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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 8c. Are Logging and Fire the Right Tools to Restore Oak Hickory?As to the effects of drought and other environmental stresses:(Ecology: Vol. 79, No. 1, pp. 79–93. THE ROLE OF STRESS IN THE MORTALITY OF MIDWESTERN OAKS AS INDICATED BY GROWTH PRIOR TO DEATH Brian S. Pedersena)). “Three-fourths of the dead trees had growth patterns prior to mortality that included growth declines indicative of inciting stress. The median intervention resulted in a 38% decline in basal-area growth rate. The interventions were more likely to occur during environmentally stressful years, with five drought years accounting for 40% of the interventions experienced by the dead trees. Prior to experiencing interventions, the now-dead trees were growing an average of 18% slower than comparable surviving trees, indicating the action of predisposing stresses.” Even the Forest Service researchers themselves have seen the connection between drought and decline of oak hickory: Oak Decline Philip M. Wargo,1 David R. Houston,2and Leon A. LaMadeleine Forest Insect & Disease Leaflet 165 U.S. Department of Agriculture Forest Service “The initiating stress factors associated most frequently with oak decline are drought, frost injury, or insect defoliation. Trees on ridge tops and in wet areas suffer most severely from drought.” Frost often affects trees growing in valleys and frost pockets. Defoliated trees that refoliate the same season may exhibit dieback symptoms the next year. Other factors such as leaf diseases and soils that are waterlogged, compacted, or shallow have occasionally been implicated in oak decline. Waterlogging is especially important in the heavier clay soils of the Midwest.” “These stress factors often weaken trees so much that they succumb, sometimes suddenly, to the root killing and girdling actions of insects and diseases. The two major pests associated with oak decline are Armillaria mellea (Vahl: Fr.), a root disease commonly called armillaria root rot, and Agrilus bilineatus (Weber), the two-lined chestnut borer.” “In the forest, factors such as drought and frost cannot be controlled.” The last point illustrates why the Forest Service would fail to mention drought and frost as playing a role in oak hickory decline: They cannot control drought by logging, which is the real intent of this Forest Plan. Lastly, we have searched the document for any information on the role of the decline of the American Chestnuts and its effect on forest composition, particularly, Oak Hickory. While the EIS mentions the American Chestnut as a tree species that disappeared because of a pathogen, the Forest Service does not analyze a possible consequence of the disappearance of the Chestnut. That animals are eating more oak and hickory mast because of the disappearance of chestnuts, and that this may be one possible reason for oak-hickory decline, is left out of the HNF EIS. How is it possible that the entire Forest Plan AND Ecological Assessment that purports to discuss history and subsequent forest composition fail to properly assess the consequences of losing a tree species that was dominant in the region and is now practically extinct? Probably because they would have to tell the public that the oak hickory was not the real dominant tree in the southern Indiana landscape, but rather the American Chestnut, which they cannot purport to bring back by logging, since it is virtually extinct. Looking at the data in the Forest Plan on the amount of Oak Hickory we can expect over the next 150 years brings us to question the methodology used to come up with these numbers. Table 3.10 in the HNF FEIS (page 3-104) shows oak hickory in Alternative 2 at the 50 year mark to be only 4,000 acres less than in Alternative 5. Then, at year 150, the level of Oak Hickory slides to only 63,570 acres in Alternative 2, but is 87,610 in Alternative 5. There is no explanation as to why this is the case. The Forest Service recommends prescribed burning and logging to bring back Oak Hickory. In the case of German Ridge, they are proposing to cut pine trees to “restore” Oak Hickory. However, they never evaluated an alternative that would burn the understory and not log the large, older, oak hickory stands, which provides the seed stocks. They do not evaluate an alternative that would plant oak hickory in the understory to help bring back more oak hickory. The Forest Plan and therefore the German Ridge Project Plans rely heavily on the 2005 Seifert paper to make its case that clearcuts bring back oak hickory forests. However, this study does not present empiricial evidence on pre-study amounts of oak hickory to prove that they are in