utility if all ecological impacts are considered.

This brings me back to why most funding is directed at “fuel reductions” (i.e., logging) in forests. There are several reasons, I suspect, that forests are featured in federal fuel reduction projects. The first is that, in most fuel treatments, some commercial logging occurs. This creates a financial motivation for the timber industry and its supporters to lobby for “thinning” projects.

The second reason is that Congress and state agencies are convinced that fuel treatments work to protect homes. While the evidence for this assumption is disputed, the public and many government representatives believe “fuel reductions” will save homes. Legislative “fixes” like the Fix Our Forests Act and others are doomed to failure because misguided assumptions sustain them. Under extreme wildfire conditions, thinning, prescribed burns, and other common “solutions” to wildfire are ineffective.

Meanwhile, the best solution to all wildfires, whether grasslands or forests, is home hardening. We can’t predict where a fire will occur, making most fuel reductions irrelevant even if they did work, while we know what we don’t want to burn. So, a focus on home hardening and fuel reductions in the immediate area around a house is the most effective strategy.

There is nothing in federal regulations that makes protecting cultural heritage a priority at the expense of the public’s ecological heritage. The memorandum affects 230 million acres of Bureau of Land Management and U.S. Forest Service lands—an area more than twice the size of California (CA is 103 million acres), making livestock grazing the single biggest commercial use of the public domain.

Given the vast acreage devoted to livestock production, it is by far the most destructive human activity on public lands. I use the term “livestock production” because the utilization of public lands by ranchers’ impacts more than just the cultivation of grasses. Producing domestic livestock results in the slaughter of native predators, competition for forage between native herbivores from prairie dogs to elk, social displacement of native animals by the mere presence of livestock, the pollution of water, the compaction of soil and loss of cryptogrammic soil crusts, the interference of animal migration by the presence of tens of thousands of miles of fences, the destruction of springs and loss of wetlands, the ruin of riparian areas (the green vegetation along streams) and the endangerment of many native species.

Even before this memorandum was created, public rangelands were in a disastrous condition. A 2024 analysis of agency records by Public Employees for Environmental Responsibility (PEER) found that more than 56 million acres of land assessed by the BLM failed to meet land health standards.

On at least 37 million acres, livestock is identified as the major cause of failure. BLM has found that overgrazing is by far the biggest cause of land health failure across the West.

The poor condition of public rangelands is due to the lack of environmental review and analysis. BLM has not completed land health assessments on more than 36 million acres.

The entire premise of this administrative mandate is to provide huge subsidies to commercial businesses (ranchers) who use public lands for private profit. Among the obnoxious proposals is a requirement that federal land managers participate in “immersion and training programs” so they understand the “daily life, decisions, and dilemmas of ranchers.”

A full accounting of both the economic and ecological impacts of livestock production would rationally lead to the conclusion that there is no place for commercial grazing on public lands. It’s important to note that ranchers have no “right” to graze public lands. A grazing permit is essentially a lease agreement and can be canceled at any time. And ranchers certainly have no right to degrade public resources for their private profit.

The ongoing degradation of public lands by commercial livestock production amounts to vandalism of our public patrimony.

Although it is doubtful that the Trump administration will put the public interest before commercial interests, a reasonable way to end public land grazing is the Voluntary Livestock Permit Retirement Act, which has been introduced into Congress numerous times. The Act would pay the fair market value of the AUMS voluntarily relinquished by a rancher and permanently close the allotment to future grazing.

In the meantime, the Trump administration appears set on sacrificing our public heritage to promote the economic well-being of the West’s Welfare Queens.

by George Wuerthner April 12, 2026

He was alone. He was unheeded, happy, and near to the wild heart of life. James Joyce

Now I see the secret of making the best persons. It is to grow in the open air, and to eat and sleep with the earth. Walt Whitman

Today, April 12^th, my son, Stratton Matteson, would have been 29 years old. He died February 24^th of this year in a massive avalanche while backcountry snowboarding near Joffree Peak Provincial Park in Southwest British Columbia.

