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June 5, 2007: EXECUTIVE SUMMARY - Hoosier National Forest German Ridge Restoration Project Appeal of Record of Decision(11) The Forest Service Neglected to Consider Alternatives to Creating Early Successional Habitat by LoggingNEPA requires that an agency consider reasonable alternatives to a proposed action, especially if those alternatives are less environmentally degrading. This even includes reasonable alternatives not within the jurisdiction of the lead agency.Yet the alternatives considered for German Ridge, as well as in the Hoosier National Forest Plan, always revolve around more or less cutting/burning. They are not truly alternatives, but variations on the one-dimensional scale of more or less cutting and burning, where all purposes and all needs are accomplished by ‘management’ and ‘treatments’ (logging) on the National Forest. Instead of further fragmenting the Hoosier National Forest to create more early successional habitat, we proposed purchasing suitable land on the edges of the National Forest. There are plenty of recently logged private forests and other private lands suitable for regenerating early successional habitat already available. After purchase, these lands could then be maintained as early successional habitat. Other ways to increase or maintain early successional habitat on private land would be purchasing conservation easements, providing incentives and education, establishing wildlife corridors, or formulation of Best Management Practices for private woodland owners regarding maintaining early successional habitat. None of those possibilities were explored by the Forest Service. (12) The Forest Service is Using a Timber Industry Rationale for Early Successional Habitats GoalsWhen the Forest Service claims 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, what is the standard according to which ‘lack of disturbance’ is measured?Where does the Forest Service come up with its goals for early successional habitat? The Forest Plan recommends that 4 to 12 percent of Management Area 2.8 should be in young hardwood stands in the 0 to 9-year age class. Why is it between 4-12 %, and no 2%, or 20%, or 35%? Or why isn’t the goal expressed in the increases in numbers of certain wildlife species, which are the intended beneficiaries of more early successional habitat? The reason for that seems obvious to us. Forestry industry experts have figured out that it is most economical to cut trees long before they reach their maximum age, so usually tress are cut when they are about 80-100 years old. Leaving trees that have reached the optimal age for cutting in the forest is a waste, according to timber industry economics. And to guarantee a continuous supply of timber, it makes sense to plant and cut trees in such a way that every year, or every decade, there is a certain number of trees that is ready to be harvested. At all times there are therefore trees in different age classes growing towards the harvest, and it makes sense to keep a certain percentage of them in the age class 0-9%. But is this age-class distribution something that would naturally occur in a multi-layered, highly differentiated old growth forest that displays different age classes in a fine-grained way? That is highly unlikely, given that trees, when not logged after 80-100 years, can grow hundreds of years old. And if, as the Forest Service claims, natural disturbances hardly make a dent in the forest, then there is no reason to think that it is in any way natural or ‘native’ that forest openings would have to make up 12 % of the forest. A much smaller percentage of trees would die and re-grow on an ongoing basis. Why then, should this timber-industry rationale provide the standard against which natural disturbances are judged as insufficient? We claim it is the timber industry standard that calls for a certain percentage of forest to be in each age class, and not the “decline” of certain wildlife species that have become dependent on the ‘disturbance’, and that of course then ‘require’ the remedy of timber ‘treatments’ to continue to provide sufficient levels of ‘disturbance’. Likewise, the restoration of native forests where there are pines now seems to be inspired by timber industry rationale. This is evidenced for example when the Forest Service states that deferring treatment on a large portion of the area until a later time would mean much of the wood could not be utilized and would instead just fall and add to the fuel loading. The natural process would be that older pines gradually die and fall over and rot in place. No human labour or machines are needed for this natural process to unfold. The Forest Service likes to refer to logging as “mimicking” natural processes. However, there is nothing “natural” about cutting trees down and logging them out of the forest. We surmise that getting the timber value out before the pines start falling and rotting is one of the true motives behind these cuts, in addition to the prospect of establishing higher value oaks for future commercial use. We question whether this is the best use of the National Forest, at a time when forests are still only a tiny fraction of what they used to be, when they are still highly fragmented, and when recreational use, and ecosystem and habitat functions become more and more valuable compared to the timber value of the forest. The habitat functions are especially important to consider when it comes to endangered species like the Indiana Bat. (13) The Forest Service Fails to Protect the Endangered Indiana BatHabitat for recovery of an endangered species is supposed to have the same force of law for protection as habitat for survival. The Indiana bat’s population has never reached the population numbers of 1967 when it was first listed. Timber sales, such as this one, where foraging, roosting, and swarming habitat will be removed will have a negative effect on the Indiana bat. Any negative effect is significant when the species is already endangered.This project therefore jeopardizes the continued existence of the Indiana bat, counter to the findings of the U.S. Fish and Wildlife Service (USFWS) and the claims by the Forest Service that replacing pines with native forests will benefit the species in the long run. The proposed benefits from more native forests will take many years to materialize. The adverse effects on Indiana bats from logging and burning, however, will take effect immediately, and will be long lasting. We provided the Forest Service with ample scientific evidence for that in previous comments, appeals, and in the current appeal. The Forest Service documents fail to point out that the population of Indiana bats has been increasing on the Hoosier and Shawnee where the Forest Service has not been logging much over the same time period. In other words, forest preservation, not “management”, has favored Indiana bats and furthered their existence. On the other hand, in forests with more extensive logging, the populations are decreasing. Taking into account that “no jeopardy” findings are now the only determination coming out of the present USFWS on every national forest plan in the region, at what point does the cumulative effect of all these plans result in jeopardy for the Indiana bat? The Forest Service’s own Manual requires that the forest planning process must “[e]nsure that the plan provides for the kinds, amounts, and distribution of habitat needed for recovery of threatened or endangered species.” FSM § 1922.15 (13) (emphasis added). “The Forest Service must manage habitats at levels that accomplish the recovery of Federally listed species so that protective measures under the Act are no longer necessary.” FSM § 2672.21 Nothing in the Environmental Impact Statement explains how this project will aid in the recovery of the Indiana bat. Instead of leaving habitat necessary for the Indiana bat’s survival, the Forest Service is cutting it down for trees what may only become good habitat decades later. (14) The Forest Service Downplays Pines as Bat Habitat and Fails to Give Importance to the Fact that Indiana Bats Were Found in the Project AreaAs elusive and rare as Indiana bats seem to be, still they were found in German Ridge pine trees. Yet the USFWS and the Forest Service say the pines have little value to the bat!In Response to Comment, p.33, the Forest Service writes: “Consequently, conversion of nonnative pines to a native hardwood forest type will unequivocally benefit the Indiana bat by improving the quality and availability of its foraging habitat.” This statement is untenable, as the evidence presented below clearly shows.
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