From: Indiana Forest Alliance
615 N. Alabama St Suite A
Indianapolis, IN 46204
To: Indiana Division of Forestry (DOF)
402 W. Washington Street, Room W-296
Indianapolis, IN 46204
CC: Governor Holcomb Date: June 5, 2024
Subject: DRMG Logging Plans for Moran-Monroe and Yellowwood State Forest
Posted May 8, 2024
Morgan-Monroe State Forest:
Compartment 3 Tract 6; Amended (53 acres)
Compartment 3 Tract 11; Amended (53 acres)
Compartment 4 Tract 10; Amended (58 acres)
Compartment 16 Tract 9 (116 acres)
Compartment 16 Tract 23 (90 acres)
Compartment 16 Tract 24 (41 acres)
Compartment 11 Tract 1; Amended (110 acres)
Compartment 11 Tract 2; Amended (115.5 acres)
Yellowwood State Forest:
Compartment 7 Tract 19; Amended (172 acres)
Dear Division of Forestry,
We appreciate this opportunity to comment on these proposed timber harvests in the Morgan-Monroe and Yellowwood State Forests. The Indiana Forest Alliance does not oppose all timber harvests in state forests, but we object to the overall volume of timber authorized for harvest from our state forests and the lack of transparency and accountability for such activities. To begin with, these proposed harvest plans do not indicate whether they have been authorized by the DOF’s 2020-2025 Strategic Direction Management Plan for Indiana’s state forests. We have attempted to find this Plan on the DOF website to reference in our public comments but could not locate this document. Further, there was too little opportunity for public comment on this Strategic Direction Management Plan. If the goal of harvesting 14 million board feet per year is still the target, it is too high to be considered sustainable.
The Indiana State Forest system consists of approximately 160,000 acres of forest land. Presently and under the previous Strategic Management Plan, these lands are being managed almost entirely (more than 97%) under a timber harvest rotation that subjects nearly all state forest acres to commercial timber harvests. Rather than such harvests, our public forests should be managed primarily to “protect and conserve the timber, water resources, wildlife, and topsoil … for the equal enjoyment and guaranteed use of future generations,” as stated in the enabling statute for Indiana’s state forests, IC 14-23-4-1. Therefore, timber harvests on public lands should be undertaken only when and if it can be demonstrated that local market needs cannot be met by harvesting from private lands and the harvest is needed to improve forest health. Thus far the only working definition of forest health IFA has been able to locate is a reference made on the DOF website which reads, “The term “forest health” describes forest conditions relative to human values, needs, expectations and functions.” While we appreciate this candid and transparent explanation of forest health, such an anthropocentric viewpoint displays a lack of appreciation for the myriad floral and faunal relationships that maintain forest resilience through time. Forests are dynamic, self-organizing ecosystems that depend upon an incredibly diverse set of relationships that go well beyond just the values, needs and expectations of humans. In the face of climate change and a significant loss to biodiversity, our state forests have far more value in sequestering and storing carbon and providing a home for all native forest dependent, rare, threatened and/or endangered species than they do as sources of timber.
Over the past two decades, the DOF has repeatedly represented to the Forest Stewardship Council (FSC) that 10% of our state forests are to be managed for late seral conditions. Yet, the DOF has never indicated which areas of the state forests have been designated for older forest condition, or which areas are targeted for the development of early succession habitat, and/or regeneration of oak hickory forests, nor why any of these areas were selected.
We continue to support the establishment of management plans for each state forest, and the establishment of specific Wild Areas within each state forest to be managed without timber harvests for late seral conditions and the restoration of old growth forest as recommended in the guidelines for sustainable forestry by the Forest Stewardship Council. Large blocks of interior forest still exist in our state forests, and these should be protected to provide future generations of Hoosiers with old growth forests. These areas would serve as climate reserves for carbon sequestration, and would also provide core scientific reference areas, habitat for species that need older forest, and a wilderness experience for recreational users. Prioritizing the conservation of these areas would demonstrate the DOF’s commitment to restoring a fully functioning hardwood forest ecosystem within our state forests.
Current state forest timber management does not comply with the enabling statute (Indiana Code 14-23-4-1) because it fails to protect the wildlife and wildlife habitat, topsoil, water resources, recreational uses, and ecosystem services of these forests for future generations. The agency’s current approach of managing our state’s public forests for oak and hickory timber production is a one-size-fits-all approach that reduces the natural diversity of the mixed mesophytic hardwood forest ecosystem of our region and does not serve the people of Indiana.
