Public Comment on Logging: IFA’s Response to DRMG

IFA’s Official Response to DRMG

Indiana Forest Alliance Comments on Proposed Timber Harvest in Clark State Forest, Compartment 10, Tract 4; Compartment 11, Tract 5; Compartment 11, Tract 6; Compartment 15, Tract 3  – posted Nov. 14, 2019

  • Compartment 15 Tract 3
  • Compartment 10 Tract 4
  • Compartment 11 Tract 5
  • Compartment 11 Tract 6

The DRMG is too vague. The DRMG states that virtually every type of harvest method will be used: single tree, group tree, patch openings, shelterwood, and regeneration cuts (a.k.a. “clearcutting”) as well as prescribed burning in all four tracts. Yet the DRMG provides only a general idea of which methods might be used where. No stand table is provided and there is no estimate of the timber volume to be removed. The DRMG should be amended and re-posted with this information.

Suitability of Terrain, Erosion and Water Quality

These tracts all contain steep slopes. These tracts contain steep slopes and highly erodible soils on severe slopes that are as steep as 60 to 75% and not suitable for logging. The DRMGs recognize that portions of these tracts are very steep, but there is no indication that logging activities will avoid these areas. Best Management Practices are inadequate to protect soils and water quality in these areas.

Three of the tracts include streams that flow into the South Fork Blue River, the last home of the hellbender salamander, endangered in Indiana. Hellbenders are extremely sensitive to sedimentation from soil erosion that coats gravel river bottoms and suffocates their young. Any logging that proceeds should avoid slopes greater than 25%.

Forest Health

The DRMGs do not demonstrate that logging will restore or maintain forest health. Forest health should be defined by ecological complexity and indicators such as floristic quality, not the quantity of commercial timber. Nonnative invasive plants are one of the most significant factors attacking forest health. These plans state that invasives such as Japanese stiltgrass, oriental bittersweet, and Japanese honeysuckle and multiflora rose are present in some of the tracts. The prospect of these tracts being logged at the same time by the same timber buyer, given their harvests are being posted in one document raises additional concerns about spreading invasives from one area to another.

Wildlife & Rare Threatened and Endangered Species

The proposed DRMG does not contain a pre-harvest wildlife inventory. It states that a Natural Heritage Database Review was conducted as part of the management planning process.  This statement is not sufficient to ensure that Rare, Threatened or Endangered (RTE) species will be protected. The Natural Heritage Database is merely a collection of locations where Rare, Threatened or Endangered (RTE) species have been seen and should not be presumed to indicate the presence or absence of species in a given tract of forest. A wildlife inventory is essential to determine the impact that the prescribed timber harvest will have on wildlife present in this specific tract and the entire state forest.

Indiana’s state forests provide some of the last suitable habitat in the state for rare, threatened, or endangered species such as the Timber Rattlesnake, Indiana Bat, Hoary Bat, Northern Long-Eared Bat, Eastern Pipestrelle, Cerulean, Hooded and Worm-eating Warblers, and several other neo-tropical migratory song birds. Nearly all of Indiana’s salamanders and many of our frogs require closed canopy forests to maintain healthy populations. Indiana’s forests harbor several species of salamanders, including the spotted salamander, which depend upon continuous forest canopy to maintain their body moisture. Most shrews live in forests and two rare species, the pygmy and smoky shrews, live in the forests of south central Indiana. Both were discovered in the state in 1982 and are dependent on the deep soils of undisturbed interior forest.

Since Indiana’s state forests contain some of the only areas in the state where large, contiguous forests are found, the DOF should focus its management on the preservation of deep forest habitat for the RTEs that rely on intact forests for successful reproduction and survival. In order to ensure that no RTEs are adversely affected, either directly or through habitat degradation, and so the public can fully evaluate the implications and necessity of the proposed DRMGs management activities, the DOF should publish in every DRMG an up-to-date, detailed inventory of wildlife identified within the tract. No logging should commence without a comprehensive wildlife inventory and a specific plan for preventing adverse impacts to RTE species on these tracts.

