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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 Forest

9.    Failure To Consider Reasonable Alternatives to Logging For Oak-Hickory Restoration

NEPA requires that an agency consider reasonable alternatives to a proposed action, especially if that alternative is less environmentally degrading.

The German Ridge Plan identifies increasing the oak hickory component and regeneration of oak hickory as a major objective. It provides a number of controversial and environmentally damaging alternatives as how this might happen, even though the science isn’t at all certain that it will work.

Yet, much less environmentally damaging alternatives, such as planting oak seedlings in the understory - when oak regeneration is lacking, and there is some evidence that site conditions are appropriate for oaks -  aren’t even considered.

There are other alternatives, such as the very judicious use of fire when conditions are right, which might also work with less impacts than cutting down large trees.

In German Ridge, that could for example include controlled burns in areas with dead and fallen pines. It could also include planting oaks and hickory in early successional habitats created by dying and fallen pines.

Yet every alternative that purportedly focuses on oak regeneration identifies logging as the major management tool to accomplish the goal.

Even though we don’t agree that the FS should be focusing on forcing the woods to produce oak, we do believe that if the agency is going to do this, that it should consider the least environmentally damaging alternatives, and failure to do so is not consistent with NEPA’s mandate.

The DSFEIS does not present a no-timbering alternative to re-establishing Oak-Hickory communities.  No-timber need not be identical with no-action  (Alt. B), since other actions besides timbering may be taken to achieve the “purpose and need”, assuming the purpose and need is valid .

Click here for Cumulative Effects Analysis Is Still Insufficient  Part 1 of 4

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