Wisconsin Department of Natural Resources

Comments on Chequamegon-Nicolet National Forest Plan Revision

August 2003

The Department’s comments have been framed around the four major topics identified as the focus of the Plan revision process:  Access and Recreation opportunities, Biological Diversity, Special Land Allocations and Timber production.  Additional comments have also been included on important facets of land management not addressed in detail in the proposed Plan revision.

ACCESS & RECREATION OPPORTUNITIES

Motorized Recreation

The proposed forest plan outlines four general policies that are consistent regardless of alternative.  They are:

·         No off trail or off-road use

·         No intensive-use or play areas

·         National Forest roads and trails are closed to all-terrain vehicles unless posted open

·         People with disabilities may apply for permits to use all-terrain vehicles for designated access

The prohibiting of off-trail and off-road use is going to have the biggest impact on the Chequamegon side of the forest where the historical management philosophy has been “open unless posted closed”.  Beyond posing challenges for enforcement of a change in historic use patterns, this change may place an increased pressure on formalized trail opportunities for both trail users and other users using all-terrain vehicles for other purposes, e.g. berry picking, hunting, etc.

Recommendation:

Ø      The Department supports these recommendations for the forest plan.  These policies are consistent with the operating practices and policies of the Department in the management of its lands. 

Standards and Guidelines for Off Road Vehicle Use and Construction, Reconstruction and Use of Motorized Trails

The forest plan sets standards, which are required courses of action or levels of attainment that are mandatory, and guidelines, which are also required courses of action or levels of attainment, but may be adjusted or modified on a site specific basis if conditions warrant.  The plan outlines standards and guides for both off road vehicle use and for the construction, reconstruction and use of motorized trails.  Currently the guidelines for construction, reconstruction and use of motorized trails contain a statement “Avoids (when possible) wetlands, riparian areas, stream crossings, sustained grades of 5% or more…”.  While the Department was going to refrain from small comments on the standards and guidelines, this citation of 5% does have ramifications in terms of siting and construction of the number of miles of new trail or connector trail presently allowed in the draft.  A 5% slope is the now federal law for accessibility of pathways for folks with disabilities.  Simply put, 5% is pretty flat, whether the slope is sustained or not (and currently the guideline does not define the meaning of “sustained).  Presumably this percentage relates to forestry BMPs produced by the Department.  The BMP for skid roads speaks to avoidance of slopes greater than 15% without any mention of whether the slope is sustained

Recommendation:

Ø      The Department supports the proposed standards and guidelines for off road vehicle use and recommends modifying the guideline for the construction, reconstruction and use of motorized trails to reflect a more realistic slope that serves as a guideline.

Maximum Miles of ATV Trails and Connectors:

In terms of the potential for growth of new all-terrain vehicle trails and connectors, preferred alternative 5 lies somewhat less than 50% of the difference between no growth and maximum growth.  The preferred alternative anticipates that there will be no new trail systems that arise in the Chequamegon side of the forest.  It does, however, allow 50 miles of connector route or trail to be constructed that may be necessary or desirable to complement or support a trail or trail system that emerges from other trail sponsors.  The preferred alternative offers the most potential for the Nicolet side of the Forest where presently there are no existing public trail riding opportunities.  The recommendation for both new miles and new connectors is roughly in the middle of the range of alternatives considered.

The plan currently distinguishes new miles of trails from connector miles of trail or road.  It would give Forest Service personnel more flexibility by removing the distinction between new miles and connectors in terms of the totals, i.e. 50 miles of new or connector trail on the Chequamegon and 85 miles of new mile or connector trail on the Nicolet.  However, the distinction in the standard and guidelines between new miles and connectors could still remain, i.e. new miles should not be located within areas designated as least suitable for ATV use while connectors may be located in any portion of the Forest that is not specifically designated as non-motorized. 

Recommendations: 

Ø      The Department supports the number of new trail miles and connectors outlined in the preferred alternative.

Ø      The Department recommends that the mileage for new trail and connectors be combined for maximum flexibility, i.e., 50 miles for the Chequamegon and 85 miles for the Nicolet.

Ø      Maintain the statements in the guidelines for new trails and connectors, i. e.

v     Locate new all-terrain vehicle trails outside of areas identified as least suitable for such uses

v     New all-terrain vehicle connectors, with appropriate mitigation measures, may be located in any portion of the Forest that is not specifically designated as non-motorized.

Ø      The Department supports designating connectors with outside trail systems as high priority.

Designating Roads Open for ATV Use:

The preferred alternative provides for the use of all-terrain vehicles on roads designated for use during the 3-1/2 months of the fall hunting season.  These roads so designated would be in addition to any roads that serve as part of an officially recognized trail or trail connector route.  Designations would take place at the district ranger level.  In previous discussions with Forest Service personnel, there has been some thought of extending this period to 9 or 10 months.  The 2 to 3 month closure period would correspond to a uniform spring break-up period across the forest.

It should be noted that the Department does not currently have the statutory ability to designate roads through its properties and under its management that are open for motor vehicle use as available for all-terrain vehicle use (i.e. as an all-terrain vehicle route).  The ability to designate routes is only given to towns, villages, cities and counties under s. 23.33(8)(b), Wis. Stats.

The blending of two diametrically opposed forest policies regarding ATV use is going to be problematic for the Forest Service.  On the Chequamegon side, the “open unless posted closed” policy has fostered a historical pattern of use over the years.  Removing off-trail use and restricting use to only designated trails is going to be a considerable change in the use patterns on this side of the forest and will pose enforcement problems in and of itself.  Opening up designated roads for the hunting season is a recognition of historical use and deals with a broader, more dispersed public than the organized trail riding community.  Expansion of this opportunity to 9 or 10 months may serve to reduce the implementation problems involved with signing and educating the public on the designations.  On the Chequamegon side, this potential for opening designated roads may reduce some of the pressure for the implementation of the “closed unless posted open” policy and a large-scale change of historical use.

On the Nicolet side of the forest, the proposal to allow the use of designated roads for any period of time is something that has not existed in the past.  The weight of past practice and policy would lead one to believe that implementation of such an opportunity on the Nicolet side of the forest would be slow in coming because of the historical policy/practice to not allow such an activity.  However, the potential for public pressure to influence a local decision-maker is cause for concern.  Shifting the authority to make this decision to the Forest Supervisor would promote coordination between Ranger Districts and other public entities.  It would also relieve some of the local pressure from the District Ranger.  

The Department is also not in favor of opening up road use specifically to accommodate hunting (3.5 month period).  There are concerns over the ethics of using mechanized equipment for hunting as well as concerns for trespass, resource damage and invasive species introduction when ATV’s fail to remain on the road system.  Any opening of roads for motorized recreation should incorporate adequate enforcement and a sound monitoring plan to annually evaluate any increases in off-road use, safety issues, resource damage and invasive species introduction. 

While there has been some discussion on establishing an upper limit on the number of roads that might be considered for designation, it is acknowledged that it is difficult to factually establish a defensible range.  There has also been a concern voiced that establishing an upper limit tends to establish a goal.

Recommendations:

Ø      With some reservations, the Department supports the opportunity for designation of roads of maintenance level 3, 4 or 5 for all-terrain vehicle use.  We further recommend that the period be increased from 3-1/2 months to 9 or 10 months to foster less confusion on the part of the public and operational concerns for the Forest Service. The authority to open roads for motorized recreation should rest with the Forest Supervisor.  Adequate enforcement and an annual monitoring plan should be implemented to evaluate this practice.  The opening and closing dates for ATV trails, including roads used as trail connector routes and designated road routes, should be the same to minimize confusion to the user.  If there are combination ATV and snowmobile routes, they should be clearly designated and marked.  

Designated 4-Wheel Drive Trails:

The preferred alternative calls for the maintenance of the existing 25 mile Pipeline Trail and offers the potential of adding one additional 4-wheel rive trail of a maximum of 25 miles in length.  The development of the Pipeline trail was the product of a federal recreation trails program grant issued by the Department to the Wisconsin Four Wheel Drive Association.

Recommendation:

Ø      The Department recommends continued maintenance of the trail and that the Forest should remain open to a future opportunity so long as there is a stipulation for monitoring and that a maintenance agreement be secured.  

Non-Motorized Recreation

According to the Wisconsin Statewide Comprehensive Outdoor Recreation Plan 2000-2005 (SCORP), 24.3% of Wisconsin residents participate in hunting while 48.4% hike, 40.1% bird watch, 33.4% participate in nature photography, 21% mountain bike, 48.1% bicycle, 10.8% cross-country ski and 59.5% participate in wildlife viewing.

The Department acknowledges the interest in these types of recreation and supports the CNNF in providing this type of experience. We commend the recommendation to eliminate off-trail / cross county use of motorized vehicles.  This type of use has potential to disrupt on-trail non-motorized recreation, create environmental damage and pose safety issues.  The Department understands the primary objective for the Forest is to “sustain the health, diversity, and productivity of the Forest…” (USDA Forest Service Strategic Plan 2000). We are generally supportive of the proposal in the preferred alternative, but note that it is on the low end of the number of acres of non-motorized recreation.  Objectives common to non-motorized recreationists are suitably addressed in Objective 2.1a (P. 1-4, R9-CN-FP-0403). The Department also concurs with Objective 2.1g (P. 1-4, R9-CN-FP-0403) which addresses the goal of managing remote camping areas to minimize environmental impact while continuing to provide such facilities.

A segment of Wisconsin hunters desire to hunt in a remote, primitive setting with low hunter density. The National Forests provide the best opportunity for this hunting experience. The active forest management permissible under MA 6B or MA XX.0 is preferable on a large scale for non-motorized recreation.

Recommendation:

Ø      The Department recommends that the CNNF seek to provide a broad range of non-motorized recreational opportunities within a variety of appropriate management and special designation areas, as well as in the SPNM/Wilderness MAs. 

