Sunday, November 02, 2008

Minnesota’s Evidence of an Ancient Meteorite Impact

Imagine central North America nearly 2 billion years ago, as a
meteorite 10 miles in diameter strikes the Earth near what is now
Sudbury, Ontario . The force of the collision vaporizes the meteorite and
much of the ground near the impact site, forming a crater more than 150 miles wide(1).
Shock waves race from the impact, deforming the Earth’s crust around the crater’s edge,
and causing earthquakes that shatter the ground hundreds of miles away(2). Within seconds, a cloud of ash, rock fragments, gases, and droplets of molten rock—known
collectively as ejecta—rises through the atmosphere and begins to
spread across the globe. In this turbulent cloud of ejecta, some of the
ash and vapor coalesces—much like hail stones form during thunder
storms—to create small spheres called accretionary lapilli. The lapilli
and other ejecta are propelled from the impact site at supersonic
speeds. In the shallow ocean that covered much of the region, the
impact generates huge tidal waves (tsunamis) that cross the ocean
surface, mixing together rock fragments and ejecta. Over time, this
material is buried by younger sediments, cemented together, and
fused by molten rock to form a solid layer.


In 2007, a layer of rock was discovered in Minnesota that is
thought to have formed during the Sudbury meteorite impact event.
The layer is exposed near GUNFLINT LAKE, nearly 500 miles west
of the impact site at Sudbury (Figure 2). It is sandwiched between
the Gunflint Iron Formation below, and slate of the Rove Formation
above (Figure 3). Both of these formations were deposited as muddy,
oceanic sediments. Nearly a billion years later, these rocks were
intruded by magma (Logan Intrusion) as part of a major continental
rifting event.

Most of the impact layer consists of breccia—a mixture of
fragments broken from the underlying iron-formation and cemented
together (Figure 4). These fragments represent pieces of seafloor that
were ripped loose by impact-related earthquakes and carried down
a submarine slope.

Only the uppermost part of the layer at Gunflint Lake contains
true ejecta—the most obvious of which are accretionary lapilli. Notice
in repeated layering of ash and melt droplets onto the hail-stone like
projectiles. In some of the locations near Gunflint Lake, the lapilli
are intermixed with large iron-formation fragments (Figure 6),
suggesting that the material was reworked by tsunamis.
The impact layer extends discontinuously from Thunder Bay,
Ontario(3), southward into parts of Michigan(4) (5), and westward into
Minnesota (Figure 2). Although it’s a thin layer—only about 25 feet
thick in Minnesota—it’s a very important and remarkable one. Its
importance lies in the record of global catastrophe that occurred in a
“moment” of the planet’s long geologic history and it is remarkable
that such a thin layer has survived weathering and erosion for nearly
2 billion years.

Of the 174 scientifically verified impact structures on Earth,
only one is larger, and few are older, than the Sudbury Impact(1).
For comparison, the Chicxulub Impact on the Yucatan Peninsula of
Mexico, is much younger (~65 million years old) and its crater size
is smaller. Yet, the Chicxulub event caused world-wide extinction
of many species, including dinosaurs. Clearly, the larger Sudbury
impact event would also have had global ramifications.

The internal organization of units within the impact layer at
Gunflint Lake is consistent with the sequence of events outlined
on the table. Seismic shaking from earthquakes deformed and
fragmented the underlying iron-formation, and caused submarine
debris flows that redistributed the fragments into a thick breccia
unit. This was followed by deposition of airborne ejecta that rained
down on the ocean surface and settled to the sea floor, forming the
lapilli unit. Finally, localized reworking of the ejecta and breccia units
by tsunamis produced the uppermost unit of mixed fragments and
lapilli.

