September 11, 2003

Forest Plan Revision
Chippewa National Forest
200 Ash Avenue NW
Cass Lake, MN 56633-8929

Dear Forest Planning Team:

On behalf of the Board of Directors and staff of the Friends of the Boundary Waters Wilderness (“Friends”), please accept the following comments regarding the Draft Environmental Impact Statement (DEIS) and Proposed Forest Plan for the Superior National Forest. We appreciate the opportunity to share our concerns, comments and recommendations with you. Please make our comments and enclosed cited documents part of the official record.

The Friends is a non-profit wilderness conservation organization with about 3,000 members from across the country. The mission of the Friends of the Boundary Waters Wilderness is to protect, preserve and restore the wilderness character of the Boundary Waters Canoe Area Wilderness (BWCAW) and the Quetico-Superior Ecosystem. Staff and members attended open houses hosted by the Forest Service, and we appreciate the time and effort taken by Forest Service staff members to present information and to answer our questions.

I. EXECUTIVE SUMMARY

First and foremost, the Friends of the Boundary Waters Wilderness urges the Forest Service to seize the opportunity to permanently protect the few remaining roadless areas in the Superior National Forest, as documented in Preserving the Canoe Country Heritage: A Wilderness Study on Permanently Protecting Minnesota’s Remaining Wild Places. In addition to the study itself, we elaborate on the need for wilderness designation with respect to issues in the DEIS, including forest vegetation, wildlife, watershed health, recreation, and economic and social sustainability.

The Friends of the Boundary Waters Wilderness also offers the following comments and recommendations:

1) The Proposed Forest Plan fails to protect roadless areas inventoried under the Roadless Area Conservation of 2001.

2) The DEIS does not provide justification for the selection of Alternative E.

3) Alternative E’s theme fails to balance multiple use.

4) The Proposed Forest Plan does not provide adequate protection of old growth forest.

5) The Proposed Forest Plan allows unacceptable levels of fragmentation and loss of interior forest.

6) The DEIS lacks discussion of forest tent caterpillar outbreaks.

7) The Forest Plan needs improved controls on ATVs and other recreational motor vehicles.

8) The Forest Plan must improve balance between motorized and non-motorized recreation.

9) The Proposed Forest Plan doesn’t go far enough in meeting the need for change in timber harvest.

10) The DEIS does not present a balanced assessment of the even-aged versus uneven-aged management debate.

11) We commend the Forest Service for its desire to restore the ecological process of fire, but we’d like to see a more detailed discussion of how the Proposed Forest Plan meets the need for change.

II. COMMENTS AND RECOMMENDATIONS ON THE ROADLESS AREA AND POTENTIAL WILDERNESS EVALUATION

A. The Friends urges the Forest Service to seize the opportunity to permanently protect the few remaining roadless areas in the Superior National Forest as documented in Preserving the Canoe Country Heritage: A Wilderness Study on Permanently Protecting Minnesota’s Remaining Wild Places.

Preserving the Canoe Country Heritage is a study that details the results of an exhaustive inventory conducted in 2001 and 2002 on approximately 120,000 acres of roadless areas in the Superior National Forest, and we submit the study as part of our official comments. In preparing this study, the Friends of the Boundary Waters Wilderness, aided by trained field volunteers, conducted an inventory of available lands and gathered data that was then reviewed by a committee of experts.

Of the roadless areas inventoried, the study recommends that approximately 89,000 acres in 24 separate units, receive wilderness protection. The units range in size from approximately 550 acres to approximately 14,000 acres. Nineteen of these units are adjacent to the BWCAW and five are separate from the BWCAW but lie within the Superior National Forest. In some instances, a selected unit creates a natural boundary, such as a river or stream for the BWCAW. A few of the units complete an existing canoe route or create a new one. Many of the units provide opportunities for true wilderness experiences due to their remote locations or rugged landscapes. And many of the units protect wildlife and/or native species habitat.

Our opportunity today is to address the gap between the amount of land currently protected and the amount of land the majority of people in the county, and in Minnesota, would like to see protected. According to a 2000 poll conducted in Minnesota, 83 percent of respondents favored the protection of Minnesota’s roadless areas (Feldman Group 2000). This sentiment echoes that of Americans across the country. More than six in 10 Americans believe that there is not enough wilderness permanently protected for future generations (Campaign for America’s Wilderness 2003). Additionally, Preserving the Canoe Country Heritage is supported by more than 20 organizations located throughout Minnesota and across the country (list attached).

In addition to the comments included in Preserving the Canoe Country Heritage, the Friends wishes to elaborate on some of the issues presented in the draft forest plan and DEIS since we believe that wilderness designation addresses a number of these issues. With permanent protection, these lands will provide healthy habitat for fish, birds, and other wildlife; places for solitude and recreational activities for hunters, anglers, bird watchers, paddlers, campers, hikers, kayakers, and skiers; and clean water for all Minnesotans.

