Foothills Landscape Project Comments
by Georgia ForestWatch, the Southern Environmental Law Center, and the Georgia Chapter of the Sierra Club
The first official comment period on the Foothills Landscape project has come and gone. The Forest Service released a scoping notice (proposed action) with over 50 pages describing their plans for about 145,000 acres around the edge of the mountains. However, the description was as notable for what it left out as for what it included – nowhere did the Forest Service identify the actual locations where they planned silvicultural treatments. Georgia ForestWatch worked with the Southern Environmental Law Center and the Georgia Chapter of the Sierra Club to describe to the Forest Service the risks and repercussions of that omission. We also offered suggestions on the proposed actions, including the over 20 kinds of silvicultural treatments, rare community management, prescribed fire, and the road network changes. Copied below is the executive summary from our official comments. The complete comment letter can be found at https://gafw.org/wp-content/uploads/2018/01/2017-12-22-Foothills-Scoping-Comments-FINAL.pdf. More information on the Foothills Project can be found at https:/www.fs.usda.gov/project/?project=52509.
Georgia ForestWatch, the Georgia Chapter of the Sierra Club, and the Southern Environmental Law Center have been involved with the Foothills Landscape for over 30 years. Our members routinely hike, hunt, and otherwise recreate on this section of national forest, and many live in the landscape. We are personally committed to seeing successful management of the landscape.
We support the agency’s effort at conducting landscape-scale analysis, but the lack of specific information in the proposed action has impaired the public’s ability to provide constructive feedback on this project, far more so than in previous projects. While this project may be planned on a larger scale it still requires fine-scale, site-specific information and analysis. Without knowing the specific location of treatments, we cannot assess plans for individual stands or the scale of the project. When visiting individual stands in the field, we have not been able to determine which treatment is most likely, only a range of treatments. When considering watersheds and other larger units, we cannot assess cumulative impacts.
Being able to visit stands to be treated is indispensable for constructive public participation in public lands management in the Southern Appalachians. On past projects, stand-specific information has led to beneficial public comments on rare and at-risk resources, and the efficacy of proposed treatments. Visiting stands allows the public to check the quality of data supporting plans. Location of treatments, independent of what is being treated, impacts how adjacent resources will hinder or facilitate treatment and how a treatment will interact with nearby treatments. Trying to account for all of these variables in advance is impossible and misses the point that it is often the unforeseen factors that turn out to be the most important.
We support the agency’s desire to collaborate and recognize the benefits of having different groups work together for a common goal. But collaboration is not a substitute for National Environmental Policy Act (“NEPA”) compliance. More specifically, the promise of future collaboration on site-specific decision making is not a substitute for considering site-specific issues now, during the NEPA process. We are confident that we can work with other forest stakeholders to develop a consensus-based project and ask that the agency facilitate that outcome. As part of that, the agency should focus discussion more on points of common ground rather than contention, which we fear will ultimately undermine efforts at collaboration. We continue to believe that clearly stating the agency’s constraints for performing work in the Foothills would channel discussions in a more productive direction. Since the agency’s descriptions of “collaboration” have shifted away from “build[ing] and promot[ing] a collective vision,” we would appreciate the agency clarifying what it is seeking through collaboration.
We support true restoration, but we remain unsure of how the agency understands “restoration” when describing “[t]he Foothills Landscape project [as] a restoration project.” The agency has described the project as both “functional restoration” and “ecological restoration,” which are not synonymous. Forest Service Manual prerequisites for applying functional restoration have not been satisfied. References to “achievable future conditions” in project documents add further confusion to the agency’s approach to restoration. We continue to believe that the agency should define its restoration goals using applicable from the agency’s 2012 Forest Planning Rule. More clarity on these issues would help the public better understand and evaluate this project.
This project includes over 20 potential silvacultural treatments. We are concerned the scale of treatments, up to 90,000 acres, threatens water quality, wildlife populations, invasive species control and recreation while contravening the public’s desires for the landscape. Similarly, the extent of herbicide use, potentially over 60,000 acres, presents qualitatively different risks than found in previous, smaller projects. We are also concerned that in trying to promote a few common desirable species, many desirable but less common species will inadvertently be harmed, such as serviceberry and persimmon. Plans to harvest older mid-successional forests (100-120 years old or more) will perpetuate the shortage of truly late successional forests (though the project does preserve some of the most important old forests, existing old growth, which we support). Many treatments in this project make commitments to follow up actions which have been promised in the past but not always fulfilled. The agency should consider the effects of the treatments if follow-ups cannot be implemented due to future budgetary or logistical restrictions. Applying prescribed fire before rather than after timber harvests may increase the effectiveness of treatments for multiple reasons. The experimental treatments, scale of the project, and novel conditions on the landscape make monitoring for this project more important than ever.
