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ALERT - December 4, 2006: Protect Our Woods joins allies to submit a response to the Draft Supplement to the Final Environmental Impact Statement (FEIS) for the German Ridge Restoration Project in Hoosier National ForestPart 10c. Cumulative Effects Analysis Is Still InsufficientSALVAGE LOGGINGThe Cumulative Effects Analysis does not include a consideration of the fact that salvage logging could be happening anywhere anytime and in any amount. In a different section, we pointed out that the Forest Service does not adequately assess natural disturbances as factors that create openings in the forest, and are the reasons for salvage operations. We wonder why natural disturbances/salvage are not included in the cumulative effects analysis, since it seems pretty obvious that natural disturbances happen, and that the resulting salvage operations have environmental impacts.In the last 10 years, few timber sales for purposes other than salvage have occurred on the Hoosier National Forest. No real reason was given for this in the HNF FEIS. “Salvage logging” is one of those terms used by the Forest Service all around the country as an excuse to log commercially. Often, these salvage sales” include very old, healthy trees as well as the “damaged trees.” These trees are offered as an enticement to timber companies to come in and take out the less commercially valuable, damaged trees. According to the HNF LRMP, just about no area on the Hoosier National Forest is exempt from salvage logging. “MA 2.4, 6.2, 6.4, and 7.1 areas would allow salvage of timber products in the event of natural catastrophes, such as insect and disease outbreaks, tornadoes, or wildfire. Salvage would be allowed in Management Areas 2.8 (Alternatives 1 and 5), 3.1 (Alternative 4), 3.5 (Alternative 3), and 3.3 (Alternatives 3, 4, and 5).” A commenter replied: “This is an odious and offensive subterfuge that would justify logging of virtually any tree almost anywhere in the national forest. All trees are ‘potentially affected!’” In the past, the Forest Service has used salvage logging as an excuse to take out perfectly healthy trees. This has happened in many national forests around the country, as the law clearly allows this, and the timber companies desire it, information which has not been given to citizens in the Forest Plan The DNR in Indiana has used this tactic to commercially log perfectly healthy trees. It is no wonder that citizens, therefore, do not trust the Forest Service to use salvage logging simply to “maintain and restore sustainable forest ecosystems.” In fact, one can look through the “Response to Comments” section of the FEIS and see many, many comments from citizens concerned (when the Forest Service chose to publish them) about past and future abuses of the salvage logging provisions. We also do not see any proof in the FEIS that salvage logging actually helps maintain and restore sustainable forest ecosystems. Ross Gorte, in the CRS study concluded, “Hence, it is unknown whether salvage sales benefit or cost U.S. taxpayers.” Where is the monitoring and evaluation of past salvage logging programs? What are the pros and cons listed of leaving the “dead and dying and diseased trees” alone in the forest to die? There has not been an honest evaluation of this controversial topic in the FEIS. CLIMATE CHANGEThe HNF FEIS, as well as the German Ridge FEIS/DSFEIS, do very little to analyze the effects of the Forest Service’s proposed actions, such as logging, burning and mining, on the amount of carbon that is either stored or released into the atmosphere. Obviously, these effects can be local or even international in scope, taken cumulatively with other actions. No attempt is made to assess the combined impact of burning and logging on Climate change- in other words, how much more Greenhouse gases are released as a result of multiple actions of burning and logging on State, private and HNF. IS THERE MORE LOGGING COMING?The Forest Service has guidance, acknowledged in the Hoosier Land and Resource Management Plan (LRMP), to keep up to 12 percent of the Hoosier National Forest in “early successional habitat,” in Management Area 2.8., a point which we do not concede as necessary or legal. From the German Ridge FEIS, Page 4: “Removing most of the pine trees would create areas of early successional forest habitat, which currently is in limited supply on the Forests.”The Forest Plan calls for considerably more of that habitat than currently exists.” How will this project meet that need if the documents all tell us that the point of the German Ridge Project is to restore Oak Hickory? What percentage of the 12 percent will this project meet? How will this be monitored? How will the Forest Service “keep” any percentage of this project area in early successional habitat without more logging than revealed in the German Ridge Planning documents? How much will this cost the public to sustain? Is this project area the best candidate for the Forest Service to do this in, versus other areas? On Page 46 of the German Ridge FEIS, Table 2-7 shows that in fact there will be only a “moderate” increase in Management Indicator Species (MIS) of early successional habitat (whatever that means), but a minimal change in the long-term (whatever that means). If this is the case, that in the long-term there will be minimal change in early successional habitat, why then is the Forest Service using MIS’s that are associated with early successional habitat, such as the grouse, to measure the Project’s success in regards to wildlife? Our Question: How much more logging, and when, can we anticipate in German Ridge based on the M.A. 2.8 Management Guidleline to achieve the desired level of early successional habitat, since obviously this current project is only meant to create temporary early successional habitat? And shouldn’t the effects of such additional logging be included in the cumulative effects analysis? Click here for Cumulative Effects Analysis Is Still Insufficient Part 4 of 4Protect Our Woods
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