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RGS Files Administrative Appeal to Chippewa National Forest
The Ruffed Grouse Society has unfortunately been forced to file an administrative appeal to the management decision on the Rice River Management Project of the Chippewa National Forest. The Deer River/Marcell Ranger District is ignoring the Chippewa's current Land and Resource Management Plan and implementing forest management practices designed to be detrimental to the regeneration of aspen forests and to the wildlife that thrive in aspen communities. During the appeal process, the Society will be encouraging the District to enact the original proposed action and regenerate 516 acres of aspen in the 30,000 acre project area. Following is the full text of the Society's appeal. Please don't hesitate to call if you have any questions. Rick Horton
Forest Wildlife Biologist
Ruffed Grouse Society218-697-2820
February 4, 2002 Regional Forester, Appeal Deciding Officer Attn: 1570 Appeals USDA Forest Service 310 West Wisconsin Avenue, Suite 500 Milwaukee, WI 53203Dear Appeal Deciding Officer,Regrettably, the Ruffed Grouse Society hereby registers notice of appeal of the Rice River Resource Management Project Decision Notice (Marcell/Deer River Ranger District, Chippewa National Forest) dated 26 December 2001 and signed by Wade Spang, District Ranger.This appeal is filed pursuant to 36 CFR 215 and is timely according to 215.13.The Ruffed Grouse Society sincerely appreciates the time taken by District staff to address certain issues raised by the Society regarding proposed project activities.However, the District's failure to address still other issues raised by the Society, and its failure to propose management activities consistent with Forest Plan direction forces the Society to utilize the administrative appeals process to compel the District to design a resource management project that meets public expectations as outlined in the Forest Plan.
The Society’s principle concerns include:
The District has capriciously altered the focus of this project from the initial proposed action, which managed the area toward the future condition detailed in the Forest Plan, to the selected Alternative, which moves away from the Plan’s desired future condition.
The Forest Plan for the Chippewa National Forest clearly and unambiguously states that the purpose of this project area (100% M.A. 1.1, 1.2 and 1.3) is to “…provide habitat for large populations of white-tailed deer, ruffed grouse, and woodcock…” Ruffed grouse are early successional forest specialists.Optimal habitats include young even-aged deciduous hardwood stands that typically support 20-25,000 woody stems/ha (Gullion 1984, Kubisiak 1985, Stoll et al. 1999, Dimmick et al. 1998).Aspen stands recently regenerated through clearcutting frequently exceed these stem densities and provide abundant protective cover for grouse.Aspen forests can support ruffed grouse population densities that greatly exceed those attained in other forest communities (Thompson and Dessecker 1997).Gullion (1984) demonstrated that optimal grouse densities are attained by managing aspen stands on a 40-year rotation, such that 25% of the forest is in each 10-year age class.This management regime will also provide abundant habitat for white-tailed deer and American woodcock.
The Plan further specifies that Management Areas 1.1, 1.2 and 1.3 should be composed of 51-80% aspen.Aspen forests currently comprise only 44% of national forest lands in the project area.Given the demonstrated importance of aspen to ruffed grouse, deer and woodcock and the clearly stated purpose of these Management Areas, it seems intuitive that the District would manage to increase aspen habitat from 44% of the project area to meet the Plan’s specification of 51-80%.The proposed action in the Pre-Decisional EA would have regenerated 516 acres of aspen and maintained, but not increased aspen acreage in the project area.
The selected Alternative would utilize silvicultural methods designed to inhibit aspen regeneration in favor of conifer (especially white pine) restoration, eventually leading to the conversion of aspen to conifers.Indeed, the prescription for the scant 112 acres of aspen regenerated through clearcutting with reserve trees specifies leaving “10 to 15 evenly scattered dominant or co-dominant aspen per acre” in an effort to reduce aspen suckering. The selected Alternative also prescribes shelterwood cutting, underplanting pine, thinning, manual release, intrastand diversification, landtype restoration, and “mature forest processes simulation” in overmature aspen stands.While the EA asserts that there are no immediate stand conversions planned for the project area, the Society feels that these efforts will lead to retyping treated stands from aspen to conifer in the near future.There is no scientific evidence that any of these actions will benefit early successional wildlife in any significant way.In fact, they are detrimental to ruffed grouse, American woodcock and white-tailed deer populations and will lead the project area away from the future condition outlined in the Plan.
The District uses Range of Natural Variability (RNV) estimates to abrogate its responsibility to manage according to the tenets of the Forest Plan.The Plan in no way mentions managing for historic conditions as a management objective for the District.