In 2018, Governor Holcomb halted all logging in Morgan-Monroe and Yellowwood State Forests in response to the public outcry over a timber harvest carried out in the Morgan-Monroe/Yellowwood Back Country Area. IFA is displeased with the decision to lift the moratorium considering the widespread public opposition to logging in these state forests.
The Indiana Forest Alliance would not oppose timber harvests on these tracts, provided the DOF demonstrates that:
- Comprehensive flora and fauna wildlife inventories are conducted on each Compartment and Tract to identify a baseline of rare, threatened, and endangered species that may be present before a logging decision is made. A review of the Natural Heritage Database alone is not sufficient; the Division of Nature Preserves has concurred that a review of the Natural Heritage database is not adequate to determine whether rare, threatened, or endangered species are present on a specific tract. Only onsite surveys by professional forest ecologists or biologists can accomplish this objective.
- Set aside some compartments and tracts (at least 10% of state forest acres as indicated to the FSC), particularly those in previously designated Old Forests, Back Country Areas (BCAs), High Conservation Value Forests (HCVFs), and IFA’s proposed State Wild Areas from harvest altogether.
- Logging on steep slopes (exceeding 30 deg.) will be avoided and water quality will be protected by avoiding timber harvests within riparian strips (of at least 100 feet in width, 50 feet on both sides of ephemeral and intermittent streams). Simply referencing Best Management Practices (BMPs) is not enough to ensure that the waters of the state will be protected. The Resource Management Guides (RMGs) do not provide enough information to know exactly where the harvesting will take place or what measures will be taken to prevent soil erosion and protect water quality.
- The ecosystem services are considered, especially the potential of standing forests to mitigate climate change. Indiana ranks among the top 10 states for carbon emissions per capita and has a responsibility to offset those emissions as much as possible. The Draft Resource Management Guides (DRMGs) should demonstrate the carbon sequestration consequences of the proposed logging activities providing an accounting of forest carbon stocks in the pre-harvest and post-harvest conditions and managing forests on slower rotations.
- Recreational uses are not subverted to the interests of timber buyers. A 200 ft. (100 ft. from the center line in each direction) visual corridor without timbering should be maintained along all major trails.
- Public participation is enhanced by cross-referencing the DRMGs with timber sale documents. Currently it is almost impossible to determine if a harvest was done in accordance with the published RMGs or BMPs.
- Tree markings and subsequent timber management activities for the proposed harvest plan areas are not conducted until the public has been granted the full public comment period to express their concerns and/or support for the planned timber harvests. IFA staff visited Compartment 3 Tract 11 to the south of Gose Creek Road in the Morgan-Monroe State Forest to find numerous tree markings, logging, and prescribed burning on this tract just prior to and/or during the public comment period for these amended RMGs. The DoF is circumventing the democratic process and not taking the public comment period seriously as the public’s only way to provide input on its management activities.
- Evidence that shows the logging, prescribed burning, and use of herbicides to control invasive plant species in our forests are not in fact accelerating their establishment or creating the conditions which make them thrive. The failure to show past successes in these approaches on state forest land does not support their continued use. It is crucial to start showing documentation which evaluates the efficacy of these management practices over time and then use this data to determine whether these practices should continue especially if they have not shown themselves to be effective at obtaining the desired results.
Suitability of Terrain. A few of these tracts have “sharply dissected hills” and “narrow ridges and valleys” with high potential for erosion. For example, the soils present in Compartment 3 Tract 11 and Compartment 7 Tract 19 (in Yellowwood S.F.) indicate slopes ranging from 6-80% yet the DRMG says nothing about avoiding the steepest areas. Best Management Practices indicate that slopes greater than 30 deg. (or ~58%) should be avoided altogether but the RMG makes no mention of this. BMPs are unlikely to prevent soil erosion and polluted runoff will inevitably be the result from logging in these tracts.
Water Quality. Using heavy equipment and removing tree cover on steep slopes with low organic matter is a formula for creating soil erosion and polluted runoff into nearby waterways. Several of these tracts drain to one of the major tributaries to Lake Monroe, the North Fork of Salt Creek which is already impaired for sediment, excessive nitrate and phosphate levels, and impaired biotic communities. It is a violation of the Clean Water Act to exacerbate a known impairment. In addition, Compartment 3 Tract 11 drains to the Butler Creek-White River watershed. Do the North Fork of Salt Creek and Butler Creek meet water quality standards for sediment and dissolved oxygen? Logging in these tracts is likely to increase sediment and reduce dissolved oxygen. The DOF should monitor water quality on both the North Fork of Salt Creek and Butler Creek upstream and downstream of the logging operations and before, during and immediately after the harvests to ensure that sediment, nutrient, and turbidity levels do not exceed baseline levels prior to logging. And the DOF should enforce corrective actions at these tracts if baseline levels are exceeded.
