General Data Comments

1. Exclusive reliance on outdated FIA inventory analysis is inappropriate. We urge you to supplement FIA data with the use of satellite imagery, GIS mapping and other advanced forms of spatial analysis.
2. Aerial photographs are available through the US Department of Agriculture for all 13 states in the Southeast region. These photographs can be used to document forest changes over time and should be used in any small area assessment as they can provide more detail on a smaller scale than satellite imagery.
3. This assessment would incorporate information founded on peer reviewed, scientific study. We fully support this approach and suggest this issue be emphasized throughout the process and in any final documents.
4. It is extremely important that all data be collected in a scientific manner, and that it be peer reviewed by professionals from the pertinent field of study.
5. If the study arrives at conclusions regarding sustainability, all sources of data and assumptions used to determine sustainability should be clearly documented.
6. Your studies are so important and need to be as unbiased as possible and solutions be as creative and innovative as possible.
7. We encourage the USDA Forest Service to draw upon the expertise of related agencies, (EPA, USFW, and State natural resource agencies), mentioned in the preliminary USFS SE Assessment materials, to the greatest extent possible. Like the NC Chip Mill study mandated by Gov. James Hunt, the utilization of knowledge across agencies, disciplines, and fields can be invaluable to the validity of a study's end result.
8. The agencies should at least meet--and, preferably, exceed--the analytical standards established by recent, similar studies in other regions.
9. While it may be anticipated that no data or limited data will be available to answer many questions "regarding the forest ecosystem's status, diversity and sustainability," I am concerned that the focus will be on the rudimentary data that are available, and users of the document will try to base management decisions on those facts.
10. At our meeting at Emory University, there was a great deal of interest in Geographic Information Systems (GIS), and how GIS can be used in the currently proposed study. As powerful as the GIS tool is, it cannot overcome a fundamental lack of data on biodiversity, ecosystem functioning, and what it takes to make a forest sustainable in the broad sense of the word.
11. What data are needed to evaluate ecosystems as to sustainability? What of these data are available presently? How can these data be collected and evaluated in the future?
12. Scientific literature should provide the foundation for information reported in the Assessment. Subject to peer review source of all information, including use of anecdotal information and opinions, should be clearly referenced.
13. FIA information in the South is the best information available, but is outdated in some states and of somewhat limited usefulness in drawing conclusions about the "sustainability" of the forest resource. Assessment should clearly explain the objectives and limitations of the FIA program and the currently available information. It should also clearly outline the sources of other resource information and their completeness or limitations for assessing "sustainability."
14. Richard A. Harper, R.F., Clemson Extension Forester, Forest Resource Analyst, would like to reiterate my interest to assist the Southern Forest Resource Assessment team in this study. I am willing to be a point of contact to coordinate a literature review of existing research. There is no need to "reinvent the wheel" when the southern universities should have volumes of appropriate research from which to start the study. Dr. David Van Lear (Forest Resources) has an excellent presentation of how historical disturbances have shaped the forest ecology throughout the Southeast. It begins about 18,000 years back in time and demonstrates how anthropogenic and natural disturbances shaped vegetative patterns and processes. It also shows how many silvicultural practices are designed to mimic there natural processes.
15. Our membership believes that a scientifically based forest assessment is in order, because it will provide objective and credible information.
16. Scientific literature should provide the foundation for information reported in the Assessment. Such studies and papers, whether from the public or private sector, should be subject to peer review by professionally qualified experts prior to being accepted and included in the Southern Assessment. The source of all information, including use of anecdotal information and opinions, should be clearly referenced.
17. A & PA supports a number of programs and initiatives that have developed detailed information about the status of the South's forest resources. This information can be very valuable to the U.S. Forest Service as it initiates its assessment of the sustainability of the Southern forests.
18. Scientific literature should provide the foundation for information reported in the Assessment. Such studies and paper, whether from the public or private sector, should be subject to peer review by professionally qualified experts prior to being accepted and included in the Southern Assessment. The source of all information including use of anecdotal information and opinions, should be clearly referenced.
19. In order to achieve the best Assessment possible, we strongly encourage you to utilize only the best scientific, up-to-date and peer reviewed information available. Anecdotal evidence or assumed cause-and-affect conclusions related to forest management and harvesting should be avoided.
20. It is my hope that you as leaders in this assessment will filter out all biased and misleading information that will be attempted to be a part of the record.
21. Your commitment to data contained in scientifically peer reviewed studies is commendable. I am sure that a bibliography of the sources used will accompany any reports, both preliminary and final, that are released to the public.
