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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 Forest

16a. Logging of Hardwoods

HARDWOODS PROTECTED?

In the German Ridge FEIS and DSFEIS we are told that hardwood trees will not be cut in the German Ridge Project area:

German Ridge FEIS, Page 6:

“Hardwood trees, none of which are targeted for removal, account for 10 to 50
percent of the trees in pine stands in harvest areas. Pine thinning would remove
all or some of the pine while retaining the hardwoods.”

“Timber harvest is proposed to remove nonnative pine trees that are mature or
declining within the German Ridge Project Area. The proposal includes:
   • Timber harvest (total pine removal) on approximately 350 acres, I.E., CLEARCUTS
   • Shelterwood harvest in pine on approximately 120 acres; I.E., CLEARCUTS
   • Pine thinning on approximately 210 acres
   • Prescribed burn treatment under controlled conditions on an estimated 2,170
   acres”

So what are the definitions of these terms?

If you read the USFWS BO from 2001, you can see that the definitions of the management “prescriptions” that the Forest Service is planning for German Ridge include the cutting of hardwoods:

pine clearcuts; all trees within a stand are removed at
one time

pine shelterwood cuts; only the largest and most
vigorous hardwood trees are not cut, those trees are
removed later once seedlings are established

pine thinning; all trees are removed except hardwood
trees greater that 4 inches in diameter

So, is the Forest Service going to log hardwoods or not?

And if not, and the Forest Service is telling the public the truth about the market value of the pine trees, (see below) then what is the incentive for commercial loggers to log trees that have a low stumpage value? Experience shows that hardwood trees are usually “thrown in” so that commercial loggers have an incentive to log low stumpage value tree species.

German Ridge DSFEIS, Page 54:

“The stumpage value of pine is low.”

The Forest Service is also telling us below that the pine stands actually have a large percentage of hardwoods in the stands:

“(Pinus echinata), white pine (Pinus strobus), red pine (Pinus resinosa), and
Virginia pine (Pinus virginiana), none of which are native. The pine composition
in stands proposed for timber treatment ranges from 50 to 90 percent. Stands
range in age from 31 to 72 years (the number of years since various plantations
were planted): three stands in the 30 to 39 year age class, 19 stands in the 40 to
59 year age class, and 17 stands in the 60 to 79 year age class.

Although pine trees were planted on a large portion of the area, the pine stands
include an appreciable hardwood component, ranging from 10 to 50 percent of
the total basal area. The oak-hickory component of the hardwood consists
mainly of white oak (Quercus alba), black oak (Q. velutina) and pignut (Carya
glabra) (USDA FS 1995). The understory layer of the stands consists largely of
tree species such as maple, dogwood, tulip poplar, ash, oak, hickory, beech, and
sassafras. Some stands also include nonnative Japanese honeysuckle and
Eastern redcedar, which (although not exotic) can be invasive. Detailed
information on existing pine in each stand proposed for treatment by alternative
is provided in Tables 2-1, 2-3, and 2-4. Most stands on the Hoosier can be
described as dense, mature, and overstocked.

In the German Ridge Project Area, the approximate composition of pine stands is
as follows.

Pine Species Approximate Acres
Red pine 10
White pine 140
Shortleaf pine 900
Pine with hardwoods 45
Yellow pine with hardwoods 100
Total Pine 1,195 acres”

From German Ridge FEIS, Page 25:

“The only hardwoods that would be cut would be those designated by the Forest
Service for removal to allow access for operations, including the construction of
landings or to protect human health and safety. It is also possible that some small
hardwoods would be removed (cut during fire line construction or killed by the fire)
during implementation of the prescribed burning.”

As we have seen with Forest Service salvage sales, the fact that the Forest Service
is using the terminology “to protect human health and safety” leaves the possibility
for the removal of valuable hardwoods by the agency’s contractors wide open.

TIMBER INDUSTRY FOCUS AND LACK OF OLD GROWTH

The German Ridge FEIS states in 1.2 (page 1):

“The purpose of this proposal is to re-establish a native hardwood community
having a strong component of oak and hickory and a composition and structure
that functions as closely as possible to the ecological potential of the land, including
the plant and animal community….”

According to the Hoosier National Forest Plan, German Ridge is mainly within Management Area 2.8., which is not geared towards establishing old growth forests. Instead, MA 2.8 areas provide a variety of forest types, and gaps in the canopy result in different canopy levels and different successional stages of vegetation. The Forest Plan recommends that 4 to 12 percent of MA 2.8 should be in young hardwood stands (in the 0 to 9-year age class) (Forest Plan, page 3-28). The Forest manages the area primarily for plant and animal habitat, and timber harvest is an appropriate tool for use in this area. There is a higher percentage of edge habitat in this management area than in most of the forest. The Forest Plan provides guidance for achieving desired habitat conditions, including:

     • “Limit temporary openings created by clearcut and shelterwood harvest to
   10 acres.”

