|
|
|
|
| Home > Draft Report > Comments |
The discussion of the regulation of forestry in the draft Summary Report appears to be confined to conveying the simple fact that regulation of forestry in the South is limited and that the states generally rely on voluntary BMPs (p. 18). We do not believe that this limited and simplistic treatment of the regulation of forestry is sufficient to respond to the level of public interest in this question. -- Draft Report
We have revised this section of the Summary Report to incorporate more details on the findings regarding regulation of forestry in the South (from SOCIO-3). -- Final Report
Our primary suggestion for improving the discussion of outdoor recreation would be to add some information about the potential for acquisition of additional public lands from willing sellers. At a bare minimum, we want to correct the report by removing the unfounded conclusion that "there appears to be limited capacity to expand forest-based recreation opportunities in the South." The amount of timber industry land up for sale at present is quite significant; it would be appropriate to give an explanation of how federal dollars are made available by the LWCF to acquire additional lands. It would be helpful to have a calculation of the additional acres of public land that would be necessary to meet the demand for forest-based recreation through 2020 and through 2040. -- Draft Report
We now emphasize that the current ownership pattern constrains the opportunities to expand recreation supply. Proposing solutions to resource problems was beyond the scope of the Assessment. -- Final Report
We are concerned by apparent contradictions between the draft Summary Report and the relevant technical papers. The draft Summary Report conclusion that "forestry practices may provide important benefits for forest breeding bird species through provision of early successional habitats" (p. 70) is questioned by statements in Terra-4: "claims that the present and projected increase in intensively managed pine plantations should bode well for early successional species is highly suspect "(p. 17). -- Draft Report
While the effects of forest management on wildlife is an area of uncertainty, it is clear that the design of management practices will have important influence on the quality of resulting wildlife habitat. This is borne out in Chapters TERRA-1, 2, and 4. -- Final Report
…. small "subregions" such as the Green Swamp and the Cumberland Plateau should be discussed. -- Draft Report
We now emphasize that while we have identified three broad subregions of concern, there are several smaller areas that will likely be impacted by ongoing forces of change. -- Final Report
In the past 3 decades, the most rapidly urbanizing region in the south was southern Piedmont. Breeding bird survey data for this region reveals that from 1966-2000, 73% of all "woodland breeding" bird species in the southern Piedmont had positive population trends. (see website www.mbr-pwrc.usgs.gov/cgi-bin/guild00.pl). With all the associated negative impacts discussed in Terra-3, it is interesting that only 8% of "urban breeding" birds had "significant positive" population trends while 50% had "significant negative" population trends during this period of urbanization. The generally positive trend for forest bird species during a period of significant urbanization in the Piedmont requires further explanation. -- Draft Report
These counterintuitive findings reflect the state of knowledge with respect to linking landscape level change to effects on fauna--especially birds. Shifts out of agricultural uses can have positive impacts, and time lags between habitat alteration and species response is also possible. Our intent was to define the state of knowledge with respect to all questions and to highlight where knowledge deficits exist. This is clearly a case of the latter. -- Final Report
The draft summary report and technical papers fail to examine adequately the ecological implications of forest change and forest trends in the South. The final report should focus on assessing the ecological effects of forest change in the region and, importantly, the expected ecological effects of predicted trends. We recommend that the final report include a detailed assessment of birds and bird communities as well as additional indicators of ecological effects and change. The draft Assessment already includes a significant focus on birds; but it fails to synthesize the information from the technical papers in a manner clearly accessible and understandable to the lay reader. -- Draft Report
While chapters provide various insights into the effects of land use changes (TERRA-3) and forest management (TERRA-4) on birds and other fauna, we lack the scientific basis to complete the cumulative impacts analysis proposed here. We highlight the need for effective ecological forecasting as an important research need in our conclusions. -- Final Report
We were disappointed to learn that for a variety of reasons it had not been possible to provide the authors of the various technical reports the forest trend data and land use results from the models in advance of their report preparation. -- Draft Report
Authors of chapters had access to the land use and forest management/timber production forecasts before the chapters were finalized. Preliminary findings were discussed in sessions held in January 2001 and were available on an FTP site from that time forward. -- Final Report
Since forestry practices take place outside the regulatory permitting process, no mitigation is required to compensate for silvicultural wetland losses. It is an uncontroverted fact that the "minor drainage" limitation on silvicultural ditching of wetlands under the exemption remains undefined and illusive. As a result, enforcement efforts to prevent this type of illegal, unmitigated conversion will continue to be thwarted. It is incumbent on the report writers to include at least some reference to them and the potential consequences for the future of forested wetlands. -- Draft Report
As noted by the commenter and discussed in Chapter Aqua 2, minor drainage is exempt from Section 404 Permitting, as long as it does not result in conversion to a non-wetland. Whether or to what extent conversions have occurred as a result of exempt activities, including minor drainage is unknown, so could not be reported. -- Final Report
Finding "Investment in pine plantations is forecast to expand…". The assumptions upon which this forecast is based should be mentioned. -- Draft Report
We've added more description of assumptions of the forecasting models and the modeling results. -- Final Report
There is brief mention of Section 404 of the Clean Water Act and the silvicultural exemption to its requirements. However, the discussion fails to present a clear picture of the relevance of the exemption to the long term status of forested wetlands in the region. Estimates of wetlands losses due to silviculture are provided in the report, as is the limitations of the exemptions, but nowhere is there any mention of the relationship between the two and the implications for the future of forested wetlands. Clearly there is a need to address this discrepancy between the law and the reality of wetlands conversion on the ground. -- Draft Report
Wetland losses characterized in the report are based on the National Wetlands Inventory Status and Trends, which does not report wetlands trends meeting the Section 404 jurisdictional definition. The relationship between wetland losses and Section 404 exemptions, if any, is not known; therefore it cannot be reported. -- Final Report
Data in the report clearly indicate there is little basis for the proposition that the more benign practice of clearcutting with natural stand regeneration dominates forestry activities in wetlands. The report indicates that substantial numbers of acres of natural wetland forests are being converted to pine plantations. Other forested wetland types are not individually reported in the Assessment data for comparison. -- Draft Report
This proposition was not made in the Summary Report. See Aqua 2 for discussion of silviculture treatments in wetlands. Clearcutting and natural regeneration are dominant in riverine wetlands, whereas site preparation and planting are common in mineral soil pine flats. -- Final Report
The report makes a very flawed assumption concerning predominant silvicultural practices in wetlands by presupposing that forestry activities in wetlands typically consist of clearcutting with natural regeneration. The treatment of this topic misleads the reader by failing to provide any mention of other, notably more controversial forestry practices such as ditching, draining, bedding and conversion of natural forest types to pine plantations. -- Draft Report
Chapter Aqua 2 reports that clearcutting and natural regeneration are predominant in riverine wetlands, and that intensive site preparation and plantation establishment are predominant in mineral soil pine flats. -- Final Report
The Broad Finding "population is growing and the social context is changing" should highlight the "public values" mentioned, particularly the emerging need for additional forest-based recreation, the lack of adequate public forestland to accommodate the increased recreation need, the potential conflict between timber cutting on both private and public land, and the recreational, aesthetic, and biotic preferences of the increasingly urbanized southern population. -- Draft Report
We have included these issues in the broad finding mentioned here. -- Final Report
We are concerned that the SFRA runs the risk of conveying that urbanization is the only real threat of any significance to southern forests. Because we know this simply is not so, we urge a more balanced discussion of the sprawl issue relative to other factors. The number of forested acres being urbanized actually decreased during the 1990s as compared to both the 1970s and 1980s. -- Draft Report
Effects of forest management on forested ecosystems are emphasized in the broad findings--i.e.., changing forest type distributions, including increased pine plantations. -- Final Report
