PA Sierra Club review of draft state forest resource management
plan (talking points below):
Click
here for major shortcomings
Click here for primary recommendations
Click here for secondary recommendations
The state forest plan prepared by
the Bureau of Forestry (BOF) is a lengthy document of background,
policies, objectives, and goals. It states a commitment to preserve biodiversity
all throughout the document.
However, the details in the plan fall short of providing
a realistic blueprint for accomplishing that.
One reason for this deficiency is the fact that the designation
of old growth, considerations of logging, concerns about watersheds,
fragmentation, and so on, all seem to be somewhat disconnected
from the science and the on-the-ground conditions. The deficiency
stems from the fact that there is no comprehensive environmental
impact statement analyzing these conditions. There is very little
biological science (as opposed to Silviculture "science")
utilized to develop the policies, goals, and objectives of the
plan.
The BOF is the steward of our public
state forests. Yet, in the plan, the BOF seems to ignore that
acid rain deposition is impacting our state forests. In addition, the BOF does not prescribe management
control of the overabundant white-tail deer herd other than prescribing
deer fencing in certain forest treatments. While the BOF does not control acid rain (EPA/DEP)
or the deer herd (Game Commission), it can and should be more
vocal about the impacts these problems have on the state forests
and seek out partnerships with the appropriate agencies to help
minimize the problems.
Another shortcoming of the draft forest plan
is the failure to provide for an environmental impact statement
and public review for activities that have the potential for significant
negative environmental impacts. Activities such as oil and gas
drilling, timber sales, mining, development of facilities and
road building should be required to go through a public process
that includes an analysis of alternatives to the proposed activity
and the associated impacts of each alternative. Currently, DCNR
decides what it wants to do, rather than study alternatives and
then give the public and opportunity to review and comment on
the alternatives. An EIS process is used for these kinds of activities
on federal lands, but not on Pennsylvania public lands.
The most important component of the
plan is that of establishing “old growth” management
zones. These are areas
of our state forests that will be set aside – hopefully in
perpetuity – to allow natural forces and influences to shape
the forest lands. The
Bureau of Forestry recognizes the benefits that old growth forests
can provide, but does not translate that into proactive planning.
The details of the Bureau’s old
growth management plan can be seen on the Proposed
Old Growth Areas map included with the plan. In part due to our continued state forest wild area campaign over
the last few years, the proposed old growth management zone includes
all of the state forest natural areas and almost all of the state
forest wild areas. Some good zoning is delineated on the mapping
such as a corridor surrounding the Mid State Trail through Rothrock
and Bald Eagle forest districts, expansion of a few wild areas,
and old growth designation for some medium size drainages in the
Tioga state forest district.
There are major shortcomings
in the proposed old growth management plan:
- It is not clear from the plan that old growth management zones
would be completely free from commercial timber harvesting. Several sections of the plan suggest that
silviculture “treatments” (read timber harvesting)
could “accelerate” the formation of old growth.
That is simply a misguided policy; we cannot expect forests,
let alone trees, to get older by cutting trees and impacting
the forest floor with these types of man-made disturbances.
If the BOF intends to create bigger trees faster through
selective cutting, then the intent is symptomatic of its failure
to incorporate biological (ecosystem) science in its planning.
Bigger does not equate with older; timber harvesting
interferes with the processes that old growth permits.
- As mentioned above, not all of our state forest Wild Areas
are included in the old growth management zones.
Quehanna Wild Area (Moshannon and Elk state forests),
our state’s first and largest wild area, is heavily fragmented
with sections that would still be subject to commercial timber
harvesting. The state’s newest proposed wild
area, the Squaretimber Wild Area (Elk State Forest), would receive
a similar fate with the BOF proposal.
Sadly, only a very small portion of the Quebec Run Wild
Area (Forbes State Forest) would be included.
- Inclusion of the state forest natural and wild areas in the
proposal accounts for roughly half of the goal of 20% of state
forest lands managed as “old growth”. The
other half is, unfortunately, comprised of much smaller, thinner,
and dispersed pieces of proposed old growth zones.
With few exceptions, this half of the Bureau’s proposal
are areas where commercial timber harvesting is not suitable
anyway – due to topography (slope), stream buffer zones,
and, as stated as a management criteria in the plan, aesthetic
buffer zones. The latter
is especially disturbing as the BOF would like to hide commercial
timber harvesting activities behind thin stands of big trees.
- Worse
yet, most of these thin strips of proposed “old-growth”
would be along existing paved and unpaved roads which, while
allowing the driving tourist to see big trees, does not allow
for functional old “forests”. It is bad enough to have thin strips of
“old-growth” zones thus allowing natural and manmade
disturbances to have significant potential to disrupt the entire
tract, but the proximity of roads to these old-growth stands
would allow more invasions of exotic pests and plants and an
increased potential of man-made wild-fire.
- The
BOF proposal does little to further protect our existing state
forest natural areas with buffers of protected old-growth management
zones. Except where natural areas happen to lie
within the larger wild areas, most of the natural areas would
still be subject to edge fragmentation with commercial timber
harvesting.
- The
BOF proposal does not go far enough to connect large core-areas
(natural and wild areas) with permanently protected old growth
corridors. The biggest example of this is that there
is no connecting old growth zone between the protected natural
and wild areas surrounding the Pine Creek gorge of Tioga and
Tiadaghton forest districts and the large wild areas in the
Susquehannock and Sproul forest districts.
Similarly, there is no significant corridor connecting
the wild and natural areas of the Bald Eagle Forest District.
There is a great potential to allow a real framework
of interconnected wildlands in the state forest system that
is not realized with the BOF proposal.
Primary Recommendations:
Ø All
state forest Wild Areas should be fully protected with old growth
management zoning.
Ø Old
Growth management zones should guarantee permanent protection
of forests with a complete removal of commercial or “salvage”
timber activities.
Ø Existing
Natural areas and Wild areas should be expanded and new areas
created to include a diversity of habitat types.
Ø Old
Growth management zones should be connected with wide, protected
corridors.
Ø BOF
should undertake an environmental impact statement process that
includes public input for all activities that have the potential
for significant environmental impacts.
Secondary Recommendations:
Ø Old
Growth management zones should be delineated to protect larger
tracts of forest lands than those currently proposed.
Buffer zones and smaller tracts of forest delineated for
other purposes than should not be counted by BOF as old-growth
acreage.
Ø The
BOF should fully inventory and plan for the sustainability of
all plants and animal species in the state forest system, not
just the propagation of commercially desirable tree species.
Ø The
BOF should be a more vocal advocate for the protection of state
forests by recognizing and advocating remedies to all of the threats
to forest lands, including acid rain deposition and an overabundance
of White Tail Deer.
Ø Old
Growth management zones should be applied to areas that are the
most remote and undeveloped, and not applied simply to create
visual buffers from commercial timber operations in the more interior
portions of our forests.
Ø Old
Growth management zones should be expanded around state forest
Natural areas and Wild Areas.
Ø No
new ATV trails should be developed on state forest lands.