   • “Control grape, ivy, and other vines as necessary to ensure satisfactory
   regeneration and growth…”

   • ”Retain a variety of hardwood species in timber stand improvement and
   thinning operations.”

   • “Conduct thinning, improvement cuts, and timber stand improvements.”

So what will be the fate of the hardwoods, the oak and hickory trees, once their “communities” have been established? They will be thinned, and “improved”, so that when they are “mature” (that means about 80 years old), they will be cut.

The German Ridge project is tiered to the HNF Plan, and therefore to all the deficiencies that are included in it. One of those deficiencies is a neglect and disregard of the public’s desire for natural, undisturbed forests that are allowed to develop into old growth forests, without being subjected to the requirements of industrial logging.

A natural forest doesn’t need a Forest Service to perpetuate it, only a forest slated for industrial logging does, and what is perpetuated is a continuous supply of timber. That is usually achieved through having a “rough balance of age classes”, which, most conveniently, are of even age. But these are human, timber industry-derived requirements. As the Forest Service itself reports in the HNF FEIS, an old growth forest has a multi-layered canopy and an all-aged structure, and is horizontally heterogeneous, characterized by fine-grained patchiness, providing habitat for early and late successional species alike. Old Growth Forest is nature’s way of providing for diversity, but this type of diversity is not convenient for logging. Just letting trees fall after a windstorm, or letting them die naturally after a drought, or because of disease or insect damage or old age, is contrary to the timber-industry logic. Therefore, salvage logging has such a big place in the plan, since according to the timber-industry logic trees have a $-value that you should not just let rot. The logic of the old growth forest, on the other hand, is to let the big trees return to the forest floor and feed the forest life that is dependent on dead and decaying “biomass”.

The fine-grained, patchy, multilayered forest has all but disappeared. But instead of providing the conditions for such a forest to re-emerge on national forest land, as is the desire of most Hoosiers and of most people nationally, the Forest Service tries to keep the commodity focus going while claiming to provide for diversity. There is no correlation between means and ends here. The means of timber production is the end. The end of diversity may justify the means of cutting some single tress in the largely second growth forest, and leaving them there, but that is vastly different from the cutting and logging that is proposed.

Neither the pine plantations slated for cutting in the German Ridge project, nor the hardwoods that are supposed to be established in their place, will have the opportunity to grow and die and decompose naturally.

We therefore challenge the designation of German Ridge as Management Area 2.8, and demand that the Forest Service revises its 2006 Forest Plan that does not respect the public’s desire for the reestablishment of Old Growth Forests. Old Growth Forest is in short supply in Indiana and in the nation.

Here is what the Hoosier National Forest Planning Documents say about the availability of Old Growth Forests in Indiana:

(a) Availability of old growth forest on private land:

The FEIS reports on NO old growth forest on private land.

(a)    Availability of Old Growth Forest on Public Land in Indiana?

There are 895 acres (p. 100 of FEIS), most of which are supposedly on the Hoosier… where are they?

The only reported 88 acres of old growth (Pioneer Mother) on the Hoosier, constitute .004 percent of the HNF, with a total of 199,150 acres on the HNF according to the Table on p. 10 of ROD.

Even if all 895 old growth forest acres were on the HNF, they would make up only 0.4 percent of the Total HNF area.

In Comparison:

What does the Forest Service say about availability of early successional forest on private land?

a) FEIS: p. 293

“Forest Inventory Analysis, as compiled by North Central Research Station, is another
source of information on comparable management practices on private lands. A query
of private lands showed only five counties in the Hoosier region have stands in the 0 to
10 year age class. The counties with private lands having stands in the 0 to 10 year age
classes were: Crawford (1,254 acres), Jackson (5,181 acres), Lawrence (7,406 acres),
Martin (1,360 acres), and Perry (1,642 acres). This indicates where timber management
may be occurring on private lands in the area. If the propensity of landowners to manage
their own forest were an indication of social. acceptance of timber management, these
counties would appear to have a higher acceptance of such management.”

That brings the total 0 to 10 year habitat on private land in the 5 counties in the Hoosier Region to 16, 843 acres, even in the absence of any “treatments” on the Hoosier.

With a total area for the HNF of 199,150 acres, that would be the equivalent of 8.5 percent of the HNF area in early successional habitat.

However, early successional habitat on the HNF only constitutes less then 1 percent of the Forest area, as the Forest Service claims.

FEIS, p. 100
Conversely, forestland less than 10 years of age comprises less than one percent of the forested landscape reflecting the lack of disturbance across the Forest (Parker and Ruffner 2004).”