"Urbanization presents a substantial threat to the extent, conditions and health of forests". This Finding needs to be linked to the first finding to make it clear that current timber cutting practices and urbanization work in tandem to fragment and reduce the extent and natural productivity of the southern forest. -- Draft Report
We emphasize that these and other forces interact in their effects on forests in the referenced section. -- Final Report
There is a discrepancy between the 75% growth rate used in the timber supply model displayed in TIMBR-1 at Table 1 versus the information provided relative to a 65% growth rate (or increased volume) as set forth in TMBR-2 at page 7. The differences between these two growth rates is all the more perplexing because the 75% figure used in the timber supply model is characterized as an average growth rate whereas the narrative concerning the 65% growth rate implies that this is a maximum rate. -- Draft Report
The issue is the point of comparison. The 65 percent refers to increases using the stand-level models of production. On page 8 of TMBR-2, you'll notice that the high intensity options are estimated to enhance yields used in the SRTS model (based on observed FIA data) by 100 percent. The 75 percent increase is derived from estimation of adoption rates coupled with these differences in physical production rates. -- Final Report
An issue needing resolution in the final report is the growth rates used for southern pine plantations. If these rates are not as high as assumed, even more acreage must be put into pine plantation management in order to produce the volumes necessary to meet demand. Failure to achieve high growth rates could result in an 80% increase in pine plantations, rather than the 67% currently forecasted. -- Draft Report
We have expanded our description of management assumptions used in the base scenario of the forecasting model. The sensitivity to productivity assumptions is also described. -- Final Report
The final report should clarify whether the projection that future plantations will come largely from former agricultural lands is based solely on the models, or whether other factors were taken into account. The extent that government agencies offer forest landowners both stewardship advice and financial subsidies has and continues to promote conversion of natural stands to pine, and this governmental intervention may distort the landowner behavior otherwise assumed from the timber/agricultural price ratio. -- Draft Report
The investment model is calibrated to observed behavior, so incorporates the influence of existing institutions and programs on landowners' choices. The specific effects of these policies on land use choice is not precisely known. -- Final Report
The discussion of aquatic species of concern contains important statements and findings that we believe need to be more adequately and accurately reflected in the Broad Findings discussion in the Summary, especially the "imperiled" nature of the southern forest aquatic ecosystem. -- Draft Report
We have added additional information on aquatic systems to the broad findings section. -- Final Report
A second, related issue of pine plantations is where they will be created. The SFRA projection that most new pine plantations will result from conversion of agricultural lands, in contrast to the actual experience of the past two decades in which 75% of new pine plantations resulted from conversion of natural forests. Given this dramatic shift from past experience, the bases for this projection should be explained in complete detail. We can only infer the model assumes plantations will be on agricultural lands due to favorable timber/agricultural price ratios. -- Draft Report
Indeed these projections are a departure from recent historical data. We have added a discussion of this departure to the report and describe why the forecasting models yield this result. The impacts of price ratios can be inferred by comparing scenarios in chapter SOCIO-1. -- Final Report
Causation of the historical loss of wetlands need to be discussed in more detail. The relationship between industrial forestry practices and the significant loss of freshwater forested wetlands needs to be made clear in Aqua-2 and highlighted in the Summary. -- Draft Report
Losses of wetlands, as characterized by the National Wetlands Inventory, due to silviculture practices is discussed in Chapter Aqua 2.. Intensification of silviculture is cited in the Summary Report as a factor influencing certain wetland types. -- Final Report
The first issue needing better resolution or explanation is the projection of a significant decrease in the rate at which pine plantation acreage will increase in the future. HLTH-1, Table 9 shows that during the 1990s pine plantation acreage in the south increased by 9M acres, or an annual rate of 900,000 acres. By contrast, the SFRA projects pine plantation acreage to increase by 22M acres between 1999 and 2040. This reflects an increase of some 536,585 acres during the forecast period, and represents a 40% reduction in the rate at which pine plantations are forecast to be established. As far as we can determine, the reasons for the assumptions behind this significant downturn in planted acreage is not explained in the SFRA or technical reports. This issue needs fuller treatment in the final report. -- Draft Report
The forecasts of plantation area are outcomes of the model which forecasts investment demand as a function of timber scarcity (I.e., prices). Part of the modeling involves projecting the contribution of existing and especially recently established plantations to timber markets. Increased productivity expected for new and more intensively managed plantations reduces the demand for planted area. Sensitivity analysis regarding this element of the model indicates that reducing expected productivity gains leads to further expansion in the area of planted pine. -- Final Report
The assumption in Aqua-2, section 5.2.3 that the effects of harvesting "are short-lived and that these stands will return to pretreatment species composition" is incorrect. Indeed, the authors admit that additional long term research is needed to track the development of plant community and ecological function in harvested compared with unharvested stands. This point is important enough to warrant mention in the Broad Findings section of the Summary. we also believe the extreme uncertainly in Aqua-2 about silvicultural practices related to the impacts of timber cutting and removal in wetlands makes it unwise to assume their impacts are minimal - and certainly undermines any conclusion that such practices "enhance" water quality. -- Draft Report
Based on the literature reviewed for this report, the effects of harvesting in riverine wetlands are short-lived. In the author's opinion, additional long-term research is needed to verify these effects. -- Final Report
While we've emphasized that the assumption that favorable timber/agriculture price ratios will result in substantial gains in forestland in the south, other "unseen" assumptions no doubt are driving other conclusions or projections. The final report must to a much better job of explicitly identifying critical assumptions which are built into the key models. -- Draft Report
In response to comment 36.14, we added a qualifier to our findings regarding the sensitivity of the model to the demand formulation. We have been careful to point out that assumptions play an important role in our (or any) forecasts and highlight two areas where the models are especially sensitive (section 2.1). We also now include more detail on the management assumptions used in model runs. -- Final Report
It should be noted that because of their large-scale nature, the National Wetlands inventory maps tend to underestimate, and more importantly under-record the presence of wetlands. Thus, the wetland acreages estimated in the study are likely to represent minimum acres. As a result, the analysis very likely underestimates the effects of all land use activities on wetland functions in the environment. -- Draft Report
The limitations of wetlands databases are discussed in detail in AQUA-2. It is unknown what, if any, effects the scale of NWI maps has on reported wetland acreages. -- Final Report
The output or conclusion that significant new acreages of forestland will be generated from agricultural lands due to changes in landowner behavior resulting from the favorable rent/price ratio is, to our knowledge, an untested econometric proposition that may or may not hold true. Just how closely does actual landowner behavior track the behavior that would be rationally dictated by price ratios? -- Draft Report
Indeed these projections are a departure from recent historical data. We have added a discussion of this departure to the report and describe why the forecasting models yield this result. The impacts of price ratios can be inferred by comparing scenarios in chapter SOCIO-1. -- Final Report
A major effort needs to be made to synthesize cumulative water quality impacts of all "major" sources of water quality [degradation] at the stream reach and watershed level. ... It should be pointed out that the level of detail in the EPA Index of Watershed Indicators is too coarse to produce significant analytical results. -- Draft Report
The cumulative effects analysis that you propose is beyond the scope of current data and methodology. It is an area that warrants additional research. We’ve used the EPA Index of Watershed Indicators only to categorize broad watershed conditions. -- Final Report
This discussion inaccurately minimized the effects of cutting and removing timber. The point is not that silviculture is only number 10 out of 11 "major" sources of water quality degradation but that it is one of the top 10 causes and operates cumulatively with most of the other 10 in contributing sediment, nutrients and toxic chemicals to the south's waterways. This is a case of "editorializing" in what should be a scientific study. -- Draft Report
