 |
Protect Our
Woods
Working to preserve our rural heritage and quality of life in southern Indiana since 1985 |
Home Site Map Contact Us |
Home News & ALERTS Issues Forum Archives Conservationist's Alternative Klawitter Memorial Downloads Join Us About Us Contact Us Site Map Links |
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 Forest28c. Soil Analysis Is Incomplete – Soils Could Be Harmed Permanently (Part 3 of 3)In addition, here are some more points to consider about soils, that were not (adequately) addressed in the DSFEIS.36 CFR 219.27(a) requires that all management prescriptions shall conserve soil and water resources and not allow significant or permanent impairment of the productivity of the land. Paragraphs (e) requires that special attention shall be given to land and vegetation for approximately 100 feet from the edges of all perennial streams, lakes, and other bodies of water. This area shall correspond to at least the recognizable area dominated by the riparian vegetation. No management practices causing detrimental changes in water temperature or chemical composition, blockages of water courses, or deposits of sediment shall be permitted within these areas which seriously and adversely affect water conditions or fish habitat. Topography, vegetation type, soil, climatic conditions, management objectives, and other factors shall be considered in determining what management practices may be performed within these areas or the constraints to be placed upon their performance. Paragraph (f) of this section further requires that conservation of soil and water resources involves the analysis, protection, enhancement, treatment, and evaluation of soil and water resources and their responses under management and shall be guided by instructions in official technical handbooks. These handbooks must show specific ways to avoid or mitigate damage, and maintain or enhance productivity on specific sites. These handbooks may be regional in scope or, where feasible, specific to physiographic or climatic provinces. Clearly, this provides a very strong duty upon the agency to not allow timber harvesting or any other activities to tear up the soil, disturb or alter streams or other water bodies, to not allow detrimental sedimentation into the watersheds, and to have a valid scientific basis for actions to eliminate these adverse effects. The EIS of the German Ridge and the HNF EIS, while on it’s face has a lot of information about soils, doesn’t go into the depth of analysis that should be required considering that the soil is the basis of the forest and the impacts from the heavy machinery of logging and road work cause such tremendous damage to the long term productivity of the soil. For example, In the Forest Service’s own study, “The Effects of Forest Management on Erosion and Soil Productivity,” , (Elliot,Page-Dumroese, and Robichaud), they state that, “Ground cover by forest litter, duff, and organic material is the most important component of the forest environment for protecting the mineral soil from erosion. Forest litter provides most of the nutrients needed for sustainable forestry. Ground cover amounts can be reduced by the logging operation (harvesting and site preparation) and burning by either wildfire or prescribed fire. For example, skidder traffic on skid trails can reduce ground cover from 100 to 10–65%. Burning can reduce ground cover from 100 to 10–90% depending on the fire severity.” Yet, although the EA admits that a large portion of the project area is in soils with significant soil erosion and compaction hazards, it doesn’t indicate how many of the skid trails will be across such soils. There is no requirement in the protective measures to keep a certain percent of the ground covered by litter on skid trails, and yet there is an assumption that the ground will remain sufficient covered by litter, to prevent any significant erosion. Yet this is but one more conclusory assertion that has no support in the record. The same is true about compaction. While the EIS does acknowledge some impacts from compaction, it seems to brush off any impacts simply because there will be some mitigation applied. But there is scant evidence that such activities as the listed BMP’s will actually eliminate the impacts. However, the previously cited paper by the FS, plus other important studies on the subject, counter these assertions. In the Elliot, et al paper, they stress the damage to the environment from compaction. They also list impacts that are not listed in the EIS, and counter some of the agency assertions. The paper states, “Compaction of forest soil is a serious concern for managers because of the use of heavy equipment to harvest timber and to prepare a site for planting. Usually, the more porous the soil initially, the greater the compaction depth. For example, volcanic ash soils of the western United States are highly productive in their undisturbed condition but are prone to compaction because they have a low-volume bulk density and relatively few coarse fragments (Geist and Cochran, 1991). Once sensitive sites have been disturbed through timber harvest activities and site preparation, porosity (Dickerson, 1976) and hydraulic conductivity decline (Gent et al., 1984). Compaction depth can exceed 450 mm (Page-Dumroese, 1996). “Compaction reduces productivity through reduction in root growth, height, and timber volume (Greacen and Sands, 1980; Froehlich and McNabb, 1984) and may be produced by a single pass of logging equipment across a site (Wronski, 1984). Productivity losses have been documented for whole sites (Wert and Thomas, 1981) and for individual trees (Froehlich, 1979; Helms and Hipkin, 1986). Decreases in important microbial populations have been observed in compacted soils (Amaranthus et al., 1996). In general, however, the environmental degradation observed in the field results from both compaction and disturbance or removal of surface organic horizons (Childs et al., 1989).” In some of these areas, it is near wetlands, and the water table could be very high. If the water table is high, then if there is rutting, they will stand in