Anonymous Response to Comments on USFS fire suppression/retardant story

I received a response to Eddie G.'s comments on my initial story on the USFS firefighting issues from air tankers in the US. I was unable to insert the comments as a reply so I created a new post. The first in black are the comments by Eddie G. The second in red italic is the anonymous response to the comments. 

Eddie G.: Gel is NOT a retardant. Gel is a water enhancer that simply makes water more effective by allowing it to stay in place. Once the water is gone, after only minutes under fire conditions, there is ZERO effectiveness. Retardants react chemically with the fuel to render it non-combustible, don't rely on water to be effective, and are effective until physically removed. Calling a gel a "retardant gel" is wrong, misleading and dangerous.

Anon Response: The definition of a retardant is anything other than water that slows or stops combustion.  The USFS own Specification 5100-306a for “water enhancers” states in the first paragraph:

1. GENERAL

1.1 Scope:

They may be applied from ground or aerial application equipment, directly to the fire area to SLOW OR STOP COMBUSTION, and for exposure protection.

Effectively defining the product as a RETARDANT!

Eddie G.: Gels and retardants must meet the SAME health, safety, toxicity and environmental friendliness requirements in order to be qualified. Calling retardant toxic and gel non-toxic is a lie.

Anon Response: Washington Journal of Environmental Law & Policy 2011

Similarly, a U.S. Fish and Wildlife Service study found that use  of  aerial  fire  retardant  likely  causes  an  “increase  in invasive species,  loss of substantial fraction of population or habitat, and harm to soil chemistry and plant physiology,” as well as direct mortality to fish and amphibian populations.160

Aerial fire retardant consists of eighty-five percent water and fifteen percent fertilizer, thickeners and corrosion inhibitors.161

Each   year,   firefighters  drop   millions  of   gallons  of   this substance  on  the  nation’s forests, which may  inadvertently

land on people, on animals and in streams.162 The retardant’s

effect  on  streams  can  be  catastrophic  and  can  kill  fish, including  some threatened species.163     For example, in 2001

Fire Regimes, 284 SCIENCE 1829, 1829–32 (1999).

157. See ROBERT L. BESCHTA ET AL., WILDFIRE AND SALVAGE LOGGING 5, 11 (Mar.

1995) [hereinafter Beschta Report], http://www.saveamericasforests.org/congress/Fire/ Beschta-report.htm.  The  Beschta  Report  is  an  independent  scientific  study  that questioned about salvage logging in severely burned areas. See Keiter, supra note 6, at 336.

158. Beschta Report, supra note 157, at 12.

159. Id.

160. Forest Serv. Employees for Envtl. Ethics v. U.S. Forest Serv. (FSEEE III), 726

F. Supp. 2d 1195, 1226 (D. Mont. 2010).

161. Id. at 1225.

162. See id. at 1244–45 (discussing Forest Service guidance on use of aerial fire retardants that prohibits drops within 300 feet of streams).

163. See   Restoration   Project:   Omak   Creek,   WILD   FISH   HABITAT   INITIATIVE, http://wildfish.montana.edu/Cases/browse_details.asp?ProjectID=48 (last updated Apr.

7, 2007) (According to a study by the Wildfish Habitat Initiative, a cooperative effort between  US   FWS  and  the  Montana  Water  Center,  Omak  Creek  in  Eastern Washington State  experienced catastrophic environmental harm from fire retardant drops. In 1992, the Confederated  Tribes of the Colville Reservation began restoring Omak Creek to rehabilitate historic steelhead  and salmon spawning grounds. The project involved removing large boulders and other barriers  that tumbled into the stream as a result of decades of blasting from mining and expansion projects. In 2001, the project experienced a major setback. That summer a wildfire raged on the public lands near the creek. Firefighters called for retardant to be dropped to stop the blaze, but instead of  blanketing the trees, the drop blanketed the fragile creek eventually killing a significant amount of the threatened steelhead in the creek. 

Eddie G.: In addition, retardant must also pass a burn test to prove it is effective stopping and slowing a fire. Gel has no such requirement. There is no data anywhere that proves gel will stop a fire.

Anon Response: Gel has been used since 1960 to STOP fires and many documents exist from the USFS describing its retardant properties on hundreds of fires

In addition all “water enhancers” go through a LIFT test for extinguishment completed by the USFS

Eddie G.: The 300 foot buffer around water streams, a policy that has been in place for 10 years, is good policy because anything dropped directly into a water stream will impact water quality and could impact fish. Including gel.

Anon Response: There are exceptions to the rule when public safety is threatened, and the current Record of Decision on retardant by specification states water or more environmentally friendly product should be substituted ie. Gel

Eddie G.: GelTech's BPAs for Delivery Equipment are for RETARDANT not gel. Perhaps you should read them.

Anon Response: Interesting Issue and may be a violation of FCIC laws concerning competition in contracting

Eddie G.: There is no evidence that FireIce is "the most effective suppressant/retardant in the world." In fact, the QPL would say otherwise. It takes 2-4 times as much FireIce as either AquaGel or Thermogel 500P to achieve the same result.

Anon Response: The QPL is a recommendation from a laboratory looking at “water enhancer” products from a primarily structure protection aspect.  All other firefighting agencies currently use the product at the same viscosity as long term retardant with a 100% success rate.

Eddie G.: The planes breaking off wings happened 8 years ago and had nothing to do with the chemical on board. Read the Blue Ribbon Panel Report.

Anon Response: After reading the report the loads associated with the payload causes fatigue on some airframes including the plane in question.

Eddie G.: Just because FireIce is mixed the same, uses the same equipment with the same viscosity...does not make it a retardant versus a water enhancer. That's like saying potatoes and watermelons are the same because they both cut with a knife in a kitchen. Retardants and water enhancers are totally different chemicals that do totally different things. FireIce does not function, in any aspect, as a retardant.

Anon Response: The USFS has called gel a “RETARDANT” since 1960

Eddie G.: Finally the mix ratio of the new Phos-Chek products was reduced to reflect its INCREASED effectiveness. It takes less of the new concentrate than the old to achieve the same effectiveness. That REDUCES the cost per gallon.

Anon Response: The standing joke around the USFS, Tanker Base Managers, and pilots is that Phos-Chek is gum thickened water