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Intensive Forestry Operations in the Pinelands:
A Request for Action by the Endangered and Nongame Species Advisory Committee
November 19, 2003
Prepared By: Pinelands Preservation Alliance
New Jersey Audubon Society
Contents
Exhibit Index ..................... 2
1. Introduction ..................... 3
2. Interest of ENSAC ..................... 3
3. Forestry in the PNR and the Forest Stewardship Program ..................... 4
A. The Pinelands and the Forest Stewardship Program ..................... 4
i) Enrollment in the Forest Stewardship Program ..................... 4
ii) Pinelands Forestry Standards ..................... 5
B. Production Based Management ..................... 6
4. The Pinelands Forest ..................... 8
A. Identification by Classification ..................... 8
B. Identification by Associated Species ..................... 9
C. The Pine Barrens Make For Poor Cropland ..................... 9
5. Plantation-Style Forestry ..................... 10
6. Impacts of Plantation-Style Forestry ..................... 10
A. Pests and Pathogens ..................... 10
i. Fusiform rust fungus ..................... 10
ii. Insects ..................... 11
B. Invasive Plant Species ..................... 12
C. Impacts on Wildlife ..................... 12
i. Birds ..................... 12
ii. Nonavian ..................... 13
iii. Game Species ..................... 14
D. Soils ..................... 14
7. Summary ..................... 16
8. Requested Action by ENSCA ..................... 17
Exhibit Index
Exhibit Book I:
- Pinelands Forestry Regulations and Background Information Tabs A – G
- Documents and Papers Which Support Agroforestry Concern Tabs H – U
Pinelands Forestry Standards; N.J.A.C. §§ 7:50-6.41 – 6.47 (CMP) ... Tab A
Memorandum of Agreement between the Pinelands Commission and DEP (1997) ... Tab B
Memorandum: "Forestry and Threatened or Endangered Animal Species" (9/24/96) Tab C
New Jersey Register, Vol. 27 No. 20 (10/16/95) (Print) ... Tab D
New Jersey Register, Vol. 28 No. 10 (5/20/96) (Print) ... Tab E
Memorandum: "Recommendations for the Pinelands Forestry Program" (11/1/94) ... Tab F
Excerpt: Comprehensive Management Plan for the Pinelands National Reserve
November 21, 1980; pp. 234 –235 "Forestry Program" ... Tab G
Excerpt: Classification of Vegetation Communities of New Jersey: 2nd Iteration ... Tab H
Letter of A. Windisch; Re: Haines and Haines forestry proposal (6/5/03) ... Tab I
Paper: "Cost Effectiveness of Natural Regeneration for Sustaining Production
Continuity in Commercial Pine Plantations" ... Tab J
Notes: N.J. Audubon Society: "Impacts of Agroforestry on Natural Pine Ecosystems" Tab K
Paper: "The Effects on Bird Communities of Converting Southern
Hardwood Forests to Pine Plantations" ... Tab L
Report: "An Assessment of Forest Change on the Cumberland Plateau in
Southern Tennessee" Tab M
Paper: "Use of Forested Habitat By Breeding Birds in the Gulf Coastal Plain" ... Tab N
Paper: "Winter Birds in a Developing Pine Plantation" ... Tab O
Report: The Northern Bobwhite Conservation Initiative; "A Report on the
Status of the Northern Bobwhite and a Plan for Recovery of the Species" ... Tab P
Paper: "Belowground Microbial Processes Underpin Forest Productivity" ... Tab Q
Notes: Jonsson, Lena: Soil Notes ... Tab R
Paper: "Glyphosate, Part 2: Human Exposure and Ecological Effects" ... Tab S
Article: Chattanooga Times Free Press (2/8/02) ... Tab T
Paper: "Forest Herbicide Benefits and Developments for Intensive Southern
Pine Culture" ... Tab U
Exhibit Book II:
- Lee Brothers Forest Management Plan and Associated Correspondence and Plan Amendments
- Haines and Haines Forest Management Plan and Associated Correspondence
1. Introduction
Recently, forest management plans have been created for private lands within the Pinelands which anticipate the use of intensive forest management practices. These activities are intended to optimize conditions for wood fiber generation at sites within the Pinelands through the removal of all native terrestrial vegetation, disruption of existing soil conditions, re-planting of the site with a uniform species, and ongoing maintenance to limit competition.
Forestry has been a part of the Pinelands ecosystem since at least colonial settlement. Forestry activities have not only helped define the Pinelands we see today, but certain forestry practices and techniques may even be used to enhance fire deprived forest communities.
However, large scale, intensive, plantation-style forestry has not been a part of the Pinelands forest community. These intensive forestry practices, specifically designed to replace the existing forest associations with a monoculture plantation, are not compatible with the need to maintain native, locally characteristic Pinelands forest communities. Further, by removing and replacing entire forest communities, these practices will likely jeopardize the health and welfare of the rare, threatened and endangered species using the native forest communities.
The native forests of the Pinelands are a recognized land resource of the Pinelands National Reserve (PNR). Regulations designed to protect the forest resource specifically require that "all silviculture and reforestation practices shall serve to maintain native Pinelands forest types, including those that are locally characteristic ... ." Though this rule is clear on its face, at this time there are no detailed guidelines available to guide Pinelands compatible forestry practices.
The absence of detailed guidelines has encouraged landowners to propose forest management plans that anticipate using plantation-style silviculture and reforestation practices. These practices will cause great harm to the Pinelands forests. Plantation-style forestry transforms the native forest community into single-age, monotypic stands which are devoid of structural diversity, habitat poor, and are at high risk of loss from pests and pathogens.
Adequate guidelines must be created for, and applied to, forestry operation within the Pinelands before the native forest community is lost.
2. Interest of ENSAC
Established by the New Jersey Statutes at §23:2A-7(e), the Endangered and Nongame Species Advisory Committee ("the Committee") is that group of experts appointed by the Commissioner of DEP to advise and assist the Commissioner in matters pertaining to the conservation of wildlife, and in carrying out the mandate of The Endangered and Nongame Species Conservation Act.
Native Pinelands forest communities support many rare species and important wildlife populations. The advent of plantation-style forestry practices in Pinelands raises significant questions regarding wildlife conservation in general, and compliance with the state Endangered and Nongame Species Conservation Act. Consideration of the impact of intensive forestry practices is squarely within the Committee's mandate.
3. Forestry in the PNR and the Forest Stewardship Program
The forests of the Pinelands are one of the land resources of local and national interest designated for special protection under the National Parks and Recreation Act of 1978 (16 U.S.C. § 471i) and the Pinelands Protection Act (N.J.S.A. 13:18A-1 et seq.). Though protection of the Pinelands forest resource is required, management of the forest resource for wood production is needed. The forestry program set out in the Pinelands Comprehensive Management Plan is intended to preserve and protect the forest resource, while providing for traditional lifestyles which are compatible with the ecological values of the Pinelands. See Comprehensive Management Plan for the Pinelands National Reserve, November 21, 1980, page 234 [Tab G]. Thus forestry and forest protection are considered potentially compatible.
In order to balance the need to protect native Pinelands forests, and the rare species that live in them, while allowing forestry operations to be conducted, Pinelands rules require that "[a]ll silvicultural and reforestation practices [in the Pinelands] shall serve to maintain native Pinelands forest types, including those that are locally characteristic, except on those parcels where other forest types exist." N.J.A.C. 7:50-6.45(a)(3). Additionally, "[a]ll forestry activities and practices shall be designed and carried out so as to comply with the [threatened and endangered plant and wildlife] standards set forth in N.J.A.C. 7:50-6.27 and 6.33." N.J.A.C. 7:50-6.45(a)(5) [Tab A].
A. The Pinelands and the Forest Stewardship Program
For purposes of Pinelands regulations, forestry is considered "development." All development in the Pinelands ordinarily requires that a development application be submitted to and approved by the Pinelands Commission prior to commencing any project. Forestry projects in the Pinelands then could be subject to review by the Pinelands Commission under a development application, and also by the state Forest Service for compliance with standard silviculture practices.
In order to avoid duplicative review, a mechanism was established whereby forestry operations could be conducted on properties enrolled in the New Jersey Forest Stewardship Program without the need to submit a Pinelands development application. See N.J.A.C. 7:50-6.43(a) and 28 N.J. Reg. 2596(a)(May 20, 1996) [Tab E]. Acceptance of a parcel into the Stewardship Program (enrollment) acts as Pinelands "approval" of the forestry project.
i) Enrollment in the Forest Stewardship Program
The mechanism for enrollment in the Forest Stewardship Program for parcels located in the Pinelands is set out in a Memorandum of Agreement between the Pinelands Commission and the DEP (MOA of 5/22/97)[Tab B]. To accept enrollment, the DEP, through its State Forestry Stewardship Coordinating Committee, established a Pinelands Stewardship Technical Subcommittee. The Pinelands Stewardship Technical Subcommittee is made up of three people: a Regional Forester, a Pinelands Commission staff member, and a DEP Parks and Forestry staff member.
For parcels in the Pinelands, a Forest Stewardship Plan (a/k/a forest management plan) is submitted to the Regional forester, who then delivers the management plan to the Technical Subcommittee. The Technical Subcommittee determines i) whether the management plan is complete, ii) whether the plan is consistent with the forestry standards of the CMP, and iii) whether the property is eligible for enrollment in the Stewardship Program. Favorable determination as to each element results in enrollment into the Stewardship Program.
A forest management plan must contain certain general information and information regarding cultural resources and threatened or endangered species. See MOA of 5/22/97 pp. 2-4 [Tab B]. There is no explicit requirement for a forest management plan to include a description of the local forest community (the local vegetative association), though a strict reading of the content requirements at § I(A)(3)(v) of the MOA implies such requirement. There is no requirement that the forest management plan state how the local forest community will be maintained.