1. Forest Vegetation

a. Wilderness designation helps protect under-represented forest types
The Sugar Maple Landscape Ecosystem (“LE”), the largest component of which is northern hardwood under range of natural variability (“RNV”) conditions, comprises just three percent of Superior National Forest lands (DEIS, 3.2-13). Much of the recommended Cabin Creek Unit is northern hardwood forest, dominated by a mix of red and sugar maple, as well as cedar and birch. Such hardwood forests are not well represented in the BWCAW (approximately one percent of the BWCAW is in the Sugar Maple LE), meaning that the designation of Cabin Creek would add to the diversity of wilderness in the Superior National Forest and help to ensure that hardwood forests are represented in perpetuity. The Seven Beaver Unit is another example where designation would permanently protect under-represented vegetation types. Seven Beaver contains one of the few patterned peatlands outside of the Red Lake area and is therefore ecologically unique among areas in the Superior National Forest.

2. Wildlife

The Superior National Forest lies in a transitional zone between the Great Lakes and boreal forests and therefore possesses a diverse landscape, which houses a vast array of wildlife species. Roadless forests and undeveloped lakeshore are critical to maintaining quality habitat for the wildlife that is an essential piece of the canoe country heritage. The units documented in Preserving the Canoe Country Wilderness represent remnant habitat for forest interior species, threatened and endangered species, and popular game species.

a. Wilderness designation provides habitat for forest interior species, especially migratory songbirds.
During the last decade, concerns have been raised about apparent declines in populations of forest songbirds (Terborgh 1989). Several species may be declining in abundance, and fragmentation of forest breeding grounds is thought to be one of the contributing factors (Robinson et al. 1995). Migratory songbirds, many of which prefer forest interior habitats, rely on unfragmented forest as refuge from high levels of nest predation and parasitism (Noss and Cooperrider 1994).

The Superior National Forest provides important habitat for migratory and other birds. With 155 nesting species, it has the greatest number of breeding birds of any National Forest. For this reason, the American Bird Conservancy named the Superior National Forest one of 100 “Globally Important Bird Areas” in 2001. The forests of northern Minnesota and Wisconsin also may be population sources for certain bird species and may stock population sinks elsewhere in the Midwest (Robinson et al. 1995, Temple and Flaspohler 1998). Thus, the continued existence of unfragmented landscapes, like those recommended for wilderness protection, is important to maintaining the species of birds that thrive in the Superior National Forest.

b. Wilderness designation provides habitat for threatened and endangered species.
The units described in Preserving the Canoe Country Heritage also provide habitat for the three federally-listed threatened and endangered species present in the Superior National Forest, the lynx, the wolf, and the bald eagle. According to the Forest Service’s Roadless Area Evaluation, a few of the areas contain potential “critical habitat” for the Canada lynx. These units include the Homer Lake Unit and the Urho Creek Unit. Signs of wolf were commonly noted by field volunteers as they surveyed the areas, including the Cucumber Lake Unit, the Magnetic Lake Unit, and the Mississippi Creek Unit. Finally, some of the units, like the Echo Lake Unit, contain “super-canopy” white pine trees that could serve as potential nesting trees for bald eagles.

3. Watershed Health
a. Wilderness designation enhances watershed health
Protecting water quality is one of the top wilderness values according to a 2001/2002 poll conducted by the U.S. Forest Service as part of its National Survey on Recreation and Environment. Protection of forest watersheds is essential to ensuring a continuous and safe water supply since the Forest Service estimates that 60 million Americans receive their water from sources with headwaters in a national forest.

Permanent protection of the units described in Preserving the Canoe Country Heritage enhances watershed health. Forests and trees intercept moisture, thereby increasing infiltration into the soil and reducing runoff. They can slow snowmelt, which prevents water, soil, and precious nutrients from being swept away to other areas during spring thaws. Approximately two-thirds of the 24 units contain all or part of at least one lake, and roughly one-half contain several lakes. All units contain one or more streams. Notably, the Seven Beaver Unit contains the headwaters to the St. Louis River. The St. Louis is the largest U.S. tributary to Lake Superior and is popular with recreationists.

4. Recreation

a. Wilderness designation preserves diverse recreational opportunities
Throughout Minnesota, hunting areas are being bulldozed to accommodate suburban and rural subdivisions, and lakes are filled with the buzz of outboard motors. As private lands increasingly become unavailable for recreational activities, there will be greater pressure on public lands, and the National Forests, with their large land bases, are in the best position to provide remote wilderness-type experiences (see 3.7-2 and 3.8-10). Unless the remaining roadless areas are protected, we will lose the vast diversity of recreational experience for which the Superior National Forest is known.

Breaking from daily routines and enjoying outdoor recreational activities is one of the major reasons that people want to protect more wild lands (Tilly 2002). In 2001, nearly 75 percent of Minnesotans engaged in some type of outdoor recreational activity such as hiking, camping, bird watching, paddling and skiing (Tilly 2002). Fifty-four percent took part in wildlife viewing (second highest in the nation), and 39 percent went fishing or hunting (third highest in the nation) (U.S. Fish and Wildlife 2002).