Ø      The Department would be supportive of the CNNF’s efforts in exploring opportunities to create some separated use trails, including separated non-motorized uses, where a maintenance and monitoring agreement can be secured with local users or user groups.  The incompatibility of some non-motorized uses should be recognized. 

Ø      The Department supports the Standards and Guidelines for High Scenic Integrity Objective (SIO) travelways (Pgs. 2-37 to 2-41, R9-CN-FP-0403), which includes mention of Wisconsin’s two National Scenic Trails, both of which are partially located in the CNNF.  There are some additional recommendations that we feel may be of value to the non-motorized recreationist in the CNNF.

The Ice Age National Scenic Trail (IANST) stretches across Wisconsin approximating the path of the extent of the last continental glaciation. Upon completion, the trail will extend 1,200 miles through twenty-nine counties. At present, 42 of the 560 completed miles are in the CNNF.

Recommendations:

Ø      The Department recommends that the final CNNF plan:

v     Acknowledge and reference the Ice Age Trail as a congressionally designated National Scenic Trail and as a statutorily designated State Scenic Trail.

v     Designate the Ice Age Trail so that it is delineated separately on all appropriate maps of the Draft Environmental Impact Statement Map Set in their final form. (The GIS file (data layer) can be downloaded from the Internet: http://www.iceagetrail.org/infocenter/ctrline.html)

v     Recognize the 1994 Ice Age National Scenic Trail Plan (IANST) and address how it is to be incorporated into the Plan revision.  Page 10, paragraph 3 of the IANST states that “when the Forest Plan is reviewed or revised, the direction in this corridor plan can be proposed for inclusion”. The Department requests inclusion of the IANST plan into the CNNF Forest Plan.  Including the IANST Corridor Plan in the Forest Plan would clarify the management objectives for the trail corridor.

At a minimum, the IANST Corridor Plan needs to be referenced in the overall CNNF Proposed Plan with the following highlights reaffirmed:

·         The CNNF provides the best opportunity for primitive, non-motorized recreation of the entire IANST

·        Per the 1994 IANST plan, lands along the IANST within the CNNF are to "be managed to improve the semiprimitive experience it currently offers" and "The trail will be managed primarily for hiking and backpacking, with mountain biking prohibited" and the "trail corridor is defined as a minimum 600' wide zone, with the actual trail tread running through the center of the zone; however, the boundary has been expanded to coincide with vegetative stand boundaries as well as visual and/or social edges."

The North Country National Scenic Trail (NCT) is also a congressionally designated National Scenic Trail and a designated (Wisconsin) State Trail. The NCT stretches from New York to North Dakota. Sixty miles of the approximately 4,600 mile NCT are in the Chequamegon National Forest. The National Park Service, the USFS, and the North Country Trail Association have in place a triad agreement regarding management and desired future conditions for the trail.

Recommendations:

Ø      The Department recommends that the final CNNF plan:

v     Acknowledge and reference the NCT as a congressionally designated National Scenic Trail and as a designated State Trail.

v     Designate the NCT so that it is delineated separately on all appropriate maps of the Draft Environmental Impact Statement Map Set in their final form.

The GIS file (data layer) is available from the North Country Trail Association’s GIS Coordinator Tiffany Stram (tiffanystram@northcountrytrail.org).

An agreement signed in conjunction with the 1999 Telecommunications Act requires the notification of the North Country Trail Association and the Ice Age Park and Trail Foundation by any cell tower citing company considering placement of a cell tower within one mile of either trail, regardless of land ownership. The cell tower citing company and trail organization determine if and how wireless communications facilities near national scenic trails can be sited in a way consistent with trails' scenic values.

Recommendation:

Ø      Include language in the Utilities section of the SIO guidelines (p 2-39, Plan) referencing this agreement regarding the placement of cell towers within one mile of the Ice Age or North Country Trails.

Road Management / Access                     

The WDNR commends the efforts of the Forest Service in managing roads and access based on social, economical, cultural, recreational and ecological impacts.  Preferred alternative 5 goes a long way at attempting to address some of these issues.  .  Increasing areas with no motorized access will be useful to many wildlife species, primitive recreation, and some other benefits of the Forest.  Alternative 5 increases wilderness and non-motorized semi-primitive areas from 125,000 acres currently, to 200,000 acres, and increases non-motorized/fully managed areas from 12,200 acres to 64,500.  Also 446,000 acres will be considered in low road density areas (< 2.0 mi./ mi²). The Department’s recommendations on the various land allocations and non-motorized recreation are more fully addressed later in this document

Such restrictions on motorized use will be useful to wildlife species requiring large, more remote areas, or susceptible to over-exploitation by humans.  This will benefit reptiles and amphibians, spruce grouse, forest raptors, American marten, gray wolf, bobcat, moose and elk.  While such efforts are helpful, more could be done to protect and maintain habitat for some of these species, and address other issues of roads/access management.  Specific concerns and issues are listed below:

·         The Proposed Alternative, as do all the alternatives, maintains maximum road density of 4 miles/ square mile for 848,000 acres or about 56% of the Forest.  It is understood that road density was not identified as a focus of the plan revision.  None-the-less, such high road density seems unnecessary for most of the Forest except highly developed recreational areas, landscapes with lots of private lands, and very intensely managed plantations.  Road density continues to be an important factor in habitat selection for gray wolves, and other wildlife species (Mladenoff et al. 1995, Mladenoff et al 1999, Unger 1999, Wydeven et al 2001).

·        The “Proposed Land and Resource Management Plan 2003” states on page 2-22 for Eastern (sic) Timber Wolf, under “Guidelines: Do not exceed existing densities of road open to public vehicles within active wolf territories. This requirement also applies within areas that have a Wisconsin Department of Natural Resources Probability Index of 50 or above….”.  It appears the current proposed alternative has several areas that have been occupied by wolf packs since the early 1990s or have a wolf probability index >50%, that are being designated to have road densities up to 4 miles of road per square mile of land.

·         An extensive area east and south of Clam Lake in the Great Divide District has been occupied by wolves throughout the 1990s and is listed as 50 % or greater wolf probability (Mladenoff et al 1995), but is proposed in Alternative 5, to have road densities of up to 4 miles per square mile.   Mladenoff et al. (1995) indicates that extensive portions of this area have road densities of <1.0 mi./ mi²  for roads at maintenance levels 3 or greater.   The area also contains the largest block of inventoried roadless area in the Roadless Area Conservation initiative for the west side of the CNNF.  Thus, it seems highly unlikely that current road densities are anywhere near 4 miles per square mile, and designating much of this area for such a level, seems like a major increase of road densities for this area.

Recommendation:

Ø      The Department recommends that within the Great Divide District, “roaded natural remote areas” (maximum road density 2mi/mi²) be expanded to also include all of the areas east of County GG to the eastern Forest boundary, and north to Highway 77 in areas proposed for Roaded Natural Rural Areas (open road density up to 4 miles per square mile).  The same Remote designation could be made for rural areas west of County GG to Moose Lake, southwest to County Highway B, north to Highway 77, and in the vicinity of Clam Lake.  Additional Remote designations could be applied to Rural areas north of Clam Lake and north of Highway 77 and County D, east of Lake Namakagon and west of Highway 13, to join with proposed low road areas to the north.  Areas within 2 to 3 miles of Clam Lake could continue to be designated as Roaded Rural.  Therefore, Remote Areas of low road density would connect the Porcupine Lake Wilderness and St. Peters Dome Semi-Primitive Area on the north, to the Spring Brook Semi-primitive Area on the south.

The Great Divide District is also the core area of the American marten population for northwest Wisconsin.  Remote area designation reduces risk of accidental trapping by fisher trappers or trapping by poachers in protected areas.  Reduced road densities also facilitates travel and long-distance dispersal by marten.  Designation of the Hungry Run Wilderness in the Great Divide District is not necessary if this, and surrounding land, can be designated in a low road density system.

Recommendation:

Ø      The Department recommends that within the Park Falls District, most of the area north of Hwy. 182 be designated “Remote Area: (road density <2 miles per square mile) and considerations be given to expand “remote area” classification to most of the rural areas south of Hwy. 70.  Additional “remote area” designation is probably not necessary for other portions of the Chequamegon-side of the CNNF.

Designations of Remote Areas for the Nicolet-side of the CNNF seems reasonable, adequate, and appear to meet the needs of endangered, threatened, and nongame species for that area.  Wolves are still doing poorly on the Nicolet, and maintaining extensive areas of low road density may help establish more stable populations.

Road densities and road distributions within the Forest will affect future changes in ATV usage. Expansion of low road density areas will also reduce future impact of ATVs on wildlife.

Extensive areas of low road densities proved important core habitat areas for gray wolves.  During recent times, wolves have expanded drastically across northern Wisconsin, and remote habitats seem less important.  However, if human attitudes change or drastic declines in the deer herd occur, remote habitats will again become critical for maintaining viable populations of wolves.  Additionally, future housing and other human developments on private lands may cause most private lands to become unsuitable for wolves.  Persistence of wolves in Wisconsin may become more dependent on the National Forest and other large blocks of public land.  Extensive areas of the Great Divide and Park Falls Districts will be important core areas for wolves in the future.  Northern portions of the Nicolet-side of the CNNF may also become important.  A long-term perspective needs to be maintained for managing habitat for wolves.

Recommendation:

Ø      The Department is supportive of maintaining roads at the lowest density and lowest standard needed for forest management and access purposes in order to minimize adverse impacts on wildlife that are sensitive to human disturbance or exploitation.  We recommend that greater portions of the Forest be designated in low road density areas to protect habitat for wildlife sensitive to human disturbance or exploitation.  Such designation will protect remote and roadless areas that Alternative 5 does not adequately protect.   Low road density designation for more areas of the Great Divide and Park Falls Districts would provide better representation of current low road densities and roadless conditions that exist in portions of these areas.

