Act Now: Submit Comments Here
Numerous forest wildlife are at-risk in the southern Appalachians due to lack of forest diversity and an unnaturally single-aged forest (i.e., lacking very young and very old forest interspersed across the landscape). Many, including ruffed grouse and American woodcock, are listed as species of greatest conservation need in North Carolina’s State Wildlife Action Plan. Some are even considered species of concern at the federal level (golden-winged warbler and Appalachian cottontail). The conservation needs of these species center mainly on habitat restoration and management.
The southern Appalachians are a key part of ruffed grouse range. Declining populations in the region sound the alarm nationally, emphasizing the urgent need to act now, before it’s too late.
The U.S. Forest Service (USFS) has released a proposed forest plan for the Nantahala-Pisgah National Forests (1.04 M acres) that establishes a vision for how the Forests will be managed for the next 10 to 15 years. All future projects will have to be consistent with the forest plan. Public comments over the next month will play an important role in shaping the final plan and implementation activities moving forward.
Additionally, as mentioned previously, we will submit official organizational comments to the USFS. We encourage you to read the plan yourself and review the USFS’ Virtual Open House on their website to learn more. The Reader’s Guide for the plan is a great place to start.
We recommend following the USFS’ guidance on writing good comments, as this will result in the greatest impact and best use of your time. The USFS recommends the following as tips:
The strongest comments are:
· Solution-oriented rather than advocating for or opposing general actions or activities.
· Comments are not a “vote” on whether the proposed action should take place.
· Specificity is important, but at the forest plan level, we won’t address every road, trail or recreation location – we are developing a strategic plan for use forest-wide, so identifying broader forest regions, or using particular places to make a broader point are both useful.
The public comment deadline is June 29th, 2020.
You can provide comments on the Nantahala-Pisgah Forest Plan here.
Draft Nantahala-Pisgah Forest Plan Components and Key Features:
Ø Desired conditions for the Forests were based on ecological modeling of the natural range of variation (NRV) across 11 different ecozones.
Ø The USFS has identified objectives to meet desired conditions for the plan based on two tiers: one if existing USFS capacity continues at expected levels, and a second tier if the USFS can increase capacity in the form of help from others and additional resources
Ø The USFS has created Management Areas to designate parts of the forest that have similar management intent and strategy, emphasizing different aspects of the vision established in the Draft Plan.
Ø The USFS has proposed four alternative approaches to managing the Forests, Alternative A, Alternative B, Alternative C, and Alternative D. The Alternatives examine different ways that management can make progress towards multiple goals.
Ø The Draft Plan distinguishes between areas identified as suitable for timber production and areas that will potentially be impacted by timber operations.
Background Information:
Ø Acres Available for Timber Harvesting: Depending on which alternative is selected, the total area where timber harvesting is allowed is 488-540k acres; However, only 235,000-265,000 acres will be commercially viable during the scope of the plan and only 111,000-113,000 acres is operable with current levels of road construction.
Ø Acres Likely to be Harvested: Current timber harvest is approximately 800 acre per year.
In the current draft plan, annual regeneration and thinning per Tier 1 is 1,600 acres. Per Tier 2, it is up to 3,800 acres annually. This equates to approximately 1.5% (Tier 1) to 3.8% (Tier 2) of the total forest being managed by timber harvesting over a decade.
Ø Young Forest Conditions: Tier 1 objectives achieve 60,000 acres (6% of total) in 30 years, but do not sustain that amount over time and Tier 2 objectives achieve 90,000 acres (9% of total) in about 20 years and sustain that amount long-term.
Ø Open Forest Conditions: Long-term desired conditions are to have 360,000- 480,000 acres (36-48%) of forest in open woodlands. In general, woodland restoration would begin with mechanical treatments (such as timber harvest) and be maintained over time with prescribed fire. The woodland condition would be an improvement over closed canopy condition for disturbance dependent wildlife like ruffed grouse. Tier 1 objectives would result in significantly lower than desired conditions and Tier 2 objectives for Alternatives B & D take 70 years to meet the lowest threshold of desired conditions. Alternative C never meets desired conditions regardless of Tier objectives.
