Photo by Jess Riddle
by Jim Walker & David Govus : District Leaders
For those of us who have participated in the Foothills Landscape Community Collaboration, it has been a long road, and the process at times seems interminable. It began with a Collaborative Learning Workshop in June 2016, followed by Community Conversations in five different locations in October through November 1. Then came four Proposal Development Workshops in January, March, May, and July of 2017, each consisting of one full day followed by a shorter session the next evening. And there have also been an all-day science symposium and five field trips, with more to come. As of this writing, there have been seven additional focused-issue discussions or field trips scheduled through August, to be followed by more Community Conversations in the fall. ForestWatch, the Southern Environmental Law Center (SELC), and the Georgia Chapter of the Sierra Club have been committed participants throughout this process, representing a much-needed conservation voice.
The Forest Service has started incorporating comments from these Community Conversations in a Draft Restoration Plan for the Foothills Landscape Project document. This document can be found on the Foothills Landscape website (https:// www.fs.usda.gov/detail/conf/home/?cid=fseprd514937) and is the rough draft of an eventual scoping notice (proposed action) expected to come out in October. At this stage it is not clear how detailed this project scoping will be, and whether individual stands and proposed treatments will be identified in this document or a later scoping notice. Either way, it will be nearly impossible for ForestWatch to survey all the sites where treatments are likely to be proposed (at least based on conversations during the collaborative meetings) in just 30 days – the time typically allowed for a scoping response.
But there is more! During the first five months of 2018 there will be workshops for critiquing the proposed actions, followed by additional workshops from May through October 2018 to analyze the environmental effects of the proposed projects.
This type of collaborative process on such a project-specific, large landscape scale has not been done before on this forest or any other forest within the Southern Region of the Forest Service. The Southern Region encompasses 13 States – from Virginia to Florida and Oklahoma – as well as Puerto Rico. So who knows? Maybe all of these collaborative conversations and workshops will lead to some kind of consensus, or at the very least, mutual tolerance of proposed actions.
Extensive notes from each Workshop were recorded and can be viewed online under the “Workshop Harvest” sub-heading – along with an abundance of information about the Foothills Landscape and the Draft Restoration Plan for the Foothills Landscape Project. In the midst of so much information and so many diverse opinions, Georgia ForestWatch, SELC and the Georgia Chapter of the Sierra Club felt the need to offer their thoughts in writing because the concepts discussed in the Draft Restoration Plan are complex, and the time to discuss them in detail during in-person collaborative meetings has been somewhat limited (understandably so).
The remainder of this article is a highly abbreviated summary of our comments on the Draft Restoration Plan for the Foothills Landscape Project. We have selected excerpts from an 18-page letter sent to Angie Bell, the Foothills Project Team Leader, on June 9th on behalf of Georgia ForestWatch, SELC, and the Georgia Chapter of the Sierra Club. The letter was intended to further the collaborative effort, not stymie it. Any text within quotation marks is from the Draft Restoration Plan document.
I. Sustainable Recreation
We wholeheartedly endorse the agency’s “desire … to provide recreation settings and opportunities within the Foothills Analysis area that are economically, environmentally and socially sustainable,” and also understand that the agency does not currently have sufficient funding to adequately maintain its existing network of recreational facilities and trails. To mitigate impacts we support the general concept of focusing limited agency dollars on high-use sites with demonstrated needs for maintenance or mitigation of natural resource impacts, and limiting access to low-use sites causing significant adverse impacts to natural resources.
II. Watershed and Aquatic Habitat Health
We support the agency’s efforts to right-size its road system by spending limited agency funding on high-use roads and decreasing access to low-use roads that cause significant adverse impacts. We also agree with the agency that one of the primary threats presented by an out-sized road system is sedimentation of streams. We suggest prioritizing road maintenance funding on high-use portions of roads close to impaired streams and decommissioning or downgrading maintenance levels of low-use roads near impaired waterways. The agency should avoid any commercial timber harvesting in the Riparian Corridor and instead focus commercial harvesting in areas with a functioning road system in place.
