Southern Forest Resource Assessment The suggestions or concerns below were submitted in response to preliminary assessment questions but did not directly fit with a particular question--for details see our Public Input or Methods pages

Scope of Assessment Process I believe it is very important that these agencies address the issues of recreation, ship mill permits, water quality, and clearcutting so that these forests can be enjoyed by future generations. The timeline for the Small Area Assessments should not be limited by the timeline for the broader, regional analysis. Ecological Impacts - We are particularly concerned about the ecological costs of modern forestry including the loss of biological diversity (including species diversity, genetic diversity and structural diversity -- horizontal and vertical), damage to aquatic systems, and increases in planted pine. Your researchers should identify and map rare or threatened ecological forest types (I.e. long-leaf pine ecosystem and incorporate the most up-to-date available from state heritage programs into the ecological analysis. Reliance on FIA data for the ecological analysis is inappropriate, as FIA forest types do not coincide with ecological forest types. Likewise, your researchers should identify and map large tracts of mature contiguous forests and conduct an analysis of how modern industrial forestry practices impacts the dynamics of these areas. I am writing to request that this study encompass ecological concerns in addition to silvicultural and economic considerations. Include water quality and wildlife habitat along with recreation, tourism and other economic effects on the rural communities involved. Conducting a study, while having no controls in place over continued chip mill production during the two-year study period is naïve and potentially harmful. A primary goal of managing a watershed is to consider the range of impacts and benefits of individual activities within the context of larger ecosystems such as ecological hubs, which are connected to one another and to other conservation areas by greenway corridors, protection of the state's ground and surface water resources, protecting wetlands, minimizing downstream watershed impacts, and protecting riverine corridors, and implementing forestry Best Management Practices. The Forest Service should give complete consideration t the relationship of the resources it manages to the natural systems that extend beyond its forests' boundaries. In order to accomplish this, it will be necessary to replace an emphasis on resource rather than political boundaries. I hope that the findings will be descriptive rather than prescriptive. Everything presented should be scientific, and it should be valid science, not speculative science. Over the last several years, southern forests have been playing a larger role in supporting forest industries as much of the harvesting from the Pacific northwest has relocated to the south. It is therefore an appropriate time to evaluate the overall trends in production, use and environmental quality of southern forests and provide a peer reviewed, technically-based evaluation of forest conditions. The assessment will be descriptive in nature and not prescriptive. Describing or identifying potential challenges to regional sustainability will be an appropriate role for this assessment to undertake. Any prescriptions, actions, or strategies to address forest sustainability issues should be developed separate of this assessment. Sustainability should be defined for several management alternatives or goals. Some examples of sustainability would be: (a) keeping total forest tree volume growth greater than removal, (b) keeping saw timber growth greater than removal (and other timber objectives), © sustainability of various levels of wildlife habitats and populations in addition to the timber sustainability, (d) adding sustainability of recreational and other social and economic values. We believe that the proposed action is timely and important. The Assessment should include the long term protection of public lands, restoration of forested habitat and particularly riparian habitat, enhancement of aquatic habitat, delineation of rare, threatened or endangered species habitat, and identification of technologies or procedures that will accomplish these commitments as part of the federal agency process or procedures. We would recommend that continued surveys of the project lands be conducted as part of the Assessment. Our staff has been working to identify rare, threatened or endangered species habitat within the U.S. Forest Service's lands in Tennessee. The results of our Departmental data bases review does not mean that a comprehensive biological survey of the U.S. Forest Service's lands has been completed. Because of the presence of State and/or Federally listed species near or within the Assessment lands, the U.S. Forest Service should commit to identification and protection of biodiversity on public lands. It is probable that a recorded species will occur in the project area if suitable habitat exists. We urge this group of agencies to truly address the problems of forestry in the South. We need to protect and restore the diverse ecosystems that exist here. The South has more biodiversity in its forests than almost any other temperate forest in the United States. Thank you for initiating a study of Southern forest sustainability. It's high time we looked judiciously at the state of our forests -- we are losing them at too rapid a rate and will not be able to quickly restore, if at all, what is lost. You have accepted a tremendous task here, one that we should have initiated years ago. Thank you, thank you, thank you. I hope from your work -- from the scientific data and recommendations you give to Southern policymakers and forestry bureaucrats, as well as to the public -- we are able to slow the rate of destruction and manage to retain some of the glorious ecosystems that make up our landscape. The preliminary assessment questions posed at the workshops encompass most issues the Service would want addressed in any forest assessment. However, their broad scope provokes the concern that the Forest Service will have so much information to gather that the assessment cannot possibly be done in a meaningful way in two years. In past discussions regarding this project, there was preliminary proposals to gather general information about all the forest but focus more attention on "hot spots." Such a strategy would enable more specific answers to questions such as "what conditions will be needed to sustain plant and animal habitat associations?" or "what is the history, status and likely future of aquatic habitats and species in the South?" Considering recent forest-clearing trends in certain areas of Tennessee, North Carolina, and other states, finding a "hot spot" to focus on would likely be simple. The focus areas would serve as case histories to be used for comparison by resource agencies when developing new or revised conservation measures for other forest systems. What Is a Prudent Course of Action, Given that We Don't Yet Know What the Full Ecological and Economic Consequences of Widespread Logging Will Be? Some of the conceptual issues remain unresolved, the analytical models are immature, and the data are limited. Nonetheless, the agencies must not allow these difficulties to become an excuse for doing nothing. Those interested in understanding the outlook for southern forests cannot be fully informed without the best possible description of the uncertainty and risk--both ecological and economic--inherent in widespread logging. My greatest concerns are that the stated objectives of the study are misleading, the actual benefits of the study as it is currently outlined are minimal, and that the 2-year time-frame to complete a study of forest sustainability is unrealistic. My fear is that the bound documents produced at the end of the study will contain conclusions or be used to draw conclusions about forest sustainability when such conclusions are inappropriate give the primitive nature of the data. Policy makers will use the documents to make important decisions that impact forests, thinking they have sufficient information. However, because 2 years is not enough time to collect the information that is needed, and because current information is inadequate for decision making, the end result will be inappropriate policy by misinformed decision makers. An assessment of southern forest sustainability in 2 years cannot be achieved. Instead, I hope a more meaningful scientific study will be undertaken that will truly assess impacts of chip mills and related industries on natural ecosystems and provide responsible opinion about possible future trends in biodiversity and its significance to humanity. Such an undertaking will certainly take many years and millions of dollars to complete, and may take 2 years or more just to design. Considering the value and extent of the resources in question, this investment of both money and time is appropriate. The ability of forests to produce our current or future needs for paper and building products should not be included in an assessment of forest sustainability. Instead, once we determine how we will manage the forest to make it sustainable for the more-critical projects it produces (e.g., the biodiversity that supports life itself), we can determine how much we might use for wood and paper without impacting sustainability. The focus should be on watershed health and restoration--to be certain, wood fiber and jobs will follow from many of these efforts but only as a function of restoring the health, diversity, or productivity of the land. An alternative to the presently-proposed study is the funding of a study to assess impacts of chip mills and related industries on natural ecosystems. Such a study would not only look at acreage of forest cleared per year, but would incorporate a before-and-after approach to data collection. Detailed data would be gathered on all plant and animal species present on forests selected for clearing and the structure and functioning of the ecosystem supporting them. Simultaneously, control sites (protected from logging) would be evaluated identically. Following logging, both impacted and control areas would be monitored over the next several decades to evaluate community and ecosystem structure and functioning. This model would be followed on multiple areas within each of several geographic regions and ecosystem types within each region. The study would not add to the forests being exploited by chip mills, but would incorporate areas already scheduled to be cut. A book or books that outline our current state of knowledge will not all us to assess sustainability. For that reason, I suggest the title and objectives of the presently-proposed study are misleading. Because critical questions about sustaining biodiversity cannot be answered in two years, the study