Concerns Specific to Each Tract

Compartment 15 Tract 3

IFA strongly opposes logging on this tract and the substantial damage it will do to its recreational value. This tract contains 222 acres and is located partially in the northern portion of the Deam Lake State Recreation Area as well as IFA’s proposed Knobstone Wild Area. The tract contains five multi-use recreational trails (Cross Country Trail, Deam Lake Loop, Flower Gap Loop, Tree Lane Loop, and the Three Hills Trail), and a portion of the Knobstone Trail that will likely cause trail closures and have a negative impact on recreational users.

Steep west-facing slopes drain into Deam Lake, a popular recreation area.

Invasive species that are present within this tract could be spread throughout this area by logging equipment and by opening up the canopy.

IFA believes that logging in the other three tracts should at least be prohibited on slopes exceeding 25%

IFA will also push for water quality monitoring of streams draining from these tracts to ensure that Best Management Practices are adequately controlling sediment runoff.

We will push for limits on the prescribed fire to avoid burning up Eastern box turtles, state endangered timber rattlesnakes and several species of salamanders, and the young of ground and shrub nesting birds.

Compartment 10 Tract 4

This 123-acre tract includes popular horseback riding trails. Its steep slopes and streams drain into the Poplar Branch Creek, which empties into the South Fork of the Blue River a half mile further. Blue River is the last remaining home of the Hellbender salamander in Indiana and is very sensitive to sediment in the water column. This tract has few invasive species but logging would likely introduce and/or exacerbate the problem.

Compartment 11 Tract 5

This 102-acre tract contains few trails and very few invasive species in its current undisturbed condition. There is some stiltgrass along old skid roads and we would like to ensure that this problem is not expanded or repeated.  This tract drains into Honey Run and then into Whiskey Run, which empties to the South Fork of the Blue River less than a mile away, threatening to damage the last remaining habitat of the Hellbender salamander.

Compartment 11 Tract 6

This 74-acre tract also drains into the South Fork of the Blue River via Honey and Whiskey Runs. Some invasive species have been found but are somewhat localized. There is some stiltgrass along old skid roads and we would like to ensure that this problem is not expanded or repeated.  Like the other tracts, opening up the canopy and moving equipment around is likely to spread invasives. Logging in this tract threatens to damage the last remaining Indiana habitat for the Hellbender salamander.

IFA’s Opinion on DRMG

Proposed Logging in Four Clark State Forest Tracts Includes Proposed Knobstone Wild Area

December 13 was the deadline to submit your comments.

The Indiana Department of Natural Resources has issued logging plans in Clark State Forest. The deadline for public comments on these plans is midnight December 13.

Please take 30-40 minutes to:

  1. Submit opposing comments via the Division of Forestry (DoF) website;
  2. Submit your comments to Governor Holcomb and your state legislators (state senator and state representative); and
  3. Send a copy of your comments to IFA.

Applying pressure to officials lets them know we are watching and that we want our state forests protected for their recreational, natural, and ecological values. Read on to see how to comment, and points you can make.

Background and Tract Overview

IFA’s Conservation Director, Rae Schnapp, Ph.D., has reviewed the logging plans. The following tracts in Clark State Forest will be logged:

  • Compartment 15 Tract 3
  • Compartment 10 Tract 4
  • Compartment 11 Tract 5
  • Compartment 11 Tract 6

Dr. Schnapp has called for a statewide action alert to protect these four tracts. She found the following concerns in all of the tracts:

Overall Concerns: The IDNR’s Draft Resource Management Guides (DRMGs), or logging plans, state that virtually every type of harvest method will be used: single tree, group tree, patch openings, shelterwood, and regeneration cuts (a.k.a. “clearcutting”) as well as prescribed burning in all four of the tracts. Yet they provide only general ideas on where these methods might be used and no estimate of the timber volume to be removed. The DRMGs are too vague.

Forest Health Timber harvests degrade the recreational enjoyment and ecological value of state forests. The DRMGs do not demonstrate that logging will restore or maintain forest health. Forest health should be defined by ecological complexity and indicators such as floristic quality, not the quantity of commercial timber.

Nonnative invasive plants are one of the most significant factors attacking forest health. These plans state that invasives such as Japanese Stiltgrass and Tree of Heaven are likely to be introduced or increased by logging and logging roads built through these four tracts. The prospect of these tracts being logged at the same time by the same timber buyer, given their harvests are being posted in one document raises additional concerns about spreading invasives from one area to another.

