The Sierra Club has commented on the proposed Nebletts Creek Project (NCP) that the U.S. Forest Service (FS) recently proposed for Sam Houston National Forest (SHNF). The proposed NCP would do the following:
1. Thin (log) 2,674 acres of pine stands.
2. Thin 2,274 acres of midstory/overstory hardwoods with the focus on removal of Sweetgum/suppressed/poorly formed/diseased hardwood trees.
3. Broadcast burn 3 compartments.
4. Use existing county/state/forest system roads. Up to 1 mile of road construction/maintenance may occur.
5. Use a Categorical Exclusion (CE) to conduct a minimal environmental analysis and approve the decision.
6. The FS states the NCP proposal will improve timber stand viability; restore a more fire-adapted ecosystem; improve drought resistance by decreasing density of timber stands; improve foraging habitat for wildlife by decreasing overstory growth which allows understory vegetation growth.
Sierra Club comments on this proposal included:
1. Initiation of public collaboration.
2. Revise purpose/need to match ecosystem management.
3. Take historic/cultural significance into consideration.
4. Timber production is biased over ecosystem management.
5. Historic ecological forests are naturally dense; are part of an extensive/unique Loblolly Pine Belt; Loblolly Pine/mixed hardwood trees are dominant; hardwood trees are prevalent and sometimes dominant in upland/slope/bottomland positions; mixed forests of pines/hardwoods are normal; soils are sandy loam/clay subsoils; gently sloping/undulating/rolling hills are normal; NCP Area is part of the historic “Big Thicket” region; pure pine stands are small in size; Sweetgum grows naturally with Loblolly/Shortleaf Pine; thick undergrowth of shade-loving trees/shrubs/vines is a normal condition.
6. FS Ecological Classification System (ECS) documents uplands consist of mixed pine/hardwood forest; upland hardwoods are common in the Big Thicket; Sweetgum is common in uplands.
7. In Management Area 1 (MA-1, mixed pine/hardwood forests) there is no scientifically necessary reason to log overstory hardwood trees.
8. Creation/protection of snags/downed trees/den/cavity trees are key for ecosystem management.
9. Protection of mature/old growth forests in the NCP Area (4,860 acres) via inventories/evaluations/analyses/designations.
10. Climate change must be a significant issue analyzed/planned for in the NCP.
11. The most up-to-date best management practices (BMPs) to protect water quality must be used.
12. Variable density thinning (VDT) is used for pines, no logging of overstory hardwoods.
13. An environmental assessment (EA) or impact statement (EIS) must be prepared.
14. Site-specific environmental analysis/mitigation measures/monitoring provides for environmental protection.
15. Larger streamside management zones protect wildlife/water quality.
16. Don’t log Stand 5/Stand 23 in Compartment 97; do protect/manage Blackland Prairie Inclusions; don’t log Stand 1, Compartment 99, Loblolly Pine-Laurel Oak Flatwoods pond and similar ponds; don’t log Stand 4, Compartment 97, White Oak-Southern Red Oak-Hickory forest.
The Sierra Club will work with the FS to ensure that the NCP is as environmentally benign as possible via the use of ecosystem management. For further information please contact Brandt Mannchen, 281-570-7212 and brandt_mannchen@comcast.net.
Article and photo by Brandt Mannchen.