Executive Summary

Technical Review of the Daniel Boone National Forest Draft Plan and EIS

 

Kentucky/Tennessee Society of American Foresters DBNF Task Force

July 2003

 

Review Summary

This technical review of the Daniel Boone National Forest (DBNF) draft plan and EIS was compiled by the Kentucky/Tennessee Society of American Foresters Daniel Boone Task Force (task force) with the aid of associated natural resource professionals and scientists. The goal was to provide analysis of the draft EIS and Plan to determine if technical inconsistencies exist in the draft relative to the achievement of forest goals and to spotlight areas were clarifications are required to ensure that forest goals and prescriptions are clear and provide workable guides for management of the DBNF. A secondary goal was to provide analysis of the draft plan an EIS relative to the effect on forests and forestry in the region.

 

This executive summary was developed to provide information for those individuals or groups interested in sustainable management of the DBNF. This summary does not provide exhaustive detail on the technical evaluation of the draft. Rather it focuses on several key items that the task force believes must be addressed if the EIS and associated Plan are to provide a successful management platform for the DBNF.

 

General Issues

Review of the draft indicated several significant inconsistencies between forest objectives and prescriptions as well as several areas where clarifications and definitions are required to provide for effective management of the DBNF. Analysis of the draft also indicated that management strategies for the different Prescription Areas were not developed in a strategic manner.  The objectives and prescriptions for one Prescription Area was often found to be  inconsistent with planning for an adjacent Area or was developed in a manner inconsistent with overall forest objectives.

 

It is also important to note that the draft almost exclusively avoids directly stating harvesting actions or intents. This is counter productive to the clear understanding of the intent of forest goals, objectives, and prescriptions as outlined in the draft. Timber harvesting is a well recognized management tool and its proper use is supported by a wide range of environmental, academic, and professional organizations and associations. Further, timber production, the scheduled harvesting of timber, is a legitimate use of public forests. By minimizing the role of timber production and the use of timber harvesting as a legitimate management tool the DBNF may well avoid initial conflict but in the end hamper the ability of resource managers to properly manage for the desired conditions set forth in the draft. This strategy is counter to current accepted standards for ecosystem based sustainable forest management planning. SFI and Tree Farm clearly recognize timber production as a legitimate forest use. Even the globally recognized green certification system established by the Forest Stewardship Council deals directly with the scheduling of timber harvests and the growth of timber resources in a manner consistent with good forest stewardship and the maintenance of ecosystem values and attributes. It is strongly encouraged that the draft be amended to clearly show where timber harvesting can and should be used as a management tool and timber production as a legitimate objective for management.

 

Summary of Specific Issues  

The following is a summary of some of the significant areas of concern generated from the review. Details and recommendations are provided in the last section of this executive summary.

 

·       Issue 1. The “allowable sale quantity” is not sufficient to maintain the desired conditions established for the Habitat Diversity Emphasis Area. The Habitat Diversity Emphasis Area (HDEA) is the largest Prescription Area on the DBNF representing approximately one-half of the forest acreage (376,000 acres) and it is the only Area that provides for timber production. Technical analysis indicates that the “allowable sale quantity” provides for a rotation age of approximately 200 years. In 50 years over one-half of the HDEA will progress into age classes between 100 – 150+ years decreasing species diversity, forest health, and production capacity. Further, as these stands age the old-growth provisions (POGS and FOGS) in the draft will remove this acreage from timber production ultimately leaving the DBNF with no feasible alternative for managing for a diverse and healthy forest. Adjustment in the allowable sale quantity must be made to allow for the maintenance of a suitable age class distribution in the HDEA and the ultimate development of fully-stocked healthy stands with an average canopy tree age between 70 and 100 years. This is consistent with maintaining maximum tree diversity and health. Thinning schedules are provided for in the draft to maintain forest health and diversity. However, it should be noted that thinning many upland hardwood stands to maintain minimum full stocking is in many cases economically infeasible and more importantly will not maintain the long-term species diversity required in this Area (see detailed recommendation below).   

