KENTUCKY – TENNESSEE

SOCIETY OF AMERICAN FORESTERS

602 Hawthorne Drive

Maryville, TN   37803

 

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

August 13, 2003

 

Review Summary

This technical review of the Daniel Boone National Forest (DBNF) Draft Plan and Environmental Impact Statement (referred to as the draft) 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 to:

·         determine if technical inconsistencies exist in the draft relative to the achievement of forest goals

·         spotlight areas were clarifications are required to ensure that forest goals and prescriptions are clear and provide workable guides for management of the DBNF

·         determine the impact of implementation of the draft to forests of the region and the ability of those forests to effectively provide resources for the communities surrounded by and close proximity to the DBNF

The review does not provide a detailed evaluation of all aspects 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.

 

The task force fully realizes that development of a comprehensive forest plan for the DBNF is an extremely difficult undertaking and that the topographic and biological diversity of the DBNF well as the diversity of the users of the DBNF make it difficult to provide an effective and efficient plan that caters to all situations and users. We further recognize that the DBNF staff and particularly the planning team developed the draft to respond to regional issues and mandates and concerns voiced by citizenry while protecting and enhancing ecosystem integrity. The task force recognizes the enormity and complexity of the planning process and appreciates the work of the DBNF staff to develop the draft to this point. The issues outlined below are provided to aid the DBNF staff in developing a final draft of the plan that is operationally effective and provides a sound management platform allowing for efficient, sustainable, and ecologically sound management of the DBNF encompassing the biological complexity of the regions forests and the societal concerns of regional communities. 

 

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 decreasing the ability to effectively and strategically manage the forest as a whole for all of the attributes stated in the draft. The objectives and prescriptions for one Prescription Area were often found to be inconsistent with planning for an adjacent Area or were developed in a manner inconsistent with overall forest objectives.

 

The review also indicated that draft did not contain sufficient prescriptions for the maintenance of forest health and for the sustainable management of timber resources. Regarding the latter, it is understood that the premise of the plan is to provide for sound ecosystem management with timber as only one of the many attributes of the forest that is to be managed for. However, a significant body of research now exists that indicates that successful silvicultural and timber management systems, particularly for high quality hardwood sawtimber production, can be consistent with the ecological goals targeted by the DBNF. We submit that the draft is not structured in a manner that allows this substantial body of work to be incorporated into the plan. This will lead to the long-term degradation of timber quality on the DBNF (countering years of progress in rehabilitating stands) and leading to the loss of forest and ecosystem health (defined as the ability of the forest to effectively maintain growth and development of its dominant species in the face of natural and anthropogenic perturbations).  

 

The following sections outline the major issues that surfaced in the review and are provided to aid in the development of a final plan that is operationally sound and can be implemented in an efficient and effective manner.    

 

Clarifications

 

Issue 1. Timber Harvesting and Timber Production

There is a significant and potentially debilitating 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 leading to a misunderstanding of the management techniques approved for use 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 Area.

 

Timber production means the scheduled harvesting of timber to provide for a relatively constant supply of timber resources, which is significantly different than using timber harvesting as a management tool and this needs to be clearly stated in the plan. All Prescription Areas should include statements that indicate that timber harvesting is allowed where it is consistent with Area objectives.     

 

Recommendation: Provide the following statement in all Prescription Areas except the Habitat Diversity Emphasis Area: “The Prescription Area is unsuitable for timber production, the regulated and scheduled harvesting of timber, timber harvesting is suitable and will be used in the Prescription Area as a tool to achieve desired objectives.”   

 

Inconsistencies between Objectives and Prescriptions

 

Issue 2. Forest Health

Forest Goal 2 is to improve the ability of the forest’s ecosystem to withstand and to recover from disturbance (Forest Health)….  This goal is supported by the subtending goals aimed as regulating stand density as determined by Gingrich’s upland oak stocking chart and ensuring that proper regeneration is naturally developed.

 

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 the draft provides for timber production. Analysis of the “allowable sale quantity” provides for a rotation age of approximately 200 years in the HDEA. In 50 years over one-half of the HDEA (200,000 acres) will progress into age classes between 100 – 150+ years (see figure below) and a substantial number of acres will be approaching 200 years.

