Maryland Alliance for Greenway Improvement and Conservation

October 26, 2003

George Winfield, Director

Baltimore Department of Public Works

200 N. Holliday Street

Baltimore, MD 21202

Ref: Comprehensive Forest Conservation Plan for City of Baltimore Reservoirs

Dear Mr. Winfield:

The goals for the Forest Conservation Plan for Baltimore’s reservoirs were clearly and distinctly described in the referenced document as being:

• The protection and enhancement of water quality,
• The maintenance and restoration of regional biological diversity within the public lands surrounding the reservoirs,
• The management of woodlands to maximize forest habitat value, and,
• Providing recreational opportunities compatible with the above objectives.

Although the primary goals for the forests surrounding the reservoirs were clearly articulated, the conclusions drawn in the report simply do not meet those goals.

It would appear from the report’s conclusions that the goals set for forest conservation were to log the forest around the reservoirs of Baltimore. The report concludes that 1,230 acres of forest will remain "untreated", while the remainder of the 17,580 acres are to be "managed" - a euphemism for logging . You need to question why the most sensitive areas of the forests, like stream riparian buffers, are being preserved while logging is recommended for the rest of the forest. This immediately should suggest that logging is not a particularly good activity for a sensitive area like a forest that surrounds and protects a water reservoir.

The reservoir study starts out by explaining numerous studies of watersheds "provided evidence that forest ecosystems provide the best protection for water quality". Why then would anyone contemplate logging the forests to protect water quality? Trees that are removed can no longer protect the water in the reservoirs.

Roads cause pollution in a watershed, but they are necessary components of most logging operations. Roads are bulldozed into the earth and expose the open ground to the elements like wind and rain. Sediments washing off roads, and oils escaping from vehicles wash into streams and into the reservoirs. While some polluting effects of roads can be minimized with pollution control devices more commonly known as best management practices, these devices and BMPs are never 100% effective. Sediments and oils will still wash into the reservoirs if new roads are built to log trees around them.

Forest Roads: A Synthesis of Scientific Information is a technical report released by the US Forest Service in May 2001. It provides a detailed description of the problems created by forest roads including their effect on hydrology and geomorphic features, (such as debris slides and sedimentation), habitat fragmentation, predation, road kill, invasion by exotic species, dispersal of pathogens, degraded water quality and chemical contamination, degraded aquatic habitat, destructive human actions (for example, trash dumping, illegal hunting, fires), loss of soil productivity, and decline in biodiversity. Logging roads also provide attraction for off road vehicle enthusiasts who are already known to be causing problems in the reservoir forests. For additional information on the impact of roads on forests, you can examine the USFS document at the www.Magicalliance.org website. The document appears under Articles/Forest/USFS Roads Analysis.

To justify the recommendations made in the reservoir report, the authors offered a 1978 study by J. H. Connell that discusses biodiversity in a "tropical rain forest and on coral reefs". I suggest that hardwood and pine forests have little in common with tropical rain forests, and that this reference is mostly inappropriate. There are far better studies that have been done in recent years that are more applicable to the forests of North America.

A book titled Conserving Biological Diversity in Our National Forests, published in 1986, is a more recent study dedicated to forest biology of North America. Several well-known biologists familiar with pine and hardwood forests authored this book. The authors include Bruce Wilcox, (Director of Conservation Biology for Stanford University); Elliott Norse, (Director of the Ecological Society of America’s Public Affairs Office in Washington, DC); William Romme, (Assistant Professor of Biology at Fort Lewis College in Colorado) along with several other prominent biologists. A chart contained in this book reveals that the largest variety of plant species occur in a forest undisturbed by major destructive activities like logging. The authors of the book also suggest that a chart showing diversity of animal species would be similar to the chart of plants. The chart shown in this book is well known to the authors of your reservoir report since it was initially included in their report, and we have discussed its importance with them. If you would like to examine this chart, it is still contained in the distributed CD version of the reservoir report, but was apparently pulled out of the hardcopy report since it does not agree with the reports conclusions and recommendations.

In addition, to having a greater number of species in an unlogged forest, the plants and animals found in such forests are more often the uncommon rare or endangered species of the types that we have relatively few of in Maryland, whereas the species found in logged forests are more often the ones we have an abundance of. This is explained in Conserving Biological Diversity in Our National Forests. The book also explains that rotational logging cycles, even when extended to hundreds of years per cycle, will still result in a loss of many species that require the snags and logs of an old growth forest for their habitat. Additional information on this subject can also be found in Eastern Old Growth Forests, a book consisting of environmental studies of old growth forest habitats. Studies in this book will show that plants common to an area have failed to rejuvenate in logged forest 90-100 years after the event.

