no early successional habitat

[mandchurley]

Everyone (this is directed to the AGS members, but meant for the TSC members to hear as well. Please share with anyone not on these lists:)

 

         I have written to the stakeholders, at your individual addresses, to avoid overloading the google groups with emails, to see if there are areas of consensus from the AGS members for making comments.    It's now time for comments.

 

        Do any of you have a desire to combine thoughts into group comments on this most recent draft?   We are expected to make our comments by 5 p.m. Sunday

 

        I have a concern about the proposal to allow "early successional habitat cutting" on a portion of the woodlands that are being proposed, that I have reason to believe are shared by many of us on the AGS and also on the TSC.

 

    .   I have multiple comments I plan to make about the allocation of acres to woodlands, about language pertaining to taking wood from our forests for biomass, about language describing what can occur for cutting in the parklands and reserves, about what we should expect for renewed and better oversight of forestry where it occurs on our woodlands, and about whether FSC certification can be expected to play that role   (not) , about the idea of having a Commissioner of Forestry Stewardship,  and other comments related to this draft... but

 

        I mention to all of you the proposal to allow for the creation of "early successional habitat" on conservation and recreation lands that exists in the draft.(lines 982 and 997 specifically, and in other places)     I simply do not think we should have that in the recommendations for stewardship of forests and parks that are in the Department of Conservation and Recreation.   And I don't think there is clear and unambiguous support for it by the TSC, either.   I would like to suggest that we all say, leave that to Fish and Wildlife.  From what I can see, opposition to forestry that creates large openings and the protection of parklands seem to be where the widest support lies.   How many of you would like to say, take "creation of early successional habitat" on DCR state forests and parks OFF THE TABLE.?

 

         Here is what I have observed and collected on this topic:    Bob O'Connor, in presenting the DCR/EEA request for woodlands asked for 30,000 acres designated for this kind of cutting.   I have not heard anyone else advocate for it on these DCR lands. Yet it still exists in the draft of recommendations.    I attended the TSC meeting on Jan. 6, and I definitely heard some "reservations" about it from the members of the TSC:  (keep in mind, three people were absent from that meeting:   Joe Zorzin, William Moomaw and Kate Connolly.)  Of the people there,    I heard one person say:   "don't put it in with the woodlands, that's how we got in trouble".   I heard another person say, "don't make it part of the demonstration forests".   I heard another person say, "maybe we should reduce the amount of acreage to 15,000 acres".   I heard another person say, "maybe we shouldn't have any specific acreage in there, maybe we should ask DFW how much they need for early successional habitat, watch and see if natural disturbances create what they need, and only do it if it turns out to be necessary".   I heard another person say, "the science is not clear on this topic, there are different views on the need for it". I heard still another say, "I guess we should not remove any tool from the toolbox, but the clearcutting tool should be allowed to get rusty in that toolbox."   I have reason to suspect that it is possible that members absent from that meeting might also have concerns about this kind of forestry on these lands.     In other words, there is HARDLY A CONSENSUS WITHIN THE  TSC ON THE PROPOSAL FROM DCR for this idea.   So why is it still there?

 

        On top of that,  there is a clear indication that "early successional habitat" which is essentially clearcutting, is definitely what all the negative pictures have been about on public lands.  This is a public relations nightmare for DCR.   It will continue and expand if they do it on state forests and parks.

 

         We have two state laws that seem to indicate that the legislature is concerned about clearcutting.  One seems to be unambiguous about prohibition of clearcutting for DFW lands   (Chapter 131, Chapter 4, section 16). (They will have to face this legal question at some point).     Another is the Chapter 132 Forest Cutting Practices Act, 304 CMR 11.05 which puts restrictions on clearcuts over 5 acres or 10 acres on DCR lands.

 

         We have several references to DCR's clearcutting of conifer plantations and justification for clearcutting for early successional habitat in the recent FSC/SCS report.  A couple of key statements are: 

 

 Page 60: (excerpts:   please see full context: ) 

http://www.mass.gov/Eoeea/docs/eea/lf/green_certification_report_2009.pdf

Non-conformity: Prior to harvesting of conifer plantations (with often complete removal), BoF and DWSP have not completed an adequate environmental impact assessment to assess impacts on long-term ecological functions of the forest ...

BoF has been the most aggressive with the least developed rationale for converting conifer plantations.

For BoF the justification centers on two points: (1) that non-native species are intrinsically in conflict with biodiversity goals, and (2) aggressive regeneration harvesting of non-native stands presents an opportunity to create early successional habitat.

        We also have heard from Bob O'Connor and others that the foresters can't maintain the early successional habitat that is created with the logging.... it only lasts for a few years... (15 or so?)  then they have to cut in another place to create it.   Maintaining that which is established is too expensive.   So, I have to ask:  is it really their intent to create it?  Or is it a justification for the large openings? 

         In sum, I personally do  not  see much if anything in the way of support for this, and I personally think there are a lot of people who would agree with me that it should be taken out of the recommendations for stewarship of DCR conservation and recreation lands.   I'll be saying that loud and clear.  It's a deal breaker for me.  If you agree, we could make a group statement.   If not, we'll just make a few individual comments, but I repeat, mine will be loud and clear.    Claudia

 

[Nan Finkenaur]

I agree with Claudia--No early successional habitat on DCR lands. Clearly the legislature was concerned about this enough to put it into law she references below. I also have other comments to make, but feel there are areas of agreement between various stakeholders that should to taken into account in the next draft.

I would add: if we recommend 80% of the lands in reserves and parklands, both officially protected from commercial timber extraction, that is still only 240,000 acres which is well under 50% of all publicly held lands. All public lands should be considered when deciding the appropriate percentage of woodlands to parklands/reserves.

The draft language to protect our public forests from biomass harvesting must be stronger.

Language to protect parklands and reserves from timber extraction in the name of ‘management’ or ‘in kind’ services must be stronger.

Nan

[Cathy Kristofferson]

I agree with Claudia and Nan.  No early successional on DCR lands.  Leave it to DFW.  Remove all 20 references to in the draft.

 

Cathy

---

From: Nan Finkenaur <n...@adrenaline-design.com>
To: forestfutur...@googlegroups.com; forest-futures-advisor...@googlegroups.com
Sent: Sat, January 16, 2010 10:06:20 PM
Subject: Re: no early successional habitat

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[Mary Booth]

I concur as well. I can not say that we’ve seen a single real justification offered for creation of early successional habitat through forest cutting.