Given the preceeding “context for interpretation,” it is an
interesting footnote that the entire layer of breccia and ejecta very
likely represents the catastrophic events of a single day; caught
during the 48 million years that separate the deposition of Gunflint
Iron Formation below from Rove Formation above Table

ARRIVAL TIME EFFECT MODERN ANALOG
1. ~13 seconds Fireball 3rd degree burns, trees ignite
2. ~2-3 minutes Earthquakes Richter scale 10.2 at Sudbury,
buildings collapse at Gunflint Lake
3. ~5-10 minutes Airborne ejecta a layer 1-3 meters thick, with
arrives fragments <1 cm in size
4. ~40 minutes Air Blast Maximum wind speeds ~1,400 mph
5. ~1-2 hours Tsunami None of this magnitude
F
Despite the fact that large meteorite impacts are exceedingly rare
and unlikely in our lifetime, recent geological research demonstrates
that the impact process is fundamental to the formation of terrestrial
planets. The on-going study of these ancient deposits in the Lake
Superior region (Figure 8) will enhance our understanding of the
environmental consequences of impact during the oldest time period
in Earth history.

REFERENCES AND ADDITIONAL RESOURCES
(1)www.unb.ca/passc/ImpactDatabase Website describing 174
meteorite impacts world-wide. Developed and maintained
by Planetary and Space Science Centre, University of New
Brunswick, Fredericton, New Brunswick, Canada.
(2)Dietz, R.S., 1964, Sudbury structure as an astrobleme: Journal of
Geology 72:412-434.
(3)Addison, W.D., Brumpton, G.R., Vallini, D.A., McNaughton, N.J.,
Davis, D.W., Kissin, S.A., Fralick, P.W., and Hammond, A.L.,
2005, Discovery of distal ejecta from the 1850 Ma Sudbury impact
event: Geology 33:193-196.
Figure 8. Electron microprobe image of accretionary lapilli (by McSwiggen and
Associates, PA).
8
(4)Cannon, W.F. and Addison, W.D., 2007, The Sudbury Impact layer
in the Lake Superior iron ranges: A time-line from the heavens:
Institute of Lake Superior Geology, 53rd Annual Meeting,
May 8-13, 2007, Lutsen, Minnesota, v. 53, Part 1-Proceedings
and Abstracts, p. 20-21. Available via website: (http://www.
lakesuperiorgeology.org).
(5)Pufahl, P.K., Hiatt, E.E., Stanley, C.R., Morrow, J.R., Nelson, G.J.,
and Edwards, C.T., 2007, Physical and chemical evidence of the
1850 Ma Sudbury impact event in the Baraga Group, Michigan:
Geology 35:827-830.
(6)Collins, G.S., Melosh, J. H., Marcus, R.A., 2005, Earth impact effects
program: A web-based computer program for calculating the
regional environmental consequences of a meteoroid impact on
Earth; Meteorite and Planetary Science 40:817-840. (www.lpl.
arizona.edu/impacteffects)
(7)Davis, D.W., 2008, Sub-million-year age resolution of Precambrian
igneous events by thermal extraction-thermal ionization mass
spectrometer Pb dating of zircon: Application to crystallization
of the Sudbury impact melt sheet: Geology, 36:383-386.
(8)Fralick, P.W., Davis, D.W., and Kissin, S.A., 2002, The age of the
Gunflint Formation, Ontario, Canada: single zircon U-Pb age
determinations from reworked volcanic ash: Canadian Journal of
Earth Sciences 39:1085-1091.
Or Contact:
Mark Jirsa
Minnesota Geological Survey
jirsa001@umn.edu
612-627-4780 X208
or
Paul Weiblen
University of Minnesota
Department of Geology and Geophysics
pweib@umn.edu
Prepared with editorial and technical support from Barb Lusardi and Richard
Lively-MGS

Friday, June 13, 2008

Echo Ridge (Complete)

Our property consists of 5.5 acres of land with 350 feet of lakeshore. The Gunflint Trail bisects the property, east to west, with approximately 1.5 acres on the south side of the trail, facing the lake. Nor’wester lodge is to our east, Windigo lodge is to our west.
The first deed recorded on our abstract shows George Signalness filed on June 26, 1891, paying the princely sum of $206.15. The property consisted of several thousand feet of lakeshore which was acquired in 1934 by Alice and Carl Brandt Sr. The Brandt’s divided the property into smaller parcels in the early 1940’s, selling to Victor Abrahamson, A. J. Eaton, Frank Arco and Richard & Earnest Heidenrick.

The Eaton parcel, 350 feet of lakeshore and 5.5 acres of land was sold to Arthur and Lucille Berndt in 1949, who sold to Robert and Nell Williams in 1955. The property was purchased by Arnold Longfellow in 1956 for $3,850 and named “Longfellow’s Hiawatha Resort”. It was run on a part-time basis until the new Gunflint Trail divided the property. Longfellow abandoned the resort shortly after that, listed it for sale several times, changed his mind several times, and (luckily for us) agreed to our offer in 1976.