Most of the units recommended in Preserving the Canoe County Heritage offer a variety of outdoor activities. The Echo River unit provides excellent habitat for grouse, partridge, ducks, deer, and moose and is popular for hunting. Paddlers can enjoy a “Boundary Waters-like” experience in the Picket Lake Unit, including camping on one of the lake’s three backcounty campsites. Throughout these units, there are opportunities for solitude and natural experiences which, according to a 1999 nationwide poll, are very important to seven out of 10 hunters and anglers. In fact, 84 percent of hunters and 86 percent of anglers supported efforts to prevent development within roadless areas “to provide hunters and anglers places to hunt and fish with more solitude and no disturbance by vehicles, including off-road vehicles” (Campaign for America’s Wilderness 2003).

Given the remaining roadless areas, the Friends believes that the Superior National Forest is well positioned to offer quality, non-motorized recreation. The Proposed Forest Plan places too much emphasis on motorized recreation opportunities. While the demand for recreation in remote areas is mentioned briefly, there is no extended discussion of how the National Forest will provide opportunities for these users. In its final form, the Forest Plan must provide a better balance. Please see additional comments under section B2.

5. Economic and Social Sustainability
a. Wilderness is consistent with economic and social sustainability
Another major reason the public supports the protection of wild lands is their desire to live near open places, parks, and wilderness that boast strong local economies. In fact, seven of the 10 fastest growing metro areas in the country either border, or are adjacent to, national forests and parks (Tilly 2002). For further discussion, please see our comments under section B1.

The economic benefits of wild lands and recreational opportunities also seem to be evident in the Present Net Value calculations (DEIS, 2-35). Under all alternatives, the Present Net Values are negative when only market values (timber, user fees) are considered. These values become positive when non-market values (recreation) of the forest are included.

B. The Forest Service process for determining wilderness recommendations is flawed.

1. The claim that wilderness designation is inconsistent with the theme of Alternative E is unsubstantiated and counter to available evidence.

The DEIS states, “the process of allocation of potential wilderness areas determined in Alternative E that adding wilderness does not support the theme of enhancing positive effects to the economy and tourism” (3.7-8). If such a claim is the basis for wilderness recommendations, the Forest Service must substantiate its assertion with some sort of analysis that demonstrates the jobs and dollars generated from wilderness versus the jobs and dollars generated from alternative uses. The Friends, however, does not believe that the Forest Service can support its claim.

Research on the relationship between protected lands and economic growth indicates that wilderness benefits local economies. A 2000 study on the relationship between economic growth and roadless and wilderness areas in the eleven western states found that the presence of protected areas and roadless areas positively correlates with employment and income growth (Southwick Associates 2000). The study further stated that “when only rural western counties are studied, the relationship between economic growth and protected areas and Forest Service roadless areas is even stronger,” indicating that rural communities benefit rather than suffer when lands are protected from extractive industries (Southwick Associates 2000). The authors of this study point to the changing role of extractive industries in Oregon and note that tourism and retirement are becoming increasingly important drivers of the state’s economy.

Data on Minnesota’s economy seems to indicate a similar situation. A report issued by The Wilderness Society states that “timber-related industries represent a small percentage of the Minnesota economy, as measured by jobs and personal income” (The Wilderness Society 2002). Conversely, the industries providing the most jobs in the state are services (31.2 percent), retail trade (16.6 percent) and non-forest products manufacturing (12.1 percent). Services and finance, insurance, and real estate are examples of fast-growth industries that saw increases in jobs and income in 1999, while timber-related industries saw a decrease in earnings as a percent of Minnesota personal income (The Wilderness Society 2002).

At first glance, wilderness recreation generates only a modest amount of revenue compared to other forms of recreation and tourism (Rudzitis and Johnson 2000). However, the impact of wilderness on local economies is based on more than the amount of money visitors spend on wilderness-related recreation. The influence wilderness has on drawing in new residents and keeping current residents should not be underestimated. A study conducted by Gundar Rudzitis attempted to determine why people were moving to counties with designated wilderness and wildlands. By analyzing the results of questionnaires sent to both recent migrants and long term residents of these counties, Rudzitis found that wilderness plays an extremely important role in the growth of wilderness counties. In fact, when asked to reveal the single most important factor influencing their decision to move to their current location, 23 percent of respondents cited employment opportunities, while 35 percent cited reasons specific to the physical environment of the area. An additional 42 percent cited other factors related to the county’s social environment. This study revealed that an overwhelming majority moved for amenity-related reasons (Rudzitis and Johnson 2000).

Rudzitis and Johnson cite research that indicates that the benefits of proximity to protected lands are not lost on entrepreneurs and businesses. They state, “in a series of studies, William Beyers and associates found amenity factors to be among the major factors in the location decisions of producer service firms nationwide…” The data indicate that the consideration of amenities should be included in a community’s strategic plan for economic development (Rudzitis and Johnson 2000).