BIOLOGICAL DIVERSITY

Terrestrial Ecosystems and Land Patterns  

The issue of maintaining biological diversity on the CNNF has been a long and controversial one. A brief history of this controversy is pertinent in demonstrating that biological diversity was the major issue that led to Plan revision.

The current Forest Plans, approved in 1986, assessed diversity based primarily on forest type, age class, within-stand diversity of tree species, and the coarse spatial distribution of Management Area allocations across the Forest. Standards and Guides also included provisions for snags, cavity trees, shrubs, woody ground debris, and reserve trees at the stand level. Animal diversity was evaluated primarily on the basis of vegetative diversity, and Management Indicator Species were used to represent various habitats.

The Forest Plans were appealed and litigated through 1994, primarily on the issue of whether scientific principles of conservation biology had been applied to the analysis of diversity. The courts decided in favor of the Service, but noted that the Forest Service's diversity analysis was based on the state of scientific knowledge that existed in the early 1980's, and that "the court's conclusions regarding the rationality of defendants' mid-1980's analysis of biological diversity do not necessarily apply to its subsequent analyses." (Sierra Club et al. v. Marita 90-C-0989).

One of the results of the initial appeal was the decision by the Chief of the Forest Service to remand portions of the Forest Plans, and to set up a process for evaluating new information. The Regional Forester was instructed to establish a committee of experts with a goal of developing objectives, standards, and guidelines for enhancing diversity (Appeal decisions, Nicolet National Forest LRMP, 1/8/1990). The Scientific Roundtable on Biological Diversity was convened in 1992, and produced their report in 1994 (Crow et al.). Roundtable recommendations include a number of specific actions, including "minimize forest fragmentation to protect forest interior birds and other area-sensitive or edge-sensitive species; block forest management activities into larger units", and "attempt to reduce deer densities in some areas of each Forest, either directly through changes in hunting practices… or indirectly via vegetation management".

After the conclusion of litigation in 1994, the Sierra Club, Wisconsin Audubon Council, and the Wisconsin Forest Conservation Task Force requested that the CNNF prepare a Supplemental Environmental Impact statement based on "significant new circumstances or information relevant to environmental concerns".  The Service responded that they must first determine whether to "amend, supplement or revise the existing Forest Plan and its EIS" (letter from Floyd J. Marita, Filecode 1950, dated 9/27/1994). This letter initiated a formal agency process of evaluating new information.

The Forest Service produced a 'New Information Report' in 1995, evaluating the diversity approach in the 1986 Plans. The report noted that it "was and is a standard approach used for maximizing smaller-scale compositional and structural diversity". It found that "developments during the past decade… make it clear that this approach is too limited for a complete consideration of biological diversity". The Report concluded that new scientific information existed on the issue of biological diversity, and that "environmental effects on biological diversity, including the interrelated components of composition, structure, and function, must be considered at multiple spatial and temporal scales during environmental analysis of proposed actions."

The New Information Report led directly to the decision to revise the Forest Plans. A Notice of Intent (NOI) was published in June of 1996 and identified four major revision topics, including biological diversity. Addressing this issue would include: 1) analysis at a broader spatial scale; 2) considering the unique role of the Forests in conserving biological diversity regionally; 3) providing for old growth forest, large forest patches, and habitat linkages; 4) restoring and maintaining ecosystems at risk or underrepresented in the regional landscape; 5) identifying Management Indicator Species that better serve as ecological indicators; and 6) evaluating recommendations of the Scientific Roundtable for possible inclusion in the revised Plan. The NOI describes biological diversity as being at "the heart" of challenges to the current Forest Plans, and states that the Forest Plan "needs to be revised to incorporate these new approaches for addressing concerns about biological diversity."

Given this long series of events, there has been anticipation that the revised Plan would substantially apply new scientific information in the fields of conservation biology and landscape ecology, leading to the restoration and maintenance of a high level of regionally significant biological diversity appropriate to the unique role of the CNNF. The proposed Plan does not seize upon existing opportunities that it identifies among its Alternatives

The State of Wisconsin has an interest in biological diversity, among other benefits supplied by public lands. Wisconsin's Public Forests statute (28.04) sets forth the purposes of management on state forests, including benefits to present and future generations. "These benefits include soil protection, public hunting, protection of water quality, production of recurring forest products, outdoor recreation, native biological diversity, aquatic and terrestrial wildlife, and aesthetics. The range of benefits provided by the department in each state forest shall reflect its unique character and position in the regional landscape."

Analysis in the proposed 2003 CNNF Plan's DEIS sections on Terrestrial Ecosystems and Land Patterns examines many facets of the biological diversity issue. It compares current conditions to those of the historic range of variability, noting declines of hemlock, yellow birch, northern white cedar, Canada yew shrub layers, pine barrens, natural red-white pine forests, and the boreal-transition forest. It describes the loss of structural components like large woody debris, cavities, vertical structural layers, and super-canopy conifers. It notes the negative effects of white-tailed deer herbivory, and describes changes in the natural disturbance regimes of fire and wind. The analysis is thorough and incorporates all the relevant new scientific information focused on the northern Lake States area. Comparisons among Alternatives consistently identify Alternative 5 (the selected Alternative in the proposed Plan) as one of the lower-ranked alternatives in addressing the biological diversity issue. There are better Alternatives than the one selected for addressing this legally, socially, and biologically significant issue.

Specific examples of biological diversity issues ranked by alternative in the DEIS include:

-          Of alternatives favorable to establishment of hemlock, Alternative 5 was ranked 6^th among the 8 alternatives (p. 3-57, R9-CN-DEIS-0403.).

-          For maintaining understory vegetation in northern hardwoods, Alternative 5 was ranked among the three lowest (pp. 3-57 through 3-59,  R9-CN-DEIS-0403).

-          Landscape patterns that included interior forest habitat were ranked highest in Alts. 3 and 4, followed by 7 and 9; again, Alternative 5 was not among the higher ranked alternatives (p. 3-96,  R9-CN-DEIS-0403).

-          Area in northern hardwood "core patches" and "connective patches" placed Alternative 5 among the three lowest-ranked alternatives (pp. 3-99,100 of R9-CN-DEIS-0403).

-          Analyses that measured interior forest, mature hardwood interior forest, northern hardwood patch size, and total northern hardwood area consistently ranked Alts. 3, 4, 9, and 7 as among the highest, and Alts. 1, 2, 5, and 6 among the lowest (p. 3-101, R9-CN-DEIS-0403).

The CNNF has a unique role in Wisconsin and the Lake States. These forests have a set of specific laws and regulations, notably the MUSY (Multiple Use Sustained Yield Act) requirement that production of timber and water products shall not impair the productivity of the land. This clause has been interpreted by the FS to mean that resource outputs from National Forests are to be provided only within the context of "ecologically unimpaired" lands, a term that has also been equated with ecosystem health, integrity, and sustainability. The basis for this reasoning is that a variety of organisms contribute to productivity, including microorganisms that cycle nutrients, ground-layer species that play roles in nitrogen capture and moisture infiltration, insects that pollinate many plant species, and birds that keep harmful insect populations in check. The legal requirement to maintain productivity, as interpreted to include the physical and biological environment that supports productivity, gives the CNNF a unique role. Another unique role of the CNNF is their ecological capability to support large contiguous examples of the former forest matrix community in Wisconsin, namely the northern hardwoods. Other large ownerships in Wisconsin have different legal requirements and management goals, or are located in areas with different land capability, and are unlikely to be able to provide large blocks of interior northern hardwood forests.

There are several diversity issues that the Department hopes and expects can be partially addressed by creating large northern hardwood interior forest blocks. These include declines of understory herbaceous species and shrub layers, lack of regeneration of yellow birch and hemlock (identified by Forest Service analysis as being more likely to occur in the conditions of interior forest), simplification and homogenization of landscape patterns, and predation that limits reproduction of certain neotropical migratory bird species. These issues are of concern to the Wisconsin DNR as well as to the Forest Service. The Deer 2000 report (Wisconsin Conservation Congress 2000) summarizes damage caused by deer herbivory, stating "Research projects have repeatedly documented that high herd densities damage natural, agricultural, and urban vegetation…. Excessive browsing also leads to reduced regeneration success or even extirpation of some plant species." The DNR's Wisconsin's Biodiversity as a Management Issue (1995) notes that "the major biological issue relating to the northern forests is that they have been managed on a stand-by-stand basis with little regard for sustaining landscape or regional diversity". The document Northern State Forests Assessment: Regional Ecology (1999) identifies ecological management opportunities, including those for northern mesic forests in the Winegar Moraines for "forest interior species because the area contains little open land". The DNR Handbook, Ecological Landscapes of Wisconsin, lists ecological opportunities for the northern forests, including increasing hemlock, northern white cedar, jack pine, boreal-transition forest conifers, old-growth communities, and white pine. Also, it identifies reducing impacts of white-tailed deer herbivory, maintaining large patches of northern hardwood forests, and emulating natural fire and wind disturbances in forest management. The CNNF's DEIS and assessment documents present a good analyses of diversity issues, and identify designation of interior forest blocks as a way to address these concerns.

The proposed Plan identifies a need for at least one large interior forest block as an objective for each side of the CNNF; one on the Nicolet-side and one on the Chequamegon-side (Pg. 1-3, R9-CN-FP-0403), to achieve goals for healthy and sustainable ecosystems. Because Alternative 5 calls for a minimum amount of interior forest needed to achieve the goal, it must be assumed that there is a reasonable justification for selecting the minimum approach rather than a middle-of-the-road tactic such as that represented by the allocation of interior forest blocks (Management Area 2B) in Alternative 9. The MA 2B areas are not set-asides, as they will continue to produce timber, contain roads, and be used for recreational purposes.

