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June 5, 2007: EXECUTIVE SUMMARY - Hoosier National Forest German Ridge Restoration Project Appeal of Record of Decision(8) The Forest Service Does Not Account For Natural Disturbances as Factors in Creating Early Successional HabitatNot only does the German Ridge Project promote the removal of pines to hasten the re-establishment of native forest communities, with special emphasis on Oak-Hickory. In addition, it claims another need that also has to be met by cutting trees - the creation of early successional habitat.In a model used for the Hoosier National Forest Plan, the Forest Service claimed that 150 years from now the age class 0-9 (early successional habitat) would be Zero for the no-logging alternative. In other words, what the Forest Service is claiming is that without logging, there would be no early successional habitat on the Hoosier National Forest, or, in other words, all those natural processes that create openings in the forest, like windthrow, drought, flood, diseases and insect damage, amount to nothing. However, severe storms damaged trees on 1600 acres on the Hoosier National Forest in 2004 alone. There is also the Tell City windthrow project that indicates a recent major natural disturbance. The Forest Service puts the average occurrence of natural disturbance as 1600 acres over 10 years. We would like for the Forest Service to disclose the “best available scientific information” on which the estimates of average natural disturbances are built. The Hoosier National Forest Plan does not disclose how many acres of forest may be affected by natural disturbances other than windthrow, like drought, flood, disease, and insects. Are those included in the average of 1600 acres over 10 years of natural disturbances, or would they have to be added? Diseases and insects may be killing trees on thousands of acres within a few years, as a White Paper from the Indiana State DNR shows (FOREST HEALTH PROBLEMS IMPACTING INDIANA FOREST RESOURCES by Philip T. Marshall, Forest Health Specialist, 2005) How can the Forest Service state authoritatively that we need more of this early successional type of habitat – to be established by logging - when there is no credible estimate of openings from natural disturbances? (9) There is an Insufficient Accounting for Early Successional Habitat in the RegionOur appeal states that the Forest Service has failed to conduct a cumulative, comprehensive, analysis with regard to assessing the availability of early successional habitat in the region. A comprehensive analysis would have to consider not just what is happening on German Ridge, but also in the following areas:
We requested that the planned creation of early successional habitat outside of the current German Ridge Project should be added in assessing cumulative availability and environmental effects of that habitat type. In response the Forest Service said this: “No additional project has been proposed on the Hoosier to move this project area toward the desired level of early successional forest habitat. …. Any thoughts about additional projects in the German Ridge area would be speculative and not reasonably foreseeable future actions.” Our question therefore still remains: How much more logging, and when, can we anticipate in German Ridge based on the M.A. 2.8 Management Guideline to achieve the desired level of early successional habitat? Obviously The German Ridge project is only meant to create temporary early successional habitat, since its prime purpose is to restore Oak-Hickory. If this is the case, then in the long-term there will be minimal changes in early successional habitat and associated species from this project. What percentage of the 12 percent will this project meet? How will the Forest Service “keep” any percentage of this project area in early successional habitat without more logging than revealed in the German Ridge Planning documents? And shouldn’t the effects of such additional logging be included in the cumulative environmental effects analysis for this project? (See more on that below) Furthermore, at the time that this proposal was given to the public the supposed “speculative” Oriole Project was no longer speculative. In fact, the EA was sent out to the public before this Environmental Impact Statement (EIS). Yet the Forest Service has still not included this project in the cumulative environmental effects analysis.
(10) The Forest Service is Showing an Illegal Bias Towards Creating Early Successional Habitat And Neglect in Considering Forest FragmentationWhile the Forest Service stresses the lack of early successional habitat, it downplays and virtually ignores the effects that forest fragmentation has on many forest interior species.The creation of more early successional habitat on the Hoosier, and in the German Ridge Project area, comes along with reducing the availability of unfragmented, large tracts of Hoosier National Forest land, and of habitat for interior forest species that are dependent on unfragmented forests for survival and successful reproduction. Numerous studies indicate the adverse effects of forest fragmentation in the Midwestern United States on forest interior birds. Heartwood, in its appeal of the German Ridge Final Environmental Impact Statement (FEIS), pointed out that the Forest Service is amiss in studying interior forest species and the effects on them from increased logging. The District has not performed site-specific surveys or obtained current population or inventory data on all the threatened, endangered, or sensitive species which may inhabit these areas. Nor has the District performed site-specific surveys for or obtained current population or inventory data on all the Management Indicator Species (MIS) in these planning areas. Nor are there adequate site-specific surveys and inventory data on the status and health of the aquatic species and biological communities in the streams in the project areas. The Forest Service does not identify the size, shape and character of the largest forest patches in the German Ridge area. What is the largest block of forest that can be enclosed in a polygon which contains no significant breaks in the canopy cover? Is it 300 acres? 500 acres? Less? More? What birds are located in the center of these patches, and are they reproducing successfully? Whether pines are native or not, clearcutting them will increase fragmentation of the forest! A proper analysis should explain how it can be desirable to create more of an already fairly plentiful habitat type that results from logging, at the cost of degrading habitat that exists in very few, if any other locations in the region – unfragmented forest. Commercial logging is common on the small, private woodlands in the region, and the State forests are logged more heavily than in the past. Yet, large, continuous tracts of forests are practically non-existing. Click here to continue to comment sections 11-14 Protect Our Woods
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