The Lone Star Chapter/Houston Regional Group of the Sierra Club (Sierra Club) sent the U.S. Forest Service (FS) a letter that asked questions and provided concerns/issues about a “briefing” that doesn’t provide a protected corridor for the Lone Star Hiking Trail (LSHT) in the proposed Montgomery County Wildlife Habitat Improvement Project (MCWHIP). This proposal will result in logging and mulching of the LSHT. Some of the questions and concerns/issues the Sierra Club brought up include:
1. Whether the “briefing” included the site-specific environmental analysis (SSEA) that is required by the 1996 NFGT Forest Plan and Record of Decision (ROD) for the protection of the LSHT.
2. Whether the FS plan that doesn’t provide a protective corridor for the LSHT has followed and undergone the deviation analysis that the Forest Plan requires. Pages 27-28, 1996 Forest Plan, ROD, state:
“Roadside and trailside zones have been given more guidelines for maintaining visual qualities than was provided in the 1987 Plan. National Recreation Trails, 4-C and Lone Star, will have a zone established where management will be applied that promotes scenic quality of the trailside zone.”
The “briefing” fails to examine the question of “Why the LSHT is Unique” and needs protection from management actions and activities like the proposed logging and mulching.
The LSHT's intrinsic value and uniqueness is as the only long distance, continuously marked, footpath in the State of Texas. The LSHT is the only maintained trail where a person can hike many days through the forests of East Texas with only Nature as company. This type of backcountry wilderness-like experience is important to provide for the public.
Hikers come to protected footpaths to experience Nature in peace, listening and watching only the sounds and sights of Nature. This type of experience is extremely rare in today's world. The LSHT allows the public a place to explore Nature, the ecosystems of East Texas, and along a path with plenty of room for the over 9 million residents that live within a three-hour drive of the LSHT.
The LSHT's status as a protected footpath makes it unique and should be preserved at all costs. Any loss of this status means a loss of most of the protected footpath-only trail miles available to the public in the NFGT.
This would be a tragic loss for the citizens of Texas. It is extremely important to realize and distinguish that the LSHT is UNIQUE as a footpath. There just aren't many other places to tell people to go for this type of experience. “Forever” protection is what is needed for the LSHT.
The LSHT is also a historic trail. The 57-year-old LSHT is one of the oldest recreational trails that exist in the State of Texas. The LSHT is an important part of Sierra Club and conservation history in Texas.
As the longest, continuous, cross-country, wilderness-like hiking trail in the State of Texas (128 miles) the LSHT outranks Big Bend and Guadalupe Mountains National Parks, Big Thicket National Preserve, and Davy Crockett, Angelina, and Sabine National Forests for wilderness-like long distance hiking trails. There is nothing like the LSHT in Texas. The LSHT should be treasured, not compromised.
The LSHT provides hikers with different trail experiences and protects them from being displaced by mechanized users. Hikers on the LSHT often participate in multiple uses like appreciation of quiet, solitude, and natural sounds; birding; Nature study; wildlife observation; environmental education; tree identification; mushrooming; wildflower viewing; and similar uses. Safety concerns about mechanized uses can result in distraction, loss of focus, and loss of experiences that hikers seek. These are some reasons that the LSHT is unique and should be protected by the FS in the proposed MCWHIP.
3. The Sierra Club is concerned that the FS is biased against protection of the LSHT. The FS states in the MCWHIP proposal, for Timber thinning (logging), that “scenic quality and recreation opportunities” along the LSHT will be improved by the proposed logging.
Pages 214-216, 1996 Forest Plan, Environmental Impact Statement (EIS) state:
“The trail systems were originally planned and designed to provide a representative cross section of a managed forest environment. It was designed to work in harmony with other resource management activities, while neither dominating nor being subordinate to them. It was recognized that this would involve compromise between trail management and other resource management activities.”
Pages 6-7, 1996 Forest Plan, ROD, state:
“Recreational Pursuits: Many common activities will continue; however, increasing activities on favorite areas will require more restrictive measures to protect the environment.”
Pages 46-47, 1996 Forest Plan, state:
“d. Manage trails to enhance recreation opportunities yet emphasize protection of resources and reduction of conflicts with other users.”
The “briefing” doesn’t provide “visual quality objective standards” or maps, discuss or explain these, and doesn’t emphasize “protection of resources and reduction of conflicts with other users”.
This need to compromise “between trail management and other source management activities” but require “more restrictive measures to protect the environment” has been forgotten by the FS in the “briefing”.