Some numbers from Cook County, home of a section of the BWCAW, seem to indicate that similar growth is occurring in Minnesota. Cook County saw a 34 percent increase in population since 1990 (U.S. Census Bureau 2000). These numbers are significant because they reinforce the idea that environmental amenities influence where people choose to live, and that these amenities strengthen and encourage local economies.

While wilderness boosts local economies by attracting residents, companies, and tourists to rural areas, wilderness also provides services such as carbon sequestration and water filtration. These are valuable services that nature provides. If government, or other, entities had to provide these services, the costs would be enormous. Loomis and Richardson estimate that the preservation of 42 million acres of national forest roadless areas would yield an annual benefit of $490 million to $1 billion for carbon sequestration services and $490 million for waste treatment services (2000).

2. The wilderness evaluation process is fatally flawed.
a. The step-wise process of capability, availability, and need is unsound.
According to the DEIS, the wilderness evaluation process involves assessing each inventoried area for capability, availability, and need in a step-wise process (3.7-3). The capability of potential wilderness is defined as “the degree to which it contains the basic characteristics that qualify it for wilderness designation” (DEIS, 3.7-3). Inventoried areas that pass the capability step, then are evaluated for availability, which is determined by “comparing wilderness values in that location to the value of and need for other resource uses and production from the same land area” (DEIS, 3.7-3). Those inventoried areas that have passed the first two steps are evaluated for need by “comparing the value of a potential area to existing wilderness in nearby locations as well as to the National Wilderness Preservation System as a whole” (3.7-3).

The Friends is concerned that this step-wise process for evaluating potential wilderness areas places the biological and social needs for wilderness below the needs for other resource uses since only areas passing the availability assessment are considered in the need assessment. We strongly feel that the issues considered in the need assessment are at least as important as those in the availability assessment.

b. The planning documents do not include any specific discussion of the need analysis.
Page 3.7-10 of the DEIS states that the “biological and social needs analysis was done, at a local scale when allocation of potential wilderness area was made, while giving consideration to the theme of an alternative.” Neither the DEIS, the Proposed Forest Plan, nor Appendix C (Roadless Area Inventory and Evaluation Potential for Wilderness Designation) provide a discussion of the biological and social needs of each area. Nor do any of these documents describe the criteria by which potential wilderness areas were allocated to alternatives. A more thorough explanation of the process and better documentation is needed in the Final EIS and Record of Decision.

Our failure to understand the needs assessment is heightened by the fact that not one potential wilderness area passed this assessment level in Alternative E. As already noted above, available research indicates that wilderness enhances local economies through tourism and by attracting residents and businesses with a high quality of life. We also point to the popularity of the BWCAW as evidence of the social need for more designated wilderness. As the Forest Service rightly points out, demand for recreation in unroaded areas is growing, and the decline of unroaded areas may limit the ability to meet future demand (DEIS, 3.7-2 and 3.7-10). The BWCAW is unique among areas within the National Wilderness Preservation System due to its extensive opportunities for canoe-based recreation. Its uniqueness makes the BWCAW one of the most popular wilderness areas in the country. At its present size, it will be difficult to meet future demand. Therefore it is inconceivable how the Forest Service failed to identify any additional wilderness land. On a final note, while Quetico Provincial Park may provide an experience similar to the BWCAW, it is a Canadian Park and thus does not contribute value to the U.S. National Wilderness Preservation System (DEIS, 3.7-10).

C. The Proposed Forest Plan fails to protect roadless areas inventoried under the Roadless Area Conservation Rule of 2001.

The Roadless Area Conservation Rule (“Roadless Rule”) was published in the Federal Register on January 12, 2001. The Roadless Rule established a policy to protect 58.5 million acres of roadless areas in our national forests by generally prohibiting road building and logging in these areas. Its purpose was to preserve important forest values such as wildlife, clean water and recreational opportunities, and to spare federal taxpayers from the $8.4 billion backlog in the National Forest road system. The draft Forest Plan does not address compliance with the Roadless Rule for the 62,000 acres of inventoried roadless areas in the Superior National Forest.

We recognize that the Roadless Rule is currently under challenge in federal court, however, the Superior National Forest must comply with this rule of law until such a time that the Roadless Rule is abandoned or revised. Thus, the Forest Plan needs to include a special designation for inventoried roadless areas, provide a map locating these areas within the forest, and indicate what types of activities will be allowed in these areas. Finally, the Plan must outline a decision-making process for activities such as fire management and insect control, which are permitted in roadless areas under the Roadless Rule.

III. SELECTION OF ALTERNATIVE E

We have two concerns regarding the selection of Alternative E as the preferred alternative. First, the justification for selecting Alternative E is unclear, and second, the theme of Alternative E fails to balance multiple uses of the Superior National Forest.

A. The DEIS does not provide justification for the selection of Alternative E

After reading the Executive Summary, DEIS, and the Proposed Forest Plan, we find no discussion explaining how or why Alternative E was chosen as the preferred alternative. We believe that the absence of such a discussion is a fundamental omission in the planning documents. It is not clear how Alternative E better meets forest goals than the other six alternatives or how the public might better be served by the selection of Alternative E.