 

We understand that is being accomplished to achieve attributes of older forests across the landscape. However, this prescription will also lead to a decrease in overstory species diversity and forest health (as it relates to dominant overstory species) which is inconsistent with Forest Goal 2. Maintaining overstory tree vigor and stand “health” with an average 200 year rotation will be impossible for a large number of the stands on the DBNF based on species longevity, disturbance regimes, and the onslaught of invasive species and other anthropogenic stressors. 

 

Thinning based on the Gingrich stocking chart is the preferred method used in the draft for maintaining stand health. Unfortunately, it is not a tool that was designed for or appropriate for maintaining forest health over the forest ages indicated in the draft. Data used by Gingrich to construct the stocking chart was taken from trees much younger than 150 years old and his stocking standards were designed to work in even-aged closed canopy forests where full site occupancy was desired and healthy and consistent dbh and volume growth was optimized (as witnessed by the fact that the chart only reads to 15 inches dbh). It was not designed as a tool to maintain species in stands where their average age is well beyond 100 years old. Many of the species dominating the overstory do not have average life spans that will allow them to progress to the age limits imposed by the age class distribution in the draft. While textbook life spans and maximum ages are published for many species these assume nearly ideal growing conditions. However, a recent survey of silviculture instructors in the United States (conducted by George Hopper at the University of Tennessee) provides the following expert generated list of species longevities indicating that operational ages of many of the dominant species present on the DBNF will not provide stand integrity through the age classes required by the harvesting cycle prescribed for the HDEA. 

Species

Average

Range

beech

168

100-250

white ash

129

80-150

black cherry

115

70-175

bitternut hickory

133

80-200

mockernut hickory

127

60-200

shagbark hickory

137

75-225

pignut hickory

117

50-175

sugar maple

162

90-200

red maple

106

50-175

northern red oak

151

90-200

scarlet oak

105

65-150

black oak

129

75-200

chesnut oak

141

75-200

white oak

194

90-250

post oak

137

70-190

sweetgum

112

80-125

blackgum

116

80-150

yellow-poplar

136

80-300

black walnut

131

75-200

sassafras

69

30-175

Virginia pine

76

40-125

shortleaf pine

110

75-200

pitch pine

110

75-200

eastern white pine

 

75-200

black locust

 

15-150

pin oak

116

80-170

 

 

Also data derived from recent analysis of relative densities of common trees species in Kentucky by the USFS Northeast Forest Experiment Station (Spatial Trends in Relative Stocking Point to Potential Problems in Forest Health, USFS, Gen. Tech. Report NE-197) shows that some species, dominating the forest overstories on the DBNF, are already in a state of decline in eastern Kentucky (as indicated by significant loss of growing space or occupancy). Also shade tolerant species, particularly the maples are rapidly increasing there occupancy.

 

Thus, thinning to maintain stands at or below 80 percent stocking will not improve forest health if the species can not sustain the ages involved and an overall loss of overstory species will occur over the next 50 years if this plan is adopted. While some attributes of older aged forest will be achieved, such an increase in older trees, course woody debris, canopy gaps and complex forest structure this rapid aging of many of the stands will lead to an increase in susceptibility of stands to gypsy moth and other invasive exotics and other anthropogenic stressors (from increased storm frequency predicted by global warming models to localized pollution) that were not present in the abundance that they are now 100 years ago when the majority of old-growth forests were initiated. Unfortunately, these stressors are real and on the increase. The only known mechanism that can limit their effect on the forest systems is to maintain overstory species diversity, canopy continuity, and individual tree vigor. This means keeping shade intolerant and intermediate species regenerating and maintaining them in a well stocked and vigorously growing condition. USFS research indicates that increases in forest health can be achieved by maintaining vigorous, well balanced individual tree growth. This is not possible when species are grown to or through their average life spans.

 

A second forest goal associated with forest health is to maintain regeneration of old-age stands that are capable of dominating areas where overstory disturbance has occurred. Well established research indicates that without management of midstories and understories the loss of oak will continue to occur in many of our stands (with the exception of oak dominated stands on xeric sites). Prescribed fire is the preferred method for accomplishing this objective in the draft. While it is currently understood that landscape level fires coupled with other historical land disturbances played a significant role in shaping current overstories and our perception of old-growth stands and forests research has not shown that fire can be used as a prescriptive tool with the control or in a manner that is consistent with meeting management objectives of improving the vigor of oak advanced regeneration and aiding the development of natural regeneration of these species required to maintain forest diversity. It is therefore premature to operationally use this proposed technique on an operational basis until research indicates its effectiveness and provides guidelines for its use.