In some resource management situations, there are substantial tradeoffs between environmental concerns and other multiple-use benefits. This does not appear to be the case when comparing Alternative 5 with Alternative 9. Analyses of forest product outputs and economic benefits summarized in the DEIS do not indicate an obvious significant difference between these two alternatives. For some measures of outputs and value, particularly those focused on a northern Wisconsin analysis area, Alternative 9 is more beneficial than Alternative 5; by other measures Alternative 5 is more beneficial, but by a relatively small margin. For example, Table 3-72, projecting annual timber volume, indicates that for the first decade, Alternative 5 and Alternative 9 both produce 131 MMBF.  Projections diverge for the 10^th decade, but there are a number of potential factors that make this long-term production estimate uncertain, including impacts of insects, diseases, invasive plants, climate change, etc. Employment and labor analyses shown in Table 3-106 indicate a slightly lower labor income overall for Alternative 9 ($527.6 million) as compared with Alternative 5 ($535.0 million), but for Wisconsin's impact area, Alternative 9 provided slightly more labor income than Alternative 5 ($702.2 versus $690.4 million).  Economic efficiency summaries in Table 3-107, including non-market recreation values, differ by less than 1% between Alternative 5 and Alternative 9. The value of ecosystem services, such as water infiltration and purification, flood protection, nutrient capture and cycling, and some portion of the value of primary productive capacity that supports food webs (apart from the recreational value associated with non-consumptive wildlife uses; e.g. bird consumption of harmful insects), are not included in these analyses. If there is some overriding economic benefit provided by Alternative 5, it is not apparent from the analyses in the DEIS. Because there is not an apparent significant impact on other multiple use benefits, the Department suggests that the Forest Service should provide a higher likelihood of supporting the viability of native species within the matrix northern hardwood forest community by substituting all of the MA 2B areas displayed in Alternative 9 for MA's in the proposed Plan. This would change some of the 2A and 2C MA's in Alternative 5 to MA 2B.

Recommendations:

Ø      The Department recommends that the revised CNNF Plan better address long-standing issues regarding biological diversity by substituting Management Area 2B's from Alternative 9 into the proposed Plan.

Ø      Specific comments on particular 2B areas are:

v     Under the proposed Plan, the Park Falls district has no MA 2B areas. Allocating some 2B areas here would provide connectivity to important forested tracts and wetlands to the east.

v     Changing the MA 2A and 2C areas around Clam Lake, as well as the 2C area northeast of Prentice, to MA 2B would support connectivity with the Flambeau River State Forest. Site productivity and potential in the Clam Lake area, as well as its existing condition (northern hardwoods and supercanopy red and white pines) would support its designation as part of a large interior forest block.

A large number of Legacy Places identified through the Land Legacy process within WDNR are potentially affected by the proposed Plan. These areas are in the CNNF, near them, or within a connected watershed or landscape. These Legacy Places, and their connected areas, should receive special consideration for their unique recreational or biological values. Areas affected by the CNNF Plan are listed in Attachment A.

Public land management should focus on addressing gaps that occur as a result of the way private lands are managed. The CNNF should provide for species, communities, and ecological values that are not available elsewhere.

Wildlife

The Department supports the various goal and objective statements for the Forest Plan. However, the State of Wisconsin holds populations of resident wildlife in Public Trust.  There is no objective to consult with the State on management of wildlife habitat and wildlife populations for State Public Trust species.

The overall goals and objectives described in the proposed Forest Plan will help conserve the native plants and animal species present on the CNNF.  These goals and objectives are founded on the best available science and are consistent with the following Wisconsin DNR documents:

·         Wisconsin’s Biological Diversity as a Management Issue (WDNR, 1995)

·         The Northern State Forests Assessment: Regional Ecology (Bartelt et al. 1999)

·         The Northern State Forests Assessment: Community Restoration & Old Growth for the Brule River and Northern Highland-American Legion State Forests (Eckstein et al. 2001)

·         The Brule River Regional Analysis (Planning Strategies, 2001)

·         The Northern Highland-American Legion State Forest Regional Analysis (Rissman and Daniels, 2002)

·         The various Recovery Plans for state-listed species

·         The Ecological Landscapes of Wisconsin (WDNR, 2001)

In addition, the goals and objectives are consistent with:

·         The Report on the Scientific Roundtable on Biological Diversity (1994)

·         The Forest Service Landscape Analysis and Design Report (2001)

The key to conserving the 350-odd species of terrestrial vertebrates that live in the Upper Great Lakes is to follow the recommendations listed in Wisconsin’s Biodiversity as a Management Issue (WDNR, 1995).  All successional stages should be present in the regional forests including pine barrens and old growth and in patch sizes from small to very large.  The CNNF is a very large public ownership that is the best place to manage for very large patches of appropriate habitat.  Managing the composition and structure of forested landscapes and individual forest stands is the key to maintaining biological diversity and wildlife habitat.  Standards and Guidelines for landscape, stand-level, and individual species management insure the biological diversity and wildlife habitat objectives will be met when land management practices are designed.  

The Forest Plan proposes to maintain and enhance biological diversity and wildlife habitat by:

·        Increasing the area managed for pine barrens and surrogate barrens

·        Managing for large, 50,000-acre patches of mature northern hardwoods

·        Developing stand structure in maturing northern hardwood forests (25-inch size class structure in Management Areas 2B, 3B, 4B, and 6B as well as Forestwide and Management Area Reserve Tree Guidelines)

·        Maintaining tree species composition in Management Areas (Forestwide and Management Area Reserve Tree Guidelines for white pine, eastern hemlock, yellow birch, white cedar, red oak, and butternut)

·        Maintaining the composition and structure of forested and non-forested wetlands

·        Protecting state and federally listed species and Regional Forester’s Sensitive Species

The Forest Plan proposes to reduce the amount of early successional habitats (aspen, white birch, jack pine, and balsam fir).  A reduction in early successional habitats will reduce populations of important forest game species and certain elements of biological diversity.

 Recommendations:

Goals and Objectives

Ø      Add an objective that states the Forest Service will consult with the State of Wisconsin on the management of wildlife held in Public Trust by the State.

Biological Diversity - Land Management

Ø      Implement the Management Area landscape composition and structure guidelines as planned, however, manage for the highest percentage of early successional habitats (within the established range) for Management Areas 1A, 1B, 1C, 2A, 2C, 3A, 3B, 3C, 4A, and 4B.  While this will still represent a reduction from current levels, it will better address the need to provide for early successional forest types and the wildlife species and recreation associated with them.

Ø      Implement the Management Area site level composition and structure guidelines for each Management Area.

Ø      Implement the general Forestwide Guidelines for Biological Diversity and Timber Harvest Reserve Areas and Reserve Trees.

Ø      Implement the specific Management Area Biological Diversity and Reserve Tree Guidelines.

Ø      Use clearcuts larger than 40 acres in order to meet the objectives set for early successional habitats.

Ø      Use clearcuts greater than 10 acres in Management Area 6B to manage for appropriate early successional habitats.

Ø      Add additional information to the Standards and Guides for the following:

v     American marten: Add a sentence that recognizes American marten require a great amount of large coarse woody debris and many large cavity and den trees in their range on the Chequamegon/Nicolet National Forest.

v     Spruce grouse: Place small informational signs at hunter parking areas identifying the differences between ruffed grouse and spruce grouse.

v     Northern goshawk and red-shouldered hawk: Change the road closure guideline from February 15 - August 1 to February 1 - August 1.

Ø      Concentrate management of small upland openings in early successional habitats in Management Areas 1, 3, and 4 with an emphasis on bracken grasslands.  Reduce management of small upland openings in Management Areas 2A, 2B, and 2C.

Biodiversity and Special Land Allocations

Ø      Fully implement the land allocations for Research Natural Areas, Special Areas, and Old Growth Areas.

Ø      Make the following changes to Management Area allocations:

v     As previously mentioned under the Biodiversity recommendations, the MA 2B designations from Alternative 9 should be implemented.

v     The MA 4B designations from Alternative 9 should be implemented in the Park Falls and Eagle River Ranger Districts with the recommendation to maintain as much jack pine forest as possible (the importance of jack pine is referenced on page 22).

Recreation - Hunting

A segment of Wisconsin hunters desire to hunt in a remote, primitive setting with low hunter density.

Ø      Improve the quality of semi-primitive non-motorized areas by increasing the opportunity for quiet and remote experiences. Implement the Management Area 6A land allocation and change the proposed Management Area 5B designation at Flynn Lake to Management Area 6B.

SPECIAL LAND ALLOCATIONS

Background Information

The major Forest Plan revision topics of biodiversity and special land allocations are closely related. WDNR has had a long history of cooperating with the USFS on a suite of issues relevant to these topics dating back to the mid-1970s.  Joint projects that had a historical role in providing some of the background information presented by the USFS included: community level site inventories, surveys for rare plants and animals, evaluations of candidate Research Natural Areas/Special Areas, development of regional and CNNF specific sensitive species lists, population/species viability analysis, and co-designation of Research Natural Areas-State Natural Areas (NR 23.27, NR 23.28). 

Comments

The Forest’s size, location, configuration, ecological content, and the wealth of relevant inventory and research information now available to inform the planning process, make the CNNF unique.  Because of this, opportunities for success in meeting key management objectives for large scale and declining vegetation types are greater here than on many other ownerships in Wisconsin. Some management objectives on a National Forest differ significantly from those on most other public and private lands, also an important factor in the decision-making process.  

The Department supports the Research Natural Areas program (RNAs), which addresses many of the conservation goals shared by our agencies and others, including the protection and maintenance of native terrestrial, wetland, and aquatic ecosystems, protection of rare and declining species, and representation of the full spectrum of outstanding natural features within the CNNF.