should not be called an "assessment" of forests, and an objective should not be to provide data on which to base decisions about sustainability. If the goal is to gather all data currently available on the distribution of forest land and the historical impacts of tree harvest on that distribution, then, perhaps, that can be done in 2 years given sufficient funding and personnel. Unfortunately, because we have almost no control areas (areas not previously logged) as a basis for comparison, very little can be said about the impact of harvest on forest health or the economy. If the goal is to evaluate the state of knowledge on forest sustainability, such a study could look at all research conducted to date on impacts of logging, including impacts on wildlife populations and their habitats, plant and animal community structure, ecosystem wildlife populations and their habitats, plant and animal community structure, ecosystem structure and function (including the physical environment, of course), local economies, and sociological impacts. If the goal of the study is to assess sustainability of forests in 13 southeastern states, it will fail, because necessary data are not available, and cannot possibly be collected within 2 years. Ultimately, of course, the goal is forest sustainability. To achieve that goal, a document that summarizes or current state of knowledge on the subject is appropriate. The set of preliminary questions outlined by the federal team, however, does not necessarily lead to such a document. What is the definition of ecosystem sustainability? What steps are required to insure ecosystem sustainability in the future? Identify the issues & resources of concern, including their location. Define the time & space scales for analysis. Identify the magnitude of risk to resources, adjust the scope of the analysis according to the likely cost to resource values of a wrong answer and select the appropriate level of effort for the analysis. Identify key cause-and-effect mechanisms. Estimate the range of natural variability and relative condition(s) for the resource(s) of concern. Identify past, present, and expected future activities in the area of concern & evaluate the relative impact of past, present & future activities. Evaluate the validity & sensitivity of the predicted cumulative effects. Identify key data daps & monitoring needs. Identify possibilities for modification, mitigation, planning & restoration. I strongly support a scientifically based forest resource assessment in order to provide objective and credible information that forest owners, industry, and state governments can then use to adjust strategies and programs to work toward ensuring the sustainable management of the South's forest resources. I applaud that the assessment will not make policy judgments or decisions about future forest uses, nor will it recommend mechanisms for managing resource extractions or services. The Assessment should be on the sustainability of the forest resource, and not on how wood and paper products are processed or manufactured. We support the agency effort to undertake a detailed study of Southern forests and the threats posed to them by a variety of factors. These include escalating harvest areas in certain geographic areas which may be related, in part, to changing technologies, such as high capacity chip mills. These developments, when considering in combination with such external factors as increased population, all re-enforce the need for this detailed Assessment. Our primary, overarching concern is that the study be structured in all respects to result in the highest possible relevance to ongoing policy development and decision-making by state and federal agencies and legislative bodies. While we understand that (for better of worse) the Assessment will not make recommendations for action per se, we suggest that the utility of the effort be evaluated largely by whether the resulting product actually helps decision-makers take action to address current problems and potential threats to our forest ecosystems. Descriptive responsible officials. With the proliferation of chip mills and industrial scale forestry throughout the south east, particularly on private lands, what agency will track the OVERALL impacts? Who will coordinate region-wide assessments of timber harvesting: amount of cutting, location of cutting, and environmental impacts. State studies are clearly insufficient to cover, even at a state level, the key questions of environmental and economic impacts. How will you involve state agencies like the Dept of Forestry, Game and Inland Fisheries, Dept of Conservation, Natural Heritage Programs in this study? What regional agency will oversee lax state agencies to insure a sustainable forest ecosystem? We suggest that the concept of sustainability be defined to include ecosystem functions (e.g. primary productivity, nutrient cycling, floodplain storage, and natural disturbance regimes), as well as the economic return from forest-related resources. When future likely conditions or trends are described, it should be very clear exactly what assumptions are implicit in these predictions. If we are genuinely to wish to move towards ecological sustainability, a desired future condition should be the preferred or default option. Temperate but endangered planet, enjoys weather, continental drift, photosynthesis, and evolution. Seeks caring relationship with intelligent life form. We agree with the agency's decisions