Under the existing mechanism, a forest management plan may be approved which does not contain a description of the local forest that is to be maintained (the baseline) during the forestry operation. Because there is no description of the existing forest, there is no way to i) develop a plan to maintain that forest as required by the CMP, or ii) ensure that the forestry operation will in fact maintain the native, locally characteristic forest. Simply put, there is no requirement that a forest management plan contain the very elements that are necessary to ensure that the proposed forestry operation is consistent with the forestry standards of the CMP.
ii) Pinelands Forestry Standards
Enrollment in the Forest Stewardship program obviates the need make a separate development application to the Pinelands Commission. However, Pinelands forestry standards continue to apply to forestry operations after enrollment. N.J.A.C. 7:50-6.45(a); 27 N.J. Reg. 3878(a) [Tab D]. Thus, certain standards, including the requirement to maintain locally characteristic native forest types (§ 7:50-6.45(a)(3)) and ensure compliance with threatened and endangered specie rules (§ 7:50-6.45(a)(5)), apply to forest operations on enrolled properties.
In fact, § 7:50-6.45(a)(3) was reworded during the promulgation process specifically to make it clear that that native, locally characteristic forest types must be maintained during the silvicultural and reforestation components of any forestry operation: the phrase "locally characteristic" was added specifically to make the native forest protection standard more precise. See 28 N.J. Reg. 2596 [Tab E].
The locally characteristic native forest types to be maintained at any particular forestry site in the Pinelands are the very characteristics which define the forest community specific to the site. Any forestry operation must maintain that forest community.
The § 6.45(a)(3) requirement to maintain native, locally characteristic forest types did not arise with publication of the rule in 1996. In fact, as early as 1994 a study group exploring ways to improve the Pinelands forestry program specifically recommended that supplemental forestry standards be included in the CMP (Title 7, Chapter 50, N.J.A.C.) which address matters "of special importance in the Pinelands." Memorandum of John Stokes, et al.; Re: Recommendations for the Pinelands Forestry Program, p. 3, Recommendation # 3 (Sept. 1, 1994) [Tab F]. The list of recommended supplemental standards included that "ilvicultural practices should serve to maintain characteristic and native forest except in those areas where non-native or non-characteristic species are harvested." Id. at "Exhibit 1".
The authors of the Stokes memorandum explained the need for this protective recommendation by reiterating "the Commission's goal of maintaining characteristic and native forests in the Pinelands," and specifically noting the absence of any basis on which an "expanded view of native or characteristic species (e.g. white pine, loblolly pine)" could be supported. Id at 4. Thus, the study group considered and then specifically rejected any forestry practice which would allow conversion of characteristic, native Pinelands forest types.
B. Production Based Management
Forestry was and is part of the Pinelands forest. Certain forestry practices may be entirely compatible with the need to maintain locally characteristic, native Pinelands forest communities. However, production driven forest management techniques may not be compatible with the need to maintain the native forest community; sustainability and compatibility are not the same, and intensive management stewardship of a forest may actively extirpate the native forest community.
One example of a forest management plan that aims to replace the local forest community with a pine plantation is the forest management plan created for Lee Brothers, Inc. Lee Brothers, Inc. enrolled approximately 1,600 acres in the Forest Stewardship Program in November, 2001. The Lee Bros. plan identifies eleven stands, only six of which were scheduled for any forest activity. The treatment scheduled for Stand Three provides an example of a potentially incompatible forestry practice.
A limited description of the existing forest community at Stand Three is provided in the forest plan. The forest in Stand Three is described as being understocked, made up of mostly moderate to poor quality pitch pine aged sixty to one hundred years, with black-jack, scarlet and chestnut oak scattered throughout the stand. It appears that the understory varies from open to dense. The plan does not appear to contain a comprehensive description of the canopy cover, shrub layer, vegetative community, or soil composition. Thus, we do not have an informative description of the existing forest community.
The treatment anticipated for Stand Three includes clear-cutting a 250 acre area, drum chopping and applying herbicide to prepare the area, and the re-planting of the area at the rate of 800 pine trees per acre (TPA). Herbicides will be used to control competing growth while the pine stand becomes established. The goal of this treatment regime is to remove the existing forest community, and then create a fully stocked, highly productive pine stand. The result of the treatment is that the ecological resource will be replaced with an extractable resource.
The Lee Bros. management plan lists eleven specific stewardship objectives. Maintenance of locally characteristic, native Pinelands forests is not listed as a stewardship objective. Production of high value timber is listed. Lee Bros. Plan pp. 2-3.
Maintenance of the native, locally characteristic forest does not appear to be mentioned anywhere in the forest management plan. In fact, rather than making maintenance of the existing forest community an objective, the plan specifically anticipates removing and replacing this "defective" forest community. The objective of planned harvest and regeneration is "to focus on regeneration and spend the remaining years managing a healthy high quality forest as opposed to the defective understocked, unsustainable timber that is presently occupying the site." Lee Bros. App. Docs.; July 16, 1999 Letter of Land Dimensions Engineering p. 2.
The Pinelands Forest Technical Subcommittee approved the Lee Brothers plan.
A second example of a potentially harmful forestry operation is described in the forest management plan created for Haines and Haines, Inc. Haines and Haines is seeking to enroll approximately 9,000 acres in the Forest Stewardship program. The Haines plan identifies seven stands, and anticipates forestry activity on approximately 1,600 acres within the seven stands. The treatment scheduled for Stand One provides an example of a potentially incompatible forestry practice.
Stand One is described as made up primarily of mature, poor quality, moderately stocked pitch pine, with an understory of dense scrub oak, blueberry and laurel. The pine trees range in size from 4"-20" dbh and 20-55 feet in height, with a stem density of approximately 206 TAP.
The treatment anticipated for Stand One includes harvesting 1,000 acres using a combination of seed tree, shelterwood and clear-cut harvests, drum chopping and root raking to maximize exposure of the mineral soil, herbicide treatment, and replanting to achieve a 700 – 800 TPA density. Again, the goal is to remove the existing forest community and replace it with a "fully stocked" pine stand.
The Haines management plan lists seven general stewardship objectives. Maintenance of locally characteristic, native Pinelands forests is not listed as a stewardship objective. Practicing intensive forestry to produce wood and wood products is listed. Haines & Haines plan at 2. Maintenance of the native locally characteristic forest does not appear to be mentioned anywhere in the forest management plan.
The Pinelands Forest Technical Subcommittee has not yet approved the Haines plan.
Forestry operations in the Pinelands can be ecologically compatible with the need to maintain the Pinelands forest if the forest native community is not lost. To establish how forestry in the Pinelands should be carried out so that native, locally characteristic forest types are not lost, we first need to establish what the Pinelands forest is.
4. The Pinelands Forest
"The manner in which a community occurs is, in part, an intrinsic property of the vegetation itself." Breeden, T.F. et al, 2001. Classification of Vegetation Communities of New Jersey: Second Iteration at 1.
The forests of the Pinelands are essentially integrated systems of natural vegetative associations or communities. The locally characteristic native forest type existing in any particular area in the Pinelands can be identified and defined by the vegetation association in such area. As a "basic unit of inventory, the plant association or community element [a floristic unit as opposed to a physiognomic unit of habitat type], is more or less uniform in structure, composition, and habitat." Breeden, T.F. et al, 2001. Classification of Vegetation Communities of New Jersey: Second Iteration [Tab H]. Any particular site may have several different community types, though combinations tend to be predictable. Id. at 2. For terrestrial systems, "plant association" is "a plant community of definite floristic composition, presenting a uniform physiognomy, and growing in uniform habitat conditions" Id. at 6.
A. Identification by Classification
The "plant association is a suitable unit for conservation planning because it encompasses all the layers of vegetation in a stand, reflects ecological and human-caused processes including management activities, and is a repeating unit in different landscapes." Id. at 2.
The structure of a "forest" at any particular site may be inventoried or described top down - from sub-class through alliance (similar to the "cover type" as used by the American Society of Foresters), on down to the local forest association or community. For example, a "pine-oak" forest may contain several forest alliances, each of which contain several distinct forest associations. Since any forestry project necessarily identifies a forest site to be cut, a more precise forest structure inventory may be gained using a bottom up approach. In either case, the locally characteristic Pinelands forest types – the forest that must be maintained throughout any forestry operation - are easily and accurately identified at the plant association level.
For example, the Haines and Haines forest management proposal would cut, remove and replace areas of pitch pine-scrub oak barrens community [Tab I]. This community is restricted to the New Jersey coastal plain, and is imperiled both globally (G2) as well as in the state (S2). The characteristic structure of this community is described in the classification manual:
Concept: This pine barrens community is restricted to the New Jersey Pine Barrens. It is a highly fire-dependent community, occurring most frequently on warmer microclimates of knoll crests and slopes where it is least effected by cold air drainage. The open canopy is strongly dominated by Pinus rigida, with very low cover of deciduous trees. Oaks, when present, may include Quercus stellata or Quercus velutina. The understory is dominated by Quercus marilandica, with lesser cover of Quercus ilicifolia. A low heath shrub layer is dominated by Vaccinium pallidum and Gaylussacia baccata. The herbaceous layer is of variable cover, depending on fire frequency and intensity. Pyxidanthera barbulata is characteristic of the type, although may not be present in all stands. Other herbaceous associates include Schizachyrium scoparium, Andropogon virginicus, Carex pensylvanica, Minuartia caroliniana, Gaultheria procumbens, Pteridium aquilinum, Tephrosia virginiana, Helianthemum canadense, and Lechea spp.
The locally characteristic forest types of any particular area of the Pinelands may be structurally diagnosed by identifying the local community in the snapshot area. Only after the locally characteristic forest community has been identified can a forest management plan assure the maintenance of that locally characteristic native Pinelands forest type.
B. Identification by Associated Species
Particular Pinelands forest associations have been successfully exploited by certain species. For example, in the West Plains fireshed, an area which will be affected by the Haines and Haines proposal, the globally ranked terrestrial communities support rare species such as: Agrotis buchholzi, Atrytone arogos arogos,Spartiniphaga carterae, Pituophis m. melanoleucus, Juncus caesariensis, and Narthecium americanum to name a few [See Tab I].