The report lists miles of stream impairment as well as the rank among all categories reported. The editorializing word "only" was not used as the commenter suggests. After revision the ranking is now 9 out of 10 rather than 10 out of 11. -- Final Report
The final report should explicitly discuss any legitimate reservations or questions about the model assumptions. One assumption that may be questioned is that real timber prices will continue to rise in our region and that they will not rise faster than agricultural prices. The only information about regional timber prices in the technical reports is limited to a single state, Louisiana (Socio-1, Figure 7). A brief review of the Timber Mart South data back to the early 90's suggests that pulpwood prices have remained flat, or declined, for a significant time period.; sawtimber prices have generally risen but have been flat or declining in recent years. Given the importance of this assumption, a better discussion of timber price projections, and their relationship to agricultural prices, is warranted. -- Draft Report
To clarify, our assumption regarding prices is that, in general, agricultural rents (derived from product prices) will remain level in real terms. In TMBR-1, an outward shift in the demand function is applied to the model based on previous national analyses of timber markets. The increasing timber price is an outcome of the interaction between this model of demand and a disaggregate model of supply based on yield and behavioral supply models. We examined another demand model in TMBR-1 to demonstrate sensitivity of the model. This model had a different relationship between price and quantity (in technical terms it is a more elastic relationship). For these scenarios, prices were flat and the area of timberland declined by about 32 million acres, consistent with the flat price scenario for land use described in chapter SOCIO-1. (Note that almost all empirical demand models in the literature suggest that timber demand is of the inelastic variety specified for our base scenario). Louisiana prices were displayed because they are the only consistently-measured long time series of timber prices available for the South. We have added a qualifier to our description of land use changes in the Summary Report to indicate that these price dynamics depend on these price ratios. -- Final Report
Page 86: You state "recreational access to private land is expected to continue to decrease." There certainly is not much private land that provides free access to the public but there is a lot of "paid for" recreation use of private land. This recreational use of private land should be acknowledged as providing significant opportunities for those willing to pay. -- Draft Report
We emphasize that there is an emerging scarcity of free access to private lands for recreation. Further we now emphasize that the current ownership pattern constrains opportunities to expand recreation supply of various types of activities. -- Final Report
Section 5.2 of Socio-7 states "…forest-related recreation and tourism sector is concentrated in areas that are economically more favorable than areas where the wood products sectors is located." This is an opportunity for additional synthesis of findings, and should be included in the Summary. In the technical paper, the author could state there is a higher quality of life in counties with secondary wood products than in counties with paper and pulp industries. -- Draft Report
The relevant information regarding these issues is contained in the Summary Report as a bullet in Section 3.1.5. While many factors contribute to quality of life, there is no single index that would allow us to derive this kind of general finding. -- Final Report
The final summary report should be much clearer that the results of the land use model vary dramatically depending on which "scenario" is selected (Base or Market scenario). The draft Summary on page 11 discusses results under both scenarios without making it explicit which scenario is being relied upon. A careful reading of the technical reports reveals the projection that the South will lose 12M forest acres to urbanization between 1992 and 2020 is based on the Base scenario; the projection that some 10M acres will be gained from agricultural land to forests during the same time period is based on the Market scenario. This sort of "picking and choosing" from the results of the multiple scenarios, without making the differential assumptions clear to the lay reader, is problematic and needs correction in the final report. -- Draft Report
Two issues are raised here. One has to do with the labeling of scenarios. We discovered that the draft contained inconsistencies in the labels applied to scenarios in the TMBR-1 and SOCIO-1 chapters. We have corrected these inconsistencies so that "Base" now refers to the baseline scenario described in the Summary Report. The other issue is how some effects were inferred from model runs. We used a nested set of scenarios to evaluate changes. The initial scenario is based on population and income forecasts and includes no rural land market interactions. The base scenario adds the agricultural and timber market impacts consistent with the integrated market analysis conducted in TMBR-1. The initial scenario allowed us to isolate the impacts of population and income growth alone. We have edited the Summary Report to eliminate confusion regarding the source of our results. -- Final Report
Page 69: You end a short discussion on plantation use by wildlife with the sentence "After canopy closure, plant diversity generally decreases and wildlife use declines." This is certainly true, but the problem can be alleviated with burning and thinnings, and this should be noted. -- Draft Report
We describe the effects of these treatments later in the referenced section of the report. -- Final Report
Explain what is meant by "changes in ecological structure and function". I agree that more research will be needed, and questions of Regional Scale must be addressed. -- Draft Report
See the TERRA chapters for details on types of changes. -- Final Report
This discussion understates the effect of acid deposition on forest vegetation. While it may be arguable that the vast majority of the south is not significantly affected at present, it is clear from the situation in the high Appalachians that this issue is of critical importance in that region. The implications of the "high degree of uncertainty about the direction and magnitude of forest impacts from projected climate changes" also should be discussed. -- Draft Report
We do highlight concern for the effects of acid deposition in the Southern Appalachians in both the Summary Report and in chapter HLTH-3. -- Final Report
Page 63: You state "mature pine trees are more susceptible to damage from SOB than younger trees." This statement is true, but stocking seems to have more to do with susceptibility than does age up to 70-90 years. Overly dense young stands (120-160 BA) are more susceptible to SPB than older stands that are less dense (60-90 BA). -- Draft Report
We have added a statement that density is also a significant factor in susceptibility, even more than age. For trees larger than 2 inches, density is the major factor in beetle attack, with older dense stands more susceptible than young dense stands. -- Final Report
I am concerned about the potential over-harvesting projections for hardwood forests by the year 2025. What will the USFS do to prevent a decrease in future timber production, and maintenance of forest reserves? Also, I found no mention of the Ozarks as a sub-region that will be suffering with the broad changes from blight and insect infestations. -- Draft Report
Policy recommendations were beyond the scope of this assessment Subregions of concern were based on a confluence of multiple concerns within a subregion; therefore regions with individually significant concerns were not highlighted. This in no way belittles the significance of individual concerns. -- Final Report
Including subregional analyses of forest trends would also enhance the meaningfulness of the discussion of forest trends. Reporting of forestland data at a broad regional level make less evident the significant changes in forest cover occurring in certain subregions. In the final Summary Report, we suggest a meaningful discussion of major subregional differences in forestland loss (or gain) be included, and that the factors mentioned above (see comment #8) be addressed subregionally as well. -- Draft Report
These data are displayed and discussed in Table 3 of chapter SOCIO-1. We've summarized the subregional trends in the Summary Report. -- Final Report
This discussion is largely limited to plant diseases, exotic plants, and exotic pests. These are not the only biological factors affecting the southern forests. Examples of biological factors that should be introduced in this section include other human-induced impacts such as replacement of natural species by pine plantations, the effects of development-induced sprawl, and resulting threats to biodiversity. -- Draft Report
These other factors are described in immediately preceding sections and their effects on forest systems are described in more detail in several chapters (e.g., TERRA-3 and TERRA-4). Effects of these changes are also described in other sections of the Summary Report. -- Final Report
A related issue that receives little or no attention in the draft assessment is the historical and projects shifts in forest age class. Age class distribution serves as a very useful indicator of the complexity of forest structure and sustainability. We suggest a much fuller discussion of the potential ecological impacts of expected shifts in forest age class distribution be included in the Summary Report and in Terra-5. -- Draft Report
Historic changes in age class distributions are found in HLTH-1 and forecasts of age classes are found in TMBR-1. Without better insights into the ecological implications of changes at broad scales, we chose not to highlight these aspects in the Summary Report. -- Final Report
