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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 ForestPart 7a. The Questionable Need of Restoring Oak HickoryFrom the German Ridge Restoration Project FEIS 50:“Natural communities in the Crawford Upland Section are mostly upland forests. An assortment of oak and hickory species is found on upper slopes, while mixed mesophytic species (plants that grow in relatively moist conditions) are found in coves (Homoya et al. 1985) and northerly exposed slopes (Braun 1950). According to Braun (1950), the mixed mesophytic forests in southern Indiana are similar to those found further south, but they lack the diverse herbaceous layer, have a lower frequency of buckeye (Aesculus octandra) and basswood (Tilia americana), and contain a greater abundance of American beech (Fagus grandifolia) and sugar maple (Acer saccharum). Along with American beech and sugar maple, the overstory is also dominated by tuliptree (Liriodendron tulipifera), black walnut (Juglans nigra), white oak (Quercus alba), northern red oak (Q. rubra), and shagbark hickory (Carya ovata) (Braun 1950). Xeric habitats (relatively dry sites) are dominated by an overstory of white oak, black oak (Q. velutina), northern red oak, shagbark hickory, and pignut hickory (C. glabra). Subdominant overstory species in uplands often include mockernut hickory (C. tomentosa), shellbark hickory (C. laciniosa), and white ash (Fraxinus americana).” The “purpose and need” of the German Ridge project is to restore more “natural” native hardwood forests with an increased oak hickory component. However, as one can readily see above, the Forest Service itself is admitting that the natural communities in southern Indiana are actually not dominated by oak hickory, but are a mixed mesophytic forest, with an overstory dominated by beech and maple. Oak hickory seems to occur on dry upper slopes. Nevertheless, the Forest Service is pushing ahead to “restore” oak hickory forests. The way they purport to do this is to cut non-native pine and some hardwood trees (685 acres) and burn the logged over areas plus other areas (a total of 2, 170 acres) after logging. The restoration of oak hickory forests is a questionable need (which we do not concede) since there is no basis to claim that a particular extent of oak hickory is “natural” or “historic.” There is, however, evidence that the extent of oak hickory that the Forest Service is attempting to bring back was the result of heavy logging in the past. The forests in Indiana were more likely a mix of beech/maple and other species, depending on site conditions. Is the Forest Service pushing oak restoration because oaks are more commercially valuable? One of the key justifications they use for commercial logging on the Hoosier National Forest is a perceived emergency decline in oak-hickory forest. This decline will supposedly be bad for species diversity. The forecast is that within a generation, the oak-hickory forests would be replaced by maple-beech forests, a process known as succession. The only way to stop this decline is by cutting down the forests using “even-aged treatment” or clearcuts, ranging from 10 to 40 acres in size, in combination with a prescribed burn program. German Ridge FEIS page 2: “Without active intervention, maple, beech and other shade-tolerant tree species would replace the existing pine stands over the next 100 years (Shifley and Woodall In Prep.). A unique opportunity to effectively re-establish the native oak hickory community will have been lost. Restoration of this natural community is important, because it serves a broader array of plants and animals than the more shade-tolerant maple and beech forest type that is replacing the oak-hickory community. Oak-hickory communities are continuing to decline in Indiana (Shifley and Woodall In Prep.). In general, the purpose of this proposal is to enhance the diversity of plant and animal communities in southern Indiana by restoring two unique communities that are disappearing—the barrens community and the native oak-hickory community.” The German Ridge project justification therefore echoes the Hoosier LRMP (Page B-9) with regard to Oak Hickory regeneration, which states: “Without ecological restoration in the form of silvicultural techniques, oak systems will continue to decline (in terms of species richness and ecological function), converting from oak to mesophytic forests within a generation. Native wildlife species dependent on trees producing large-seeded acorns and nuts may be imperiled (Nowacki and Carr in press). To maintain the oak component, silvicultural systems need to be matched to the site characteristics combining harvest systems with regeneration treatments such as prescribed burning.” From the HNF FEIS, page 3-81: “Due to natural succession and limited management, sugar maple and American beech are increasing in stand density and basal area at the expense of the oak-hickory overstory throughout the Hoosier.” This theory and the subsequent “management prescriptions” in the HNF Plan, and in the German Ridge Plan that is tiered to the HNF plan, have numerous problems: 1. The Forest Service is basing its conclusion about a need for Oak Hickory Regeneration on biased science. In particular, throughout the HNF FEIS, the evidence for the oak hickory situation was referenced back to an article titled, “Current and Historical Forest Conditions and Disturbance Regimes in the Hoosier-Shawnee Ecological Assessment Area” by George R. Parker and Charles M. Ruffner, a chapter from the 2004 Hoosier-Shawnee Ecological Assessment. 2. In a judgment in the case Heartwood v. U.S. Forest Service, 1:02-cv-01898-RWR, from the U.S. District Court of the District of Columbia, filed 04/21/2006, Judge Richard Roberts ruled that the Forest Service had both illegally withheld documents from Heartwood, and violated the Federal Advisory Committee Act in the development of the Hoosier-Shawnee Ecological Assessment. This decision was not appealed and the decision stands as final. As stated above the Forest Service relied heavily on the Hoosier-Shawnee Ecological Assessment in the promulgation of both the Shawnee and Hoosier Revised Forest Plans, including such controversial aspects as substantially increased logging and burning (under the guise of “ecosystem restoration, as in the German Ridge Project), creation of extensive acreages of early successional habitat, and failure to designate any additional wilderness areas. 3. In the judgment, the court ruled that the team of hand-picked, contract scientists, which the Forest Service retained to complete the ecological assessment, should have been subject to the regulations of the Federal Advisory Committee Act (FACA). Under the FACA regulations meetings should have been listed in the Federal Register and open to the public, and the public should have had the right to provide input into the process. The meetings were not publicized and were not open to the public. This is in spite of the fact that many tens of thousands of dollars of public money were spent on this committee which held numerous meetings, including at least one in Terre Haute where the Forest Service handpicked non-committee members from outside the agency to attend, while otherwise excluding the public from the process. 4. The Forest Service is in violation of the judge's ruling. Despite the fact that the issue of non-compliance with these legal public involvement requirements was brought to the Forest Service's attention during the comment period for the revised plans, the Forest Service has thus far refused to re-open the process to provide the required public involvement. In fact, just the opposite appears to have occurred. Both the Hoosier and Shawnee are proceeding with controversial projects, such as this German Ridge commercial logging and large scale prescribed burning project. We believe that to proceed with such potentially harmful projects that are based in large part on the Hoosier-Shawnee Ecological Assessment is inappropriate and illegal. 5. The right thing to do in this case is to refrain from large scale projects, such as the logging and burning in the German Ridge area of the Hoosier National Forest, until these issues are resolved. In addition, the Forest Service has: 1. Disregarded the history and context which has brought us to the current situation with regard to Oak-Hickory. 2. Portrayed the situation as very cut and dry, with a very simple and straightforward solution, when in fact the situation and solutions are very complex; 3. Given references that support their position, and leaving out references that point to other conclusions, leading to an arbitrary and capricious bias toward logging and burning; and, 4. Attempted to justify the logging of oak hickory to save oak hickory as a smokescreen for the real issue: that oak trees are considered very valuable for the commercial timber industry. Then the question becomes, should the public forest be sacrificed for the needs of the timber industry? Click here for part 7b. The Questionable Need of Restoring Oak Hickory Part 2 of 2Protect Our Woods
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