The District states in its rationale for non-selection of the proposed Alternative (FONSI pg. 13) that this Alternative would “move the project area away from the range of natural variation in terms of forest composition, thus impacting the ecosystems’ ability to maintain their health and sustainability.” The presumption underlying this statement is that the only healthy and sustainable ecosystem in northern Minnesota is a re-creation of the conditions that existed at the time of European settlement.This is entirely false, as there are innumerable combinations of forest types, age classes and patch sizes that would constitute a forest that is sustainable, healthy, and supports viable populations of the host of species found in the region.Management for past conditions is unrealistic in the face of the fact that 5 million people now inhabit Minnesota.The District must continue to manage the forest in the manner dictated by the 1986 Land and Resource Management Plan until such a time that the public, through the Plan revision process, requests differently.
Historic Range of Variability was a key element of the Committee of Scientists’ proposed Forest Service Planning Regulations in 1999.The concept was thoroughly rejected by most involved, including the Executive Team of Forest Service Research and Development.Deputy Chief of Research Robert Lewis explicitly stated, “..the concept and reference point of historic range of variability have little value in terms of reality in the 21st century…there is little utility in using them as a reference.In fact, there is great harm in suggesting them as possible ideals.”In light of this, decisions throughout the FONSI and analyses in the EA (pages 23-40, 96, 71, 73, 75, 77) based upon historic RNV forest composition, age structure and levels of wildlife populations are inappropriate.Indeed, the emphasis the District puts on RNV could lead one to conclude that the District has made an a priori decision on the future management direction in the Chippewa National Forest, rendering the plan revision public input process moot.
The District arbitrarily dismissed documentation submitted by the Ruffed Grouse Society concerning the appropriate use of GLO survey data in reconstructing the RNV estimates used by the District to justify the selected Alternative.
To reiterate the Society's concerns, GLO data can provide useful insight into preexisting landscape conditions, but biases inherent in data collection and temporal variability in disturbance frequencies must be taken into account - the District failed to do so.
Clearly, GLO survey bearing and line tree data are not random and, therefore, should not be taken at face value.It is simply not reasonable to suggest that surveyors randomly selected these reference trees, after all, their primary interest was to establish lines and corners that could be readily located at a later date. Bourdo (1956) provided an in-depth analysis of GLO survey data and found, "There can be little question that the selection of bearing trees was not strictly random.It is unreasonable to assume that it should be.When two or more trees were equally handy, it is inevitable that personal preference, as well as the condition and kind of tree, should dictate to some degree the one that was picked."The forests assessed during 19th century GLO surveys likely differed from those of only 400-500 years prior as a result of variation in disturbance regimes.Clark (1990) clearly documented through charcoal stratigraphic analysis that fire frequencies have varied significantly over the past 750 years in northern Minnesota.Clark explicitly states, "..fire was most frequent during the warm/dry 15th and 16th centuries.Intervals were longer during cooler/moister times from AD 1240-1440 and since 1600 (Little Ice Age)."It was during this cooler climatic period of the Little Ice Age, with documented less frequent fires, that the forests measured by GLO surveys developed.It is simply not reasonable to assert, as does the District, that RNV estimates based on GLO survey data are sufficiently broad to accurately reflect actual natural variability in the species composition and age-class structure of this region's forests.Clearly, RNV estimates based on GLO data likely overrepresent late-successional communities and old age classes, and underrepresented fire-dependent early-successional communities and young age classes.The recognition of this fact does not render GLO data useless in estimating RNV, it merely requires that these data be viewed as one component of a broader range, rather than as THE range or the mean thereof.It is disappointing that the District either didn't fully understand or chose to misrepresent the data and the conclusions of Dessecker (1997) concerning the likely cause(s) of documented changes in fire frequencies and their effects on reconstructions of historical conditions.Dessecker did not, as the District states, suggest a "direct one-to-one relationship between aboriginal population size and acres burned."Rather, Dessecker stated that reductions in native American populations likely led to reductions in fires of native American origin.The opinion presented by the District, that changes in native American population size had no effect on fire frequency simply belies common sense.To carry this perspective to a logical extreme, the presence of one native American on the landscape would lead to the same number of fires as would the presence of 10,000.The District's suggestion that the boreal forests of this region were less frequently burned by Native Americans than other forests on other landscapes is a reasonable assessment.However, that significant burning by Native Americans did occur on all landscapes to protect population centers from potential adversaries, to provide habitat for important game species, and to reduce insect pests, is hardly debatable (Day 1953, Pyne 1982, Krech 1999).