 

Despite requesting further analysis, we’ve seen no analysis offered of the total amount of early succesional habitat created every year in the state and the potential role of state lands in that larger context. There’s been no discussion of how the need to create habitat for the few rare species that benefit from brushy habitat weighs against goals to reduce forest fragmentation. There’s been no serious discussion of creating a program that maintains existing early successional habitat through mowing and brushhogging of existing opneing, which would obviously be much cheaper than doing new land-clearing, if the real objective were maintenance of habitat and not generation of wood products. When Bob O’Connor presented that proposal, I asked why, if they want early successional habitat, they don’t just maintian a few openings instead of cutting new patches each year, and he admitted that this could be a good approach, but there was no substantive dscussion.

 

In my opinion, the DCR proposal requires an unacceptably high amount of clear-cutting. I know that although large-scale biomass plants are finally beginning to be seen more widely as a stupid policy move by the state, there is still a widespread perception at DCR that small-scale biomass plants are desireable. Bob O’Connor himself seems incredulous, in the conversations we’ve had, that I would continue to question even small-scale plants (it's not the size of the plants but the magnitude of the overall fuel supply that matters, and even small-scale plants require a steady fuel supply that could approach demands by largescale plants, if implemented widely.) I can not help but think that it is just too coincidentally convenient that a clear-cutting program for “habitat creation” would also be an excellent way to generate fuel for these proposals.

 

There is just no reason to be creating big patches of brambles in the middle of the forest.. These openings are nothing like those created by blowdown. If DCR wants to be in the business of habitat creation (and I think other agencies do this better) then maybe they can focus on aquiring some old farmland that is going back to forest and manage it for habitat, or something – blasting big holes in the intact forest and calling it early successional is crude and unneccessary. They’ve not even come close to making a scientific or policy-based case.

 

Mary

--

Mary S. Booth, PhD
mbo...@massenvironmentalenergy.org
**********************************************
check out our website:
www.massenvironmentalenergy.org

[Ted Cady]

I disagree with Claudia's logic regarding early successional habitat.  She recommends that creating this habitat not be allowed on DCR lands but only on DFW lands and then correcctly points out that clear cutting may not be allowed on DFW lands.  This could  mean that no such habitat could be created, when we have heard presentations that clearly indicate we need to be creating it.  We have heard that unevenaged forests in certain situations are often best created by patch cutting (clear cutting an opening about one or two tree heights in diameter), which could be interpreted as a tiny clear cut.  The creation of early successional habitat should be left in the recommendations.

-----Original Message-----
From: mandchurley
Sent: Jan 16, 2010 9:16 PM
To: forestfutur...@googlegroups.com, forest-futures-advisor...@googlegroups.com
Subject: no early successional habitat

Everyone (this is directed to the AGS members, but meant for the TSC members to hear as well. Please share with anyone not on these lists:)

 

         I have written to the stakeholders, at your individual addresses, to avoid overloading the google groups with emails, to see if there are areas of consensus from the AGS members for making comments.    It's now time for comments.

 

        Do any of you have a desire to combine thoughts into group comments on this most recent draft?   We are expected to make our comments by 5 p.m. Sunday

 

        I have a concern about the proposal to allow "early successional habitat cutting" on a portion of the woodlands that are being proposed, that I have reason to believe are shared by many of us on the AGS and also on the TSC.

 

    .   I have multiple comments I plan to make about the allocation of acres to woodlands, about language pertaining to taking wood from our forests for biomass, about language describing what can occur for cutting in the parklands and reserves, about what we should expect for renewed and better oversight of forestry where it occurs on our woodlands, and about whether FSC certification can be expected to play that role   (not) , about the idea of having a Commissioner of Forestry Stewardship,  and other comments related to this draft... but

 

        I mention to all of you the proposal to allow for the creation of "early successional habitat" on conservation and recreation lands that exists in the draft.(lines 982 and 997 specifically, and in other places)     I simply do not think we should have that in the recommendations for stewardship of forests and parks that are in the Department of Conservation and Recreation.   And I don't think there is clear and unambiguous support for it by the TSC, either.   I would like to suggest that we all say, leave that to Fish and Wildlife.  From what I can see, opposition to forestry that creates large openings and the protection of parklands seem to be where the widest support lies.   How many of you would like to say, take "creation of early successional habitat" on DCR state forests and parks OFF THE TABLE.?

 

         Here is what I have observed and collected on this topic:    Bob O'Connor, in presenting the DCR/EEA request for woodlands asked for 30,000 acres designated for this kind of cutting.   I have not heard anyone else advocate for it on these DCR lands. Yet it still exists in the draft of recommendations.    I attended the TSC meeting on Jan. 6, and I definitely heard some "reservations" about it from the members of the TSC:  (keep in mind, three people were absent from that meeting:   Joe Zorzin, William Moomaw and Kate Connolly.)  Of the people there,    I heard one person say:   "don't put it in with the woodlands, that's how we got in trouble".   I heard another person say, "don't make it part of the demonstration forests".   I heard another person say, "maybe we should reduce the amount of acreage to 15,000 acres".   I heard another person say, "maybe we shouldn't have any specific acreage in there, maybe we should ask DFW how much they need for early successional habitat, watch and see if natural disturbances create what they need, and only do it if it turns out to be necessary".   I heard another person say, "the science is not clear on this topic, there are different views on the need for it". I heard still another say, "I guess we should not remove any tool from the toolbox, but the clearcutting tool should be allowed to get rusty in that toolbox."   I have reason to suspect that it is possible that members absent from that meeting might also have concerns about this kind of forestry on these lands.     In other words, there is HARDLY A CONSENSUS WITHIN THE  TSC ON THE PROPOSAL FROM DCR for this idea.   So why is it still there?

 

        On top of that,  there is a clear indication that "early successional habitat" which is essentially clearcutting, is definitely what all the negative pictures have been about on public lands.  This is a public relations nightmare for DCR.   It will continue and expand if they do it on state forests and parks.