III. Non-Native Invasive Species
We agree with the agency that “non-native invasive species need to be reduced across the landscape and measures need to be in place to minimize their spread during implementation of the Foothills project.” We believe invasive species represent one of the greatest threats to the ecological integrity of the Foothills. As such, the agency should minimize the likelihood of the spread of invasives into uncolonized areas by avoiding road building and mechanical treatments in unroaded areas.
IV. Old Growth
Old-growth forest was predominant in north Georgia prior to European settlement; now it is less than 3% of the Chattahoochee National Forest. Because existing old growth is so rare, we are opposed to any harvesting of existing old growth and likely cannot support a project that contemplates cutting existing old growth. Nor do we think the agency can justify harvesting existing old growth given the biological, ecological, cultural, aesthetic, and spiritual values old growth provides.
Regarding future old growth, we support the agency’s efforts to implement the Forest Plan objective requiring 5% of each 6th level HUC [hydrologic unit code] with at least 1,000 acres of national forest system land to be designated as existing or future old growth, though in truth we think (and the best available science supports) that much more than 5% of the forest would be in old growth under a natural disturbance regime. To truly utilize the best available science and move the forest closer to its NRV [natural range of variation] the agency should consider designating areas as future old growth even above the 5% requirement.
V. Protecting Communities from Wildfire
Protecting communities from wildfire is an important goal, and we support the agency’s commitment.
According to the Draft Foothills Restoration Plan, the collaboration will create a restoration plan that will guide the development of the proposed action.
We are pleased that the agency envisions the Foothills project as a restoration-based project. The Foothills Landscape and its watersheds have been affected by past management and other anthropogenic disturbances, including the intense logging program implemented in the southern Appalachians in the last century and a half; invasion of exotic species and loss of keystone species such as chestnut and hemlock from NNIS [non-native invasive species]; the replacement of mixed pine-hardwood communities with single pine species; altered disturbance regimes (e.g. fire frequency and loss of beaver habitat); private land development; and high recreational use. Projects that serve legitimate restoration objectives have the opportunity to enjoy widespread support as they meet ecological needs, allow the agency to remove timber from the forest, and create early-successional habitat for game species. Restoration projects can be a win-win-win for the agency – bringing together wildlife, timber, and conservation interests that have struggled at times to find common ground in the past.
But restoration must also be grounded in Forest Service guidance on restoration which relies on the best available science. To rephrase, the agency’s assessments of what is and is not restoration must be based on the agency’s regulations, not only on public input.
The goal of restoration, under the [Forest Planning] Rule, is to establish “the composition, structure, pattern, and ecological processes necessary to facilitate terrestrial and aquatic ecosystems sustainability, resilience and health under current and future conditions.” The natural range of variation is “the full range of variation produced by dominant natural disturbance regimes” and generally refers to a “pre-European reference period.”
These agency regulations provide several key takeaways that should guide evaluation of restoration opportunities in the Foothills area. First, restoration is focused on areas that have been “degraded, damaged or destroyed.” In other words, areas of high ecological integrity – where the dominant ecological characteristics occur within the natural range of variation – are not candidates for restoration treatment.
Second, restoration seeks to move the composition, structure, function, and connectivity of forest ecosystems toward the natural range of variation (NRV), or the range of variation produced by natural disturbance regimes prior to European influence. We suspect that in the Foothills area two structural conditions are highly departed from NRV: lack of old-growth forest and lack of ESH [early successional habitat].
Third, because restoration moves the forest closer to NRV, site-specific restoration activities should move the forest toward a condition that would naturally occur in that specific area. Creating a new ecosystem in a specific area, when there no evidence that ecosystem naturally existed in that space, is not restoration.
Fourth, restoration must consider landscape-scale concerns as well as site-specific concerns. For instance, forcing woodlands on a site to meet a forest-wide objective, when there is no evidence that woodlands are appropriate for the site, is not restoration of woodlands but an effort to create woodlands anew. The latter would likely take much more intensive management to maintain the woodland.
