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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 Forest24. Forests and Climate ChangeA carbon dioxide buildup in the environment is a fact. Continuous samples of air taken at Mauna Loa, Hawaii, for decades, shows an 18.8% increase, from 315.9 ppm in 1959 to 375.6 ppm in 2003. There is a growing international consensus that this fact is causing a greenhouse effect and changing the climate on the earth.Forest management influences the carbon cycle. Site preparation and timber harvest create logging slash and disturb down wood, leaf litter, duff, and other organic material in the soil. This results in increased decomposition, which releases stored carbon into the atmosphere as carbon dioxide. There is unavoidable carbon release in the processing, use and disposal of wood products also. In addition, prescribed fire releases stored carbon into the atmosphere. The Hoosier National Forest Final Environmental Impact Statement (FEIS) and Land and Resource Management Plan (LRMP) and the German Ridge Project FEIS/DSFEIS do not address these issues adequately. This is irresponsible, illogical, uninformed, and not what the National Forest Management Act (NFMA) and the National Environmental Policy Act (NEPA) intended for such important environmental issues. Not addressing how forest management affects carbon dioxide release, and carbon storage, is a violation of NFMA and NEPA. One example of potential ecological impacts of climate change on our region was stated by Dr. Scott Robinson in a program in Carbondale, Illinois two years ago. An impact that is showing up that researchers believe is climate change driven and which has tremendous potential for forest health is that the plant community is responding more immediately to climate change than the deeply ingrained habits of animals. Researchers are seeing on an average trees opening their buds weeks earlier than what has been considered normal. Yet, the migratory birds, such as the warblers, whose migration has become almost perfectly synchronized with the hatching of earlier spring Lepidoptera that feed on tree leaves, are keeping their habitual time frames for migration. This could mean that the warblers could end up losing a vital source of food as they migrate – and their ability to control these insects and keep them from decimating the trees. Therefore, if the climate keeps warming, we could see a serious impact to just this one aspect of our eastern forests - with many other impacts yet to show up or yet for us to understand. There are other impacts that have been identified but are not mentioned in the EIS, such as differing responses by different tree species to a CO2 enriched atmosphere, including such factors as growth rate, insect damage, and other factors. Climate is one of the major factors that shapes the composition of a forest. Lucy Braun, among others, has stated this. Therefore, any significant changes in climate will have a strong impact on the development and succession of a forest, and this is especially true in transition forests, where they have many complex factors tugging at them to try and establish a dominance, creating a very precariously balanced ecology. Climate is one of those factors that can tip the ecology out of balance quickly. The question of the interrelationship between forests and carbon cycling is of great interest to the general public. This is due to concerns about global climate change and increasing air pollution, and the effect these events have on people’s health and property. Yet the 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. From the HNF Plan:c) GreenFire Comment on Lack of “Response to Comments” on Carbon Storage HNF FEIS Appendix p. 143PC #3: The Hoosier should consider the cumulative impacts of land use on climate. C) Assess how much carbon is being stored in the forest and how the proposed actions will release this. Response: " #3C) Both above- and below-ground carbon was significantly reduced during the exploitive era following European settlement. Indiana suffered a century of overgrazing, poor farming, and nearly complete removal of timber resources. This early cultural landscape change caused severe soil erosion and a dramatic loss of overall biomass. Since this exploitation, all of the acres that comprise the Hoosier have seen a long period of slow vegetation recovery, primarily in the form of tree growth. Livestock is no longer grazed on the Forest, and ground cover biomass is recovering. The goals of the revised Forest Plan will continue to increase grass and forb ground cover associated with healthy ecosystems and should increase biomass above and below ground, thus increasing or having no net loss in CO2. Also, while prescribed burning releases CO2, the resulting response to biomass should compensate for the temporary loss. Prescribed burning ultimately reduces the amount of carbon released because the absolute magnitude of wildfires decreases, even when some natural communities slowly return to greater fire frequency. The combustion of ground cover fuels is followed by biomass regrowth and an increasing uptake of carbon below ground in the deep roots of prairie grasses and wildflowers." "According to the 2003 FIA (Forest Inventory Analysis), live biomass in Indiana is 228 million dry tons. Within the nine counties that comprise the Forest, there are approximately 60 million dry tons, and on the Hoosier there are an estimated 1 million dry tons of biomass. FIA data from timber inventories for the State and NFS lands over the past four decades indicate a continuous increase in net timber volume. Average annual net growth exceeded harvest by a 2.5 to 1 margin between 1986 and 1997. During the 12 years between inventories, an average of 18 million new growing stock trees were established each year in Indiana." " The Forest Plan projects a maximum removal of 57 MMBF on six percent of the Forest with a dry biomass of approximately 472,800 dry tons. Over that time, growth will continue. On average, approximately 2,000 acres per year would be burned and one ton per acre of carbon would be removed in the form of carbon monoxide, carbon dioxide, and other gases, equaling approximately 2,000 tons per year or 20,000 tons per decade. The ash and other byproducts created by the burns would remain on site, were not projected to be carbon lost since the ash would not leave the site and would be readily available for nutrient absorption and incorporation." The comment does not present any scientific