 

Recommendations:

1. Develop prescriptions in the HDEA and adjust the allowable sale quantity to provide for forests with a maximum age of 120 -140 years to maintain species composition and individual tree health.

2. Use proven techniques to manage for older age stands and attributes in the HDEA. Use silvicultural systems such as two-age that promotes some older age attributes where the stands can support them. Include in prescriptions the requirement for large course woody debris, snags and other old growth attributes that can obtained while maintaining reasonable stocking levels.

3. Use proven mid-story and understory control treatments to ensure adequate regeneration of a diversity of species. The use of landscape fire should be included as an experimental treatment until research indicates when and how it can be used effectively to meet regeneration, density, and habitat goals.

4. Use appropriate stocking controls and release techniques to accomplish thinnings (ex. Gingrich’s Upland Oak Stock Chart or modifications thereof, crop-tree management and crown touching release) to ensure individual tree vigor and overall stand health. 

5. Designate specific old-growth areas where core old-growth areas can best be isolated and necessary feathering of the core areas can be achieved to enhance old-growth characteristics. Unfortunately, the DBNF is a highly fragmented ownership and the ability to develop large areas of continuous forest cover in a protected environment (where effects from other ownerships are minimized) is impossible for much of the HDEA. For example, controlling invasive exotics in naturally occurring old-growth gaps would be virtually impossible throughout the HDEA. This situation indicates that it would be far better to locate and designate old-growth stands were they can be managed, along with the adjacent forested areas, to best achieve the desired future condition. The matrix of cliffline and riparian areas along with older aged attributes encouraged in the HDEA and the older HDEA will result in tangible old-growth assets over the landscape.

 

Issue 3.  Strategic Cliffline Planning

Current scientific evidence indicates that protections for clifflines should consider the nature and needs of each 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 though attributes and 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 in the draft preclude the use of the heavy equipment within 100 feet of 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.

 

Recommendation:

1. 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.”          

2. Evaluation of cliffline communities 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.

 

Issue 4. Riparian Corridor

It is unclear in the draft exactly what activities are allowed in the riparian zone. The draft indicates that deflections for cable yarding must lift logs to avoid bank disturbance and that roads are allowed. However, no other direction is provided. 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.  

 

A second issue revolves around the specifications for riparian setbacks. The requirements for riparian systems 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 corridors call for benign neglect management within the 100 year flood width and adjacent areas according to distances prescribed in table 3-1 regardless of the quality of water, aquatic habitats and nature of the riparian areas. It is not clear whether these are horizontal distances or slope distances. This presents an operationally difficult situation for laying out riparian corridors and managing forest health. The draft indicates that cut and leave is the preferred method for control operations in the riparian zone. One of the reasons for this is that course woody debris and woody habitat is underrepresented. However, these will increase as riparian corridors are allowed to age. When control measures are needed in isolated incidences cut and leave should not be required. 

 

Recommendations: 

1. 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.”

2. Eliminate the 100 year flood plain mark requirement for riparian corridor establishment and use a table based on slope percent and slope distance with the three divisions as there are now.

3. Eliminate the cut and leave emphasis associated with control measures.  

 

Issue 5.  Old Growth Decisions

While the mechanism exits to reclassify stands as old-growth no controls or provisions indicate how or when these decisions are made. One interpretation would be that the DBNF will classify all POGS and FOGS into old-growth ultimately removing all acreage from the HDEA thus eliminating the management of a diverse and healthy forest (as defined in the draft).

 

Recommendations:

  1. Clearly define in the plan how the decision will be made to reclassify lands (POGs and FOGs) into old-growth.  
  2. See Issue 2 recommendation 5. 

 

Issue 6.  Timber Production

The draft exclusively avoids directly stating harvesting actions or intents other than indicating that timber production is suitable for implementation in the HDEA and that timber harvesting is a tool for vegetative manipulation. While timber harvesting remains a volatile issue, especially on public lands, the national forests and the DBNF list timber as a resource to be managed for and provided as a forest resource. If a regulated timber harvest is to be accomplished, as is planned in the HDEA, and if timber is a resource to be sustainably provided by the DBNF then it is imperative that a section of the plan be devoted to discussing what timber is and how it should be managed. The lack of a section in the draft dealing specifically with timber production also does not allow for the significant body of timber production research to be encompassed in the planning process. 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 as underscored by the recent joint letter from the Society of American Foresters, the National Association of Professional Forestry Schools and Colleges (NAPFSC, comprised of the 69 universities that conduct the Nation’s research, teaching, and extension programs in forestry and related areas of environmental and natural resource management) and the National Association of State Foresters (NASF) to President Bush outlining the importance of timber harvesting on federal forests. Further, timber production, the scheduled harvesting of timber, is a legitimate use of public forests.