Page 61: Reference to "exotic plant" pests. You include Japanese honeysuckle along with kudzu. Japanese honeysuckle is easy to control and does not provide any problem in establishment or management of pine stands. -- Draft Report
Both have implications for forest ecosystems beyond pine management--i.e.., they displace other species. -- Final Report
This discussion does not deal adequately with the issue of regulating timber harvesting in the south. The study's discussion gives the impression that the only areas where regulation is affecting, or should affect, timber harvesting are urbanizing regions. We believe that this discussion is very misleading and incomplete. Moreover, regulation in the south does not appear static. -- Draft Report
We have revised this section of the Summary Report to incorporate more details on the findings regarding regulation of forestry in the South (from SOCIO-3). Our findings suggest that indeed, regulation is not static. -- Final Report
One of the most important changes needed in the final report is that any discussion of "forestland acreage" should include the distinction between naturally occurring or naturally regenerated forests on the one hand, and planted monoculture forest types on the other. The current trends in forest cover pertain only to the aggregated acreages of all forest types, both natural forests and monoculture plantations, thus obscuring the differential trends with regard to these two classes. -- Draft Report
Planted pine is included in estimates of total forest area consistent with standard definitions of forest cover. However, we include planted pine as a separate forest type so it can be tracked and its effects can be evaluated. We also conclude that changes in forest composition raise important issues for forest functions of various sorts (this is discussed in three of the broad findings included in Section 4.1). -- Final Report
In the bullet statement below Figure 3.4.2 Number of acres enrolled in WRP: insert a space before the word "largely". -- Draft Report
Technical editing. -- Final Report
The discussion of Timber Markets in the Summary reflect a "business as usual" projection that is probably appropriate as a near "worst case" scenario. One trend that should be examined could be called the "market shift" scenario, where changing use patterns - particularly in paper, but also in the use of engineered wood products, could result in less intense demands on the southern forest over the study period. (See the World Resources Institute paper attached to comment letter.) -- Draft Report
With regard to forecasting, our objectives were to evaluate the "most likely" future, based on current conditions and observed trends. Evaluating scenarios that would involve structural changes in industries or economies would be beyond the structural basis of the forecasting models employed here. -- Final Report
Page 56: Your statement that intensive management yields about 65% more timber volume compared to plantations not intensively managed and more than double natural pine stands. I do not question the validity of your statement as worded but I do question the implication that individual private land owners are primarily concerned with increasing timber volume or physical productivity. Most individual private timberland owners are concerned about "net dollar yield". They are more inclined to analyze silvicultural treatments by net dollar yield after management cost than by the amount of increase in physical growth. -- Draft Report
We did not mean to imply that landowners are motivated by increased volume production. Chapter SOCIO-4 examines forest landowner motivations. Adoption of intensive management is assumed to be driven by profit motives in the forecasting models. -- Final Report
Contains a vague statement about "certain amphibians". Please make specific statements. Are you saying wet upland conditions for amphibians, or lumping these two opposite ecosystems (wet vs. upland) into one discussion? There are rare relatively wet upland forests in the Ozarks forests. -- Draft Report
The generic statement seems appropriate here--much more detail on this issue can be found in the TERRA and AQUA chapters. -- Final Report
We were disappointed in the simple "takeaway message" that …"..the forests of the south are sustainable" and that "..total forest area will remain stable." There is an overemphasis on the stability of forest area despite the significant additional threats identified in the technical papers. -- Draft Report
We emphasize that while total area is sustainable, that this is masking considerable change in either direction. Loss of forests in the eastern part of the region is emphasized in the summary report. Additional discussion of other forest type changes has been added. -- Final Report
In section 3.3.4 Effects of forest management: "afforestation" is misspelled in the second paragraph. -- Draft Report
Technical editing. -- Final Report
The issue of forest fragmentation of mature forests by attempting to compare it with potential loss of other habitat on shrub-scrub and grassland: the SFRA is a discussion of forest conditions, please stick to the subject. Tell the public how bad you think that the loss of endangered forest habitats really is, rather than comparing trees to grasslands. -- Draft Report
Grasslands are relevant here to the extent that they become displaced by forest cover. -- Final Report
In Figure 3.3.3 Various exotic diseases: the labels are AWFULLY small. -- Draft Report
Technical editing. -- Final Report
Navigational tools are needed to guide readers through the technical reports and summary report. We strongly recommend much more cross-referencing of the disparate but related information be done, and that an index be added to help the reader navigate the report. -- Draft Report
We have added cross references to chapters as appropriate and have added indexes for all chapters and the summary report. -- Final Report
The term "forest" needs to be qualified throughout the SFRA. The broad definitions used fail to capture the significant ecological differences between a natural forest and a planted pine plantation. -- Draft Report
In most chapters of the Assessment, we use the standard definitions of forestland and timberland as defined by the Forest Inventories (FIA). In other places, mainly the land use chapter (SOCIO-1), we also use data from the NRI surveys and from the MRLC satellite-based records which have somewhat different definitions of forest area. Where the FIA definitions are not used we specify the alternative definitions. However, we include planted pine as a separate forest type so it can be tracked and its effects can be evaluated. We also conclude that changes in forest composition raise important issues for forest functions of various sorts (this is discussed in three of the broad findings included in Section 4.1). -- Final Report
Page 40-41: Statement "Forest-based recreation is largely concentrated on relatively scarce public land." and also "only 7% of private land held by individuals is open to the public." It appears to me that you have too narrowly defined forest-based recreation. Most private land held by individuals is used for recreation purposes either by invitees or by the lessee. Lots of private land is leased by individuals or groups. Just because only 7% are open to free access by any member of the public does not mean that the other 93% are not used for recreation purposes. -- Draft Report
We were referring to free public access and state this in the referenced material. -- Final Report
Statement: "Northern part of the region…" please explain where this is and what % and how severely the forests there will be affected. -- Draft Report
We have provided clarification in the text. -- Final Report
A larger question is what will be the long-term genetic cost to biodiversity of planting genetically improved pine seedlings and of planting only pine seedlings, while eliminating other vegetation, especially when considering global warming and increased levels of CO2. The draft acknowledges that the massive alterations from European settlement still influence forest structure and function yet there is no discussion of the legacy we are likely to leave if we inflict intensive silviculture upon ever-increasing numbers of acres. -- Draft Report
The cumulative effects analysis proposed is beyond current ability. We have described current knowledge of climate change effects and interactions between climate and vegetative condition. Our forecasts suggest up to 75 percent of forest will be naturally regenerated so effects on gene pools may not be substantial. This area does warrant additional research though. -- Final Report
In Figure 3.2.10 average annual growth to removals ratio: the chart would be enhanced by adding projected values at 2025 and 2040. In Figure 3.3.2 counties in SPB outbreak status: see our comments on Figure 2.7. -- Draft Report
We've added these data to the figure. We've addressed the issue regarding missing data in the map. -- Final Report
The definition of "sustainability" seems to emphasize sustaining the cutting rate and volumes necessary for increased production of wood products as projected in the study's model. -- Draft Report
The report does not offer a summary assessment of the "sustainability" of southern forests. We have provided analysis of the various dimensions of the issue as we have answered the specific questions that organized the assessment. -- Final Report
Page 35: The statement "pine plantations are forecast to be managed for short rotation timber production." I question the accuracy of this forecast considering the very low demand and low price for pulpwood. The economics of short fiber rotations (<25 years) will not justify the expenditure of plantation establishment in today's pine pulpwood market. A lot of plantations are being established on non-paper company lands that are planned for 35-50 year rotations. -- Draft Report
