response to Message from Lisa Vernegaard

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Heidi Ricci

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Dec 7, 2009, 5:22:08 PM12/7/09
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Here is my feedback on Lisa’s request for suggestions on how to focus the meeting on Wednesday.

 

My overall comment is that the entire report needs to be discussed in the joint meeting because this is the first opportunity the AGS has had any opportunity to see any parts of it or provide feedback to the TSC.

 

That said, here are areas I believe need strong attention and where there are significant gaps:

 

1.      Introduction and statements of purpose/issues to be addressed.

Structure of report needs to be clearly linked to the goals and objectives identified at the start of the Vision process:

http://www.mass.gov/dcr/news/publicmeetings/forestryfvpgoals.htm

-          In particular, more information and analysis is needed on the recreational and biodiversity resources within the DCR lands, and the issues of conflicts between these values and forestry.  The words recreation and biodiversity are mentioned in the report but there is no context about what these mean or how they relate to forestry.

-          The problems and concerns that led to the Vision process need to be clearly articulated and then the recommendations showing how they address the concerns.

 

Key sub-aspects needing discussion and better articulation in the report:

o   Integrated management planning required by statute Ch. 21 S. 2F vs. recommendations for modifying a forestry-focused planning process.  There is some good language in the report about the need to unify and make more integrated the management planning process, and to better incorporate public input.  However, I think the focus is still too much on forestry and not enough on really understanding the recreational, scenic, and biodiversity issues at hand (see third bullet below on biodiversity).  The discussion in Recommendation #9 that the Vision process was “necessitated by public outcry over a relatively small number of forest management decisions,” combined with the statements about the need to “educate the public” about silviculture indicate that the systemic problems that got us here in the first place are not understood.  It is not enough to say that public and stakeholder input was sought and accepted into the process.  The report needs to document main themes of concerns raised in order to show the problems have been heard and then link recommendations to those concerns.  The issue of district level vs. site specific plans needs to be discussed and addressed further.

o   Ch. 132 vs. 132A lands and the report summary repeating the statement many have objected to about much of DCR lands having originally been acquired in degraded state with a goal of re-growing forests.  I object to the repetition in the report of DCR’s unsubstantiated claim that “most” of the public forestlands were acquired to rehab lands that had been poorly managed or abused.  There has been no attempt to objectively examine the history of land acquisition, why we have two different statutes for state forest acquisition vs. parks and recreation acquisition; or even consider the fact that many properties acquired long ago as parks or reservations were in pretty good condition when acquired, or that many properties acquired more recently were acquired because of the high ecological, scenic, and/or recreational values.  There is no mention of the thousands of miles of trails, or the many other recreational features and facilities on DCR land (even though DCR has a paragraph about this that could easily be cut and pasted in), nor of the many other kinds of habitats imbedded within forested lands (rivers and streams, lakes and ponds, fields and other openings, mountaintops, rocky outcroppings, etc. etc.).

o   Ch. 131A Mass Endangered Species Act and the fact that DCR has a responsibility to do more than minimize harm to rare species, it has a proactive responsibility to management for the benefit of these species.  There is no discussion in the report of the 291 rare species found on DCR land nor to find out from NHESP how many of these are forest dependent vs. dependent on other habitats or how many would benefit from forestry vs. those that might be harmed by forestry.  The issue simply wasn’t studied at all, other than to recognize that the best way to maintain the full range of native biodiversity is to significantly expand the forest reserves (but that needs to be stated more explicitly).  Maybe this report can’t go into the details, but there should be explicit recognition of the tremendous diversity of habitats and species on DCR lands, that some will thrive best with a hands off approach and others need active ecological management, and all should be guided by plans with input from NHESP for the benefit of rare species and habitats under state stewardship.

 

  2.       Recommendations for improved public input.  There are some good recommendations here, and some I don’t think are high priorities.   More clarity is needed in recommending how DCR should unify its management planning to truly address and balance resource management, recreation, and forestry as well as all other interests inherent in public lands. Also more about public process for review specific projects going forward.  And on recommendations for management of parklands, what is meant by consultation with “park stewards”?  Who are they? How identified and contacted?  What about people who may not live nearby but have an interest in a property or the public lands in general?  What is the process?

 

3.         Resource protection and stewardship.  Too much generalities, we need more specifics including specifics on process when resources are newly identified after a plan has been written.  Involve citizens in vernal pool certification.  Work with qualified volunteer experts to better document cultural resources and rare species habitats.

 

Which sections need least discussion?

 

The report strays beyond its appointed scope in the degree to which it delves into issues of private forestland protection and management and recommends creation of a Commissioner of Forests.  This both detracts from the need to address issues related to management of the state lands clearly and directly as was the task of this process, and risks derailing implementation by making broad proposals affecting many interests who were not at the table in the discussions.  Nor is this the right time to propose creation of a whole new department in EEA when the state is looking to conserve resources through consolidations.

 

If any of this material must remain in the report, it should be condensed and moved to the end of the recommendations, in the context of here is the role of the public lands and how we recommend you manage them, but we recognize most forests are in private hands so here are some other issues we recommend EEA look at through some other process (there a whole statewide assessment being written up for compliance with the Farm Bill – that is where this kind of analysis should be taking place).

 

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
If you support our public policy initiatives, advocacy positions & environmental projects, join over 100,000 other people as a Mass Audubon member at: www.massaudubon.org

 

 

 

 

From: Bill Logue [mailto:Bi...@LogueGroup.com]
Sent: Friday, December 04, 2009 5:52 PM
To: forest-futures-advisor...@googlegroups.com
Subject: Message from Lisa Vernegaard

 

Below is a message from Lisa Vernegaard concerning the meeting on the 9th. Have a great weekend, Bill

 

 

Members of the Advisory Group of Stakeholders:

 

I and the rest of the Technical Steering Committee look forward to hearing from you on December 9th.

 

To help us make best use of this meeting, we would like to get an early sense of which sections require the most discussion, and which require the least.  It would be very helpful if, by mid-day on Tuesday the 8th, if you could send the facilitators your answers to the following questions:

 

  1. Which sections or issues of the report need the most discussion?  Please tell us your top three choices.
  2. Which sections or issues require the least discussion?  Please tell us your top three.
  3. Where are there significant gaps?

 

I’ve also asked Bill to facilitate the meeting in a way to make sure that we are hearing the full breadth of input from all interest groups which I understand to be:

 

  1. Citizen stewards
  2. Environmental organizations
  3. Foresters/landowners
  4. Government/Economic Development/Cultural
  5. Recreational.

 

Thanks in advance for your time and your review of our discussion draft.  I and the rest of the TSC are looking forward to hearing your input on Wednesday.

 

Best,

 

Lisa

 

 

 

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Nan Finkenaur

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Dec 8, 2009, 12:30:36 PM12/8/09
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Hello Bill and Lisa,
Below is my response to Lisa’s request on the meeting focus for tomorrow. I agree with Cathy Kristofferson’s and Heidi Ricci’s comments as important areas to discuss, as well.

