Recent Correspondence

FINGER LAKES FOREST WATCH
“Dedicated to educating the public about Forest Service land management in the Finger Lakes National Forest”

TO:  
Kathy Donna
NEPA Editor
231 Main St
Rutland, Vermont  05701-2417

Dear Ms. Donna,

After spending many hours on the ground in the proposed Cotton Mill Timber Sale Project Area, attending the Forest Service field trip and doing research to facilitate public involvement with the sale, Forest Watch has the following comments:

Preface

Because all the stands in the proposed sale are categorized as M.A.3.1 in the current LRMP, the prescriptions for each stand (excepting stand 7, the pine plantation) determine to manage the timber specifically for future desired conditions featuring oak and maintaining 10% of that forest type in the 0-9 year age class.

Stands 3, 5, and 12 and the northern portion of stand 6 occur in some of the oldest forest areas in FLNF. These areas appear as established forest in 1938 aerial photos, the result of natural regeneration since clear cuts in the early and mid nineteenth century. During the early settlement of the Hector Backbone, most of the timber was cut and sold, and then the land was put into cultivation and pasture. Areas too steep or wet to plow reverted to woodland. Some of these woods are now as much as 200 years old, as evidenced in tree rings on stumps adjacent to stands 5 and 12. Stumps adjacent to stand 6 are as much as 150 years old. Stand 2, near stand 3 in compartment 33 had a date of origin of 1850. Stand 2 was logged in the 1980’s and the opportunity to study its ecology has been lost. Managing stand 3 as well as all the Oldforest type remaining in FLNF for continuous forest cover (per the prescriptions for M.A.2.1) will preserve opportunities for research and education. Areas of this habitat type are rare in the FLNF and should be managed carefully so as not to loose this habitat and forest type in the future. Oak has regenerated well in these areas since conditions at the time of origin of these stands (clear-cut or burned over land) favored shade intolerant species. Deer browse at that time was repressed due to a drop in deer population from over hunting and habitat loss following Euro-American settlement. Chestnut, a significant component in the original forest, left a! n open ecological niche after succumbing to chestnut blight and this gap was readily filled by its competitor, oak. Preserving Oldforest as a type in FLNF enables future foresters to relate patterns of species composition in areas of natural regeneration to experimental regenerative manipulations. Oldforest provides a context for defining reproducible results following the original natural disaster of white settlement. Existing conditions in these stands provide important reference points for the examining the complex roles of multiple factors in stand establishment after severe disturbance.

COMMENTS:

1.  Species diversity and age class distribution in Stands 3, 5, 12 and northern 6 are indicative of conditions of natural succession and forest recovery. Such conditions are becoming increasingly rare on private lands (witness the logging on private lands adjacent to stand 6 and stand 5, as well as the Forest Service shelterwood cut adjacent to stand 12). Natural conditions in areas of successful oak stands are valuable references for developing models of manipulating oak regeneration and should be preserved as the future desired condition wherever it exists in FLNF.

2.  Only in these oldest forested areas of FLNF, especially in areas that have never been plowed, can the least disturbed soil composition, texture and chemistry be studied for refining models of Ecological Land Types. Maintaining the existing forest type is essential to checking ELT predictions against actual regeneration.

3.  The native plant associations within a mature closed canopy forest (we question the classification of stands 5 and 12 as immature) will change when the canopy is opened, competing plant species arrive and soil temperatures rise. An opportunity to study native plant assemblages in relation to soil type and neighboring tree species will be lost if the community ecology is altered to meet M.A.3.1 future desired conditions.

4.  All the stands under consideration are in areas of high or moderate sensitivity for Native American occupation. Stand 6 is in close proximity to all 3 of the reported Native American archaeological sites on FLNF. The woodland condition of these stands should be managed either as a special area (M.A.8.1) or, at the very least, continuous forest cover (M.A.2.1). Maintaining closed canopy conditions would better protect the soil, and future opportunities for ethno botanical and archaeological studies would be preserved by minimizing surface disturbing activities.

Stands 7, 5, 3 and 12 are adjacent to abandoned roads from the 1850 settlement area. These roads and the locations of settlers’ houses, mills, schools and churches along them are evident on the Tompkins County 1853 map of Hector. These abandoned roads are ready made trails and natural avenues of research and education about 19th century history and archaeology. SUNY Brockport has already conducted an archaeological field school involving excavations of homestead sites on Burnt Hill close to the timber sale project area. The forested areas adjacent to these homestead sites, if they include secondary old growth (as in stands 5 and 12) are significant cultural and historical resources for interpretive and educational activities. Opportunities to study such “time capsule” landscapes are not available from other lands and altering the forest type in stands 3, 6, 5 and 12 violates the Forest Plan goals of

1) protecting significant cultural and historical resources (the existing forest type is integral to the cultural landscape)

2) Providing a variety of goods and services, emphasizing those not available from other lands.

These sites are rich in Uncommon and Intangible Values such as those protected in the Forest Plan.

5.   The 2001 Forest Inventory represents, at best, a snapshot look at the stands in question. The stands under consideration for the Cotton Mill Sale should be reevaluated for Year of Origin and Stand Condition designations. Stand Condition descriptions should be checked for consistency with Animal Habitat Codes. Soil Type data should be provided. Visual quality Objectives should be reconsidered in a cultural landscape context.

6.  The majority of FLNF is already an even-aged forest of 60-70 years old that has been established since Federal acquisition of the property in the 1930’s. Much or the presently forested area of FLNF was abandoned or degraded farmland bought specifically for soil restoration through reforestation. There are ample opportunities in these young woodlands to manipulate the post 1938 reforested areas for oak regeneration to meet M.A.3.1 goals.

While understanding that the Revised LRMP may not be implemented soon, management Area designation could most fairly be regarded as flexible during the transition.

SUMMARY

If tabling the implementation of the timber sale is not feasible until new management area designations for the proposed project areas (To Special Area, Interior Forest or Shade Tolerant Forest) can be assigned in the Revised Forest Plan, then the least irreparable results would occur from framing the objectives of the sale to match those of current M.A.2.1. There will always be future opportunities to open the canopy and manage for shade intolerant oak. Presumably, further research and Sylva cultural experience in FLNF will enhance the skill of the Forest Service in maintaining a steady supply of valuable s! aw timber and maintaining a natural forest environment.

If the existing forest type in the project area (excepting the plantation) is manipulated to meet M.A.3.1 desired future conditions, we will lose forever a valuable resource for studying both ecological and cultural succession on the Hector Backbone. Rather than focus on prolonging the lives of individual old trees indefinitely, Forest Watch feels the most ecologically and economically responsible course is to maintain the existing closed canopy forest conditions rather than manipulate the forest type for predominantly shade intolerant species, taking ex! tra consideration to leave the best genetic material of all species currently represented to reseed the gaps created by thinning.

Thank you for considering these comments in the environmental analysis for the proposed Cotton Mill Timber Sale.

Kathyrn Engel

Submitting comments for:
Finger Lakes Forest Watch
Friends of the Forest Education Committee
Ground Truth Scouts
Finger Lakes Old Growth Survey Team