 

·       Issue 2: Clarification of Timber Harvesting and Timber Production Nomenclature. All Prescription Areas except the Habitat Diversity Emphasis Areas indicate that the Prescription Area is unsuitable or mostly unsuitable for timber production. Without further explanation most public and resource professionals would equate timber production with timber harvesting and assume that no harvesting is allowed in these Areas. However, timber harvesting is allowed and is needed as a management tool where is it is consistent with the objectives of the Area. Timber production is the scheduled harvesting of timber for sustainable timber growth and harvesting. There is a significant difference between the two. All Prescription Areas should include statements that indicate that timber harvesting is allowed where it is consistent with Area objectives (see detailed recommendation below).      

 

·       Issue 3. Cliffline and Riparian management standards should allow for the strategic and effective management of all of the Areas in the DBNF. It is widely understood that these Areas support (in some cases) unique and valuable communities and resources. However, the management standards set forth in the draft are static and unnecessarily restrictive (in some cases indefensible) to the point of making it technically difficult or impossible to successfully manage adjacent Prescription Areas and in some cases to maintain required attributes of the Cliffline and Riparian Areas. Cliffline and riparian standards should allow for the use of equipment in designated zones for the proper management of adjacent zones as well as maintaining cliffline and riparian attributes (see detailed recommendations below).  

 

Specific Issues Discussion and Recommendations

Several of the technical flaws associated with the draft from the apparent lack of strategic planning across or between Prescription Areas which are often in direct or close proximity to one another as well as prescriptions that, if followed, will not achieve the stated forest or area objective. Details of the issues previously outlined are discussed below. 

 

Issue 1. Inability to meet stated objectives of the Habitat Diversity Emphasis Area  This is the largest prescription area in the draft and the stated desired conditions require that a diversity of communities and their inherent biodiversity are maintained including mix mesophytic, upland oak (xeric and mesic) and yellow pine forests among other minor forest and vegetative types providing a variation in the density and kinds of trees, shrubs, and herbaceous plants in the Area.  The only possible mechanism to achieve this objective is to provide for an age class distribution allowing regeneration and perpetuation of the desired species and forest types. It is well known that allowing the forest types in question to age significantly will decrease overall species diversity and decrease the overall health and vigor of many species present and the forest as a whole. Maintenance of the proper age class distribution to achieve the objectives for this Area can only be achieved with a carefully designed timber production system providing for regenerating age classes using two-aged, even-aged, or group selection uneven-aged systems. It is technically not feasible to maintain the health and desired age class distributions with treatments such as thinning or fire. While timber production and regeneration treatments are consistent with this Area the “allowable sale quantity” for the forest is significantly below that necessary to maintain the desired conditions established for the HDEA. Age class and allowable sale quantity analysis indicates that within 30 years 45% of the HDEA (286,668 acres) will be over 100 years old and that in 50 years 54% (340,355 acres) will be 100 and 150+ years old. Research and expert based systems have found that many species on the DBNF that are required to be present in the main canopy of these forests do not have the longevity necessary to sustain themselves for this period of time. Secondly, the old growth provisions in the draft indicate that as stands age above 100 years they be considered for old growth designation, essentially taking them out of the HDEA and providing management only through benign neglect. The risk to forest health is significant and must be addressed. 

 

Issue 1. Recommendation: To address this inconsistency, the “allowable sale quantity” must be increased to provide the proper age class distribution in the Habitat Diversity Emphasis Area. Secondly, potential old growth and old growth stands must be maintained by designating old-growth management on the allotted 16,700 acres and strategically positioning these old-growth stands adjacent to areas where old-growth is currently developing such as the wilderness areas. This provides for large blocks of relatively undisturbed forest where edge is minimized and old growth attributes will be easier to develop and maintain.

 

Issue 2: Clarification of the use of timber harvesting and timber production  There is a significant and potentially debilitating nomenclature problem associated with the use of the terms “timber production” and “timber harvesting.” In all areas except the Habitat Diversity Emphasis Area it is stated that “The Prescription Area is unsuitable (or mostly unsuitable) for timber production”. The review indicated that the correct meaning of this phrase was not understood by many practitioners or the public which lead to a misunderstanding of the intent of the statement and thus a significant understanding of management techniques that are allowed and could be prescribed in these Areas. Most individuals, including natural resource professionals, believed that this statement indicated that these Areas were unsuitable for timber harvesting. It is fully understood that timber harvesting is allowed in these areas when consistent with objectives of the Areas. Timber production means the scheduled harvesting of timber to provide for a relatively constant supply of timber resources, which is significantly different than providing habitat manipulation using a timber harvest.