We also support the Special Management Areas (SMAs), Old-growth Areas, and Alternative Management Areas (AMAs) for the same reasons, but these designations offer protection and management opportunities that are more focused on rare species, missing successional stages, and large forested landscapes. The context of the lands within which RNAs, SMAs, and Old-growth Areas are to be embedded is critical to the long-term viability of many ecosystem types and sensitive site features. The AMAs provide a means of meeting management goals and objectives that more meaningfully address issues of scale and context than past efforts. They will also produce forest products. The Alternative Management Areas (AMAs) need to be large enough to accommodate the disturbance regimes (windthrow, fire, flooding, insect infestation, etc.) characteristic of the ecosystem types occurring within them, while still remaining relatively unaffected by other factors that can negatively impact those systems (including fragmentation, isolation, species loss, excessive browse, and regeneration problems). Designation of additional AMAs beyond those offered in Alternative 5 would ensure better representation of characteristic landscape features across the CNNF. The MA 2B areas will enable the development of forest interior conditions and missing structural features better than 2A or 2C designations. Site specific suggestions are offered at the end of this section under “Recommendations”.

The Landscape Analysis and Design (LAD) process used by the USFS to identify and select candidate RNAs, SMAs, AMAs and Old-growth Areas of high ecological value was thorough and effective.  It built on previous, much more limited inventory efforts conducted on the CNNF by the DNR and others. The use of a methodology that permitted comparison of the LAD process results with similar efforts conducted elsewhere in Wisconsin by the DNR, was especially helpful.

Aquatic systems are extremely important to protect on the C-NNF and will need additional consideration in the future to ensure that they are adequately represented within appropriate special management areas. Many of Wisconsin’s most important streams originate within or near the CNNF, and a great number of undeveloped lakes occur within the Forest boundary. Developmental pressures on lakes and streams are currently high and increasing throughout the upper midwest.  Threats from the spread of invasive species continue to rise. The Department supports the strong protection of stream corridors, both for the many values they hold and as potentially important connecting links between scattered habit patches. For many of the major rivers, multiple administrative jurisdictions are affected.  We welcome and encourage continued cooperation and collaboration between agencies to meet mutual management and protection goals.

In recent years CNNF staff have done an excellent job of identifying populations of rare plants and designing management protocols that will maintain critical habitats for these species. We support the continued implementation of rare plant conservation practices.

Some of the largest MA polygons in preferred Alternative 5 are typed MA 1A (early successional aspen). Diversifying some of these with MA 1B designations would be beneficial to many species, especially where uplands are in close proximity to coniferous wetlands supporting spruce grouse, diverse assemblages of neo-tropical migrant songbirds, or where other significant public lands adjoin the CNNF. 

As expressed previously, the context of MAs with respect to adjoining ownerships (especially county and industrial forests) and the management emphasis on those lands is an important consideration. WDNR’s comments acknowledge the unique character of the CNNF and the association with adjacent ownerships.

Although the Department supports the values associated with wilderness areas, the Wilderness Area (WA) candidates do not appear to have ecological values or other characteristics that are compatible with wilderness designation.  Resource protection of these areas can be attained through other MA designations (see “Recommendations”).  The critical factor when selecting an MA designation for the candidate sites is to ensure compatibility with and enhancement of adjoining lands, especially existing Wilderness Areas, RNAs, roadless areas, and proposed AMAs, RNAs, SMAs, Old-growth Areas, and LAD complexes. Protection of large forest blocks, wetlands, undeveloped lakes, streams, springs and roadless conditions are all of paramount importance. 

Preferred Alternative 5 is especially weak in emphasizing the management of upland conifer-dominated communities. We would like to see additional attention to the management of natural pine and oak forests. 

The Department supports the protection, management and restoration of pine barrens systems and associated xeric forest communities at Moquah (Washburn District) and, as is feasible, on the Lakewood District in the southeastern Nicolet. The pine barrens community is now globally rare and provides critical habitat for many species that are rare or declining. Opportunities to maintain barrens systems and embed them within natural stands of pine, oak, and aspen are increasingly limited. Wisconsin contains some of the most diverse and largest barrens remnants in the nation.

Preferred Alternative 5 consistently ranked among the lowest of the 9 plan alternatives in meeting Forest goals and objectives for the major plan revision topics of biodiversity and certain special land allocation (R9-CN-DEIS-0403). Shifting MA designations from other plan alternatives at selected sites would be one way to address specific shortcomings.

Recommendations:

Ø      Implement the establishment of RNAs, SMAs, AMAs, and Old–Growth areas at appropriate locations across the CNNF.

Ø      Continue the co-designation of RNAs and selected SMAs as State Natural Areas at appropriate locations on the CNNF.

Ø      Identify and consider RNA designation of aquatic reference sites that cover the full spectrum of aquatic systems (lakes, ponds, rivers, springs) occurring on the Forest as an important future need.

Ø      Change the MA designations for the candidate Wilderness Areas due to the fact that the Department feels that neither Hungry Run nor Flynn Lake exhibit the ecological or other attributes associated with wilderness.  The Department recommends shifting these areas to alternative classifications.  In the Hungry Run Roadless Area a SMA designation (MA 8F) for the Bear Creek Slough and an Old Growth designation (MA 8G) for the Hungry Run Pines and Cedars may be more appropriate.  The remainder could be left open for management activities under MA 6B.  We would recommend a MA 6B designation, focusing on landscape scale hardwood management, for all of Flynn Lake.  These changes would offer similar resource protection while allowing for some research, safety, land management and ecosystem restoration efforts.

Ø      The Department is in favor of continued efforts towards using AMA’s and non-traditional management strategies (e.g. MA’s 2B, 3B, 4B, 4C, 6B and XX.0) in order to maintain some forest productivity on those lands where ecological and recreational needs are foremost. 

Ø      Site specific recommendations for other MA designation changes are as follows:

v     MA 2B additions:  As recommended under the Biodiversity Section of our comments, the Department is supportive of the MA2B designations under Alternative 9.  Included within these recommended MA 2B changes are the following specific examples:

·        The easternmost part of Park Falls District south of Hwy70. This will better protect LAD sites, and interface with an extensive and remote area dominated by coniferous wetlands just to the east of the Forest boundary in Oneida County (Bootjack Lake Peatlands).

·        A portion of the Medford District that contains a high percentage of the CNNF’s hemlock forests, large coniferous wetlands, and features that are unique within the CNNF such as ice-walled lake-plains and floodplain forest. The corridors of the Black, Yellow, and Jump Rivers are all ecologically important for their aquatic biota and associated wetland vegetation.

·        The southeastern part of the Great Divide District will afford further protection to the Chippewa River corridor and a concentration of LAD sites. MA 2B should also be considered along the common boundary with the Flambeau River State Forest.

·        The Eagle River District to the south and east of the Headwaters Wilderness Area. There are state-owned in-holdings (Board of Commissioners of Public Lands) within and adjacent to the Headwaters WA that offer outstanding old-growth opportunities. The natural features in this part of the Forest would be better complemented by MA 2B designation on adjoining CNNF lands.

v     MA 4B additions:

·        On Eagle River District between the Headwaters and Blackjack Springs Wilderness Areas and adjacent to the AMA.  This would be more compatible than the 4C proposed in Alternative 5. As a minimal number of AMAs were selected under Alt. 5, restructuring the MA designations on surrounding lands is especially important. Sites within or adjacent to this area that support jack pine forests should continue to be managed for that community.

·        On the northeastern Park Falls District north of Highway 70, MA 4B would be a more compatible designation with the concentration of LAD sites occurring there that the 4C proposed under Alternative 5. There are important linkages with ecologically significant and remote lands on adjacent ownerships to the north and east (DNR, Tribal, TNC).

v     Miscellaneous MA shifts:

·        MA 2 would be more appropriate than the MA 1A in Alternative 5 for southeastern Washburn District east of the Rainbow Wilderness Area and adjacent to the Bibon Swamp The Bibon is a 10,000 acre conservation project of the DNR in Bayfield County containing mature forest communities of white cedar, black ash, tamarack, and black spruce. The streams draining the Bibon originate on the C-NNF and provide vital connecting links between the Forest and the vast Bad River-Kakagon Sloughs on Lake Superior (one of the premier wetland complexes on all of the Great Lakes). This designation change would block in a concentration of existing and proposed Wilderness Areas, LAD complexes, and Old-growth Areas, and eliminate the large gap that would be created between CNNF and adjacent state ownerships by a management emphasis on early successional forest types dependent on clearcutting in between these sites.    

·        It would be appropriate to emphasize some upland conifer representation in the large areas designated as MA 1A on the Park Falls and Great Divide RDs by designating portions of them MA 1B. This would be especially beneficial in parts of the Great Divide RD with an abundance of coniferous wetlands.

TIMBER PRODUCTION

Land management activities are designed and conducted to produce ecological benefits that enhance our natural resources.  They also have secondary benefits, including the production of forest products.  The Department supports the Forest Service in utilizing the harvest and sale of timber as a means of conducting habitat management activities.

Economics:

Maintaining a sustainable mix of forest types and successional stages that are available for harvest is vitally important to the economies of the local counties, northern Wisconsin, and the state as a whole.  Both the forest products and tourism industries rely  on the National Forest for a sustainable flow of natural resource benefits .  In providing 7.5% of the timber harvested in Wisconsin (FIA data 1983 – 1995) the CNNF is an important source of roundwood to the forest products industry, the second largest industry in the state.  Within the eleven counties containing CNNF land, timber harvested from the CNNF increases to 17% of the total forest product output.  Contributions as high as 31% (Ashland County) illustrate the considerable impact to localized economies.  Federal payment in lieu of taxes (PILT) and 25% payments to counties are also significant.  Projections indicate that 81% of the 15,110 jobs and 87% of the $498.5 million of the economic impact stemming from the CNNF can be attributed to the timber program (Pg. 3-268 of R9-CN-DEIS-0403). 

