
1. Expanding the Use of Beneficial Fire at Meaningful Cultural and Ecological Scales via collaborative partnerships and science-based treatment prioritization and perpetual maintenance.
The three pillars are: prescribed fire, indigenous cultural fire, and wildfires managed for multiple resource objectives.
This document was crafted by a suite of Federal, State, NGOs, Tribal, UC ANR partners, and overseen by Sara Clark, Attorney with Shute, Mihaly & Weinberger LLP

2. Utilize the National Wildland Fire Mitigation and Management Commission Report in Advocacy Work
Select recommendations and support beneficial fire advocacy (see the full list in Appendix E, page 315).
https://wfca.com/wp-content/uploads/2023/10/wfmmc-final-report-09-2023.pdf
148 Recommendations with 100% consensus, dig in and present to reporters, politicians, state agencies, RCDs, air quality districts, teachers and others. It’s about building unity and support for science-based (not political) decision-making. Below are some key fire restoration recommendations:
Recommendation #13: Establish a prescribed fire target based on natural fire regimes as determined locally.
Recommendation #42: Direct the Environmental Protection Agency, the Department of the Interior, and the U.S. Department of Agriculture to work together to expeditiously evaluate current federal regulations and guidance around the treatment of smoke from wildland fire in air quality management programs with the intent of ensuring the programs can accommodate increased use of beneficial fire. Such an evaluation includes the exceptional events pathway and making any necessary changes to enhance programmatic and procedural ease and clarity while ensuring protection of public health, in a manner consistent with the Clean Air Act. Further, Congress should provide resources to ensure federal, state, and local authorities can expand their capacity to document and exclude wildfire and beneficial fire smoke from regulatory significance.
Recommendation #57: Congress and agencies should expand support for the further development and utilization of pre-fire response planning, such as the Potential Operational Delineations methodology, as a science-based, collaborative, and interdisciplinary framework for improving wildfire management and mitigation, integration of land management objectives with wildfire management objectives, and collaborative engagement.
Recommendation #89: Invest in the creation of a workforce primarily focused on restoration and mitigation.
Recommendation #92: Tribes should be supported to expand mitigation, response, and restoration workforces.
Recommendation #140: When authorizing and funding programs related to wildfire, Congress should directly recognize the historic role and continued importance of Indigenous stewardship related to fire.
Recommendation #147: Change the system of land management agency performance metrics beyond acres treated, timber volume output, or acres burned to measure success. Success should be measured by outcomes such as the number of protected assets, values, and resources, and the degree to which forests and rangeland are returned to and maintained in a more resilient state.

3. Advance and Defend Ecological Integrity
—36 CFR § 219.8 in the 2012 Forest Planning Rule should guide all Forest Service management decisions. Management decisions should be planned, implemented, and monitored by teams of forest, fire, and aquatic ecologists where what matters is Outcomes, not Outputs.
36 CFR § 219.8 (a) Ecological sustainability. (1) Ecosystem Integrity. The plan must include plan components, including standards or guidelines, to maintain or restore the ecological integrity of terrestrial and aquatic ecosystems and watersheds in the plan area, including plan components to maintain or restore structure, function, composition, and connectivity, taking into account:
(i) Interdependence of terrestrial and aquatic ecosystems in the plan area.
(ii) Contributions of the plan area to ecological conditions within the broader landscape influenced by the plan area.
(iii) Conditions in the broader landscape that may influence the sustainability of resources and ecosystems within the plan area.
(iv) System drivers, including dominant ecological processes, disturbance regimes, and stressors, such as natural succession, wildland fire, invasive species, and climate change; and the ability of terrestrial and aquatic ecosystems on the plan area to adapt to change.
(v) Wildland fire and opportunities to restore fire adapted ecosystems.
*It is important to note that only a very small number of National Forests in California (4 units of the total of 18) have completed their plan revisions (Sierra, Sequoia, Inyo, and LTBMU) under this now 13-year-old Planning Rule.
While forest plan revisions require funding, staffing, and deep public engagement we are approaching 3 decades of non-compliance with existing laws and regulations in the older plans which make a mockery of the rules designed to protect the public’s national forests, saying nothing about the use of best available science in designing the revised plans.
While the Planning Rule sections 219.8 Sustainability and 219.9 Diversity were created to restore and maintain structure (large old growth, fire resilient, carbon storing, habitat enhancing trees for example), function (science-based fire restoration and maintenance in the West), composition (plant and animal species diversity), and connectivity (avoiding the creation of isolated habitat islands or barriers to movement and migration) these rules have been intentionally avoided in order to foster production outputs that contribute to the unraveling and flammability of our forest ecosystems.
Demanding that forest management is guided by the Best Available Science and the Ecosystem Integrity and Diversity requirements is what our restoration work is all about.
4. Restore Old Forest Emphasis Areas, Habitats and Associated Wildlife Species.
In 2001 the Sierra Nevada Framework Old Forest Emphasis Areas--4 million acres managed for old forest values, not timber outputs-- from Sierra Nevada Ecosystem Project Report (SNEP) -- 1996 Chapter Vol. II Chapter 21 and SNEP Addendum –Science got it right!
SNEP Addendum p.57 There was only 11.5% of size class 4-5 of mixed conifer forest remaining in the Sierra Nevada when this SNEP Report was published in 1996.