 

Issue 2. Recommendation: Provide the following statement in all Prescription Areas except the Habitat Diversity Emphasis Area: “The Prescription Area is unsuitable for timber production. Timber harvesting is suitable for use in the Prescription Area to achieve desired Forest and Area objectives.”   

 

 

Issue 3:  Cliffline and Riparian Areas Current scientific evidence indicates that protections for riparian zones and clifflines should consider the nature and needs of each stream type and cliffline environment and provide protection zones accordingly. The prescription used on clifflines is static and is the same for both mesic and xeric clifflines even thought management needs are significantly different. While the argument can be made that overprotecting these areas is rational from the standpoint of the cliffline community these communities and this Prescription Area does not exist in a vacuum. To the contrary, the inherent linear and narrow nature of Cliffline Areas means that they are directly adjacent and surrounded by other Prescription Areas and the needs of these Areas must be considered in an effective forest plan. 

 

Prescriptions preclude the use of the heavy equipment within 100 feet a cliffline. This effectively precludes the use of skyline cable harvesting methods in tracts where clifflines exist around their ridges. The cable yarder must be placed within 20 to 30 feet of the cliff edge and the standards prescribed for clifflines precludes the proper and feasible use of this technology. It is well known that skyline cable yarding is the most environmentally sound method, outside of helicopters, for timber extraction. The DBNF has historically been the leader in skyline cable use in the region. The draft cliffline standards preclude cable sets next to the cliffline thus precluding the use of these systems to harvest timber in subtending Habitat Diversity Emphasis Areas.  Instead ground skidding operations, with there inherent need for skid trails and roads, will have to be used and will lead to greater environmental degradation that would occur if skyline cable yarding was used. Restricted heavy equipment use (as defined by one cable set per 300 ft cliffline and their associated skid trails) in the Cliffline Area will allow for the use of skyline cable yarding of adjacent Areas and according to review by biologist dealing with cliffline communities and their biota will not will not significantly degrade cliffline communities. This modification of the Cliffline Area provides for strategic management of adjacent Prescription Areas.

 

Riparian management and buffer zone distances are known to be variable depending on water quality, aquatic populations and habitats, and surrounding topography and drainage characteristics. The current standards provided in the draft for riparian areas in effect call for benign neglect management within 100 feet of perennial streams and 50 feet for intermittent streams regardless of quality of water, aquatic habitats and nature of the riparian areas. This is not scientifically defensible for the majority of the streams in the physiographic regions encompassed by the DBNF leading to decrease in the ability to effectively manage these Areas as well as adjacent Prescription Areas.   The elimination of equipment use in the Riparian Area causes problems with the proper harvesting of timber and management in adjacent Habitat Diversity Emphasis Areas. To strategically manage the entire Forest provisions in the management of Riparian Areas must be made to allow for designated equipment operations of the size and scope that will not create undue stress on the riparian and aquatic communities while allowing for the proper management of adjacent Areas.  

 

Issue 3. Recommendations:

1. Evaluation of cliffline communities and riparian zones are conducted and evaluations used to set appropriate Area widths and distances allowing for variable distance setbacks based on the actual needs of the cliffline communities and the riparian and associated aquatic habitats and populations.

2. Cliffline Vegetation Management Standards 1.C-Veg-2. should read: “Restrict heavy equipment to designated areas to allow for the extraction of timber in adjacent Prescription Areas. Where timber harvesting is conducted in the Cliffline Area heavy equipment use is restricted to designated locations and end lining used to extract timber from the cliff edge.”          

3. Riparian Vegetation 1.E-Veg-1 should read: “Cable logging corridors, cable sets, and tail trees/equipment for cable logging may be placed at designation locations in the riparian zones. Roads, skid trails, and cable corridors may pass through the Riparian Area at designated points to facilitate the management of adjacent Prescription Areas or for the management of the Riparian Area.”