I first inquired about the property in late fall of 1975 upon seeing an ad in the St Paul Pioneer Press. Rarely were northern Minnesota properties advertised in Twin Cities papers. My telephone call to United Farm Realty revealed their offering was zoned commercial and priced beyond our budget.

In May of 1976 I spoke by telephone with the United Farm agent in Grand Marais, Mr. Trygve Hanson, who was eager to show me some properties off the Gunflint Trail. Armed with a blank check and high expectations, I drove alone to Grand Marais to see what was available. Mr. Hanson took me to two places, one on West Bearskin Lake and one on Poplar Lake. Neither was appealing. Surprised to find these were the only properties being offered and already headed back to Grand Marais, I asked about the “abandoned resort” offered in the paper last fall. “Oh, would you like to see it?” Mr Hanson replied. (We have often wondered how well he did in the real estate business).

A quick turnaround had us back at Poplar Lake, having driven past the place on our way back towards town. After overcoming the initial shock of this truly abandoned mess, I surrendered my sanity, signed an earnest money contract, deposited $100 with the understanding the property would be held for 30 days pending inspection and approval of my business partner. My thoughts on the drive back to St Paul were focused on how to artfully present this opportunity to Joan, my compassionate, understanding, loving and adventurous wife. A coward dies a thousand deaths!

In June we met Mr. Hanson and began to explore the abandoned resort (fishing camp) consisting of six sleeping cabins, “main lodge”, ice house across the trail, pump house at lake, two outhouses and shed containing inoperative gas generators, water pump, suspended water tank and lots of parts (to what?) All the buildings had been broken into and ransacked. The windows were boarded up and the doors were padlocked. However, the lodge and cabins still contained beds, bedding, dishes, glassware, cutlery, towels, dry foodstuffs, some pieces of furniture, two gas ranges and a gas refrigerator. Cedar-strip boats, partly submerged, littered the shore. Electric wires drooped between the cabins. Copper tubing curved along an outside wall serving the kitchen sink. Each cabin had a wood burning stove, two burner gas plate, sink basin with drain through the floor, hand made bunk beds, shelf for dishes and a clothes rack. Several large brush piles were prominent. Garbage dumps containing a wide variety of interesting debris were conveniently situated proximate to the cabins. In the ice house across the road, and behind it, was a trove of discarded treasures.

After tramping the grounds and inspecting the insides of all the buildings, our real estate agent gave us the cabin keys and told us to drop them off at his office the next day. “Where can we find a place to get a martini” Joan inquired, fed up with crawling into dark, musty buildings and battling swarms of voracious mosquitoes. Told that Rockwood Lodge, owned then by Don Lobdell and Rick Whitney, was right down the road, we headed for the only spot within 30 miles that had on sale liquor. Civilization at last!

During the 6 hour drive to St Paul the next day, we debated the wisdom of purchasing a “work farm” 300 miles from home, with considerable anxiety directed towards the financial burden of a second mortgage. “Why do I want to drive this far when my dad has a place in Wisconsin we can get to in less than 2 hours” she asked. “Because it’s on the edge of the BWCA wilderness, with no cabins or roads on the other side of the lake” he replied. “The place is a disaster, it’s too far from St Paul, nobody will ever drive this far to visit us, we don’t know anybody up here” she cried. “That’s the beauty of it” he countered, “350 feet of lakeshore and 5.5 acres is a bonanza. Besides, what’s a little work. We’ll fix it up and then just sit back and relax”. “We can’t afford it” she said.
“We can’t afford to let it get away” he said. After much discussion we agreed to buy the place. The down payment was $7000, quite a bit more than we had in our savings account. The mortgage would be $16,500 at 8% interest for 17 years, payments a ghastly $150 per month. Taxes would be $192.07 in 1977. The stage was set to begin our transformation from city folks to “jackpine savages”, one of the best decisions we ever made.