The day he died was perfect, as close to heaven as it could be. He woke up to a golden sunrise on the peaks. He and his buddy dug a pit to examine the snow conditions and concluded it was safe to snowboard. He paused near the summit to photograph the surrounding mountains that disappeared into the distance. He did a near-perfect run down the slope and radioed to his partner to come on down.

His friend took a couple of turns, and the entire mountainside gave way, and the snow came down on Stratton. He was recording the run on his phone. The phone was damaged in the snowslide, but technicians were able to download the contents.

What we saw in those last moments were dozens of photos he took, from the top of the ridge, mountain upon mountain in every direction. Deep blue sky. And a perfect sheet of snow below. He was no doubt jubilant.

Some people dream about going to heaven after they die. But for Stratton, every day he was alive, he was in heaven. He always raved about the beauty of the mountains. He always mentioned how grateful he was to be able to watch sunsets or sunrises in wild places.

Backcountry snowboarding for him wasn’t just about getting a quick jolt of adrenaline. It was his way of feeling fully alive. It was about grace and love. And grace does not come easy.

Every climb up a mountain was a commitment, and every descent was a dance with the mountain—a chance to feel completely in the moment.

After one of his numerous trips, he would call me on his way home to tell me about the beauty of the place. The giant red fir trees he might hike through on the way up. The way the sun shone on the peaks or the infinite stars at night. He was always grateful to have had another trip in the mountains.

Stratton’s mother and I took him on his first backpack trip in the mountains of Olympic National Park when he was about two weeks old. From that day forward, we continuously made trips into wildlands across the country. Canoeing lakes in the Adirondacks, x-c skiing in Yellowstone, backpacking into the Grand Canyon, hiking trails in Yosemite, hiking on glaciers in the Canadian Rockies, and pack rafting rivers in Alaska’s Arctic, and many more adventures. During his life, he had visited and experienced hundreds of parks and wildlands across the continent.

He started snowboarding when he was nine after we moved to Vermont. At first, like for many people, snowboarding was about speed, sense of competency, and skill.

By the time he was in his twenties, he began to realize that human impacts were changing the planet’s climate. At some point, he decided to use his bike as his main mode of transportation, for everything from going to the local grocery store to pedaling to trailheads with all his camping and snowboarding gear.

From a base in Bend, Oregon, he would ride his bike 40–100 miles one-way to a starting point, then hike or ski to the slopes of the high, glaciated peaks visible from town. Seeing him peddling up a road in a blizzard, with a bike loaded down with all his gear, was a common feature in Central Oregon.

Self-propelling himself to the trailheads made him feel more connected to the land, and reducing his own carbon footprint. He once rode from the Sierra Nevada of California to the Canadian border, climbing most of the higher peaks along the way to snowboard from their summits.

From the very beginning of his life, he was immersed and nurtured by wildlands. It was a place where he felt the joy of life. His last year of life, he spent more than 230 nights out sleeping among the peaks.

He was also gradually shifting his values toward a concern for more than his own recreational pursuits. Perhaps initially, he climbed peaks to get a good ride down the mountain. But in the last few years, he began to appreciate that these wildlands were essential to his being and other life on the planet. He treated each of his trips to a summit as a pilgrimage to a sacred temple. Hiking or snowboarding in wild places made him feel he was part of a greater design.

Just before he left Bend on his last big adventure, he sent me a proposal that he hoped to find funding to create videos promoting the need for more protection of parks and wilderness areas. He felt he needed to give something back to the planet and wanted to work towards preserving the beautiful wild landscapes that fed his soul.

His lifelong immersion in wildlands affected his personality. He had an aura of joy and playfulness about him. He looked people straight in the eye because he was totally aware and confident about his place in life.

He made a transition in values and purpose, seeing beyond our own interests and feeling part of a greater whole. And as long as we protect and preserve such places, there is hope that anyone can come to similar realizations.

