September 17, 2003
Secretary Ron Franks
Department of Natural Resources
580 Taylor Ave.
Annapolis MD 21401
Subject: DNR Letter to MAGIC dated July 10, 2003
Dear Secretary Franks:
We were pleased to read in your letter that DNR's management of state forests will always be guided by science. We completely agree with this approach, and encourage DNR to continue making decisions based on valid science. We would suggest caution be used, however, to ensure that science is not replaced by pseudo-science dictated by industries that profit from their recommendations. Timber harvest strategies, that are beneficial only to the timber industry, do not represent a balanced scientific view of a forest. It’s especially dangerous when a state agency is receiving an income stream of nearly $3 million dollars to perform certain activities that are recommended by the industry they regulate.
We have some major concerns with the information contained in your letter to us and welcome any response you might have as to its scientific basis. Although we understand that DNR does not intend to run forest management based entirely on public opinion, we suggest that the public’s concerns should be carefully evaluated especially when the primary purposes for our forests are being considered.
Your letter states "harvest levels are well below the total annual growth in the General Management Zone".
This statement is significant only from a point of view of a sustainable timber industry. It tells people that DNR is allowing a greater volume of wood fiber to accumulate on the trunks of trees than it annually removes via logging activities, but it tells nothing about whether biodiversity is being sustained, restored or diminished in the state forests. Biodiversity protection is one of the main reasons the public is interested in preserving their forests. The public would like to understand what DNR is doing to ensure this type of protection. Neither the George Washington National Forest nor the Monongahela National Forest use "total annual growth" as a yardstick for their timber programs.
Your letter states “while wood fiber is not our major focus, harvesting must remain an available tool for us in managing these lands”.
DNR’s major focus on forest management certainly appears to be wood harvesting. The actual implementation of the 10-year Forest Management Plan is primarily devoted to the health of, and logging of trees. Forest studies done by DNR consistently appear to be limited to trees while other species are virtually ignored.
Although the public is offered an opportunity to review annual work plans for the major state forests, these plans consist almost exclusively of the size and number of patches of trees that will be cut each year. DNR seems unwilling to evaluate these logging plans in the context of landscape or ecosystem planning for biodiversity. DNR's approach to management seems devoted to logging everything in the General Management Zones without regard to the size and shape of the remaining forest or requirements of forest-interior species. In addition, the logging program gives virtually no consideration to wildlife corridors, preservation of trees required for food by wildlife, impacts on nesting birds, spread of invasive exotics, or illegal ORV use of logging roads. We would appreciate seeing any document that DNR has that evaluates the cumulative impacts of continually logging these forests.
Your letter states “we have set aside thousands of acres in state parks of the most scenic and historically significant areas for our citizens to visit and enjoy”.
While this may be true, the public is interested in more than just scenic and historic areas. They are interested in biodiversity and how it is being protected by the state. Most parks are too small to preserve extensive biodiversity and this is generally not their function. Science tells us we need to look at areas of 50,000 acres or larger for biodiversity protection. More importantly, connection of Maryland's forests by biological corridors to forests in adjacent states needs to be examined. This is the science currently being studied and implemented by biologists across the US.
Your letter also states “each year less than 1% of the total area of the State forests are touched by any management activity”.
We do not agree that DNR is logging just 1% of the forests each year. Data provided by Legislative Services (See attached chart) shows DNR logs much more than 1% of the General Management Zones each year. If DNR is using the entire acreage of the state forest, rather than just the General Management Zone portion of the forest to calculate this figure, then this lower percentage reported by DNR is purposely deceptive and doesn't reflect the true rate at which public forests are being cut-over. If DNR considers “thinning” operations are not really logging operations, then the rate of logging might be somewhat lower than what our charts reflect, because legislative services did not provide any distinction between various types of logging operations. However, the thinning operations we have examined have nearly as much impact on the forest as would a clearcut. Most mature trees in these thinning operations have been removed and the trees that were left provided few seeds or nuts for wildlife. We would appreciate your providing us with updated information on the total acres logged in each of these forests in FY 2001 and 2002.
The George Washington and Jefferson National Forests cut about 4,000 acres each year of the 700,000 acres suitable for “regulated timber production”. Only .57% of their available timberland is being logged each year. This is much less than DNR is currently logging in Maryland’s public forests. We do not understand why DNR considers their rate of logging on public lands to be either appropriate or acceptable.
Much of the forest that DNR currently protects is on steep erodible slopes above streams. These Water Protection Areas cannot normally be used by visitors to the forests because of the steepness of the slopes. DNR harvests timber on the more level areas where visitors would normally want to sightsee or visit. We contend that most forest visitors do not desire to sightsee in a forest of stumps or in an immature forest. While logging steep slopes has particular problems because of increased erosion, logging off the flat areas is not an acceptable alternative for other reasons. Logging should be strictly limited in both areas. Although your staff disagreed with us when we told them that current logging practices degrade the use of the forest for most recreational users, we do not think their position is valid. Please send us any evidence DNR might have to support this contention.
A forest logged every 100 years is a very young forest, and many trees left in
such a forest are less than 50 years old. Young forests are the type of
forests that we have an abundance of in Maryland. The plants and animals that
thrive in a newly logged forest are generally sun-loving plants, and animals
frequenting these forests are animals such as whitetail deer that like forests
penetrated by sunlight. Many newly logged forests are being overrun by foreign
invasive plants that migrate into the forest along logging roads or are
introduced via the wheels of vehicles. Many endangered native plants and
animals, are unable to compete with new invasive plants or they die out when
the forest cover is removed. The science that favors unlogged forests for the
protection of many species of native biodiversity is well documented.
