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Photo of fuels conditions at Redwood Meadow Grove, showing large amounts of ladder fuelds that would easily carry flames into the foliage of more mature trees, including sequoias. NPS photo.

Decision and Other Compliance Documents


The actions outlined in the attached Decision Memornadum combine to form one emergency action that is implemented in accordance with 43 CFR 46.150 and 516 DM 2.8 in that it is necessary to mitigate harm to eleven sequoia groves and the natural and cultural resources therein as well as associated threats to life and property from high severity, catastrophic fire. Although the NPS is concurrently taking steps to initiate planning and environmental compliance on a Sequoia and Kings Canyon National Parks Fire and Fuels Management Plan, the nature and scope of actions related to this emergency are needed imminently and prior to the National Park Service's ability to complete a National Environmental Policy Act (NEPA) process for actions within these eleven groves. This decision memorandum documents the alternative arrangements for NEPA compliance pursuant to 43 CFR 46.150(c) in consultation and agreement with the Office of Environmental Policy and Compliance.

The emergency action is appropriate in this situation because without human intervention, eleven groves in the Parks—equating to 9% of all sequoia acreage and 14% of all sequoia groves in the world—and the natural and cultural resources therein, could be largely or entirely lost to high severity fire—whenever it may hit—given the high level of fuels within these eleven groves and surrounding forests (due in large to past agency fire suppression around these groves) and documented increases in the length of fire seasons, wildfire sizes, and fire intensity in the Sierra Nevada and the State of California in recent years (which increases the exposure time of these groves to wildfire). Already, an estimated 13-19% of all sequoias range-wide—a fundamental resource and value to Sequoia and Kings Canyon National Parks—are dead or dying from fire in the last 24 months alone, and this action would provide protection for 9% of all sequoia acres in the world. Given that wildfire could strike these groves at any time, expedient actions are required to reduce fuel loading and thereby minimize the potential for high intensity fire and anticipated subsequent, and potentially permanent, loss of these ancient groves and the other natural and cultural resources therein.

This emergency action is also being implemented in accordance with the National Historic Preservation Act, Endangered Species Act, Migratory Bird Treaty Act, the Bald and Golden Eagle Protection Act, and Wilderness Act. Consultation has been completed with the California State Historic Preservation Officer, with participation from the Advisory Council on Historic Preservation. The NPS has also initiated consultation with tribal partners and will continue consultation throughout implementation to identify resources that may be present and ways to mitigate if not avoid impacts to these resources. Similarly, the Parks will implement the US Fish and Wildlife Service national conservation measures to avoid direct impacts to migratory birds and bald and golden eagles. The Parks have also reached out to the US Fish and Wildlife Service in accordance with the Endangered Species Act. Consultation on some portions of the action is already completed, and consultation will be initiated and completed for any other portions of the action that may affect a federally listed species or migratory bird; work that may affect a listed species will not begin until consultations are complete. Finally, the Parks have determined that this emergency action in wilderness is necessary to administer the area as wilderness and will further document analyses in line with the provisions of the Wilderness Act for any action that would otherwise be prohibited by the Act prior to taking that action. All future consultations and analyses have the potential to modify the action in order to minimize if not avoid impacts to resources; mitigations as they are identified in the future will be incorporated into the emergency action.
 
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