  1. a) An overarching issue—The public outcry over DCR timber harvesting brought about this Forest Vision Process, not a few isolated incidents made worse by a public lacking “education” on silvicultural practices. This report should outline the problems that got DCR here, and then provide solutions. Poor quality work, lack of concern/value for ecosystem services besides timber, and broken public trust are among the problems to solve here. A great deal of time and money has been spent on this process. If we ignore the elephant in the room, it will not go away.

        
b) Recommendation 6: PARKLANDS— I am extremely concerned that selling of timber or allowing in-kind services from parklands will drive continued problems similar to what we are trying to solve with the Vision Process. For example: DCR proposal to sell 100 acres of oak/hickory in Boxford to remove 11 acres of red pine; also road construction to support the logging presented as in-kind services, which would benefit the logger and not benefit recreational trails or vernal pools in the area. The problem at Robinson came from the same approach. This is exactly what we DO NOT WANT in our parks. I am concerned about language regarding active management in parklands (lines 1073-1077, 678-679), and that commercial timber sales in our parks will fund maintenance (even if it is not called commercial.)
            More specific language is needed to suggest appropriate Parklands—in conversations, Heather Clish mentioned criteria that defined Parklands as forests within 10 miles of densely populated areas. This is a good criteria as a start. I like adding build-out and sprawl data from Audubon’s Losing Ground study since this shows us where things are headed. In addition to already-developed areas, the sprawl areas should be where we protect as much public land as possible against future loss of natural lands.

        c) Recommendation 1: ELEVATED ROLE for MA FORESTRY in Governmental hierarchy. I cannot support this recommendation. The problem that brought us to the Vision Process was forest management that prioritizes timber extraction over other ecosystem services. This will worsen the problem! This recommendation is in conflict with the excellent recommendation to broaden expertise of planners for our forests to include specialists in forest ecology, recreation, and global warming (Recommendation 8). As lines 1471-1473 says, there is a perception that planning activities by DCR has been driven by silvicultural considerations. This organizational change would exacerbate the problem, and is not part of the original process goals. This section was not part of the process goals.

2. a) Recommendation 2: Policies for Privately owned Forests
    b) Recommendation 8: DCR Organizational Structure


3. Gaps
    -Loopholes allow for logging in both parklands and reserves throughout the report. Close them. Regaining public trust is critical going forward.

    -I am concerned about the length of this document. Language throughout the report should be less ambiguous. Repetition obfuscates the report. The same material is covered repeatedly, leaving recommendations too far open to interpretation for real value. Add a table of contents. Eliminate language condescending to the public. The report is off-putting for general public comprehension and comment.

    -There is no position on biomass. While some language encourages leaving woody debris, recommendations on this topic are critical to review by stakeholders.

    -Where is the legislative mandates writing (Recommendation 10)? This is important to review.
    
    -Specific recommended amounts of land set aside for parklands, reserves, and woodlands must be established. More parklands should be recommended. More reserves should be recommended, with not so much emphasis on acquisitions. Limit public lands made available for commercial timber harvesting.


Nan



On 12/4/09 5:52 PM, "Bill Logue" <Bi...@LogueGroup.com> wrote:

Below is a message from Lisa Vernegaard concerning the meeting on the 9th. Have a great weekend, Bill
 
 
Members of the Advisory Group of Stakeholders:
 
I and the rest of the Technical Steering Committee look forward to hearing from you on December 9th.
 
To help us make best use of this meeting, we would like to get an early sense of which sections require the most discussion, and which require the least.  It would be very helpful if, by mid-day on Tuesday the 8th, if you could send the facilitators your answers to the following questions:
 
  1. Which sections or issues of the report need the most discussion?  Please tell us your top three choices.
  2. Which sections or issues require the least discussion?  Please tell us your top three.
  3. Where are there significant gaps?

I’ve also asked Bill to facilitate the meeting in a way to make sure that we are hearing the full breadth of input from all interest groups which I understand to be:
 
  1. Citizen stewards
  2. Environmental organizations
  3. Foresters/landowners
  4. Government/Economic Development/Cultural
  5. Recreational.

Thanks in advance for your time and your review of our discussion draft.  I and the rest of the TSC are looking forward to hearing your input on Wednesday.
 
Best,
 
Lisa


 
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hri...@massaudubon.org

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Dec 8, 2009, 12:39:00 PM12/8/09
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Lisa and all

Claudia's computer has crashed. She has been compiling input from numerous people and will try to bring it to the meeting tomorrow.

Meanwhile, those of you who have sent comments to Claudia and want your comments seen by all, please forward them to the joint TSC AGS list.

Heidi

E. Heidi Ricci
Senior Policy Analyst

Massachusetts Audubon Society


208 South Great Road
Lincoln, MA 01773
781-259-2172
FAX 781-259-1089
hri...@massaudubon.org
If you support our public policy initiatives, advocacy positions & environmental projects,
join over 100,000 other people as a Mass Audubon member at:

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hri...@massaudubon.org

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Dec 8, 2009, 2:37:49 PM12/8/09
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A couple of other topics I think are important for tomorrow that may or may not have been mentioned by others:

1. FSC including relationship to this process (eg the Commissioner said the district plans may be modified based on the Vision recommendations - how does that relate in terms of both timing and substance to FSC certification? Also, SCS asked for more explanation of the rationale for early successional cuts - has the state's response been submitted and will we and the general public be able to comment on it? There are several other interrelated aspects that need discussion as well as general concerns about FSC raised by other stakeholders which I think are important to discuss.)

2. Biomass

Heidi

)

E. Heidi Ricci
Senior Policy Analyst
Massachusetts Audubon Society
208 South Great Road
Lincoln, MA 01773
781-259-2172
FAX 781-259-1089
hri...@massaudubon.org
If you support our public policy initiatives, advocacy positions & environmental projects,
join over 100,000 other people as a Mass Audubon member at:
www.massaudubon.org <http://www.massaudubon.org>


Date: Tue, 8 Dec 2009 17:39:00 +0000
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Mike Ryan

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Dec 8, 2009, 8:19:59 PM12/8/09
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A. COMPROMISED PROCESS: Refusal to identify root cause of DCR forest management crisis: 

1)    The MODR facilitators never required that the TSC identify and examine the root causes of the DCR forest management crisis which led to breakdown in public trust.

2)    MODR facilitators allowed DCRto determine the goals and objectives of the (Forest Futures) process and how the outcomes will be used.” [TSC Draft, Introduction]”  In recent TSC meetings DCR and EOEEA representatives have taken an active role in TSC discussions, according to Bill Logue, “to help TSC make its recommendations.” (TSC meeting 11/10/2009)

3)    MODR facilitators allowed a paid consultant for DCR and former long-term DCR employee to lead discussion of DCR management policies and draft future management proposals.

4)    Views expressed to TSC – including stakeholder input –not conforming to the dominant aggressive forest management paradigm are totally marginalized or ignored by the TSC and its MODR advisors.