We took possession on the 4th of July, 1976. Our two youngest children, Jeanne 13 and Steven 11, came with us on the first trip. Our two older daughters, Karen 18 and Kathy 17 were more interested in being left home alone. Karen had just graduated high school. Both had summer jobs, neither relished the idea of “working” at the new lake place.

After prying the boards off the windows of the lodge we discovered there was no electricity…none, anywhere. No pole, no meter, no lights. How could this be? Our real estate agent somehow neglected to mention it. Lesson #1 – Caveat Emptor. The sun was shining, mosquitoes by the millions, holes in the screens, broken panes of glass, lots of junk to haul somewhere, who to ask, where to go? After cleaning the main lodge and the two 1930 era gas ranges, Joan started work on the gas refrigerator in the kitchen. “You’ll never get that to run” I said. “Drive down to the place with the store and ask about a dump” she replied. The kids went with me to Trail Service Center where we met GayLynn Liebertz. After introductions she gave me directions to the spring between Leo Lake and Hungry Jack, and to the dump. The spring was our drinking water supply for many years, until we learned that water was available at the Forest Service campgrounds. The dump was one of the best things we discovered in all the years we’ve lived up here. Christened “Aspen Mercantile” by old timer Rolf Huggenvik, the dump served as both a depository for what we discarded and a source of useable materials we found valuable. Best of all, the dump provided entertainment…the bears!

We soon scheduled our trips to Aspen Lake in the evenings when the adult bruins and their off-spring came to dine. Often we had to vie with visitors from the resorts and other cabin owners to find a space at the edge of the dumping area. Our guests considered a ride to the dump (in the back of our pickup) the highlight of their visit. We mourn the advance of trash disposal technology.

The first summer was backbreaking and exciting. We started by gutting the pressed sawdust walls and Masonite ceilings in the lodge, exposing 2x4 studs and rafters, no insulation and piles of dried deposits left by legions of mice and bats. We painted, stained, replaced window panes and screens, burned brush and rotted boats, living by the light of the sun during the day and Coleman lanterns at night. After lengthy discussion with Arrowhead Electric regarding replacement of a pole and meter (Longfellows left without paying their final bill) we finally had electricity in late August. After meeting Carl and Luana Brandt at Nor’wester Lodge we were introduced to Emerson and Jeanette Morris. They spent their summers on the trail, living in their cabin adjacent to Nor’wester with sons Keith and Emerson Jr. When we told Emerson about the water pump in the shed and that we had no idea how it worked, he agreed to come over and take a look. Sections of pipe and couplings were in the pump house at the lake but one piece was missing. Emerson asked if I had seen it. Duh! I had used a short piece of pipe to pry some rocks, not realizing it was part of the pump assembly. Luckily the threads were not stripped. Lesson #2 – everything lying around probably has a use. When the pump and water line were connected and the pump running we heard screams from Joan. The copper tubing in the kitchen, installed in gentle loops with no petcock, had split in several places during previous winters, turning the kitchen into a walk-in shower!

Jeanne and Steve accompanied us on all our subsequent trips, helped with the work, built our first dock and even enlisted the aid of friends whose parents let them go “up north”. They all worked, swam, fished, and had a great time. But Karen and Kathy hadn’t seen the new place. Labor Day weekend saw us all headed north, pulling a borrowed trailer loaded with necessities, many donated by relatives who had things that would be “great for the lake”. Included in the trailer were: beds, bedding, lamps, appliances, tools, (we now had electricity) pop, beer, Weber kettle, charcoal and all the new clothing recently purchased to start school. Why would teenage girls bring almost every piece of clothing they owned you ask? You never had teenage girls! The groceries were in the trunk. We filled the car with gas in Duluth. The summer of 1976 was very dry and burning bans were in effect throughout the state. Joan and daughter Kathy smoked. As we approached Two Harbors I noticed in the rear view mirror what I thought was smoke. I asked Joan if there was a fire in the roadside ditch. She answered no. When I slowed to point out the big chicken statue on the left hand side of the highway, I saw flames leaping from the rear of the trailer. I put the car in the ditch, yelled for everybody to get out and away from the car and fumbled with the trailer hitch, finally getting it unhooked. The trailer was blazing. I moved the car and within minutes the police arrived, followed shortly by the local fire truck. The firefighters had the inferno out in record time. Luckily the tires on the trailer did not burn. After contacting the State Farm agent in town we picked up the blackened, dripping trailer and parked it in a secured area. With no hope of rescuing anything we proceeded to Grand Marais, much to the disgruntled dismay of the girls. They had nothing to wear!

