Re: comments on 12/31/09 draft-please forward to TSC, bill
Joseph Zorzin
----- Original Message -----From: Fred HeyesSent: Tuesday, January 05, 2010 4:50 PMSubject: RE: comments on 12/31/09 draft-please forward to TSC, billDear TSC and AGSThe TSC has wandered way too far off the charge, and "taken the liberty" to include topics that while interesting are off course..this document is way too long and topics like private land, new commisioners, 132 etc distract from a clear presentation of the intended purpose. I suggest that the document should be 25 pages with a 3 page executive summary....much more than that and many will leave it unread....Line 394 ...opening land for subsistance agriculture in the early years can hardly be called "reckless..."Line 267....resources and timing....while this has been addressed in a very general and glossy manner, this highly critical topic has lost the essential attention it needed (perhaps from approaching to large a scope of wrok)A couple of general thoughts: reassigning field forestry and recreation staff to planning activities will not likely be successful....arent we honest about a cultural change???and as noted in the draft:..." creation of forest reserves without the necessary long-term ecological monitoring and use management is from the TSC’s perspective highly undesirable, and could result in reserves being degraded by unauthorized uses."(invasives, unmarked boundaries, gates, ecological monitoring etc.) Reserves have by my estimate a $22.00 / per acre/year carrying cost.Where is the funding????specifically...has anyone talked this topic over with the Commissioner???Where is the money? The draft suggests:" Development of funding must go hand in hand with the management recommendation outlined in this report and should itself be one of the highest and first priorities of the Commissioner." Taking on a gold standard for forestry , we must also approach the reserves and parks in the same fashion ...Where is the money???Forester liscensing by the way was a consumer protection law that aimed to protect landowners, and was really the result of one forester who stole over a quarter million dollars from landowners....Missing all along has been the discussion of how tourism and forestry can work well together and i have seen so much in europe and around the north quabbin..it is not about tourism and not forestry, it can be about the two working together.....The best way to conserve private forestland is to make management both economically attractive to landowners and a source of pride to the private landowner. Much of this process has worked to systematically degrade forestry and forest management effectively on all lands, including private forests, based on isssues with management approaches on DCR land that are not acceptable to the "Public".There really are a lot of "publics" out there, almost everyone seems to have a "public" to speak for..I support the 150 000 acre presentation which i thought was reasonable well received at the last meeting, and i am sure there is a"public" out there to support that onefred heyes
From: forestfutur...@googlegroups.com [mailto:forestfutur...@googlegroups.com] On Behalf Of Heidi Ricci
Sent: Tuesday, January 05, 2010 2:15 PM
To: forestfutur...@googlegroups.com; bi...@loguegroup.com
Subject: comments on 12/31/09 draftBill, I’d appreciate it if you would make sure that all the TSC members receive this, including any who aren’t signed onto the joint google group. Thanks.
Dear TSC and AGS
I have reviewed the 12/31/09 draft report and offer the following comments. I see some good aspects, some things I don’t agree with, and some important items that remain missing despite repeated previous comments from myself and others. Given that the TSC meeting is tomorrow, I am transmitting the following comments, focusing on aspects of the report that I think still need substantial revision. These are preliminary comments and should be considered in that context.
Regarding the questions posed to the TSC by Lisa at the beginning of the document, my comments are:
1. Ch. 132 Forest Cutting Regs – yes, I think the TSC should comment, at least to stress the importance of getting the regs that were drafted in 2007 out to the public for review and comment.
2. Yes, DCR should work closely with DFW on early successional management and in fact on all forest management – that is already mandated by law in Ch. 21 S. 2F but the provisions have never been fully implemented.
3. Yes, the report should include an appendix with backup on the Parkland and Woodland recommendations. Key pieces of Andy Finton’s presentation and spreadsheets showing the range of reserve options should be provided. You can acknowledge that further public process is needed to make final determinations, but include the good technical analysis that has already been presented. And it should include at least a preliminary list/spreadsheet of properties to consider for parkland status as well as the reserves. The more expansive option recommended by some members of the AGS should also at least be acknowledged and data on it provided in the appendices, even if the TSC decides as a group that is not your preferred option – and you need to poll the TSC on that because I know of at least a few members who support a more expansive approach.
The latest version reflects and addresses several comments made on the last version, and I appreciate those changes (e.g. the need for a new paradigm). Of necessity given time constraints these comments reflect areas needing more work:
1. The continued inaccurate statement that most of DCR’s land was in degraded condition when acquired. That may have been true of most State Forest lands acquired many decades ago but it is not true for many of the park and reservation properties, nor for all properties acquired in recently decades, many of which were acquired for the high ecological and scenic values.