Not everyone will find heaven on Earth in the wild as he did. But I feel we must provide such places. He recognized that parks and wilderness are essential for maintaining ecosystems and wildlife. But he also knew from firsthand experience that immersion in such places can lead to contentment and joy.

He died way too young, but he learned something in his years that most people never realize—how to live a life on one’s own terms and fully engaged in the dance of life.

In a recent article, “How Protecting Wilderness Could Mean Purposefully Tending It, Not Leaving It Alone,” one of many such arguments asserts that humans can’t just leave Nature alone. In this piece, like many recent pieces from the humanities disciplines like history, anthropology, political science, Native American Studies, and the media, the author argues that “many wilderness areas were and remain part of the ancestral homelands of Indigenous peoples, who, in fact, tended those lands for thousands of years.” Such statements imply that Nature can’t survive without human manipulation and management.

While most conservation organizations are willing to oppose, or at least criticize, industry propaganda promoting the management of natural landscapes, there is a growing tendency to make exceptions for any manipulation advocated by tribal people. This has the potential to undermine the very philosophical basis of parks, wilderness, and other preserves where human influence is minimized.

This attitude has led to a surprising convergence of policy between the timber industry, conservation organizations, and tribal advocates to justify “thinning” and “cultural burning” in dry forests like ponderosa pine, arguing that tribal burning kept the forest “healthy.” Never mind that ponderosa pine existed for 55–60 million years as a separate species and somehow managed to survive quite well all those millennia before any humans arrived in North America to keep them healthy.

The notion that Nature can’t survive without human manipulation, or that it will descend into chaos and destruction, is a widespread feature of our society.

This is not to suggest that places like wilderness areas or national parks were free of human manipulation in the past, from human influences, including burning, hunting, and plant collection, all of which affected natural processes and features, all designed to further human survival rather than promote ecosystem health. And certainly, that doesn’t mean Nature “needs” human manipulation. To me, that is a highly arrogant perspective that “humans know best.”

From my perspective, I have seen a gradual erosion of this precautionary principle. Increasingly, various groups from the left to the right argue that humans can and should control the Earth. From timber industry advocates who claim that logging will “fix” the forests and “restore forest health” with chainsaw medicine, or ranching advocates who suggest rangelands need to be grazed to be “restored,” and similar arguments.

At the same time, some in the progressive political perspective argue that human technology and intelligence can lead to a more equitable use of resources. But whether part of the industrial pro-development or the “Abundance Movement,” both see few reasons to limit human modification of the Earth for presumed human benefits.

In my books Keeping the Wild: Against the Domestication of Earth and Protecting the Wild Parks and Wilderness: The Foundation For Conservation, I tried to address these concerns. At the time, for lack of a better term, this worldview was Anthropocentric. Since their publication, the trend towards promotion of human intervention in wildlands to “save” them has grown.

What these ideas have in common is that Nature is improved when it serves human desires and wants.

Furthermore, the basic premise of the Anthrocentric advocates is generally recognized that humans can improve upon Nature. Whether explicit or implied, the overall message is that wild Nature is a mess, and humans can fix it.

In contrast, the biocentric perspective puts humans on a more equal basis with other life. It cautions us against rearranging the planet to meet human wants. Some exploitation of the planet is necessary for the survival of any species, including humans. However, now that we and our domestic livestock impact a large percentage of the Earth’s surface, isn’t it reasonable to preserve at least half of the planet for the rest of life?

A biocentric perspective values self-willed land or lands primarily influenced by non-human processes that have driven evolution for millions of years.

Anthropocentric advocates assert that there is nothing natural because humans have modified the planet, or that, since humans are part of Nature, everything humans do is natural.

Notwithstanding that human impacts are almost universal (climate change, for instance), the degree to which large parts of the planet are “SIGNIFICANTLY” altered by human activity is exaggerated. According to some definitions, as much as 95% of the Earth’s surface has been modified by humans. Other studies, using different sets of metrics, suggest that 14.6%of the planet’s land area—has been modified by humans.

Whatever the real number, as we continue to impact natural areas, it becomes even more imperative to protect what we have left. What I mean by protection is limiting human impacts.