The salient point remains that fires were indeed less frequent in northern Minnesota during the Little Ice Age than during preceding and subsequent intervals (Clark 1990).Whether these reductions were caused by climatic variability, reductions in Native American populations, or both (likely), is irrelevant - these reductions did occur and they did affect the forests of northern Minnesota (Heinselman 1996), the same forests that were surveyed in the 19th Century.
The District's arbitrary dismissal of the Society's request to account for the documented variability in historical disturbance regimes and, therefore, in historical landscape conditions, undermines the foundation for the District's identification of the selected Alternative.
The selected Alternative will not provide sufficient young forest habitat to support early successional wildlife species, many of which are suffering from long-term population declines across their ranges.The requirements of these species are being arbitrarily ignored in a landscape that was intended to provide for their needs under the existing Forest Plan.
Ruffed grouse utilize young forest stands for drumming and brood rearing, as the density of stems offers protection from avian predators (Gullion 1984).Regenerating aspen stands are ideal.Older aspen stands provide nesting cover and winter food in the form of male flower buds (Gullion 1984). Long-term trends in ruffed grouse population levels are difficult to determine as the species exhibits a 10-year population cycle.However, drumming count data from the Minnesota Department of Natural Resources clearly show that population peaks for routes within the Chippewa National Forest are not as high as those for the rest of the North-Central Zone, and population lows are much lower.There may be many reasons for this trend, but a thoughtful observer could reasonably conclude that grouse habitat on the Forest is lacking in abundance and quality.
The habitat requirements of American woodcock are similar to those of ruffed grouse (Dessecker and McAuley 2001) with the exceptions that they need small forest openings for breeding displays and prefer to nest in young hardwood stands, especially aspen (Gregg and Hale 1977, McAuley et al. 1996).Singing Ground Surveys organized by the U.S. Fish and Wildlife Service suggest that woodcock populations in the Central region have declined by 1.6% per year since 1968 and by 3.1 % per year since 1990 (Kelley 2000).The 2000 Woodcock Task Force convened by the International Association of Fish and Wildlife Agencies concluded that woodcock population declines were due to reductions in shrub-sapling and young forest habitats.The District suggests in the 2000 Monitoring and Evaluation Report that woodcock populations are stable on the Chippewa.That fortunate situation will not continue if the District does not maintain current levels of young forest habitat.
Partners in Flight ranks the golden-winged warbler #1 in conservation priority in the Boreal Hardwood Transition zone and of Tier 1 concern, with 80% of the current breeding population existing in this region.Recent research clearly documents the importance of regenerating aspen communities for this species (Back, 1982, Collins et al. 1982, Fouchi and Gullion 1984, Wemmer 1993, Huffman 1997 and Roth 2001).The highest densities of golden-winged warblers occur in 1 4 year old aspen stands, with densities dropping sharply after stands reach 10 years of age (Roth 2001).Golden-winged warbler use of regenerating aspen stands is negatively associated with the amount of residual cover after harvest (Huffman et al. 1997).The District has the responsibility to create abundant quality breeding cover for this highly imperiled songbird by maintaining or increasing the amount of young aspen forest on this landscape, a responsibility the district arbitrarily dismissed.
Young forest habitats are by their very nature ephemeral, often offering the benefits of abundant available food and protective cover for only <20 years.Therefore it is imperative that enough forest be regenerated to replace that which has aged to the point of not affording these benefits.The District maintains 30,068 acres within the project area, 44% (13,230 acres) of which is typed as aspen forest.Eighteen percent (2,381 acres) of the aspen is in the 0-9 age class.It is safe to assume that within the 5-year life of this project, half of the 0-9 will mature into the 10-19 age class, while half of the 10-19 age class progresses into the 20-29 age class.Therefore, the District would need to regenerate 1,191 acres of aspen in the next 5 years in order to simply maintain the current level of young forest habitat in the project area.Regenerating only 112 acres of aspen under the selected Alternative will lead to a 45% reduction in 0-10 year old forest in the project area within the next 5 years.
Despite the District’s assertions to the contrary, the Society believes that this level and type of aspen management will not provide sufficient habitat for young forest species in the project area.The District’s decision to de-emphasize aspen communities on a landscape explicitly identified as targeting this objective is a clear departure from existing forest plan direction.
