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November 09, 2003

Review of Notice of Intent - Part III

"Other Revision Changes"

In Part II we discussed the four "Preliminary Issues" recognized in the Notice of Intent. We discussed how those four issues relied on an incorrect legal standard in order to avoid addressing significant issues such as watershed management and oil & gas management. Some of these issues, particularly watershed management and soils conservation, were relegated to the next section in the Notice of Intent titled "Other Revision Changes."

The statement in the Notice of Intent is that issues in the "Other Revision Changes" will only be addressed through "updates, corrections or modifications that will clarify or strengthen guidance provided in the plan." The implication is that only minimal adjustments will be made. In this part I will review the several issues listed and where appropriate discuss how they ought to be considered "significant issues".

Soil and Water Quality Monitoring
There will be some good adjustments made in this area such as the identification of a management area specifically for "riparian zones". However, with the designation of numerous forest streams as High Quality/Exceptional Value under the Clean Water Act and as Wilderness Trout Streams under state law and the wide variety of new information on aquatic habitats and biodiversity in the Allegheny National Forest it is hard to understand why the revision process would stop there. Millstone Creek was recommended for special designation by scientists due to its high biodiversity. It would foolish to think that management area prescriptions should be limited to the "riparian zone" while headwater areas remain within management areas where logging is emphasized.

It is odd (do I overuse this word?) that watershed management is not recognized as a significant issue. The Allegheny National Forest was founded with the purpose of protecting water quality. Adopting a management plan that reflects this original purpose is evidence of negligence at the hands of forest managers - particularly with the documented degradation of Salmon Creek and Grunder Run.

As for soils, the Forest Service totally fails to act responsibly here. There is no proposals for restoring soil health due to several decades of mismanagement combined with the degradation of soil health due to acid rain. With the decline of trees due to poor soil health driving most logging projects in the Allegheny National Forest it is inexcusable not to recognize soil conservation and restoration as a significant issue.

Heritage Resources
There are no designated Heritage areas. There are few management guidelines for protecting these areas. Management Area designations do not reflect Heritage Resources adequately. But the Forest Service will not consider "Heritage Resources" a significant issue. I can't say I understand this.

Scenery
The Forest Service is proposing a change to the way they protect visual quality. The current system simply comes down to protecting an occasional beauty strip to hide logging activities from drivers on the highways. What we've found with the current visual quality system is that it really does little, if anything, to protect scenic quality. If anything it ultimately contributes to scenic degradation by encouraging activities that degrade forest quality outside of the beauty strips.

From what the Notice of Intent says the Forest Service will use a new system that will change how scenic quality is "protected" without changing the emphasis of how it should be done.

What the "Scenery" item omits is actually adopting changes to the Forest Plan to actively manage for forest scenery. For example, as noted in Part II the Forest Service is not planning to adopt any new Scenic Areas even though there hasn't been a new Scenic Area in the Allegheny in over thirty years. Another important "Scenery" change to the plan would be a reorganization of management areas to emphasize management areas that protect the scenery throughout the forest and prevent areas of the Allegheny from having permanently scarred scenes. Another important aspect would be managing the forest to emphasize scenery (management of existing vistas, providing trails to natural vistas, providing interpretation of views including education about forest ecosystems). Again, this should be a significant issue that drives alternatives.

Transportation Systems
This has to do with forest roads. This is stunning. Nothing to address the overwhelming road densities in the Allegheny National Forest. There are 4,000 miles of roads and only 200 miles of non-motorized trails in the Allegheny. This represents an abusive management program. There are few issues in the Allegheny that are more significant. But there are no proposals for addressing the density of roads in the forest except to adjust limits in certain areas for future road construction. Nothing about removing unnecessary road. Nothing about protecting roadless habitats. Nothing about actually reducing road densities. This is what you might call "dodging the issue".

Monitoring
Monitoring in the Allegheny National Forest is a huge issue. The Forest Service monitoring and evaluation requirements are so vague that there is little requirement to ensure that monitoring is done in a fashion that produces data which is comparable from year to year. The result is that much of the monitoring in the Allegheny is useless in actually determining if there are new management problems developing in the forest. There is no place where this is a larger problem than in wildlife monitoring. The Forest Service is supposed to monitor population trends, but monitoring often uses different protocols from year to year and in many years monitoring is skipped altogether. Although monitoring is required for pesticides, impacts of logging and roads and water quality, and maintenance of viable populations of wildlife there is no clear protocol for how any of this monitoring is to be done and what thresholds of disturbance should be avoided. In short, monitoring methods are not scientifically sound, repeatable, or in some cases even measurable.

Management Areas
The "Management Areas" are the areas of zoning in the Allegheny National Forest. Today, for example, 2/3 of the Allegheny falls into the zoning area "Management Area 3.0" which calls for the use of even-aged logging techniques to increase concentrations of black cherry in the Allegheny National Forest. The distinctions between most management areas are what types of logging are allowed. But this is the poor basis for identifying management areas.

The Forest Service suggests that the emphasis in this area will be in revamping standards and guidelines for management areas instead of the distribution and types of management areas. This is inadequate. The Forest Service should be using data on watersheds, special area opportunities, wildlife habitats, recreational uses, roadless areas, soil and topographical typing, and other considerations in the identification of what kinds of management areas will exist and then distribute lands appropriately. This is exactly what ADP did in our Allegheny Wild! proposal and is much more consistent with what has been done on other national forests. A good example would be the designation of different management areas for the North Country Trail corridor or the Wild and Scenic River Corridors. Unfortunately we probably will not get past identifying and distributing management areas as a means of implementing a major timber program until commercial logging in the Allegheny National Forest is eliminated.

Economics
Here the Forest Service simply says that it will do a passive analysis on the impacts of forest management alternatives on regional economies. Of course, a good economic alternative would emphasize the sustainable economic industries which are most closely linked to the national forest, i.e. recreation and tourism. It doesn't appear that the Forest Sevrice is going to give economics proper consideration as a significant issue although they clearly should.

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

Posted by jkleissler at November 9, 2003 07:08 PM

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