Restoring old forest conditions across the Sierra Nevada (and elsewhere in California) is essential to the Restoration of Ecological Integrity of our forest ecosystems. While there is a legitimate claim that we need to lower the stand density in our current forested landscapes, at the same time we MUST remember that in the historic past, many of those fewer trees/acres were larger than your dining room table! This is a 200–500-year commitment to rebuild and maintain our old growth forests and is part of the atonement for the tragic mistakes of the past greed-driven logging agenda started by our plundering pioneer relatives.
5. End use of chemicals (herbicides, pesticides) on public lands—broadly engage Tribal partners and indigenous fire application to maintain resilience across restored environments and promote safe gathering of culturally important food and fiber within the local Tribal communities.
Conservation partners and Fire Staff support fire as the key restoration and maintenance tool in our frequent fire ecosystems, yet the Forest Service (foresters) tend to default to large scale chemical herbicide use in reforestation efforts and elsewhere as the vegetation control tool of choice. Tragically, the choice of the spray tank over the drip torch damages native biodiversity (plants and wildlife) and is a significant risk to human health.
While we are regularly told Glyphosate is harmless if you “follow the label instructions", the reality of frequent use and exposure offers a very different picture.
Reported Health impacts:
(1) A University of Washington review of numerous studies determined that glyphosate exposure may increase the risk of non-Hodgkin lymphoma by up to 41%. The review included a study with 54,000 people who had jobs applying pesticides.
Comment: Reading the label direction helps, but regular occupational use inevitably leads to exposure and while applicators generally don’t die after an exposure, they do frequently die from lymphoma several years later. The other factor in play is while agencies aggressively defend toxic herbicide usage, they aren’t the ones doing the spraying. The applicators are generally guided by the instructions of the spray contractor, and the crews are often from Mexico or Central America, brown-skin people with limited knowledge of the English language or the longer-term implications of toxic chemical spraying.
(2) Where you live may affect the degree of your exposure to glyphosate. A recent study of pregnant women in Idaho found that those who lived less than one-third of a mile from fields treated with glyphosate had much higher levels of it in their urine than those who lived farther away.
Comment: So much for the chemical industry storyline that Glyphosate doesn’t move through our environments.
(3) Glyphosate in beer: Since barley is the most common grain used to make beer, and studies have detected glyphosate in the grain, it’s not surprising that the herbicide has also been found in beer. One study of 100 samples of beer found glyphosate residue in 92 of the samples.
Comment: Now there is another good reason to sue Bayer, the company who bought Monsanto’s star product and millions of dollars of legal exposure.
(4) Cancer. Some studies suggest glyphosate may be linked to cancer. Others suggest there’s no link. The International Agency for Research on Cancer categorizes glyphosate as a probable carcinogen for humans. The EPA says that glyphosate does not pose a risk to humans as long as it is used according to directions. A 2023 study by The University of California, Berkeley, found that glyphosate is a probable human carcinogen.
Comment: Why take that risk when we have a very viable and ecologically appropriate alternative, the application of beneficial fire? Oh, that’s right, the agency field staff generally aren’t the ones doing the spraying!

6. Ecological Reforestation—planting and maintaining reforested areas like fire matters. North et al. 2019, Meyer and North 2024, Levine et al. 2022 and 2025; Bousfield et al. 2025; York et al. 2025. It is not cropland, it’s an ecosystem!
The key guidance documents for Post-Fire Restoration are PSW-GTR-270 and PSW-GTR-278
https://www.fs.usda.gov/psw/publications/documents/psw_gtr270/psw_gtr270.pdf
https://www.fs.usda.gov/psw/publications/documents/psw_ /psw_gtr278.pdf
Ecological Reforestation: A Basic Guide for Achieving Resilience
Malcolm North and Marc Meyer, US Forest Service 2024