that the assessment will not make judgements or decision about future forest uses, nor will it make recommendations for managing resource extractions or services. We also agree that the focus of the Assessment should be on the sustainability of the forest resource, and not on how wood and paper products are processed or manufactured. Our members are concerned as to how the Assessment will scientifically evaluate whether sustainable forestry is being achieved or maintained. We hope that you will better inform our membership on the criteria and indicators that will be used in the scoping process and on what scale the Assessment will be used to evaluate the sustainability of the southern forest. The forest industry offers strong support to the USFS in its role as the lead agency in conducting an assessment of the sustainability of the Southern forests. We applaud the agency's decision that "the study will not make judgements or decisions about future uses nor will it recommend mechanisms for managing resource extractions or services." The forest industry also agrees that the focus of the Assessment should be on the sustainability of the forest resource, and not on how wood and paper products are processed or manufactured. The forest industry is uncertain how the Southern Assessment will scientifically evaluate whether sustainable forestry is being achieved or maintained at both regional and sub-regional scales. An issue that will need to be addressed early in the scoping process is what criteria and indicators will be used, and on what scale will the Assessment evaluate the sustainability of the Southern forest. Since the Assessment will likely be used by agencies and elected officials to develop policy and steer regulation, the results of the Assessment are of utmost importance to forest landowners and the forest industry. An accurate, non-biased assessment should provide us with information regarding what we know about our forests. But, just as importantly, clearly state what we don't know and not make subjective judgements when incomplete information does not allow accurate conclusions. The Assessment should strive to look at the long-term sustainability of the forest. The most important thing to come out of the study will be to reflect a precise picture of the actual conditions of the Southern Forest as it exists today and where it is headed. This is not to be a recommendation for policy changed or decisions about future forest use. It is imperative that the results of the assessment be placed into the hands of the forest owners. Only by providing this information to the people who own and manage the land can the assessment be used to impact the region in a positive manner. I also agree with your commitment that the final analysis deal with the analysis of data and not with recommendations for changes in policy and/or forest management practices. In regards to your preliminary assessment questions I believe it would be better to state them in an objective manner and not a subjective one. I think you can see what my concern is. The use of the word "likely" in all of the preliminary questions indicate that speculation or subjectivity must play a part in the answer. The only indication that we have of what may or may not happen in the future is what we know has happened in the past. If you want to compile and present the data as you say you do you will not speculate on what will be "likely" to happen in the future. An objective assessment of forest resources should be conducted immediately to determine the status of forest ecosystems and associated aquatic environments, forest health and productivity, and social/economic factors that are relevant to the practice of forestry in the Southeastern United States. The assessment will only be useful if it is scientifically based. The issue of forest resource sustainability will be a key factor in the assessment. Early in the process, the agencies will need to determine what criteria and indicators should be used to measure sustainability. I believe that your five part outline is unwieldy at best, and possibly more confusing than enlightening. For example, there are two categories--Forest Extent, Conditions, and Health, and Landscape/Terrestrial Ecosystems could better be rolled into one called Forest/Ecosystem Health. The purpose of your Assessment is to "describe, not prescribe". Nevertheless, decisions will be made. Lacking omniscience, our planning errors must be on the side of caution and conservation since, if our forest communities ARE endangered, there will be a point in time--as has happened in other geographic regions through history--at which there will be no real recovery. Mr. Greis, take a new direction for the Forest Service. Lets have unbiased study, not a hoax to satiate yet another corporation. Put the health and the future of the earth and humanity before next quarter's earnings. You started late. You spent too much time introducing the meeting. The facilitators did not explain clearly enough (nor did the two of you) that the break-outs were to clarify the questions, not to express opinions. You had a difficult job to do and I appreciate you doing it. Maybe if you have another series of meetings you could consider my comments above. No where did I read anything that said this process was about whether to permit chip mills. It should not be about specific issues of yes or no on individual projects. I am requesting that the state of Missouri be included in this study, as the