The analysis represented in the Final EIS was focused on the following significant issues:
Human Health and Safety: Because fire retardant contains numerous chemicals, there is concern by some as to their safety to humans. In addition, firefighting is an inherently risky activity and it is important to manage that risk and keep firefighter and public safety as the highest priority.
Water Quality: In certain rare situations, when fire retardant comes in contact with water, the fire retardant chemicals can temporarily alter the water quality and may be toxic to aquatic organisms. Fire retardant could reach water through misapplication or through leaching and erosion, although studies show no measurable increase in soluble nitrogen forms and phosphorus levels (Final EIS, section 3.3.3, page 83).
Impacts on Threatened and Endangered Species: The previous Biological Opinions and environmental analysis conducted for the aerial delivery of fire retardant included reasonable and prudent alternatives. However, the District Court determined that the measures did not adequately address the possible effects on these species and that the effects to some ESA-listed terrestrial wildlife and plant species were not adequately addressed.
Impacts on Cultural Resources: Petroglyphs, historic structures, traditional Native American gathering areas, and sacred sites may be affected by the aerial application of fire retardant.
In addition to the decision criteria listed earlier, I also considered how well each alternative responded to these issues. Based on the analysis in the Final EIS and summarized in Table 1, below, I find that the Selected Alternative responds best to these issues. Water quality will be maintained through observation of aquatic avoidance areas and monitoring. It is estimated that less than one-half of 1 percent of fire retardant drops may reach the 300-foot or larger buffer (Final EIS, section 3.4.2, page 102). Impacts due to the exceptions, or from misapplication of fire retardant into water, would be rare. The human health effects of retardant use are likely to be minimal (Final EIS, section 3.8.2, page 154). The Selected Alternative best responds to the issue of impacts to threatened and endangered species by mapping avoidance areas, providing for additional monitoring and consultation, and tightening the exceptions that allow the application of aerially delivered fire retardant into avoidance areas. The Selected Alternative best responds to the issue of impacts on cultural resources by providing national direction for the protection of important heritage, cultural, and tribal resources and sacred sites.
Alternative Comparison Table
The following two tables compare the different components for each alternative and how each alternative responds to public issues.
More species protected by additional avoidance area mapping and additional monitoring requirements.
Could have positive or negative effects on species or habitats due to the increased potential for smaller fires to become larger fires or increases in ground suppression actions.
More use of water suppression activities that may impact federally listed aquatic species or habitats.
For ESA plant species: 64 no effect, 105 likely to be adversely affected.
For designated critical habitats for plants: 9 likely to be adversely affected, 14 not likely to be adversely affected, 1 no effect.
For ESA plant species: 64 no effect, 49 likely to be adversely affected, 56 not likely to be adversely affected.
For designated critical plant habitats: 23 not likely to be adversely affected, 1 no effect.
Potential for more disturbances to occur to wildlife species under this alternative than under Alternatives 2 and 3 due to potential for more aerial use of water.
For ESA wildlife species: 43 no effect, 63 likely to be adversely affected, including 28 critical habitats.
For ESA wildlife species: 43 no effect, 13 likely to be adversely affected, 50 not likely to be adversely affected.
For wildlife designated critical habitats: 22 no effect and 6 likely to be adversely affected.
For ESA aquatic species: 21 no effect, 18 not likely to be adversely affected, 118 likely to be adversely affected.
For designated critical habitat aquatic species: 10 no effect, 15 not likely to be adversely affected, 72 likely to be adversely affected.
For ESA aquatic species: 21 no effect, 18 not likely to be adversely affected, 118 likely to be adversely affected.
For designated critical habitat aquatic species: 10 no effect, 15 not likely to be adversely affected, 72 likely to be adversely affected.