22. 8 of the 10 subparts are being conducted by the NC State School of Forestry which is funded by the timber industry! This is not a neutral school which advocates increased intensive forest management (clearcuts). How can he be objective?
23. I understand that you will accept data from almost anywhere. It is VERY important that you use credible science and peer review. How will you be doing the peer review?
24. I think that the over-arching need that can best be addressed by this study is the need for a usable map, physical and digital, that show what the forest resource is, what factors are adding to the resource base and what factors are contributing to removal. Whatever basemap is used, this map should be coordinated with the USGS Hydrologic Unit Code (HUC) maps and each state's unified watershed assessment maps. The Lower Mississippi Joint Venture Office in Vicksburg, MS, has mapped and evaluated all of the forested tracts in the lower Mississippi Aluvial Valley. (Charles K Baxter, 2524 Frontage Rd, Suite C, Vicksburg, MS, 39180, 601-629-6604)
25. I hope that journals such as Conservation Biology will be consulted and that you will decrease or eliminate your apparent reliance on unpublished, biased 'grey' literature (i.e., literature that is not subjected to scientific scrutiny and usually self-generated). A way to rectify the scientific credibility of your assessment would be to intimately include scientists who are knowledgeable about southern terrestrial and aquatic ecosystems; conservation organizations such as the Sierra Club; and National Forest watchdog groups such as the Dogwood Alliance or Heartwood. I hope that your efforts to assess southern forests will broaden beyond the needs of the timber industry. If so, your document might be the one that could carry us through to a future that includes healthy, diverse southern forests.
26. Quality of live and the future of our children depend on sound science and a greater understanding of natural processes of forestland and watershed ecosystems. Don't our grandchildren's children deserve equal if not better opportunities then we had?
27. What are the inventory and monitoring studies that need to be conducted throughout our southern forests? What high school and/or college programs could be employed to assist in the gathering of this data? How many dollars could be saved by combined funding through education and research programs?
28. The study should utilize GIS and other visual information about the present state of southeastern landscapes from the US Geological Survey, the Nature Conservancy, and other public agencies and private entities.
29. The information being generated by the Watershed Assessments being undertaken by states as part o the Clean Water Action Plan should be incorporated into the study, yet the adequacy and completeness of this information will vary across states. How will the study account for any "holes" in information resulting from incomplete or unavailable state assessments?
30. The study team should maximize the use of existing reports and data and identify data gaps up front.
31. We hope that the agencies utilize the full range of information available from public and private sources to present a comprehensive picture of the current status of southern forests and projections of their future.
32. The method for arriving at figures must be clearly stated. If information about some issues that the study seeks to examine remains unavailable or cannot be verified, that must be clearly states. Sources of information and methods for obtaining information cannot be considered proprietary if the study is achieve validity.
33. Utilize All Sources of Information: Maps and satellite images should be obtained from federal agencies such as the US Geological Survey, National Oceanic and Atmospheric Administration, and Forest Service, as well as state agencies, state and federal GIS projects, private organizations such as the Nature Conservancy, the timber industry, universities, and private-public efforts such as the Mississippi River Joint Venture. Industry projections for future demand, sourcing areas, export figures, etc., should be utilized, as well as projections for global demand being done by agencies such as the UN Food and Agriculture Administration. Information being collected by the Unified Watershed Assessments being carried out by state and federal agencies, along with state and federal information about endangered species, should also be incorporated.
34. On site research should be used whenever possible rather than computer modeling and new data should be collected if existing data is more than a few years old.
35. How far can you go back to get wildlife statistics?
36. Where will data from this assessment be stored? Will it be available to others? Will data manipulation by others be possible?
37. Will IUCN data be used? Some say it shows that the U.S. has a ``bad record'' relative to effects of human activities on wildlife (or is it really that the U.S. just has better data than most countries?).
38. How to measure quality? How current is the data? Is it biased for a certain conclusion?
39. Concerned about bad data, not recent enough, bad sources.
40. Need to use 303(d) listed GIS data for analysis.
41. Need to use existing water quality data to ``rate'' watersheds and water quality based on land use; use 303(d) lists of impaired waterways.
42. How will you solve differences in data between states - related to how data is collected and analyzed?
43. Will you make recommendations for data sharing and consistency?
44. Who makes the determination on the use of data? Can you use multiple sources?
45. Need to use historical data on forest impacts to water quality, even back to pre-settlement.
46. Study should identify future research/data needs based on the limited scope and budget available. Can the schedule be extended?
47. Consult with TVA and GSMNP for excellent data sources.
48. Is there data supporting any historical problems in water quality?
49. The core of this [study] will be based on data gathered from aerial photos and images--leads to inaccuracies.
50. No fully forested watersheds in the south.