 

         We have two state laws that seem to indicate that the legislature is concerned about clearcutting.  One seems to be unambiguous about prohibition of clearcutting for DFW lands   (Chapter 131, Chapter 4, section 16). (They will have to face this legal question at some point).     Another is the Chapter 132 Forest Cutting Practices Act, 304 CMR 11.05 which puts restrictions on clearcuts over 5 acres or 10 acres on DCR lands.

 

         We have several references to DCR's clearcutting of conifer plantations and justification for clearcutting for early successional habitat in the recent FSC/SCS report.  A couple of key statements are: 

 

 Page 60: (excerpts:   please see full context: ) 

http://www.mass.gov/Eoeea/docs/eea/lf/green_certification_report_2009.pdf

Non-conformity: Prior to harvesting of conifer plantations (with often complete removal), BoF and DWSP have not completed an adequate environmental impact assessment to assess impacts on long-term ecological functions of the forest ...

BoF has been the most aggressive with the least developed rationale for converting conifer plantations.

For BoF the justification centers on two points: (1) that non-native species are intrinsically in conflict with biodiversity goals, and (2) aggressive regeneration harvesting of non-native stands presents an opportunity to create early successional habitat.

        We also have heard from Bob O'Connor and others that the foresters can't maintain the early successional habitat that is created with the logging.... it only lasts for a few years... (15 or so?)  then they have to cut in another place to create it.   Maintaining that which is established is too expensive.   So, I have to ask:  is it really their intent to create it?  Or is it a justification for the large openings? 

         In sum, I personally do  not  see much if anything in the way of support for this, and I personally think there are a lot of people who would agree with me that it should be taken out of the recommendations for stewarship of DCR conservation and recreation lands.   I'll be saying that loud and clear.  It's a deal breaker for me.  If you agree, we could make a group statement.   If not, we'll just make a few individual comments, but I repeat, mine will be loud and clear.    Claudia

 

________________________________________
PeoplePC Online
A better way to Internet
http://www.peoplepc.com

[Tim Fohl]

Hi,

I am not a forest expert but I spend a lot of time in and around the woods. Here are some comments.

1. We have to choose what kind of ecological environments that we want. There is no perfect ecology. Life forms compete and live off each other so there are always going to be losers, including us ultimately.

2. The process of ecologic change has been going on forever. I doesn't matter whether it is "natural" or driven by humans it constantly changes. Humans have been altering the environment for tens of thousands of years and I doubt if there is any area that was untouched by the time the Europeans arrived. 

3. The Indians have a recorded history of living with this land that stretches over many millennia. They may have something useful to ell us. One of the recommendations of the certification process is to consult with the tribes: good idea.

4. If biodiversity is a goal, there is no question that forests, open fields, wetlands and open water need to coexist. I agree that such considerations should be guided by people whose expertise and interests are in ecological management not as a byproduct of timber extraction. However, you can't achieve this kind of varied environment  if you forbid cutting in large blocks of territory. There has to be some kind of dialog between the forest management people and the wildlife management people.

5. The presence of humans in the environment, in my experience, does not bother the wildlife unless the humans do it deliberately. There is far more wildlife activity around our property twenty miles from Boston than at Baxter State Park. I admit that most of the time I would rather not see another house but the presence of houses doesn't seem to bother the animals.

For what it is worth....

Best,

Tim Fohl

Tim Fohl

tf...@tigco.com

Carlisle, MA

978 371 0194

[Michael Kellett]

Artificially created early successional habitat should be removed completely from the TSC report.

Mother nature did just fine making early successional habitat before loggers started clearcutting. And she continues to create early successional habitat without our "help." For example, we just experienced a major ice storm last year that created a huge amount of early successional habitat. Again, I ask the question no one has answered: Where is the long list of species that are threatened or endangered because there is not enough early successional habitat in Massachusetts? I have yet to see a scientifically sound rationale for it, and I don't believe there is one. 

As far as I can tell, advocates of early successional logging simply want more early successional habitat for aesthetic or recreational reasons. If that's how they want to manage their own private lands, that's fine. But it's not a responsible policy for public forests unless there is a strong scientific rationale or broad public support. We have neither. I don't want our public forests clearcut for species that don't need our "help." And I think most Mass citizens would agree with me.

Regarding DFW, we don't need artificially created early successional habitat on those lands any more than we need it on DCR lands. DFW is the next land management agency that needs to account for their serious mismanagement of our public lands. Those who are mismanaging the Quabbin and other watershed lands also need to be held accountable for their abusive and scientifically unjustified logging program.

We should designate at least 80 percent of ALL public lands -- including DFW lands, watershed lands, and other holdings -- as reserves and end destructive clearcutting and artificial game "management" altogether. I think we should have a total ban on logging on public lands, but in the spirit of compromise, I am willing to go along with 20 percent of our lands open to logging if it is done in an ecologically sustainable manner (a big if).

Michael

On Jan 17, 2010, at 8:04 AM, Ted Cady wrote:

I disagree with Claudia's logic regarding early successional habitat.  She recommends that creating this habitat not be allowed on DCR lands but only on DFW lands and then correcctly points out that clear cutting may not be allowed on DFW lands.  This could  mean that no such habitat could be created, when we have heard presentations that clearly indicate we need to be creating it.  We have heard that unevenaged forests in certain situations are often best created by patch cutting (clear cutting an opening about one or two tree heights in diameter), which could be interpreted as a tiny clear cut.  The creation of early successional habitat should be left in the recommendations. 

-----Original Message----- 
From: mandchurley 
Sent: Jan 16, 2010 9:16 PM 
To: forestfutur...@googlegroups.com, forest-futures-advisor...@googlegroups.com 
Subject: no early successional habitat 

Everyone (this is directed to the AGS members, but meant for the TSC members to hear as well. Please share with anyone not on these lists:)

 

         I have written to the stakeholders, at your individual addresses, to avoid overloading the google groups with emails, to see if there are areas of consensus from the AGS members for making comments.    It's now time for comments.

 

        Do any of you have a desire to combine thoughts into group comments on this most recent draft?   We are expected to make our comments by 5 p.m. Sunday

 

        I have a concern about the proposal to allow "early successional habitat cutting" on a portion of the woodlands that are being proposed, that I have reason to believe are shared by many of us on the AGS and also on the TSC.