VII. Specific Restoration Opportunities in the Foothills Area
The agency has indicated a number of ecosystem types that it hopes to restore on the Foothills landscape. Where possible, we have identified sites where restoration of those ecosystems has a good chance of success. Because of the size of the Foothills analysis area, we have not been able to make site-specific recommendations for all ecotypes.
a. Yellow Pines
We agree with the agency that we need to look for opportunities to restore shortleaf, pitch, and table mountain pines (yellow pines) “on sites where they once likely occurred.”
To have a productive conversation about woodlands, including where they exist or should exist on the landscape, we think it is critical to get all collaborative participants on the same page regarding how the agency views woodlands. It seems essential for all participants to understand what the Forest Service envisions when it discusses woodlands. In that regard, the following questions are ripe for resolution:
- Is a woodland an ecosystem or a structural condition? The Forest Plan defines a woodland as “a plant community in which trees are often small, characteristically with a greater portion of their total height being crown than clear bole, and having trees spaced far enough apart that the canopies of adjacent trees do not touch and with the ground vegetation being mostly herbaceous, commonly grass.” We think that definition makes clear that a woodland is a particular ecosystem, i.e. a ‘plant community.’ Success in creating woodland, and analysis of where woodlands are appropriate, must be evaluated according to whether the treatment results in (or is likely to result in) a functioning woodland ecosystem with woodland-endemic species and conditions.
- What does woodland look like? There seems to be some level of agreement that a woodland is an area with widely scattered trees and an understory of grasses and herbs. The trees would be relatively short with more significant horizontal than vertical branch growth.
- Where are woodlands located? The lack of large trees, wide spacing of trees, and understory growth in woodlands, particularly as compared to other areas on the Chattahoochee, must indicate that site-specific conditions limit tree growth and reproduction in woodland areas. These conditions could be soil quality, grazing, or potentially fire.
c. Mountain Bogs and Canebrakes
We support the restoration of mountain bogs and canebrakes.
It is our view that plantation restoration should be a priority in the area. Restoration of these areas to a more natural mix of oak/pine forests will increase their resilience to warming climate and more severe drought.
Plantations are not a natural ecosystem and are therefore highly departed from NRV. Where appropriate, the Forest Service may choose to restore plantations using timber harvest to benefit local loggers and allow the Forest Service to accomplish timber objectives. In short, treating pine plantations is likely to be uncontroversial but likely to result in ecological,wildlife, forest health, and economic benefits.
We support research and efforts to incorporate experimental chestnut studies and research results into the Foothills project.
f. Threats to Other Native Species
We support taking proactive steps to protect several other species native to the foothills that may soon face a fate similar to chestnut and hemlock.
g. Forest Composition and Structure
It is not accurate to state that “both mid-late and late (alone) successional habitats exceed the desired ranges” – the classes only exceed the minimum amount. We believe there is still a shortage of early successional habitat (ESH). However, there is not an excess of late successional habitat
(as defined by the Forest Plan), and there is a shortage of true late successional habitat.
h. Beaver Reintroduction
We support restoring beavers to streams that they likely once occupied, where practical.
VIII. Timber Harvest in Unsuitable Prescriptions
Based on acreage totals presented in the May 23 workshop there appears to be more than adequate acreage in the suitable base for the Forest Service to conduct timber activities. If the agency chooses to pursue actions in unsuitable prescriptions, it must justify those actions in accordance with the National Forest Management Act. Creating ESH in unsuitable prescriptions is never appropriate because ESH can be created anywhere on the landscape, including in suitable prescriptions. Conversely, restoring a pine plantation to a more appropriate, natural mix of hardwoods and soft woods may be appropriate in unsuitable prescriptions because the justification for the treatment is site-specific – restoring that particular pine plantation – and cannot be met in another stand.
While there is opportunity for disagreement about what constitutes restoration, there is significant opportunity for agreement on the right type of work, in the right areas across the Foothills Landscape. We ask the agency to focus treatments on areas where there is high, perhaps unanimous, agreement that a treatment is in fact restorative.
To read the entire letter, click here.