By: Roger Twitchel, NEPA Compliance Officer, DOE Idaho Operations Office
NEPA can help DOE not only to make decisions about new projects but also examine ongoing activities and plan ways to reduce adverse environmental impacts. DOE’s Idaho Operations Office successfully used the NEPA process to evaluate trade-offs among alternatives and determine the best way to preserve the natural sagebrush steppe ecosystem at the Idaho National Engineering and Environmental Laboratory (INEEL). INEEL contains the largest remnant of undeveloped, ungrazed sagebrush steppe remaining in the Intermountain West. Current rangeland management practice in combination with an altered wildfire process threatens to irreversibly convert what remains of the sagebrush steppe ecosystem into a landscape dominated by non-native cheatgrass.
Wildfire in the Sagebrush Steppe
Fire is a natural component of the sagebrush steppe ecosystem, typically occurring on a 40- to 70-year cycle. The natural ecosystem consists of shrubs – most notably sagebrush, an abundance of perennial grasses, and annual grasses and broadleaf herbaceous plants. When this native vegetation burns, grasses and herbaceous plants survive (perennials re-sprout from underground stems and roots, annual grasses from seed) but the sagebrush is killed. Sagebrush will recolonize only as wind-dispersed seed from unburned areas. Once established, it will take about five years to mature and will compete with the other native plants until a natural balance is reached.
The introduction of non-native annual plants, particularly cheatgrass, alters the natural fire and recovery cycle. After a fire, cheatgrass seeds quickly germinate, and the plants successfully compete for moisture and nutrients with native seedlings and surviving plants. It grows rapidly during cool, wet springs, goes to seed, and then becomes parched during the extended dry periods in late spring and early summer. Cheatgrass can quickly form a nearly continuous carpet of fuel that is extremely prone to burn. The frequency of fire increases, cheatgrass continues to increase, and sagebrush eventually disappears from the plant community.
EA Addresses Fire Management
The Idaho Office decided to prepare an EA to address concerns that the traditional fire management strategy at INEEL – which focused solely on extinguishing fires – was adversely impacting natural resources by destroying habitat for species dependent on sagebrush, affecting cultural resources, and creating massive dust storms after a fire. Of particular concern were impacts on the eastern subspecies of the greater sage grouse, a bird that inhabits the INEEL site. The Institute for Wildlife Protection petitioned the U.S. Fish and Wildlife Service (FWS) in July 2002 to list the eastern subspecies as endangered. (To date there have been seven petitions to the FWS to list the sage grouse or one of its subspecies.)
The INEEL Wildland Fire Management Environmental Assessment (DOE/EA-1372, April 2003) was not associated with any project, and there was no budget set aside to prepare it. The Idaho Office’s management and operating contractor made the EA a reality by juggling other activities to ensure its completion.
The EA evaluated four alternatives for managing wildfires at INEEL, each of which included options for pre-fire, fire suppression, and post-fire activities:
- Maximum Fire Protection Alternative – implement the full range of pre-fire, fire suppression, and postfire activities. It would focus on creating firebreaks and aggressively fighting all fires.
- Balanced Fire Protection Approach – use minimum impact suppression tactics (e.g., allowing fires to burn to a natural barrier, placing containment lines to minimize impacts on significant environmental resources, minimizing soil disturbance) in order to suppress wildfires with the least impact on the land. It would minimize fuel loading and fire potential by developing a program for long-term management of native vegetation.
- Protect Infrastructure and Personnel Safety – include only those activities necessary to protect primary INEEL facilities. It would include pre-fire activities needed to provide safe spaces for firefighters within the site.
- No Action Alternative – continue traditional pre-fire, fire suppression, and post-fire activities, including fighting fires aggressively. This alternative differs from the Maximum Fire Protection Approach in that it prescribes significantly fewer pre-suppression activities, such as the creation of defensible space and fuel management zones, and no post-fire activities except for dust control.
Interagency Consultations Protect Natural Resources, Enhance Safety and Planning
DOE could not have reasonably assessed these alternatives without examining the general condition of sagebrush steppe in Idaho and the wildfire strategies of other area agencies. Thus, the Idaho Office contacted other organizations with interests in and knowledge of the natural resources on the site: Idaho Department of Fish and Game, Shoshone-Bannock Tribes, FWS, and the Bureau of Land Management (BLM). BLM, in particular, was interested because it was beginning an EIS and Plan Amendment for Fire, Fuels, and Related Vegetation Management Direction on wildfire management in the Upper Snake River District in southeast Idaho.
At the end of the interagency consultation process, everyone was more aware of the long-term impacts and the concerns of competing interests.
The organizations shared information about existing ecosystem conditions and determined information needed to aid in successful restoration of burned areas. In addition to useful suggestions for the EA, the consultation process has enhanced safety for all fire crews deployed at INEEL because DOE and BLM have coordinated their fire suppression and control tactics.
The EA provided a qualitative assessment and comparison of the potential impact of each alternative on air, water, wildlife, wildlife habitat, and cultural resources. Based on this analysis, the Idaho Office determined that the Balanced Fire Protection Approach will best protect natural resources. Implementing this alternative will, for example, conserve habitat critical to sagebrush-dependent species, such as the greater sage grouse. The other interested agencies agreed that this alternative was the best strategy for managing wildfires at INEEL. DOE determined that the selected alternative would not have, and in fact, likely would prevent, a significant impact on the human environment.
The NEPA process helped DOE’s Idaho Office plan wildfire management actions to minimize their potentially significant environmental impacts on the site’s natural resources. This was an innovative, cooperative approach to using NEPA to improve environmental protection, safety, and site-wide planning.