 

    .   I have multiple comments I plan to make about the allocation of acres to woodlands, about language pertaining to taking wood from our forests for biomass, about language describing what can occur for cutting in the parklands and reserves, about what we should expect for renewed and better oversight of forestry where it occurs on our woodlands, and about whether FSC certification can be expected to play that role   (not) , about the idea of having a Commissioner of Forestry Stewardship,  and other comments related to this draft... but

 

        I mention to all of you the proposal to allow for the creation of "early successional habitat" on conservation and recreation lands that exists in the draft.(lines 982 and 997 specifically, and in other places)     I simply do not think we should have that in the recommendations for stewardship of forests and parks that are in the Department of Conservation and Recreation.   And I don't think there is clear and unambiguous support for it by the TSC, either.   I would like to suggest that we all say,leave that to Fish and Wildlife.  From what I can see, opposition to forestry that creates large openings and the protection of parklands seem to be where the widest support lies.   How many of you would like to say, take "creation of early successional habitat" on DCR state forests and parks OFF THE TABLE.?

 

         Here is what I have observed and collected on this topic:    Bob O'Connor, in presenting the DCR/EEA request for woodlands asked for 30,000 acres designated for this kind of cutting.   I have not heard anyone else advocate for it on these DCR lands. Yet it still exists in the draft of recommendations.    I attended the TSC meeting on Jan. 6, and I definitely heard some "reservations" about it from the members of the TSC:  (keep in mind, three people were absent from that meeting:   Joe Zorzin, William Moomaw and Kate Connolly.)  Of the people there,    I heard one person say:   "don't put it in with the woodlands, that's how we got in trouble".   I heard another person say, "don't make it part of the demonstration forests".   I heard another person say, "maybe we should reduce the amount of acreage to 15,000 acres".   I heard another person say, "maybe we shouldn't have any specific acreage in there, maybe we should ask DFW how much they need for early successional habitat, watch and see if natural disturbances create what they need, and only do it if it turns out to be necessary".   I heard another person say, "the science is not clear on this topic, there are different views on the need for it". I heard still another say, "I guess we should not remove any tool from the toolbox, but the clearcutting tool should be allowed to get rusty in that toolbox."   I have reason to suspect that it is possible that members absent from that meeting might also have concerns about this kind of forestry on these lands.     In other words, there is HARDLY A CONSENSUS WITHIN THE  TSC ON THE PROPOSAL FROM DCR for this idea.   So why is it still there?

 

        On top of that,  there is a clear indication that "early successional habitat" which is essentially clearcutting, is definitely what all the negative pictures have been about on public lands.  This is a public relations nightmare for DCR.   It will continue and expand if they do it on state forests and parks.

 

         We have two state laws that seem to indicate that the legislature is concerned about clearcutting.  One seems to be unambiguous about prohibition of clearcutting for DFW lands   (Chapter 131, Chapter 4, section 16). (They will have to face this legal question at some point).     Another is the Chapter 132 Forest Cutting Practices Act, 304 CMR 11.05 which puts restrictions on clearcuts over 5 acres or 10 acres on DCR lands.

 

         We have several references to DCR's clearcutting of conifer plantations and justification for clearcutting for early successional habitat in the recent FSC/SCS report.  A couple of key statements are: 

 

 Page 60: (excerpts:   please see full context: ) 

http://www.mass.gov/Eoeea/docs/eea/lf/green_certification_report_2009.pdf

Non-conformity: Prior to harvesting of conifer plantations (with often complete removal), BoF and DWSP have not completed an adequate environmental impact assessment to assess impacts on long-term ecological functions of the forest ...

BoF has been the most aggressive with the least developed rationale for converting conifer plantations.

For BoF the justification centers on two points: (1) that non-native species are intrinsically in conflict with biodiversity goals, and (2) aggressive regeneration harvesting of non-native stands presents an opportunity to create early successional habitat.

        We also have heard from Bob O'Connor and others that the foresters can't maintain the early successional habitat that is created with the logging.... it only lasts for a few years... (15 or so?)  then they have to cut in another place to create it.   Maintaining that which is established is too expensive.   So, I have to ask:  is it really their intent to create it?  Or is it a justification for the large openings? 

         In sum, I personally do  not  see much if anything in the way of support for this, and I personally think there are a lot of people who would agree with me that it should be taken out of the recommendations for stewarship of DCR conservation and recreation lands.   I'll be saying that loud and clear.  It's a deal breaker for me.  If you agree, we could make a group statement.   If not, we'll just make a few individual comments, but I repeat, mine will be loud and clear.    Claudia

 

________________________________________
PeoplePC Online
A better way to Internet
http://www.peoplepc.com

-- 

[mandchurley]

Ted,  

        I am not a lawyer, but if I were trying to interpret the intent of the legislature when it discusses timber sales on DFW land, (please look at MGL Chapter 131, section 4, part 16)  and specifically prohibits clearcutting, it may be that they were trying very hard to be sure that revenues from timber sales were not the motivating factor for doing these clearcuts.   In the language there is some connection with timber sales and making money.  If I try to put myself in the place of the legislators who wrote and agreed to that law, I might be able to read between the lines that they were asking for "scientific justification" for the clearcutting and were trying to assure that DFW did not do it to make money.  I am only guessing.  That is why I keep saying they will eventually have to deal with an analysis of this law.  If the legislature has concerns about clearcutting for DFW lands, couldn't we assume that they might think it is bad or worse for DCR lands where there is no mandate to provide wildlife habitat?       Claudia 

----- Original Message -----

From: Ted Cady

To: forest-futures-advisor...@googlegroups.com

Sent: Sunday, January 17, 2010 8:04 AM

Subject: Re: no early successional habitat

[Bill Boles]

I agree with Claudia, Nan, Cathy, Mary, Joe, Michael and anyone else that would like to see all references to allowing cutting for the promotion of early successional habitat removed from the "Vision" draft.  Early successional habitat cutting is a justification for clearcutting. The appearance of forest openings is a not only natural occurrence but also occurs around fields, golf courses, housing developments as well as on power lines, gas lines and beside roadways. We don't need to create any new early successional habitat on DCR conservation and recreation lands. Bill Boles New England Mountain Bike Association http://www.nemba.org/ Dirt Rag Magazine http://www.dirtragmag.com/ Friends of Wompatuck State Park http://www.friendsofwompatuck.org/ --- On Sat, 1/16/10, mandchurley <mandc...@comcast.net> wrote:

From: mandchurley <mandc...@comcast.net> Subject: no early successional habitat

[fred heyes]

claudia

have you ever had the discussion with DFW???

fred

---

From: forest-futures-advisor...@googlegroups.com [mailto:forest-futures-advisor...@googlegroups.com] On Behalf Of mandchurley
Sent: Sunday, January 17, 2010 10:59 AM
To: forest-futures-advisor...@googlegroups.com
Subject: legality of clearcuts...