Landscape/Terrestrial Ecosystems

1. See "American Forests: A History of Resiliency and Recovery" by Douglas McCleery, US Forest Service.
2. Information on the distribution of different plant and animal communities and ecosystem types within our National Forests system is building but primitive. Almost nothing, however, is known about private forests which dominate the total forest acreage in the southeast. Studies should be initiated over the next few years to begin to gather these data, but there certainly are no data today on which to base decisions concerning sustainability in the broad, meaningful sense of the word. Although we have a rich base of aerial photographs, topographic maps, and satellite images for the region, only limited uses of these data have been validated by data collection in the field. Indeed, it has not even been demonstrated that the age and species composition of trees can be assessed from these sources. If we cannot assess the acreage of various age-classes and species of trees over the large landscape with any reasonable validity, how then can we survey the herbaceous plants and animal life and attributes of the physical environment, not to mention the complex processes that make up ecosystems? GIS will be a tool sometime in the future to help us evaluate forest sustainability, but we have not earnestly begun to collect the data to use as input. I think some will say that we CAN evaluate forest age and species composition from available aerial photographs and satellite imagery, but I challenge them to produce real scientific evidence of this. Indeed, I would like to see funding placed in the area of validating the use of remote sensing for such purposes.
3. Enclosed is a copy of the draft entitled "Do We Clearcut to Manage Deer Habitat?". "Do Appalachian Herbaceous Understories ever Recover from Clearcutting?" by Duffy and Meier; "Are We Really Managing Deer Populations?" by A., Sydney Johnson and et.; and "Timber and Wildlife Implications of Fire on Young Upland Hardwoods" by Huntley and McGee. Recent work by Van Lear hopes to restore oaks on mesic sites by using so much fire changed them to xeric. It makes better sense to let oaks grow on xeric sites instead of forcing them to be pine stands. McGee says that oaks will dominate on a lot of intermediate and lower quality sites if given the chance. Van Lear's conclusions are quite speculative.
4. The wildlife impacts analysis relies solely on computer modeling, and NOT on site specific field research.
5. Dickson et.al, Silviculture in Central and Southeastern Oak-Pine Forests, from Ecology and Management of Neotropical Migratory Birds, Franzreb and Phillips, Neotropical Migratory Birds of the Southern Appalachians, USFS Southern Research Station, General Technical Report SE-96, 1996. Petranka et al, 1993, "Effects of Timber Harvesting on Southern Appalachian Salamanders."
6. Experiments by Stuart Pimm and Mac Post at the U of Tennessee in 1985 measured the success of alien species invading an existing community and the effects on the community. Success was easy in species-poor communities and difficult in species-rich communities.
7. The 1997 World Conservation Union-IUCN Red List of Threatened Plants for its relevant US botanical data.
8. Consideration should be given to historical levels of biodiversity identified within southeastern states by the World Wildlife Fund in A Conservation Assessment of the Freshwater Ecoregions of North America, conservation Science Program (World Wildlife Fund, to be published December 1999 by Island Press).
9. How far can you go back to get wildlife statistics?
10. Developing a usable, consistant, 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 dove-tail 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.
11. Where will data from this assessment be stored? Will it be available to others? Will data manipulation by others be possible?
12. Will IUCN data be used? Some say it shows that the U.S. has a ``bad record'' relative to effects of human activities on wildlife (or is it really that the U.S. just has better data than most countries?).
13. Examine data concerning particular species that are dependent on a narrow range of habitat to see what effect changes have occurred. Breeding bird surveys and forest stand data.
14. The data on assessing plant and animal populations are too abstract. Are they reliable? Be aware that a lot of data are missing in the Forest Service database relative to ``old growth'' due to the historic lack of interest in this age class by the FS.

