— Forest Service prescribed burns resulted in a total of 387,000 acres of the Santa Fe National Forest burning last year, in three separate wildfires. In the past decade, less than 57,000 acres burned due to all other causes, including all other human-caused fires.

— Prescribed burns are risky, and the Forest Service hasn’t adequately addressed the issues specific to the Santa Fe National Forest. The agency is endangering our forest and communities by going forward with prescribed burns, without developing new strategies to avoid prescribed burn escapes in a warming climate. 

— The Forest Service does not have the agency capacity to increase prescribed burns as much as they intend to. They plan to increase fuels up treatments to 4X current levels.

— Elected representatives should instigate and oversee an investigation of the three 2022 wildfires caused by escaped prescribed burns.

– A risk/benefit analysis should be done, to determine if the benefits of widespread and aggressive tree cutting and prescribed burning outweigh the risks and costs. If they do, under which circumstances?

— The amount of smoke from so many prescribed burns is creating very poor air quality at times, which is associated with serious health impacts for vulnerable populations. Such impacts include increased asthma, COPD, vascular and heart disease, immune system disorders and cognitive disorders. The Forest Service must do a Health Impact Assessment, or an equivalent, of the real-world effects on public health of the smoke they generate.

— Aggressive thinning operations, such as in the Santa Fe Mountains Project plan, dries out the soil and vegetation, because the forest floor is no longer adequately shaded. Such operations also compact and damage soils, and introduce flammable weeds. Any thinning should be targeted, light-handed, and maintain a substantial forest canopy and relatively natural and abundant native understory.

— There are ways to keep the forest cooler and wetter, which would make trees and forest more fire resistant and improve ecological function. They include protecting soils and mycorrhizal fungi from intense heat from pile burns, creating berms and dams to hold water into the forest, fencing out cows, planting native vegetation in riparian areas where needed, promoting beaver habitation, and decommissioning forest roads, which can cause water run-off and erosion.

—  Fuel treatments do not reduce the occurrence of high severity fire in a changing climate with extreme fire weather overriding on-the-ground treatments. 

— When the tree canopy is opened up by aggressive thinning and frequent prescribed burns, wind can penetrate stands and carry fire into tree crowns.

— Fire is a natural part of the ecosystem, so the focus should be on protecting homes by fireproofing structures and the surrounding 100+ feet of landscape, instead of treating forest in the backcountry.

— Allowing natural wildfires to burn for ecosystem benefit, when safe to do so, allows fire to maintain its natural role in our forests. It is a cost effective way to reduce fuels over large areas and to help maintain biodiversity.

— Prescribed burns should be much less frequent than the Forest Service is planning, so the understory can fully regenerate between burns.    

— Prescribed burns should not be implemented in the spring due to the unpredictable spring winds in the Santa Fe National Forest. They should only be carried out in the fall and winter.    

— There are currently many unburned slash piles in the Santa Fe National Forest, creating a fire hazard. These need to be addressed, preferably by chipping or lop and scatter, before cutting any more trees.

— The Forest Service must withdraw the Santa Fe Mountains Landscape Resiliency Project Final Decision and complete an environmental impact statement for the project. It should include a conservation alternative that is developed with substantial input from conservation scientists, conservation organizations and the local community, and provide alternatives to aggressive thinning and burning.