[Mike Ryan]

Please add my name to those who adamantly wish to remove 

all references to allowing cutting for the promotion of early successional habitat from the TSC "Vision" draft.

I oppose using the justification of creation of so called 'early successional habitat' for clear cutting DCR forests, which destroys connectivity for plant and animal life.

Clear cutting to open forest canopies increases fragmentation and expands forest edges, destroying habitat for several species and inviting invasive species on a grand scale.

Does the DCR have funds to control massive invasions of exotic species which crowd out natives on newly created 'early successional' clear cuts?  Of course not.

Mike

[Dave Gafney]

Please add my name to the list of those strongly opposed to mention of "early successional habitat" as a rational/justification/excuse for even-age management (clear-cutting and its variants).  I adamantly oppose the 30,000-acre proposal for "early successional habitat."  Some of the reasons are as follows:

 

• Clear-cutting does not provide the best habitat for most early successional species.  It usually results in dense “dog-hair thickets” of sapling-size pin cherry, gray birch, white birch and quaking aspen.  These thickets tend to be unattractive, difficult to walk through and contain tree species of little or no commercial value. This is not the best environment for New England cottontail, chestnut-sided warbler, meadowlark or bobolink which have been mentioned as the early successional species that need even-age management. 
• “Old fields” - abandoned pastures and agricultural lands - maintained through bi-yearly mowing are far more productive for early successional wildlife, as are beaver meadows, marshlands and wetlands.  Using public funds to acquire abandoned farms (or conservation easements on active farms) and maintaining their existing meadows is a far better way to conserve such habitat (unfortunately, this administration has been promoting subsidies for large proposed biomass plants - my understanding is that the one in Greenfield alone will be subsidized to the tune of $50 million per year for five years.  Just think what could be accomplished if these funds were used in a real effort at land conservation - including the conserving of farmlands and open areas for early successional habitat). 
• Early successional habitat is far more prevalent today than it was during pre-colonial times because of the existence of agricultural lands, power lines, golf courses, road embankments and a pervasive suburban residential landscape.  There is little or no evidence that such habitat was prevalent in pre-colonial Massachusetts.

• Massachusetts does not stand by itself. Large areas of the northeastern quadrant of the U.S. have been converted from forest to farmland, including most of western New York, Ohio, Indiana and Illinois.  If there is less habitat for certain early succession bird species (bobwhite and meadowlark for example) as our forests have returned and reclaimed farmlands, such habitat is abundant elsewhere.  This is a poor excuse for clear-cutting our public lands (or for clear-cutting in two stages and calling it "shelterwood"). 
• Heavier equipment is often used in clear-cutting than would be used with uneven-age management.  This can leave the ground torn up and the soil impacted creating the “disturbed sites” that, in turn, allow for the invasion of harmful invasive-intrusive species.
• The micro-ecology of forest soil is more complex than the macro-ecology of the visible standing forest.  There are micorhizal associations between soil fungi and tree roots that we are only beginning to understand.  More study is required regarding the impact that heavy logging and clear-cutting have on these relationships and on the ecology of the soil. 

• Uneven-age management is aesthetically far superior to even-age management and powerful arguments can be made that it is economically and ecologically superior as well.  In this urbane, progressive and heavily populated state, clear-cutting and its variants should have no place on our public lands.  The fact that our entire congressional delegation has co-sponsored the Save America's Forest Act banning even-age management on federal lands should truly tell us something regarding this issue.

Dave

 

----- Original Message -----

From: Mike Ryan

To: forest-futures-advisor...@googlegroups.com

Cc: forestfutur...@googlegroups.com

Sent: Sunday, January 17, 2010 2:59 PM

Subject: Re: no early successional habitat

[Ted Cady]

Maybe we need a more nuanced early successional habitat policy.  Warwick is over 90% forested.  Some early successional habitat would not cause forest fragmentation, would not screw up wildlife corridors.  We have very little in the way of open fields, power lines and the other things that would substitute.  We have big blocks of pure forest, which come right up to the edge of the road.  I suspect most of the western towns are in the same situation.  In those areas that have more mixed habitat the situation might be different, but for us folks in hill towns we can use some open areas.  if you are opposed to clear cutting we could do a controled burn to create the open space.  I am not talking about huge areas, small areas scattered around function very well.  They could be brush hogged every couple of years, if that is the appropriate way.  We have several people in town with old fields who do this, cutting 1/3 the field every year.  If the state did it here, there are probaby folks who would brush hog it for the state to maintain the habitat.  Not only that, visually it is nice to see a break in the woods every now and then.

-----Original Message-----
From: Bill Boles
Sent: Jan 17, 2010 2:19 PM
To: forestfutur...@googlegroups.com, forest-futures-advisor...@googlegroups.com
Subject: Re: no early successional habitat

I agree with Claudia, Nan, Cathy, Mary, Joe, Michael and anyone else that would like to see all references to allowing cutting for the promotion of early successional habitat removed from the "Vision" draft.  Early successional habitat cutting is a justification for clearcutting. The appearance of forest openings is a not only natural occurrence but also occurs around fields, golf courses, housing developments as well as on power lines, gas lines and beside roadways. We don't need to create any new early successional habitat on DCR conservation and recreation lands. Bill Boles

New England Mountain Bike Association http://www.nemba.org/ Dirt Rag Magazine http://www.dirtragmag.com/ Friends of Wompatuck State Park http://www.friendsofwompatuck.org/ --- On Sat, 1/16/10, mandchurley <mandc...@comcast.net> wrote:

From: mandchurley <mandc...@comcast.net> Subject: no early successional habitat

To: forestfutur...@googlegroups.com, forest-futures-advisor...@googlegroups.com Date: Saturday, January 16, 2010, 9:16 PM

