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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 Forest5. Edge and Early Successional Habitats in Short Supply?The German Ridge project DSFEIS claims a need for more early successional habitat, but does not provide convincing evidence. Likewise, the HNF Plan FEIS, to which the German Ridge project I tiered, lacks convincing evidence, and has been challenged on these grounds.From the HNF FEIS: Public Comment: E) Natural disturbance events regularly create openings throughout the forest. Response to #61: The role of wildlife openings is very scientifically complex, and the Forest reviewed the best scientific information available on forest openings when determining the programmatic direction in the Forest Plan. This direction is based on monitoring information, scientific reports, and coordination with State wildlife experts. Long-established principles of administrative law allow Federal judges to defer to agencies in areas of complex scientific matters, such as the appropriate wildlife habitat and viability requirements on the national forests (Sierra Club v. Marita). Many native wildlife species require openland habitats. Some of the steepest declines in Neotropical migratory birds are grassland or shrubland species. In fact, North American Breeding Bird Survey data shows grassland and early successional breeding birds have been experiencing much greater declines than woodland breeding birds. One of the underlying premises of this comment seems to be that wildlife openings are not necessary as private or other lands provide this type of habitat (although the commentor has not included data to support this suppostion). A lengthly discussion on the importance of openings, young forest habitats, and early successional shrubland habitat is included in the EIS, Chapter 3, Animal Communities. The cummulative effects section includes a discussion of the type of habitat available on private, State and Federal lands in Indiana. This discussion reveals that private lands are providing very little early successional habitat for wildlife species (a little over one percent is in the seedling stage). Although land that is developed in agriculture, rural home sites, or other such developments may be open, they do not provide quality early successional habitats for most wildlife species. After almost 20 years of management under the 1985 Forest Plan as amended, only about 1.6 percent of the Hoosier is in permanent wildlife openings, and most of the NFS land is forested. Management of some openland habitat is important to contribute to maintaining viability of those species which use early successional habitats. Standards and guidelines are found throughout the revised Forest Plan and provide guidance related to managing vegetation to provide aquatic habitat and species management, pest and nonnative invasive species management, watershed health, and diverse ecosystems. These standards and guidelines are designed to prevent or minimize adverse impacts to other resources when conducting forest management activities, such as maintaining wildlife openings.” The Forest Service says in its Response: “One of the underlying premises of this comment seems to be that wildlife openings are not necessary as private or other lands provide this type of habitat (although the commentor has not included data to support this supposition).” Well, nor does the Forest Service support its proposition that there is not enough early successional habitat. It should be expected from a voluminous treatise as the Forest Plan, that somewhere in there, in a concise and easy to comprehend manner, the Forest Service would provide evidence for the claim that there is insufficient early successional habitat in Indiana, or whatever boundary they choose to draw. The substantiation of such a claim would have to start with an assessment of the current availability of early successional habitat, and would then have to provide convincing evidence that the available area is not enough. The HNF Plan does neither. • We were given early successional habitat numbers for private forests for some of the HNF counties, but no information about the total forest area of private forests in that area. • No information on openings on the state forest. • We are told that private land owners cut their forests much more frequently than the Forest Service, but somehow the way they do it is not good enough to provide quality early successional habitat. • The Forest Service claims in FEIS, p. 100 that “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).” • Then, elsewhere, the Forest Service says that there is 1.6 percent in permanent Forest openings which should also be counted as early successional habitat. So obviously permanent openings were not counted when the statement was made that there are less than 1 percent in early successional habitat on the Forest. If the Forest Service is so unprofessional in providing hard data about the supposed lack of early successional habitat in the state, and if this is compounded by the same kind of unprofessional treatment of the question of natural disturbances, then the Forest Service should not be surprised that people raise questions, like the one about why timber cutting on private lands, that is so much more extensive than on public land, does not provide sufficient habitat. It is the obligation of the Forest Service to provide this information (CEQ 1502.1 and 1502,14(a)), not the obligation of the public. It is also highly irresponsible to ignore the fact that the reason early successional habitat wildlife is on the decline in Indiana (if we can even believe that this is true) is because the numbers being used are highly inflated due to the presence of large amounts of artificially-created forest openings when the species were counted. The Forest Service claims, in response to public comment, that ruffed grouse and other early successional habitat dependent species are in decline. (FEIS p.213) PC #140: The lack of forest management on the Hoosier has resulted in a decline of ruffed grouse and other… Response to #140: Numerous reports indicate that many of the species that use early successional habitat are declining, including the blue-winged warbler, yellow-breasted chat, bobcat, eastern cottontail, northern bobwhite, prairie warbler, and ruffed grouse. Current habitat conditions on the Hoosier are a direct result of past management practices. Many biologists agree that population recovery for the ruffed grouse will not occur if forest succession continues to advance due to a lack of active forest management on public forestlands in south-central Indiana, especially on the Hoosier. Throughout the FEIS, the Forest Service references a paper referred to as Hunter et al. (2001). This paper is used many times to justify clearcutting the national forest in order to provide “early successional habitat” for certain bird species in Indiana. In the following e-mail, I.U. professor James Hengeveld, PhD, explains that the Hunter et al paper includes birds that 1). Are not found in southern Indiana and 2). Are not found in clearcuts: On Nov 11, 2005, Jim Hengeveld wrote: A few points about the IDNR paper by Castrale et al. They depend heavily on a paper by Hunter et al. (2001) for information about species of birds that are dependent on early successional habitats, forest disturbances, etc. Their Table 1 is based on the information in Hunter et al. About half of all of the species mentioned in the tables in Hunter et al. (Tables 3, 4, and 5) do not breed in southern Indiana. By far the majority of the species mentioned in the tables in Hunter are NOT known to use clearcuts in Indiana. In Table 1 in Castrale et al., the three asterisked species in the column headed by "Disturbance-maintained woodlands"--Mississippi Kite, Barn Owl, and Loggerhead Shrike are NOT known to use clearcut areas of any age. Of the four asterisked (all "special concern") species in the "disturbed forest" column, 2 of the species (Worm-eating Warber and Cerulean Warbler) are probably more common in forests lacking recent clearcuts than in areas with clearcuts. This might also be true of Black-and-white Warbler though I wouldn't know for sure. There are enough natural and anthropogenic disturbances in any forest to satisfy species that "require" disturbances; clearcuts are not necessary to generate further disturbances. What these clearcut areas do is generate more habitat for Brown-headed Cowbirds and for predatory small mammals. Both Brown-headed Cowbirds and small mammals then reduce the nesting success of forest-nesting species. I'll be happy to answer any further specific questions to the extent that I am able to. ..........Jim Hengeveld ------------------- James Hengeveld, PhD Biology Dept., Jordan Hall A112 Indiana University Bloomington, IN 47405 812: 855-5353 <mailto:jhengeve@indiana.edu>jhengeve@indiana.edu> It is obvious that neither the German Ridge DSFEIS nor the HNF Plan provide sufficient and convincing evidence that there is a need for more early successional habitat. Some of the claims that more early successional habitat is needed are based on the Hoosier-Shawnee Ecological Assessment, which has been successfully challenged in court based on FACA and needs to be revised (For more details on Heartwoods successful challenge of Hoosier-Shawnee Ecological Assessment see below, Chapter ???) Click here for part 6. Alternatives to Cutting and Burning for Creating Early Successional Habitat Not ConsideredProtect Our Woods
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