decline. Also, there isn’t evidence that the oak hickory will come back as the dominant tree. Yet all of these Plans are resting on this assumption: that oak hickory need to be clearcut in order for them to not disappear, and that clearcuts are the best way to bring them back. In fact, a previous study on the Hoosier, Fisher et al, 1987, showed that other species outgrow oak seedlings and sprouts in clearcuts, and that without further TSI work to “weed” out the oak trees, there will be a reduced oak component in stands following clearcuts on the Hoosier. This is a very expensive proposition, and as stated in greater detail below, was not revealed in the economic analysis. A very large problem with the Forest Plan is that the Forest Service is trying to convince the public that if we don’t log and burn the forest, the beech maples are going to take over the oak hickory trees. This gives the impression that somehow beech maple trees are capable of attacking the oak hickory and wiping them out. This is not the case. The reality is that perhaps after oak hickories die they may be replaced by beech maple trees. However, oak hickory trees last for hundreds of years if allowed to grow. Most of our forests in Indiana are not more than 80 years old. In other words, the succession may not happen for hundreds of years, if at all. Plus, oaks have an advantage over beech maple on drier ridge tops. Therefore, while they may not be the climax species in valleys, they will not disappear from the forest as long as there are ridge-tops. Since management area prescriptions were intentionally vague (explored below in greater detail), we have no way of knowing if the Forest Service has incorporated this insight into the Forest Plan. Considering the above evidence, it seems obvious that this German Ridge project is an attempt to log on the Hoosier under the guise of ecological restoration. Logging as a prerequisite for restoration of oak-hickory stands however is questionable because the success of the attempted restoration of hardwoods is not scientifically proven. Evidence is available from close by. For example, there are pine projects very similar to this that were conducted on the Shawnee National Forest in the early to mid 90s done under the guise of regenerating hardwoods. The results have been mixed and very unpredictable. Results have ranged from “bizarre” things happening, like autumn olive taking over the understory of this pine plantation, to really thick regeneration of trees in the openings, but with a healthy pine component. If the pines are thinned heavily enough, the result may be a thicket that people can hardly walk through, including vines, briars, etc. Also, the weight of science does not support this contention that clearcutting will result in oak regeneration. In fact, the Hoosier Shawnee Assessment, as flawed as it is, even admits that experience has shown that oaks have usually become overgrown by faster growing species such as tulip trees and maples after clearcutting. In fact, most studies, including the well known 1987 Fisher study done on the Hoosier, indicate this fact. THE PLAN AND EIS’S CLAIMS REGARDING LOGGING AND BURNING IMPROVING OAK REGENERATION ARE NOT SUPPORTED BY THE RECORD The science on fire and oak regeneration is unconvincing. As stated above, there are numerous studies, including the McGee study, which indicated that red maple increased after burning, the study which showed that burning and gap creation did not increase oak regeneration, in part because deer were browsing the post fire sprouts. Another study, by Abrahms and others concluded that without determining the root collar diameter and location, plus the root depth of small trees, plus calculating in the severity of the fire, that it is impossible to predict what the outcome of a prescribed fire will be. Yet, there are no standards and guidelines to collect this kind of information prior to burning. In fact, if the types of activities, from TSI to detailed pre-burn surveys, were done and collected prior to and after burning in order to make sure that oak hickory was dominating the understory, the cost of such operations would increase significantly, affecting all economic and relative value analysis. But without such information, there is a strong possibility that goals and objectives of the plan’s proposed actions won’t be met. Relying on such flimsy assumptions, and not considering the full range of science on oak regeneration is not in compliance with NFMA or NEPA. The Need to Evaluate Past Logging Operations On the Hoosier One of the best indications of how something will work in the future is how it has worked in the past. The Forest Service is proposing intensive logging in many areas of the Hoosier