Appendix D in the reservoir report explains the importance of "course woody debris" to many species in a forest. This is an important subject and is well researched in the report. It explains that debris and fallen trees provide essential habitat to many species that are dependant on this type of forest structure. The report fails to address what will happen to species in the forests around the Baltimore reservoirs when logging removes what will become the dead or dying trees from the forest habitat. This is a major conflict between logging and biodiversity protection.

Conserving Biological Diversity in Our National Forests tells us "very frequent harvests on the order of every 20 to 70 years (depending on the forest), can remove nutrients from the ecosystem faster than biogeochemical processes can replace them. Furthermore, frequent harvests diminish species diversity by depriving the forest of colonizing life history stages of plants and animals that require late successional forest." This is the ultimate result of even the sustainable logging program recommended in the reservoir report.

Appendix D documents the negative effects that habitat fragmentation has on many species of interior forest dwelling animals and plants. However, the report does not address the negative effects that logging, and logging roads built to remove timber from a forest, have on forest species. Edge forests are created by logging activities and increase the habitat for wildlife that like edge forest habitat, like the white-tailed deer, while they decrease habitat for forest interior dwelling animals. This is exactly opposite from the goals expressed by the City for the reservoir forests. Studies done as part of the reservoir report reveal that there is already an abundance of whitetail deer preventing seedlings from growing. Logging will simply exacerbate this problem.

Appendix F describes the introduction of exotic species into forests and the resultant loss of native plants and species diversity. Forest roads built for logging provide a corridor along which exotic invasive species penetrate to the heart of a forest. Logging vehicles often spread the seeds of these exotics imbedded in their tire treads or carry seeds of exotics on the logging vehicles themselves. A major problem has been created in Maryland’s State Forests over the past 25 years where logged areas are being overrun with invasive species. Japanese stilt grass is taking over many disturbed areas around the Baltimore reservoirs. Stilt grass increases the amount of run-off because its small root system cannot hold water for later release as the complex root systems it replaced once did. There seems to be no recognition in the report of the destructive impact logging will create by introducing invasives plants and animals, nor is there any discussion of the costs that the City should expected to pay in an attempt to control these invasive species. The use of herbicides, commonly used to control invasive species, would not be a recommended approach in a forest surrounding drinking water.

The reservoir report states that the primary focus of the first ten years of management is to re-establish adequate levels of seedling regeneration, reduce the high risk of disturbance to pine plantations, and develop structural complexity and diversity. Since seed generation normally occurs in gaps in a mature forest where trees have either blown down or have fallen from old age, seed regeneration does not require logging. The additional benefit of allowing trees to fall naturally in a forest is that the fallen trees also provide habitat for many diverse creatures.

Pine trees are one of the first species to claim a disturbed site. Many pines in the reservoir forests were planted to provide a fast growing wood product to replace the native hardwood forest that were logged off in the past. Although pine trees do not have a particularly long life span, pines do not have to be logged when they approach their age limits, especially if the goal of the forest is to provide biodiversity. When pines fall down or die naturally, they create gaps in the forest, and will be replaced by hardwood species that are more abundant in older forests. Pine forests 40 to 50 years old will usually have an understory of shade tolerant broadleaf trees that will grow to replace the fallen pines. If additional species are desired, they can also be planted in gaps that occur naturally in the pine forests. Logging activities are not required for pine forests to evolve into hardwood forests over time.

In summary, there are only two valid reasons for logging a forest. One is to provide wood products or wood fiber, and the second is to provide income from logging activities. Neither of these were stated as goals for management of the forests around the reservoirs of Baltimore. The extensive logging activities recommended in this report need to be closely examined for validity. The reasons stated in this report for logging the reservoir forests are invalid, and the results of these actions will certainly be loss of biodiversity and introduction of additional exotic invasive species into the forests.

We recommend that the forests around the reservoirs of Baltimore be protected from any further logging activities, and that a competent forest biologist (not a forester) thoroughly examine and review the entire report before any action is taken. Some forest restoration activities may be appropriate, and some recommended road closures might be advantageous.

We also request that public hearings be scheduled with both public officials and the authors of this plan so that the public can address the reports recommendations before implementation. Few people seem to be aware of the reports existence.

Sincerely,

Robert DeGroot

President, MAGIC

The following organizations have approved this letter and requested their names be attached to it:

Anacostia Watershed Society

Catoctin-Monocacy Climate Change Alliance