water. What are the impacts of this? This is an impact not discussed in the EIS. Also, there isn’t any kind of procedure set forth in any of the documentation for testing the groundwater level. The EA does not mention how the compaction effects might last. However, there is evidence that compaction is long lasting. One paper, by Smidt, and Blinn, Dept. of Forest Resources, Univ. of Minnesota, “Logging for the 21st Century: Protecting the Forest Environment,” for the Minnesota U.S. Extension Service. finds that “Deep ruts may collect water, disrupt underground water movement, and flood surrounding areas, injuring tree growth. In some forests the skid trails and landings are still visible from harvests 60 and 70 years earlier.” This proves that the deep ruts could affect the ground water if it is at, say, 13” below the surface. In addition, if some skid trails and landings have been documented to still be visible 60 – 70 years after, then what steps are going to be taken to insure that these aren’t? Another study, by well known Minnesota soil researcher, Host, found that “Biologists once believed that the freeze-thaw cycle of seasonal changes would reverse soil compaction following logging". Research by Host and his colleagues at a number of sites in the Great Lakes states shows that this is not true, at least in the relatively short term. They used a sort of cart called a wobble wheel to simulate the compaction that results following logging. The sites chosen spanned a variety of soil types. Seven years of follow-up observations reveal that freeze-thaw cycles have not reversed compaction. Soil types at the various sites show little or no recovery. Aspen growing on such sites are only 75 percent as tall and their biomass (weight) was about half of those on the control plots. The research shows that forest productivity declines in areas with compacted soil. As the previously cited Elliot paper states, “In most managed forest watersheds, most eroded sediment comes from roads which have no vegetative protection and tend to have low hydraulic conductivities, leading to runoff and erosion rates that are greater than in the surrounding forests (Elliot et al., 1994a). Numerous researchers, including Swift (1988) and Bilby et al. (1989), have quantified the major role of roads on sedimentation in forests. In addition to erosion, roads reduce forest productivity by the land they occupy…” This roadwork would have cumulative impacts with the skid trails and tracks, and the log landings. Yet, the EIS brushes off the cumulative impacts on soils. Another impact on soils of timber harvesting is removing the nutrients. Not only does removing the boles cause nutrient loss, but compaction also causes a reduction in organic material in the soil, which is a nutrient loss. "Quality for Loblolly Pine Growing on the Lower Coastal Plain of South Carolina” (Kelting, Dissertation submitted to the Faculty of the Virginia Polytechnic Institute and State University, April 13, 1999). All of this can have a significant impact. As the Elliot paper concludes, “…erosion, in combination with other site factors, works to degrade productivity on the scale of decades and centuries. Extreme disturbances, such as wildfire or tractor logging, cause the loss of nutrients, mycorrhizae, and organic matter. These combined losses reduce long-term site productivity and may lead to sustained periods of extended erosion that could exacerbate degradation.” This is by definition cumulative effects and they will be significant. In regard to mycorrhizal associations and the impacts from logging, it is important to document the importance of mycorrhizal associations to the long-term productivity of the forest, something that the EA completely fails to do. As stated in the FS’s own Region 8 paper regarding Mycorrhizal associations by Dr. Charles E. Cordell, National Mycorrhizal Applications Coordinator, USDA Forest Service, Region 8, “Mycorrhizal feeder roots are responsible for the uptake of most of the nutrients and water from natural soils… These structures are essential to the health and vigor of plants, especially forest trees that grow in stressful environments. Mycorrhizae can be classified into two primary types: ectomycorrhizae and endomycorrhizae. With ectomycorrhizae, which are normally found on pine, spruce, fir, beech, eucalyptus, alder, oak, and hickory, the fungi grow between rather than within root cells. They form a structure known as the Hartig net between the cells, as well as a fungus mantle or cover on the surface of feeder roots. The ectomycorrhizal feeder roots develop a swollen appearance, and in pines they normally have a forking habit (fig. I-7). The endomycorrhizae are found on maple, sycamore, ash, gum, walnut, cypress, some poplars, and some other conifers… Hardwood seedlings with endomycorrhizae are better able to compete with undesirable vegetation on the planting site. The most important long-term effect is in phosphorus uptake. Forest soils usually do not have sufficient phosphorus in available form for optimum tree growth. Naturally occurring endomycorrhizae aid in phosphorus uptake. Without them, many trees would die. Fortunately, the endomycorrhizal fungi are present naturally in forest soils.” So according to this data, soil erosion and compaction can affect mychorrhizal associations, and this can adversely impact the long term productivity of the soil. In addition, the EIS and Plan do not have guidelines for providing adequate dead and dying wood in the forest and on the forest floor. Large nurse logs are one characteristic of old growth forest that is generally missing from our forests of today. Yet these dead logs, plus other dead wood on the ground provide a number of benefits, including habitat for increased biodiversity, soil moisture, fertilization for the forest, mycorryzal associations, and carbon storage. Because the EIS does not consider these cumulative impacts, it does not meet the requirements of National Forest Management Act (NFMA) above to protect soils. Click here for Part 29a. Deficiencies of Economic Analysis (Part 1 of 2)Protect Our Woods
PO Box 352 Paoli, Indiana 47454 |