The argument that nothing is “natural” or “pristine” is a straw man because it ignores that there are degrees of modification. The Central Valley of California is a vast agricultural region. It is a domesticated landscape with natural processes shredded and tattered.

But the Coast-Klamath Mountains and Sierra Nevada mountains that frame the valley are far more influenced by natural ecological and geological processes than the highly modified Ag lands. They do have roads. There is some logging. There is livestock grazing. However, they are far more “natural” than the alfalfa, rice, and cotton fields that dominate California Ag lands.

A further problem with the Anthropocentric booster perspective that Nature needs human manipulation and “management” is that it undercuts the moral and environmental justification for preserving wild Nature. We need more national parks, wilderness areas, and other preserves that minimize human interference.

Social justice is a worthy goal, but we must remember there is no social justice on a dead planet.

In recent years, some social justice organizations and academics in the humanities (and many conservation groups with them) have been promoting tribal people as “caretakers” of the planet. The basic premise is that collectively, tribal groups lived in “harmony” with the planet.

Thus, if society were to incorporate “Traditional Ecological Knowledge,” human degradation of the planet would be reversed. A recent piece in the Guardian newspaper, “Braiding knowledge: how Indigenous expertise and western science are converging,” celebrates what it suggests are new insights into how humans “help” Nature. The article begins by explaining how rock walls built by tribal people in the Pacific Northwest increased clam production.

However, few advocates of TEK appear to be aware that this is just another version of the Anthropocentric perspective. It’s all about “me,” i.e., humans. It usually involves, as the clam example above does, providing more resources for humans. It’s not usually about what is beneficial for the planet, ecosystem function, other species, or evolutionary function.

More clam production may be good for humans who want to consume clams, but do clams need tribal manipulation of the ocean to survive? The widespread occurrence of clams in numerous locations without tribal “help” would suggest otherwise.

Traditional Ecological Knowledge is touted as just another “science” equal to Western scientific approaches, hence the inclusion of “ecological”. Suggesting that TEK is analogous to physics, higher mathematics, and careful experimental design is an attempt to elevate Indian knowledge (which may be useful to local people) to an equal status with the scientific method, and it is absurd.

Burning the forest to increase huckleberries or to attract elk to new grass growth isn’t really anything an observant outdoors person knows about natural history. And such activities are about “gardening” the forest, or domesticating the land to benefit humans.

Usually, what is perceived as humans living in harmony is due to a low population with limited technology. The same limited impacts ascribed to North American Indians (or other people like Australian Aboriginals) were characteristic of all humans living at low population levels with limited technologies, including the ancestors of Europeans, Asians, and Africans.

Change those parameters, and we often see an increase in exploitation. The invention of the bow and arrow increased the efficiency of Indian hunting. The adoption of the horse after the 1600s further increased tribal people’s ability to find and kill bison, leading to their extirpation across much of the western US before large-scale commercial hunting that began in the 1870s.

In terms of the conservation movement, while many in these organizations can see through the presumed self-justifications for logging the forests to “fix them” or grazing rangelands to “improve carbon storage” as self-promoting, spurious claims by industry, yet the same organizations will champion essentially the same human manipulation if a tribal member endorses the activity.

Yet, there are numerous examples of tribal people, at least in North America, who have adopted the same technologies and human-first attitudes and now are equally destructive towards natural ecosystems as any other group.

The degree to which tribal people advocate for ecological or environmental protections appears to depend on whether they have a vested financial, political, or other self-interest. When Alaskan Athabaskan Indians oppose drilling along the Arctic Coast because it might impact caribou migrations, which they wish to kill, it is obviously self-interest, not because caribou have some greater ecological function in the Arctic Ecosystem that should be preserved.

By contrast, the Inupiats (Eskimo) people living along the Arctic coast, where caribou calves, are generally supportive of oil drilling because they receive royalties, jobs, and other financial benefits from oil development.

The adage “Follow the Money” applies equally well to tribal people as it does to the larger society.