information concerning carbon sequestration that the agency overlooked or ignored. The effects analysis in Chapter 3 discloses, at the programmatic level, the broad-scale effects of the proposed programmatic direction and is in essence a cumulative effects analysis. The Forest has used high quality scientific information available in the development of the effects analysis. The ecological restoration and forest health emphasis of the selected alternative would be expected to have some beneficial effects on carbon sequestration. The focus of the revised plan is improving the condition of the land, not commodity production or development. The revised Plan was developed with analysis of carbon effects at the programmatic level. The effects of the Hoosier’s Forest Plan on global climate are beyond the scope of the proposal, analysis, and decision. As the Supreme Court recently noted in Department of Transportation v. Public Citizen, the EIS need only include information in that is useful to making an informed decision. GreenFire: In the above response, the Forest Service says: “and on the Hoosier there are an estimated 1 million dry tons of biomass” “The Forest Plan projects a maximum removal of 57 MMBF on six percent of the Forest with a dry biomass of approximately 472,800 dry tons.” If we understand this correctly the Forest Service is removing nearly half of the forests biomass over the ten years of the Plan. And this does not include burning. The Forest Service does not say how what is cut compares to how much biomass is accumulated during that time period. In the response they state that “average annual net growth exceeded harvest by a 2.5 to 1 margin between 1986 and 1997.” . What does not mean? If the margin is one, does that mean the regrowth equals what has been cut? That would mean no additional carbon storage compared to not cutting the trees. Even if it was 2.5, that would have to be compared to how much the old trees would have put on during that same time. For climate change concerns it is not important that carbon is stored again after it is released, that is a given. The question is: 1) How much carbon could be stored if the Forest was left alone and not logged? The urgency is great to reduce carbon dioxide in the atmosphere NOW, and so every additional, unnecessary release is a step back. The tress that are standing now could have gone on growing and maturing and storing carbon, instead of being cut down and releasing carbon before they can accumulate it again. 2) How does the carbon storage capacity of older and younger trees differ? In “Are Old Forests Underestimated As Global Carbon Sinks?” by Eileen V. Carey, Anna Sala, Robert Keane and Ragan M. Callaway (Global Change Biology, V7 N4, p 339), the authors state that, “Old forests are important carbon pools, but are thought to be insignificant as current atmospheric carbon sinks. This perception is based on the assumption that changes in productivity with age in complex, multiaged, multispecies natural forests can be modelled simply as scaled-up versions of individual trees or even-aged stands. This assumption was tested by measuring the net primary productivity (NPP) of natural subalpine forests in the Northern Rocky Mountains, where NPP is from 50% to 100% higher than predicted by a model of an even-age forest composed of a single species. If process-based terrestrial carbon models underestimate NPP by 50% in just one quarter of the temperate coniferous forests throughout the world, then global NPP is being underestimated by 145 Tg of carbon annually. This is equivalent to 4.3–7.6% of the missing atmospheric carbon sink. These results emphasize the need to account for multiple-aged, species-diverse, mature forests in models of terrestrial carbon dynamics to approximate the global carbon budget.” Another article, “Carbon storage and fluxes in ponderosa pine forests at different developmental stages, “ by B.E. Law, P.E. Thornton, J. Irvine, P.M. Anthoni and S. Van Tuyl (Global Change Biology V7 N7, p755) finds that old (>250 years) Ponderosa Pine forests sequester twice as much carbon as recently clearcut (1978) forests. What these global climate change scientists are telling us is that it does make a difference whether the trees are old or young. However, the Forest Service neglected to even mention these or other studies, and didn’t compare and contrast the costs to climate change from logging versus not logging, a requirement of the Global Climate Change Prevention Act of 1990 (7 U.S.C. 6701) (see summary here). • § 6701 (b) 5: Incorporate climate change effects into decision making. § 6701 (c) 3: Identify alternatives which mitigate climate change. The only “analysis” on the programmatic level that we could find in the FEIS about Global Climate Change by using the search words: “Carbon” , “Greenhouse”, and “Climate” was the following, which says that Alternative 2 (the no logging alternative) will not have negative effects on Carbon storage capacity. There is no carbon effect analysis on the other alternatives. FEIS p. 3-211Cumulative Effects Implementing Alternative 2, when added to the effects of past, present, and reasonably foreseeable actions, would not result in adverse cumulative effects to the quality of the soil resource or total forest ecosystem carbon storage capacity. HNF FEIS Appendix p. 143/144PC #3: The Hoosier should consider the cumulative impacts of land use on climate. C) Assess how much carbon is being stored in the forest and how the proposed actions will release this. Response: “The effects of the Hoosier’s Forest Plan on global climate are beyond the scope of the proposal, analysis, and decision. As the Supreme Court recently noted in Department of Transportation v. Public Citizen, the EIS need only include information in that is useful to making an informed decision.” GreenFire: This answer by the Forest Service does not show any genuine concern about an issue of global importance, and to claim that this is not a relevant concern, or beyond the scope of the proposal and decision is not only against the law, but is very disturbing. Certainly knowing the effects of logging on global climate change of some of the only areas in the State of Indiana under public control and decision-making should be “useful to making an informed decision.” We therefore urge the Forest Service to re-examine its plans in the light of impacts on Climate Change. Click here for Part 25. Pine Plantations Have Ecological FunctionsProtect Our Woods
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