The structural characteristics of the local forest communities are part of the system which supports rare wildlife. It is the structural components of the forest community which support the resident species suites, and the species suites help to describe the local forest community. In order to address the needs of the resident wildlife, the local vegetative community must be identified. Identification of the local forest community is a precursor to protecting the forest community.
C. The Pine Barrens Make For Poor Cropland
Locally characteristic native Pinelands forests can be identified technically through an inventory of the structure of the local community, empirically, by describing area habitat, or negatively, by describing what it is not.
What the pine barrens is not is nutrient rich, productive cropland. Compared with other forests, the upland forests of the Pinelands are not high quality, uniformly productive timberland. Unfortunately, it is this barren quality of the Pinelands that intensive forestry practices seek to change.
5. Plantation-Style Forestry
Plantation style forestry is the practice of silviculture in order to optimize tree reproduction and product production continuity. The purpose is to create a steady, uniform and predictable product supply. Plantation-style forestry has fundamentally changed the practice of silviculture from a focus on the development and care of forests to a process of commodity management and production.
"Managing timber is an economic venture." Haines and Haines Forest Management Plan p. 28. Pine plantations are managed to capitalize on site potential by maximizing growth of trees of a single species and trees are spaced to maximize fiber production over a 20-30 year rotation (Wear and Greis 2002). Management of pine plantations is intensive, and includes heavy seedling stocking rates (700 – 1000 seedlings per acre) and use of fertilizers and herbicides for reducing competition and maximizing pine growth. (Wear and Greis 2002).
The regeneration method chosen for any forestry operation directly affects the financial potential of a forest stand. "[N]atural regeneration may not be a cost effective seedling establishment method for commercial pine plantations." (Clason, T.R. 2002) [Tab J]. In fact, passive, pine seed tree regeneration methods can have significantly less value than regeneration methods using clearcuts, chemical and mechanical site preparation and chemical weed suppression techniques. Id.
"Reforestation practices [have] a significant impact on the financial potential of commercial pine plantations," Id., and intensive plantation-style forestry practices become desirable to landowners who wish to maximize profit as opposed to merely mange forests.
Aesthetically, a pine plantation differs little in structure or appearance from any other rowcrop (e.g., corn). Ecologically, pine plantations are structurally uniform, often devoid of mid or understory vegetation. Hence the moniker: "green desert."
6. Impacts of Plantation-Style Forestry
Single-species tree plantings, often called monocultures, are an economically viable option for producing wood or fiber rapidly. For this reason, they steadily became more prevalent in suitable regions in the United States over the past 50 years. Acreage of pine plantations has increased from 2 million acres in 1952 to 30 million acres today, with an additional 25 million acres is expected in the foreseeable future (Wear and Greis 2002). Although such monotypic plantings are economically attractive, negative impacts to native ecosystems, wildlife, and overall forest health have been documented as a result of conversion of native forest stands to intensively managed plantations.
A. Pests and Pathogens
Generally, the more diverse and vigorous a forest is, the less likely it is to suffer significant insect or disease damage. As diversity decreases or vigor declines susceptibility to catastrophic pest damage increases (Wear and Greis 2002). Concentrating single-species plantings over large expanses creates ideal opportunities for forest pests that normally exclusively infest the chosen species or a small group of related species that includes it. Populations of the pests that attack pine can expand and prosper in a pine monoculture, turning minor pests into major epidemics.
Two of the most destructive pathogens of pine trees in the United States have been elevated by plantation forestry from a status as a minor pest, with outbreaks significant on a local scale, to two of the most economically and ecologically devastating agents of the Southern Pinelands.
i. Fusiform rust fungus. Fusiform rust is considered the most destructive disease of southern pines, causing cigar-shaped galls on the main stem that are generally fatal (Anderson et al. 1980, Czabator 1971). Fusiform rust may be the outstanding example of a relatively minor pest turned major as a direct result of plantation planting. Extensive mono-culture planting of susceptible slash and loblolly pines since the 1930s in the South has resulted in a continuing epidemic of fusiform rust. Slash and loblolly are the most vulnerable pines to fusiform rust; however pitch pine is also susceptible (Phelps and Czabator 1978).
ii. Insects. Increased acreages in pine plantation have increased the availability and contiguity of host material for certain native insects, particularly the southern pine beetle (Wear and Greis 2002). Catastrophic outbreaks of pine beetles fueled by large acreages of pine plantations impose devastating losses on forest industry.
It is no small coincidence that during the period when plantations increased, the duration between outbreaks of the southern pine beetle has decreased while the intensity and distribution of each outbreak has increased (Belanger et al. 1993; Price et al. 1992). Southern pine beetles are a native insect that plays a significant role in the forest. In “natural†forests native insects are part of the ecological processes that maintain a mosaic of ages and stand conditions (Wear and Greis 2002). Scattered patches of dead and dying trees contribute to the health and biodiversity of the forest by contributing to the natural nutrient cycling regime of the forest and providing down and decaying logs that are important for many forest wildlife species. A forest system containing a genetic diversity of tree species can reduce the impact of insects and pathogens on productivity. (Li. 2000)
Converting a forest to a monotypic stand of a favored host species for southern pine beetle, e.g. loblolly or pitch pine, can establish a nearly ideal situation for the proliferation of the beetle and may actually contribute to near exponential growth.
Factors that help limit the spread of pine beetle are purposely selected against in a managed pine plantation. Foresters recommend the following management practices to help avoid infestations of the beetle: 1) planting more resistant species rather than highly susceptible ones, e.g., loblolly pine and pitch pine; 2) thin overstocked, dense or stagnant stands to a basal area of 80 sq. ft. per ac. (18 sq. m per ha) or less; 3) promote tree diversity in the landscape. Most plantations seek to maximize economic returns through intensive management. Maintaining a low stocking rate, planting more resistant, but slower growing species, and promoting diversity in stands are generally not compatible management options for plantation forestry.
B. Invasive Plant Species
In addition to the impacts caused by insect pests and pathogens, another less commonly recognized phenomenon associated with intensively managed forests and pine plantations is their extensive susceptibility to invasion by nuisance plants (Wear and Greis 2002). Frequent disturbance to manage a stand, intensive site preparation associated with establishment and harvest, and heavy use of herbicides and other management techniques to control and/or eliminate competition from native plants creates a scenario where nuisance plants can invade. These exotic plants might find their best opportunities along roads and other openings created by logging and maintenance operations and within the stand itself after the first few years of establishment, when the use of herbicide to control competition is greatly reduced.
Approximately 42 percent of species that are listed in the United States as threatened or endangered under the Endangered Species Act are at risk because of competition with or predation by nuisance, exotic species (Wear and Greis 2002). Thus far, the Pinelands system has not been heavily impaired from such species. However, promotion of pine plantations in a landscape containing sensitive plant communities could pose a serious threat to vulnerable plants and plant communities.
C. Impacts on Wildlife
There is a general recognition that intensively managed pine plantations are not high-quality wildlife habitats (Wear and Greis 2002). Since 1960, populations of many species of resident and temperate migratory birds associated with open pine stands have undergone significant long-term population declines across much of their ranges (Hunter et al. 1994, 2001). In addition, many other species of animals and plants associated with natural pine stands are also vulnerable (Wear and Greis 2002). The primary reason for the vulnerability of these species is the conversion of native pine forests to other forest types and other land uses.
i. Birds.
Although urban sprawl and agriculture have resulted in the loss and clearing of large amounts of native pine forest, measurable avian declines from 1960 to the present correlate with the 1500 percent increase from 2 million to 30 million of intensively managed pine plantation since 1952. Priority bird species associated with older pine stands are likely harmed most by the expansion of pine plantations. A well-managed pine plantation will provide habitats that are too dense or too young for the bird species usually associated with open pine stands that are frequently subjected to prescribed or natural fire (Wear and Greis 2002).
Pine plantations were formerly lauded for their benefits to early successional species in the first few years after establishment when they resemble an old field or shrubland habitat. However, management of pine plantations has become very intensive. The result of this more intensive management is the elimination of many of the benefits formerly provided in less efficiently managed pine plantations. As is the case with birds of open pine habitats, early successional species likewise show no reversal from long-term population declines as acreage planted to pine plantations has greatly expanded in recent decades (Capel et al. 1994, Hunter et al. 2001, Krementz and Jackson 1999).
A "reduced abundance and diversity of breeding birds when forests are converted from hardwood to pine plantation" has been observed [in southern Appalachia],and other parts of the southeastern U.S. (Hill G.E. 1997) [Tab L]. Similar results could be expected when pine forests are converted to plantations.
Field surveys of breeding birds conducted as part of the Small Area Assessment Forestry Demonstration Project for the Southern Resource Assessment (Evans, et al. 2002) [Tab M] found that pine plantations had the lowest bird diversity and lowest conservation values as measured by Partners in Flight priority scores. "Pine plantations of all age classes had lower abundances of cavity- and tree-nesters, neotropical migrants, and year round residents than did all other habitat classes [studied]." Id. at 4-7.
It is likely that the loss of forest structural complexity, which results from the intensive preparation and specified density, single species restocking associated with pine plantations, causes the loss of cavity nesters and lower bird diversity. Id. at 4-11.
Observations made during other studies corroborate the negative habitat impact associated with pine plantations. A survey of breeding birds made in forests of the Gulf Coastal Plain found that "natural forest types ... had more individuals and higher bird species richness than" other managed stands, and that planted slash pine stands "generally appeared to provide poor habitat for most species of birds". (Hill G.E. 1998) [Tab N]. "There are more birds in structurally diverse pine-hardwood stands than in pine stands." (Dickson J.G. 1995 (citation omitted)) [Tab O]. Generally, as lower vegetation is shaded out (or managed out) bird species abundance, density and diversity decrease. Id.
Additionally, considering the negative impact to Barred Owls which resulted from edge created during the Belleplain timber salvage operation, we can expect there to be an adverse impact to any resident Barred Owls from the edge and fragmentation created during large scale plantation operations.
ii. Nonavian.
Results for nonavian wildlife are similar to those for birds. Plantations have been found to offer habitat for some species of small mammals, reptiles, and bats, but only when stands are maintained in a condition that emulates, to some degree, a native pine stand (Mitchel et al. 1995; Aresco and Guyer 1999; Menzel et al. 2001).