Quantity of Forested Land “Suitable” for Harvesting:

In the assessment of Wisconsin’s Forests (Wisconsin’s Forests at the Millennium; An Assessment, November 2000), an identified trend / issue was the disconnect between resource consumption and resource production.  Forest product consumption continues to rise at the same time many are calling for reducing the amount of forest land that is actively managed.  Ecological, social and economic consequences are interwoven.

Timber harvest “suitability” identifies those lands managed for timber production on a regular basis.  The process of determining “suitability” involves several steps. Initially,  “forestland” and non-forested land (permanent openings and water) are separated.  “Forestland” is then reduced by lands withdrawn by official wilderness designation, lands where irreversible damage to soil or watersheds would occur, and lands where regeneration within 5 years is not assured.  Approximately 1,200,000 acres (80% of the CNNF) qualify as “tentatively suitable” after this process (Pg. 3-214 of R9-CN-DEIS-0403).  These lands are then further reduced by land allocation decisions and site specific issues made during the planning process.  This included designation of Old growth, special management areas (SMA), threatened / endangered and sensitive habitat, potential Wilderness, recreation areas, Wild and Scenic River corridors and also those areas with projected excessive high road costs or classified as a forested wetland.  

Under the proposed alternative, “suitable” lands are proposed to total approximately 863,000  acres (Table B-1, Pg. B-9 of R9-CN-DEIS-App-0403), or less than 60% of the combined CNNF acreage. This represents a 243,000 acre reduction from the current plan where, based on actual use, nearly 1,106,000 acres or 74% of the land base, was considered suited for harvest (Pg. 3-214 of R9-CN-DEIS-0403).

Forested wetlands and hemlock:

Our forested wetlands and hemlocks stands are critically important to the ecological makeup of Wisconsin.  Harvesting and land management activities in these areas requires an appreciation for the unique attributes and challenges they present, including:

·         The proportion of rare species associated with wetlands is high compared to most upland types, and many of these are wetland specialists that do not inhabit upland habitats. Very few are dependent on young forests, and for some of those that are, such habitat is readily available from common communities such as muskeg, or following natural disturbance events.

·         Disruption of hydrology is a significant concern, especially for species like black ash and cedar.

·         Potential for inadvertently introducing or facilitating the spread of invasive species that are difficult to control is high for some wetland types, e.g., floodplain forest.

·         Regeneration methods for some tree species need additional research, especially, but not limited to, white cedar and hemlock.

·         Patch sizes and patterns can been drastically altered by some methods, e.g., strip cutting. The effect this has on associated plants and animals are largely unknown although patch sizes are typically reduced and additional edge is created using such practices.

·        The interspersion of coniferous wetlands with hemlock-hardwoods matrix forest was one of the characteristic landscape level associations in the pre-Euro-settlement northern forests, something that has changed dramatically. Landscape level discussions are needed along with site by site review of management proposals. 

Regeneration of the forested wetlands is only marginally considered for timber harvest under the preferred alternative.  With considerations of the aforementioned concerns in managing forested wetlands, an increased emphasis for regenerating these types should be considered.   The need to maintain the habitat and regenerate these wetland types is important.  It is equally important to maintain different age classes of these types.  Without efforts to regenerate these stands, the sustainability of these forest types is suspect.  Harvesting technology has improved and the potential for adverse impacts caused by timber harvests has lessened.  Maneuverable, low ground pressure units are available to reduce physical impacts caused by timber harvesting. Criteria used to assess whether harvest is either possible or appropriate should be revised to reflect improvements in harvest technology.

Under the preferred alternative, 182,184 acres of wetland conifers and 42,975 acres of wetland hardwoods will be removed from the suitable land base and from consideration for active forest management or stand regeneration treatments (Handout, 5/9/03 USFS Consultation meeting).  Of this acreage, 52,000 acres (Table B-1 on pg. B-9 of R9-CN-DEIS-App-0403) is removed solely because it is a forested wetland or hemlock type.    This is the remaining acreage of these types after profitability, ability-to-regenerate and non-timber land designations have been evaluated.  This action in the Preferred Alternative #5 avoids the issue of when and how to regenerate these forested wetland types. 

The Department recommends that the resources of the North Central Research Station be employed to develop and monitor regeneration strategies for these forested wetlands.  As stewards of this public resource and national leaders in the development of regeneration strategies, the USFS should address regeneration of all forest types on the CNNF.  The Department is of the opinion that the USFS holds an obligation on the CNNF to provide guidance on forest habitat management, including these forest types. .   Ignoring management appears to be imprudent since, over time, many acres of these wetland forest types will convert to other types that are more common and less desirable for ecological reasons..  Allowing all wetland forest types to advance into older age classes and stand conditions, will weaken the age diversity in forested wetlands and eliminate the presence of many early serale stages within these types. This will lead to increased potential for wind throw losses, reduced stand vigor, resistance to forest pests, and eventual loss of species that depend on early stages in wetland forest types.

Both the State and the Federal foresters need to continue to learn more about successfully regenerating these types and further refine our harvest techniques so as to avoid adverse soil and water or endangered species impacts.  This is important not only on our public lands but also the private lands we assist with management on.  The Department is of the opinion that, while we are sensitive to rutting, hydrologic concerns and endangered species presence, the forested wetlands need to be evaluated for management on a site by site basis.  Types such as tamarack, black spruce, lowland balsam fir and some black ash could be designated as “managed forest wetlands” because of the current knowledge available.  Other types, such as cedar, lowland hemlock and poor quality ash swamps could be classified as “unmanaged” at this time.   Limited trials aimed at solving the hemlock and cedar regeneration problem would be permissible.  It is important that qualitative monitoring be included in these efforts so that knowledge is gained not only on the “managed” types, but also for types such as cedar and hemlock.  The approach needs to be cautious, with a high regard for hydrologic and endangered resources issues. Lowland status should not, by itself, be a reason to exclude a forest stand from timber harvest.

Alternative Management Areas (AMA’s):

In comparison to other Alternatives, the Preferred Alternative ranks near the top for highest number of acres available for harvest operations.  This amounts to 66% of the forested land on the CNNF.  Balancing ecosystem restoration and landscape pattern concerns (another focus driving the Plan revision) while maintaining forest productivity is difficult.  As opposed to a blanket “no commercial harvest” designation, the alternative management areas (MA’s 2B, 3B, 4B and 4C) offer opportunities to maintain some productivity while addressing these concerns.  MA 6B and MA XX.0 also have opportunities for harvest while still addressing the need for a non-motorized, semi-primitive recreational experience. 

Note:  The analysis of the preferred alternative was difficult due to the overlap of shared land allocations.  A matrix showing distribution of forest types across the spectrum of management areas would have been helpful in determining what changes in forest types would occur between alternatives.  It was also difficult to account for those areas that are included in two or more MAs. Additional tables would be helpful to show the overlap of common areas between Management Areas. We understand that some areas are allocated to more than one area but the extent of  these shared allocations of acreage between Management Areas is not clearly summarized.

Ecological Reference Areas:

Many of the “no harvest” designations (Old Growth, Special Management Areas, Research Natural Areas) had little variability in acreage amongst the alternatives.  It is understood that this network of “ecological reference areas” was the means used to partially address the biological diversity and special land allocation focus in the need to revise the 1986 plan.

Species mix:

The Department is concerned with identified downward trends of some forest types (e.g. jack pine, aspen, white birch, butternut).  It is important to maintain a sustainable mix of forest types and species mixes within those forest types, as well as a range of age classes.  To accommodate the maintenance of early successional habitats for wildlife and hunting interests, the Department supports managing for the upper end of the recommended management range for even-aged types such as aspen, paper birch and jack pine.  This applies to Management Areas 1A, 1B, 1C, 2A, 2C, 3A, 3B, 3C, 4A and 4B.

Jack Pine

The jack pine forest type in Wisconsin has declined significantly over time and some concern exists about the long-term viability of this forest type in the State. Results from the last Wisconsin Statewide Forest Inventory clearly show that growing stock volumes and acreage of jack pine have significantly declined from 1983 to 1996.  Jack Pine forest type acreage distribution between 1 and 20 years old is down from 117, 000 acres statewide in 1983 to 60,000 acres in 1996. Many factors have contributed to this decline but contributing causes are successional trends, improvements in fire suppression to prevent large scale, stand replacing fires, the lack of interest in managing and regenerating jack pine in Wisconsin, and significant mortality caused by jack pine budworm outbreaks. Many small private landowners have harvested mature jack pine stands but few have reinvested in regenerating this type. Public forests lands appear to be the best chance for maintaining this forest type in Wisconsin.

The Northwest Sands Landscape Level Management Plan, December, 2000, addressed  this decline also and recommended that land owners within this landscape attempt to maintain jack pine where possible.  A large portion of the jack pine type on the CNNF does occur within this landscape feature in Wisconsin.

The jack pine forest type currently occurs on approximately 34,272 acres of the CNNF  (27,440 acres on Suitable Lands and 6832 acres on Unsuitable lands) (Handout from 5/9/03 USFS Consultation meeting). Under the proposed alternative, this type will drop to 23,796 acres, a 30% decline over the next 100 years. The CNNF Preferred Alternative should give higher emphasis to maintaining this important forest type.  Where appropriate, natural red pine can be substituted, particularly where historical review suggests red pine was common either as the principal type or a common associate.

NH Management Guidelines

Under the proposed alternative, a significant allocation of CNNF acres has been made to Uneven-aged Northern Hardwoods Management Areas 2A  (224,000 acres), 2B (130,000 acres), and 2C (294,000 acres).  While the intent in this Area is to emphasize mid to late successional uneven-aged northern hardwood and northern hardwood-hemlock management, the proposed stand level structural compositions and desired size class distributions raise a number of issues. 