We appreciate the agency’s focus on southern yellow pines. They may have expanded some in response to past land use, but there is a shortage of regeneration across the Foothills. Where prescribed fire is available for pine maintenance, we believe that in the long term, fire alone would produce more effective restoration than the proposed combined fire and timber treatments. Where expanding gaps treatment is used for maintenance, thinning the surrounding stand will interfere with producing the desired stand conditions. We support the southern yellow pine restoration treatments, but we are concerned about the vulnerability of the resulting stands to southern pine beetle. The proposed action appears to omit some of the best opportunities for restoration treatments, in pole-aged stands. In the natural regeneration version of the treatment, removing the residual seed trees is completely counterproductive and will harm biodiversity. We support the thinning of pine plantations.
Oaks play many important roles in ecosystems, including as wildlife resources. Their decline also deserves management action. Similar to southern yellow pine maintenance, oak maintenance treatments would benefit from relying on prescribed fire where available and excluding thinning the surrounding stand from the expanding gaps treatment. Our views of the oak restoration treatments also parallel our views on the pine treatments – general support with concern about locations. We have no specific issues with the crown touch release treatment and believe oak restorations of pine plantations are likely to be some of the most consistently successful treatments.
The woodlands workshop appears to have been productive as the woodlands description in the proposed action is the best we have seen in any scoping document. Unfortunately, without knowing specific locations, we cannot tell if any of the proposed woodland treatments are suitable. To better understand the agency’s view of woodlands, we would appreciate knowing more of the original research or accounts that underlie its view.
We recognize that early successional habitat (“ESH”) may be departed from natural levels in some parts of the forest. The proposed action appears to omit several important sources of ESH, so the extent of the problem is overestimated. Stands that developed following agricultural abandonment would be good places for ESH on mesic habitats. Care needs to be exercised in producing ESH along existing edges, because the process could establish large, non-native invasive species populations. We see no reason to produce new permanent openings. Permanent openings are not restoration and provide inferior habitat. Changing management of right-of-ways also seems unnecessary as they are already in the desired condition. Finally, ESH should not be created in older forest. To the extent ESH is departed from natural levels, older forest is even more highly departed.
As proposed, the canopy gap treatment also does not appear to be restoration. The proposed gaps are larger, as a rule, than those produced by natural events. Literature also suggests the target wildlife species prefer smaller gaps.
The general forest health maintenance treatments cannot be evaluated without additional information. Additional information on location, species, and interaction with other treatments is needed.
Non-native invasive species (“NNIS”) are one of the biggest issues facing the Foothills. We realize the agency does not have resources commensurate with the magnitude of the problem, but the landscape scale approach is an ideal opportunity to more effectively deal with the problem. Mapping existing NNIS populations and prioritizing treatments are essential steps that collaborators can help with. More effective monitoring and follow-up of contracted treatment are also needed. Finally, there is a dire need to have plans in place before anticipated non-native pests and pathogens arrive.
We are glad to see efforts to restore wetlands, canebrakes, and American chestnut included in this proposal. We support research efforts on using high-light treatments to facilitate field insectaries and predator beetle control of hemlock woolly adelgid, but strongly urge the agency against trying to use high light levels as a stand-alone treatment to save hemlocks. Without other interventions, hemlocks exposed to the hemlock woolly adelgid die regardless of light level. We believe out-planting hemlocks is premature (unless part of a larger research effort), but support expanding hemlock conservation areas. All rare habitat treatments should include thorough monitoring.
We support the use of prescribed fire to reduce the risk of wildfire where prescribed fire can be effective. In general, there is not enough information on the use of prescribed fire to offer constructive feedback. More information on the full fire regime – frequency, intensity, season, size, and location – needs to be supplied, because fire effects depend on these variables.
Climate change will affect every ecosystem, species, and activity in the Foothills. Its impacts on the landscape and proposed treatments need to be carefully considered. The increasing precipitation variability that has been observed in the region suggests that the impact of commercial timber harvests on soils and streams will increase. The impacts of treatments, particularly at the scale proposed, on salamanders will also be more severe.
The proposed road maintenance level changes will help maintain water quality and access to more important areas of the forest. These changes will also help limit illegal dumping on the forest. Felling multiple trees across the road is likely the most effective way to close them. We feel Rock Flats Road (630D) should remain closed as it penetrates an otherwise exceptional block of core habitat.
Throughout our letter we raise concerns about compliance with various legal standards. We emphasize two here. First, the proposal to sign a decision document without knowing where actions will occur on the ground, and what those actions may be, prevents the agency from assessing project impacts and the potential to mitigate those impacts in compliance with NEPA. Second, given the scale of this multifaceted project it is guaranteed to have a significant impact on the human environment. To move forward with the project as planned the agency must prepare an Environmental Impact Statement.