In eastern Texas and western Louisiana, extensive inventories of intensively managed pine plantations and publicly-owned natural pine stands have been conducted in search of the rare Louisiana pine snake (Pituophis melanoleucus ruthveni). Results from these surveys indicated that pine snakes did not occur to any significant extent in a landscape dominated by pine plantations (Rudolph pers. com.). The only significant populations of Louisiana pine snakes remaining occur in well-burned, natural pine stands, primarily found on national forest or Department of Defense land (Rudolph pers. com.). One hypothesis offered to explain this current distribution is that alteration of natural vegetation throughout the pine snakes range, most of which has been converted to loblolly or slash pine, has negatively affected the snake’s small mammal prey base, eliminating the pine snake from many sites it formerly occupied (Rudolph and Burgdorf 1997).
In New Jersey, conversion of natural pine stands to plantations can be expected to have a similar effect upon rare snake species. Impacts to the small mammal population resulting from conversion of a natural pine forest to pine plantation can be expected to have an adverse impact on the native small mammal population upon which snakes depend for food, effectively reducing foraging habitat.
Further, Pine snakes require dry pine-oak forest types for certain life-cycle activities. Beans, B.E. and L. Niles, eds. (2003) Endangered and Threatened Wildlife of New Jersey, p. 199. In particular, open, unvegetated, sandy areas with less than 5 percent tree cover in pitch-scrub oak uplands are important nest sites for pine snakes in New Jersey (Burger and Zappalorti 1986; accord, Beans, B.E. at 199). Nesting and basking areas would not exist within a large pine plantation, and so the conversion of local pine-oak forest would only increase the rate of habitat loss now affecting the Pine snake population.
iii. Game Species
Game species such as Bobwhite quail suffer when diverse woodlands are converted to pine plantations. "Biologists have noted that crop fields established in pine are characterized by low diversity of understory plants compared to traditional clearcut and naturally regenerated or planted sites. Bobwhites and other early successional habitat dependant species simply can not thrive in these areas." (Carmichael et al. 2002) [Tab P]. See Tab P for a discussion of the impact plantation forestry has had on Bobwhite quail, and suggesting quail-friendly practices.
The findings of the Southeast Quail Study Group Technical Committee suggest that stewardship objectives which include providing habitat suitability for Bobwhite quail (Lee Bros. Plan, p.2, # 6) may not be compatible with the forest management plan.
D. Soils
Soils are a fundamental component of any forest association. The web of soil fauna and soil microorganisms has several functions: soil structure formation, organic matter decomposition, nutrient retention within the soil environment and release of nutrients to plant species inhabiting the forest. In the sandy soils of the New Jersey pine barrens, nutrients added to fertilize the soil, such as nitrogen and phosphorus, will be mobilized and pass from the soil environment into the underlying groundwater.
Disruption of the soil microbial community and removal of the shrub layer can result in decreased nutrient retention within the soil and increased loss of nutrients due to leaching. Because the soil environment of the New Jersey pine barrens is nutrient poor much of the nutrients in a pine barrens forest are tied up in the living and decomposing biomass. The soil disruption involved in agroforestry, including physical destruction of soil organisms, the use of biocides, and the suppression of understory shrub species will result in the near complete removal of nutrients necessary for forest regeneration after the harvestable timber is removed. Another consequence of elimination of the native microbial, faunal and floral community members is the increased likelihood of introduction of non-native invasive species.
Ectomycorrhizas are a major component of the soil microbial community. Ectomycorrhizas are a symbiotic association between fungi and plants such as pitch pine. Surface inventories of mushrooms reveal little about below ground community structure of ectomycorrizal fungi. (Jonsson.1998). The species richness of ectomycorrhizal fungi in coniferous boreal forest is 10-100 times higher than the diversity of the host plants. (Danielson. 1984; Allen et al. 1995); and research in the New Jersy pine barrens has found 80 different morphological types of ectomycorrhizal fungi. (Tuininga, AR. 2000).
The overall loss of species richness after clear-cutting and significant changes in species composition found by Byrd et al. (2000) indicates that clear-cutting can negatively alter the ectomycorrhizal fungal community. This alteration may have profound effects on ecosystem function. Size of forest clearcut can be important to below ground structure. After two and three growing seasons the numbers of active fine roots as well as the diversity of ectomycorrhizae in clearcuts was significantly reduced with distance from uncut forest edge (Hagerman et al. 1999). Live trees within areas of forest disturbance, such as clearcuts, could support refuge populations of ectomycorrhizal fungi. From these refuge sites the ectomycorrhizal community can reestablish during forest succession (Cranabetter. 1999). Removal of roots after tree harvest would remove the refuge for the surviving mycorrhizal fungi.
Microarthropod density rages from 9,000/m2 in the pine plains to 69,000/m2 in upland old-burn sites of the pine barrens (Dindal 1979). A vast majority of the soil animals graze on fungal tissue. Consequently, clear-cutting would result in a reduction of food resources for the microarthropods and a reduction in the amount and diversity of these soil animals.
Soil destroying activities can occur during forestry practices in several ways: causing a change in existing associations, application of microbial toxic materials, and desertification through stripping of organic material.
First, the soil ecosystem process can be severely disrupted by human caused disturbances. (Li. 2000) [Tab Q]. For example, "[c]hanges in tree species are likely to significantly alter these processes through creation of new functional processes of other organisms." Id. Thus changing the tree species of a local Pinelands forest association will likely change the very heart of that local forest ecosystem.
Second, heavy, soil-targeted, applications of Glyphosate (a/k/a Roudup, Rodeo, Accord, Vision), a broad spectrum herbicide commonly for site preparation at Pine plantation sites, can be hazardous to many soil components. In addition to possibly reducing nitrogen fixing in soils, glyphosate can be hazardous to parasitic insects and michorizal fungi. (Cox. 1995) [Tab R]. Thus, chemical site preparation for pine plantations can (and is in fact designed to) prevent regeneration of any native growth by effectively sterilizing the local soil.
Third, plantation forestry practices can quickly strip certain soils of available organic matter. Referring to the sandy, nutrient poor and acidic soils of the Cumberland Plateau, soils which like Pine Barrens have little buffering capacity and which provide nutrients only through precipitation and leaf litter, Dr. Jonathan Evans commented that "[a]fter only two cycles of pine planting and logging – about 40 – 60 years from now – the areas naturally sandy, low-fertility soil will be drained of life." Kathy Gilbert, Pine Plantations Overshadow Forests, Chattanooga Times Free Press, Feb. 8, 2002 [Tab S]. Like the Cumberland Plateau, the soils of the Pinelands can easily be drained of life if unsustainable forest practices are carried out.
Finally, an agroforestry operation leaves a long legacy. The loss of the soil communities which support native pinelands forests from mechanical and chemical sterilization, and from inoculation and colonization with non-native mycorrhiza that must accompany any successful exploitation of the sterilized mineral soils, could require thousands of years to undue. Plantation forestry in the Pinelands may cause an effectively permanent loss of the forest.
7. Summary
Intensive forest practices which result in the conversion of native, locally characteristic forest communities to ecologically sterile pine monoculture, combined with an oversight program that does not require application of ecological values in the development of forest management plans, has the potential to cause significant, long term harm to the forest communities of the Pinelands.
Proper detailed guidelines are needed for forestry practices in the Pinelands to prevent the loss of Pinelands forest communities.
8. Requested Action by ENSCA
Conversion to nonnative, hybrid, or uncharacteristic forest type will result in a loss of species, loss or habitat, loss of richness and the potential for extensive loss from disease. Loss of the locally characteristic forests may have a severe, lasting adverse biological effect.
To be certain that all wildlife conservation issues are adequately addressed before any harm occurs, and to ensure the protection of rare species and habitats, ENSAC should:
A. State that forestry practices in the Pinelands must not cause the loss of rare or critical habitat or communities.
B. Recommend that any forest projects involving more than 50 acres of clearing, or any cuts with a restocking component, be held until detailed and appropriate guidelines are developed to protect the rare species and characteristic forest community resources of the Pinelands National Reserve.
C. Encourage the State Forest Service to request assistance from public and private professionals within and without the forest industry to develop detailed guidelines for ecologically sound forestry practices in the Pinelands, including oversight and monitoring measures.
Carmichael, Breck and R.E. Thackston, Southern Pine Forests, in The Northern Bobwhite Conservation Initiative. (Dimmick, R.W. et al. eds. 2002)
Clason, T.R. Cost Effectiveness of Natural Regeneration for Sustaining Production Continuity in Commercial Pine Plantations, In Outcalt, Kenneth W., ed. 2002. Proceedings of the Eleventh Biennial Southern Silvicultural Research Conference. Gen. Tech. Rep. SRS-48. USDAFS, Southern Research Station. 622 p.
Cox, C. 1995. Glyphosate Part 2: Human Exposure and Ecological Effects. Journal of Pesticide Reform, Vol. 15 No. 4 Winter 1995.
Dickson, James G. et al. 1995. Winter Birds in Developing Pine Plantations, Proc. Annu. Conf. Southeast Ass'n. Fish and Wildlife Agencies, 49:303-313(citation omitted)
Evans, J. et al., 2002. Small Area Assessment Forestry Demonstration Project for the Southern Resource Assessment: An Assessment of Forest Change on the Cumberland Plateau in Southern Tennessee
Hill, Geoffrey E., 1997. The Effects On Bird Communities of Converting Southern Hardwood Forests to Pine Plantations, J. Alabama Academy Sci., Vol. 68, No. 4
Hill, Geoffrey E., 1998. Use of Forested Habitat by Breeding Birds in the Gulf Costal Plain, So. J. of Applied Forestry, Vol. 22, No. 3
Li. C.Y. and E. Strzelczyk. Belowground Microbial Processes Underpin Forest Productivity. Phyton, Vo. 40 Fasc. 4 pp. 129-34.