 

B. TSC DRAFT RECOMMENDATIONS REFUSES TO RECOGNIZE DCR FOREST MANAGEMENT CRISIS – BLAMES THE PUBLIC; LAYS BASIS TO STRENGTHEN POLICIES FOR WIDESPREAD LOGGING

The drafter of the TSC report has concocted a false narrative regarding ‘what went wrong’ with DCR management of our public forests.  On this basis groundwork will be laid for continuation of aggressive state forestry policies.

1)    The draft TSC Recommendations refuses to admit ecological damage has been caused by DCR clear-cutting of thousands of acres and increased logging of public forests 400%-700% over historic levels.

Instead the draft attempts to create the myth that public problems with DCR management stem from an abundance of “silvicultural considerations” (1471) and lack of enough of DCR “educating the public about forest values, forest management, and silviculture.” (1517) And the need for DCR to “…educate the public regarding the threats to Reserve ecosystem services that catalyze management actions…” (1537)  The draft calls for a “dramatic increase” (by the very agency which has ruined countless acres by unjustified logging) to “provide forest education to the public.” (1646)


2) Damage control and spin.

 Not surprisingly, the draft states there was never a problem with DCR forest management in the first place.  No, the draft states that the “public outcry” (1682) was due to just a few management decisions which stemmed from the public not understanding that “even the best of silvicultural practices”(!) will include hard to understand visual impacts that need to be explained by DCR. (1696)

In preliminary notes to the draft TSC Recommendations Tom Walker attempted to marginalize the problem of DCR management decisions as simply not being acceptable to “a vocal component of the general public.” (Walker draft note, 11/20/2009)

 

3)    Science rejected.

The TSC had no discussion of how the Bureau of Forestry pervasive culture of aggressive logging for scientifically unsupported 'forest health benefits' (eg., see ‘silvicultural prescription’ descriptions in Master Logging Plans and silvicultural prescription desciptions in each of the District Forest Management Plans) led to the very problems of fragmentation, soil compaction, invasives, soil nutrient disruption, loss of carbon sinks, and damage to habitat and social values which the Forest Futures process is supposed to address. 

Instead of science-based analysis, the TSC is being urged to endorse a continuation of the Bureau of Forestry’s aggressive forestry policies based on ecologically unjustifiable claims that public forests must be silviculturally manipulated to the maximum extent possible.

The draft Recommendations;

·          Asserts the need to clear-cut for “early successional habitat” in seven separate places in the report;

·           • Includes recommendations for wholesale clear-cutting of five acre+ sites of pines (even in Reserves!);

·           • Promotes ¼ – ⅓  acre “group selection” clear-cuts as the norm,  never mentions importance of “single tree selection” or mimicking old growth characteristics for positive impact silviculture;

·          •  Permits in-kind timber services in parklands despite widespread citizen anger over these practices;

·          •  Elevates to “essential” timber production values, and creation of “large scale” forestry management 'demonstration' sites, in Woodlands zones;

·          •  Fails to acknowledge ecological science which clearly shows that forest management activities themselves can prove harmful to the health and diversity of forest ecosystems; for example introduction of invasive plants due to group tree harvesting methods, soil compaction and nutrient loss;

·          •  Reduces the amount of proposed reserves to a minimal level solely to allow for maximization of access to public forests (Woodlands zones) for active forest manipulation;

·          •  Leaves Woodlands zones totally unprotected from access for energy extraction from biomass and wind power complexes;

·          • Excludes 110,000 acres of DCR managed watershed lands from consideration as protected reserves

 

4)    Elevating agency power and control

In the absence of any discussion of how the deficient qualities in the culture and principles of the DCR led to the crisis of public confidence in its forest management it is amazing that the very first recommendation contained in the draft TSC report is for an elevated role for DCR forestry management!


What is left out of this framework is discussion of how the Bureau of Forestry pervasive culture of aggressive logging intervention for scientifically unsupported 'forest health benefits' led to the very problems of fragmentation, soil compaction, invasives, soil nutrient disruption, loss of carbon sinks, and damage to habitat and social values which the Forest Futures process is supposed to address. 

5)    Rubber stamp approval of FSC in TSC Recommendations draft ignores ample evidence provided to TSC of widespread ecological destruction of DCR forests which occurred under FSC watch; continuation of FSC will ensure that industrialization standards will be allowed on maximum number of DCR forest acres.

 

Mike 

  

 

Dave Gafney

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Dec 8, 2009, 8:23:04 PM12/8/09
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I have a number of hearings tomorrow at 1 PM in Pittsfield Juvenile Court and so will be unable to attend.  I had begged Bill not to hold this on Wednesday, but he explained to me that because this was the only day that Andy Fenton could be there, this would be the day of the joint meeting.  This bothers me greatly because, with due respect to Andy, his views do not reflect what I, and I think many others on the AGS believe, regarding the amount of land that should be set aside in reserves.  I also think that the idea that half of the proposed reserves are supposedly on state land that has not yet even been acquired further undermines Andy's proposal.  I have been trying to read the 52 page report while working my law practice during this past week and have read most of it, but not as intensely as I would have liked. These are some of my thoughts:

1.       There is a huge discrepancy between what the TSC is proposing within this report regarding the amount of reserve land (and as mentioned above, too much of what is being proposed is pure conjecture – state land that is not yet acquired by the state).  I would remind everyone that most of the land purchased over last 20 years has not been for state parks or forests, but rather for DFW wildlife management areas and, therefore, are beyond the stated jurisdiction of this “vision” process.  I can only assume that future land purchases will follow this pattern.  The final report has to significantly move in the direction of a very large portion of our state lands being set aside for values other than timber production.  The proposals have to come far closer to what the AGS reserves working group has proposed - proposals which thus far have largely been ignored by the TSC.

2.       Regarding reserves and parklands, there are too many loopholes – some large enough to drive a buncher- feller machine through.   The philosophy and mission of both the National Park Service and of the 1964 Wilderness Act contain no such loopholes.  The natural world does not need man to manage it, it does fine on its own.  Any exceptions to the no logging rule in reserves and parklands have to be very specifically articulated.  Sadly, some foresters will use any excuse as an opportunity to cut heavily - we certainly should have learned this lesson in recent years.

3.       Regarding Woodlands, there needs to be very strict language regarding when even-age management is allowed. I hate to sound like a broken record, but I will repeat that the Save America's Forests Act is universally co-sponsored by our entire federal congressional delegation – the 10 congressmen and two US senators have to answer to their constituencies and this universal support should provide us with a solid idea of where political and public sentiment is regarding the issue of even-  verse uneven-age management within our state.  This proposed law forbids even-age management on federal public lands with a few very well-articulated and very specific exceptions.  Regarding our Massachusetts forests, such an exception might be for an infected and dying red pine plantation properly diagnosed by a mycologist or plant pathologist; another might be heavy thinning in a pitch pine-bear oak woodland where past fire control has allowed a dangerous fuel load to develop.  In other words, the exceptions have to be tightly articulated while the general rule should be that uneven-age management or single tree selection is the allowed silvicultural technique.

4.       As mentioned in an earlier e-mail, FSC certification should be jettisoned.  It is a program that was originally meant for corporate-industrial timberlands and it has failed to encourage ecologically and aesthetically sensitive forestry practices even on these lands.  It truly should not be applied to our state's public lands.  The very abuses which have brought us to the table primarily occurred during the period of time in which our state's public lands have been “green” certified.

