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October 16, 2003

Review of Notice of Intent - Part II

The Notice of Intent is the first step in the development of a Forest Plan. In Part II I'm going to discuss the "Preliminary Issues" identified in the Notice of Intent. Remember from Part I that all "significant" issues must be addressed in an environmental impact statement (EIS) and therefore you cannot prejudice the process by arbitrarily selecting a limited number of "Preliminary Issues" to narrow the scope of the EIS. Check out Part I for more on this.

Now as to the substance of the Preliminary issues identified, there is this to say. The Forest Service identifies four "preliminary" issues: Recreation, Habitat Diversity, and Special Areas Designations.

I'll discuss the full range of issues not mentioned further down. However, note at the outset that watershed management is not a key issue identified here. This is significant - the Allegheny National Forest was founded to conserve the navigable waters therein. You can view the original proclamation right here on our website.

Recreation
There can be no doubt that recreation is a significant issue for forest plan revision. The language in the notice of intent is sufficiently broad to allow for a wide array of recreation related issues to be discussed. If anything it is disappointing that the Notice of Intent doesn't do more to break down this issue as it does for other issues. That said, at this point the Forest Service is most definitely jumping the gun by getting too specific on the other issues.

Allegheny Wild! would fix this problem of course. When this five part series on the Notice of Intent is done we'll post an analysis of the mysterious recreation plan released without fanfare (or consistent with federal law for that matter) over the summer. We'll post it sooner if we get a chance.

Vegetation Management
The vegetative structure and composition of a natural forest is complex involving many flora species across an array of habitats (wetlands, uplands, old growth, opening) and within specific niches in each habitat (e.g. ground layer, shrub layer, mid-story, overstory). The Forest Service's Notice of Intent has reached new heights in oversimplifying the complex concept of vegetation management by equating vegetation management with timber production:

This issue involves maintaining healthy forest conditions capable of providing sustainable levels of forest products.

That really says it all. This apparently doesn't mean maintaining vegetative forest conditions to provide the habitats necessary to maintain viable populations of native species - even though this is clearly mandated by the National Forest Management Act (NFMA). And in case you were wondering the Notice of Intent clearly equates normal "forest products" with timber as it equates all non-timber "forest products" as "special forest products" as a sub-issue here.

Now the Forest Service wouldn't be expected to come out and say "We need to come up with ways to log unhealthy trees faster" but then they clearly do in the Notice of Intent: "There is also a need to develop guidelines for more timely and effective responses to insect and disease threats." This is verbatim of a typical timber sale projects purpose and need. It should be duly noted that the Notice of Intent surmises just before this section on "Forest health" that forest health threats are disproportionately affecting American beech and sugar maple. What we saw with the East Side Timber Sale and we are seeing with others in the pipeline is the notion that because American beech and sugar maple are susceptible to health problems they should be replaced with black cherry (we'll save the serious forest health problems of a black cherry dominated forest for another day). This is something to watch out for as this process proceeds.

The remaining subcategories are more of the same. The topics (with my shorthand on them in parentheses) are: Reforestation techniques (what kinds of herbicides, fertilizers, and fencing to use after clearcuts), timber production suitability (what kind of volume can be produced), and Silvicultural systems (how can even-aged logging be justified despite the NFMA's restrictions on its use). Most significant about all of this is the language was chosen carefully and reflects an unwillingness by the Forest Service to revisit its illegal black cherry tree farming in the Allegheny.

Habitat Diversity
I'll take one step back here because this is where this point belongs. In the previous section the Notice of Intent explains that "vegetation composition ... addresses the diversity of tree stands (particularly by species and age-class) on the Forest." That bold emphasis is my own. Chew on that sentence for a second. At first glance it may seem to make sense. Forest diversity is in many ways defined by the species of trees and various ages. However, here the Forest Service isn't talking about species and age within tree stands but rather between tree stands. How do I know this? Well, for one because it is consistent with how they treat the subject in other documents. But also because of their use of the phrase "tree stands" here compared to the use of the qualifiers of "species" and "age-class". This is entirely consistent with how the Forest Service functions, it just isn't consistent with the forest ecology perspective on biodiversity.

That was a long throw-back to the prior section. Within the habitat diversity section the Forest Service actually defines habitat diversity to include the maintenance of "desired non-native species" found on the forest. The maintenance of non-native species is unquestionably undesirable in nearly all cases here except where irradication of those species is not feasible and acceptance and adaptation are unavoidable. The major problem here is the equivalency given to certain non-native species which should never be the case. Even where non-native species might be maintained that should never be given equivalency to native species. But remember we are talking about a native forest that is supposed to be 86% Eastern hemlock-Northern Hardwoods but is now increasingly "Allegheny Hardwoods", i.e. black cherry.

There are several subsections here including threatened and endangered species, habitat for game species, habitat connectivity, and old growth habitat. Overall the descriptions of each specific subcategory are adequately broad to allow for appropriate measure to be adopted (within this already compromised framework, which isn't to say that would be sufficient). There are a few things I noticed however.

The most significant is where is the commitment to maintaining viable populations of native species? The Notice of Intent seems to limit concern to species already given protections such as Threatened, Endangered, or Sensitive ignoring the many species which are at risk but not listed (including untold invertebrates).

Another perhaps equally significant ommission is the failure to address aquatic habitats in any meaningful way. And this ties directly into the lack of a process for ensuring that both the quantity and quality of habitats are maintained. A lot of attention is paid from tree stand to tree stand but little attention seems to be given to maintaining quality habitats both across the forest and within specific forest stands. This probably reflects what I was talking about earlier with "tree stand" diversity across the forest instead of diversity within "tree stands."

Special Area Designations
As expected this section largely addresses Wilderness and Wild and Scenic Rivers. These are important issues and it is good that they are recognized here. However, this section is unnacceptably narrow.

National Recreation Areas, Research Natural Areas, Scenic Areas, and Heritage Special Areas are only mentioned in passing even though a new Scenic Area or Research Natural Area hasn't been designated in some 30 years. There are no identified Heritage Special Areas and apparently no attempts to identify Natural Areas or botanical areas. It is unclear to me what they mean by "Heritage" here: archeological or historical?

It is unclear what the Forest Service intends to do about other special designations such as state wild and scenic rivers, state wilderness trout streams, and stream designations under the Clean Water Act. In fact, the failure to give watershed management any serious consideration as a key preliminary issue is stunning. Not only is terrestrial "vegetative" management given its own prime position (why is management of animal life not given its own equal importance?) but aquatic management isn't given any mention that I can see in the habitat diversity section. The only mention here is the NFMA mandated issue of possibly designating Wild and Scenic Rivers. Now, in Part III you will see that watershed management is mentioned in the Notice of Intent but only in the section delegated to changes in the Forest Plan for "updates, corrections or modifications." That is hardly the pressing attention that I think President Coolidge might have expected when he signed the proclamation forming the Allegheny National Forest in 1923.

More on the Notice of Intent
Part I - Legal Issues
Part II - Preliminary Issues
Part III - Other Revision Changes
Part IV - Issues Not Addressed
Part V - Public Participation

Disclaimer: This is a quick review of the Notice of Intent to help folks understand the context better. Therefore, there may be significant pluses or minuses that are overlooked.

Posted by jkleissler at October 16, 2003 12:19 AM

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