Miller, James H. 1991. Forest Herbicide Benefits and Developments for Intensive Southern Pine Culture, In, Bryce, J.; Rawlins, Cynthia L., eds. Forestry and the Environment (1991)(conference proceedings).
Renee
Intensive Forestry Operations in the Pinelands:
A Request for Action by the Endangered and Nongame Species Advisory Committee
November 19, 2003
Prepared By: Pinelands Preservation Alliance
New Jersey Audubon Society
Contents
Exhibit Index ..................... 2
1. Introduction ..................... 3
2. Interest of ENSAC ..................... 3
3. Forestry in the PNR and the Forest Stewardship Program ..................... 4
A. The Pinelands and the Forest Stewardship Program ..................... 4
i) Enrollment in the Forest Stewardship Program ..................... 4
ii) Pinelands Forestry Standards ..................... 5
B. Production Based Management ..................... 6
4. The Pinelands Forest ..................... 8
A. Identification by Classification ..................... 8
B. Identification by Associated Species ..................... 9
C. The Pine Barrens Make For Poor Cropland ..................... 9
5. Plantation-Style Forestry ..................... 10
6. Impacts of Plantation-Style Forestry ..................... 10
A. Pests and Pathogens ..................... 10
i. Fusiform rust fungus ..................... 10
ii. Insects ..................... 11
B. Invasive Plant Species ..................... 12
C. Impacts on Wildlife ..................... 12
i. Birds ..................... 12
ii. Nonavian ..................... 13
iii. Game Species ..................... 14
D. Soils ..................... 14
7. Summary ..................... 16
8. Requested Action by ENSCA ..................... 17
Exhibit Index
Exhibit Book I:
- Pinelands Forestry Regulations and Background Information Tabs A – G
- Documents and Papers Which Support Agroforestry Concern Tabs H – U
Pinelands Forestry Standards; N.J.A.C. §§ 7:50-6.41 – 6.47 (CMP) ... Tab A
Memorandum of Agreement between the Pinelands Commission and DEP (1997) ... Tab B
Memorandum: "Forestry and Threatened or Endangered Animal Species" (9/24/96) Tab C
New Jersey Register, Vol. 27 No. 20 (10/16/95) (Print) ... Tab D
New Jersey Register, Vol. 28 No. 10 (5/20/96) (Print) ... Tab E
Memorandum: "Recommendations for the Pinelands Forestry Program" (11/1/94) ... Tab F
Excerpt: Comprehensive Management Plan for the Pinelands National Reserve
November 21, 1980; pp. 234 –235 "Forestry Program" ... Tab G
Excerpt: Classification of Vegetation Communities of New Jersey: 2nd Iteration ... Tab H
Letter of A. Windisch; Re: Haines and Haines forestry proposal (6/5/03) ... Tab I
Paper: "Cost Effectiveness of Natural Regeneration for Sustaining Production
Continuity in Commercial Pine Plantations" ... Tab J
Notes: N.J. Audubon Society: "Impacts of Agroforestry on Natural Pine Ecosystems" Tab K
Paper: "The Effects on Bird Communities of Converting Southern
Hardwood Forests to Pine Plantations" ... Tab L
Report: "An Assessment of Forest Change on the Cumberland Plateau in
Southern Tennessee" Tab M
Paper: "Use of Forested Habitat By Breeding Birds in the Gulf Coastal Plain" ... Tab N
Paper: "Winter Birds in a Developing Pine Plantation" ... Tab O
Report: The Northern Bobwhite Conservation Initiative; "A Report on the
Status of the Northern Bobwhite and a Plan for Recovery of the Species" ... Tab P
Paper: "Belowground Microbial Processes Underpin Forest Productivity" ... Tab Q
Notes: Jonsson, Lena: Soil Notes ... Tab R
Paper: "Glyphosate, Part 2: Human Exposure and Ecological Effects" ... Tab S
Article: Chattanooga Times Free Press (2/8/02) ... Tab T
Paper: "Forest Herbicide Benefits and Developments for Intensive Southern
Pine Culture" ... Tab U
Exhibit Book II:
- Lee Brothers Forest Management Plan and Associated Correspondence and Plan Amendments
- Haines and Haines Forest Management Plan and Associated Correspondence
1. Introduction
Recently, forest management plans have been created for private lands within the Pinelands which anticipate the use of intensive forest management practices. These activities are intended to optimize conditions for wood fiber generation at sites within the Pinelands through the removal of all native terrestrial vegetation, disruption of existing soil conditions, re-planting of the site with a uniform species, and ongoing maintenance to limit competition.
Forestry has been a part of the Pinelands ecosystem since at least colonial settlement. Forestry activities have not only helped define the Pinelands we see today, but certain forestry practices and techniques may even be used to enhance fire deprived forest communities.
However, large scale, intensive, plantation-style forestry has not been a part of the Pinelands forest community. These intensive forestry practices, specifically designed to replace the existing forest associations with a monoculture plantation, are not compatible with the need to maintain native, locally characteristic Pinelands forest communities. Further, by removing and replacing entire forest communities, these practices will likely jeopardize the health and welfare of the rare, threatened and endangered species using the native forest communities.
The native forests of the Pinelands are a recognized land resource of the Pinelands National Reserve (PNR). Regulations designed to protect the forest resource specifically require that "all silviculture and reforestation practices shall serve to maintain native Pinelands forest types, including those that are locally characteristic ... ." Though this rule is clear on its face, at this time there are no detailed guidelines available to guide Pinelands compatible forestry practices.
The absence of detailed guidelines has encouraged landowners to propose forest management plans that anticipate using plantation-style silviculture and reforestation practices. These practices will cause great harm to the Pinelands forests. Plantation-style forestry transforms the native forest community into single-age, monotypic stands which are devoid of structural diversity, habitat poor, and are at high risk of loss from pests and pathogens.
Adequate guidelines must be created for, and applied to, forestry operation within the Pinelands before the native forest community is lost.
2. Interest of ENSAC
Established by the New Jersey Statutes at §23:2A-7(e), the Endangered and Nongame Species Advisory Committee ("the Committee") is that group of experts appointed by the Commissioner of DEP to advise and assist the Commissioner in matters pertaining to the conservation of wildlife, and in carrying out the mandate of The Endangered and Nongame Species Conservation Act.
Native Pinelands forest communities support many rare species and important wildlife populations. The advent of plantation-style forestry practices in Pinelands raises significant questions regarding wildlife conservation in general, and compliance with the state Endangered and Nongame Species Conservation Act. Consideration of the impact of intensive forestry practices is squarely within the Committee's mandate.
3. Forestry in the PNR and the Forest Stewardship Program
The forests of the Pinelands are one of the land resources of local and national interest designated for special protection under the National Parks and Recreation Act of 1978 (16 U.S.C. § 471i) and the Pinelands Protection Act (N.J.S.A. 13:18A-1 et seq.). Though protection of the Pinelands forest resource is required, management of the forest resource for wood production is needed. The forestry program set out in the Pinelands Comprehensive Management Plan is intended to preserve and protect the forest resource, while providing for traditional lifestyles which are compatible with the ecological values of the Pinelands. See Comprehensive Management Plan for the Pinelands National Reserve, November 21, 1980, page 234 [Tab G]. Thus forestry and forest protection are considered potentially compatible.
In order to balance the need to protect native Pinelands forests, and the rare species that live in them, while allowing forestry operations to be conducted, Pinelands rules require that "[a]ll silvicultural and reforestation practices [in the Pinelands] shall serve to maintain native Pinelands forest types, including those that are locally characteristic, except on those parcels where other forest types exist." N.J.A.C. 7:50-6.45(a)(3). Additionally, "[a]ll forestry activities and practices shall be designed and carried out so as to comply with the [threatened and endangered plant and wildlife] standards set forth in N.J.A.C. 7:50-6.27 and 6.33." N.J.A.C. 7:50-6.45(a)(5) [Tab A].
A. The Pinelands and the Forest Stewardship Program
For purposes of Pinelands regulations, forestry is considered "development." All development in the Pinelands ordinarily requires that a development application be submitted to and approved by the Pinelands Commission prior to commencing any project. Forestry projects in the Pinelands then could be subject to review by the Pinelands Commission under a development application, and also by the state Forest Service for compliance with standard silviculture practices.
In order to avoid duplicative review, a mechanism was established whereby forestry operations could be conducted on properties enrolled in the New Jersey Forest Stewardship Program without the need to submit a Pinelands development application. See N.J.A.C. 7:50-6.43(a) and 28 N.J. Reg. 2596(a)(May 20, 1996) [Tab E]. Acceptance of a parcel into the Stewardship Program (enrollment) acts as Pinelands "approval" of the forestry project.
i) Enrollment in the Forest Stewardship Program
The mechanism for enrollment in the Forest Stewardship Program for parcels located in the Pinelands is set out in a Memorandum of Agreement between the Pinelands Commission and the DEP (MOA of 5/22/97)[Tab B]. To accept enrollment, the DEP, through its State Forestry Stewardship Coordinating Committee, established a Pinelands Stewardship Technical Subcommittee. The Pinelands Stewardship Technical Subcommittee is made up of three people: a Regional Forester, a Pinelands Commission staff member, and a DEP Parks and Forestry staff member.
For parcels in the Pinelands, a Forest Stewardship Plan (a/k/a forest management plan) is submitted to the Regional forester, who then delivers the management plan to the Technical Subcommittee. The Technical Subcommittee determines i) whether the management plan is complete, ii) whether the plan is consistent with the forestry standards of the CMP, and iii) whether the property is eligible for enrollment in the Stewardship Program. Favorable determination as to each element results in enrollment into the Stewardship Program.
A forest management plan must contain certain general information and information regarding cultural resources and threatened or endangered species. See MOA of 5/22/97 pp. 2-4 [Tab B]. There is no explicit requirement for a forest management plan to include a description of the local forest community (the local vegetative association), though a strict reading of the content requirements at § I(A)(3)(v) of the MOA implies such requirement. There is no requirement that the forest management plan state how the local forest community will be maintained.