5.       I don't know why TSC decided that forest management should be elevated to a cabinet level position, creating a whole new unnecessary bureaucracy, but it is a recommendation that should be removed from the report.  Having graduated from the UMass forestry program, I truly feel that foresters are not  well trained in the area of ecology and certainly are not experts on all those other social and cultural values for which we have public lands.  I agree with Nan who stated, The problem that brought us to the Vision Process was forest management that prioritizes timber extraction over other ecosystem services. This will worsen the problem!  This recommendation is in conflict with the excellent recommendation to broaden expertise of planners for our forests to include specialists in forest ecology, recreation, and global warming (Recommendation 8). As lines 1471-1473 says, there is a perception that planning activities by DCR has been driven by silvicultural considerations. This organizational change would exacerbate the problem, and is not part of the original process goals. This section was not part of the process goals.”

6.   I have looked through some of the earlier documents sent out during the early stage of this MODR process and cannot find where it was stated early on that watershed lands would be excluded from this process. The Quabbin, with its 80,000 acres of land and water is the one place within our state where a truly large reserve could be established (of 50,000 acres or more).  It has only been within recent TSC meetings that it

has become known to me that watershed lands, even though they are DCR owned and managed - are not included in this process.  Why is this?  What possible reason is there to exclude such a large area of DCR land from these proceedings?  

7.       I am in complete agreement with comments made today by a number of people including Cathy Kristofferson, Claudia Hurley, Jane Winn, Mike Ryan and Nan Finkenaur.

As the report is presently written, I cannot lend my signature to it or support it.

Dave Gafney

Joseph Zorzin

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Dec 8, 2009, 9:46:06 PM12/8/09
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Mike, you are sounding like a heretic! You are not showing sufficient faith in the forestry Holy Mother Church!  You must cast out that devil in you or you shall be excommunicated! It seems that the official Church sponsored exorcists have failed you!
Joe

Joseph Zorzin

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Dec 8, 2009, 10:06:23 PM12/8/09
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----- Original Message -----
Sent: Tuesday, December 08, 2009 8:23 PM
Subject: Re: Message from Lisa Vernegaard

I have a number of hearings tomorrow at 1 PM in Pittsfield Juvenile Court and so will be unable to attend.  I had begged Bill not to hold this on Wednesday, but he explained to me that because this was the only day that Andy Fenton could be there, this would be the day of the joint meeting.

 

***** Andy must have a very, very, very busy job- conserving nature- too busy to have a more flexible schedule.

 

  This bothers me greatly because, with due respect to Andy, his views do not reflect what I, and I think many others on the AGS believe, regarding the amount of land that should be set aside in reserves.

 

***** Well, Dave perhaps if you had a boss who owned 100,000 acres of timber, you also might not crave significantly more reserves.

 

  I also think that the idea that half of the proposed reserves are supposedly on state land that has not yet even been acquired further undermines Andy's proposal. 

**** must be on his Christmas list- Santa will grant such wishes, won't he?

 

 I have been trying to read the 52 page report while working my law practice during this past week and have read most of it, but not as intensely as I would have liked.

 

**** probably a lot more boring than your law books

 

 These are some of my thoughts:

1.       There is a huge discrepancy between what the TSC is proposing within this report regarding the amount of reserve land (and as mentioned above, too much of what is being proposed is pure conjecture – state land that is not yet acquired by the state).  I would remind everyone that most of the land purchased over last 20 years has not been for state parks or forests, but rather for DFW wildlife management areas and, therefore, are beyond the stated jurisdiction of this “vision” process.  I can only assume that future land purchases will follow this pattern.  The final report has to significantly move in the direction of a very large portion of our state lands being set aside for values other than timber production.  The proposals have to come far closer to what the AGS reserves working group has proposed - proposals which thus far have largely been ignored by the TSC.

***** ignored by 90% of the TSC

 

 

2.       Regarding reserves and parklands, there are too many loopholes – some large enough to drive a buncher- feller machine through.   The philosophy and mission of both the National Park Service and of the 1964 Wilderness Act contain no such loopholes. 

 

***** and the timber industry still hates John Muir

 

 The natural world does not need man to manage it, it does fine on its own.  Any exceptions to the no logging rule in reserves and parklands have to be very specifically articulated.  Sadly, some foresters will use any excuse as an opportunity to cut heavily - we certainly should have learned this lesson in recent years.

3.       Regarding Woodlands, there needs to be very strict language regarding when even-age management is allowed. I hate to sound like a broken record, but I will repeat that the Save America's Forests Act is universally co-sponsored by our entire federal congressional delegation – the 10 congressmen and two US senators have to answer to their constituencies and this universal support should provide us with a solid idea of where political and public sentiment is regarding the issue of even-  verse uneven-age management within our state.  This proposed law forbids even-age management on federal public lands with a few very well-articulated and very specific exceptions.  Regarding our Massachusetts forests, such an exception might be for an infected and dying red pine plantation properly diagnosed by a mycologist or plant pathologist; another might be heavy thinning in a pitch pine-bear oak woodland where past fire control has allowed a dangerous fuel load to develop.  In other words, the exceptions have to be tightly articulated while the general rule should be that uneven-age management or single tree selection is the allowed silvicultural technique.

**** But, the Bruce has declared that single tree selection shall be verboten! only mini clearcuts will now be allowed in uneven age silviculture- you must obey!

 

 

4.       As mentioned in an earlier e-mail, FSC certification should be jettisoned.  It is a program that was originally meant for corporate-industrial timberlands and it has failed to encourage ecologically and aesthetically sensitive forestry practices even on these lands.  It truly should not be applied to our state's public lands.  The very abuses which have brought us to the table primarily occurred during the period of time in which our state's public lands have been “green” certified.

 

***** But Dave what you say is all too rational. You must understand- rational thinking in the forestry world is verboten.

 

 

5.       I don't know why TSC decided that forest management should be elevated to a cabinet level position, creating a whole new unnecessary bureaucracy,

 

***** Sounded good when I first heard it but I now realized that it might be for the best to have no state forestry burreacracy at all.  But that would be too visionary for this "practical and feasible process".

 

 but it is a recommendation that should be removed from the report.  Having graduated from the UMass forestry program, I truly feel that foresters are not  well trained in the area of ecology and certainly are not experts on all those other social and cultural values for which we have public lands.  I agree with Nan who stated, The problem that brought us to the Vision Process was forest management that prioritizes timber extraction over other ecosystem services. This will worsen the problem!  This recommendation is in conflict with the excellent recommendation to broaden expertise of planners for our forests to include specialists in forest ecology, recreation, and global warming (Recommendation 8). As lines 1471-1473 says, there is a perception that planning activities by DCR has been driven by silvicultural considerations. This organizational change would exacerbate the problem, and is not part of the original process goals. This section was not part of the process goals.”

6.   I have looked through some of the earlier documents sent out during the early stage of this MODR process and cannot find where it was stated early on that watershed lands would be excluded from this process.

