June 5, 2007: EXECUTIVE SUMMARY - Hoosier National Forest German Ridge Restoration Project Appeal of Record of Decision

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June 5, 2007: EXECUTIVE SUMMARY - Hoosier National Forest German Ridge Restoration Project Appeal of Record of Decision

(18) The Forest Service Wrongly Claims That the Pine Plantations are Fragmenting the Forest

The Environmental Impact Statement (EIS) claims that the pine plantations are “fragmenting” the forest in the German Ridge area. However, we dispute that claim, and the record is inadequate to support the agency claim that the pines are indeed fragmenting the forest.

In order to assess populations of native species, the agency is required under the NFMA regulations to monitor the populations of Management Indicator Species, or MIS. These are supposed to give an indication of whether a particular habitat is healthy or not. If a habitat is fragmented, then that should show up in the MIS counts. There aren’t any MIS counts provided in the EIS, which is a violation of NFMA itself.

The EIS therefore provides very little site specific information to support the assertion that pines “fragment” the forest. .

But what is an even more serious omission is the failure of the agency to include site specific information that it had collected in the German Ridge area regarding the relative abundance of breeding birds in the German Ridge area. This data was collected by Indiana University students under contract with the Forest Service. According to a conversation with Hoosier official Ron Ellis, this data was not referenced or utilized in the preparation of the EIS for German Ridge. We are supplying it with this appeal to ensure that it is on the record.

These site specific bird counts collected on German Ridge generally do not support the contention that the pines are fragmenting the forest. For example, the relative abundance data found that scarlet tanagers, a deep forest interior species, were way above average. Almost all woodpecker species were above average. Northern Parula were above average, as was the Acadian Flycatcher, one of the MIS. These are all forest species.

Relative abundance studies still do not come close to telling the story of the health of the environment. In order to do any kind of useful analysis, reproductive success studies would have to be done as well. With the number of birds observed on German Ridge, the area could either be a good source for forest songbirds, or a significant ecological trap. Yet none of this is discussed in the EIS.

(19) Inadequate Cumulative Effects Analysis Regarding NNIS

While the Forest Service admits that there is a potential of introducing more NNIS into the “treatment” areas, and possibly also carrying them from the treatment areas to other areas, this potential is considered low regarding the fact that appropriate mitigation measures will be taken.

Our questions and issues remain:

Clearly the risk of spreading NNIS will increase, even if minimally, from disturbing and opening up more forest land.
The Forest Service admits that burning doesn’t necessarily take care of NNIS, but may have to be supplemented by hand pulling, which is labor-intensive and therefore expensive.
The Forest Service admittedly does not have enough money to deal with NNIS now! This issue, that we raised in our comments, is not addressed in Response to Comment.
A truly cumulative analysis has not been conducted. This would have to include the potential increase in spread of NNIS resulting from

increased disturbances on German Ridge,
plus disturbances on Mogan Ridge, Goosetown, Oriole and the Tell City Project,
in conjunction with disturbances created by projected increases in logging across the Hoosier National Forest according to the Forest Plan,
from salvage logging
and from disturbances on private lands, including disturbances resulting from development.

(20) Insufficient Evidence Regarding Blowdown

In our comments on the Draft Supplemental Environmental Impact Statement we raised the following issues regarding blow down.

The Forest Service considers the analysis area for blowdown to be the project area.
However, when an area is opened up by logging, microclimates and air flows change. This could lead to changes in areas outside the project area, especially considering the cumulative effects of increased logging

on state,
private, and
Hoosier National Forest lands according to Forest Plan,
as well as loss of forest cover due to development.

What are potential cumulative impacts from different projects? This question has not been answered.

(21) Insufficient Cumulative Effects Analysis Regarding Soil

Ironically, the logging proposed as part of the German Ridge Project would affect a stand of trees that were planted to stabilize the soil and reduce erosion. Now, the Forest Service proposes to take skidders, trucks, and other heavy equipment onto these soils and log all the trees that were planted for protection of the soils.

The Forest Service has responded to our concern about soil compaction as a result of logging by saying

- First, that measures will be taken to minimize – not eliminate - the compaction effects.

- Second, that soils in Indiana will recover within a time frame of 5-10 years.

- Third, that the compaction effects will be limited to less than 10% of the harvest area.

The fact that there are measures that can be taken to minimize effects, and that soils may eventually recover, and that effects are limited in area, do not by themselves address or eliminate the concern about compaction. There are still effects, and the effects differ between alternatives - and the no-action alternative doesn’t have any of those effects. A minimized effect can still be substantial. But where is the analysis of these differences between alternatives?

A cumulative effects analysis regarding compaction may reveal that any additional compaction, however minimal, is ill advised. It is the crux of most environmental issues that each single act contributing to the problem seems too small to be significant. Yet all those seemingly “insignificant” actions add up.

Here are some of the other issues/actions that should be looked at cumulatively with the German Ridge Project, because they have the potential to add many more compacted acres.

Hoosier National Forest Plan calls for extensive clear-cutting in some management areas.
There are increased cuts on Indiana state forests.
According to the Hoosier National Forest Plan, almost no area on the Hoosier National Forest is exempt from salvage logging.
Private forest lands are logged frequently.
The Hoosier National Forest is interlaced with private property, and subject to increasing pressures from residential development. How does all that contribute to compaction?
How much compaction - and impermeable surfaces - already exist in the area from past logging, construction, development?

In addition to compaction, there are concerns about the removal or loss of soil organic matter and nutrients, of impacts on stream flow and sedimentation, and mychorrizal associations.

Click here to continue to comment sections 22-24

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