by Caroline Pufalt
Ozark Sierran readers, and especially those who receive the Chapter’s on-line conservation alerts, will remember that last year there was a lot of activity surrounding a new management plan for the Mark Twain National Forest (MTNF). The comment period for the draft plan ended in 2005 and the new plan was released in January 2006.
There were some things about the new plan that were laudable but there were enough disappointments in the plan that the Ozark Chapter decided to file an appeal along with four other groups: Heartwood; Missouri Forest Alliance; Ozark Riverkeepers Network; and Goods From the Woods. At the time of this writing (August 2006) we are in the process of informal talks with the Regional Forester for the U.S. Forest Service in hopes of settling at least some of our appeal issues.
I will explain in this article just a few issues in our appeal. In later issues of the Ozark Sierran I’ll update readers on the appeal’s status.
To help understand where we are requires a bit of background on forest planning. All National Forests are managed under a formal plan that is designed to last 10–15 years. There are several national laws which govern how National Forest plans should be developed. The law includes a mechanism for public comments and the ability to appeal decisions within the plan. The prior MTNF plan started in 1986, the new plan is dated 2005.
Forest Plans provide overall guidance for forest management. Each year the Forest Service carries out projects such as timber sales, trail construction, prescribed burns, etc. that should fit within the general Forest Plan. The plan may also commit the Forest Service to ongoing projects such as wildlife monitoring. A new Forest Plan is an opportunity to reconsider everything in the prior plan and add new issues if needed.
Mining Issues
During the planning process we asked for reconsideration of the 1986 plan’s criteria for mining in the MTNF, primarily lead mining. We have learned a great deal since 1986 about the health and environmental hazards of lead and the destructive mining practices of Missouri’s primary mining company, Doe Run. Unfortunately the Forest Service would not consider changes in the plan regarding mining. The topic was excluded from the “scope” of the new plan despite the many comments received from the public and the clearly controversial nature of the issue. The agency argued that congressional studies were underway which might affect this topic so no decision could be made now. In effect a decision was made to accept the outdated 1986 plan guidelines on mining.
If mining is not reconsidered in the 2005 plan there is no legal requirement for the agency to re-introduce the topic of mining to the public again until the plan expires. The prior plan was in effect for 20 years. We argue that the MTNF plan, by excluding consideration of mining impacts on the forest, violates those laws that require attention be given to public comments and that require the full range of important forest impacts be considered.
Wildlife Monitoring
Another topic covered in our appeal involves wildlife monitoring. The new plan requires the Forest Service to monitor wildlife in the MTNF, especially threatened or endangered species and other species which are good indicators of overall wildlife status. But it doesn’t require any direct species monitoring or counting. Much that the monitoring agencies do depends on databases and models. These are good practices, but they should be supplemented with some on the ground actual species monitoring, not just habitat reviews. Our position is that collecting actual population data is a necessary part of good monitoring. Direct species monitoring is time consuming and, therefore, tempting to postpone indefinitely. We argue that, without an actual commitment to do direct species monitoring some time during the life of the plan, it will be too easy for the agency to depend on less reliable methods. Several laws and precedents support our position.
Roadless Areas
The last topic within our appeal concerns roadless areas and sensitive areas. I’m sure we will discuss this topic again in later issues of the Ozark Sierran.
The 1986 plan included consideration of seven sensitive areas which received additional protections from logging and other intrusions without the highly protected official wilderness status. Unfortunately, these areas lost that extra protection in the new plan.
We would like to see those seven areas, and some other deserving sites, receive special consideration, and we would like to see that protection spelled out more directly than it was in the 1986 plan.
In addition, since the 1986 plan, the agency has further developed a process for identifying roadless area inventories. Based on rules started under the Clinton administration, if an area is officially designated as a roadless area, it can be protected from some intrusions. There is actually a long story here about how the Bush administration is trying to weaken this rule, but for now we know that roadless area designation is a good thing to work for in these special areas.
We think the MTNF grossly misapplied the roadless area rules in the 2005 plan. For example, in Lower Rock Creek the agency divided the area into smaller pieces than it should have. And it counted roads and structures which were simply not there in order to disqualify the area as roadless. Thanks to some intrepid volunteers (Jim Scheff and Jim Bensman) we were able to provide ground level and aerial pictures to disprove the agency’s allegations of roads and structures. For me this was a low point in Forest Service integrity.
I hope in a future issue of the Ozark Sierran I can report that the Ozark Chapter, with our coalition of forest activists, and with the support of readers of this newsletter, have succeeded in achieving a better plan for Missouri’s National Forest lands.
New Mark Twain National Forest Plan
In 2005, the Forest Service began work on the first Mark Twain National Forest Management Plan revision in 20 years. The new plan, released in January 2006, sets management direction for all activities on the 1.5-million-acre Mark Twain National Forest—timber, mining, wilderness, wildlife, etc.—for at least the next 10–15 years. After an extensive planning period with public input many of the concerns expressed by conservationists were left unaddressed in the final document. The Plan is thought to contain “serious legal, biological, economic and ethical flaws.”
New Mark Twain National Forest Plan
In 2005, the Forest Service began work on the first Mark Twain National Forest Management Plan revision in 20 years. The new plan, released in January 2006, sets management direction for all activities on the 1.5-million-acre Mark Twain National Forest—timber, mining, wilderness, wildlife, etc.—for at least the next 10–15 years. After an extensive planning period with public input many of the concerns expressed by conservationists were left unaddressed in the final document. The Plan is thought to contain “serious legal, biological, economic and ethical flaws.”