Social and Economic Factors

1. The economic analysis must not rely exclusively on the IMPLAN model. The USDA Forest Service, utilizing the IMPLAN model, forecasted a loss of over 15,000 jobs in the Pacific Northwest if Spotted Owl habitat were protected. Instead, total employment in the owl region rose 27 percent.
2. The following studies should be incorporated into the economic analysis: Neimi and Whitelaw, Assessing Economic Tradeoffs in Forest Management, USDA Forest Service, Pacific Northwest Research Station, General Technical Report PNW-GTR-403 (August 1997). Overdevest and Green, Forest Dependence and Community Well Being: A Segmented Market Approach, (USDA Forest Service, Southeast Forest Experiment Station, 320 Green Street, Athens, GA 30602) Society of Natural Resources Vol. 8 P 111-131 (1994).
3. Courant, P. N., E. Niemi, and E.Whitelaw. (1997). The Ecosystem-Economy Relationship: Insights from Six Forested LTER sites. Report to the National Science Foundation. Eugene, OR: ECONorthwest. Describes similarities and dissimilarities in the forest-economy relationship in six regions of the U.S., including the Southern Appalachian Highlands.
4. Haynes, R.W. and A.L. Horne (1997). Chapter 6: Economic Assessment of the Basin. An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins, Volume IV. T.M. Quigley and S.J Arbelbide (editors). Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. June. General Technical Report PNw-gtr-405.: 1715-1869. The most comprehensive analysis ever produced by the Forest Service of the modern economic consequences of forest management.
5. Holmes, S. and Sustein, C.R. (1999). The Cost of Rights. New York, Norton & Company. A comprehensive discussion of the costs society bears to enforce property and other rights, and an exploration of the interaction between property-owners' rights and their obligations.
6. Niemi, E. et. al. (1999). The Sky Did NOT Fall: The Pacific Northwest's Response to Logging Reductions. Eugene, OR: ECONorthwest. Explains how nearly all communities adjusted quickly and smoothly.
7. Neimi, E. et. al. (forthcoming). Salmon, Timber, and the Economy: The Potential Economic Consequences of Restricting Logging to Save Oregon's Salmon. Eugene, OR: ECONorthwest. Detailed treatment of the six questions, in the Pacific Northwest.
8. Power, T.M. (1996). Lost Landscapes and Failed Economies: The Search for a Value of Place. Washington, D.C.: Island Press. A thorough discussion of how changes in the economy have diminished the importance of resource extraction.
9. Power, T.M. et. al. (1995). Economic Well-Being and Environmental Protection in the Pacific Northwest. Missoula, MT: Economics Department, University of Montana. A statement by more than 60 economists of how protecting and enhancing environmental quality in the Pacific Northwest enhances the regions' economic well-being.
10. Currently available scientific data is at variance with your statements that urban areas are stable in size. What about the grave problem of urban sprawl? What about the loss of prime agricultural land to urbanization?