Everyone (this is directed to the AGS members, but meant for the TSC members to hear as well. Please share with anyone not on these lists:)            I have written to the stakeholders, at your individual addresses, to avoid overloading the google groups with emails, to see if there are areas of consensus from the AGS members for making comments.    It's now time for comments.           Do any of you have a desire to combine thoughts into group comments on this most recent draft?   We are expected to make our comments by 5 p.m. Sunday           I have a concern about the proposal to allow "early successional habitat cutting" on a portion of the woodlands that are being proposed, that I have reason to believe are shared by many of us on the AGS and also on the TSC.       .   I have multiple comments I plan to make about the allocation of acres to woodlands, about language pertaining to taking wood from our forests for biomass, about language describing what can occur for cutting in the parklands and reserves, about what we should expect for renewed and better oversight of forestry where it occurs on our woodlands, and about whether FSC certification can be expected to play that role   (not) , about the idea of having a Commissioner of Forestry Stewardship,  and other comments related to this draft... but           I mention to all of you the proposal to allow for the creation of "early successional habitat" on conservation and recreation lands that exists in the draft.(lines 982 and 997 specifically, and in other places)     I simply do not think we should have that in the recommendations for stewardship of forests and parks that are in the Department of Conservation and Recreation.   And I don't think there is clear and unambiguous support for it by the TSC, either.   I would like to suggest that we all say, leave that to Fish and Wildlife.  From what I can see, opposition to forestry that creates large openings and the protection of parklands seem to be where the widest support lies.   How many of you would like to say, take "creation of early successional habitat" on DCR state forests and parks OFF THE TABLE.?            Here is what I have observed and collected on this topic:    Bob O'Connor, in presenting the DCR/EEA request for woodlands asked for 30,000 acres designated for this kind of cutting.   I have not heard anyone else advocate for it on these DCR lands. Yet it still exists in the draft of recommendations.    I attended the TSC meeting on Jan. 6, and I definitely heard some "reservations" about it from the members of the TSC:  (keep in mind, three people were absent from that meeting:   Joe Zorzin, William Moomaw and Kate Connolly.)  Of the people there,    I heard one person say:   "don't put it in with the woodlands, that's how we got in trouble".   I heard another person say, "don't make it part of the demonstration forests".   I heard another person say, "maybe we should reduce the amount of acreage to 15,000 acres".   I heard another person say, "maybe we shouldn't have any specific acreage in there, maybe we should ask DFW how much they need for early successional habitat, watch and see if natural disturbances create what they need, and only do it if it turns out to be necessary".   I heard another person say, "the science is not clear on this topic, there are different views on the need for it". I heard still another say, "I guess we should not remove any tool from the toolbox, but the clearcutting tool should be allowed to get rusty in that toolbox."   I have reason to suspect that it is possible that members absent from that meeting might also have concerns about this kind of forestry on these lands.     In other words, there is HARDLY A CONSENSUS WITHIN THE  TSC ON THE PROPOSAL FROM DCR for this idea.   So why is it still there?           On top of that,  there is a clear indication that "early successional habitat" which is essentially clearcutting, is definitely what all the negative pictures have been about on public lands.  This is a public relations nightmare for DCR.   It will continue and expand if they do it on state forests and parks.            We have two state laws that seem to indicate that the legislature is concerned about clearcutting.  One seems to be unambiguous about prohibition of clearcutting for DFW lands   (Chapter 131, Chapter 4, section 16). (They will have to face this legal question at some point).     Another is the Chapter 132 Forest Cutting Practices Act, 304 CMR 11.05 which puts restrictions on clearcuts over 5 acres or 10 acres on DCR lands.            We have several references to DCR's clearcutting of conifer plantations and justification for clearcutting for early successional habitat in the recent FSC/SCS report.  A couple of key statements are:     Page 60: (excerpts:   please see full context: )  http://www.mass.gov/Eoeea/docs/eea/lf/green_certification_report_2009.pdf Non-conformity: Prior to harvesting of conifer plantations (with often complete removal), BoF and DWSP have not completed an adequate environmental impact assessment to assess impacts on long-term ecological functions of the forest ... BoF has been the most aggressive with the least developed rationale for converting conifer plantations. For BoF the justification centers on two points: (1) that non-native species are intrinsically in conflict with biodiversity goals, and (2) aggressive regeneration harvesting of non-native stands presents an opportunity to create early successional habitat.         We also have heard from Bob O'Connor and others that the foresters can't maintain the early successional habitat that is created with the logging.... it only lasts for a few years... (15 or so?)  then they have to cut in another place to create it.   Maintaining that which is established is too expensive.   So, I have to ask:  is it really their intent to create it?  Or is it a justification for the large openings?           In sum, I personally do  not  see much if anything in the way of support for this, and I personally think there are a lot of people who would agree with me that it should be taken out of the recommendations for stewarship of DCR conservation and recreation lands.   I'll be saying that loud and clear.  It's a deal breaker for me.  If you agree, we could make a group statement.   If not, we'll just make a few individual comments, but I repeat, mine will be loud and clear.    Claudia

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[mandchurley]

Fred,

         I have not spoken directly with anyone from DFW about this law, but I did read in the green certification report where a public comment asked about this and they recorded the DFW response this way:

 

http://www.mass.gov/Eoeea/docs/eea/lf/green_certification_report_2009.pdf     page 41

 

 It should be determined once and for all whether it is against MA General Laws to clearcut on Fish and Wildlife lands.

DFW has sought legal council on the interpretation of application law and determined that clear cutting is allowable so long as it is not pursued as a profitable venture and fits with agency mandates.

 

I have asked multiple times to have Bill Logue facilitate our getting a copy of that legal interpretation, especially in light of the fact that our Forest Futures Visioning Process lawyers,  Kate Connolly and Dave Gafney both agree that the language of the MA General Law, Chapter 131, Section 4, part 16 is unambiguous:

 

 

 

PART I. ADMINISTRATION OF THE GOVERNMENT

TITLE XIX. AGRICULTURE AND CONSERVATION

CHAPTER 131. INLAND FISHERIES AND GAME AND OTHER NATURAL RESOURCES

Chapter 131: Section 4. Powers of director

  Section 4. The director may:

(skipping over other numbers down to #16)

[ Clause (16) as amended by 2008, 451, Sec. 89, effective January 5, 2009. For text effective until January 5, 2009, see above.]