 

***** Apparently it was hoped nobody would notice that they were missing. In fact, the DFW lands should be on the table too- the early criticism of state forestry work included criticism of DFW practices too.

 

The Quabbin, with its 80,000 acres of land and water is the one place within our state where a truly large reserve could be established (of 50,000 acres or more).  It has only been within recent TSC meetings that it

has become known to me that watershed lands, even though they are DCR owned and managed - are not included in this process.  Why is this?  What possible reason is there to exclude such a large area of DCR land from these proceedings?  

***** But Dave, the Quabbin is the "Holy Land" for DCR- it is untouchable - it is forbidden even to make such a suggestion.

 

 

7.       I am in complete agreement with comments made today by a number of people including Cathy Kristofferson, Claudia Hurley, Jane Winn, Mike Ryan and Nan Finkenaur.

As the report is presently written, I cannot lend my signature to it or support it.

**** But, the TSC, minus me, doesn't care what any of you think.

 

 

Dave Gafney

Bill Logue

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Dec 9, 2009, 1:29:00 PM12/9/09
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Mike,

 

To clarify some of your points concerning our role as facilitators. The reference to goals and outcomes in the introduction comes from the goals and outcomes distributed last spring after the design stage and these were circulated publicly at the time. As to the role of DCR I addressed this in my November 30 email by saying in part:  "The TSC has acted independently of DCR. The usual practice in these types of process is that the sponsoring agency fully participates or chairs the meetings. In this case, DCR has pulled back from the table while the AGS has had three joint meetings with the TSC and TSC members have worked on concepts with AGS members such as you. The AGS has had greater access to the TSC than DCR. DCR had important information to provide the TSC that go to the feasibility of the recommendations and the TSC asked for that information. ...At the same meetings some of you are referring to, AGS members in the audience were asked to address specific concerns and one member joined the TSC at the table for more than an hour of the discussion at the November 24 meeting."

 

Almost every TSC member has taken responsibility for drafting and/or proposing language for the draft recommendations and has shared those with the full group for discussion. Each member has led various portions of the discussion. The AGS work group on reserves has had several opportunities to speak to the TSC during its meetings, the members have had conference calls with TSC members taking the lead on those sections. Have other AGS members been given the same opportunity to weigh in on the AGS work group drafts before they were sent to the TSC?

 

We are in now in the stage of the process that is designed to hear from the AGS about the draft. The TSC is getting comments from  the AGS members and will hear more at a face-to-face meeting next week. I expect that changes will be made to the draft. The process is designed to do just that. As facilitators we take no stance on the substance of the discussions. Several meetings ago I asked you how things were going and you said "ok, we are making progress". Several days after that you sent an email critiquing the process. At the subsequent meeting we made adjustments to address many of those concerns and you expressed appreciation for that at the meeting. At each stage we have tried to balance time while being as inclusive as possible.  MODR serves as a neutral forum where we strive to make sure ALL voices are heard and respected and that all interests are brought forward and balanced. We take pride in being reflective practitioners and have always and will continue to welcome constructive feedback on how we as facilitators can better serve this process. 

 

 I look forward to seeing you and the rest of the AGS on the 18th. Within the next day or so we should have more information about next steps based on the feedback from the AGS so far and any adjustments made necessary from the cancellation of today's meeting.

 

 Bill

 

 

From: forest-futures-advisor...@googlegroups.com [mailto:forest-futures-advisor...@googlegroups.com] On Behalf Of Mike Ryan
Sent: Tuesday, December 08, 2009 8:20 PM
To: forest-futures-advisor...@googlegroups.com; ForestFutur...@googlegroups.com
Subject: Comments on draft TSC Recommendations

 

A. COMPROMISED PROCESS: Refusal to identify root cause of DCR forest management crisis:  

--

Bill Logue

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Dec 9, 2009, 1:29:08 PM12/9/09
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Dave,

 

Just a clarification on what I said to you about scheduling.

 

I indicated that with the rescheduling we looked for dates when the most TSC members could make the meeting. Of the dates floated two were relatively equal. Andy could make one of those days. Given the importance of reserves to so many of the AGS members, it seemed prudent to select the day Andy could be present as he has taken the lead in putting options before the TSC for their consideration. Given that if questions came up about underlying assumptions he could most readily answer them. You have taken the opportunity to attend a number of the TSC meetings and so have listened to their deliberations. An opportunity many other AGS have not taken advantage of. With scheduling for more than 30 people it is difficult to allow one person's schedule control as you are suggesting we do for you. We had to find a time when the greatest number of TSC members could attend and assume that given the overlap in AGS stakeholder representation that if an AGS member could not make it they would be able to have a colleague raise their concerns. We hope everyone will be able to make the 18th.

 

Bill

 

 

 

From: forest-futures-advisor...@googlegroups.com [mailto:forest-futures-advisor...@googlegroups.com] On Behalf Of Dave Gafney
Sent: Tuesday, December 08, 2009 8:23 PM
To: forestfutur...@googlegroups.com; forest-futures-advisor...@googlegroups.com
Subject: Re: Message from Lisa Vernegaard

 

I have a number of hearings tomorrow at 1 PM in Pittsfield Juvenile Court and so will be unable to attend.  I had begged Bill not to hold this on Wednesday, but he explained to me that because this was the only day that Andy Fenton could be there, this would be the day of the joint meeting.  This bothers me greatly because, with due respect to Andy, his views do not reflect what I, and I think many others on the AGS believe, regarding the amount of land that should be set aside in reserves.  I also think that the idea that half of the proposed reserves are supposedly on state land that has not yet even been acquired further undermines Andy's proposal.  I have been trying to read the 52 page report while working my law practice during this past week and have read most of it, but not as intensely as I would have liked. These are some of my thoughts:

--

Joseph Zorzin

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Dec 9, 2009, 2:33:10 PM12/9/09
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----- Original Message -----
From: Bill Logue
Sent: Wednesday, December 09, 2009 1:29 PM
Subject: RE: Comments on draft TSC Recommendations

Mike,

 

To clarify some of your points concerning our role as facilitators. The reference to goals and outcomes in the introduction comes from the goals and outcomes distributed last spring after the design stage and these were circulated publicly at the time. As to the role of DCR I addressed this in my November 30 email by saying in part:  "The TSC has acted independently of DCR. The usual practice in these types of process is that the sponsoring agency fully participates or chairs the meetings. In this case, DCR has pulled back from the table

 

 

But Bill, some of us just don't accept that- from the beginning, the DCR was sitting at the table- I complained about that and for the next several meetings they stayed away from the table- Bob O'Connor even once replied to a question by saying, "I'm not sure I can speak". Then, about 2 meetings ago, the DCR  people were invited back at the table- literally. They have been at every meeting, which is fair enough but they also have been privy to the online discussions as I believe Stephanie is on the google lists. I'm not saying that the DCR should be totally out of site- after all, this is their thing- they're paying for it and it's reasonable that they should know how it's going- but I wouldn't go so far as to say they haven't been involved- and one could even conclude that their concerns have been listened to very closely, while the concerns of some of us, such as Claudia, Dave Gafney, Mike Kellet, Mike Ryan, Nan, Mary Booth and even comments by some of the industry people- have not been so pondered and factored into the draft reports- at least, that's my opinion.

