Sierra Club Preliminary analysis of changes to the management plan for
Superior National Forest

Environmental Issue

Changes between final & draft alternative E

Source

Allowable logging rates

24% increase to 1,020 million board feet (bf) from 820 million bf. This is a 30% increase over recent actual annual logging volume and three times the amount in alternative D supported by the Sierra Club.

The administration claims no additional acres would be logged to reach this higher volume, but they did not set a limit on acres logged in the plan so more acres may be logged than evaluated by the wildlife experts.

P 23 Record of Decision SNF

Forest habitat has to have a natural spatial pattern for it to be a home to wildlife. This is the first forest plan in Minnesota to consider spatial issues using new science.

The Regional Forester in the ROD says that the changes listed below to spatial standards and guidelines (S&Gs) were made to “reflect a more implementable objective.” Note that they could have chosen to reduce the amount of logging. Scientists have identified spatial issues like the size of a patch of forest or how dense the tree canopy is as important to rare wildlife that needs continuous, “interior” forests to survive. The Regional Forester was promoted under the Bush administration.

P 23 Record of Decision, SNF

Protecting remaining large patches of red or white pine from logging or road building. Forest-wide direction.

27% reduction in # of red or white pine patches (11 to only 8) that are over 300 acres that are protected, and 22% reduction in total acres (6,000 to 4,700).

P 2-26 SNF plan, G-VG-1&2, p 126 SC comments.

4.5% reduction in # of red or white pine patches (92 to 88) that are over 100 acres that will be protected, and 3.5% increase in total acres. (But kept a loophole—up to 40% of the canopy can be removed and still qualify it as “interior forest”.)

P 2-26, G-VG-2&3, SNF plan

Protecting lowland conifer large patches from logging or road-building

Lowland conifer large patch retention only protects a “reasonable array”. The plan does not specify what this means. But the FEIS predicts Lowland conifer edge is to increase by 50% in first 20 years of plan.

P 2-26, O-VG-19, SNF plan

Protecting remaining large patches of mature or older upland forest from logging or roading by zone

The forest outside the BWCAW is divided into three zones. Zone 1 is along Lake Superior, Zone two the South and West sides of the forest, and Zone 3 is adjacent to the BWCAW.

Zone map is on page 2-25 of SNF plan.

55% fewer patches of mature or older upland forest in patches over 1,000 acres protected from logging or roading (18 to 8 patches protected, loss of 10 patches) in zone 1

Pa 2-26, G-VG-5, SNF plan

12.5% fewer patches of mature or older upland forest in patches over 1,000 acres in zone 1 are protected (16 to 14 patches)

P 2-26, G-VG-6, SNF plan

42% reduction in mature or older upland forest in patches over 300 acres in zone 1 (76,500 to 44,700 acres) are protected.

P 2-26/27, G-VG-6, SNF plan

65% reduction in mature or older upland forest in patches over 300 acres in zone 1, (76,500 to 44,700 acres).

P 2-27 S-VG-7, SNF plan

Zone next to the BWCAW

Zone 3 has no interior forest minimum requirements, so no areas are protected from logging. Foresters are told to “strive” to maintain interior forest and large mature patches, but that age and composition objectives are to be the “drivers” of logging decisions in this zone.

The EIS admits, “S&Gs for zone 3 do not protect spatial issues or habitat connectivity.”

The Standards and Guidelines only cover areas of the SNF with fragmented ownership patterns (zones 1 &2). This reduces the effectiveness of the S&Gs—even if 100% implemented. Fragmented ownership areas are the wrong place to try and protect interior forest spaces. The best place is zone 3, the area next to the BWCAW because it is mostly in federal ownership.

There will be less connectivity of habitats in the BWCAW and zones 1 & 2 due to vegetation age and compostion objectives of zone 3.

“interior forest objectives in zone 1 or 2 would require specific “site-specific efforts” at the project level”

P 2-27, O-VG-24/25 SNF plan

FEIS 3.3.2-7

FEIS 3.3.2

“Forest-wide, inclusive of all spatial zones and wilderness, recent downward trends to forest spatial patterns in the region would be perpetrated and would result in an overall decrease in spatial diversity in the Northern Superior Uplands (NSU) (ecological) section during the first two decades of the plan and beyond,”

EIS 3.3.2-7

Protect remaining very large patches (10,000 acres or more) of mature upland forest in areas far from the BWCAW from logging or roading.

These very large protected patches were recommended in the 1994 Generic Environmental Impact Statement on Timber Harvest and Forest Management by the State of Minnesota. Their purpose was to mitigate the predicted biodiversity losses from the almost tripling of logging in Minnesota since 1975 due to new mills and expansions. This mitigation has not been implemented on state land and now, not on federal land.

P 23 Record of Decision, SNF

50% fewer very large patches of mature upland forest (from 2 to 1) in Zone 2.

P 2-26, V-VG-1,SNF plan

14% fewer acres of mature or older upland forest in patches over 10,000 acres in zone 2 (13,600 to 11,700 acres) Note that zone 2 is already so fragmented that there are no longer two 10,000 acre patches to protect.