Forecasts of investment in pine plantations are based on empirical relationships and long run projections of prices. They represent our best estimate of future conditions and actions and are sensitive to the assumptions used. However, we have added a qualifier to this statement to describe the range of anticipated management approaches. -- Final Report
In forest fragmentation, what about damage to areas other than the Piedmont being fragmented? -- Draft Report
Effects of forest fragmentation are discussed in chapters SOCIO-1 and TERRA-1. We highlighted the areas where fragmentation is expected to be especially problematic in the Summary Report. -- Final Report
We recommend that the final Summary Report be expanded to include more data and discussion about the particular trends in each subregion. We have created a draft matrix (see attachment A of comment letter #36) of the various ecoregions identified by the multiple measures of concern, and hope this could serve as a starting point for a broader discussion in the final Summary Report. Note that the matrix also includes information about the ecological resources in the various subregions. -- Draft Report
We have added a description of how we selected the three subregions of concern listed in the summary report. At this point we feel that the disparities in types of information available for the various resource and ecological issues described in the assessment (i.e., some are readily quantified, others are qualitative) precludes us from completing the specific analysis that you suggest. We do think it is a natural extension of the work contained in the assessment. -- Final Report
By focusing on the entire region, the report is less helpful than it could have been if it have pointed out problems in subregions and made suggestions for change. -- Draft Report
Suggestions for change are beyond the scope of the Assessment. -- Final Report
An additional question that should be addressed is what percentage of the species attracted to these habitats face any threat to their continued existence, or are they globally secure, opportunistic species able to utilize a wide variety of severely disturbed habitats? -- Draft Report
See chapters in the TERRA section for detailed findings regarding this issue. -- Final Report
On page 86, near the bottom, there is an extra blank line that should be deleted. -- Draft Report
Technical editing. -- Final Report
In the paragraph below Figure 3.1.10: it appears that softwood production is also expected to increase significantly in eastern Oklahoma. If so, please include us in the paragraph. -- Draft Report
Technical editing. -- Final Report
The report points out that communities where outdoor recreation is concentrated is much better off economically. Yet, the conclusion drawn is that the wood products industry provides stability to the region's economy, in effect failing to acknowledge the ecological tradeoffs involved. -- Draft Report
The report does not state that the wood products industries cause stability. Rather it reports the levels of employment and income provided by these industries. Also, we have limited data on the specific contributions of forest based recreation. -- Final Report
Table 1 in Socio 1 lists only percentages for each of the land use categories. Do you have acreages for these categories? Also, why don't the percentages add up to 100% - what's missing? Is there any way to separate timberland from forestland as you have in the section on Forest Area and Conditions? -- Draft Report
The raw data for these percentages are found in the web source of this particular data set (see SOCIO-1 for details). We've checked the sums--they add to 99.9 or 100 percent for all rows. There data could not be split between timberland and nontimberland--i.e., they are not FIA data. -- Final Report
You state that pine plantations on converted sites can have increased diversity over sites planted on former agricultural fields, and that these former ag sites "can develop considerable grass and forb diversity in early stages, but because they lack the biological legacies of earlier forests, their vegetative diversity is limited for a longer period of time". We question the legitimacy of mentioning the value of forest legacies when the recommended management techniques are designed to obliterate those legacies. -- Draft Report
Plantations do display a broad range of diversity depending on previous cover, stand establishment methods and cultural treatments. These factors are highly variable in the South and this is borne out in studies which measure diversity in planted pine stands. -- Final Report
We note that a variety of different measures used throughout the report to prioritize the ecoregions as areas of concern. It appears, however, that only one of these measures --the loss of forestland -- has been utilized to target the so-called "Subregions of Concern" in the Summary report. A broader look at all of the threats facing each subregion is needed and we strongly suggest the Cumberland Plateau be included as a subregion of concern. -- Draft Report
We have added a description of how we selected the three subregions of concern listed in the summary report. Several factors were considered and these are now described in detail. -- Final Report
On page 84, first paragraph under Conservation issues, last sentence of the paragraph, conservation easements can be both thirty year and perpetual. -- Draft Report
Technical editing. -- Final Report
In Figure 3.1.6 change in urban land: there is no data shown for Oklahoma counties. Is data not available or just not shown? In Figures 3.1.8 forest population density and 3.1.9 change in density: there is no data shown for Oklahoma counties. Surely this data is available. -- Draft Report
The model used to forecast land use did not include eastern Oklahoma. -- Final Report
The final document should present an integrated picture of all of the silvicultural requirements that went into your models of future timber supply and link those with their ecological and economic impacts. -- Draft Report
We have added more detail on the management assumptions behind the forecasts. The ecological implications of increased pine plantations are described in TERRA 4 and elsewhere in the Summary Report. -- Final Report
Decreases in the ozone exposure will lead to increased growth from some pines depending on the forest type. The Draft SAMI report on ozone effects to forest trees presents this relevant finding after using the TREGRO and Zelig models. Between 1995 and 2010 loblolly pine is expected to increase in basal area by about 25% for two forest types in two ozone regions (see Figure 3 in comment letter) and by 2040 increase by 55% in the loblolly-hardwood type in the Sipsey ozone region (see Figure 4 supplied in comment letter). Therefore, SAMI results indicate that loblolly pine, in stands mixed with hardwoods, are likely to increase in basal area because the stress caused by ozone will be reduced and loblolly pine will be able to outcompete neighboring tree species. -- Draft Report
This conclusion assumes that the scenario in the previous comment (40-3) is true. See above comment. -- Final Report
The ecological implications of intensive pine monoculture management and increased logging and clearcutting are not addressed in the document. The report does not include ANY information about the inevitable and continuous decline in biodiversity, water quality, soil productivity, etc. -- Draft Report
Chapters TERRA-4 and TERRA-2 examine the state of knowledge regarding the effects of intensive forest management on wildlife in the South. Planted pine is included in estimates of total forest area consistent with standard definition of forest cover. However, we include planted pine as a separate forest type so it can be tracked and its effects can be evaluated. We also conclude that changes in forest composition raise important issues for forest functions of various sorts (this is discussed in three of the broad findings included in Section 4.1). -- Final Report
The sustainability of tourist-based economy should be mentioned. The harvest practices in the south today mimic those in the Northwest; the practice is to move from one area to another and harvest there until all the logs are gone. -- Draft Report
Our forecasts of timber harvesting and growth do not generally bear out the concerns raised here regarding a transient timber industry in the South. The exception is where development displaces forests. -- Final Report
Ecoregions of priority concern should be given fuller treatment in the final summary report. At present, the draft report provides useful information about particular ecosystems but, like the issue-related information, it is so scattered through the documents that, for practical purposes, it is inaccessible to the average reader. -- Draft Report
We have added a description of how we selected the three subregions of concern listed in the summary report. -- Final Report
The projections upon which the entire study is based are based on an assumption of continued increases in timber production. While this is a critical perspective for assessing the likely future of southern forests under a "worst case" scenario, an equally critical perspective is one where production remains the same over the 40-year study period. it is only through such an alternatives analysis that the implications of various policy decisions (or lack thereof) can be adequately addressed. -- Draft Report
The Assessment was designed to look at likely futures and not to evaluate alternatives because this was not a decision process. We do conduct some sensitivity analysis to gauge the importance of certain assumptions. -- Final Report
On page 79, there is a spelling in the last paragraph: "…Oof" should be simply "of". -- Draft Report
Technical editing. -- Final Report
In Figure 2.7, counties in outbreak status for SPB, please show LeFlore, McCurtain and Pushmataha counties in southeastern Oklahoma in outbreak status for the 1-5 year period. We had severe SPB in the mid-1970s and they did not stop at the state line. -- Draft Report
The three counties have been added to the figure. -- Final Report