The Ruffed Grouse Society sincerely desires to work with the Forest Service to address the demonstrated conservation needs of early successional wildlife and the interests of sportsmen and sportswomen.However, we feel these issues were clearly given inadequate consideration in the Rice River Decision Notice.The Society requests that the Regional Office remand the Decision Notice and provide guidance to the District to formulate a project that adheres to the clear intent and direction of the existing Forest Plan.
Sincerely,
Rick Horton Forest Wildlife Biologist
LITERATURE CITED
Back, G.N. 1982.Impacts of management for ruffed grouse and pulpwood on nongame birds.Ph. D. Thesis, Univ. Minnesota, St. Paul.96 pp.
Bourdo, E.A.1956.A review of the general land office survey and of its use in quantitative studies of former forests.Ecology 37:754-768.
Clark, J.S.1990.Fire and climate change during the last 750 YR in northwestern Minnesota.Ecological Monographs 60(2):135-159.
Collins, S.L., F.C. James, and P.G. Risser.1982.Habitat relationships of wood warblers (Parulidae) in northern central Minnesota.Oikos 38:50-58.
Day, G.M.1953.The Indian as an ecological factor in the northeastern forest.Ecology 34:329-346.
Dessecker, D.R.1997.Back to the future - is the past a guide to a "healthy" forest landscape in the northern Great Lakes region?Transactions North American Wildlife and Natural Resources Conference.62:469-478.
Dessecker, D.R. and D.G. McAuley.2001.Importance of early successional habitat to ruffed grouse and American woodcock.Wildl. Soc. Bull. 29(2):456-465.
Dimmick, R.W., J.D. Sole, W.G. Minser, and P.E. Hale.1998.Response of ruffed grouse to forest management in the southern Appalachian Mountains.S.E. Assoc. Fish & Wildl. Agencies 52:294-302.
Fouchi, C.M., and G.W. Gullion.1984.Nongame bird response to aspen regeneration.Pages 218-229 in W. C. McComb, ed.Proc. of the workshop on management of nongame species and ecological communities.Univ. Ky., Lexington.
Gregg, L.E. and J.B. Hale. 1977.Woodcock nesting habitat in northern Wisconsin.Auk 94:489-493.
Gullion, G.W.1984.Managing northern forests for wildlife.Ruffed Grouse Society, Coraopolis, PA, USA.
Heinselman, M.1996.The boundary waters wilderness ecosystem.University of Minnesota Press, Minneapolis, MN.334pp.
Huffman, R.D. 1997.Effects of residual overstory on bird use and aspen regeneration in aspen harvest sites in Tamarac National Wildlife Refuge, Minnesota.M. S. Thesis, West Virginia University, Morgantown. 129 pp.
Kelley, J.R., Jr.2000.American woodcock population status, 2000.U.S. Fish & Wildlife Service.Laurel, MD, USA.
Krech, S.1999.The ecological Indian, myth and history.W.W. Norton & Co., New York, NY.318pp.
Kubisiak, J.F.1985.Ruffed grouse habitat relationships in aspen and oak forests of central Wisconsin.Wisc. Dept. Nat. Resour. Tech. Bull. 151.Madison, WI.
McAuley, D.G., J.R. Longcore, G.F. Sepik and G.W. Pendleton.1996.Habitat characteristics of American woodcock nest sites on a managed area in Maine.J. Wildl. Manage. 60:138-148.
Pyne, S.J.1982.Fire in America, a cultural history of wildland and rural fire. Princeton University Press, Princeton, NJ.654pp.
Roth, A.M. 2001.Impact of forest succession on shrubland-dependent birds in aspen forests managed with traditional and alternative clearcutting systems in Northern Wisconsin.M. S. Thesis, University of Wisconsin, Madison. 118 pp.
Stoll, R.J., Jr., W.L. Culbertson, M.W. McClain, R.W. Donohue, and G.P. Honchul.1999.Effects of clearcutting on ruffed grouse in Ohio’s oak-hickory forests.Ohio Dept. Nat. Resour., Fish and Wildl. Rpt. 14.Columbus, OH.
Thompson, F.R., III, and D.R. Dessecker.1997.Management of early successional communities in central hardwood forests.U.S. Dept. Ag. Forest Service, Gen. Tech. Rpt. NC-195,St. Paul,MN.
Wemmer, L.C. 1993.Avian diversity in managed aspen and northern hardwood forest in Minnesota.M. S. thesis, University of Minnesota, St. Paul.69 pp.
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