National Forest. One of the excuses for logging in some areas is to “restore native hardwoods” in areas where the government had previously planted nonnative pine trees to restore eroded soils. The Forest Service has had experience in the past with native hardwood restoration, namely on the French Ridge and Eastside Pine – Native Hardwood Regeneration projects. However, nowhere in the HNF FEIS do we see an evaluation of either the success or failure of these projects, Where is the evaluation of what the Forest Service has done before? The Forest Service must do a monitoring and evaluation program. From the Table 4.2, Page 4-6, From the Hoosier LRMP: Monitoring Requirement: “To what extent are management, natural disturbances, and subsequent recovery processes changing the vegetative composition, special patterns, and structure? Are conditions moving toward short-term and long-term objectives?” Residents of counties near the French Ridge and Eastside Pine—Native Hardwood Regeneration projects have given first hand accounts of what the areas looked like before and after logging. According to resident Andy Mahler (from e-mail, April, 2006): “Regeneration was so bad on part of the French Ridge project that they had to have the boy scouts come in for a tree planting, despite there having been real good regeneration of hardwoods before the sale. The damage to the residual stand in the Eastside sale was appalling, virtually every hardwood tree damaged in some way and extensive compaction (first sale on the Hoosier logged with feller bunchers, brought over from Ohio for the sale to Mead Paper company in Chillicothe OH, 200 miles away -- first sale on the Hoosier in almost 10 years -- a money loser for Mead according to reports I heard.” The EIS is full of plans to log pines in order to restore native hardwoods. If this was tried in the past, then according to the Forest Service’s monitoring requirements, the public should have been told how and if it worked. In addition, if feller bunchers caused so much damage in the past, then why wasn’t this disclosed in the Forest Plan and included in an analysis of cumulative effects? If the agency would like to convince the public of the need for logging pine in order to regenerate hardwoods, a full disclosure of the effects of these logging operations should have been presented in the HNF and German Ridge EIS’s.As to the effects of drought and other environmental stresses: (Ecology: Vol. 79, No. 1, pp. 79–93. THE ROLE OF STRESS IN THE MORTALITY OF MIDWESTERN OAKS AS INDICATED BY GROWTH PRIOR TO DEATH Brian S. Pedersena)). “Three-fourths of the dead trees had growth patterns prior to mortality that included growth declines indicative of inciting stress. The median intervention resulted in a 38% decline in basal-area growth rate. The interventions were more likely to occur during environmentally stressful years, with five drought years accounting for 40% of the interventions experienced by the dead trees. Prior to experiencing interventions, the now-dead trees were growing an average of 18% slower than comparable surviving trees, indicating the action of predisposing stresses.” Even the Forest Service researchers themselves have seen the connection between drought and decline of oak hickory: Oak Decline Philip M. Wargo,1 David R. Houston,2and Leon A. LaMadeleine Forest Insect & Disease Leaflet 165 U.S. Department of Agriculture Forest Service “The initiating stress factors associated most frequently with oak decline are drought, frost injury, or insect defoliation. Trees on ridge tops and in wet areas suffer most severely from drought.” Frost often affects trees growing in valleys and frost pockets. Defoliated trees that refoliate the same season may exhibit dieback symptoms the next year. Other factors such as leaf diseases and soils that are waterlogged, compacted, or shallow have occasionally been implicated in oak decline. Waterlogging is especially important in the heavier clay soils of the Midwest.” “These stress factors often weaken trees so much that they succumb, sometimes suddenly, to the root killing and girdling actions of insects and diseases. The two major pests associated with oak decline are Armillaria mellea (Vahl: Fr.), a root disease commonly called armillaria root rot, and Agrilus bilineatus (Weber), the two-lined chestnut borer.” “In the forest, factors such as drought and frost cannot be controlled.” The last point illustrates why the Forest Service would fail to mention drought and frost as playing a role in oak hickory decline: They cannot control drought by logging, which is the real intent of this Forest Plan. Lastly, we have searched the document for any information on the role of the decline of the American Chestnuts and its