Indiana Forest Alliance P.O. Box 1074 Bloomington, IN IndianaForestAlliance.org

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1 Indiana Forest Alliance P.O. Box 1074 Bloomington, IN IndianaForestAlliance.org May 27, 2016 Submitted via electronic mail portal at Indiana Division of Forestry 402 W. Washington, Room W-296 Indianapolis, IN RE: Morgan Monroe State Forest, Compartment 4, Tract 8 posted April 29, 2016 Dear Division of Forestry (DOF) staff, Please accept the following comments on behalf of the Indiana Forest Alliance regarding the proposed amendment and the original Draft Resource Management Guide (DRMG) for Morgan Monroe State Forest, Compartment 4, Tract 8 posted April 29, These comments have been submitted within 30-days of the documents posting on the Division s website and therefore should be considered in any final determination and implementation of the proposed DRMG in management of the public s state forest property. Comments: 1) The proposed DRMG does not contain a pre-harvest wildlife inventory. A wildlife inventory is essential to determine the impact that the prescribed timber harvest will have on wildlife present not only in this specific tract and compartment but adjoining tracts and compartments, and the entire state forest. Indiana s state forests provide some of the last suitable habitat in the state for such rare, threatened, or endangered species (RTEs) 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 frog species 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 the interior forest. (Jackson, 2014) 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 which rely upon interior, intact forests for successful Protecting Indiana s Public Forests

2 reproduction and survival, with considerably fewer threats of nest predation and displacement by generalist species. 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, along with plant species found in the understory and herbaceous layers. 2) IFA is highly concerned with the impact that a timber harvest as proposed in the DRMG would have on state and federally listed rare, threatened, and endangered (RTE) species. This tract falls in the heart of the five-mile buffer zone of a juvenile or female Indiana bat capture locations near DOF land, which makes management activities within this tract subject to US Fish and Wildlife Service (USFWS) Forest Management Guidelines to prevent take of the Indiana bat. The DOF should abide by the forest management guidelines issued by the US Fish and Wildlife Service s Bloomington Field Office (BFO) to prevent take of the Indiana bat. More specifically, IFA believes the best forest management approach to preserving critical Indiana bat habitat is to leave these areas completely undisturbed. A hands-off management approach to areas where the Indiana bat have been identified or may be present is the only way to ensure that no incidental take of Indiana bats occur and that the current abundance of potential maternity roost trees remain viable. With Indiana bat populations under heavy assault from the white nose syndrome epidemic, any disregard for the USFWS Indiana bat Forest Management Guidelines is reckless and irresponsible, and it betrays a dedication to board feet production above all else, including preservation of critical habitat for this state and federal endangered species. IFA requests the DOF explain in the response to comments what on-site practices are employed in the absence of a wildlife inventory prior to the commencement of logging operations to guarantee Indiana bats and other RTE species are not present on the the tract(s) in order to insure no incidental take occurs? According to Indiana bat experts, females prefer to roost in mature trees in deep forests with dense canopies and many roosting trees to choose from. Therefore, it should be a priority for the DOF to preserve as much of the most suitable habitat for this critically endangered species as possible. The DOF should abide by the forest management guidelines issued by the US Fish and Wildlife Service s Bloomington Field Office (BFO) to prevent take of the Indiana bat. More specifically, IFA believes the best forest management approach to preserving critical Indiana bat habitat is to leave these areas completely undisturbed. A hands-off management approach to areas where the Indiana bat have been identified is the only way to ensure that no incidental take of Indiana bats occur and that the current abundance of potential maternity roost trees remain viable. Finally, the viability of nesting habitat for many forest interior birds will be harmed by canopy openings of the size proposed in this DRMG. The cerulean warbler and particularly the worm-eating and black and white warblers, which have been

3 documented as ground nesters in Morgan-Monroe State Forest (Mumford and Keller) and listed as "species of special concern" in Indiana, are specifically at risk from logging disturbances. The openings proposed in the DRMG will invite more predation and parasitization of these species by cow birds which ground nesters are particularly vulnerable to. 3) The tract is deficient in small size snag classes for Forest Snag Density as defined by the Management Guidelines for Compartment-Level Wildlife Habitat. Legacy trees, snags and roost trees as defined by the Resource Management Strategy for the Indiana Bat on State Forest Property and the Management Guidelines for Compartment-Level Wildlife Habitat Features should be retained as habitat for the Indiana bat and other RTE species and wildlife. The proposed DRMG should evaluate whether this compartment and tract is viable for designation as High Conservation Value (HCV) or inclusion as Old Forest Areas, as defined in the DOF s 2008 Oak-Hickory Environmental Assessment (EA) and required for Sustainable Forestry Initiative (SFI) and Forest Stewardship Council (FSC) certifications. 4) This tract contains mapped intermittent streams. The steep slopes and valleys present on these tracts create erosion hazards that threaten soil suspension and water quality. The exceedingly steep slopes directly uphill from the intermittent streams on this tract are particularly vulnerable to severe soil runoff. In the event of a timber harvest, these areas should be avoided entirely or at minimum protected by a 100-foot riparian buffer. Despite Best Management Practices (BMP) training conducted by the DOF, IFA has recorded gross violations of BMPs on state forest land, including unmitigated skid trails running directly into intermittent streams after a harvest, drainages that are filled with tree tops and other debris, and trees marked for harvest within just a few feet of waters of the US. The slopes and soil type that are most predominant in this tract serve to only increase concerns for such violations, whether they occur from operator neglect or the inevitable heavy soil disturbances resulting from commercial harvests. 5) The proposed DRMG prescribes a sanitation harvest of all ash trees in the tract. The conclusion that preemptively removing ash would slow the spread of EAB is not founded in the latest science, as the most current research on EAB suggests that removing ash trees does not slow, and only exacerbates, the spread of the invasive pest. Research by the US Forest Service Northern Research Station has found a positive correlation between ash density and ash survival rates. (Knight, Brown, & Long, 2013) Further, the rate of EAB spread by contaminated vehicles, equipment, and wood products is ten times the rate at which it would spread on its own accord. (Bossenbroek, et al., 2009) By logging all of the ash trees on this tract, the DOF will be eliminating the ash species genetic diversity, thereby eliminating a valuable opportunity for research into genes potentially resistant to the EAB and lessening the prospects for resistant ash trees and indeed the entire suite of ash species to survive the EAB infestation in Indiana.