Our first recommendation is that the final report clearly emphasize coherent discussions of the key issues, drawing together and synthesizing the relevant information in the disparate technical reports into an understandable narrative. What is utterly lacking, thus far, is any meaningful synthesized discussion of how all this information should be added up to reflect a coherent status report on migratory birds, including a sense of the cumulative effects of forest changes on birds, among other factors. Also missing is any meaningful effort to resolve inconsistencies among the various technical papers. -- Draft Report
The Summary Report is intended to summarize findings from the individual chapters and at the same time provide a road map to where related findings are located in the technical report. While chapters provide various insights into the effects of land use changes (TERRA-3) and forest management (TERRA-4) on birds and other fauna, we lack the scientific basis to complete the cumulative impacts analysis proposed here. We highlight the need for effective ecological forecasting as an important research need in our conclusions. Peer review was used to evaluate the technical accuracy of individual chapters, but those that reflect the diversity of findings in the scientific literature are not necessarily resolvable. -- Final Report
...communities in which value-added wood products industries are concentrated have more sustainability and more sound economic bases than do communities in which paper industries are based. -- Draft Report
While correlations between industry conditions and various measures of social conditions are made, this comment suggests that we assign "causation" to these relationships. This goes beyond the scope of the findings--it cannot be inferred from the analysis. -- Final Report
The statement "many southern forests are fire adapted" is vague and not provable through time with research nor is there sufficient empirical evidence to support this claim. Please be more specific with a number or percentage, and locate these forest types. The statement "increases in ozone will reduce growth" leaves out the logical conclusion that harvests will go down from the existing forecasts on both public and private forestlands. -- Draft Report
We've added specific information regarding fire regimes to the Summary Report from the Background Paper on Fire. -- Final Report
The second conclusion (Ozone pollution is forecast to increase..."): It is true that a warmer climate could lead to increased ozone formation due to warmer and sunnier days needed for ozone formation. Furthermore, high doses of ozone can result in the reduction in the amount of fine root formation and make trees more susceptible to drought. These assumptions may be valid if nitrogen oxides are expected to increase, but as discussed previously, most likely nitrogen oxide emissions will decrease in the future. Certainly an anticipated increase in ozone (exposure) of 20 to 50 percent by 2025 will not occur and the cumulative ozone exposures (Figure 2, supplied in comment letter #40) and peak concentrations are expected to decrease at low elevation and high elevation sites in the SAMI domain. The assumption that NOx concentrations will decrease in the future is the critical assumption here. The SAMI integrated assessment shows NOx concentrations as remaining stable between 1990 and 2010 and then declining slightly by 2040. According to the document, shifts in NOx sources will occur primarily in the utilities and highway sectors such that decreases in utility-driven NOx production will more than offset major predicted increases in highway emissions, thus lowering overall atmospheric NOx concentrations. No further information is given in the document regarding how these numbers are derived. The SAMI document says: "SAMI will qualitatively evaluate the uncertainty for inventory projections, and where possible, quantify the range of uncertainty for specific emissions categories or source sectors of the projection inventories." (from http://www.saminet.org/ia/emissions.html). Also, it does not appear that these numbers have been peer-reviewed. Based on these conclusions, it seems a bit hasty to assume that ozone concentrations will be lower in the future (based on projected NOx reductions); especially if summer temperatures and human densities continue to rise in the region. -- Draft Report
We've added specific information regarding fire regimes to the Summary Report from the Background Paper on Fire. -- Final Report
The conclusion that wood products industry provides stability to the region's economy does not fit the historic picture of feast and famine in the timber industry. The report also fails to acknowledge the economic tradeoffs of a continued expansion in wood products industry. -- Draft Report
We do not conclude that these industries necessarily lead to more stability. Instead, we have charted their contributions to income and employment. The historical model of timber production moving from region to region appears to no longer hold with expanded agricultural-style timber production (and with timber inventories increasing or remaining level while harvest levels expand). Discussion of tradeoffs is found in chapter SOCIO-5. -- Final Report
The report asserts that most pine plantation expansion will come at the expense of abandoned agricultural fields. But data in the report shows that the majority of increases in the south have come at the expense of natural forests. The report does not provide convincing support that this trend will shift. -- Draft Report
Indeed these projections are a departure from recent historical data. We have added a discussion of this departure to the report and describe why the forecasting models yield this result. -- Final Report
We urge the agency to establish priorities as part of its regular research program rather than undertake any new initiatives directly based on this Assessment. The USFS is contemplating "small area assessments" as a subsequent task. We do not believe that these small area assessments will produce significant new insights beyond the findings of the SFRA. If fact, such a narrow focus would likely produce misleading findings. We believe the agency should instead focus its attention and limited resources on improving and expanding data collection efforts such as the annualized FIA system. -- Draft Report
The Assessment includes identification of information gaps, but it is beyond the scope of the assessment to recommend priorities for future research. -- Final Report
The report fails to present a balanced analysis of the long-term implications of these trends for biodiversity, water quality, and economic stability in rural communities. Second, there is insufficient analysis on the cumulative effects of increased logging and shorter rotations in natural forests on biodiversity, water quality and specific species of concern. Third, the report fails to acknowledge the critical role the wood products industry has played in the destruction of the south's wetlands. -- Draft Report
The assessment's purpose was to compile and present credible resource information and to, where possible, forecast likely future conditions in a defensible fashion. The assessment is not an environmental effects or impact analysis. The role played by silviculture in historical wetlands losses as reported by the NWI are included in Chapter Aqua 2. -- Final Report
The report states there are 39 rare forest communities reduced to 25% or less of their habitat since settlement, and 14 of these communities are down to less than 2% of their habitat. Most of these communities are in seven habitat classes, and only two of these seven classes are found on public land. How do we get private landowners to manage for these rare communities when there are no regulations to guide them, and not enough money to inspire them to do so? -- Draft Report
The assessment was designed as strictly a descriptive effort. Recommendation and design of policies were beyond its scope. -- Final Report
You also fail to mention that timber jobs and associated income shift from place to place. Please ensure that the report makes it clear that the jobs provided by logging tend to shift from one community to another if an area is overharvested. -- Draft Report
Shifts toward agricultural style timber production suggest that the interregional movement of harvesting will not be a major issue in the future. The exception would be areas where urbanization reduces forest area. -- Final Report
On page 74, Figure 3.36 the figure illustrated "public" land in the South; unless I'm mistaken the figure maps federal ownership and not all public. Replace "public" with "federal". -- Draft Report
Technical editing. -- Final Report
In Figure 1.2 the size of the font is different in the first block. -- Draft Report
Technical editing. -- Final Report
The Technical Report papers provide a good overview of existing conditions in the southern forest. However, the utility of the papers is limited because the SFRA's merely assuming that current industrial forestry trends will continue unabated into the future. We believe that a more balanced "alternatives" approach to the consideration of regulatory versus nonregulatory approaches, like that of NEPA, would be appropriate from the standpoint of decisionmakers and stakeholders who will use SFRA as a point of departure in coming years. -- Draft Report
With regard to forecasting, our objectives were to evaluate the "most likely" future, based on current conditions and observed trends. Evaluating scenarios that would involve structural changes in industries or economies would be beyond the structural basis of the forecasting models employed here. -- Final Report
When you discuss sustainability, I think you need a definition. -- Draft Report
The report does not offer a summary assessment of the "sustainability" of southern forests. We have provided an analysis of the various dimensions of the issue as we have answered the specific questions that organized the assessment. -- Final Report
