Ohio Division of Forestry Assessment comments needed by Wednesday, May 26th

[Mary_Krupa]

Below are 16 comments from the Buckeye Forest Council regarding the Ohio Division of Forestry's Ohio Forest Resource Assessment Strategy. Everyone is encouraged to post comments but they are needed by the Wednesday, May 26 .

According to Division of Forestry, "The Forest Assessment provides a comprehensive evaluation of forest-related resources in Ohio, and their current conditions and trends.  The document also identifies Ohio's high priority forest areas and the key issues and threats to forests statewide.  The Statewide Strategy describes the key forest issues in the State and outlines specific strategies that the Ohio Division of Forestry will use to address them, with the support of stakeholders like you.  It supports the Division's mission of promoting and applying management for the sustainable use and protection of Ohio's private and public private forest land.  The draft documents can be downloaded from the Ohio Division of Forestry's website at: http://www.ohiodnr.com/tabid/22319/Default.aspx


If you provide comments about specific issues, objectives, or strategies that are numbered in the Strategy document, please specify which ones you are commenting on. 


Comments can be emailed to Cotton.Randall@dnr.state.oh.us or mailed to: ODNR Division of Forestry, 2045 Morse Road, Building H-1, Columbus, OH 43229-6693." 

If you would also like the BFC to post your comments on our website for ease of public access, send them for consideration to Cheryl@buckeyeforestcouncil.org.
BFC talking points on the DOF FRAS draft and process to date:
DOF and USFS management practices do not support forest health, provision of ecosystem services, human health, long-term economic benefits for Ohioans, or climate stabilization.  This FRAS document, like other DOF materials, highlights the misguided, unscientifically based practices of DOF and USFS.


1.DOF generally acts based on a simplistic view of biodiversity. DOF's use of prescribed fire in habitats in which fire is not natural and in which native species are not fire dependent or fire-adapted is one indication of DOF's misunderstanding of basic ecological principles, such as biodiversity. Critique of this practice presented in full in BFC comments (posted on BFC website).

2.DOF's goal of increasing early successional habitat at the expense of mature forest and of increasingly rare and endangered native forest biodiversity has no basis in ecological principles and is purely the result of industrial short-term profit motives. Critique of this goal presented in full in BFC comments.

3.DOF's management and decision-making are heavily biased toward silviculture, industry interests, and short-term financial motives. Its use of prescribed fire assures access to Federal fire funds created for western, fire-dependent ecosystems. Its interest in oak-hickory at the expense of overall native biodiversity is also heavily influenced by private industry interests. The head of the private industry forestry association sits on the steering committee of this process, while no one with an ecological, non-industrial perspective does. (See BFC comments for discussion of oak-hickory "restoration" goals.)

4.The one member of the steering committee representing a non-profit land conservation group does not reflect the wider environmental community's critique of DOF policies. TNC has publicly supported DOF's logging on state forests and timber plans that were critiqued by ecologists and experienced foresters. While The Nature Conservancy works out compromises with DOF, their relationship does not reflect the broader environmental community's critique of DOF policies and practices.

5.The Comprehensive Wildlife Conservation Strategy referenced in the FRAS draft suffers from the same biases and industry-biased goals for oak hickory and early successional habitat. Both documents use the term "restoration" to discuss goals that attempt to recreate human-induced disturbances and human-created states of nature. Recreating these (even if possible, an open question) has no basis in ecological principles. See below for detailed critique of "restoration" goals.

6.There is no role in DOF decision-making or DOF oversight by unbiased scientists with an ecological perspective. DOF does frequently cite USFS scientists' material, but this is heavily influenced by Bush era goals for public lands, which were entirely dominated by wood product industry interests and access to federal fire money. See for example the report, An Economic Analysis of the 2006 Wayne National Forest Plan for an economic and science-based critique of USFS goals and activities. (available at http://heartwood.org/Wayne_Economic_Analysis/)


7.The FRAS document cites sources selectively, distorting data, intent and conclusions of sources. For example, in citing the 2007 Audubon Ohio State of the Birds Report it neglects to cite the primary and secondary conclusions there––that decrease in yellow chat habitat is the result of intensive farming and development in addition to afforestation, listed third by Audubon but the only reason listed by DOF. Audubon Ohio makes no statement in support of cutting down mature forest to rectify chats' habitat loss but instead suggests, as one would expect, "Drink shade grown coffee to help protect the wintering habitat for yellow-breasted chats," and "Plant brambles and shrubs along edges of farm fields and forest clearings."

8.The document's maps of the Buckeye Trail and other long distance trails do not give any indication of how much "trail" is actually just use of roads, a majority of the mileage. This distorts greatly readers' perceptions of how adequate Ohio's non-motorized forest recreation facilities are.


9.The document also contradicts itself on the level of public interest in outdoor recreation. For example, it cites the 008 SCORP as stating, "A decline in participation in outdoor recreation especially by American youth...all across the country" and concludes, "This trend, combined with reduced budgets, does not suggest a long-term trend toward facility expansion." (p. 90) But later it states, "According to the 2008 Ohio SCORP, over one-third of Ohio households reported participation in the activity of camping."

10.As stated in this FRAS draft document (Criteron 1, indicator #1), reserved forest land in Ohio is less than 204,000 acres (318 of 41,000 square miles), about ¾ of 1% of Ohio's landmass. This is pitiful, especially for a state that was once 97% forested.

11.Note the complete absence of references or data on the extensive logging, as well as use of fire, on public forestland. How could this data not be important to a true assessment of Ohio forests by the Ohio Division of Forestry?

12.Forest management plans cited in the FRAS document are basically just timber and prescribed fire support documents with little basis in forest ecology. There is no public oversight of these plans or of DOF practices generally. See discussion of Criterion 7 (legal framework) in BFC comments.
13.The continuing imperilment (and likely death) of the ODNR Division of Natural Areas and Preserves should be addressed and rectified before DOF and ODNR are entrusted and credentialed with any further "protection" of Ohio's natural "resources."

14.As a document outlining the state of Ohio forests and Ohio Division of Forestry activity, this document should discuss the disastrous 2970-acre fire in the Shawnee State Forest in April 2009, which, from all available evidence, was the outcome of poor planning and escaped fires from a DOF prescribed burn, lit on a day of extreme fire danger across southern Ohio. Given that DOF has not acknowledged any responsibility for this tragedy, DOF's credibility and integrity as an agency of public land protection are particularly urgent questions.

15.The public input process is flawed and biased. Survey questions were poorly written and loaded. Conclusions drawn by DOF, stated in the FRAS draft document, do not reflect actual survey results. Compare for example DOF's list of threats with the results presented in the Appendix and note the huge discrepancies of order and omissions. Much data have not yet been made available to the public for scrutiny. It is unclear whether any un-interpreted public input will make its way beyond DOF to USDA or FSC.


16.Given DOF's industrial priorities and lack of ecological basis for its activities, its entry into the biomass supply system is more than alarming. (See biomass discussion in BFC comments.)


Thank you for your support of Ohio forest protection!


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