2. Failure to address the requirements of the Massachusetts Endangered Species Act regulations that require more than minimizing harm, they require that management plans for state lands be designed for the BENEFIT of the rare species on those lands. This comment applies to all three zones.
- I’m also disappointed that the very basic facts of how much biodiversity DCR lands support have not been included. DCR land includes habitat for 291 state listed rare species (out of 435 total listed species – 67%). Eight listed species occur only on DCR land and are not known to occur anywhere else in MA. DCR lands support 68 natural community types. NHESP could provide the number of the rare species on DCR lands that depend on closed canopy forests if asked.
4. Lack of inclusion of available data showing that the economic value of outdoor recreation and tourism is in the billions of dollars in MA, representing $100s of millions of tax revenue, and that this is orders of magnitude above the economic value of forestry (see attached data compiled by Nan F.). Not that the value of forestry and timber production is insignificant, but the role of public lands in supporting recreation and tourism is a very high “ecosystem service” value and should be put in perspective using available numbers. I have the 1973 Statewide Outdoor Recreation Plan and it does a far more complete job presenting data on the growing demand for outdoor recreation across the state than this report does. Obviously the demand and need has increased greatly in the past quarter century, but this report gives only passing reference and no sense of scale. This is also important in relation to concerns about costs of managing state lands – that needs to be considered in the context of what these amenities contribute to the state’s economy, tax revenues, and quality of life.
5. Failure to address the duplicative, inefficient planning structure within DCR. The report calls for an improved planning process and better public involvement, but it makes no mention of Ch. 21 S. 2F, the problems that have arisen from having the BoF prepare Forest Resource Management Plans separate from the Resource Management Planning unit, etc. These are serious structural and government efficiency issues and a report that lacks recommendations to fix this is a big missed opportunity.
6. Management descriptions for parklands and reserves have too much silviculture/forestry related language and not enough ecological and park landscape management language. Intensive management around campgrounds and other high intensity recreation areas means something completely different than “management” in woodlands but this is not at all clear. And the management and restoration recommendations for reserves should focus on ecological management not potential use of “traditional siliviculture” where it will benefit rare species habitat. Even where (rare instances) some tree cutting might be needed to benefit rare species, the plans for the work and the methods used would most likely not resemble “traditional silviculture.” Management of pests and diseases that are already widespread in the landscape should be prohibited in reserves. So should “clean-up” after major disturbance events except in very rare instances where there is a real threat of wildfire on surrounding developed land. The emphasis should be on allowing nature to take its course, except in rare instances. The word-for-word adoption of EEA’s existing management recommendations for reserves fails to address the many public comments reflecting need for refinement of these guidelines.
7. Where is Kate Connolly’s legal analysis? This is important!
8. The addition of a “preferred” option for reserves above and beyond the “minimum” is an improvement, but there should also be the third alternative of at least 80% with recognition that many citizen and environmental stakeholders support that option while some members of the TSC do not. Stakeholders can’t force the TSC to adopt their position, but the report should at least reflect and explain the full range of views provided by the Stakeholders, especially those representing the general public values, which is a key item in the process goals.
9. An objective analysis of FSC pros and cons is warranted. Vague generalities about most TSC members acknowledging the “potential value of FSC Certification in advancing the ecosystem service goals outlined for DCR woodlands” is not useful.
Finally, some general comments. There is far too much wandering beyond the scope, goals and objectives established for this process. The committees were tasked with examining and making recommendations to protect all of the public values inherent in the public lands, and that should be the primary focus. Recommendations #1 and 2 exceed the scope of the assignment. While I agree with some of the ideas presented in those recommendations and disagree with others, my main concern is that they are a distraction from the intended purpose of this process: http://www.mass.gov/dcr/news/publicmeetings/forestryfvpgoals.htm
Recommendations 1 and 2 should be deleted or moved to an addendum, with only a brief reference to them earlier in the document.
Overall, the language needs to be considerably tightened up and the report made more succinct and concise. There is too much general descriptive language and not enough specifics.
The key terminology issues I raised in a previous communication (attached) have not been addressed. Logging doesn’t promote forest health, etc.
Heidi
E. Heidi Ricci
Senior Policy Analyst
Mass Audubon
208 South Great Road
Lincoln, MA 01773
781-259-2172
FAX 781-259-1089
hri...@massaudubon.org
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