Local Market Conditions. Please explain how the removal of this timber will “provide local markets with a further source of building material” as required by statute.
Forest Health. Forest health should not be defined by economic productivity, but by ecological complexity and ecosystem services. Please describe the ecological complexity and ecosystem services provided by standing forests in these tracts, especially the carbon sequestration potential. Understanding carbon sequestration is stated as one of the goals of the State Forest Strategic Direction Management Plan. What are the carbon stocks (in metric tons per acre) presently in these tracts and what is the carbon sequestration potential of these tracts in the logged versus unlogged conditions? These should be delineated and estimated to inform decisions in these harvest plans. Diseases and pests should be specifically identified within these tracts that pose a significant threat to forest health and the DOF should explain how those pests and diseases will not abate (e.g. from natural thinning or mortality from old trees) without activities proposed in the harvest plan.
Prescription. The harvest prescriptions describe a range of options e.g. single tree selection, regeneration opening, small group selection, sanitation cutting, or Timber Stand Improvement (TSI), but do not actually inform the public about what treatments will be used where. The Division should provide a more precise map showing where different management practices will be applied. The DOF should also provide estimates of how many trees will be removed before or after the timber harvest during the “sanitation cutting” and “timber stand improvement” phases of the harvest management project.
Invasive species are one of the biggest threats to forest health. But the description of how non-native invasive species will be managed is very general and takes the form of a suggestion rather than a prescription. Please prioritize eradication of invasive species before any timber harvest is undertaken. Provide details about how and when invasive species will be controlled. Logging and prescribed burning often introduce invasive species and exacerbate their spread, as evidenced by the introduction and rapid spread of Japanese stilt grass. According to research, deciduous forests that undergo repeated fire treatments are more vulnerable to the takeover of non-native invasive species due to less leaf litter, less fine woody debris, and from increased fire intensity. The harvest plans should explain how the DOF will prevent these problems. The plans should also explain how runoff and herbicide drift that are potentially harmful to biota and human health will be avoided.
The DOF should tell the public what “will” be done instead of what “could” or “should” be done to control non-native invasive species.
Wildlife. No pre-harvest wildlife inventory has been done on these tracts. How will the Division of Forestry be able to protect rare, threatened, or endangered species if no wildlife inventory has been done? Endangered or proposed endangered mammals including Indiana Northen Long-Eared and Tri-colored bats are likely to be present, and utilizing features that will be targeted for removal by the harvest operation such as snags or older, declining trees with cavities, exfoliating bark, and/or additional deadwood. How will the Division of Forestry protect these species and other endangered species that may be present? A review of the Natural Heritage Database is not sufficient. While the Natural Heritage database is a wonderful tool, it is not a substitute for a site-specific taxonomic inventory and does not present an understanding of the functional groups of endemic flora and fauna that are prevalent in the harvest areas. For example, the Indiana Forest Alliance’s scientific surveys in a 900-acre portion of Morgan Monroe-Yellowwood Backcountry Area revealed more than 30 species of invertebrates that had never been reported in Brown County. It is indicated that most, if not all, the Compartments and Tracts feature roost trees and snags that meet or exceed the recommended maintenance levels and are great for wildlife habitat. The harvest plans should explain how the proposed logging activities will ensure the legacy and standing dead trees will be maintained.
If early successional habitat is desired, it should be created on areas that are adjacent to state forests, thereby expanding the state forest base. This would enable the DOF to create late successional habitat and old growth forests for future generations.
Given the high value of the interior forest habitat in these tracts for rare, threatened and endangered bats, small mammals, forest songbirds, reptiles, amphibians, and other species, the DOF should also outline measures that will be taken to avoid the illegal take (killing) of federal and state endangered species and any harm to rare species resulting from logging, Timber Stand Improvement (TSI), and prescribed fire activities in these harvest plans.
The DOF should ensure that each state forest property will have some old growth forests for future generations to enjoy by creating Wild Areas or High Conservation Value Forest Areas that will be permanently managed for old growth conditions without human disturbance.
Addressing these concerns would help demonstrate compliance with the DOF’s enabling statute.
Thank you for this opportunity to comment on the amended Draft Resource Management Guides for Compartment 3 Tracts 6 & 11, Compartment 4 Tract 10, Compartment 11 Tracts 1 & 2, Compartment 16 Tracts 9, 23 & 24 in the Morgan-Monroe State Forest, and Compartment 7 Tract 19 in the Yellowwood State Forest.
Respectfully,
Dex Conaway
State Forest Director
Indiana Forest Alliance