 

 

 while the AGS has had three joint meetings with the TSC and TSC members have worked on concepts with AGS members such as you.

 

In my opinion, most of the TSC really hasn't paid all that much attention to the AGS's opinions. Perhaps we should give the entire TSC a quiz to see how much they've absorbed from the AGS opinions. Maybe Mike Ryan and Claudia will write up that quiz! And, certainly, it would be a stretch to say that opinions of the AGS have gotten into the draft report. The only opinion/suggestion from me that's in there is the proposed requirement that only a lic. forester can prepare a cut plan. Everything else I've said has been ignored, other than the suggestion that perhaps I might have hinted that Manomet is compromised- THAT apparently got heard or imagined.

 

 

The AGS has had greater access to the TSC than DCR.

 

 

Oh, come on Bill- you don't really believe that? Stephanie gets all the TSC google list emails- Bob O'Connor hasn't missed a meeting. Bob and Stepanie have often sat at the table. Bill Hill hasn't missed a meeting. Thom Kyker Snowman has been to most of the meetings.

 

 DCR had important information to provide the TSC that go to the feasibility of the recommendations and the TSC asked for that information.

 

I don't recall anyone in the TSC actually doing that, though perhaps MODR read our minds and thought we were thinking that. I see way too often that MODR says/writes that the "TSC did such and such or thought such and such or asked such and such" when the TSC as a group really hasn't done any of those things- I'm just trying to give everyone a reality check. We do have lots of brief often superficial discussions on a lot of subjects, seldom any in depth on anything and never seem to resolve anything- when I point out in email falsehoods and errors in the drafts- they are ignored.

 

 

 ...At the same meetings some of you are referring to, AGS members in the audience were asked to address specific concerns and one member joined the TSC at the table for more than an hour of the discussion at the November 24 meeting."

 

sitting at the table but not being able to actually say much isn't really a big deal- if you refering to Claudia, I could see several times when she wanted to speak but wasn't given the chance

 

 

 

 

 

Almost every TSC member has taken responsibility for drafting and/or proposing language for the draft recommendations and has shared those with the full group for discussion. Each member has led various portions of the discussion. The AGS work group on reserves has had several opportunities to speak to the TSC during its meetings, the members have had conference calls with TSC members taking the lead on those sections. Have other AGS members been given the same opportunity to weigh in on the AGS work group drafts before they were sent to the TSC?

 

this has all been carefully choreographed to appear as if the AGS was being heard- I don't believe it has been heard- just as I don't feel I've been listened to- while the skeptic Chris Matera has said right along that this process is all - well, I won't say what his opinion is---- and, it all goes back to the original choice of membership which is not truly a balance between the major perspectives- it is slanted very heavily towards industry friendly people with half of the TSC and a fourth of the AGS being forestry/industry people- when I suggest Mike Kellet to be on the TSC to give it balance, that opinion was quickly dismissed- let's go back to the group that picked the TSC, that group was by no means balanced

 

 

 

 

We are in now in the stage of the process that is designed to hear from the AGS about the draft. The TSC is getting comments from  the AGS members and will hear more at a face-to-face meeting next week. I expect that changes will be made to the draft. The process is designed to do just that. As facilitators we take no stance on the substance of the discussions. Several meetings ago I asked you how things were going and you said "ok, we are making progress". Several days after that you sent an email critiquing the process. At the subsequent meeting we made adjustments to address many of those concerns and you expressed appreciation for that at the meeting. At each stage we have tried to balance time while being as inclusive as possible.  MODR serves as a neutral forum where we strive to make sure ALL voices are heard and respected and that all interests are brought forward and balanced. We take pride in being reflective practitioners and have always and will continue to welcome constructive feedback on how we as facilitators can better serve this process. 

 

 I look forward to seeing you and the rest of the AGS on the 18th. Within the next day or so we should have more information about next steps based on the feedback from the AGS so far and any adjustments made necessary from the cancellation of today's meeting.

 

Bill, no doubt MODR is masterful at this method- it's a very smooth machine- but as I've suggested many times- if it doesn't get the biggest critics to feel that the final result truly addresses their concerns, then it's a failure- you have listed what appears to be a sophisticated methodology- yet, the result, I predict is that the biggest critics whose efforts caused this process to happen will not be satisfied- hence, regardless of how sophisticated this methodology is- it will not succeed in ending the controversies. You can argue that you've done everything- but that's just not going to be enough.

 

Mike and I and others suggested from the beginning that this "consensus" system could not really succeed. I do recall one day when we were chatting that you said "this is not a dispute resolution" because that's a different methodology entirely- but that's what it should have been- then we'd have a true balance- the 2 opposing groups would sit opposite each other at a table- like an old fashioned labor union vs. company dispute - it would be a balanced method- instead, the consensus methodology is designed, I suggest to get the results that the entity paying for it wants and it appears to us that that's where it's going- more of the same, more clearcutting as we're now seeing large scale on the  Quabbin, only a token increase in reserves and most of that is the fantasy realm, etc.

Joe

Alexandra

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Dec 9, 2009, 2:33:41 PM12/9/09
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Mike, I believe the TSC is actually in reverse, reducing the amount of preserves and accelerating cutting.  But I think the AGS job right now is to forget the forestry culture and Logue and concentrate on ourown priorities compared to TSCs'  Do you agree?
Sent: Tuesday, December 08, 2009 8:19 PM
Subject: Comments on draft TSC Recommendations

Bill Logue

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Dec 9, 2009, 4:39:16 PM12/9/09
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Joe,

 

I don’t wish to get involved in a back and forth on this.

 

I do ask that people adhere to the ground rules and be respectful. The ground rules ask people to speak for themselves. Some AGS members have used the AGS Google group quite actively. However, this does not mean that those who speak most speak for everyone. I expect  that we will hear from all of the AGS through their comments and at the meeting as this process is designed to do. Your role as a TSC member is to help develop the recommendations. I encourage, and others to look at the ground rules on roles and responsibilities.

 

 Two clarifications:

1.       This is an open process where the public and DCR staff are able to attend. You seem to be saying that you don’t want transparency for DCR to be able to observe . DCR has been criticized for not taking into account the opinion of others, what better way than to have them hear what is being discussed. Unless they understand how the recommendations were arrived at it will be difficult for them to implement them.

2.       The Google list were closed by agreement of the TSC until opened to the public by request. Stephanie Cooper nor any DCR/EEA staff has ever been part of either group – as agreed. In fact, I seem to recall you suggested that Bob O’Connor be added at one point.

