CWCS Comments on the Forest Plan Revision

Conservationists with Common Sense (CWCS) finds that the Forest Plan Revision does not meet the National Environmental Policy Act - Public Law 495. Communities and economic factors do not have the protection that is afforded by NEPA. USFS allows hardly 25% of the cut in any given year, as our communities continue to erode. For accurate scientific analysis according to NEPA, BWCAW forestland should be part of the science to determine overall age class. None of the alternatives proposing tree species diversity objectives and age class objectives consider the 800,000 acres of forestland within the BWCAW, 82% of which is mature. Old-growth should be left in the BWCAW and the rest of the Superior National should be managed to be age diversity. Those areas protected by the Shipstead-Newton-Nolan Act and areas not suitable for timber harvest can address old-Growth values within the Superior National Forest outside the BWCAW.

Forest Health is not defined or listed as a goal in the current plan. To propose management for more mature and older forests will lead to the higher probability of uncharacteristic wildfire. Safety of communities has been put at great risk by the inability of the USFS to do proper fuel reduction from the July 4th 1999 blowdown in the Superior National Forest. Controlled fire is a useful tool in managing forests, but fuel-removal to avert the possibility of wildfire is also needed. We do not want to repeat of wildfires of the past few years out West. The BWCAW management plan should also be revised to take into consideration the Healthy Forest Reforestation Act regarding the fire danger to those individuals living in close proximity to the 1999 blow down area.

We need to manage the forests to prevent uncharacteristic wildfire to assure a healthy watershed. The proposed plan moves the forest to more over-mature stands, putting the forest in a state in which wildfire could occur. Uncharacteristic wildfire sterilizes soil and crystallizes soil leading to excess erosion. The environmental effect of these wildfires doesn't address the amounts of carbon, mercury, methane gas, and other greenhouse effect gases into the atmosphere. Also not addressed is the pollution effect of smoke, ash and debris that clog the rivers and streams.

Economic effects are not even mentioned. There is a great economic impact of less harvest on the payments made by the federal government to the state of Minnesota and the counties that are home to the Superior and Chippewa National Forests. Economics should equally be part of an NEPA as environmental effects.

Community is defined as recurring groupings of plants and animals. Throughout the Plan, community has no relation to the people who live and use the forest. The greatest proposed trade-off is the depopulation of northeastern Minnesota.

In the analysis of the Wildlife Habitat management situation you state "The greatest difference in demands since the last planning period is that there is now explicitly a greater demand for habitat for species associated with: older forest; large contiguous forest patches with less edges; etc." We find no data that supports dependence on old growth for any vertebrate species or plants in Minnesota.

Rare natural resources should be protected. But increased protection of dry Mesic Jack Pine/Black Spruce and Lowland Conifer is not justified. These areas are neither unique nor rare.

Local forest managers must ask Congress for full funding of the timber program. The Forest Service Mission states the need to sustain health, diversity, and productivity of the nation's forest. The public process is in the EAS. Once the public process leads to a determination, special interests should not be able to file lawsuits, at the cost of the people of the United States.

The Organic Administration Act and the Multiple Use Sustained Yield Act should be used in preparing the Plan. Both protect users of the forests. The "Multiple-Use Sustained Yield Act" and "National Forest Management Act" direct the forest service to manage federal land for a broad range of resources. The plan must include acknowledgement of the numerous Civil Conservation Corps' plantations for future timber sources.

The proposed plan limits, and sometimes, prohibits uses and types of access in certain management areas. Federal lands should be managed under a General Forest Management Area, providing all users equal opportunity for use and access to forests, restricting no one.

Access in the Superior National Forest and Chippewa National Forest need to be maintained. The Superior National Forest has been leaning to treat forestlands outside the BWCAW as a buffer zone. The original intent of the forest was to bring people to the area and have an economic base to have stable communities. All of the forest should be available for recreational use. All the proposed alternatives, except the no action alternative, place restrictions on ATV and snowmobile use. Minnesota registration and license purchases show growth in these outdoor activities.

What is an unneeded road, and who determines? Decommissioned roads will affect some forest users, but no forest users will be affected by leaving the roads intact. The congressional intent of the "Organic Act" was to protect the "community stability" of communities affected by the management of federal lands. Although "community stability" cannot be defined by national agencies it is logical to conclude that some users and their customs and cultures are negatively effect by the decommissioning of roads and restricted access including prohibition of ATV or snowmobile use. ie: trapping, bough picking, commercial minnow trapping, berry picking, mushroom harvest, trapping, hunting, fishing, and logging, etc.

All through the plan restrictions have been placed on ATV and snowmobiles. Foresters and loggers cruise timber using these means. This has been historically done prohibiting it adds an undo burden on persons needing to survey large units. We know of no scientific studies and analysis on the type and amount of negative impact caused by ATV and snowmobile use. There is also some commercial and recreational use of motorized recreation. What is the justification used to propose the ATV/snowmobile ban and restrict the custom of motorized use?

Alternatives D and E - CWCS cannot support these alternatives. These alternatives appear to transfer management of more land from active timber management to wilderness/special designation. This is not consistent with Congressional intent of Public Law 495.

All through the plan the word aesthetic is used. Beauty is in the eye of the beholder. What are aesthetic values as referenced? The word spiritual is also used in the forest plan and is not defined.

The exchange of School Trust Lands and other lands whose management are restricted by the federal government should be a priority under the proposed plan. The exchange of these lands needs to be addressed to minimize the adverse economic effect to the people of the state of Minnesota, the effected communities, and most importantly the effect to our schools. For over twenty-five years, state lands within the Boundary Waters have not been able to generate revenues for our schools.

CWCS encourages the Forest Service to work with the Minnesota Department of Natural Resources to determine an equal value trade of state lands within the Boundary Waters for Forest Service lands outside of the wilderness area.

According to Minnesota Statute 127A.31 has determined that it is the goal of the Permanent School Fund to secure the maximum long-term economic return from the school trust lands consistent with the responsibilities imposed by the trust relationship established in the Minnesota Constitution, with sound natural resource conservation and management principles, and with other specific policy provided in State law. This law also states that if management decisions were found to be producing less than adequate income from certain trust lands, the trust fund would have to be compensated in some way for the loss of revenue.