  (16) enter into such contracts as the director, in consultation with the commissioner, deems necessary or appropriate in order to fulfill the responsibilities and mandates of the agency, including, but not limited to, contracts for the cutting and sale of timber on lands managed by the division, and shall deposit monies received from such contracts into the Inland Fisheries and Game Fund pursuant to section 2C; provided, however, that it shall be a condition of each contract for the cutting and sale of timber that clear-cutting timber on lands managed by the division is specifically prohibited.

 

 

 

[Whitney Beals]

Folks – I do not agree that the creation of early successional habitats should be removed from the recommendations.  Dr. David King gave a good summary of why those habitats are important if we are to maintain the full array of biodiversity in Massachusetts (ref. his brief paper:  Shrubland Birds in Massachusetts - David I. King).  In that paper he explains why the lands “around fields, golf courses, housing developments as well as on power lines, gas lines and beside roadways”  fall far short of meeting the needs of birds that rely on early successional habitats.  Claudia states in her Jan. 16 e-mail (below) that creating such habitats should be left to DFW, and then goes on to state that doing so is illegal on DFW lands.

                I managed to track down some information as presented in a PowerPoint by one Gary Donovan, then (and now?) working for the Wildlife Management Institute in conjunction with the US Fish & Wildlife Service.  The study indicates that Mass. needs to create an additional 7,500 acres of early successional habitat annually for the next 10 years (or a total of 75,000 acres) to stop the decline of the American woodcock population; more would be needed to bring it back to populations we had in the 1970s.  In BCR (bird conservation region) 14, the total is 316,000 acres just to stop the decline; nationally it’s 3.2 million acres to get back to the ‘70s.

Here’s a link to the 2005 WMI report (which might not present the info above in the same format…it’s a much longer and more detailed document than the PowerPoint):   http://timberdoodle.org/sites/default/files/woodcockPlan_0.pdf  (I have attached the Northeast region section of that report.)  The study found that woodcock populations have declined 2 to 4 per cent per year since the early ‘70s due to the loss of young forest and shrublands through a combination of natural growth and manmade habitat conversion.  Dr. King cited similar declines in other bird species.

To fulfill an earlier promise that I made at an AGS meeting, I have attached a list of 59 species of “greatest conservation need” (garnered from five New England State Wildlife Action Plans) that benefit from early successional/young forest/shrubland habitats.  One can assume that the ideal early successional habitat for woodcock is not the same as that for, say the Canada warbler or the black rat snake, but there’s probably quite a bit of overlap when comparing requirements. 

Respectfully,  Whit Beals  

 

From: forest-futures-advisor...@googlegroups.com [mailto:forest-futures-advisor...@googlegroups.com] On Behalf Of Bill Boles
Sent: Sunday, January 17, 2010 2:19 PM
To: forestfutur...@googlegroups.com; forest-futures-advisor...@googlegroups.com
Subject: Re: no early successional habitat

 

I agree with Claudia, Nan, Cathy, Mary, Joe, Michael and anyone else that would like to see all references to allowing cutting for the promotion of early successional habitat removed from the "Vision" draft.

[Michael Kellett]

Hi Whit,

Just because some early successional species are declining doesn't mean we need to artificially create habitat -- unless they are in danger of extinction. Woodcocks are not. Virtually no other early successional species is endangered in New England. The King paper and the USFWS don't refute this. They don't prove any ecological need to artificially create early successional habitat.

Michael

On Jan 22, 2010, at 11:45 AM, Whitney Beals wrote:

Folks – I do not agree that the creation of early successional habitats should be removed from the recommendations.  Dr. David King gave a good summary of why those habitats are important if we are to maintain the full array of biodiversity in Massachusetts (ref. his brief paper:  Shrubland Birds in Massachusetts - David I. King).  In that paper he explains why the lands “around fields, golf courses, housing developments as well as on power lines, gas lines and beside roadways”  fall far short of meeting the needs of birds that rely on early successional habitats.  Claudia states in her Jan. 16 e-mail (below) that creating such habitats should be left to DFW, and then goes on to state that doing so is illegal on DFW lands.

                I managed to track down some information as presented in a PowerPoint by one Gary Donovan, then (and now?) working for the Wildlife Management Institute in conjunction with the US Fish & Wildlife Service.  The study indicates that Mass. needs to create an additional7,500 acres of early successional habitat annually for the next 10 years (or a total of 75,000 acres) to stop the decline of the American woodcock population; more would be needed to bring it back to populations we had in the 1970s.  In BCR (bird conservation region) 14, the total is 316,000 acres just to stop the decline; nationally it’s 3.2 million acres to get back to the ‘70s.

[Whitney Beals]

Michael – Since we have the means to stop, or at least slow, the decline of certain species through habitat management, it would seem irresponsible to let those species get to the brink of extinction (or elimination from the Massachusetts landscape) before taking action.   Regards,   Whit

[Alexandra]

Whitney:  The reason you name is why the environmental comunity has not objected to the forestry work of the Div. of fish & wildlife even tho the Div. is allowing large cuts in derogation of their charter law.

[Michael Kellett]

Hi Whit,

I respect the point of view that there are some species that people might not want to lose. I myself like early successional species just as well as late successional species. My point is that it is a legitimate question, but it's a social question, not a scientific question. In terms of how to address it, I tend to agree with Dave Gafney, that instead of logging existing forest lands to create early successional habitat, why not buy failing farms and keep a portion as fields and early successional habitat?

Best,

Michael

[mandchurley]

It may add to this discussion to note that in the FSC/SCS report of April 2009, which the TSC apparently wants to continue to use for guidance,  concerns are expressed about the rationale for early successional habitat used by BOF and DWSP to justify clearcutting.    In addition to those concerns which I have submitted previously, the peer review has more discussion of this topic:

http://www.mass.gov/Eoeea/docs/eea/lf/green_certification_report_peer_review_2009.pdf

Page 7

Given that in several instances the audit team observed harvested Norway spruce plantations regenerating or returning to Norway Spruce (with no actions by the State to correct this), the argument of removal of an exotic (i.e., restoration of native hardwoods) was not a sufficient justification for converting mature conifer plantation stands. Creating early successional habitat was another stated rationale for removal of conifer plantations. However, the FSC Northeast Standard does not explicitly state that managers should be creating early successional habitat nor does it mention early successional being of importance. The States rationale for these treatments do not take into consideration the fact that such plantations offer valuable habitats, viz. dense mature coniferous habitat used during migration and as winter habitat for animals. In addition, such habitats require at least 50 years to create, whereas early successional pioneer hardwoods require only a year or two. The precautionary principle would thus suggest that clearcutting such stands would be a last, not first, resort (as mentioned again, below, Norway spruce is non-invasive). The evaluation team found no evidence that the positive aspects of maintaining these plantations on the landscape have been considered, and thus BoF and DWSP have not presented a balanced environmental impact assessment – that addresses the pros and cons of their maintenance – prior to implementing a program for their rapid removal. The combination of the lack of proper environmental assessment and the huge public outcry to conifer plantation removal- warrants a CAR that requires analysis to be completed before any of these harvests are continued. The team also feels that given the controversial nature of this issue an independent review is warranted.