See the Fire Science Consortium presentations by ecologists Marc Meyer and Malcolm North at: https://www.youtube.com/watch?v=Tu92373T8Gg&t=208s
All these factors are not just about checking boxes. We must move our thinking and actions into a better place, science-based, ecologically and culturally more resilient and attuned with landscape need for change from the past misguided era of fire exclusion and into that era of fire restoration as a core principle for actions guided by the good work in PSW-GTR-270/278 (Meyer et al. 2021 & Long et al. 2023) and Reforestation for Resilience (North et al. 2019) and other key work in recent years by Forest Service ecologists, PSW researchers, academic researchers, Tribal partners and Conservation NGOs. We need to BE THE CHANGE.
(From Levine et al. 2022 pg. 6) “The heightened likelihood of high- severity fire both on and around industrially managed forests suggests that the predominant forest management practice on these lands (even- aged plantation forestry) may contribute to the broader pattern of increased high- severity fire incidence in California on land of all ownership types. This, together with the complex intermix of ownership types and evidence that high- severity fire effects may be spread across ownership boundaries, emphasizes the necessity of cross- ownership cooperation to reverse recent, concerning trends in extreme fire effects.”
https://esajournals.onlinelibrary.wiley.com/doi/10.1002/fee.2499

In the Levine et al. 2025 paper the authors reaffirmed the relationship between high-density forest conditions, extreme weather and land management ownership. See the Abstract below:
Despite widespread concern over increases in wildfire severity, the mechanisms underlying this trend remain unclear, hampering our ability to mitigate the severity of future fires. There is substantial uncertainty regarding the relative roles of extreme weather conditions, which are exacerbated by climate change, and forest management, in particular differences between private industrial timber companies and public land agencies. To investigate the effects of extreme weather and forest management on fire severity, we used light detection and ranging (LiDAR) data to characterize pre-fire forest structure across five large wildfires which burned 460,000 ha in the northern Sierra Nevada, California, USA. We found that the odds of high severity fire occurrence in these fires were 1.45 times higher on private industrial land than in publicly owned forests, an effect equivalent to a three standard deviation decrease in fuel moisture. Next, we quantified the relationships between key forest structure metrics and the probability of high severity fire, as well as how these relationships were modified by extreme weather. We found that dense, spatially homogeneous forests with high ladder fuels were more likely to burn at high severity. Extreme weather magnified the effect of density, suggesting that treatments which remove overstory trees are especially important in extreme conditions. Forests managed by private industry were more likely to be dense, spatially homogeneous, and contain high ladder fuel loads than publicly owned forests, offering a potential explanation for the increase in high-severity fire occurrence on private industrial land. Overall, these results illustrate the need for comprehensive forest management to mitigate fire severity in a warmer future. Link to the Levine et al. 2025 paper:
https://onlinelibrary.wiley.com/doi/10.1111/gcb.70400\
https://www.nature.com/articles/s41467-025-59272-6 Bousfield et al. 2025
This is a problematic look at high density plantation forestry in the Northern Hemisphere (China, Russia, Canada and the U.S.).
7) The Dedicated Restoration Workforce—whether the management unit is federal, state, Tribal, private landowner, land trust, conservancy, or other . . . Conservation Stewardship for the enhancement of biodiversity and resilience, Indigenous cultural values, and community protection must be supported as an integral part of our responsibility to Planet Earth and current and future generations.
While we have spent 125 years fighting fire at the cost of billions, we have spent a pittance on fire lighting—restoring this critical ecological process and maintaining restored fire-associated landscapes through time.
Having the skilled, unit-based restoration workforce that knows the landscape, vegetation, meteorology, topography, fire and management history, and knowing the community deeply which builds trust that travels with engaged partnership. Permanent funding is stable and supported with state, federal and private funding with the clear and defendable recognition that the cost of restorative landscape management and maintenance is a far better investment than the billions we are spending annually fighting uncharacteristic and highly damaging wildfires and long-term damage to communities, infrastructure, and natural ecosystems.
Although a top priority in our seriously fire-departed landscapes, the restoration workforce includes more than beneficial fire restoration and maintenance. Broad training in meadow and stream restoration, habitat restoration and enhancement, forest stewardship and community training for partnership support of restoration that encourages people of all ages to get involved.

8) Support Tribal coalitions and their cultural practices
There must be something in the water? Yes, those are native salmon! Thank You Yurok and Karuk Tribes (and others) for your persistence in the removal of the Klamath Dams!
Yurok Tribe’s Fight to Save the Klamath River –The Kelly Clarkson Interview watch it here:
https://www.youtube.com/watch?v=YAZCiAsygL0
Indigenous Stewardship Network https://www.indigenousstewardship.org/
The Cultural Fire Management Council https://www.culturalfire.org/
The California Indian Basketweavers’ Association https://ciba.org/
The Sierra-Sequoia Burn Cooperative https://www.facebook.com/p/Sierra-Sequoia-Burn-Cooperative-61568097621008

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