effect on forest composition, particularly, Oak Hickory. While the EIS mentions the American Chestnut as a tree species that disappeared because of a pathogen, the Forest Service does not analyze a possible consequence of the disappearance of the Chestnut. That animals are eating more oak and hickory mast because of the disappearance of chestnuts, and that this may be one possible reason for oak-hickory decline, is left out of the HNF EIS. How is it possible that the entire Forest Plan AND Ecological Assessment that purports to discuss history and subsequent forest composition fail to properly assess the consequences of losing a tree species that was dominant in the region and is now practically extinct? Probably because they would have to tell the public that the oak hickory was not the real dominant tree in the southern Indiana landscape, but rather the American Chestnut, which they cannot purport to bring back by logging, since it is virtually extinct. Looking at the data in the Forest Plan on the amount of Oak Hickory we can expect over the next 150 years brings us to question the methodology used to come up with these numbers. Table 3.10 in the HNF FEIS (page 3-104) shows oak hickory in Alternative 2 at the 50 year mark to be only 4,000 acres less than in Alternative 5. Then, at year 150, the level of Oak Hickory slides to only 63,570 acres in Alternative 2, but is 87,610 in Alternative 5. There is no explanation as to why this is the case. The Forest Service recommends prescribed burning and logging to bring back Oak Hickory. In the case of German Ridge, they are proposing to cut pine trees to “restore” Oak Hickory. However, they never evaluated an alternative that would burn the understory and not log the large, older, oak hickory stands, which provides the seed stocks. They do not evaluate an alternative that would plant oak hickory in the understory to help bring back more oak hickory. The Forest Plan and therefore the German Ridge Project Plans rely heavily on the 2005 Seifert paper to make its case that clearcuts bring back oak hickory forests. However, this study does not present empiricial evidence on pre-study amounts of oak hickory to prove that they are in decline. Also, there isn’t evidence that the oak hickory will come back as the dominant tree. Yet all of these Plans are resting on this assumption: that oak hickory need to be clearcut in order for them to not disappear, and that clearcuts are the best way to bring them back. In fact, a previous study on the Hoosier, Fisher et al, 1987, showed that other species outgrow oak seedlings and sprouts in clearcuts, and that without further TSI work to “weed” out the oak trees, there will be a reduced oak component in stands following clearcuts on the Hoosier. This is a very expensive proposition, and as stated in greater detail below, was not revealed in the economic analysis. A very large problem with the Forest Plan is that the Forest Service is trying to convince the public that if we don’t log and burn the forest, the beech maples are going to take over the oak hickory trees. This gives the impression that somehow beech maple trees are capable of attacking the oak hickory and wiping them out. This is not the case. The reality is that perhaps after oak hickories die they may be replaced by beech maple trees. However, oak hickory trees last for hundreds of years if allowed to grow. Most of our forests in Indiana are not more than 80 years old. In other words, the succession may not happen for hundreds of years, if at all. Plus, oaks have an advantage over beech maple on drier ridge tops. Therefore, while they may not be the climax species in valleys, they will not disappear from the forest as long as there are ridge-tops. Since management area prescriptions were intentionally vague (explored below in greater detail), we have no way of knowing if the Forest Service has incorporated this insight into the Forest Plan. Considering the above evidence, it seems obvious that this German Ridge project is an attempt to log on the Hoosier under the guise of ecological restoration. Logging as a prerequisite for restoration of oak-hickory stands however is questionable because the success of the attempted restoration of hardwoods is not scientifically proven. Evidence is available from close by. For example, there are pine projects very similar to this that were conducted on the Shawnee National Forest in the early to mid 90s done under the guise of regenerating hardwoods. The results have been mixed and very unpredictable. Results have ranged from “bizarre” things happening, like autumn olive taking over the understory of this pine plantation, to really thick regeneration of trees in the openings, but with a healthy pine