Ø Ruffed Grouse: The Draft Plan recognizes grouse as a demand wildlife species, and cites a slight downward trend in population levels and states that current population levels are low compared to historic levels. Across all Alternatives and Tiers, the Draft Plan estimates that grouse would improve over existing conditions but remain “fair” in terms of open forest habitat.
Ø Recommended Wilderness Designations: The USFS states that Recommended Wilderness designations are generally not areas that would be otherwise managed for young forest habitat or motorized access. However, the Draft Plan does not make clear the amount of forestland that will be moving from land potentially suitable for timber harvesting to Recommended Wilderness designation. Across the different Alternatives, the amount of Recommended Wilderness varies between 11,193 to 126,333 acres.
Nantahala-Pisgah Forest Plan RGS & AWS Position Statements: Because we are still working through analysis of the plan, we will select a preferred Alternative (or modified Alternative) for our official RGS & AWS comments in the coming weeks. At this point, Alternative D with modifications is a strong candidate. For now, the following position statements highlight our stance on certain issues.
Ø RGS & AWS supports the USFS to select an Alternative that reduces complexity and increases flexibility for wildlife habitat and forest restoration projects.
Ø As a science-based organization, RGS & AWS supports the USFS’s adoption of natural range of variation (NRV) to define forest diversity goals. In that, we emphasize management that achieves NRV while maximizing benefits for at-risk wildlife.
Ø The Draft Plan’s target acreage range for young forest (6-9% of total) is lower than the standard range used by wildlife managers in the region (8-12%) and lower than guidance in the NC Wildlife Resources Commission’s Bird-Matrix report (14.1%). RGS & AWS advocates for goals consistent with state wildlife agency guidelines at 12-14% along with land designations to ensure that such scale of forest management actually occurs.
Ø RGS & AWS supports the Draft Plan’s target acreage of 360,000-480,000 acres (36-48% of total) in open forest habitat conditions using all appropriate means including timber harvest. As such, we recommend maximizing fire-dependent ecosystem land area in the “Matrix” designation to allow for management flexibility and achievement of plan goals.
Ø RGS & AWS emphasizes that commercial timber harvesting is the most cost-effective means of improving wildlife habitat conditions and should be preferred over noncommercial treatments as much as possible.
Ø RGS & AWS requests specific management objectives over the next 20 years for forest diversification at higher elevation ecozones where no timber harvest recommendations are made in the plan (i.e., northern hardwood). Habitat diversity in these high elevation ecozones is imperative for wildlife, especially ruffed grouse, in resilience to climate change.
Ø RGS & AWS strongly believes that Tier 2 Objectives are the minimum level of management necessary to meet the USFS’ desired conditions for young and open forest and associated wildlife habitat. We emphasize that the USFS propose annual harvest levels above Tier 2 as determined by ecological and sustained yield modeling.
Ø RGS & AWS does not support new Recommended Wilderness designations that hinder ability to achieve forest diversity goals defined by NRV. We also request that USFS better quantify and explain the scope and impact of acres moving from designations suitable for various forms of management (including prescribed fire and timber harvest) to Recommended Wilderness designation.
Ø Specifically, RGS & AWS recommends the removal of the following areas from Recommended Wilderness designation: Black Mountains (11,875 acres), Mackey Mountain (7,872 acres), Tusquitee Bald (15,957 acres), Middle Prong Ext. (1,871 acres), and Portion of Joyce Kilmer Ext. #2 (443 acres).
Ø RGS & AWS believes that Backcountry designations which are outside of Inventoried Roadless Areas and conflict with the NC Wildlife Resources Commission’s Wildlife Habitat Active Management Areas (WHAMAs) should be designated as Matrix.
Ø RGS & AWS would like the USFS to clarify and expand on what timber management activities are allowed within the EIA designation.
Ø RGS & AWS would like the USFS to modify their language of how the old growth network is managed and dealt with at the project level.
We encourage members and all who are interested in wildlife conservation to comment on the draft plan and hope you find this background and position statements useful in guiding those comments.
The public comment deadline is June 29th, 2020.
You can provide comments on the Nantahala-Pisgah Forest Plan here.