P 2-26, S-VG-5, SNF plan

Weakening of habitat spatial protections by zone map changes

Acres with spatial protections were reduced by 119,300 acres or 19% due to changes in the zone boundaries (reduced area protected by spatial standards and guidelines, 16% fewer large patches than in draft) “Fewer large patches than existing for 50 years and doesn’t recover for 100 years.”

EIS 3.2-61

Wildlife survival impacts of volume and most likely arrangement of logging.

“…rates of disturbance (logging)…may limit the ability of an ecosystem coarse filter to maintain some species or habitats.”

“additional declines in populations of ground nesting birds or other edge effects”

EIS 3.3.2-7

Predicted large patch acres lost even after spatial standards and guidelines are implemented

Zone 1: 29% decrease in decade 1

Zone 2: 4% decrease in decade 1

Zone 3: 27% decrease in 20 years

This alarmed the FS enough to claim, “conditions will be monitored to determine if spatial objectives along with other multiple use objectives can be met during implementation of the plan.” But wasn’t the purpose of the planning process to answer this question?

12,600 acres of interior upland forest is predicted to be lost in the first decade. Note that they were losing interior forest at a 74,500 acres per decade rate from 2002 to 2004.

3.2-62

Wildlife Impacts of spatial patters of logging

“Sustained decreases until 10th decade on Superior in habitat for species such as the northern goshawk, black throated blue warbler, boreal owl, lynx, goblin fern, rams’ head lady slipper, and Canada yew.

“Decreases from existing conditions increase risk to maintaining viability of these species…”

EIS 3.3.2-5 text and table WLA 12/13

Rare habitat lost from 2002 to 2004 while planning was underway

14,900 acres of mature or older upland interior forest lost from 2002 to 2004 while planning dragged on.

EIS 3.2-65

Restoring the forest to nature’s design-range of natural variation (RNV) for growth stage and composition

Mod E has 28% more aspen and 23% less spruce-fir than nature’s design. It has six major departures from the natural range for age of forest types.

Accomplishing MN Forest Resources Council Landscape Restoration Goals

“Overall this alternative (Mod E) tends to manage the SNF lands in a way as to contribute minimally towards the landscape goals for forest vegetation within the Northern Superior Uplands (ecological) section and in moving it towards RNV.”

“It limits management flexibility needed to manipulate and move over-represented 50-99 age class to multi-aged/old-growth stages and for increasing within stand complexity,”

It contributes a “modest amount” (20% of acres) to the two oldest age classes.

Rates of disturbance (logging mostly) by federal and local foresters “would create large gaps in connectivity and spatial diversity. This would likely run counter to the desired conditions for the Northern Superior Uplands areas.”

The plan “…would perpetuate or increase recent past effects on forest spatial patterns in the s area of the NSU during the first two decades of the plan and beyond.”

Conclusion: Modification of E did not improve its landscape restoration impact.

EIS 3.2-47

FEIS 3.2-72

Old Growth Protection

There are no directly protected old-growth stands in the Mod E plan, except in the Research and Natural Areas (about 21,000 acres in existing or recommended RNAs). The recreation emphasis MA has the most old-growth, but its management direction permits logging and “are not managed specifically to protect, maintain or enhance old growth values.” This is deceiving because the table is labeled, “management areas contributing to old-growth and future old-growth conditions.”

FEIS 3.2-41

Logging in sensitive areas

Both draft and final zone maps put logging in the Fernberg Trail Corridor (it separates the two units of the BWCAW) and the Gunflint Trail.

The spatial plans do not include any habitat corridors for wildlife to move between the remnant interior forests.

Logging and roadbuilding in the Fernberg Corridor prevents if from even being made part of the BWCAW. This is a strategy the Bush administration is using in wild forests and deserts across the county.

P 2-25 SNF plan.

Restoring native forests with prescribed fire

30% reduction in acres (9,500 to 6,700) treated with fire in final plan.

FEIS Summary, ROD

Representative pristine forest reserves (RNAs)

22 candidate areas will be lost, about 27,000 acres.

Wild and Scenic River Corridors

Logging will be allowed along rivers that the FS promised the Sierra Club in a settlement agreement for a lawsuit over the 1986 forest plan that were to be nominated as wild and scenic rivers. This was never done by the FS.

Wildlife—well distributed populations that naturally replace themselves.

The plan admits to negative impacts to five important species, where there is a risk to their extinction on the SNF forest.

FEIS Summary p 31

Commercial trapping is now an objective of the forest managers

Commercial trapping was added to the final wildlife objectives for the plan to allow local communities to “realize the economic potential.”

P 2-28, D-WL-#G

Is there a limit on acres treated? Or will they log more acres to reach the ASQ and violate the EIS?

There is no limit to the acres “treated” by logging in the timber section of the plan. If the new higher yields used to increase the allowable cut are wrong, than more acres could be logged to get the volume—and increasing the negative impacts of the plan

White Pine

Still no quantifiable goals for white pine restoration. 900 acres of additional white pine predicted in first decade of implementation, a “moderate benefit to white pines”

P 2-35 SNF Plan

EIS 3.3.6.2-12

Net Present Value

The difference between the Mod E and alternative D supported by the Sierra Club, is only 1.3 percent, even in an accounting system that does not recognize any intrinsic value for stewardship.

EIS 3.9