component. If the pines are thinned heavily enough, the result may be a thicket that people can hardly walk through, including vines, briars, etc. Also, the weight of science does not support this contention that clearcutting will result in oak regeneration. In fact, the Hoosier Shawnee Assessment, as flawed as it is, even admits that experience has shown that oaks have usually become overgrown by faster growing species such as tulip trees and maples after clearcutting. In fact, most studies, including the well known 1987 Fisher study done on the Hoosier, indicate this fact. THE PLAN AND EIS’S CLAIMS REGARDING LOGGING AND BURNING IMPROVING OAK REGENERATION ARE NOT SUPPORTED BY THE RECORD The science on fire and oak regeneration is unconvincing. As stated above, there are numerous studies, including the McGee study, which indicated that red maple increased after burning, the study which showed that burning and gap creation did not increase oak regeneration, in part because deer were browsing the post fire sprouts. Another study, by Abrahms and others concluded that without determining the root collar diameter and location, plus the root depth of small trees, plus calculating in the severity of the fire, that it is impossible to predict what the outcome of a prescribed fire will be. Yet, there are no standards and guidelines to collect this kind of information prior to burning. In fact, if the types of activities, from TSI to detailed pre-burn surveys, were done and collected prior to and after burning in order to make sure that oak hickory was dominating the understory, the cost of such operations would increase significantly, affecting all economic and relative value analysis. But without such information, there is a strong possibility that goals and objectives of the plan’s proposed actions won’t be met. Relying on such flimsy assumptions, and not considering the full range of science on oak regeneration is not in compliance with NFMA or NEPA. The Need to Evaluate Past Logging Operations On the Hoosier One of the best indications of how something will work in the future is how it has worked in the past. The Forest Service is proposing intensive logging in many areas of the Hoosier National Forest. One of the excuses for logging in some areas is to “restore native hardwoods” in areas where the government had previously planted nonnative pine trees to restore eroded soils. The Forest Service has had experience in the past with native hardwood restoration, namely on the French Ridge and Eastside Pine – Native Hardwood Regeneration projects. However, nowhere in the HNF FEIS do we see an evaluation of either the success or failure of these projects, Where is the evaluation of what the Forest Service has done before? The Forest Service must do a monitoring and evaluation program. From the Table 4.2, Page 4-6, From the Hoosier LRMP: Monitoring Requirement: “To what extent are management, natural disturbances, and subsequent recovery processes changing the vegetative composition, special patterns, and structure? Are conditions moving toward short-term and long-term objectives?” Residents of counties near the French Ridge and Eastside Pine—Native Hardwood Regeneration projects have given first hand accounts of what the areas looked like before and after logging. According to resident Andy Mahler (from e-mail, April, 2006): “Regeneration was so bad on part of the French Ridge project that they had to have the boy scouts come in for a tree planting, despite there having been real good regeneration of hardwoods before the sale. The damage to the residual stand in the Eastside sale was appalling, virtually every hardwood tree damaged in some way and extensive compaction (first sale on the Hoosier logged with feller bunchers, brought over from Ohio for the sale to Mead Paper company in Chillicothe OH, 200 miles away -- first sale on the Hoosier in almost 10 years -- a money loser for Mead according to reports I heard.” The EIS is full of plans to log pines in order to restore native hardwoods. If this was tried in the past, then according to the Forest Service’s monitoring requirements, the public should have been told how and if it worked. In addition, if feller bunchers caused so much damage in the past, then why wasn’t this disclosed in the Forest Plan and included in an analysis of cumulative effects? If the agency would like to convince the public of the need for logging pine in order to regenerate hardwoods, a full disclosure of the effects of these logging operations should have been presented in the HNF and German Ridge EIS’s. Click here for Failure To Consider Reasonable Alternatives to Logging For Oak-Hickory RestorationProtect Our Woods
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