Timber Markets and Forest Management

1. It is not demands we should talk about but needs. There are a lot of alternatives to wood use. This study and others conducted in the past have not talked about alternatives to wood use. Kanaf, hemp, cotton, steel, straw bale houses, earth and tire houses, reduced junk mail, reuse of hardwood pallets, plastic pallets and substitutions, bamboo, flax, salvaging wood from landfills, using more efficient milling equipment, recycling paper, bagasse, bananas, and many other alternatives can reduce wood use. Why does this study not look at wood alternatives?
2. Encourage alternatives to the use of hardwood chips for the production of paper.
3. If an alternate fiber could be used to replace wood that was more economical industry will change to use it. After all, we are capitalist and want to increase the bottom line.
4. Substitute products can be produced efficiently, creating as many jobs, if not more, than those lost by a decline in logging and wood-processing. Just because we have obtained paper and two-by-fours from a forest in the past, it does not mean we should do so in the future.
5. Serious investigation of alternative crops for paper pulp, such as kenaf and hemp, could potentially benefit forest habitat conservation.
6. Could demand for timber be offset through the increased use of recycled materials, agricultural wastes and fiber crops such as kenaf?
7. We need to start reducing our wasteful use of wood and paper products ad start using alternative fibers to relieve the demand on our forests. And we need to start using alternative sources of energy instead of fossil fuels to significantly reduce the effects of acid rain and ozone depletion.
8. Study Promotional/educational efforts currently undertaken (by whom/extent/resources) to lessen consumption of wood products, especially paper, and practice and promotion of paper recycling by government agencies at all levels.
9. What disincentives to paper recycling (and corollary loss of jobs in recycling economy/faster landfill loss from paper disposal) arise from industrial forestry for chip/pulp use, and chip/pulp exports?
10. Impacts of alternatives to timber such as the use of recycled materials, agricultural residues and crops, such as kenaf and industrial hemp. This analysis should include consideration of the environmental impacts, both positive and negative, and economic viability of these alternatives.