B. Alternative E’s theme fails to balance multiple uses

1. The proposed plan over-emphasizes economic issues

The lack of any discussion justifying the selection of Alternative E is even more troubling because the theme of Alternative E reflects only a narrow focus to the purpose of National Forests. According to the DEIS, “Alternative E emphasizes a diverse economic base in local communities” (2-25). It is the Friends’ position that the Forest Plan for Superior National Forest should emphasize the ecological purposes of forests as well as any economic purposes.

The Organic Administration Act describes the purpose for which National Forests were established:

No national forests shall be established, except to improve and protect the forest within the boundaries, or for the purpose of securing favorable water flows, and to furnish a continuous supply of timber for the use and necessities of citizens of the United States (16 U.S.C. § 475)

The Multiple-Use Sustained Yield Act builds upon the Organic Administration Act and provides further direction that the national forests should be managed for a broad range of resources.

It is the policy of Congress that the National Forests are established and shall be administered for outdoor recreation, range, timber, watershed, and fish and wildlife purposes (16 U.S.C. § 528).

Therefore, National Forests were not established for economic purposes alone; they must also be managed for the protection of the forests, water, and wildlife. Furthermore, the interests of all citizens must be considered equally to the interests of communities near forests.

2. The proposed plan’s emphasis on economic issues comes at the expense of the forest’s ecological health

Alternative E is inferior to other alternatives in its ability to sustain ecologically healthy forests, providing further evidence that Alternative E is not an appropriately balanced alternative. The DEIS itself states that “overall, this alternative tends to manage Superior National Forest lands in such a way as to contribute minimally towards the desired landscape goals for forest vegetation within the Northern Superior Uplands (“NSU”) and in moving them toward RNV” (3.2-49).

Further evidence of the Proposed Plan’s inferiority is provided in an assessment of the seven alternatives conducted by NRRI. While we commend the Forest Service for using some of the tools RNV analysis provides, Alternative E is a poor choice for a preferred alternative if the agency truly desires to move forests closer to RNV. According to the report, Alternative E maintained more young forest across all Landscape Ecosystems (“LEs”) than B, D, F, and G but does allow development of significantly more mature-late successional forest than A and C (White et. al. 2003). While Alternative E may be better than A and C, it should be noted that both these alternatives “pose a risk to the viability of the above [sensitive wildlife] species” (DEIS, 3.3.5, Sum-35), and therefore Alternative E could be considered the worst ecologically among the remaining reasonable alternatives.

IV. COMMENTS ON FOREST VEGETATION

A. The Proposed Forest Plan does not provide adequate protection of old growth forest

The small amount of remaining old growth in the Superior National Forest will not be protected under the Proposed Forest Plan. The Plan lacks measurable objectives for old-growth protection, fails to use the widely accepted definition of old-growth, and does not include a special designation for old-growth stands.

According to the Proposed Forest Plan, “objectives are measurable steps taken within a specified timeframe to move toward a desired condition” (1-7). Objective O-VG-15 is to “increase acres of old forest, old-growth forest, and multi-aged upland forest vegetation communities” (2-11). Without a targeted level of increase, this objective is not a measurable objective. A specific amount by which old-growth will be increased needs to be identified.

Second, the draft plan suffers from an incomplete definition of old growth. The Forest Service generally defines old growth as “a forest that has developed relatively free of stand replacement disturbances over a long period of time” (DEIS, Glossary-21). The standard and widely agreed upon definition of old growth includes stands of natural origin (not regeneration from harvest), long-lived forest types, and age of greater than 120 years. The Forest Service should be using this definition.

Using the accepted definition of old-growth, the only credible and effective means of protecting old growth forest is to identify old-growth stands and protect them in reserved status within areas like RNA, SMCs, Wilderness, or as a separate category of special designation. Such designation was one of the mitigation measures identified in the Generic Environmental Impact Statement on Timber Harvest and Forest Management in Minnesota (Jaakko Poyry Consulting 1994).

Finally, the Friends believes that the Forest Service over-estimated the contribution of the BWCAW to old growth forest. According to the DEIS, the BWCAW contains more than 800,000 acres of forest that contribute to the old-growth condition (DEIS, 3.2-42, table FAC-34). This is an excessive assessment. Again, the Forest Service must begin using the standard definition of old-growth. Using this definition, there are a number of sources that point to more accurate assessments of old-growth forest in the BWCAW. Using data from Heinselman (1996), we estimate approximately 154,000 acres of old-growth before the 1999 blowdown. The 2001 FEIS for the BWCAW Fuel Treatment indicates about 108,000 acres of primary long-lived upland and lowland forest after the 1999 blowdown (Table 3.7-3).