Bill

Dave Gafney

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Dec 10, 2009, 9:31:04 AM12/10/09
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Bill,
 
I am not suggesting, nor do I expect, that your scheduling should revolve around me, nor do I expect it to revolve around any other individual.  When you said that you set the date because it was when Andy was able to make it - that bothered me, not because I have anything against Andy (I don't), but because it seems to me that the only important thing is Andy's "vision" on reserves - while the work and effort of the Reserves Working Group of the AGS has been completely swept under the rug - ignored by the TSC, as have most of the opinions of the AGS.  Many of us on the AGS will not support a proposal that is weak in terms of the amount of existing state land protected in reserves and is too dependant on future acquisitions that may never happen.  I am in agreement with others who believe that there is weakness in the structure of this process.  A true dispute resolution process would have been a negotiation with DCR on one side of the table and the critics on the other.  I still have a small hope that this process will produce a report that can put this controversy to rest.  I would much rather spend the coming years hiking in and enjoying our public forests rather than having to fight for them by working toward a ballot initiative that will ban all logging, by litigation, by going to the media and by showing up at Gov. Patrick's campaign rallies and "town halls" with posters of clear-cuts.   
 
Dave
----- Original Message -----
From: Bill Logue
Sent: Wednesday, December 09, 2009 1:29 PM

Mike Ryan

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Dec 10, 2009, 10:58:02 AM12/10/09
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Bill,

Sorry, but in your response to me you have completely missed what I was conveying in my critique of the contents of the draft TSC Recommendations report.

At the heart of the matter isn't that we were informed in the spring that MODR accepted the premise that DCR, the very agency which had violated the public trust, would be expected to "determine the goals and objectives of the FF process  and how the outcomes will be used" (quoting MODR here).  

You say, well you were informed.  

But you miss the point: we do not agree with this construct; we didn't then and we don't now

You continue to claim outright legitimacy for this flawed influence arrangement: The point, again, is that our view is ignored.  

Your response to my post continues by asserting that I indicated to you at one meeting that progress was being made because MODR had allowed AGS to meet directly with the TSC.  You make several references to the great amount of access allowed the AGS to the TSC, "greater than DCR" you write, a member sitting at the TSC table at the November 24 meeting you add, plus the AGS Reserves working group had "several opportunities" to speak to the TSC.

Again, you miss the point.  

The TSC might have heard but the TSC did not respond to anything the AGS has said.

Your response to my critique of the draft TSC Recommendations fits right into this paradigm.  You completely ignored the substance of what I wrote.  

You heard me (ie., you read my critique) but your response lacked evidence that what I had said had any importance whatsoever because you simply ignored the matter of the validity of the substance of what I wrote regarding process and the draft TSC report recommendations.  

You see, this mirrors how the TSC report was written.  

The TSC may have listened to AGS members but the substance of what was said by AGS members was ignored, swept under the rug, marginalized, denied (some phrases we have seen from AGS members regarding the draft TSC Recommendations report) in favor of the dominant maximum forest management paradigm.

Lets just take one key example: The amount of DCR reserves.  No matter how many powerpoint presentations, position papers, occasions speaking to the TSC by the AGS working group for a truly meaningful reserves proposal based on incontrovertible scientific methodology and recognition of social values, the MODR facilitators and advisors said NO; the only floor we will allow to be proposed in the draft Recommendations report is the one endorsed by EOEEA.  Period.

So here it is in a nutshell.

You say "Mike, you said you were pleased that we listened, so what's your beef?"  

To which I say listening alone is a pro forma meaningless defense.  The draft TSC recommendations document tells the results tale:

Again, to take just one example (but there are countless others as you know), reserves: the reality is that MODR abets a process by which the EEA position of a grand total of 74,675 actual DCR acres becomes the TSC operative reserves proposal purposely leaving out 188,593 acres of DCR forests involving numerous ecorgions which have been scientifically identified as qualifying for reserve status, so those needed-for-reserves acres can instead be potentially used by DCR using small and large clear-cut methods for active forestry, including large scale 'demonstration projects' and clear cuts for "early successional habitat" (!!) and not precluding energy extraction from biomass or wind complexes. 

Moreover, despite repeated statements by AGS members and one member of the TSC (why only one we ask?) that it is it illusory and deceptive to allow the TSC reserves proposals to be ginned up with phantom pie-in-the-sky acres under the heading of New Acquisitions and Protected Open Space (POS) lands, nevertheless the TSC reserves proposal includes 79,000-109,744 acres (20-50 year time frame) to pump up the appearance of having some significance.

You say, well we MODR facilitators act very neutral, don't take positions.  Following our most recent AGS working group presentation in which the above points were (again) clearly made Lisa Vernagaard proceeded to propose reserves language the TSC would adopt which excluded everything we had just conveyed to the group.  

To which I responded directly, "but what about all the points we just conveyed about the abject deficiencies in the TNC/EEA proposal?" To which Lisa replied, "oh, all we want to propose is a floor," and the motion carried!  No discussion of any of the points raised. Zero.  End of story.

I mean this to be constructive feedback so you can better serve the process, but from what we see in the draft TSC Recommendations many have come to the conclusion that a fresh piece of paper needs to be inserted into the typewriter.

Mike

mandchurley

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Dec 10, 2009, 12:33:34 PM12/10/09
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Bill and others,
       While I appreciated my invitation to say a few words to the TSC with respect to FSC certification of MA public lands, at the Nov. 10 meeting,  I felt that the session was virtually worthless and that my input that day was restricted, and that the TSC took a straw vote immediately following my brief presentation without in depth discussion that resulted in the position they held before I spoke..
 
        My essential point to the TSC was that FSC/SCS is not equipped to monitor, nor interested in the social values of multiple use lands.   I contend that it was meant to oversee productive forest land whose primary, if not ONLY purpose is to provide for the continuing extraction of timber.  That is not the primary purpose of the public lands of Massachusetts.
 
        I sat at the table for approximately an hour, but during that hour we listened to Corey Brinkema, president of FSC US, on the speaker phone deliver a very general public relations type presentation about FSC certification.   It was quite clear to me that he had virtually no knowledge of the details of the current status of FSC certification in Massachusetts.  There was no indication that he even knew we are not currently certified. It would have been much more appropriate to talk with Dave Wager of Scientific Certification Systems, the auditing company that has been involved in the certification process here.   I had not been informed before the meeting that we would be talking with anyone from FSC or SCS. 
 
        When Mr. Brinkema was asked if FSC certification is able to properly protect social values on public land, he began a discussion of how IN THE FUTURE, WHEN THEY REWRITE THE NORTHEAST STANDARD ( of ten major principles and over 50 related criteria and indicators) TO HARMONIZE IT WITH OTHER REGIONAL STANDARDS, TO CREATE A NATIONAL STANDARD, THEY WILL INCLUDE MORE SOCIAL ASPECTS.  I had my doubts that many members of the TSC even knew what he was talking about... about the Northeast Standard or proposed changes to it.
 
         When we asked him why aesthetics (an extremely important aspect of harvesting on public lands that strive to balance social with economic values) did not have a Principle of its own, but was relegated to a non binding recommendation, he created the impression that aesthetics are a somewhat subjective issue, and that when they are not "serious", they just become recommendations, but have the potential of being elevated to a higher level of concern if warranted.   that was an unsatisfacory answer  to those of us who drive along County Road in October Mountain, who saw the devastation at Savoy State Forest, who have seen the massive strip clearcuts on the way to Windsor Jambs in Windsor State Forest and who are witnessing current clearcutting at the Quabbin visible from a scenic highway.
 