Forest Extent, Conditions, and Health Data

1. As you said, the study must be science-based, but you must realize that current data may not be sufficient, if it has been gathered under errant guidelines. For example, in your presentation, you said that 70 million acres of upland pine habitat once covered the Southeast. The figure used most commonly, by scientists like Dr. Reed Noss of the National Biological Survey, is 93 million. Declining from 70 to 30 million looks a lot better than declining from 93 to 3. Dr. Noss calls this a "critically endangered ecosystem," 99 percent reduced. I would ask you to be fair and impartial in your use of current statistics, and carefully weigh the source of your data. When you solicit peer review, I hope you will do so from biologists across the entire spectrum of forestry -- including those that embrace ecology as well as those that would turn their heads on the alarming loss of biodiversity evidenced around us here at the turn of the millennium. If the public could have a hand in deciding peer reviewers, I would be in favor of and eager to do so.
2. Some long term studies have been conducted that address commercial logging to a limited degree (e.g., the Hubbard Brook experiments of Bormann and Likens), but future studies need to investigate impacts on invertebrate and vertebrate communities, and not just the flora and physical components of the ecosystem.
3. The Assessment should explain the objectives of the Forest Inventory Analysis. Other sources of information and their completeness or limitation should also be outlined.
4. FIA information in the South is the best information available, but is outdated in some states and of somewhat limited usefulness in drawing conclusions about the "sustainability" of the forest resource. Systematic, south-wide information on other resources including wildlife, biodiversity, water quality, and forest health is even more variable and may prove to be unreliable in drawing conclusions over large areas. Assessment should clearly explain the objectives and limitations of the FIA program and the currently available information. It should also clearly outline the sources of other resource information and their completeness or limitations for assessing "sustainability."
5. Information gathered in determining the present state of the Southern Forests is the most critical part of developing an accurate assessment. All sources of data should be documented and made available to the public. Even the best available data may be outdated and other sources for information may be unreliable for such a vast geographical area. The varying information submitted or gathered can be as diverse as the regions of the South and can lead to a distorted assessment if not interpreted accurately. It is for these reasons that accurate science has to be the measure for determining the conditions and health of the forests of the South.
6. Forest health is the "sine qua non" -- without a healthy forest, the rest of it fades into insignificance. For better answers to the above questions, I strongly urge your Research Group to contact all biologists in this area of study and ask for more direct testimony and research.
7. There will not be any field research analyzing the impact of clearcuts and pine conversions on the diversity of microorganisms in the soil.
8. My concern about the integrity of your mission began shortly after the speaker began to relate what he apparently viewed as "facts" about southern forest resources. You were apparently using "data" that was generated by entities concerned solely with timber production and that had not been published in peer-reviewed scientific journals. Your "data" regarding the relative amounts of hardwood growth versus removal are questionable. Your "data" must surely relate to early successional growth because the current scientific literature shows repeatedly that hardwood forest are in decline not increasing as you stated.
9. What is the impact to the soil and its components, such as the microrisal fungi, of the sun/temperature change on clearcut land?
10. The 1992 Southern Appalachian Assessment for its recency, its emphasis on forest management and involvement by the same major agencies.
11. A number of private organizations, such as the Nature Conservancy, and public-private partnerships, such as the Mississippi River Joint Venture, have mapped forested areas along the river corridor, and we urge you to incorporate this information into your study.
12. No comments on data needs recorded from public meetings for Forest Extent, Forest Conditions or Forest Health.

Watersheds, Aquatic/Riparian Ecosystems, and Forested Wetlands

1. Stream-side management zones width in Louisiana is not required. Many landowners cut timber on stream banks.
2. Is it possible to produce a coordinated, consistent map (physical & digital) of watersheds in the South?
3. I was also interested to see that a map created by the Nature Conservancy (TNC) was shown to illustrate at risk fish and mussel species. Are you aware that USDA Forest Service research scientists (at the Oxford, MS, Hydrology Lab) have maps that are much more detailed and specifically for the southern United States? Unfortunately, your presentation revealed that the initial basis for the assessment is unscientifically based data.
4. Information about the cumulative loss of forested wetlands to development in Louisiana should be obtained from the US Army Corps of Engineers and the state Department of Natural Resources.
5. The state Department of Environmental Quality has been charged with carrying out assessments of the health of Louisiana's watershed, and we hope that the information from these assessments is incorporated into your study.
6. Hunt, Constance, Quinn McKew & Alice Taylor, eds., A Conservation Potential Assessment of the Mobile and Tennessee/Cumberland River Basins in Alabama, Georgia and Tennessee (WWF 1999)(working draft presented at the State of the Rivers Conference, Chattanooga, Tennessee, March 14, 1999.)
7. Need to use existing water quality data to ``rate'' watersheds and water quality based on land use; use 303(d) lists of impaired waterways.
8. Will/Can a map be developed that coordinates data and is consistant across watershed and forest? Will water quality ne approached as point source and non-point source? Will wetlands mitigation impact forests? Does BMP directly reduce non-point source pollution? Can it be verifified?
9. How will you solve differences in data between states - related to how data is collected and analyzed?
10. Will you make recommendations for data sharing and consistency?
11. Who makes the determination on the use of data? Can you use multiple sources?
12. Need to use historical data on forest impacts to water quality, even back to pre-settlement.
13. Study should identify future research/data needs based on the limited scope and budget available. Can the schedule be extended?
14. Consult with TVA and GSMNP for excellent data sources.
15. Is there data supporting any historical problems in water quality?
16. The core of this [study] will be based on data gathered from aerial photos and images--leads to inaccuracies.