From: Heinselman (1996), Table 4.1

From: BWCAW Fuel Treatment FEIS (2001), Table 3.7-3

Plant Community Acres Plant Community Acres

Red Pine 17,700 Primary mesic white-red pine forest 33,482

Black-Spruce-feathermoss 28,700 Primary dry-mesic white-red pine forest 28,193

Maple-oak - Lowland conifer forest 60,047

Aspen-birch-white pine 21,400

Maple-aspen-birch 32,300

White cedar 17,700

Mixed conifer swamp forest 2,300

Black-spruce bog forest 33,200

Tamarack bog forest 500

Ash-elm swamp forest 500

Total Virgin Forest Acres 154,300 121,722

Post blowdown:

108,127

B. The Proposed Forest Plan allows unacceptable levels of fragmentation and loss of interior forest.

As noted in a previous section of our comments, interior forest represents essential habitat for a number of wildlife species, including migratory songbirds. Previous losses of interior forests may already be harming populations of some species. Alternative E has the objectionable outcome of further decreasing the amount of interior forest. According to the DEIS, interior forest will decrease by 23 percent in the first decade and 28 percent in the second decade under Alternative E (3.2-66). The total area of interior forest within mature or older upland forest patches doesn’t return to today’s level even after 100 years (DEIS, 3.2-67). Meanwhile, the amount of edge habitat is expected to increase beyond existing levels (DEIS, 3.2-69). The Forest Service should be working to increase large patches of interior forest; further loss is totally unacceptable.

C. The DEIS lacks discussion of forest tent caterpillar outbreaks

The “Forest Insect and Disease” section should include a discussion that considers the effects of above-RNV aspen levels on outbreaks of forest tent caterpillars. With aspen levels above RNV, caterpillar outbreaks may be worse than they would be under natural conditions. The 2001 and 2002 outbreaks of tent caterpillars and subsequent population explosion of “friendly flies” was a concern for many tourists, and therefore may have an adverse economic impact.

V. COMMENTS ON RECREATION

A. The Forest Plan needs improved controls on ATVs and other recreational motor vehicles (RMVs).

In Minnesota, there are approximately 250,000 users of off-highway vehicles (OHVs), which include all-terrain vehicles (ATVs), off-road motorcycles, and 4x4 trucks. The growing, and seldom enforced, use of OHVs on our public lands often results in habitat degradation, air and noise pollution, soil compaction and erosion, and conflict with people seeking non-motorized recreation. In some cases, the destruction of public lands is startling (Meersman 2002).

The need for a sensible and thorough policy for OHV use on public lands is now widely accepted. Such a policy must include a “designated routes only” provision, environmental review of proposed trails, and adequate funding for enforcement and restoration. The draft forest plan for the Superior National Forest falls far short of this goal.

First, while the Chippewa National Forest prohibits ATV use on Forest Service unclassified roads (standard S-RMV-1), there is no such standard for the Superior. Thus, ATV travel will be allowed on hundreds of unclassified roads, which is sure to exacerbate environmental damage and user conflicts. We urge the Forest Service to provide the same protections for the Superior National Forest as are provided for the Chippewa.

Second, allowing ATV use in Riparian Emphasis Management Areas (“MAs”) is completely contrary to the purpose that “riparian ecological functions are actively restored, protected, and enhanced in areas where ecosystem processes are sensitive to degradation (Proposed Forest Plan, 3-29).” ATVs are known to cause soil erosion, destroy vegetation, and to be a vehicle for the spread of exotic species, and therefore have no place in sensitive riparian habitats. To this end, we request that Desired Condition D-RE-7 be amended to exclude ATVs from Riparian Emphasis MAs, and that Desired Condition D-RE-9 be eliminated completely.

Finally, we do not believe the draft forest plan includes sufficient securities that temporary roads will be closed to RMV use. Statements that temporary roads will be “effectively” closed provide little comfort since there are numerous examples of ineffective closures across the forest (Cheney 2002; Friends’ ATV fact sheet). The Friends requests a discussion of what an effective closure entails and how this differs, or improves upon, past Forest Service practice.

B. The Forest Plan must improve balance between motorized and non-motorized recreation.

Additionally, the planning documents emphasize the demand for motorized access over other types of recreation. According to the Proposed Forest Plan, only 34 percent of the Superior National Forest is in a non-motorized Recreation Opportunity Spectrum (ROS) class objective, and this includes the BWCAW. Thus, there are only 3,493 acres of non-motorized semi-primitive (SPNM) areas outside the BWCAW (DEIS, 2-27, Table 2-5). This small amount of non-motorized forest is inadequate.

For example, the proposed plan does not provide for the establishment of wildlife viewing trails. According to the U.S. Fish and Wildlife’s 2001 National Survey of Fishing, Hunting, and Wildlife-Associated Recreation, Minnesota ranks second in the nation as a state of “wildlife watchers.” The number of wildlife enthusiasts who participate in bird watching, wildlife tourism, bird feeding and wildlife photography in Minnesota has increased 53 percent over the past five years. Wildlife watchers now outnumber hunters by a factor of more than three to one. In light of these statistics, the Forest Plan should address how these demands will be met.

