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NEVADA DIVISION OF FORESTRY September 18, 2018 Mr. Robert Fenton Regional Administrator PEMA Region IX 111 Broadway, Suits 1200 (Oakland, CA 94607-4052 RE: Appeal of Fire Management Assistance Grant (F MAG) Determination on South Sugarloaf Fire (FEMA Log: 390756) In accordance with Tile 44 of the Code of Federal Regulations (CFR) Part 204.26(a), Nevada Division of Forestry INDF) is appealing the rejected FMAG request for the South Sugarloaf Fire as initially requested and held on August 22 and submitted on August 24, 2018. FEMA’s determination, pera letter dated September 7, 2018 and an email from the watch officer dated ‘August 24, 2018 10:46 PM, stated tha this fire did not meet eligibility citeri associated with or constituting a major disaster. NDF would like to restate and add information t show that ths fre does constitute a major disaster for the ecosystems and habitat affected, residents of these communities, and livelihoods of those who depend on this land for income. er CFR Part 204.21. FMAG declaration criteria follow 4 primary consideraion factors. Those factors as well as the specifies to each for the South Sugarloaf are detailed in the following paragraphs. 1. Threat to lives and improved property, including threats to critical facilites infrastructure, and critical watershed areas, The South Sugarloaf Fire started on August 17, 2018 on private land. This fire was caused by lightning. Initially the fire burned primarily on private and state lands with small inter-mixed Bureau of Land Management (BLM) acres. As the fire progressed, it erossed onto United States Forest Service (USFS) and Bureau of Indian Affairs (BIA). The communitiesthreatened between ‘August 22 and 24 were: Wildhorse Estates (54 homes), Mountain City (14 homes), Owyinee (494 homes), Maggie Sunamit (40 homes) Jarbidge (207 homes), Tuscarora (74 homes) and many dispersed ranches (data from city data.com website). Together this represents well over 800 homes threatened no: including outbuildings and other infrastructure. Over 300 persons were evacuated, of which 75-100 were mandatory in Wildhorse Estates and Mountain City. In addition, the USFS campgrounds, Jarbidge Wildemess Atea and Wildhorse State Park were also evacuated and closed. Other teats to infrastructure included multiple Raft River Power Company Utility lines, NDF"s Pennsylvania Hil repeater site, numerous eel and radio towers, State Route 225 and Jack Creek Summit Road, Jerritt Mine and all ofits infrastructure, 403 listed archeological sites, ‘and 20 Rural Historic Buildings (including Gold Creek Ranger Station, Mountain City Ranget Station, Wildhorse Dam, nd Cob Creek Cabin). Two primary watersheds (South Fork Owyhee River and North Fork Owyhee River) were affected inthe South Sugarloaf Fire. These watersheds lui eventually reach the Snake River in Klaho aud provide support to agivullars, water supplies, and critical sage grouse an mule deer habitat, The aea affected by the South Sugarloaf Fire was Ihome to some of the most pristine and intact greater sage grouse habitat in Nevada. Many ofthe ‘acres bummed were include in the sagebrush focal areas, as defined by the US Fish & Wildlife Service. The sagebrush focal areas were so critical for preservation that they were called out to have complete exclusion of new disturbance as authorized by the BLM and USFS in the Land Use Plan Amendments. Approximately 7,089 acres of general habitat and 136,892 pririty habitat ‘burned inthis ie 2. Availability of State and loal firefighting resources. National and Grest Basin Preparedness Levels were for the majority ofthe active bun periods, ‘moving to4 only on August 31 (the last day of fire growth). At the time of the South Sugarloaf Fire, there were 15 fires buming simultaneously in Nevada (Bery, Rifle Range, Ranch, ‘Anniversary, Side Hill, Patrick, Interstate, Windsor, Pole Canyon, Road, Carville, Sheep Creek, County Line, Ow! Creek, and Goshute Cave) and many more across the west and the nation. Eight of the 15 fires were in and around Elko County, directly straining the available local resources, ‘This greally affected the availabilty of state and local firefighters for initial and extended attack, 3. High Fire Danger conditions, as indicated by nationally accepted indices such as the National Fire Danger Rating System, Fire behavior was extreme from the stat on South Sugarloaf, with multiple days burning over 25,000 acres, peaking on August 25 consuming approximately 70,000 acres in one burn period Nevada experienced a significant fall and winter in 2017, which caused a heavy density of fine flashy fuels across the state. This fuel load added to already drought strested and overpopulated forests, woodlands and rangelands increasing susceptibility to extreme fie behavior and rapid rates of spread, State and federal agencies went into fire restrictions statewide in early June and still ‘maintain these restrictions today. ‘Additional prognosis information missing ftom the Quick Response Checklist for the South Sugarloaf fre: Haines index- 5 Energy Release Componert- 90% Drought Indices: Abnormally Dry to Severe Drought 4. Potential major economie impact, ‘One of the greatest economic impacts on the South Sugarloaf Fire was to ranchers whose private land and federal allotments were buried. Twenty-eight allotments and multiple permittees were affected by this fre. The impacts ranged with the bur intensity ofthe vegetation but all permits will be affected and timeframes of retur to the sites could be extensive based on current policies fon required rst following wildfire. Page -2-0f3 Many of the other major economic impacts have been mentioned in the above paragraphs, bu include: ‘Shuting down mine operations in the Jerrit Mine for multiple days (Closing state and federal campgrounds and wilderness areas to tourists Closure of State Route 225 to North and Southbound trafic LLossof the first credit project inthe habitat bank for Greater Sage Grouse Habitat Long term impacts tothe watershed functionality, and Habitat and species loss [NDF believes that with all the above stated data, the South Sugarloaf Fire does constitute a major disaster and thus should be considered for the FMAG program. If you have any questions or neec any further information, please email jacekc/@foresity 1 zov oF eall 775-684-2500, Sin eh KaceyKC State Forester Firewarden ‘cc: Biadley Crowell, Director DCNR Dominique Etchegoyhen, Deputy Director DCNR Page -3 -0of 3