The main point is that people tend to put their own interests ahead of those of other species and planetary health. This tendency is built into our evolutionary survival.

The promotion of Tribal exploitation of natural landscapes is a dangerous Trojan horse that justifies human manipulation of the land (and waters).

But no matter who advocates these ideas, you can trace nearly all of them back to a central concern for humans, or the Anthropocentric perspective. For instance, Robin Wall Kimmerer, author of Braiding Sweetgrass, promotes the native harvest of sweetgrass because it appears to increase the plant’s productivity, as if the plant must be grateful that humans are there to promote its abundance.

Recently, Acadia National Park in Maine permitted local tribal people to harvest sweetgrass in the park, as if there were no other locations (including on their own reservations) where sweetgrass could be obtained.

Similarly, there is almost no criticism by most conservation organizations of the ongoing slaughter of bison by native hunters on the border of Yellowstone National Park. Indeed, numerous conservation organizations that claim to advocate for the ecological integrity of the Greater Yellowstone Ecosystem actively support unrestricted tribal hunting. The National Park Service even justifies tribal hunting to preserve “cultural” traditions and essentially says Yellowstone Park should be like a hatchery producing animals for humans to kill. Few organizations are willing to question why human culture should have precedence over ecological values, especially in a national park.

Hunting by humans removes food resources for predators and scavengers. Reduction in bison herbivory can affect the Park’s vegetative community. And since human hunters do not select the same animals as native predators, it changes the age structure and other demographic features of the bison population. Hunting may even be affecting bison genetics by removing the animals most inclined to migrate. Migration has been one of the singular features of bison over the millennia, helping them cope with drought, harsh winters, wildfires, and predators.

While national parks, under some circumstances, do allow human exploitation of plants and animals (e.g., sport fishing and hunting in Alaskan parks and preserves), the general philosophy of the National Park Service is to minimize human exploitation.

There is a good reason for such a policy. We cannot determine how human exploitation affects plants, animals, and ecosystem function without controls. It is the first rule of what is sometimes derisively called “western science” or “colonial science” that one must have an unmanipulated comparison.

It surprises me that opponents of the Forest Service logging and burning programs will make exceptions for Indian “cultural” burning, as if changing the source of the ignition somehow makes it acceptable. Many scientific studies have demonstrated that tribal cultural burns were localized and had insignificant landscape-scale ecosystem effects.

This is not to suggest that tribal people (and we were all tribal at some point in the past) didn’t, and couldn’t, exert a significant impact on natural systems. The extinction of numerous bird species on islands, or the extirpation across much of the West of abundant species like American bison by tribal hunting in the earlier part of the 1800s, before the commercial bison slaughter of the 1870s, are examples.

In the past, we did so with sacred chants, sacrifices, and dances designed to appease the gods and bring good fortune to our human efforts, whether to beat the enemy in battle, direct the buffalo to visit the hunters, or end a drought threatening crops. Religion may comfort humans, but it doesn’t necessarily lead to any better outcomes for natural systems.

Preserving large tracts of land without human manipulation or exploitation, and without colonization by any people, is essential for protecting ecosystem function and evolutionary processes, and for creating space for the rest of life we share the planet with. Nature doesn’t need humans to be healthy or any other human value.

Nature needs to be left alone to continue the evolutionary process that has occurred for millions of years. The only protection Nature needs are from persistent human manipulation.

In 2001, the Forest Service passed the Roadless Rule Conservation Act. The Trump administration is seeking to rescind the Act. During a brief public comment period, 99% of the respondents opposed the idea.

The Roadless Rule affected 58.5 million acres of Forest Service roadless lands and put them off-limits to new road construction, logging, and road reconstruction. As the Forest Service recognized in its original review, these roadless lands “have the greatest likelihood of altering and fragmenting landscapes, resulting in immediate, long-term loss of roadless area values and characteristics.”

Abolishing protection from logging and roading provided by the Roadless Rules has major economic consequences, both in direct costs and in avoided costs.