Additionally, the Proposed Forest Plan does not give sufficient protection to the remote character, viewshed, and scenic qualities of the Superior Hiking Trail. The Superior Hiking Trail is one of Minnesota’s premier hiking experiences, and more than 70 miles of the Trail traverse Superior National Forest land. The final Forest Plan must contain specific standards and guidelines for protecting the scenic values of the trail.

VI. COMMENTS ON TIMBER

A. The Proposed Forest Plan doesn’t go far enough in meeting the need for change in timber harvest.

Appendix A of the Proposed Forest Plan discusses the need for a new forest plan. Switching timber management to a more ecological approach was one of the issues identified in this “need for change” section. Alternative E, however, does not satisfy the need for a new approach.

From 1992 to 2002, the Superior National Forest displayed an average annual cut of 75 million board feet (mmbf) (DEIS, 2-35, Table 2-9). Alternative E proposes to increase this level to 82 mmbf. Additionally, even-aged management techniques, or clearcutting, will remain the predominant harvest method on the Superior National Forest. Clearcutting will account for 71 percent of timber harvest. Thus, the Proposed Forest Plan does not significantly change harvest levels or harvest methods from those in the current forest plan. The Friends urges the Forest Service to make some meaningful progress towards a new, ecologically-based timber harvest.

B. The DEIS does not present a balanced assessment of the even-aged versus uneven-aged management debate. In fact, it does not even include a balanced treatment of the positive and negative effects of clearcutting.

The Proposed Forest Plan for Superior National Forest states, “the issues of forest age-class distribution, uneven-aged versus even-aged prescriptions, and timber supply will be analyzed in the [DEIS] that will be prepared for the Forest Plans” (A-11). The “timber” section of the DEIS, however, does not include an adequate discussion of even-aged versus uneven-aged management. While the DEIS discusses the positive aspects of clearcutting, namely the economic benefits, it fails to consider all of the negative effects. It mentions visual resources but fails to address issues such as chemical application, soil erosion, or forest health issues in the “timber” section. It appears that the Forest Service pays lip service to the letter from Forest Chief F. Dale Robertson (DEIS 3.4-2), which encouraged a nationwide decrease in clearcutting, while the Proposed Forest Plan calls for the continued use of this management strategy.

Furthermore, the DEIS directs the reader to find explanations of environmental effects throughout the other sections of the document. This makes it extremely difficult for the reader to fully understand the effects of timber harvest on wildlife, RNV and watershed health. The discussion of effects should be located in one place so that the reader may easily understand the Forest Service’s analysis.

VII. COMMENTS ON THE ROLE OF FIRE

In 2001, the Friends affirmed a position on the role of fire in the Quetico-Superior Ecosystem as part of our official comments on the BWCAW Fuel Treatment DEIS. Our position is: The Friends of the Boundary Waters Wilderness believes that fire is an essential ecological process in the Boundary Waters Canoe Area Wilderness. We support allowing natural fire in the wilderness to the greatest extent possible. To move toward and replicate a natural fire regime, we support prescribed fires that mimic the ecological effects of natural fires. To that end, we offer the following comments on the role of fire.

A. To the maximum extent possible, the Forest Plan should use fire as a management tool.

Nearly the entire terrestrial Quetico-Superior Ecosystem is dependent upon fire (Heinselman 1973). Fire determines the species composition, age classes, and spatial patterns of forests. The dominant fire regime consisted of large-scale crown fires or high-intensity surface fires that killed most of the vegetation across large areas, resulting in new even-aged forests. Additionally, low-intensity creeping fires that killed only portions of stands were common in red and white pine stands. The dynamic mosaic of forest communities resulting from periodic fire maintained a high degree of species diversity and a long-term stability in the ecosystem.

Fire also affects ecosystem nutrient cycles and productivity. The forest soils of the Quetico-Superior are relatively infertile, with the majority of nutrients tied up in the biomass of living and un-decomposed plants. Fire serves as an agent of renewal by consuming living and dead plant material and re-depositing nutrients as ash on the forest floor. This release of nutrients spurs production of new vegetation and completes the renewal cycle.

During the past century, the removal of fire from the Quetico-Superior has altered forest species composition and age. For example, the abundance of jack pine has declined because it requires the heat of fire to open its cones and drop its seeds. Unnatural fuel accumulations pose an enormous threat to rare and endangered resources, such as old-growth red and white pine, which are among the most endangered forest communities of the entire Great Lakes region (Heinselman 1996).

In addition to vegetational changes, the Quetico-Superior will experience long-term changes in wildlife species. The scarcity of recent burns in the BWCAW presents food and resource problems for black bears, moose and beaver. Eventually, the removal of fire could cause an overall decrease in wildlife diversity.

Finally, the removal of fire from the Quetico-Superior Ecosystem has altered the process of nutrient cycling. Nutrients that would otherwise be returned to the soil via fire are now instead tied up in the biomass, slowing the production of new forest growth.