Erosion and Water Quality These tracts contain highly erodible soils on severe slopes that are as steep as 60 to 75% and not suitable for logging. The DRMGs recognize that portions of these tracts are very steep, but there is no indication that logging activities will avoid these areas. Best Management Practices are inadequate to protect soils and water quality in these areas.

Three of the tracts include streams that flow into the South Fork Blue River, the last home of the hellbender salamander, endangered in Indiana. Hellbenders are extremely sensitive to sedimentation from soil erosion that coats gravel river bottoms and suffocates their young.

Wildlife The DRMG suggests that “A Natural Heritage Database Review is part of the management planning process.” But the Natural Heritage Database is merely a collection of locations where Rare, Threatened or Endangered (RTE) species have been seen and should not be presumed to indicate the presence or absence of species in a given tract of forest. No logging should commence without a comprehensive wildlife inventory on these tracts and a specific plan for preventing adverse impacts on RTE species.

Logging Volume For all four of these tracts, the public should demand that the DoF divulge the volume of timber it is proposing to log so that reviewers can better understand the relative impact of this logging within each tract. Furthermore, the public should ask that these plans be updated and reposted for public comment with that information. Total volumes below 50,000 board feet in each of the three tracts in Compartments 10 and 11 (which are approximately 74 to 120 acres in size) would be less significant and a total volume below 100,000 in the 222-acre tract in Compartment 15, would be less significant than the typical volumes the DoF proposes to remove from tracts today in its timber harvests, which usually amounts to around 20 to 30 percent of the merchantable timber volume.

Concerns Specific to Each Tract

Compartment 15 Tract 3
This tract contains 222 acres and is located partially in the northern portion of the Deam Lake State Recreation Area as well as IFA’s proposed Knobstone Wild Area. The tract contains five multi-use recreational trails (Cross Country Trail, Deam Lake Loop, Flower Gap Loop, Tree Lane Loop, and the Three Hills Trail), and a portion of the Knobstone Trail that may be temporarily closed and negatively impacted by the logging. Steep west-facing slopes drain into Deam Lake. Invasive species that are present within this tract could be spread throughout this area by logging equipment and by opening up the canopy.

IFA will strongly oppose logging on this tract and the substantial damage it will do to its recreational value.

IFA believes that logging in the other three tracts should at least be prohibited on slopes exceeding 25% and not undertaken until a wildlife inventory has been completed ensuring that no RTE species or their habitats will be harmed.

IFA will also push for water quality monitoring of streams draining from these tracts to ensure that Best Management Practices are adequately controlling sediment runoff.

We will push for limits on the prescribed fire to avoid burning up Eastern box turtles, state endangered timber rattlesnakes and several species of salamanders, and the young of ground and shrub nesting birds.

Compartment 10 Tract 4
This 123-acre tract includes horseback riding trails. Its steep slopes and streams drain into the Poplar Branch Creek, which empties into the South Fork of the Blue River a half-mile further.

Compartment 11 Tract 5
This 102-acre tract contains few trails and very few invasive species in its current undisturbed condition. Its waters drain into Honey Run and then into Whiskey Run, which empties to the South Fork of the Blue River less than a mile away.

Compartment 11 Tract 6
This 74-acre tract also drains into the South Fork of the Blue River via Honey and Whiskey Runs. Some invasive species have been found but are somewhat localized. Like the other tracts, opening up the canopy and moving equipment around is likely to spread invasives.

How to Comment

Review the IDNR’s proposed logging plan/DRMG. For tips on how to comment on proposed logging, visit indianaforestalliance.org/public-comment/.

The IDNR is taking public comment until December 13, 2019. Submit comments at:
https://www.in.gov/dnr/forestry/8122.htm.

For IDNR accountability, please send a copy of your comments to your state legislators. Find your legislator.

Most importantly, send a copy of your letter to Governor Holcomb.

Find more tips on how to comment on the IFA website.

Thank you for your participation in the public comment period and your forest advocacy and support! Together we can work to protect Indiana’s priceless remaining wild nature.