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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 Forest16b. Logging of HardwoodsSo 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 Mothers Memorial Forest) on the Hoosier, constitute .004 percent of the HNF, with a total of 199,150 acres on the Hoosier National Forest 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 Charles C. 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 forest (as defined on p. 80) vs. second growth forest; • 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 The Multiple-Use-Sustained Yield Act of 1960 (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 Ridge, 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 17a. Prescribed Burning (Part 1 of 6)Protect Our Woods
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