Sustaining biodiversity requires both living and dead trees in a forest. Biologists tell us that a large proportion of the species in a forest may depend upon the dead and dying trees, perhaps more than the number of species that utilize the live trees. Snags and the remains of large downed trees, upon which much biodiversity depends, are not abundant in frequently logged forests where unfortunately dead trees are considered as “gone to waste”.
The canopy of a forest that has
been logged does not generally close for many years following intensive
logging operations. Only when the forest canopy closes can shade-loving plants
begin to squeeze out the sun-loving plants. Studies have shown the cycle of
restoring species adapted to mature forest conditions can take a hundred years
or more and may never happen in frequently logged forests (Elliott Norse,
Kenneth Rosenbaum, David Wilcove, Bruce Wilcox, William Romme, David Johnson,
and Martha Stout, 1986. Conserving Biological Diversity in Our National
Forests: The Wilderness Society).
Seed and nut trees that are
younger than 40 years of age produce much less fruit and mast than do older
trees. Many wildlife species require quantities of these foods for
their survival especially during winter months including the black bear,
turkeys, squirrels and birds. In
addition, the greater structural complexity found in older forests provides
optimal nesting conditions for many declining bird species, including many
that benefit from larger tracts of forest.
Forests managed for the benefit of a variety of species should be
largely mature or old growth forests. Unfortunately, both clearcut and
thinning operations eliminate most of the trees needed for dens or food
supplies for wildlife and perpetuate sub-optimal habitat for most nesting
songbirds. Habitats for early successional species - the types found in young
forests - are provided for by gaps in the mature forest canopy from trees
blown down by wind or trees dying from disease.
While we have an abundance of young forests in Maryland, old growth
forests have been largely eliminated throughout the State.
Young forests with fast growing species may be fine for a
forest industry intent on logging trees of any size to feed pulp mills, but
young forests don't provide the characteristics needed to sustain populations
of many species of native plants and animals.
Your letter states that the public opinion survey designed by “The Partnership for Sustainable Forestry” shows a big difference in the public’s opinion from that shown in our public opinion survey.
Individuals who have reviewed both public opinion surveys
have told us that the survey created by “The Partnership for Sustainable
Forestry” is a "push" survey and was designed to elicit a desired
response. Their survey provided
statements of “facts” before each question was asked.
Several statements made in their survey were either blatantly false or
exaggerations of the truth. Surveys like this are known to provide invalid
results. Legislators, including
Delegate Dembrow, told DNR this in the meeting he held with them.
After providing all of the misleading information, the pollsters could
still get only 57% of the respondents to agree with
DNR’s forest management policies on logging.
We hope this information might be useful as you examine current management policies concerning state forests. We encourage you take a closer look at how the public thinks their forests should be managed, as well as the science used by DNR to manage them.
Sincerely,
Robert DeGroot
President, MAGIC
The following
organizations have approved this letter and requested their names be attached
to it:
Action
for Animals Network
Anacostia
Watershed Society
Catoctin-Monocacy
Climate Change Alliance
Citizens
to Conserve and Restore Indian Creek
Canoe Cruisers Association of Greater Washington
Earth
Energy
Eyes
of Paint Branch
Friends
of Crabtree
Friends
of Northwest Branch
Friends
of Sligo Creek
Grassroots
Coalition for Environmental and Economic Justice
Maryland
Native Plant Society
Montgomery
Intercounty Connector Coalition
Natural
Pathfinders Association
Norbeck
Conservation Society
Potomac
River Association
The
Fund for Animals
The
HSUS Wildlife Land Trust
The
Humane Society of the U.S.
Urban
Forest Initiative
Maryland
State Forest Harvest Plans
Savage
River State Forest
|
Year |
Acres Harvested1 |
Acres General Mgmt Zone2 |
Rotational Cycle Years3 |
Acres of Special Protection2 |
|
2,000 |
391 |
29,000 |
74.1 |
24,500 |
|
1,999 |
417.5 |
29,000 |
69.5 |
24,500 |
|
1,998 |
487 |
29,000 |
59.5 |
24,500 |
|
1,997 |
420.3 |
29,000 |
68.9 |
24,500 |
|
1,996 |
369.5 |
29,000 |
78.4 |
24,500 |
Potomac-Garrett
State Forest
|
Year |
Acres Harvested1 |
Acres General Mgmt Zone2 |
Rotational Cycle Years3 |
Acres of Special Protection2 |
|
2,000 |
147.8 |
9,750 |
65.9 |
8,492 |
|
1,999 |
119 |
9,750 |
81.9 |
8,492 |
|
1,998 |
213.5 |
9,750 |
45.6 |
8,492 |
|
1,997 |
186 |
9,750 |
52.4 |
8,492 |
|
1,996 |
194.5 |
9,750 |
50.1 |
8,492 |
Green
Ridge State Forest
|
Year |
Acres Harvested1 |
Acres General Mgmt Zone2 |
Rotational Cycle Years3 |
Acres of Special Protection2 |
|
2,000 |
204.1 |
17,500 |
85.7 |
25,500 |
|
1,999 |
199.2 |
17,500 |
87.8 |
25,500 |
|
1,998 |
203.5 |
17,500 |
85.9 |
25,500 |
|
1,997 |
150.7 |
17,500 |
116.1 |
25,500 |
|
1,996 |
233.8 |
17,500 |
74.8 |
25,500 |
1 State forest harvesting data provided by Department of Legislative Services.
2 Forest Manager estimates of GMZ and Special Protection Areas.
3
Rotational Cycle is determined by dividing the acres in the logging zones by
annual harvests.