The Department acknowledges that the 25 inch DBH target maximum diameter in the MA 2B designation addresses the biodiversity issue by compromising some timber production and quality for ecological considerations.  We are supportive of the landscape scale hardwood management.  However, the DEIS and Standards & Guidelines are unclear as to the degree of the tradeoffs (economics, log quality, production loss) associated with the MA 2B designation and the 25 inch target diameter.  The stocking charts used in MA 2B (Table 2-5, R9-CN-FP-0403), coupled with the recommended 6-13 reserve trees per acre, give the appearance that the reserve trees may ultimately dominate the upper size classes.  It is unclear how the reserve trees will be treated once they attain the 25-inch size. The Department recommends that the Standards & Guides for Northern Hardwoods be expanded to clarify the policy on treating reserve trees that exceed the desired level of stocking within diameter classes.  We believe there is potential for reserve trees to dominate the upper range of diameters, restricting harvest, and limiting the development of gaps for development of northern hardwood seedlings, saplings, and poles.

Projected Accomplishments:

Recent history illustrates that the USFS has not been able to meet the allowable sale quantity (ASQ).  Discussions over ASQ levels are mute given the fact that for the foreseeable future the Forest Service does not have the staffing or resources to come close to the projected ASQ of 131 million board feet (MMBF) in the first decade of the plan or 144 MMBF for the second decade.  In the last 5 years an average of 99 MMBF has been sold and 121 MMBF harvested annually on the CNNF.  There has been a steady downward trend in timber harvest over time since the 1980’s.   Overall we have become better stewards of the land in the past 20 years, however, the overlapping and sometimes conflicting laws, attention to detail, and litigation have negatively impacted productivity.

Recommendations:

Ø      The Department supports the continued use of commercial timber sales as one of the means of conducting habitat management activities.

Ø      The Department supports the CNNF’s commercial timber harvest program at a level consistent with achieving desired forest conditions.  The CNNF timber program is a valuable contributor in addressing the increasing demand for industrial roundwood and also provides a sustainable source of funds to support direct federal payments and associated economic benefits to the local economies. 

Ø      The Department is supportive of efforts to streamline National Forest Planning regulations in order to facilitate completion of land management projects.  The Department recommends the USFS pursue efforts to provide the necessary staffing to achieve the Plan objectives, including attaining the ASQ levels in the plan. 

Ø      As mentioned previously, the Department is in favor of continued efforts towards using non-traditional and alternative management strategies (e.g. MA’s 2B, 3B, 4B, 4C, 6B and XX.0) in order to maintain some forest productivity on those lands where ecological and recreational needs are foremost. 

Ø      As referenced in the Wildlife section (p. 14), the Department supports efforts to maintain the State’s base of early successional forest types in order to continue to provide the range of benefits associated with these types.  These types are in decline and will remain so in the Plan.  To address this, the Department recommends managing for the upper end of the recommended Standards and Guides percentages for types such as aspen, white birch and jack pine.  This does not apply to MA 2B where the focus is on developing large-scale interior hardwood forests.

Ø      The Department agrees that there is a need to have reference areas to represent native ecosystem types and seral stages.

Ø      Include “forested wetlands” typed as tamarack, black spruce, lowland balsam fir and productive black ash into the category of lands “suitable” for timber harvest and include them in the allowable sale quantity calculation.  Allow site- specific considerations to be the determining factor in the appropriateness of timber harvest in these areas.  Limited research studies that will improve regeneration techniques should be conducted in wetlands typed as cedar, lowland hemlock and poor quality black ash.  When regeneration success can be routinely achieved, these types should be moved back into the “suitable” land base.

Special Forest Products

The issue of maintaining sustainable populations of various special forest products has been an increasing concern for several decades at a local, regional and national level.  Species harvested from forests other than timber commodities have been referred to as special forest products or non-timber forest products i.e. plants, lichen, fungi, and balsam bough.  Interest in special forest products in the region has increased along with the demand for herbal medicine, decorative floral products and edible wild fruits and mushrooms. One CNNF annual report stated that $42,000 worth of special forest product permits was sold in 1999 to over 100 individuals. Several warehouses that buy these products are located within the CNNF boundary due to the close proximity to the resources and harvesters that live in the area. 

The Timber Appraisal Handbook for the Forest addresses the permit system for special forest products.  Revisions to the handbook are done at the regional and national level of the Forest Service.  The handbook briefly addresses the allowable quantities of each special forest products permit.   Specific policies for each product can be addressed at the Forest level since there are unique, local issues to that Forest.  One example of setting local policy was on the Hoosier National Forest regarding wild ginseng.  Here the Forest made the decision at the local level not to allow harvest of wild ginseng because of harvesting impacts until a resource assessment was conducted.

In the mid-1990s, a special forest products conference was organized on the Nicolet National Forest where a variety of agencies and individuals discussed harvesting and management concerns.  Topics related to social, economic and biological concerns regarding special forest products were presented.   Several people expressed that non-timber commodities present opportunities for rural entrepreneurs to supplement their incomes. One harvested product, princess pine clubmoss, was discussed in great detail.  A botanist from the region expressed that an estimated 300 tons of clubmoss are gathered each year in the Lake States.  This conference prompted many questions; however, it was mainly an informational effort with no follow up activities.  Such leadership efforts and collaboration with other agencies need to continue.

Public land managers are charged with the task of providing for public uses and benefits of the forest while maintaining biodiversity and forest health. Natural resource professionals continue to raise the same questions about the habitat and populations being impacted by harvesting, land management practices and other disturbances.  With few exceptions, special forest products have been harvested without inventories or monitoring and without addressing sustainability or conservation of the resources and their habitat.  This is true on our State and County forests as well as on the CNNF.  Products such as balsam boughs may appear to be abundantly available across the landscape, yet incorrect methods of harvest raise aesthetic and wildlife habitat concerns. Another harvested product, “sheet moss”, which is in the bryophyte family, has very slow growth rates.  All of the State’s public land entities need to acquire more knowledge about these species in order to assure a sustainable harvest of these products.

With increasing demands for these products and still little knowledge of their sustainability, this would be an opportunity for the proposed land and resource management plan to address a monitoring plan for special forest products. The following suggestions should be highlighted in the standards and guidelines and further mentioned in the monitoring and evaluation plan.

Recommendations:

Ø      The Department supports issuance of educational brochures to the public that would illustrate sustainable harvest methods for special forest products.

Ø      The Department is supportive of any efforts towards conducting an assessment of special forest product availability, determining sustainable harvest methods and quantities, and studying methods of regeneration.  Annual monitoring efforts to this end would be essential.  The Department would be interested in collaborating with the Forest Service in this effort.

OTHER TOPICS OF CONCERN

Aquatics                                             

Overall the Plan revision, through its Standards and Guides, provides for a high level of concern for, and protection of, aquatic resources.  The direction in the Plan is consistent with, and supportive of, DNR water management goals.  There is a concern that some of the statements in the Standards and Guides can be construed to indicate that the Forest Service has authority for some water-related decisions.  The forest-wide standards for water related permits (Pg. 2-2, R9-CN-FP-0403) acknowledge WDNR responsibility for permitting “prior to any activity that will affect the quality of navigable Wisconsin waters”.  Some of the Standards & Guides for the individual management areas are less clear.  Specific examples have been included in Attachment B accompanying this document.

Objective 1.3f (Pg. 1-2, R9-CN-FP-0403) references the application of lime to mitigate acid deposition effects and improve productivity.  WDNR is concerned with this practice.  Besides permitting requirements, the Department would welcome discussion with the Forest Service biologists on this issue.  This practice may be in conflict with the general goals of the plan, such as ensuring healthy and sustainable ecosystems, and providing benefits for people within the capabilities of sustainable ecosystems. 

Recommendation:

Ø      Implement the Plan, including the Standards and Guides, but clarify the responsibilities associated with aquatic management activities.

Wild & Scenic River Designations

While not identified during the analysis of need process for the Plan revision, the Department would recommend the Forest Service explore the potential for additional Wild, Scenic or Recreational river designations.  In specific, the East Fork of the Chippewa, South Fork of the Flambeau, Pine, Popple and Peshtigo rivers, all encompassed partly within the CNNF land base, have been identified as eligible for such designations.  We would support the Forest Service in efforts to conduct suitability analyses on these rivers to determine whether such designations are appropriate, and whether Congressional recommendations for designations should be made.  Conducting such analyses, in concert with local citizen’s groups, will provide a more complete picture of what the proper river management options might entail in the future.     

Recommendation:

Ø      Conduct suitability analyses on the East Fork of the Chippews, South Fork of the Flambeau, Pine, Popple and Peshtigo rivers to determine whether special dexignation are warranted and appropriate. mplement the Plan, including the Standards and Guides, but clarify the responsibilities associated with aquatic management activities.

Monitoring and Evaluation Plan

As noted in the introduction section of the Monitoring and Evaluation (M&E) Plan, monitoring is required by National Forest Management Act (NFMA) regulations (36 CFR 219) to determine how well the Forest Plan is working.  A M&E Plan includes several categories, including: 1) "implementation monitoring" to determine whether management activities are being carried out according to the Plan; 2) "effectiveness monitoring" that evaluates whether activities are achieving the desired objectives; and, 3) "validation monitoring" to examine whether the Plan's objectives, standards, and guidelines are resulting in conditions that comply with federal regulations, goals, and policies.

The brevity of the CNNF's M&E Plan, and the lack of detail about some monitoring questions and techniques, makes it difficult to evaluate how well it addresses important monitoring needs. At the May 9, 2003, meeting it was stated that there is to be an additional monitoring plan developed aside from the Forest Plan. The WDNR would appreciate an opportunity to comment on the detailed M&E Plan when it becomes available, if possible.