Old clothes from friends at Kimball Creek and a stop at a local garage sale outfitted the teenagers in garb they wouldn’t be seen dead in at home. Less than a perfect beginning to their first look at the new lake place we had renamed “Echo Ridge”. How did the fire start? Possibly one of my smokers tossed a cigarette out the window and it landed in the trailer? Or perhaps someone in a passing car? An unsolved mystery since neither of my suspects ever confessed. The older girls survived the weekend, helped with the dirty work in their new, old clothes and accompanied us to Windigo where we all became friends of the Ekroot family and the Saint Bernard dogs.

On the trip home we picked up the trailer, unloaded all the burnt debris at the Two Harbor’s dump, salvaged some tools and, miraculously, a 14K gold necklace and several pairs of brand new earrings. I paid for the materials, helped rebuild the trailer and was allowed to use it many more times in the following years. Lesson #3 – be thankful for good friends.

In October we hosted Joan’s parents, two of her brothers (Ron and Jack), Jack’s wife Katie and their infant son Andy. I roofed for the first time in my life during their stay, wisely choosing to begin on the back side of the lodge where the wavy shingle lines were not obvious. It snowed! We had a turkey dinner and pretended it was Thanksgiving Day.

What we have experienced in the 31 years since buying our lake home is nothing short of wonderful. We learned early on that Echo Ridge is not too far for visitors from the cities to travel, and we had cabins and beds for them to sleep in. Although the lures we dangled were canoeing, fishing, hunting, wildlife (moose, bear, grouse, Windigo), great meals and occasional beverages, what we really angled for was a volunteer (low cost) workforce. This was willingly provided by our kids and their pals, good friends, and most notably the Lachenmayer clan, our main source of help; technical, physical, emotional and comical. Sweat labor was the most common form of summer entertainment, enhanced by the constant attack of black flies and mosquitoes. Summer started in May when the lake opened and ended in October with “Honeymoon Weekend”, the no-kids-allowed hiatus for grown-up siblings, where the only labor beyond cutting and splitting firewood was the futile efforts of the guys trying to best the girls in Trivial Pursuit.

We have enjoyed the visits of not only relatives and friends, but also former owners of our property and families who vacationed here before we bought it.

We’ve yet to achieve our original goal to stop working and just relax, but we don’t do as much every day as we did in the early years…our energy levels aren’t what they were. The Morris family became our close friends, sharing recipes, stories and even secret spots to pick blueberries. Jeannette became Joan’s “north shore mother”. Emerson and Keith did all the major renovations to our buildings; moving cabins, designing and remodeling interiors, building our garage and upgrading the outhouses, cutting off the end of the main lodge and creating a bathroom and kitchen with indoor plumbing.

Since his parents’ passing, Keith has continued to be our builder. Working with Bob Johnston and Bob Olson they recently converted the original generator shed into a laundry room. After 28 years using the machines at Nor’wester and Windigo, Joan finally has her own washer and dryer.

Adversity tempers the steel of north woods property owners. We have endured the onslaught of army worms and tent caterpillars, survived the wrath of the “Blowdown”, overcome a frozen septic system, lamented the diminishing population of walleyes, seen lake levels fall and wondered why the snow doesn’t. We have watched in horror as fires burned thousands of acres of our beloved forests, destroying homes and businesses. We count ourselves blessed that our property has been spared. We love it up here because it is a unique treasure. We have wonderful friends and neighbors who share our affection for all the things Cook County and the Gunflint Trail offer. Many of the property owners we have met or heard about during our years at Echo Ridge have stories to share that make ours pale in comparison. We are first generation land owners who stand in awe of the pioneers who developed this area and we are deeply indebted to them for their sacrifices

Sunday, October 21, 2007

Save the Planet: Vote Smart

New York Times-Op-Ed Columnist
Published: October 21, 2007

People often ask: I want to get greener, what should I do? New light bulbs? A hybrid? A solar roof? Well, all of those things are helpful. But actually, the greenest thing you can do is this: Choose the right leaders. It is so much more important to change your leaders than change your light bulbs.

