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Subregional focus areas: In International Paper's 180,000-acre Green Swamp timber holding, the company harvests about 2,000 acres a year. The intensive management of plantations, including the ditching and draining and the use of herbicides to limit other vegetation degrades the ecological value of the stands. The Green Swamp is an important subregional focus area that should be the subject of a "small area study" in the second tier. -- Draft Report
This would be a good idea. -- Final Report
Section 5.1 states "The percentage of timberland in wetland and the expected increase in timber harvest in the south (TMBR-1) indicate the likelihood of additional wetland modifications due to silvicultural activities." No further discussion of this point is contained in this section, but it needs further detail. What is the acreage of forested wetland expected to be modified? What is the expected nature and range of the wetland modification? How will BMPs be used to minimize wetland impacts? -- Draft Report
This is an excellent question but one which the scientific and inventory information collected for this paper was unable to answer. To make such projections would be conjecture on my part. -- Final Report
The Key Finding "Offsetting losses of wetland functions through the Section 404 permitting process has not been well documented but appears to have had limited success" is not substantiated with regard to forestry-impacted wetlands by the discussion in the text in Section 5.4. The Key Finding should be changed to remove the statement "but appears to have had limited success." -- Draft Report
The 404 process does not document silvicultural impacts or restoration. The intent of the comment in the text is directed towards those fill activities for which mitigation is routinely required. -- Final Report
The assumptions about the "naturalness" of cutover natural forested wetlands is probably overstated. Any such assumptions should be qualified. Something more cautionary, such as the conclusion regarding pine plantations -"Sites converted to intensive pine plantation culture experience longer term changes to their structural and biotic diversity" would be appropriate. This should be mentioned in Key Findings in the report and the Summary. -- Draft Report
No specific changes made in response to this comment since the commenter apparently confused the discussion of silviculture in riverine wetlands with practices in wet pine flats. See text. -- Final Report
Although section 5.2.3 says "effects of harvesting are short-lived and that these stands will return to pretreatment species composition", the authors admit almost immediately that additional long term research is needed to compare composition and ecological function of harvested and nonharvested stands. This point is important enough to warrant mention in the Key Findings of this paper and in the Summary. -- Draft Report
Key Finding added -- Final Report
Although the assumption from the Key Findings that 90% of southern forested wetlands that changed to "scrub-shrub or ermergent wetlands" were not changed because of silvicultural activities, it is unclear what other activity could have made such a conversion. -- Draft Report
Attribution of conversion not included in NWI studies. See comment 1. -- Final Report
The NRI use of the term "loss due to silviculture" for cause of wetlands loss is ambiguous. This category actually represents the loss of forested wetands from all causes, not just silviculture. The NRCS does not distinguish between natural and man-caused wetlands losses. Losses could have been due to differences in flooding or wet signatures between the two inventory dates (Steve Brady, NRCS phone conversation, 10/17/2001) (p. 7). -- Draft Report
The terms and figures reported are as stated on the NRCS NRI web site. This was the primary citable source for NRI data and results. -- Final Report
After first paragraph, explain that conversion of forested wetlands to scrub-shrub or emergent wetlands is temporary. For example, the difference between palustrine forested wetlands and palustrine scrub shrub is the height of the vegetation. So when a forest is clearcut harvested, it goes from PFO to PSS. In a few years, the young forest exceeds 20 feet in height and becomes PFO again. So this type of conversion is essentially an artifact of the Cowardin classification system and not a permanent change (p. 7). -- Draft Report
Explained in Section 5.2.3 -- Final Report
The policy section omitted the 1995 agency guidance on mechanical site preparation to establish pine plantations (Federal Register, 2/27/96, Vol 61 No 39, pp 7242-7245). This is important because it separates forest wetlands into two classes; those which mechanical site prep can be conducted to establish pine plantations without a 404 permit and those that would require a permit for such an operation (p. 22). -- Draft Report
Brief discussion of guidance added -- Final Report
The major deficiency of this chapter is the lack of discussion and reference to the 1987 Wetlands Delineation Manual that is the definitive guidance on wetland determination. -- Draft Report
Referred to '87 Manual. -- Final Report
This chapter should better explain how the apparent loss of wetland habitats under the various categories is, in part, a function of natural succession. -- Draft Report
Didn't respond to this comment directly since status and trends studies by NWI, NRI, or FIA do not deal directly with loss of wetlands as a result of natural succession. Section 5.2.3 does deal with successional changes to forested wetlands foloowing harvesting. -- Final Report
Although the author relies primarily on data from the NWI Status and Trends reports, he also includes data from the NRI prepared by the NRCS. The data from these two reports do not agree. To gain a better understanding of the difference between these two data sets, it would be helpful to see a comparison of the definitions. -- Draft Report
A table of these differences is included in Dahl (2000). Reference to this document made in text. -- Final Report
What percentage of the south's wetlands have been lost due to draining and subsequent pine conversion and how much will remain when all conversion is completed. Will the 25% of southern forests converted to pine deserts be adequate for industry demands for profit? -- Draft Report
Presumably, as explained in the text, attribution of losses to silviculture result only when hydrologic alteration (i.e., drainage) is detected on the aerial photos used in the analysis. -- Final Report
Confusing information is presented on Table 1, page 34. Here the '86 to '97 comparison of wetlands lost actually shows more "forested" wetlands lost than "total" wetlands lost. The figures that pertain to the southeastern US show the same. This table needs to be looked at again. -- Draft Report
Added additional information inntext following Table 1 to explain the discrepancy. Column in Table on labelled "Total Wetland" includes acreage that has been restored since the last inventory period. -- Final Report
Key Findings cite the NWI conclusion that 3.5 million acres of southern forested wetlands underwent changes between 1986 and 1997, with 90% to "conversions to another wetland or aquatic habitat type," 95% of which were scrub-shrub or emergent wetlands. It is not clear from the reference what the driving factor for this change was. Acreage figures are given for conversion to urban use and agriculture, and it is noted that 102,000 acres underwent "intensive silviculture." Clarification of this point will be helpful. -- Draft Report
Added a statement in the Key Findings about the attribution of conversions. This commenter is confusing "losses" and "conversions" as defined in this paper. -- Final Report
In section 4, page 5, considerable care is dedicated to explaining the difference between wetland "loss" and wetland "conversion". These two conditions imply considerably different environmental impacts. In section 5.1, the author begins with a discussion of wetlands lost, however, in the third paragraph he begins by quoting figures that combine wetlands lost with wetlands converted, then quotes figures for wetlands lost, and then switches back again to figures that combine the two. Since lost and converted mean two very different things, care should be taken to keep comparisons based on the same terminologies. -- Draft Report
Rearranged 3rd paragraph and added sentence on conversion acreage to atempt to make clearer. -- Final Report
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