The FS fails to state that logging trees along and next to the LSHT decreases shade, which with human climate change increased temperatures means that hikers will have to deal with hotter temperatures, for longer, with less shade. This could lead to safety and health problems for those who hike on the LSHT.
Logging destroys scenic quality and leaves a long-term visual degradation via slash, log landings, and openings with debris that thinning and clearcut logging create.
Pages 11-12, 1996 Forest Plan, state:
“One of the major concerns is for protection of trails and trail areas from other management activities …”
The FS fails to provide discussion and documentation about protection of trails from other management activities and increased compaction and erosion due to logging on and or next to the LSHT.
The FS doesn’t discuss that thinning (logging) next to or near the LSHT causes the loss of vegetative diversity and the interception of raindrops. This increases the potential for rivulet/gully erosion by the increase in raindrop impacts on soil. Page 73, 1996 Forest Plan, FW-158, requires that the FS conduct:
“Trail planning, design construction and maintenance will conform to the USFS Trails Handbook and/or the Trails South Guide.”
There is no mention of Trails South Guide and or the USFS Trails Handbook in the “briefing” and what is required by those documents that will be implemented for the protection of the LSHT.
The “briefing” fails to discuss what mitigation measures will be used to ensure that the LSHT is protected. Pages 75-77, 1996 Forest Plan, FW-185, state:
“Include scenic resource assessment and recommendations during project analysis for proposed actions. Consult the Scenic Resource Management matrix for guidance during project analysis for management actions that affect the visual resource. Specific project situations may require additional site-specific information during analysis to address scenery and visual quality."
The “briefing” doesn’t review the Scenic Resource Management matrix so the FS can take advantage of its’ guidance to protect the LSHT. Page 81, 1996 Forest Plan, FW-204-11, states:
"Vegetation along trails is treated to maintenance levels identified in the publication "Trails South". Priority is given to correcting unsafe conditions, preventing resource damage, and providing for intended recreation experience level.”
The “briefing” doesn’t discuss this or propose anything “correcting unsafe conditions, preventing resource damage, and providing for intended recreation experience level.” Page 106, 1996 Forest Plan, MA-2-51, states:
"Meet partial retention visual quality objective (VQO) for management along … trails”.
“a. These designations should refer to established VQO maps.”
“b. Favor midstory trees that provide high visual characteristics such as spring flowering and all coloring along travelways.”
The “briefing” doesn’t discuss these points, what the “established VQO maps” are, and what these maps mean for the proposed MCWHIP. Page 106, 1996 Forest Plan, MA-2-53, states:
"Modify timber management practices on visually sensitive areas to maintain or enhance the visual resources, as described in the USFS VQO Handbook and in FW-185.”
The “briefing” doesn’t discuss this mitigation measure and whether it will be implemented. FW-158 d., 1996 Forest Plan, states:
“Designated trails will have a management zone corridor up to 300 feet as/or appropriate for type of trails use; these corridors are to enhance the recreational experience and will be determined through site specific analysis.”
No trail corridor has been planned by the FS for the proposed MCWHIP with mitigation measures via site-specific analysis.
This failure of the FS to use FW-158 d. turns this guideline on its head so that it’s not used by the FS for the protection of the LSHT. This guideline hasn’t been used recently by the FS for any proposed project that affects the LSHT.
The FS nullifies the definition of this guideline because it doesn’t use it. This isn’t unusual. The Sierra Club hasn’t seen a FS-initiated project in SHNF which creates a LSHT corridor during most of the 28 year-old Forest Plan’s history.
The FS isn’t specific about what scenic quality is, how it’s determined, how it will increase on the LSHT due to logging, and how the recreational opportunities will increase along portions or all of the 2.5 miles of the LSHT that are found in the proposed MCWHIP.
4. In the MCWHIP, for Timber stand restoration cuts, planned by the FS in the “briefing” the FS states that clearcutting will “Increase the diversity of canopy species for users experience and enjoyment.”
Clearcutting, and the implementation of even-aged management, which includes prescribed burning, thinning (logging), mulching, site preparation, and planting, reduces the diversity of canopy trees. This is because the FS manages specifically for Shortleaf Pine trees in the MCWHIP and other canopy trees are logged, wounded, or killed in timber stand restoration cuts (clearcutting).
Hardwood canopy trees are destroyed, degraded, or wounded by clearcutting. Any canopy hardwood trees that survive clearcutting often have: a. Wounds on the bark; b. Broken or damaged root systems; c. Suffer sun scald since they are left growing alone in the climate change induced increased temperatures and are no longer growing in a forest where they have protection from too much sun; and d. Are exposed to winds which result in more blowdowns.