 

Page 9 and 10:   SCS was defending the need for Minor Corrective Action Request (CAR)

2009.13

This was the CAR:  Specifically addressed to the Watershed properties,   from the SCS report

http://www.mass.gov/Eoeea/docs/eea/lf/green_certification_report_2009.pdf

Page 59

DWSP shall conduct an analysis that fully addresses the ecological impacts of clearcutting healthy mature forest stands. The assessment must:  include an analysis of the disturbance history of the landscape at the site and landscape level and consider the range of species potentially impacted among all representative seral stages;  include biodiversity experts; and  the results of this review must be incorporated into written guidelines to be used in making future silvicultural prescriptions for intact mature forest stands.

 

The Peer Review questioned the need for the CAR, and this was the SCS defense:

 

SCS Response: The team agrees that there is evidence that early successional species have declined in New England over the past 35-40 years based on Breeding bird Survey data. Partners-in-flight species of high concern in the two regions that encompass MA include more species that have associations with mature forests (Wood Thrush, Canada Warbler, Blackburnian Warbler, Black-throated Blue Warbler, Cerulean Warbler, Worm-eating Warbler, and Louisiana Waterthrush) than have associations with young forests (Chestnut-sided Warbler, American Woodcock, Golden-winged Warbler, Prarie Warbler, Blue-winged Warbler). Of the latter group, the chestnut-sided is a habitat generalist, the golden-winged is associated with higher elevation wet forests, the Prairie is associated with pine-oak barrens, the woodcock requires more permanent open areas, and the blue-wing is actually a threat to the golden-wing. With this information, the CAR is simply asking that the agency determine whether their clear-cutting practices will provide habitat for the early successional species that are currently declining and whether the practice will have a negative impact on species that require mature, intact forests. The agencies have documented disturbance type, patch sizes of the disturbances, and return intervals. However, from the information provided and from what is included in the management plans, the agencies have not used the information to help them plan for the restoration of the long-term ecological functions of the forest. The audit findings are asking them to calculate the range of acres that would be expected on the landscape given the natural disturbance history of these forests. For example, how much of the landscape (range of acres were in early successional habitat)? How does that compare to what exists today on the landscape? If there is less now than historically, then they are justified in creating more.

It may also be useful to recognize there are several issues that came together to cause the team to develop this CAR. Again, the team took the approach of consolidating several areas of non-conformance into a single CAR. Additional Indicators that provide context for this CAR include Indicators 5.1.e, 6.1.e, 6.3.a.7, and 8.2.c.1. The ecological disadvantages of clearcutting relatively rare mature conifer stands to develop early successional habitat, when the same early successional habitat can be created from more common stand types, seems obvious to the team, as well as to many involved citizens. A "range of natural variability" analysis (like MN and many other federally managed areas as well as much of the public land in Canada) is one of the approaches that could be used to address this CAR. Citation: Hanowski, J. M. 2002. Habitats and landscapes used by breeding Golden-winged Warblers in western Great Lakes forests. Loon 74: 127-133.

 

 

----- Original Message -----

From: Michael Kellett

To: forest-futures-advisor...@googlegroups.com

Sent: Friday, January 22, 2010 2:55 PM

Subject: Re: yes to early successional habitat

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[Whitney Beals]

Michael – Good suggestion regarding the purchase of failing farms, but hard to effect due to the scarcity of purchase funds, the current priorities in place for the use of those funds, and the lack of funds and personnel to manage existing DCR (and DFW) lands.  There’s also a dwindling number of failing farms available for purchase at affordable prices. 

                I am not suggesting that DCR should initiate an effort to create substantial acres of early successional habitats beginning tomorrow.  I am advocating that creating those habitats should remain an option for DCR to implement, but only when necessary, as determined, in part, by assessing habitat status statewide on all lands, both public and private.

[Michael Kellett]

Hi Whit,

My biggest problem is to prescribe a certain acreage for early successional habitat, knowing what we know today. If we are more results oriented and flexible -- as you are describing it -- rather than prescriptive, it makes me a lot more comfortable. But I would want to be sure that we determine when creating early successional habitat is "necessary" through a thorough scientific and social review process. I am not convinced that this has been happening in many cases. I am also concerned about using clearcutting for any purpose, but there might be a way to use very small patch cuts on a small proportion of lands already open to logging. I'm not against these things being discussed.

Michael

[Dicken Crane]

Micheal

It is important to understand that early successional habitat implies succession. Occasionally mowing old fields is not going to support succession. It is important to understand that creating habitat for species that depend on the early successional state close to farms and homes creates an eco-trap. Cats, dogs, skunks, raccoons, rats and cow birds will take advantage of their proximity to nesting. Truly beneficial early successional habitat should be well buffered from our pets and vermin associated with people. It is also important to understand how ephemeral early successional habitat is. In 10 to 15 years saplings have begun to shade out the berries and their associated pollen and nectar producing blossoms. Pin cherry will begin producing blossoms and berries but will senesce in another 10 years and these berries won't be accessible from the ground. In 30 years the site will be a young pole stand, providing many habitat values but not the early successional ones. Again it is important realize that healthy stands are not the place to create early successional habitat. Stands that have been degraded, often by previous high grading but in some cases storm or pest damage are the appropriate candidates for the creation of early succession habitat. Ultimately you have to recognize that you need to replace the early successional habitat that has succeeded to the pole stand condition and eventually to a mature forest that is likely to be much better than the one that was cut to make it.

30 years after clear cut