For instance, a practical rationale for the rule is the Forest Service’s acknowledgment that the roughly 370,000 miles of existing Forest Service road network could not be maintained. There is already an $ 11 billion backlog in road maintenance, and creating even more roads would exacerbate this situation.

For instance, nearly 85 percent of the wildfires that start on National Forest land are human-caused. We spend 2.5 billion fighting these fires, and new logging and roading will only increase firefighting costs. A new study found that from 1992 to 2024, wildfires were 4 times more likely to ignite within 50 meters of a road than in a forest without motorized roads. Thus, preserving roadless lands will reduce the likelihood of wildfire.

There are other ecological and economic reasons for preserving the Roadless Rule. Some of the highest quality water is found in roadless areas. Many western cities obtain their drinking water from Forest Service roadless areas and require less treatment than water from other sources.

That same high-quality water supports important fisheries, from salmon to trout, that anglers seek, and provides important food for other wildlife, from bald eagles to river otters. Approximately 70 percent of all roadless areas support native trout and salmon, with 92% of all species at some risk. This includes the “Blue Ribbon” trout streams found in Montana, Idaho, Wyoming, and Colorado, all of which flow from roadless areas. In SE Alaska, nearly all salmon production occurs in Forest Service roadless lands.

Roadless lands are critical for sustaining populations of elk and deer, important to hunters, and essential as prey for predators like mountain lions and wolves. For example, in Idaho, 98% of elk use roadless lands at some point.

Roadless lands are also a major repository of carbon. Carbon emissions are driving climate warming. Just their carbon storage value alone exceeds any economic return from logging.

The idea promoted by the Trump administration that logging our roadless lands can decrease wildfires ignores studies showing that intact forest ecosystems are less likely to burn and burn at lower severity than “managed” forests.

Finally, intact roadless lands are essential for preserving biodiversity, which is the foundation for ecosystem function and stability. Estimates suggest that 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas.

When all these opportunity costs, as well as actual economic and ecological costs, are considered, any rational person would keep the existing 2001 Roadless Rule Conservation Act intact. Let’s hope a few rational people are working in the current administration.

Passage of legislation like the Northern Rockies Ecosystem Protection Act (NREPA) would permanently protect nearly all the roadless lands in the region.

Yet there are numerous problems with such studies and including interpretation of the ecological role of fire in plant communities.

Perhaps the biggest problem is that most wildfires are small and inconsequential from a landscape scale perspective. In other words, they do not significantly influence the vegetation over large areas.

Because the vast majority (perhaps as much as 99%) of all wildfires burn a very small area, typically a few acres or less, their ecological influence is typically insignificant.

For instance, from 1970 to 2002 on U.S. Forest Service lands, firefighters successfully extinguished 97 to 99 percent of all wildfires on Forest Service lands while they were still small (<300 acres). The reason? Without severe fire weather, most fires are relatively easy to extinguish or will self-extinguish even without any fire suppression action.Very large fires are infrequent. For example, , 1.1 percent of all fires in this period burned 97.5 percent of total area.

In the first 16 years of Yellowstone’s natural fire policy (1972 to 1987), 235 were permitted to burn and only 15 of those fires were larger than 100 acres, and all of the fires were extinguished naturally.

Yet in 1988, one of the worse drought years on record with a number of days with 50 mph winds, more than a half million acres were charred in the park. Was there suddenly more fuel in 1988 than 1987 or 1986? Climate/weather is clearly the major influence on acreage burned.

Nearly all fire history studies are done by counting fire scars in representative trees. Yet proponents seldom acknowledged that fire scars studies are prone to exaggeration. What fire scar studies document is the number of fires. But the number of fires is less important than the geographical extent of any individual fire.

It is like suggesting that someone who has 100-dollar bills has more cash than someone with a single $10,000 dollar bill. If you equate the number of blazes with ecological significance without accounting for the geographical influence of the fires, you can easily exaggerate the importance of small blazes.