Under the existing mechanism, a forest management plan may be approved which does not contain a description of the local forest that is to be maintained (the baseline) during the forestry operation. Because there is no description of the existing forest, there is no way to i) develop a plan to maintain that forest as required by the CMP, or ii) ensure that the forestry operation will in fact maintain the native, locally characteristic forest. Simply put, there is no requirement that a forest management plan contain the very elements that are necessary to ensure that the proposed forestry operation is consistent with the forestry standards of the CMP.
ii) Pinelands Forestry Standards
Enrollment in the Forest Stewardship program obviates the need make a separate development application to the Pinelands Commission. However, Pinelands forestry standards continue to apply to forestry operations after enrollment. N.J.A.C. 7:50-6.45(a); 27 N.J. Reg. 3878(a) [Tab D]. Thus, certain standards, including the requirement to maintain locally characteristic native forest types (§ 7:50-6.45(a)(3)) and ensure compliance with threatened and endangered specie rules (§ 7:50-6.45(a)(5)), apply to forest operations on enrolled properties.
In fact, § 7:50-6.45(a)(3) was reworded during the promulgation process specifically to make it clear that that native, locally characteristic forest types must be maintained during the silvicultural and reforestation components of any forestry operation: the phrase "locally characteristic" was added specifically to make the native forest protection standard more precise. See 28 N.J. Reg. 2596 [Tab E].
The locally characteristic native forest types to be maintained at any particular forestry site in the Pinelands are the very characteristics which define the forest community specific to the site. Any forestry operation must maintain that forest community.
The § 6.45(a)(3) requirement to maintain native, locally characteristic forest types did not arise with publication of the rule in 1996. In fact, as early as 1994 a study group exploring ways to improve the Pinelands forestry program specifically recommended that supplemental forestry standards be included in the CMP (Title 7, Chapter 50, N.J.A.C.) which address matters "of special importance in the Pinelands." Memorandum of John Stokes, et al.; Re: Recommendations for the Pinelands Forestry Program, p. 3, Recommendation # 3 (Sept. 1, 1994) [Tab F]. The list of recommended supplemental standards included that "
The authors of the Stokes memorandum explained the need for this protective recommendation by reiterating "the Commission's goal of maintaining characteristic and native forests in the Pinelands," and specifically noting the absence of any basis on which an "expanded view of native or characteristic species (e.g. white pine, loblolly pine)" could be supported. Id at 4. Thus, the study group considered and then specifically rejected any forestry practice which would allow conversion of characteristic, native Pinelands forest types.
B. Production Based Management
Forestry was and is part of the Pinelands forest. Certain forestry practices may be entirely compatible with the need to maintain locally characteristic, native Pinelands forest communities. However, production driven forest management techniques may not be compatible with the need to maintain the native forest community; sustainability and compatibility are not the same, and intensive management stewardship of a forest may actively extirpate the native forest community.
One example of a forest management plan that aims to replace the local forest community with a pine plantation is the forest management plan created for Lee Brothers, Inc. Lee Brothers, Inc. enrolled approximately 1,600 acres in the Forest Stewardship Program in November, 2001. The Lee Bros. plan identifies eleven stands, only six of which were scheduled for any forest activity. The treatment scheduled for Stand Three provides an example of a potentially incompatible forestry practice.
A limited description of the existing forest community at Stand Three is provided in the forest plan. The forest in Stand Three is described as being understocked, made up of mostly moderate to poor quality pitch pine aged sixty to one hundred years, with black-jack, scarlet and chestnut oak scattered throughout the stand. It appears that the understory varies from open to dense. The plan does not appear to contain a comprehensive description of the canopy cover, shrub layer, vegetative community, or soil composition. Thus, we do not have an informative description of the existing forest community.
The treatment anticipated for Stand Three includes clear-cutting a 250 acre area, drum chopping and applying herbicide to prepare the area, and the re-planting of the area at the rate of 800 pine trees per acre (TPA). Herbicides will be used to control competing growth while the pine stand becomes established. The goal of this treatment regime is to remove the existing forest community, and then create a fully stocked, highly productive pine stand. The result of the treatment is that the ecological resource will be replaced with an extractable resource.
The Lee Bros. management plan lists eleven specific stewardship objectives. Maintenance of locally characteristic, native Pinelands forests is not listed as a stewardship objective. Production of high value timber is listed. Lee Bros. Plan pp. 2-3.
Maintenance of the native, locally characteristic forest does not appear to be mentioned anywhere in the forest management plan. In fact, rather than making maintenance of the existing forest community an objective, the plan specifically anticipates removing and replacing this "defective" forest community. The objective of planned harvest and regeneration is "to focus on regeneration and spend the remaining years managing a healthy high quality forest as opposed to the defective understocked, unsustainable timber that is presently occupying the site." Lee Bros. App. Docs.; July 16, 1999 Letter of Land Dimensions Engineering p. 2.
The Pinelands Forest Technical Subcommittee approved the Lee Brothers plan.
A second example of a potentially harmful forestry operation is described in the forest management plan created for Haines and Haines, Inc. Haines and Haines is seeking to enroll approximately 9,000 acres in the Forest Stewardship program. The Haines plan identifies seven stands, and anticipates forestry activity on approximately 1,600 acres within the seven stands. The treatment scheduled for Stand One provides an example of a potentially incompatible forestry practice.
Stand One is described as made up primarily of mature, poor quality, moderately stocked pitch pine, with an understory of dense scrub oak, blueberry and laurel. The pine trees range in size from 4"-20" dbh and 20-55 feet in height, with a stem density of approximately 206 TAP.
The treatment anticipated for Stand One includes harvesting 1,000 acres using a combination of seed tree, shelterwood and clear-cut harvests, drum chopping and root raking to maximize exposure of the mineral soil, herbicide treatment, and replanting to achieve a 700 – 800 TPA density. Again, the goal is to remove the existing forest community and replace it with a "fully stocked" pine stand.
The Haines management plan lists seven general stewardship objectives. Maintenance of locally characteristic, native Pinelands forests is not listed as a stewardship objective. Practicing intensive forestry to produce wood and wood products is listed. Haines & Haines plan at 2. Maintenance of the native locally characteristic forest does not appear to be mentioned anywhere in the forest management plan.
The Pinelands Forest Technical Subcommittee has not yet approved the Haines plan.
Forestry operations in the Pinelands can be ecologically compatible with the need to maintain the Pinelands forest if the forest native community is not lost. To establish how forestry in the Pinelands should be carried out so that native, locally characteristic forest types are not lost, we first need to establish what the Pinelands forest is.
4. The Pinelands Forest
"The manner in which a community occurs is, in part, an intrinsic property of the vegetation itself." Breeden, T.F. et al, 2001. Classification of Vegetation Communities of New Jersey: Second Iteration at 1.
The forests of the Pinelands are essentially integrated systems of natural vegetative associations or communities. The locally characteristic native forest type existing in any particular area in the Pinelands can be identified and defined by the vegetation association in such area. As a "basic unit of inventory, the plant association or community element [a floristic unit as opposed to a physiognomic unit of habitat type], is more or less uniform in structure, composition, and habitat." Breeden, T.F. et al, 2001. Classification of Vegetation Communities of New Jersey: Second Iteration [Tab H]. Any particular site may have several different community types, though combinations tend to be predictable. Id. at 2. For terrestrial systems, "plant association" is "a plant community of definite floristic composition, presenting a uniform physiognomy, and growing in uniform habitat conditions" Id. at 6.
A. Identification by Classification
The "plant association is a suitable unit for conservation planning because it encompasses all the layers of vegetation in a stand, reflects ecological and human-caused processes including management activities, and is a repeating unit in different landscapes." Id. at 2.
The structure of a "forest" at any particular site may be inventoried or described top down - from sub-class through alliance (similar to the "cover type" as used by the American Society of Foresters), on down to the local forest association or community. For example, a "pine-oak" forest may contain several forest alliances, each of which contain several distinct forest associations. Since any forestry project necessarily identifies a forest site to be cut, a more precise forest structure inventory may be gained using a bottom up approach. In either case, the locally characteristic Pinelands forest types – the forest that must be maintained throughout any forestry operation - are easily and accurately identified at the plant association level.
For example, the Haines and Haines forest management proposal would cut, remove and replace areas of pitch pine-scrub oak barrens community [Tab I]. This community is restricted to the New Jersey coastal plain, and is imperiled both globally (G2) as well as in the state (S2). The characteristic structure of this community is described in the classification manual:
Concept: This pine barrens community is restricted to the New Jersey Pine Barrens. It is a highly fire-dependent community, occurring most frequently on warmer microclimates of knoll crests and slopes where it is least effected by cold air drainage. The open canopy is strongly dominated by Pinus rigida, with very low cover of deciduous trees. Oaks, when present, may include Quercus stellata or Quercus velutina. The understory is dominated by Quercus marilandica, with lesser cover of Quercus ilicifolia. A low heath shrub layer is dominated by Vaccinium pallidum and Gaylussacia baccata. The herbaceous layer is of variable cover, depending on fire frequency and intensity. Pyxidanthera barbulata is characteristic of the type, although may not be present in all stands. Other herbaceous associates include Schizachyrium scoparium, Andropogon virginicus, Carex pensylvanica, Minuartia caroliniana, Gaultheria procumbens, Pteridium aquilinum, Tephrosia virginiana, Helianthemum canadense, and Lechea spp.
The locally characteristic forest types of any particular area of the Pinelands may be structurally diagnosed by identifying the local community in the snapshot area. Only after the locally characteristic forest community has been identified can a forest management plan assure the maintenance of that locally characteristic native Pinelands forest type.
B. Identification by Associated Species
Particular Pinelands forest associations have been successfully exploited by certain species. For example, in the West Plains fireshed, an area which will be affected by the Haines and Haines proposal, the globally ranked terrestrial communities support rare species such as: Agrotis buchholzi, Atrytone arogos arogos,Spartiniphaga carterae, Pituophis m. melanoleucus, Juncus caesariensis, and Narthecium americanum to name a few [See Tab I].