Because fire is such a fundamentally important element of the Quetico-Superior Ecosystem, no conservation measure is more essential than restoring natural fire regimes. The Friends believes that prescribed fire is a step that will move us toward this long-term goal. We would like to see lightning-ignited fires play a greater role in the Quetico-Superior than they do now. We realize, however, that for practical reasons, this may not always be feasible. Prescribed burns that mimic the ecological effects of natural fire can then be used to move the ecosystem toward a more natural fire regime. We encourage the Forest Service to use fire as a management tool to the maximum extent possible.

Former Forest Service ecologist Dr. Miron "Bud" Heinselman, the first Chairman of the Friends of the Boundary Waters Wilderness, perhaps expressed it best: "We will be living dangerously if we fail to move aggressively into more proactive fire-management programs that could restore a more natural patch mosaic of forest communities and age-classes to the landscapes of the BWCAW and Quetico, and in the process break up the vast areas of unnaturally homogenous connected forest fuels. If we do not, nature may very well do it for us. If we wait too long, the result could be an unnaturally large holocaust that would reduce the biodiversity of the wilderness" (Heinselman 1996).

B. The Friends requests a more detailed discussion of how the Proposed Forest Plan meets the need for change with respect to fire management.

Objective O-VG-10 is to “increase amount of a variety of prescribed burning practices to restore the ecological process of fire and provide habitat for threatened, endangered species and other wildlife that require burned vegetation” (Proposed Forest Plan, 2-11). This goal is not measurable because it does not specify a target level of increase or indicate what the “variety of prescribed burning practices” is. Furthermore, according to the DEIS, Alternative E proposes to use fire on a small scale to mimic natural disturbance, and therefore will only somewhat contribute to the enhancement of fire dependent species and their associated ecosystems (emphasis added) (3.5-8). The word “somewhat” does not provide a clear, specific indication of the effects of Alternative E. Therefore, we question the extent to which Alternative E responds to the “Known Problems with Existing Forest Plan Direction” (Proposed Forest Plan, A-14).

We commend the Forest Service for working to restore fire to the Superior National Forest, but we hope to see more specific details as to how the final Forest Plan will meet this goal.

Again, the Friends appreciates the opportunity to comment on the Proposed Forest Plan and DEIS for the Superior National Forest. We look forward to receiving more information as the planning process progresses.

Kind regards,
Sarah Strommen
Policy Director

Melissa Lindsay
Executive Director

VIII. LITERATURE CITED
Campaign for America’s Wilderness. 2003. A Mandate to protect America’s wilderness: a comprehensive review of recent public opinion research. Durango, CO: Campaign for America’s Wilderness.

Cheney, C. 2002. Memo to Forest Supervisor regarding wilderness boundary and illegal road use. July 19.

The Feldman Group, Washington D.C., 2000 poll.

Heinselman, M. 1996. The Boundary Waters Wilderness Ecosystem. Minneapolis: University of Minnesota Press.

Jaako Poyry Consulting. 1994. Generic Environmental Impact Statement on Timber Harvest and Forest Management in Minnesota. Prepared for the Minnesota Environmental Quality Board.

Loomis, J. and R. Richardson. 2000. Economic values of protecting roadless areas in the United States. Washington, D.C.: The Wilderness Society.

Meersman, T. 2002. “Nature pays the price as ATVs hit the woods.” Minneapolis Star Tribune, February 24.

Noss, R. and A. Cooperrider. 1994. Saving Nature’s Legacy: Protecting and Restoring Biodiversity. Washington D.C.: Island Press.

Robinson. S.K., F.R. Thompson III, T.M. Donovan, D.R. Whitehead, and J. Faaborg. 1995. Regional forest fragmentation and the nesting success of migratory birds. Science 267:1987-1900.

Rudzitis, G. and R. Johnson. 2000. The impact of wilderness and other wildlands on local economies and regional development trends. USDA Forest Service Proceedings RMRS-P-15, VOL. 2:14-26.

Southwick Associates. 2000. Historical economic performance of Oregon and western counties associated with roadless and wilderness areas. A project of the Oregon Natural

Resources Council and the World Wildlife Fund.

Superior National Forest. 2001. FEIS for the BWCAW fuel treatment.

Temple, S.A. and D.J. Flaspohler. 1998. The edge of the cut: implications for wildlife populations. Journal of Forestry 96:22-26.

Terborgh, J. 1989. Where Have All The Birds Gone? Princeton: Princeton University Press.

Tilly, J. 2002. Human powered outdoor recreation: state of the industry study. Boulder, CO.

U.S. Fish and Wildlife. 2002. 2001 national survey of fishing, hunting, , and wildlife-associated recreation.

White, M.A., T. N. Brown, and G. E. Host. 2003. A comparison of plan alternatives to RNV for landscape ecosystems in the Chippewa and Superior National Forests. A report prepared for the Minnesota Center for Environmental Advocacy.

The Wilderness Society. 2002. Minnesota’s national forest and the Minnesota economy. Washington, D.C.: The Wilderness Society.

* Cited literature that is not easily available is included with our comments.