4 6) The DRMG recommends control measures for the exotic invasive species - Japanese stiltgrass and Multiflora rose. IFA supports non-herbicidal control efforts to eradicate exotic invasive species. The prescribed commercial timber harvest in the proposed DRMG would likely lead to the spread of the identified exotic invasive species and the introduction of new nonnative invasive species (NNIS) in the tract. Research by Angie Shelton, formerly of the Indiana University Research and Teaching Preserve, documents the rapid spread of Japanese Stiltgrass into sites that were recently logged. (Shelton, 2011) According to Dr. Timothy Brothers, Associate Professor of Geography at Indiana University-Purdue University Indianapolis, Invasives are kept from invading more natural forests mainly by dense shade, undisturbed forest floor, and lack of access from outside. Timbering in the state forests is likely to encourage alien invasions via all three of these means. Opening of the canopy will provide the light necessary for invasion [of exotic species]; even selective logging is sufficient. Disturbance of the forest floor, inevitable even in the most painstaking logging operations, will reduce competition from native understory plants and provide the bare seedbed some of these plants need. (Brothers, 2013) If the DOF is truly dedicated to reducing the spread of invasive species in Indiana s forests, then forest canopies intact and reduce the network of roads and logging yards in state forests. 7) The proposed DRMG completely neglects the impacts that this proposed timber harvest would have on the tract s ability to store carbon and sequester CO2 from the atmosphere. Climate change is perhaps the single greatest threat to our environment; a forest s role in mitigating climate change, both on a global and local scale, must be addressed in order to fully assess the comprehensive environmental impacts of the silvicultural prescription in the proposed DRMG. Recent studies have shown that a mature forest continues to sequester carbon from the atmosphere at a much higher rate than a young forest. (Stephenson, 2014) Once a forest has been logged, it takes more than a decade for the forest to complete a full recovery of the carbon storage that was lost during a timber harvest. (Williams, Vanderhoof, Khomik, & Ghimire, 2014) The DOF should put into place a standard for evaluating the cumulative impacts of its forest management practices on climate change, including effects on the forest s capacity for carbon storage, carbon sequestration, and carbon releases caused by proposed timber harvests and other management activities. This evaluation should consider the cumulative impacts of all state and federal forest management projects across the state, and it should include the subsequent uses of forest products once they have been extracted, including transportation or refinement of any carbon-based material removed from the forest. This evaluation should be made available for public review in each new DRMG posted by the DOF.

5 Due to an incomplete analysis of cumulative effects of the silvicultural prescription described in the DRMG, as well as the adverse impacts on critical habitat and ecological services this tract currently provides, IFA opposes the commercial timber sale prescribed for this tract. Please provide a response to these comments at the address listed below. Thank you for your time and consideration of our comments. Sincerely, Jason Flickner Conservation Director Indiana Forest Alliance P.O. Box 1074 Bloomington, IN Works Cited Bossenbroek, J., Finoff, D., Iverson, L., Prasad, A., Sydnor, D., Croskey, A.,... McDermott, S. M. (2009). The Bioeconomics of the Emerald Ash Borer Invasion in Ohio and Michigan. Retrieved December 27, 2014, from Farm Foundation: Brothers, T. S. (2013, Fall). Logging and Invasive Species. The Forest Defender, p. 13. Jackson, M.T., Whitaker J.O. Interior Forests in Indiana. The Forest Defender (Winter, 2014), p. 5. Knight, K. S., Brown, J. P., & Long, R. P. (2013). Factors affecting the survival of ash (Fraxinus spp.) trees infested by emerald ash borer (Agrilus planipennis). Biological Invasions, Mumford and Keller, (1984) THE BIRDS OF INDIANA, p. 276 Shelton, A. (2011, January 26). Maps of Japanese Stiltgrass Spread. Retrieved January 14, 2015, from Indiana University Research and Teaching Preserve: Stephenson, N. e. (2014, March 6). Rate of tree carbon accumulation increases continuously with tree size. Nature, pp

6 Williams, C. A., Vanderhoof, M. K., Khomik, M., & Ghimire, B. (2014). Post-clearcut dynamics of carbon, water and energy exchanges in a midlatitude temperate, deciduous broadleaf forest environment. Global Change Biology, 20(3),