The structural characteristics of the local forest communities are part of the system which supports rare wildlife. It is the structural components of the forest community which support the resident species suites, and the species suites help to describe the local forest community. In order to address the needs of the resident wildlife, the local vegetative community must be identified. Identification of the local forest community is a precursor to protecting the forest community.
C. The Pine Barrens Make For Poor Cropland
Locally characteristic native Pinelands forests can be identified technically through an inventory of the structure of the local community, empirically, by describing area habitat, or negatively, by describing what it is not.
What the pine barrens is not is nutrient rich, productive cropland. Compared with other forests, the upland forests of the Pinelands are not high quality, uniformly productive timberland. Unfortunately, it is this barren quality of the Pinelands that intensive forestry practices seek to change.
5. Plantation-Style Forestry
Plantation style forestry is the practice of silviculture in order to optimize tree reproduction and product production continuity. The purpose is to create a steady, uniform and predictable product supply. Plantation-style forestry has fundamentally changed the practice of silviculture from a focus on the development and care of forests to a process of commodity management and production.
"Managing timber is an economic venture." Haines and Haines Forest Management Plan p. 28. Pine plantations are managed to capitalize on site potential by maximizing growth of trees of a single species and trees are spaced to maximize fiber production over a 20-30 year rotation (Wear and Greis 2002). Management of pine plantations is intensive, and includes heavy seedling stocking rates (700 – 1000 seedlings per acre) and use of fertilizers and herbicides for reducing competition and maximizing pine growth. (Wear and Greis 2002).
The regeneration method chosen for any forestry operation directly affects the financial potential of a forest stand. "[N]atural regeneration may not be a cost effective seedling establishment method for commercial pine plantations." (Clason, T.R. 2002) [Tab J]. In fact, passive, pine seed tree regeneration methods can have significantly less value than regeneration methods using clearcuts, chemical and mechanical site preparation and chemical weed suppression techniques. Id.
"Reforestation practices [have] a significant impact on the financial potential of commercial pine plantations," Id., and intensive plantation-style forestry practices become desirable to landowners who wish to maximize profit as opposed to merely mange forests.
Aesthetically, a pine plantation differs little in structure or appearance from any other rowcrop (e.g., corn). Ecologically, pine plantations are structurally uniform, often devoid of mid or understory vegetation. Hence the moniker: "green desert."
6. Impacts of Plantation-Style Forestry
Single-species tree plantings, often called monocultures, are an economically viable option for producing wood or fiber rapidly. For this reason, they steadily became more prevalent in suitable regions in the United States over the past 50 years. Acreage of pine plantations has increased from 2 million acres in 1952 to 30 million acres today, with an additional 25 million acres is expected in the foreseeable future (Wear and Greis 2002). Although such monotypic plantings are economically attractive, negative impacts to native ecosystems, wildlife, and overall forest health have been documented as a result of conversion of native forest stands to intensively managed plantations.
A. Pests and Pathogens
Generally, the more diverse and vigorous a forest is, the less likely it is to suffer significant insect or disease damage. As diversity decreases or vigor declines susceptibility to catastrophic pest damage increases (Wear and Greis 2002). Concentrating single-species plantings over large expanses creates ideal opportunities for forest pests that normally exclusively infest the chosen species or a small group of related species that includes it. Populations of the pests that attack pine can expand and prosper in a pine monoculture, turning minor pests into major epidemics.
Two of the most destructive pathogens of pine trees in the United States have been elevated by plantation forestry from a status as a minor pest, with outbreaks significant on a local scale, to two of the most economically and ecologically devastating agents of the Southern Pinelands.
i. Fusiform rust fungus. Fusiform rust is considered the most destructive disease of southern pines, causing cigar-shaped galls on the main stem that are generally fatal (Anderson et al. 1980, Czabator 1971). Fusiform rust may be the outstanding example of a relatively minor pest turned major as a direct result of plantation planting. Extensive mono-culture planting of susceptible slash and loblolly pines since the 1930s in the South has resulted in a continuing epidemic of fusiform rust. Slash and loblolly are the most vulnerable pines to fusiform rust; however pitch pine is also susceptible (Phelps and Czabator 1978).
ii. Insects. Increased acreages in pine plantation have increased the availability and contiguity of host material for certain native insects, particularly the southern pine beetle (Wear and Greis 2002). Catastrophic outbreaks of pine beetles fueled by large acreages of pine plantations impose devastating losses on forest industry.
It is no small coincidence that during the period when plantations increased, the duration between outbreaks of the southern pine beetle has decreased while the intensity and distribution of each outbreak has increased (Belanger et al. 1993; Price et al. 1992). Southern pine beetles are a native insect that plays a significant role in the forest. In “natural†forests native insects are part of the ecological processes that maintain a mosaic of ages and stand conditions (Wear and Greis 2002). Scattered patches of dead and dying trees contribute to the health and biodiversity of the forest by contributing to the natural nutrient cycling regime of the forest and providing down and decaying logs that are important for many forest wildlife species. A forest system containing a genetic diversity of tree species can reduce the impact of insects and pathogens on productivity. (Li. 2000)
Converting a forest to a monotypic stand of a favored host species for southern pine beetle, e.g. loblolly or pitch pine, can establish a nearly ideal situation for the proliferation of the beetle and may actually contribute to near exponential growth.
Factors that help limit the spread of pine beetle are purposely selected against in a managed pine plantation. Foresters recommend the following management practices to help avoid infestations of the beetle: 1) planting more resistant species rather than highly susceptible ones, e.g., loblolly pine and pitch pine; 2) thin overstocked, dense or stagnant stands to a basal area of 80 sq. ft. per ac. (18 sq. m per ha) or less; 3) promote tree diversity in the landscape. Most plantations seek to maximize economic returns through intensive management. Maintaining a low stocking rate, planting more resistant, but slower growing species, and promoting diversity in stands are generally not compatible management options for plantation forestry.
B. Invasive Plant Species
In addition to the impacts caused by insect pests and pathogens, another less commonly recognized phenomenon associated with intensively managed forests and pine plantations is their extensive susceptibility to invasion by nuisance plants (Wear and Greis 2002). Frequent disturbance to manage a stand, intensive site preparation associated with establishment and harvest, and heavy use of herbicides and other management techniques to control and/or eliminate competition from native plants creates a scenario where nuisance plants can invade. These exotic plants might find their best opportunities along roads and other openings created by logging and maintenance operations and within the stand itself after the first few years of establishment, when the use of herbicide to control competition is greatly reduced.
Approximately 42 percent of species that are listed in the United States as threatened or endangered under the Endangered Species Act are at risk because of competition with or predation by nuisance, exotic species (Wear and Greis 2002). Thus far, the Pinelands system has not been heavily impaired from such species. However, promotion of pine plantations in a landscape containing sensitive plant communities could pose a serious threat to vulnerable plants and plant communities.
C. Impacts on Wildlife
There is a general recognition that intensively managed pine plantations are not high-quality wildlife habitats (Wear and Greis 2002). Since 1960, populations of many species of resident and temperate migratory birds associated with open pine stands have undergone significant long-term population declines across much of their ranges (Hunter et al. 1994, 2001). In addition, many other species of animals and plants associated with natural pine stands are also vulnerable (Wear and Greis 2002). The primary reason for the vulnerability of these species is the conversion of native pine forests to other forest types and other land uses.
i. Birds.
Although urban sprawl and agriculture have resulted in the loss and clearing of large amounts of native pine forest, measurable avian declines from 1960 to the present correlate with the 1500 percent increase from 2 million to 30 million of intensively managed pine plantation since 1952. Priority bird species associated with older pine stands are likely harmed most by the expansion of pine plantations. A well-managed pine plantation will provide habitats that are too dense or too young for the bird species usually associated with open pine stands that are frequently subjected to prescribed or natural fire (Wear and Greis 2002).
Pine plantations were formerly lauded for their benefits to early successional species in the first few years after establishment when they resemble an old field or shrubland habitat. However, management of pine plantations has become very intensive. The result of this more intensive management is the elimination of many of the benefits formerly provided in less efficiently managed pine plantations. As is the case with birds of open pine habitats, early successional species likewise show no reversal from long-term population declines as acreage planted to pine plantations has greatly expanded in recent decades (Capel et al. 1994, Hunter et al. 2001, Krementz and Jackson 1999).
A "reduced abundance and diversity of breeding birds when forests are converted from hardwood to pine plantation
Field surveys of breeding birds conducted as part of the Small Area Assessment Forestry Demonstration Project for the Southern Resource Assessment (Evans, et al. 2002) [Tab M] found that pine plantations had the lowest bird diversity and lowest conservation values as measured by Partners in Flight priority scores. "Pine plantations of all age classes had lower abundances of cavity- and tree-nesters, neotropical migrants, and year round residents than did all other habitat classes [studied]." Id. at 4-7.
It is likely that the loss of forest structural complexity, which results from the intensive preparation and specified density, single species restocking associated with pine plantations, causes the loss of cavity nesters and lower bird diversity. Id. at 4-11.
Observations made during other studies corroborate the negative habitat impact associated with pine plantations. A survey of breeding birds made in forests of the Gulf Coastal Plain found that "natural forest types ... had more individuals and higher bird species richness than" other managed stands, and that planted slash pine stands "generally appeared to provide poor habitat for most species of birds". (Hill G.E. 1998) [Tab N]. "There are more birds in structurally diverse pine-hardwood stands than in pine stands." (Dickson J.G. 1995 (citation omitted)) [Tab O]. Generally, as lower vegetation is shaded out (or managed out) bird species abundance, density and diversity decrease. Id.
Additionally, considering the negative impact to Barred Owls which resulted from edge created during the Belleplain timber salvage operation, we can expect there to be an adverse impact to any resident Barred Owls from the edge and fragmentation created during large scale plantation operations.
ii. Nonavian.
Results for nonavian wildlife are similar to those for birds. Plantations have been found to offer habitat for some species of small mammals, reptiles, and bats, but only when stands are maintained in a condition that emulates, to some degree, a native pine stand (Mitchel et al. 1995; Aresco and Guyer 1999; Menzel et al. 2001).
