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HomeMy WebLinkAboutWldfire Grant LtrBoard of Coun Commissioners P.O. Box 6005 • Bend, OR 97708-6005 1300 NW Wall St, Suite 206 • Bend, OR 97701-1960 (541) 388-6570· Fax (541) 385-3202 July 28,2014 www.deschutes .org board@deschutes.org Sustainability and Environmental Programs Office of the Chief Readiness Support Officer Tammy Baney Anthony DeB one Alan Unger Department of Homeland Security Submitted by email to: SEP-EHP@hq.dhs.gov Comment re: DHS NEPA Procedures Thank you for the opportunity to comment on docket number DHS-2013-00S2, relating to the National Environmental Policy Act Implementing Procedures for the Department of Homeland Security. Our comment is related to the proposed text of the Categorical Exclusion Nll, "Federal Assistance for Wildfire Hazard Mitigation Actions". We are pleased to see that a Categorical Exclusion for wildfire mitigation is being considered. Deschutes County has experience implementing two FEMA pre-disaster mitigation grants for wildfire mitigation and are currently embarking on our third. We have found the process currently followed by FEMA to comply with the National Environmental Policy Act to be particularly cumbersome and slow. It is imperative that this process is improved by granting a Categorical Exclusion for activities that have historically had findings of no significant impact. Unfortunately, the proposed text is much too conservative by having a limitation of 100 acres. It is our understanding that FEMA fully supports implementing the National Cohesive Wildland Fire Management Strategy. According to the Cohesive Strategy there is a desire to enhance the FEMA pre­ disaster mitigation program to maximize fuels reduction across the landscape, with emphasis on private lands. Currently FEMA has pre-disaster mitigation grants available, but less than 1% of those funds go towards wildland fire mitigation. Establishing a wildfire Categorical Exclusion was explicitly identified as a Critical Success Factor in the National Cohesive Wildland Fire Management Strategy. Critical Success Factor #12, FEMA Pre-Disaster Mitigation Program, was identified as one of the highest priority barriers to be addressed in order to contribute to the successful implementation of the Cohesive Strategy. We feel that with the stringent acreage limitation proposed this barrier will remain an issue into the future, and funds that could be used to protect homes from wildfire will go to other programs. We would call attention to the Deschutes and Crook County Wildfire Mitigation Environmental Assessment, April 2009, which is cited in the proposal as an example of an Environmental Assessment that justifies the Categorical Exclusion. This EA, as described and studied, proposed to treat 1,000 acres and had a finding of no significant impact. We would think that this example would justify a cap of at least 1,000 acres being considered. Enhancing the Lives of Citizens by Delivering Quality Services in a Cost-Effective Manner We urge you to consider striking the acreage limitation when the proposed actions involve creation of defensible space within 100 feet of a structure. The reality is that this zone is already highly disturbed due to previous or ongoing activities related to building or maintaining the structure. Research by Cohen and others has shown that this is the most critical area for fuels management as it relates to structure survivability during a wildfire. Having this categorical exclusion in place with no acreage limitation would greatly streamline implementation of these defensible space projects, and provide increased home survivability while having no adverse effects on the environment. Thank you for your consideration. Sincerely, Deschutes County, Oregon Board of County Commissioners Tammy Baney, Chair Anthony DeBone, Vice Chair Alan Unger, Commissioner Cc: Senator Ron Wyden Senator Jeff Merkley Representative Greg Walden