NON-ECONOMICS

As of now, my experience with FEMA spans three years and sixty days. So I am speaking from direct knowledge of its dysfunction, which has been consistent during this entire timeframe. Specifically, its reluctance to acknowledge the economic value of standing timber losses in the Hermit's Peak/Calf Canyon Fire–a prescribed burn ignited by USFS nincompoops gone wild. To date, FEMA has staunchly refused to compensate victims one red cent for economic losses experienced from destruction of a valuable natural resource: its standing timberland.

This reluctance persists even after The Honorable James O. Browning, United States District of New Mexico Judge, has ruled FEMA must fully compensate victims for such losses. It's difficult to understand why FEMA has decided to appeal this ruling. To me, it's a blatant act of cruelty directed at victims long beleaguered by this demonstrably dysfunctional agency.

FEMA's own Benefit-Cost Analysis (BCA) Toolkit actually provides a path to value forests. In 2022, FEMA updated these values, and by 2026, adjusted for inflation, the Annual Ecosystem Service Value for temperate coniferous forests is roughly $12,500 - $14,000 per acre per year. So they've prepared for an outcome wherein standard calculations for standing timber losses are readily performed with any cheap handheld calculator, slide rule, or in one's own head if one so desires, and possesses adequate computational acuity. So FEMA is amply prepared.

Then why are they being so stubborn about compensating victims accordingly? They need no proof of loss evidence beyond the plethora of before-and-after aerial imagery clearly showning each and every acre of totally destroyed standing timber across the entire 345,000 plus acres of the still all too obvious burn scar. My take on it all indicates a case of pure cruelty. With Judge Browning's ruling and backing of Congress, there remains nothing more to debate about what FEMA continues to call non-economic losses (a deceitful evaluation).

Moreover, the fire didn't just destroy "wood", it destroyed a complex system that provided vital ecological stabilization and enhancement services every year. Over my seventeen-year tenure living and working on my wilderness homestead full time, forest acreage ecological service value losses include, at the very least, the following naturally-renewable benefits:

1. Loss of Protective Infrastructure (Windbreak and Thermal Mass) At 8,000 feet elevation, the standing timber served as a vital windbreak and thermal buffer. Without this canopy, the cost to heat and maintain my structures increases significantly due to higher wind-chill exposure and loss of the forest's microclimate. The destruction of this living insulation creates a direct, measurable increase in future utility and maintenance costs–clearly an economic loss.

   
   

2. Erosion Control and Soil Stability The root systems of my private forestland were the primary infrastructure preventing soil erosion and debris flows. Since the USFS-initiated fire, the land is now susceptible to catastrophic runoff. Replacing the ecological service value those trees provided would require multi-million dollar engineered retaining walls and drainage systems. Therefore, the trees have an Asset Replacement Value equal to the cost of the mechanical erosion control now required in their absence–clearly an economic loss.

   
   

3. Professional and Retirement Asset Liquidation The non-economic designation assumes that timber only has value if it is currently being logged. This ignores the Standing Reserve Value. As an off-grid resident, this timber represented more than two decades of investment in self-reliance and a vital component of my retirement security. Categorizing this as non-economic is equivalent to zeroing out a citizen's 401k because they hadn't started withdrawing from it yet–clearly an economic loss.

Conclusion

I have been a taxpayer and an upstanding citizen, living a low-impact life that saved the state and federal government significant infrastructure costs for nearly two decades. To be made whole again, I must be compensated for the Restoration Cost of the land—the cost to replant, stabilize, and manage the forest until it returns to its pre-fire functional state-not merely the stumpage value of the wood. This restoration cannot be accomplished within my remaining lifespan, much less rapidly enough for me to reap any benefit from restorations. Hence, FEMA is currently applying cruel torture tactics for no good reason with their litigious delays to resist compensating victims for what they still refer to as non-economic losses.