In the Preface on page 2, you referred to an "increasing timber demand". The demand is not for "timber" all-inclusive but for selective types and grades suitable for specific products. Also, you state that there are "increasing numbers of satellite chip mills" but yet in Section 2.3 Timber Markets on page 17 you present data that shows a drop in chips produced by offsite chip mills. -- Draft Report
We concur that aggregate demand is the accumulation of demands for a variety of products and this is discussed in Chapter TMBR-1. Also a short-run drop in the number of chip mills (last two years of data) does not necessarily translate into a finding that demand will decline in the long run. -- Final Report
The sections of the report that discuss chip mills fail to acknowledge the broader force of change within the market by limiting the discussion to satellite chip mills. This narrow discussion of satellite chip mills completely ignores the bigger picture of the market force that is driving increased harvest rates, shorter and shorter rotations and the conversion of forests to intensively managed plantations. Neither the ecological implications of this market trend nor the economic implications are adequately addressed. -- Draft Report
All of our forest market analysis and modeling addresses the full suite of demands for wood productions (chip mills were discussed as a case of interest to the public.) Ecological effects of shifts toward more intensive management are described in TERRA-4 and some in AQUA-5; economic impacts of forest uses are described in SOCIO-5. -- Final Report
Does not address the losses being realized on a broad scale from red oak borers, disease, or other insects. Local loggers are harvesting red oak timber at rates above projections in an attempt to salvage the trees before they are killed by borers. -- Draft Report
These issues are described in HLTH-2. Red oak borer activity is not broad in scale at this time, but is limited to Arkansas in the South. -- Final Report
There appears to be neglect for the growing demand for forest-based recreation and the additional protected land that will be necessary. -- Draft Report
We discuss the increased demand for outdoor recreation and scarcity of land available for recreation in Chapter SOCIO-6 and the Summary Report. -- Final Report
There is an absence of information and consideration about the significant economic impact of current tourism or its potential from hunting, fishing, and other recreational activities associated with intact, native southern forests. -- Draft Report
Data limitations preclude us from making estimates of the economic impacts of forest based recreation. Estimates of outdoor recreation impacts are discussed in SOCIO-5 and elsewhere in the Summary Report. -- Final Report
The first conclusion "While effects are variable..." The conclusion states that nitrate deposition is expected to have a greater impact to terrestrial and aquatic systems than sulfate deposition. The SAMI analysis indicates nitrogen deposition is expected to decrease throughout most of the region; furthermore, sulfates will continue to play a significant role in base cation depletion due to mountainous soils retaining deposited sulfates and then releasing the sulfates in the future. -- Draft Report
We state in chapter HLTH-3 that both nitrogen and sulfur deposition are expected to change terrestrial and aquatic ecosystems. However, the degree of change is an ongoing research priority of the Southern Appalachian Mountain Initiative. -- Final Report
We found the report seriously incomplete in its coverage of the ecological and socioeconomic impacts associated with both the loss of a projected 30 million acres of forest over the next 40 years to development and with continued unsustainable levels of timber harvesting throughout the region. The report fails to adequately assess the effects on biodiversity of intensive forest management practices needed to permit such high levels of production. There was also scant mention of biodiversity impacts of the overall projected future decrease in hardwood community acreage and concomitant rise in softwoods. -- Draft Report
Individual chapters address the state of knowledge regarding the ecological and biodiversity impacts of development (TERRA-3) and forest management (TERRA-4). State of knowledge does not yet support ecological forecasts suggested here, and this was identified as an area deserving additional research. -- Final Report
Part of the problem is divergent understandings/perceptions of words like "sustainable" and "forest". I get the feeling that when you use the word "sustainable" you ultimately mean economically sustainable with little or no thought for the native, natural habitats involved. When I use the word sustainable, I mean ecologically sustainable where all biotic communities including humans are mutually supported and sustained. -- Draft Report
The report does not offer a summary assessment of the "sustainability" of southern forest. We have provided an analysis of the various dimensions of the issue as we have answered the specific questions that organized the assessment. -- Final Report
You state that total forest area will remain stable with subregional and compositional changes. I think this is somewhat misleading, in that you are not making enough of a distinction between a planted pine plantation and a natural forest. You ignore this and lump pine plantations in with natural forests when you say that only a small amount of forest will be lost by 2040. The way you write this downplays the potential seriousness of the loss. We are projected to lose 25 million acres of natural forest by 2040 if your projections are correct. -- Draft Report
We forecast planted pine area as well as total forest area and raise concerns about changes in forest structure as one of our broad findings. We are emphatic about changes in the structure of forests. -- Final Report
The conclusion that most of the gain in pine plantations will come from abandoned agricultural fields is more likely an assumption than grounded in fact. The ground level facts tend to point the other way, that the lost forest lands are being replaced in monoculture pine plantations. -- Draft Report
Indeed these projections are a departure from recent historical data. We have added a discussion of this departure to the report and describe why the forecasting models yield this result. -- Final Report
The ecological impacts of the wood industry should be more clearly recognized. The report should emphasize the need for full protection of all old growth and rare forest communities on public lands. In addition, the report should provide an analysis of sustainability into subregional areas to provide a better sense of areas of concern. -- Draft Report
Individual chapters address the state of knowledge regarding the ecological and biodiversity impacts of development (TERRA-3) and forest management (TERRA-4). TERRA-5 discusses the importance of public lands in sustaining more forest communities and we point out that public land has a strong role to play in the cases of certain rare forest communities. It was, however, beyond the scope of the assessment to recommend policies. -- Final Report
It is difficult to find one location in the report that deals with the many aspects of this fundamental question. The various threats to sustainability are scattered (buried) all through this large report, but not coherently gathered together with conclusions and recommendations. -- Draft Report
The report does not offer a summary assessment of the "sustainability" of southern forests. We have provided an analysis of these various dimensions of the issue as we have answered the specific questions that organized the assessment. -- Final Report
On page 15 under Figure 2.5 there's a missing number in the caption; it should read "1995" and not "199". -- Draft Report
Technical editing. -- Final Report
The charter of the US Forest Service directs the FS to provide for the nations timber needs and to protect watersheds. Private property does not fall under the USFS charter, so the USFS should play no regulatory role in managing private southern forests. -- Draft Report
Note that this is an assessment of conditions and contains no recommendations regarding regulation or any other policy. -- Final Report
The term "sustainable" forestry needs careful definition. -- Draft Report
The report does not offer a summary assessment of the "sustainability" of southern forests. We have provided an analysis of the various dimensions of the issue as we have answered the specific questions that organized the assessment. -- Final Report
Figure 1.1 that shows the region, please show the entire states of Oklahoma and Texas. If you want to continue to delineate the areas that are actually under FIA in these states that is fine, but please include the entire state as part of the assessment. -- Draft Report
Technical editing. -- Final Report
Although the SFRA documents that the expansion in the pulpwood sector of the industry has been the most pronounced, there is no real analysis of this finding. The link between increased use of immature trees, the resulting increases in even-aged cutting and the conversion of natural forests to short-rotation plantation management is never clearly made in this analysis. -- Draft Report
The report lists changes in forest ecosystem structures arising from intensified management as one of the key findings in Section 4.1. -- Final Report
The SFRA fails to address the ecological impact of intensive pine plantation management, which includes the use of herbicides, genetically modified trees, and fertilizers which have the effect of compromising water quality, biodiversity, and habitat for wildlife. -- Draft Report
The state of knowledge regarding the effects of various forest management techniques on wildlife habitat, species persistence, and biodiversity is described at length in chapter TERRA-4. The effects of management on water quality are summarized in chapters AQUA-3 and AQUA-4. -- Final Report
I question the Forest Service's terminology of "sustainability" within this study. -- Draft Report
