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

Sub-Regional Focus Areas Any small area assessment should emphasize site specific research and de-emphasize broad sweeping generalizations. The purpose of the small area assessment should be to document the impacts of the current demands on the forests, watersheds, communities and local economies within a given area. With this in mind, each small area assessment should: 1) include a strong field research component; 2) emphasize the collection of site specific data relevant to the area; 3) involve experts with the relevant knowledge and background for addressing specific questions; 4) involve periodic fly-overs of the area for mapping and gathering data about current land use patterns; 5) involve strong collaboration between any scientists conducting the assessment and the federal agencies and 6) develop a framework for continued monitoring after the study is complete. The geographic scope and locations small area should be focused on areas where forest sustainability is of particular concern. 1) Do the area's forests supply wood to a number of chip mill, pulp mill and/or chip board facilities; and, for contrast, are there areas where demands for forest extraction is relatively low? Are there new mills under construction in or near the area that would increase the demand on the forests? 2) Is the area large enough to ensure that the USFS FIA data is statistically significant? 3) Do the FIA data for the area demonstrate that removals exceed growth or that there is a decreasing growth-to-removal ratio? or are there counties within the area where pulpwood extraction is relatively high? 4) Do planted pine plantations constitute 25% or more of the forests within the area? 5) Is there existing relevant data already collected within the area that could be useful? 6) Are there competing economic demands for the forest resources within the area? Are there outstanding recreation opportunities within the area? 7) Is the Best Management Practices compliance rate relatively low? 8) Are there known locations of federal or state listed threatened and endangered species? 9) Are there areas chosen representative of geographic and topographic diversity? There is some discussion of allocating federal resources to North Carolina to conduct a small area assessment. The North Carolina study of the ecological and economic impacts of chip mills, is limited to a broad, generalized study of the impacts of chip mills across the state. Proposals: The Upper Yadkin River Basin in North Carolina would be an appropriate place to initiate a small area assessment. The Upper Yadkin covers a broad enough area to ensure the accuracy and statistical significance of FIA date. Potential locations for small area assessments include: forests surrounding the Tenn-Tombigbee Waterway, bottomland hardwood forests in Louisiana and/or Mississippi, forests in southern Arkansas, intensively managed pine plantations along the coastal plains of Georgia and/or South Carolina and the Upstate area of South Carolina. While we fully support the small-area assessments' importance to the Forest Sustainability Assessment as a whole, we feel that two years is not a sufficient time-frame. Please be aware that the public recognizes that this is not enough time to gather accurate empirical data, and that citizens deem this small-area assessment critical. In addition, HA proposes the NW Piedmont, North Carolina as an excellent choice. Criteria for site selection (monitoring) should include: statistically based general monitoring, Hot spot/specific species monitoring, adaptive management sites--monitoring before, during and after management implementation. Criteria for selecting which species to monitor: threatened and endangered species, keystone species, abundant and easily sampled species, indicator species. Assessment should explicitly address how it will define and assess sustainability across the Southern regional landscape, as well as on sub-regional levels. Outline clear criteria for selecting sub-regions for analysis and describe how sustainable forestry will be defined and assessed. These criteria should be open to public input and review prior to initiating the sub-regional assessments. We also support the idea of including "Smaller Area Assessments" within the study. Preliminary data suggest that some parts of our region are being harder hit by the increased timber activities than others and the study needs to focus on one or more of these areas, perhaps at a watershed level. Specific sub-regions should be well defined in all thirteen Southern states. A concern that I do have is the attempt to make any sort of smaller area assessment unless there Is adequate data available. In the absence of adequate data it would be prudent to indicate where further study is needed rather then to present an analysis based on insufficient data. Forest resources may be shifting from place to place at the local level while they increase or remain fairly constant at the regional level. Change at the local level is inevitable, and it should not be a major focus of the assessment. Landowners are particularly concerned about how sub-regional assessments will be selected and conducted. The agencies should outline clear criteria for selecting sub-regions for analysis and describe how sustainable forestry will be defined and assessed. These criteria should be open to public input and review prior to initiating the sub-regional assessment. The use of small area assessments is critical to substantiate the need for site-specific information about the intensive clearcutting and conversions to pine plantations that we are seeing throughout North Carolina and the Southeast. We are encouraging you to consider North Carolina. Careful selection of smaller study areas and associated data collection and analysis can assure that some of these critical information gaps are filled, and help assure that data on regional and state-wide trends do not obscure what may be happening in particular watersheds or localities. We are also concerned about the adequacy of the small area studies. Obviously, many areas need to be examined to determine the scope and scale of regional impacts on forests. …small areas studied more intensely using site specific research will provide valuable documentation of the consequences of high sustained demand or increasing demand on forest resources. Watersheds, flora and fauna, and economies. In order for a Small Area Assessment site chosen should be: diverse biologically and geographically; contain several centers of manufacturing as well as areas that supply raw forest products to several mills; have areas of population growth as well as stable rural areas; contain diverse forest types both native and planted, and contain protected (public) and unprotected (private) forests; an area that has recent water quality data; large enough so that any data collected is reliable and significance can be achieved but small enough to make the SAE affordable and manageable. Save Southern Forests: These Forests provide clean drinking water, protect habitat for hunting and fishing, and improve the quality of life for families throughout the South. Corporations must not build any new chip mills until we have more information about their impact on forests and have adequate safeguards in place for the forests. Because the growth and proliferation of chip mills has been the driving force behind the public outcry, it is absolutely essential that the study explicitly address impacts of chip mills on ecological sustainability. Further because concerns over increased clearcutting of native forests and conversion to plantations are on the rise because of other industrial forestry pressures on southern forests besides chip mills (strictly defined), the assessment must also address expansion of current pulp and paper facilities, construction of new oriented strand board mills and increases in forest products industry capacity such as medium density fiberboard plants which are degrading southeastern forest ecosystems. Specifically, the study will be incomplete if it does not address how these pressures are impacting the resources over which federal and state agencies have mandatory or discretionary authority or over which they have influence. Landowners are particularly concerned about how sub-regional assessments will be selected and conducted. The agencies should outline clear criteria for selecting sub-regions for analysis and describe how sustainable forestry will be defined and assessed. These criteria should be open to public input and review prior to initiating the sub-regional assessments. Chip mills are an irresponsible solution to satisfy a hungry paper industry. The multiple agency study should expend some effort studying site-specific effects as for example, a single watershed or a single sourcing area or the long range economic impact on a single community. The chip mill infested corridor along the Tenn-Tom waterway must be included as a case study in this larger study. That chip mill infested area, along with the existing pulp and paper industries overlapping sourcing areas is an indicator of what is occurring throughout the study area. 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