Assessment Methodology We believe that your proposed timeline will not give researchers enough time to adequately address all of the issues before you in this assessment. After the completion of the initial conclusions in this two-year assessment, we hope you will consider continuing the research. I encourage the Fish & Wildlife Service and Environmental Protection Agency to provide similar amounts of staff time and other resources that the Forest Service has committed to this study. If the findings could be reviewed by a "panel of experts" before it is made public, so much the better. The good intentions of those involved in the study are too often defeated by a limited range of perspectives, initial presumptions controlling the evaluation process, and short-sightedness in the consideration of impacts. Enclosed are the comments of the Houston Sierra Club (HSC) for scoping for the two year assessment of forest resources of 13 southern states. We request that we be placed on the mailing list to receive any and all documents or information about this proposed study. We would appreciate it if you would send us the most current information that you have on the study. I recommend the Forest Service and other cooperators begin planning for the next step after the two-year assessment. For example, based on the information gathered, prepare guidelines for management of southern forests that could be disseminated to other Federal agencies, State agencies, local governments and private landowners. I would like the task force to adopt a more complete definition of ecological sustainability, somewhat akin to that developed in the Journet and Logan paper available at: (http://cstl.semo.edu/journet/bi684/LoganC.htm), namely: "Sustainable management will: Provide from the forests to current and future generations (in perpetuity) a wide array of goods and services in addition to wood products, while protecting biodiversity, maintain ecological processes and the ability of ecosystems to respond to disturbance and accommodate change while recognizing the ecological limits imposed by a planet with finite resources, promote forest health and productivity, prevent industrial pollution and waste, while promoting resource use efficiency (reducing consumption). In addition, sustainable management will assure social justice through allowing equitable access to and consumption of natural resources. While the principles of sustainability do not prescribe management techniques, employed strategies and techniques will be socially responsible, and will promote management of complete ecosystems. Finally, ecologically sustainable management will acknowledge the intrinsic value of the natural world." I also think the questions for which data are sought should explicitly focus on 'ecological sustainability' rather than 'forest land base' and the like, indicating that the goal is to assess sustainability not just how many harvestable trees are out there. Evaluate forest quality on a landscape rather than a stand level, and attempt not just to maintain quality, but to enhance it. Your definition of sustainability as contained in the handout is right on target. I believe maintaining biological diversity is the key concern. Without biodiversity, human health, wildlife habitats and rural community stability are challenged. Perhaps this study of our Southern forests could go beyond the protection of wildlife habitats to include humans as well. The diminishing of soil, water and air quality, the dependence on aerial spraying of herbicides, the uncertainty of timber markets, the short life of chip mills, the loss of farmland to feed ourselves -- these can greatly undermine human health and security. Uncertain profits from commercial timberland will not be enough to repair the damage. One of your team members has shown a definite bias against private property rights. How will you assign and distribute your work load to ensure all team members are fairly considering the job at hand? Will you attempt to come up with a definition of sustainable? The term "forest" is used generically, and it is not clear how rigorous and specific the study intends to be in its use of the term. Ecologically, a forest refers not just to tree species, but also to understory plants, animals, and the interactions between them. Native forest ecosystems, and in particular mature native forest ecosystems, are under the greatest threat. Initially, the GRN would like to recommend to the report authors that additional federal agencies actively participate in the study. The study authors should work closely with the U.S. Army Corps of Engineers (Corps) to determine the impact of the Corps' regulatory/permitting activities on the nature, extent, and health of forested wetlands, NOAA to ascertain the impact of present and future forestry practices on coastal water quality and fisheries habitat, the study authors must work with the Corps, NOAA, the U.S. Fish and Wildlife Service, the U.S. Environmental Protection Agency and other federal agencies to determine the role the federal government has played in the staggering loss of bottomland hardwood forests in the Louisiana and Mississippi Deltas and the potential contribution federal agencies and the policies they implement will have in continued losses of these forests in the future. The term sustainability should be considered from both economic and environmental standpoints, and it should be clearly stated which sense of the term is being employed. As I read through your questions, I see many references to ""the likely future"" of various forest elements and values. You do not say what assumptions this ""likely future"" will be based on. It is important to recognize that people have considerable control over that future. What is the ""desired future"" of these elements and values? I am concerned that the wording of several sections and questions suggests that what already is will have to continue to be. You should assess the opportunities for restoring more natural ecosystems and wildlife habitat to benefit wildlife, clean water, etc. The focus appears to be on what the future may hold for forest products at the expense of other values. Your scope should be broad and include consideration of the cumulative effects of management for commercial products on functioning ecosystems, wildlife, and other noncommercial values, also. The Southern Forest Resource Assessment, having just read your methodology and the questions generated for the assessment, hugely impresses me. What a good combination of brains and empiricism. Would that all forest decisions could be based on your model. Will/Can a map be developed that coordinates data and is consistent across watershed and forest? Developing a usable, consistent, translatable or common language physical and digital map of the Southeast Forest resource is the most important goal to accomplish. The mapping should be able to coordinate and dovetail with Federal and state watershed assessment maps. Having a usable map will make all other study and conclusion fall into place. We have to know what we are dealing with before we deal with it. Regarding who participates in the study, we believe that it is essential that state natural resource agencies and water quality agencies be included in this assessment from the beginning. We believe that it the study will be imbalanced if the Forest Service as the lead agency only brings state forestry agencies and not all the pertinent players to the table. We are concerned about the Forest Service taking the lead in this study. With all due respect to the members of the Southeastern Natural Resource Agency Leaders Group, many of the problems we now face come from past policy's of the Forest Service. Define “history.” The study should not concentrate merely on the long-term availability of logs for lumber or chip mills, but also on the overall environmental impact of logging, including water quality, forest undergrowth, wildlife of all kinds, tree species diversity, tourism, long-term economic health of the region from which trees are extracted, and the time required for ALL plant types lost as a result of a clearcut to regenerate on the cut site. For the study to have any credibility, there must not even be the slightest appearance that the timber and chip mill interests have in any way taken control of it or biased the focus away from such things as biodiversity and general environmental impact. What is your definition of forest? A plot of land of a minimum size covered predominantly by trees? It might be advisable to make a definition that distinguishes between ecosystems created by God or nature and those created by humans. PLEASE SEPARATE/DIFFERENTIATE PINE FARMS FROM "FOREST COVER" REFERENCES. THEY ARE MORE AKIN TO MONSANTO CORN FIELDS THAN FORESTS. ALLOWING MAN-MADE PINE DESERTS AND OTHER PLANTED MONOCULTURES TO BE CALLED FORESTS IS A TRAVESTY. We need to be very consistent and explicit about wetland terminology. Historical part of this question is unanswerable. Questions as revised in response to these comments Previous Question | Next Question Public Input Home | Methods | Assessment Home
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