The report does not offer a summary assessment of the "sustainability" of southern forests. We have provided an analysis of the various dimensions of the issue as we have answered the specific questions that organized the assessment. -- Final Report
The SFRA did not address the ecological implications of intensive plantation management and increased logging. -- Draft Report
The state of knowledge regarding the effects of various forest management techniques on wildlife habitat, species persistence, and biodiversity is described at length in chapter TERRA-4. -- Final Report
Pine plantations are treated as equal in ecological status and function as undisturbed old growth mixed hardwood and conifer. -- Draft Report
Planted pine is included in estimates of total forest area consistent with standard definitions of forest cover. However, we include planted pine as a separate forest type so it can be tracked and its effects can be evaluated. We also conclude that changes in forest composition raise important issues for forest functions of various sorts (this is discussed in three of the broad findings included in Section 4.1). Also, a more thorough discussion of plant communities is contained in Chapter TERRA-2. -- Final Report
Please include a more complete analysis of ecological and socio-economic threats posed by the expansion of forestry and sprawl, esp. on wetlands, water quality, recreation, wildlife diversity, species diversity, and viability of communities as industrialization decreases jobs. -- Draft Report
The Summary Report does not contain the entire complement of findings from the Assessment. See individual chapters for detailed findings in all of these areas: Chapter AQUA-2 examines wetlands, AQUA-1, 2, and 4--water quality, SOCIO-6--recreation, TERRA 3 and 4--wildlife diversity, TERRA 1 and 2--species diversity, and SOCIO--5 and viability of communities and forest-based employment. -- Final Report
the conclusion that most of the increase in pine plantation stems from abandoned agricultural fields is not borne out by the report's own data. -- Draft Report
Indeed these projections are a departure from recent historical data. We have added a discussion of this departure to the report and describe why the forecasting models yield this result. -- Final Report
The document focuses mainly on the sustainability of wood fiber supply rather than on economical, biological, and ecological sustainability. -- Draft Report
The report does not offer a summary assessment of the "sustainability" of southern forests. We have provided an analysis of the various dimensions of the issue as we have answered the specific questions that organized the assessment. -- Final Report
The report identifies 14 "critically endangered" forest communities and many more imperiled species, but misses the opportunity to analyze the ecological impact on these resources of increasingly intensive forest management. -- Draft Report
There are no data that yet allow us to directly map the specific concurrence of management and these rare forest types. We do however, discuss general concerns regarding rare forest types (Chapter TERRA-1 and Summary Report). -- Final Report
Forest gains in the West through agricultural land converted to forests will equate to lower potential timber markets due to the decrease in moisture as one moves west. Please recognize this fact and include it in your report. -- Draft Report
Productivity differentials are recognized in models of growth and yield (see Chapter TMBR-1 and references cited) and are therefore a part of the market projections described in this report. -- Final Report
The statement (p. 13-14) that "change in pulping technology has allowed hardwoods to be substituted for more expensive softwood in the manufacturing of paper products." This is certainly not the case in our area of southwest Alabama and southeast Mississippi. Paper companies are using hardwoods because they have to have hardwood fiber to make the paper product they manufacture. Hardwood pulp presently brings $2 to $6 per ton more delivered to paper mills than does pine. -- Draft Report
This has been a general trend for the region over the last two decades. However, it may not apply at every facility throughout the region. -- Final Report
LFA requests you include the various contributions of private landowners, loggers, industry, and academia to the sustainability of southern forests in the final report. -- Draft Report
It is beyond the purpose and scope of the assessment to assign credit or blame for trends in forest conditions. -- Final Report
In the first finding "While the effects are variable...": It appears there is an assumption that nitrogen oxides are expected to increase. Figure 1 (supplied in comment letter #40) shows the estimated nitrogen oxide reductions throughout the eight SAMI states, which correspond to a large portion of the SFRA. The three values to examine in the figure are the base, A2 in 2010 and A2 in 2040. The base case represents total estimated nitrogen oxide emissions for the 8 states, while the A2 emissions represent current laws, rules, and regulations that are being implemented. Clearly it can be seen that nitrogen oxide emissions are expected to decrease in the future. (See comment letter #40 for data.) -- Draft Report
Throughout chapter HLTH-3, we state that nitrogen oxide concentrations are expected to decrease. However, these new concentrations are still expected to have negative impacts on forests across the South. -- Final Report
The significance of much of the data is obscured or lost on the reader because information on forest trends is not well integrated with data on ecological trends. This lack of integration diminishes the value of the draft report as a tool to inform future state and federal policymakers related to forests. -- Draft Report
Limitations of scientific knowledge and the spatial resolution of models prevent explicit ecological forecasting. We highlight this as an important direction for future research. -- Final Report
The SFRA documents that while 30 million acres of forest will be lost to sprawl through 2040, at least 250 million acres of forests will be heavily logged by big timber companies to produce products such as paper. It is puzzling that the conclusion drawn in SFRA is that sprawl is the largest threat to our forests. -- Draft Report
The estimate of 250 million acres is not familiar to us (there are about 200 million acres of timberland in the South). We do identify changes in forest structure, including increased plantation area, as a Broad Finding in Section 4.1 of the Summary Report. -- Final Report
The SFRA has no mention of soils. As the "ultimate resource" of the forest ecosystem, an assessment is not complete without an assessment of the soils. The sustainability of the region's soils has been a very high priority scientific and management issue. -- Draft Report
Soil sustainability was not selected as a topic of a question, though soil erosion is addressed in some detail in Chapter Aqua 4, and soil productivity to a limited extent in Chapter Timber 3. -- Final Report
The SFRA fails to project the effect of increasingly intensive use of southern forests on broad ecological and socio-economic sustainability as well as the likely effect on wildlife, water quality, and wetlands. -- Draft Report
Individual chapters get at these concerns (see TERRA 1-5, Socio 5 and 7, and AQUA 2). They are also raised in various sections of the Summary Report. -- Final Report
....how many additional acres of protected forests are needed to supply demand for public recreation due to increasing recreation pressure on public lands in the southern Appalachian forests, and with respect to local economies, how will forest-dependent communities fare as the wood products industry intensifies management and automates more processing facilities? -- Draft Report
Recreation effects and demands are described in chapter SOCIO-6 and employment and other social effects are described in chapters SOCIO-5 and SOCIO-7 respectively. -- Final Report
I urge you to amend the SFRA to include a greater emphasis on the maintenance of high quality, diverse and old growth native forests throughout the region. -- Draft Report
Old growth forests were identified in the report as one of the threatened forest communities. -- Final Report
Rather than undertaking any subregional analyses, we hope the Forest Service will give complete consideration to the full breadth of forest research needs including full implementation of the Forest Inventory and Analysis program and those issues described as "Scientific Uncertainties". -- Draft Report
The Assessment includes identification of information gaps, but it is beyond the scope of the assessment to recommend priorities for future research. -- Final Report
The sustainability of the south's scarce plant communities such as longleaf pine/bluestem, shortleaf pine/oak-hickory, and mixed hardwood/loblolly pine and all old growth plant communities should be discussed to provide an accurate picture of the forest resource. -- Draft Report
We have flagged these rare communities as serious concerns for the future of southern forests. -- Final Report
The conclusion that most of the gain in pine plantations will come from abandoned agricultural fields is not strongly supported. Your own documents have data that 75% of the increase in plantations have come at the expense of natural forests. -- Draft Report
Indeed these projections are a departure from recent historical data. We have added a discussion of this departure to the report and describe why the forecasting models yield this result. -- Final Report
In the "Implications for Ongoing Programs" discussion of the Summary and in Section 4.3 of the Report you need to discuss the implications of the projected increases in timber cutting and the potential for BMP implementation and other environmentally-protective forest measures through both voluntary and mandatory programs. -- Draft Report
We now describe the needs for providing assistance that addresses water quality and other concerns as production intensifies in the future. -- Final Report
|
|
webmaster: John M. Pye |
created: 4-OCT-2002 |