 

By minimizing the role of timber production as a legitimate management goal the DBNF may well avoid initial conflict but in the end the task force believes this will hamper the ability of resource managers to properly manage for the desired conditions set forth in the draft.

 

The strategy of avoiding the timber issue is counter to current accepted standards for ecosystem based sustainable forest management planning. Forest industry, private forest landowner groups and environmentally based forest managers all recognize the need for actively managing forest resources for timber production. The Sustainable Forestry Initiative (SFI) and the American Tree Farm System 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. In this light, the task force believes the DBNF should be a guiding light for high quality hardwood timber production in the region. The task force recognizes that the DBNF has the potential to grow and produce extremely value hardwood sawtimber and veneer in a manner that is consistent with ecosystem management principals. USFS FIA data shows that timber resources on the DBNF are above regional averages for private lands and the DBNF has historically been a leader in timber resource development in the region. Clearly a loss of management for this valuable resource should be strongly considered in development of the plan.

 

Recommendation:

1. The draft be amended to clearly show where timber harvesting can and should be used as a management tool in areas where timber production is used a tool for achieve ecological objectives.

2.  Provide a section in the plan that specifically deals with timber production, how it will be scheduled, the type of products that will be targeted and the methods used to produce and harvest timber resources.

  1. Provide guidance in the thinning descriptions to include timber based objectives specifically to promote the development of high valued sawtimber and veneer. 

 

Issue 7. DBNF as a Demonstration

One of the biggest changes in this draft, relative to past forest strategies, is the change in philosophy used to prioritize management objectives. While a change in overall emphasis in itself is not bad, it will change the interaction between non-industrial private forest owners and the DBNF. In the past, the DBNF was always viewed as a demonstration of forestry practices that could be used by many private landowners, forest industry, and loggers in the region. However, the change in philosophy, primarily based on the prioritization of management for landscape level ecosystems and away from multiple use management, makes the DBNF far less of a viable demonstration for forest management that can be used on non-industrial private forest lands in the region. Also, we have already seen instances where state agencies have incorporated proposals made in this draft into management planning for private landowners without first critically reviewing the implications of this for these same owners. While it is realized that a DBNF, managed with this draft, can be a model for forest management for those having the ability and interest in managing at the ecosystem and landscape level the majority of the non-industrial private owners and loggers will not have the operational platform to pursue the scale of management described in this plan. For instance large landscape scale prescribed burning is out of the question for most landowners. Riparian and cliffline setbacks will make many timber harvests impractical. HDEA rotation ages will not benefit, and in many cases will harm, many NIPF owners. 

 

The graphic below shows the importance of the DBNF as a demonstration. The points in the graphic represent timber harvesting sites on non-industrial private forest land in Kentucky surveyed in 1997-98 by the University of Kentucky. Each site was rated as to the operators use of BMPs. The clustering of excellent use of bmps is clearly around the DBNF and LBL in western Kentucky. One clear interpretation of this data is that loggers and landowners have used what they have learned on the DBNF putting it to use on private forestlands in the region. The current cliffline and riparian setbacks are operationally feasible only for a limited number of individuals and the lack of focus on timber production in the draft will clearly affect the impact that the DBNF will have on private lands in the region.    

 

Recommendation: It is difficult to state a recommendation for this concern other than to indicate that there will be a discontinuity between the DBNF and non-industrial private forest owners as it relates to the demonstration of appropriate management strategies. The only way to address this issue is to elevate the importance of timber production and timber as a commodity, provide increase strategic planning among prescription areas to increase operational effectiveness across the landscape, and provide for cliffline, riparian, and HDEA management criteria that is consistent with the operational constraints of many interested non-industrial private forest owners.  

 

 

 

 

 

 

 

 

 

 

 

 

About the Organization

The Kentucky-Tennessee Society of the Society of American Foresters (KTSAF) represents over 400 professional foresters and natural resource managers in Kentucky and Tennessee whose mission is to advance the science, education technology and practice of forestry to ensure the continued health and use of forest ecosystems to benefit society. We are the professional scientific and educational association representing the profession of forestry.