In eastern Texas and western Louisiana, extensive inventories of intensively managed pine plantations and publicly-owned natural pine stands have been conducted in search of the rare Louisiana pine snake (Pituophis melanoleucus ruthveni). Results from these surveys indicated that pine snakes did not occur to any significant extent in a landscape dominated by pine plantations (Rudolph pers. com.). The only significant populations of Louisiana pine snakes remaining occur in well-burned, natural pine stands, primarily found on national forest or Department of Defense land (Rudolph pers. com.). One hypothesis offered to explain this current distribution is that alteration of natural vegetation throughout the pine snakes range, most of which has been converted to loblolly or slash pine, has negatively affected the snake’s small mammal prey base, eliminating the pine snake from many sites it formerly occupied (Rudolph and Burgdorf 1997).
In New Jersey, conversion of natural pine stands to plantations can be expected to have a similar effect upon rare snake species. Impacts to the small mammal population resulting from conversion of a natural pine forest to pine plantation can be expected to have an adverse impact on the native small mammal population upon which snakes depend for food, effectively reducing foraging habitat.
Further, Pine snakes require dry pine-oak forest types for certain life-cycle activities. Beans, B.E. and L. Niles, eds. (2003) Endangered and Threatened Wildlife of New Jersey, p. 199. In particular, open, unvegetated, sandy areas with less than 5 percent tree cover in pitch-scrub oak uplands are important nest sites for pine snakes in New Jersey (Burger and Zappalorti 1986; accord, Beans, B.E. at 199). Nesting and basking areas would not exist within a large pine plantation, and so the conversion of local pine-oak forest would only increase the rate of habitat loss now affecting the Pine snake population.
iii. Game Species
Game species such as Bobwhite quail suffer when diverse woodlands are converted to pine plantations. "Biologists have noted that crop fields established in pine are characterized by low diversity of understory plants compared to traditional clearcut and naturally regenerated or planted sites. Bobwhites and other early successional habitat dependant species simply can not thrive in these areas." (Carmichael et al. 2002) [Tab P]. See Tab P for a discussion of the impact plantation forestry has had on Bobwhite quail, and suggesting quail-friendly practices.
The findings of the Southeast Quail Study Group Technical Committee suggest that stewardship objectives which include providing habitat suitability for Bobwhite quail (Lee Bros. Plan, p.2, # 6) may not be compatible with the forest management plan.
D. Soils
Soils are a fundamental component of any forest association. The web of soil fauna and soil microorganisms has several functions: soil structure formation, organic matter decomposition, nutrient retention within the soil environment and release of nutrients to plant species inhabiting the forest. In the sandy soils of the New Jersey pine barrens, nutrients added to fertilize the soil, such as nitrogen and phosphorus, will be mobilized and pass from the soil environment into the underlying groundwater.
Disruption of the soil microbial community and removal of the shrub layer can result in decreased nutrient retention within the soil and increased loss of nutrients due to leaching. Because the soil environment of the New Jersey pine barrens is nutrient poor much of the nutrients in a pine barrens forest are tied up in the living and decomposing biomass. The soil disruption involved in agroforestry, including physical destruction of soil organisms, the use of biocides, and the suppression of understory shrub species will result in the near complete removal of nutrients necessary for forest regeneration after the harvestable timber is removed. Another consequence of elimination of the native microbial, faunal and floral community members is the increased likelihood of introduction of non-native invasive species.
Ectomycorrhizas are a major component of the soil microbial community. Ectomycorrhizas are a symbiotic association between fungi and plants such as pitch pine. Surface inventories of mushrooms reveal little about below ground community structure of ectomycorrizal fungi. (Jonsson.1998). The species richness of ectomycorrhizal fungi in coniferous boreal forest is 10-100 times higher than the diversity of the host plants. (Danielson. 1984; Allen et al. 1995); and research in the New Jersy pine barrens has found 80 different morphological types of ectomycorrhizal fungi. (Tuininga, AR. 2000).
The overall loss of species richness after clear-cutting and significant changes in species composition found by Byrd et al. (2000) indicates that clear-cutting can negatively alter the ectomycorrhizal fungal community. This alteration may have profound effects on ecosystem function. Size of forest clearcut can be important to below ground structure. After two and three growing seasons the numbers of active fine roots as well as the diversity of ectomycorrhizae in clearcuts was significantly reduced with distance from uncut forest edge (Hagerman et al. 1999). Live trees within areas of forest disturbance, such as clearcuts, could support refuge populations of ectomycorrhizal fungi. From these refuge sites the ectomycorrhizal community can reestablish during forest succession (Cranabetter. 1999). Removal of roots after tree harvest would remove the refuge for the surviving mycorrhizal fungi.
Microarthropod density rages from 9,000/m2 in the pine plains to 69,000/m2 in upland old-burn sites of the pine barrens (Dindal 1979). A vast majority of the soil animals graze on fungal tissue. Consequently, clear-cutting would result in a reduction of food resources for the microarthropods and a reduction in the amount and diversity of these soil animals.
Soil destroying activities can occur during forestry practices in several ways: causing a change in existing associations, application of microbial toxic materials, and desertification through stripping of organic material.
First, the soil ecosystem process can be severely disrupted by human caused disturbances. (Li. 2000) [Tab Q]. For example, "[c]hanges in tree species are likely to significantly alter these processes through creation of new functional processes of other organisms." Id. Thus changing the tree species of a local Pinelands forest association will likely change the very heart of that local forest ecosystem.
Second, heavy, soil-targeted, applications of Glyphosate (a/k/a Roudup, Rodeo, Accord, Vision), a broad spectrum herbicide commonly for site preparation at Pine plantation sites, can be hazardous to many soil components. In addition to possibly reducing nitrogen fixing in soils, glyphosate can be hazardous to parasitic insects and michorizal fungi. (Cox. 1995) [Tab R]. Thus, chemical site preparation for pine plantations can (and is in fact designed to) prevent regeneration of any native growth by effectively sterilizing the local soil.
Third, plantation forestry practices can quickly strip certain soils of available organic matter. Referring to the sandy, nutrient poor and acidic soils of the Cumberland Plateau, soils which like Pine Barrens have little buffering capacity and which provide nutrients only through precipitation and leaf litter, Dr. Jonathan Evans commented that "[a]fter only two cycles of pine planting and logging – about 40 – 60 years from now – the areas naturally sandy, low-fertility soil will be drained of life." Kathy Gilbert, Pine Plantations Overshadow Forests, Chattanooga Times Free Press, Feb. 8, 2002 [Tab S]. Like the Cumberland Plateau, the soils of the Pinelands can easily be drained of life if unsustainable forest practices are carried out.
Finally, an agroforestry operation leaves a long legacy. The loss of the soil communities which support native pinelands forests from mechanical and chemical sterilization, and from inoculation and colonization with non-native mycorrhiza that must accompany any successful exploitation of the sterilized mineral soils, could require thousands of years to undue. Plantation forestry in the Pinelands may cause an effectively permanent loss of the forest.
7. Summary
Intensive forest practices which result in the conversion of native, locally characteristic forest communities to ecologically sterile pine monoculture, combined with an oversight program that does not require application of ecological values in the development of forest management plans, has the potential to cause significant, long term harm to the forest communities of the Pinelands.
Proper detailed guidelines are needed for forestry practices in the Pinelands to prevent the loss of Pinelands forest communities.
8. Requested Action by ENSCA
Conversion to nonnative, hybrid, or uncharacteristic forest type will result in a loss of species, loss or habitat, loss of richness and the potential for extensive loss from disease. Loss of the locally characteristic forests may have a severe, lasting adverse biological effect.
To be certain that all wildlife conservation issues are adequately addressed before any harm occurs, and to ensure the protection of rare species and habitats, ENSAC should:
A. State that forestry practices in the Pinelands must not cause the loss of rare or critical habitat or communities.
B. Recommend that any forest projects involving more than 50 acres of clearing, or any cuts with a restocking component, be held until detailed and appropriate guidelines are developed to protect the rare species and characteristic forest community resources of the Pinelands National Reserve.
C. Encourage the State Forest Service to request assistance from public and private professionals within and without the forest industry to develop detailed guidelines for ecologically sound forestry practices in the Pinelands, including oversight and monitoring measures.
Carmichael, Breck and R.E. Thackston, Southern Pine Forests, in The Northern Bobwhite Conservation Initiative. (Dimmick, R.W. et al. eds. 2002)
Clason, T.R. Cost Effectiveness of Natural Regeneration for Sustaining Production Continuity in Commercial Pine Plantations, In Outcalt, Kenneth W., ed. 2002. Proceedings of the Eleventh Biennial Southern Silvicultural Research Conference. Gen. Tech. Rep. SRS-48. USDAFS, Southern Research Station. 622 p.
Cox, C. 1995. Glyphosate Part 2: Human Exposure and Ecological Effects. Journal of Pesticide Reform, Vol. 15 No. 4 Winter 1995.
Dickson, James G. et al. 1995. Winter Birds in Developing Pine Plantations, Proc. Annu. Conf. Southeast Ass'n. Fish and Wildlife Agencies, 49:303-313(citation omitted)
Evans, J. et al., 2002. Small Area Assessment Forestry Demonstration Project for the Southern Resource Assessment: An Assessment of Forest Change on the Cumberland Plateau in Southern Tennessee
Hill, Geoffrey E., 1997. The Effects On Bird Communities of Converting Southern Hardwood Forests to Pine Plantations, J. Alabama Academy Sci., Vol. 68, No. 4
Hill, Geoffrey E., 1998. Use of Forested Habitat by Breeding Birds in the Gulf Costal Plain, So. J. of Applied Forestry, Vol. 22, No. 3
Li. C.Y. and E. Strzelczyk. Belowground Microbial Processes Underpin Forest Productivity. Phyton, Vo. 40 Fasc. 4 pp. 129-34.
Miller, James H. 1991. Forest Herbicide Benefits and Developments for Intensive Southern Pine Culture, In, Bryce, J.; Rawlins, Cynthia L., eds. Forestry and the Environment (1991)(conference proceedings).