The WDNR has prepared a Monitoring and Evaluation assessment document that guides development of M&E Plans on State Forests (WDNR 1998). The M&E assessment notes the scarcity of resources typically available for monitoring, and the need for prioritizing based on the most critical management issues. In addition to routine implementation reporting, the M&E assessment proposes that monitoring be related to: 1) significant management issues, 2) significant resources of high conservation value, 3) mitigation measures, to ensure that they are effective, 4) new management techniques, to ensure that they are meeting objectives, 5) high-risk actions, 6) key assumptions that the Forest Plan is based upon, and 7) areas of conflict, such as where scientific uncertainty exists.

In general, it appears that the CNNF's M&E Plan emphasizes implementation monitoring, which has long been a strength of Forest Service monitoring programs. A number of reviews of National Forest monitoring programs have reported a deficiency in the areas of effectiveness and validation monitoring. These types of monitoring are often more difficult to conduct, frequently requiring longer-term and broader-scaled efforts - nevertheless, these are areas where it would be desirable to strengthen the M&E Plan to help determine whether the Forest Plan is based on sound judgment and science. A possible danger of the lack of emphasis on effectiveness and validation monitoring is that important assumptions inherent in the design of the current Forest Plan will remain untested, and there will be a lack of data needed for Plan revision in the future.

Effective methods in data collection and analysis are required to make a qualitative and quantitative assessment of progress. Understanding the scientific basis for the monitoring design, method, and scale; assuring consistency in documentation and reporting of information; and using collaborative approaches to gain support for addressing monitoring needs, are all important facets of monitoring.  Monitoring should be emphasized as a key part of a professional’s job, and the importance of monitoring should be articulated across the Forest. Other considerations include coordinating among units to assure that monitoring is conducted efficiently at appropriate scales, and integrating forest plan monitoring with project monitoring.  Finally, the M&E annual report should document and interpret results and make recommendations for adjusting future management strategies and actions. 

The CNNF's  have demonstrated highly effective inventory and monitoring programs in some areas, such as botanical inventories, bird surveys, rare species conservation assessments, invasive plant inventories, ecological/landscape analysis, and watershed assessments.  These program areas and functions have documented results and made recommendations that integrate with the Forest Plan. 

In the proposed M&E Plan there are two precision/reliability methods, identified as A and B.  Method A is more quantitative, relying on measurements and models to indicate change.  For example, periodic measurements of deer density in a given area would be one such tool.  Method B is more qualitative and relies on less rigorous methods to assess change. Examining visitor logs at campgrounds would be one way to monitor in the Method B category.  The proposed plan uses both methods for assessing various goals and objectives, but Method B appears to be proposed for most questions in the effectiveness and validation categories.

There are several areas in the M&E Plan that could be strengthened.

Recommendations:

Ø      The Department recommends using more quantitative methods to conduct effectiveness and validation monitoring of the Forest Plan.  Many of the goals in the M&E Plan are not associated with quantitative measures for documenting significant forest ecosystem change.  Many of the measures proposed are in the B category, which is qualitative.  Method B may use existing visitor logs, surveys, photo interpretation, etc., some of which are appropriate and adequate for implementation monitoring; however, these methods do not always provide defensible, pertinent data for addressing effectiveness and validation questions. Examples of measurements that are more quantitative - in the method A category - are forest growth rates, changes in soil density, moisture infiltration vs. runoff, changes in relative abundance and composition of understory herb and shrub species, and a variety of other characteristics linked to forest productivity. These tools are indicators of ecosystem health in a well-integrated Forest Plan.

Ø      The Department recommends revision of the monitoring of interior northern hardwood patches.  There should be effectiveness and validation monitoring items that relate to 1.4d of Table 4-2a in the M&E plan. Providing large northern hardwood patches should be linked to method A monitoring, and include a periodic measure of deer density, abundance of lily, orchid, and conifer regeneration, (hemlock/cedar/Canada yew), and the productivity of forest interior birds.  This forest community, managed as large patches, will likely develop attributes that differ from those of other ownerships. There will be keen interest from a variety of groups in learning whether they are functioning as expected in supporting species' viability requirements. They warrant special monitoring attention in the effectiveness and validation categories.

Ø      The Department recommends clarification of how the objectives in the M&E plan would be measured.  Perhaps each measurable criterion could be defined further in the Appendix by explaining the inventory process and tools used in monitoring.  For example, in the Terrestrial Ecosystems Goal 1.4, how will certain desired components/structure be measured? Also, the M&E Plan should clearly show which measurements fall into the implementation-monitoring category, and which are directed toward effectiveness and validation monitoring.

Ø      The Department is supportive of any efforts toward monitoring ATV use on the Forests.  With the increasing demand for motorized access on public lands, it is necessary for our State, County and National Forest agencies to monitor the effects of this use. Annual monitoring is needed to determine if, where, and how much resource damage is occurring. In the M&E Plan, monitoring frequency is only every five years. Also, in the M&E Plan, measurable tools or criteria in assessing impacts from ATV use need to be identified in the Appendix, e.g. soil erosion, non-native species, and sedimentation at stream crossings are some indicators of change.  Leadership efforts, strategic planning and collaboration with other agencies in these assessments need to expand, since the demand is increasing for this recreational use across ownerships.

Ø      The Department recommends additional emphasis on monitoring forest productivity. Documenting significant changes in productivity of the land is part of National Forest monitoring requirements (36 CFR 219.12). The M&E Plan has no specific objectives or monitoring questions related to this requirement. It is important to monitor forest productivity as affected by prescriptions and related agency actions, but it is also critical to gather data that will allow assessment of forest change due to other influences (e.g., insects and disease, climate change, air pollution, deer herbivory). Because many Forest Plan projections are based on forest growth rates, it is critical to know whether these rates are changing in response to management and environmental variables. The monitoring information would be valuable in developing adaptive management strategies to minimize potential adverse impacts.

Fire Management

Fire Suppression and Use of Prescribed Fire

Management of fire within the wildland urban interface is an increasingly complex issue in Wisconsin as development of residential homes, recreational cabins, and commercial developments expand throughout northern Wisconsin. This growing wildland urban interface adds significant logistical challenges for suppression actions. Many privately owned inclusions fall within the CNNF boundaries.  This requires the Forest staff to plan for increasing fire occurrence and development of fire suppression capacity.  What are the CNNF plans for suppression and hazard mitigation?  What are the strategies and tactics planned to preserve life safety, protect property, and conserve resources threatened by wildfire? The current Standards & Guidelines for fire suppression are inadequate.

Use of prescribed fire in preferred Alternative #5 also appears to be increasing.  In incorporating greater use of prescribed fire to restore habitats and natural processes, the landscape, planning, logistical and technical considerations, improvements must keep pace.  The current Standards & Guidelines for prescribed fire provide few details on the processes, changes, and long term planning for deciding when fire will be used as a management tool.  Strategies and tactics to preserve life, safety, property, and resources need to be addressed.  Additional pre-planning, description of program policies, and logistical criteria are needed to clearly define the goals and objectives when the use of prescribed fire will be considered.

v      Preferred Alternative # 5 offers very limited description of the CNNF pre-planning efforts to suppress wildland fires and lacks detail on the criteria CNNF will use to manage prescribed fire. The Fire Management section of the Standards and Guidelines section within the Proposed Land and Resource Management Plan 2003 is very brief.  It offers few descriptions or details of how the CNNF will plan for, or provide resources for, either wildland fire suppression or prescribed burning during the next Plan period.  The Plan should provide a dedicated section that clearly describes the core elements that form the CNNF fire suppression policies, processes, structural organization, and desired future condition of the Forests’s fire management program.

In view of the significant wildland fire suppression efforts occurring in the western U.S. in the last decade, as well as increased litigation on prescribed burning incidents, we recommend that the fire management section of the CNNF be revised.   As the State of Wisconsin addresses the current revenue shortfalls and subsequent budget reductions, it is clear that the CNNF will have to develop additional capacity to support prescribed burning needs for the National Forest in Wisconsin. 

v      As residential, recreational, and commercial development increases within and around the CNNF boundaries, the USFS needs to consider and pre-plan for fuel mitigation / reduction efforts within the urban interface.  What does this activity involve, what treatments, where, when, and how?  Should this include development and maintenance of fuel breaks, reduction of hazardous fuel types, thinning of stand densities, conversion of forest types, or other activities?  Are additional staff, equipment, or other fire resources planned for the CNNF in anticipation of the increasing level of residential/commercial development?  Will fuel mitigation involve individual homes, clusters of buildings, or only municipalities?  Is a community Firewise education program in place?  Are water sites being developed or will the CNNF rely on ground suppression or aerial suppression tactics?  Will the fleet of tractor-plow units and the number of Type 7 or Type 8 engines expanded?  Are additional pre-planning efforts considered for seasonal restrictions on timber harvest, recreation and trail use, prescribed burning, and fire detection?  In broadest terms, how will the USFS manage and conduct fire management operations within the CNNF?

As use of prescribed fire increases, criteria need to be developed and implemented to promote the safe and effective use of fire.  Staffing standards, frequencies or cycles of burns, fuel break requirements, RX plan approval processes,  types and fuel types where burns will be permitted, sizes and seasons for burns, notification of adjacent landowners / government agencies, smoke management issues, coordination with other fire agencies,  and pre-burn as well as post-burn evaluations all need to be addressed.  Many prescribed fire logistical issues remain unknown in the current Preferred Alternative #5 or supporting documents.

Recommendation:

Ø      The Department is supportive of efforts to promote expanded use of prescribed fire, but only if proper safeguards are in place.   We would encourage the USFS to review the existing Standards & Guides and develop the criteria referenced above for prescribed fire use.  We would also encourage a review of the Standards & Guides as they relate to the overall Fire Management program on the CNNF.