Since these private forest areas are likely heavily interlaced with HNF territory, it is hard to see how the Forest Service can claim that without logging on the Hoosier to create early successional habitat, there would not be enough of that habitat. There is obviously quite a lot of early successional habitat on private land in the five counties in the Hoosier region, which is not at all surprising when considering that private woodland owners tend to cut trees more often than the Forest Service, that is every 10-20 years (FEIS p. 163).

(d) How many acres of early successional habitat are available on the Hoosier?

The FEIS does not answer this question clearly.

FEIS, p. 100

"Conversely, forestland less than 10 years of age comprises less than one percent of
the forested landscape reflecting the lack of disturbance across the Forest (Parker and
Ruffner 2004).”

According to Table 2.7 (p. 39 FEIS) there is currently 1 percent of the Hoosier in early successional habitat.

Obviously that doesn’t include what is currently available in permanent openings,

Conclusion:

There is NO Old Growth on private land, and a miniscule amount on the HNF. Actually, the percentage of old growth on the Hoosier is less than the percentage of early successional habitat, but there is no corresponding rush by the Forest Service to establish the conditions for future Old Growth to develop, even though Hoosiers, as well as people polled nationally, with overwhelming majority state that they do prefer the naturally developing forest and do not want to see logging on the National Forests.

No matter how often the Forest Service claims that logging is only happening to create habitat diversity, allegedly mimicking nature, this is not a credible claim, since there is no natural process that resembles logging. If the Forest Service really was interested in mimicking natural processes, single trees may be cut in second growth forests to achieve the fine grain, highly diverse structure of an old growth forest, but there would be no point in taking those cut trees out of the forest.

Developing Old Growth Forest, according to the above definition in the FEIS, p. 100, would entail not disturbing the understory for 80 to 100 years prior to the trees reaching about 150 years of age, and allowing trees to mature and die and decompose naturally.

Any form of logging, including salvage logging, cannot be regarded as an attempt to increase old growth areas. Therefore, M.A. 5.1, the Deam Wilderness, is the only area seriously considered as future old growth area, and constitutes about 6 percent of the HNF area today. That is, if the Forest Service doesn’t follow through with its open-ended salvage logging agenda on the Deam.

If the Forest Service were serious about promoting old growth, many more areas would have been designated as wilderness areas on the HNF.

Calling everything ”mature” that is more than 80 years old, and not distinguishing between old growth and second growth forest, makes the analysis of the relative values of different forest resources imprecise and confusing, if not misleading. We demand therefore,

•    That the Forest Service establish a clear definition of old growth (as defined on p. 80) vs.
second growth;

•    That the Forest Services uses this definition of old growth consistently throughout the
FEIS and reports honestly about the percentage of Old growth forest on the Hoosier,
now and projected into the future.

•    That the Forest Service, when claiming to increase the availability of “old growth” on the
Hoosier, propose using only management techniques consistent with achieving old growth
characteristics in second growth stands.

•    We do not consider salvage logging, which is allowed pretty much everywhere on the
Hoosier, as a practice that promotes the re-establishment of an unfragmented, naturally
developing and maturing forest. Only selective cutting, according to the Forest Services’
own analysis, may be permissible in a second growth forest, and in that case the trees
should be left on site, to “mimic’ natural processes.

What is needed is that the Forest Plan gives equal consideration to old growth in the Plan analysis, as required by MUSYA. This is not happening now. One stark indication of that is the statement on p.301, where the Forest Service summarizes “Irretrievable Commitments” :

"Vegetation

Loss of commercial timber management opportunities in Management Areas
2.4, 6.2, 6.4, 7.1, 8.1, 8.2, 8.3, 9.2, and 9.3 (all alternatives) is an irretrievable
commitment. Loss of commercial timber management opportunities in all
management areas (Alternative 2) is an irretrievable commitment."

While pointing out that there is a loss of commercial timber activities in some of the management areas in the plan, and a total loss in Alternative 2, there is no corresponding statement that wherever there is logging going on, old growth cannot develop and is therefore irretrievable lost for generations to come. How much clearer can the Forest Service display its bias?

We therefore demand a revision of the Hoosier National Forest Plan and FEIS, and of the German Ridge Projects, and of all other projects planned for this area (Mogan, Buzzard Roost, Goosetown, Tell City). The revision should develop a new focus for the Forest Plan: re-establishing scarce Old Growth Forests on public lands in Indiana in accordance with the desires expressed by a majority of people in Indiana and the nation.

Click here for Part 16b. Logging of Hardwoods Part 2 of 2

Protect Our Woods
PO Box 352
Paoli, Indiana 47454