One large 100,000 acre blaze has more ecological influence on the landscape than a hundred small 1-5 acre blazes.

Why is this important?

In 2023, a heavy snow year in the Cascade Range, wildfires burned just 44 acres of the 1.6 million acre Deschutes National Forest. However, of these ignitions, firefighters determined 81 fires to be caused by humans or an undetermined cause, with 30 started by lightning.

The above statistics support several contentions about wildfires. Historically, most blazes remain small due to climate conditions, not because of fuel. Fires were infrequent and tended to occur as larger higher severity blazes.

Most plant communities of the West typically experience long fire rotations of many decades to hundreds of years without any large landscape scale blazes. This includes spruce-fir, lodgepole pine, juniper-pinyon, sagebrush, chaparral, aspen, west-side Douglas fir, and many other plant groups.

When the right combination of drought, high temperatures, low humidity and most importantly, high winds occur in the same place as an ignition source, you get uncontrollable and large blazes.

Among the problems associated with fire scar use is that many studies tree selection processes are non-random. Trees are selected based on the presence of a fire scar.

However, the occurrence of a few scared trees may not represent the fire occurrence across a large area. A single tree may be hit by lightning and that tree would be included in the overall fire statistics for an area.

A second major problem is that most fire scars use what is termed “composite fire scars” where all scars in any particular year are added to the overall whole for the study area. This can do is significantly reduce the fire intervals.

For instance, if in some hypothetical study, there was at least one scarred tree found every ten years, the “average” fire interval would be ten years (based on a hundred-year period), even if most of those representative trees were the only scarred individual in that particular year.

The third problem with most fire scars studies is that they do not present the geographical extent of a fire. Since most fires are small and seldom burn more than a few acres, extrapolation to entire landscapes based on the limited sample of fire scarred individuals exaggerates the influence of wildfire.

Other methods of determining fire history such as government land office surveys, sediment flow studies, pollen and charcoal studies, among other techniques tend to record only the larger fires. And these are the only fires that have a significant ecological influence.

Since the conditions that are favorable for such blazes are infrequent, most of these studies tend to record fire intervals that are much longer between major conflagrations.

Firefighting and any previously executed “fuel reduction” (a euphemism for logging in many instances) cannot effectively halt wind-driven fire spread. Thus the proposed “solutions” to wildfire threat including prescribed burning and logging are overwhelmed by wind-driven blazes which can push embers through, over, and around any “fuel reduction”.

However, such extreme “red flag” weather conditions are infrequent in any location, although across the West due to climate change (a hoax according to the expert in the Whitehouse) we are seeing such conditions more frequently than the recent past.

For instance, a new study, concludes that extreme fire weather (hot, dry, and windy conditions) has intensified globally. The authors summarize that the observed increase in extreme fire weather bears a clear externally forced signal, detectable at 99% confidence above natural variability and attributable to human-induced climate change.

Using fire scar studies to promote forest management is clearly of dubious accuracy and creates numerous exaggerated conclusions about wildfire. While such strategies like fuel reductions might slow or halt fires under low to moderate fire weather conditions, such blazes are typically easy to suppress. It is fires burning under extreme weather conditions that seldom respond to such treatments.

As a recent study concluded after reviewing the Labor Day fires of 2022 that charred many Oregon Cascade forest stands “were fundamentally a weather-driven event. The influence of forest management on fire severity was minimal and variation in forest structure or fuels played relatively little role. These results provide little evidence to support the use of fuel treatments to mitigate fire severity under extreme fire weather conditions on the westside.”

It’s understandable that people want to preclude large blazes that might threatened their homes or communities, but the question remains whether logging/thinning/prescribed burn fuel reductions are the most effective and efficient way to accomplish these goals.

Many authorities believe home-hardening is the best way to protect structures both from a cost-effective as well as an ecological perspective (most forest manipulation has numerous negative ecosystem impacts). As one study concluded, the “best way to make existing wildfire-vulnerable development ignition resistant to work within the limited area of the home ignition zone——–a home and its surroundings within 100 feet.”