Ozark forest can only benefit from the data collected regarding productivity, ecological diversity, and sustainability. It is my concern that if Missouri is the only state with chip mills that is being left out of the study, that future decisions regarding the Ozark forest, will be made on limited and possibly outdated information, the result of which could be harmful to the forest. If common sense tells us that richness in biological diversity is valuable and healthful, it is likely that system stability is also important. My concern is that, even though your handouts suggest that you want to include ecological considerations in the assessment, the individual group discussions as well as the comments provided by the speaker during the initial gathering indicated that the major mission would actually be to assess forests of the south for TIMBER resources. It appeared to me that all other considerations would be incidental to all timber-related concerns. Your initial presentation provided not one bit of concern about the serious decline in biodiversity of southern forests. Yet, quite a rosy picture was painted regarding current and future availability of timber. As what cost to declining biodiversity? The cumulative effects of acid rain/ozone depletion, urban sprawl, exotic species, habitat fragmentation, etc. is causing a general trend of forest decline here in our southern forests. Water treatment plants and air purification systems are costly and inefficient. Can we afford to continue to argue differences of opinions and effectively ignore these critical benefits during this assessment? We are concerned that a bias is already reflected in the apparent prominence of timber over the other products, uses and services. We would like to point out that the mention of certain important influences are noticeably absent from the document: chip mills, air pollution, and alternatives. Education and Science. How can the future of the forest be limited to a 10 year span as mentioned in the scope of this study? First and foremost, I recommend that the team identify and evaluate current threats to the sustainability of the south's diverse forest ecosystems. These threats may include, but not be limited to, certain kinds of forest management practices (e.g., practices that encourage fragmentation, result in unsustainable rates of timber harvest, significantly change species composition, result in water pollution, etc.) and conversion of forest stands into other uses. The GRN would recommends that each of the issues, questions or concerns identified by the agencies, the GRN, and other commentors be considered in the context of tree factors: productivity, ecological biodiversity, and sustainability. This will ensure that the report when produced is a truly thorough and comprehensive assessment of our southern forest resources. Based on the stated purpose of the study, we urge that the assessment explicitly evaluate the efficacy of current federal and state policies and practices in promoting ecological sustainability in southeastern forests. I understand the USFS has not solicited the involvement of state natural resource agencies. While the expertise of state forestry commissions is indeed critical to this assessment, the expertise of state natural resource agencies is equally important. State forestry agencies tend to focus on commodity-based timber production and do not have relevant expertise on ecological issues. It appears that the federal study is going to focus too much on economic and silvicultural impacts rather than on potential impacts to fish, wildlife, clean water, and other forest values. This seems likely since the study is relying on existing information, and southeastern forest schools and agencies have funded endless forestry and logging research. We urge that the study include economic projections for the export of wood fiber products from the Mississippi River region, and utilize specific information about how this would affect both the region and its ecosystems. We recommend that Missouri should be included in this study. Are you considering smaller areas? With the direction of the study being determined via public opinion, I feel I should voice my belief that the focus should be on preservation and conservation. I believe that it's critical that the agencies address the issues of clearcutting, habitat protection, water quality, chip mill permits, and preserving our forests for future generations. This is a huge study area with multiple, cummulative, additive, and synergistic degrading influences affecting the forested landscape and dependent ecosystems. This study has the potential to set precedent to assess a situation and provide information to rectify the situation before it reaches the emergency ward. Please take this task seriously, uphold the public trust, and do what is right. How will you be reporting the information? By state, ecoregion, watershed? [Study] Needs to be an integrated assessment. Don’t emphasize the Lower Mississippi alluvial plain so much when describing forested wetland loss: address it region-wide. Describe the effectiveness and impacts of South’s forest management practices and those of other regions (N.E., Great Lakes) Describe history of N.E., Lakes states and South with regard to regulations on forest management. Questions as revised in response to these comments Previous Question | Next Question Public Input Home | Methods | Assessment Home

  modified: 1-MAR-2000
  webmaster: John M. Pye