         When I was able to ask him if in fact with any of the other "public land clients" FSC ever suggested to a landowner to remove a particular property from the scope of certification because it was not "appropriate for the commercial extraction of timber",  he said, "no".  " We do not decide which lands are in the scope.  The client decides that."
 
          I had no opportunity to follow up on the fact that the SCS report rejects as "insufficient"  the reasons given by the state to remove Robinson State Park, Walden Pond Reservation and the Connecticut River Greenways from the scope of FSC certification when the state applied for recertification in April.  Not only did they reject the reasons, they made a MAJOR corrective action out of their instruction to the state to provide more sufficient reasons.  I had my doubts that the TSC understood the difference between a MAJOR corrective action request and a MINOR corrective action request.   I had no opportunity to expand on this.  A Major Corrective action request precludes certification.   Compliance with a minor corrective action request can be worked on while a client is certified and does not preclude certification.  Recommendations are merely "opportunities" to do better.
 
         Until SCS was assured that there is "no moratorium" on DCR lands with approved management plans, it had written another MAJOR CORRECTIVE ACTION REQUEST, requiring the state to reexamine all consequences of  a real or defacto moratorium on cutting on lands with approved management plans.   They did not accept at face value, attempts by the Commissioner of DCR or the DCR Stewardship Council to limit cutting in any way in order to await expected changes in those plans from the recommendations of the Forest Futures Visioning Process.  As a matter of fact, they said, "It is not clear why such a moratorium would be implemented on lands with completed plans that have included public consultation, doing so suggests an inadequate consideration of and committment to the planning and public input process".     I am of the personal opinion that the public input process for the forest district management plans approved in November 2008 was seriously flawed.  The list of people contacted and invited to meetings was not balanced, nor did it reach a broad cross section of the public..  Two meetings were held to hear public input for the three plans.  8 people appeared at one meeting and 12 people appeared at the other.   Most of those people were agency staff.  To have SCS blindly make such an assessment of decisions made by the Commissioner of DCR and the DCR Stewardship Council who are mandated  to properly balance the economic, social and ecological values of our lands is serious documentation to me that FSC/SCS is more concerned about having the cutting proceed than it is in resolving serious concerns about balancing values.   Despite the fact that it is a goal of the Forest Futures Process to address these issues, and in spite of the fact that the FSC/SCS report claims it understands that this process is ongoing, and FSC/SCS intends to monitor the outcome, it still made  continued cutting a priority.
 
        None of this was discussed with the TSC.  There was no discussion of the points I had made.   I believe the TSC members did recognize that the general information from Mr. Brinkema could have just as easily been read on his website.... Where, by the way, as of today, (Dec. 10, 2009) it still lists Massachusetts as having FSC certified forests.  (with the caveat that this is an unofficial list of US certificate holders).  
 
 
     http://www.fscus.org/certified_companies/index.php?num=20&start=41                                                  

Commonwealth of Massachusetts
Bob O'Connor
Boston, MA
(617) 626-1170

 
       My concerns that FSC certification is sought by EOEEA for the "image" it provides as a "buffer from criticism from the public" was never addressed, although the concept of public lands seeking certification for this reason was addressed in one of the documents provided to the TSC by Tom Walker.
 
       AGS concerns about the cost of FSC certification as one to be seriously considered in economically difficult times and as redundant of our own oversight expenses,  was not discussed.  I am not sure that the TSC has ever been given accurate information about the cost of FSC certification to the state. 
 
       The issue that no principles, no conditions, no categories of land suggested by FSC/SCS certification are bound by any state or federal laws was not a topic of discussion.
 
       To add to my concerns, the "minor corrective actions" reflect the multiple problems with forestry on public lands that have been brought to the attention of EOEEA and DCR by stakeholders in Massachusetts.  The report does incorporate that stakeholder input.  The report covers: 

the state is warned to stop all clearcutting of conifer plantations, stop using "shelterwood" as another name for clearcuts when no advance regeneration is apparent, reexamine the justifications of using early successional habitat and restoration of native species as excuses to clearcut, reexamine the decision to remove all Norway Spruce,  undertake a legal examination of our state laws that put restrictions on clearcuts over 5 or 10 acres to see if the state has violated them, conduct a variety of studies of green tree retention in large openings, provide training for new foresters, and continuing education for current foresters,   focus on the condition of the way they leave landings and harvest sites in general, form and implement methods to protect seeps and steams, improve coarse woody debris standards in the face of the threat of the biomass plants,  pay some attention to aesthetics, decide what can and can not occur in reserves, and monitor all forestry for compliance with the forest cutting plan goals and show where the money will come from to do forestry properly (including marking boundaries),   and much much more...

         But, in their words, these are "minor" and the cutting can continue while the state works out how to address these concerns.   Alleged violations of these conditions are occurring right now on active harvest sites.  But FSC/SCS will not accept or act on any complaints because "we are not certified".  I have asked.

         To find out about the status of FSCcertification from the EOEEA website go to:

  http://www.mass.gov/?pageID=eoeeahomepage&L=1&L0=Home&sid=Eoeea

          choose sustainable forest management

          choose green certification    (there you could read the report, but you don't see the decision that the state will not be granted certification until page 55)

           read overview of Green Certification 2009 to hear why the state pursued green certification in 2002
 
          click on the title:  Overview of Green certification:
 
          and there you can read the latest overview of the status of Green Certification.  I appreciate that this document more accurately reflects the status of Green Certification in Massachusetts today.    It replaces one I complained about that existed on their website just a short time ago. 
 
           In summary, I feel that my opportunity to speak to the TSC about green certification was not met with a genuine attempt by all members of the TSC to hear or discuss the complex issues related to a decision about whether in fact FSC/SCS certification is appropriate, or necessary for our public lands.   If there are complaints about whether the members of the AGS have been sufficiently "heard" on topics where they can offer anecdotal, scientific or detailed information to the TSC, I do wish to offer this as one example of a legitimate complaint.
 
          I do recognize that time restraints have been imposed on the Forest Futures Visioning Process.   I think those restraints will preclude any possibility that the recommendations will reflect a thorough analysis of the problems placed in front of the Forest Futures Visioning Process.   Claudia Hurley 

mandchurley

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Dec 10, 2009, 12:34:51 PM12/10/09
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Correction:   November 24th meeting that had as its focus, FSC certification.   Sorry.

Joseph Zorzin

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Dec 10, 2009, 5:18:24 PM12/10/09
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Without any doubt- I can state that Claudia understands the FSC certification issues better than anyone else in Massachusetts- far better- yet she too is ignored by the TSC in their almost unanimous support of FSC.
 
Joe

Tim Fohl

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Dec 15, 2009, 1:20:49 PM12/15/09
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Bill,

I have a conflict on the 18th. Sorry. Good luck with the meeting!

Best,

Tim Fohl

On Dec 9, 2009, at 1:29 PM, Bill Logue wrote:


Tim Fohl
Carlisle, MA



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