From historical records we know that there were extensive and dominant numbers of mature and old-growth trees in SHNF. We know this by their size, number, density, and the tree boughs (in board feet) that were removed via logging.
A denser, diverse, mostly mature or old-growth forest was the legacy of natural disturbance, regeneration, succession, and growth in most of SHNF. The FS provides no documentation that users want to see logged areas, log landings, bulldozed areas, skidders at work, feller-bunchers at work, and pine plantations instead of diverse mature or old growth forests and the beauty, shade, and biological woody diversity of both hardwood and pine trees on the landscape.
The FS hasn’t provided in the “briefing” any information that these mature and old growth forests aren’t desired by the public. When the 1996 Forest Plan was discussed and planned the public didn’t say it wanted more clearcuts. The public said it wanted more wilderness areas and mature and old growth forests. This general public desire continues today.
5. The FS refers in the “briefing” that it will “dramatically increase the viewshed qualities for users”. The FS doesn’t say what these “qualities” are and hasn’t documented them.
The FS doesn’t document in the “briefing” how much “increase in hunter accessibility” will be provided. Since hunters aren’t supposed to hunt or aim their guns toward or near the LSHT, the idea that there will be an “increase in safety for hikers” isn’t true because there will be more hunters and more chances for hunting accidents.
The FS provides in the “briefing” no documentation that this “increase in accessibility” won’t create more safety hazards for hikers on the LSHT because there will be more hunters in the same area where hikers are. The need for better management for hunting is found on Pages 29-30, 1996 Forest Plan, ROD, states:
“The Recreation issue includes developed recreation site management, dispersed recreation, hiking … visual quality … Other concerns included in this issue are cultural resource management and law enforcement.”
“The strategy … is designed to reduce conflicts between hunters and other users through certain standards and management area allocations; better monitoring of hunting and other recreational activities to define potential overuse … and other violations.”
The FS in the “briefing” doesn’t address this inherent conflict between hunting and hiking, the provision of more access for hunting, and what this means for those who want to hike the LSHT.
6. The FS states that mulching “temporarily decreases midstory species diversity”. This statement is inaccurate.
The FS ignores that once mulching is conducted it must be followed by prescribed burning every 1-3 years. This means that mulching is inextricably linked to burning. Since Red-cockaded Woodpeckers (RCW) are managed so there is almost no midstory, midstory species will be eliminated or depressed in numbers to less than 7 feet, which is shrub height and not midstory height, for decades or forever. This is not temporary.
The FS fails to state that mulching causes environmental impacts including more smoldering after burning. The Sierra Club has provided the FS with a document which provides mitigation measures for mulching environmental impacts. The FS hasn’t committed to implementation of these mitigation measures.
The FS refers to an increase in midstory biodiversity via mulching. Neither grasses nor forbs are part of the midstory, but the FS lists them as such. This isn’t scientifically accurate.
Mulching wounds or kills trees that have grown into the midstory or soon will. Mulching along with the clearcutting and thinning, site preparation, machine planting, and burning will result in a reduction of woody species found in the midstory. This decreases woody biodiversity and the biodiversity of animals that depend upon woody plants and the ability of hikers to enjoy this biodiveristy.
The decrease in midstory woody vegetation may increase site distance but doesn’t ensure that there are “additional opportunities for nature observers”. Many species are eliminated or reduced by mulching, logging, and burning which means that food, shelter, snags, and woody debris are reduced and this will affect wildlife numbers or presence. In addition, some wildlife like more dense forest structure, like Yellow-billed Cuckoo and Yellow-breasted Chat. These species will be more difficult to observe and will be rarer due to MCWHIP.
The FS refers to “improved scenic quality and recreational opportunities” but doesn’t explain what this means, how this is measured, what VQSs are used for different forest topographies, including uplands, slopes, terraces, levees, bottomlands, and streamside management zones. The LSHT goes through all these topographic areas.
The FS refers to more openings in the tree canopy so that trail corridors (which the FS hasn’t proposed to establish on the LSHT) dry out quickly but doesn’t provide any analysis about where this may be helpful, where it wouldn’t, and ignores that fewer trees alongside or near the LSHT means less shade, more soil erosion, and more sediment water quality run-off because raindrop interception by trees is reduced.
The FS should discuss with the Sierra Club and public these questions and concerns/issues. The Sierra Club will continue to press the FS to protect the LSHT and the diverse forest ecosystems in SHNF.