Why? Because leaders write the rules, set the standards and offer the tax incentives that drive market behavior across a whole city, state or country. Whatever any of us does individually matters a tiny bit. But when leaders change the rules, you get scale change across the whole marketplace. And the energy-climate challenge we face today is a huge scale problem. Without scale, all you have is a green hobby.

Have no illusions, everything George Bush wouldn’t do on energy after 9/11 — his resisting improved mileage for cars and actually trying to weaken air-conditioner standards — swamped any good works you did. Fortunately, the vacuum in the White House is being filled by leaders from below.

Take the New York City taxi story. Two years ago, David Yassky, a City Council member, sat down with one of his backers, Jack Hidary, a technology entrepreneur, to brainstorm about how to make New York City greener — at scale. For starters, they checked with the Taxi and Limousine Commission to see what it would take to replace the old gas-guzzling Crown Victoria yellow cabs, which get around 10 miles a gallon, with better-mileage, low-emission hybrids. Great idea, only it turned out to be illegal, thanks to some old size regulations designed to favor Crown Vics.

Recalled Mr. Hidary: “When they first told me, I said, ‘Are you serious? Illegal?’” So he formed a nonprofit called SmartTransportation.org to help Mr. Yassky lobby the City Council to change the laws to permit hybrid taxis. They also reframed it as a health issue, with the help of Louise Vetter, president of the American Lung Association of the City of New York.

“New York City has among the dirtiest air in the U.S.,” Ms. Vetter said. “When it comes to ozone and particulate matter, New Yorkers are breathing very unhealthy air. Most of it is tailpipe emissions. And in New York City, where asthma rates are among the highest in the nation, the high ozone levels create very serious threats, especially for kids who spend a lot of time outdoors. Converting cabs from yellow to green would be a great gift to the city’s children.”

Matt Daus, who heads the taxi commission, which is independent of the mayor, was initially reluctant, but once he learned of the health and other benefits, he joined forces with Messrs. Yassky and Hidary, and the measure passed the City Council by 50 to 0 on June 30, 2005. Since then, more than 500 taxi drivers have converted to hybrids — mostly Ford Escapes, but also Toyota Highlanders and Priuses, and others.

On May 22, Mayor Michael Bloomberg, one of the greenest mayors in America, decided to push even further, insisting on a new rule, which the taxi commission has to approve, that will not just permit but require all cabs — 13,000 in all — to be hybrids or other low-emission vehicles that get at least 30 miles a gallon, within five years.

“When it comes to health and safety and environmental issues, government should be setting standards,” the mayor said. “What you need are leaders who are willing to push for standards that are in society’s long-term interest.” When the citizens see the progress, Mr. Bloomberg added, “then they start to lead.” And this encourages leaders to seek even higher standards.

I asked Evgeny Freidman, a top New York City fleet operator, how he liked the hybrids: “Absolutely fabulous! We started out with 18, and now we have over 200, mostly Ford Escapes. Now we only put hybrids out there. The drivers are demanding them and the public is demanding them. It has been great economically. With gas prices as they are, the drivers are saving $30 dollars a shift.” He said drivers who were getting 7 to 10 miles a gallon from their Crown Vics were getting 25 to 30 from their hybrids. The cost of shifting to these hybrids, he added, has not been onerous.

Now Mr. Hidary is trying to get law firms and investment banks, which use gas-guzzling Town Cars — 12,000 in the city — to demand hybrid sedans only.

This is how scale change happens. When the Big Apple becomes the Green Apple, and 40 million tourists come through every year and take at least one hybrid cab ride, they’ll go back home and ask their leaders, “Why don’t we have hybrid cabs?”

So if you want to be a green college kid or a green adult, don’t fool yourself: You can change lights. You can change cars. But if you don’t change leaders, your actions are nothing more than an expression of, as Dick Cheney would say, “personal virtue.”

Saturday, March 31, 2007

Byways Response to USFS's Devils Trout Forest Management Project

DATE: March 24, 2007
TO: Dennis Neitzke, District Ranger
United States Forest Service
Gunflint Ranger District
Grand Marais, MN 55604

FROM: Nancy Seaton, Chairperson
Gunflint Trail Scenic Byway Committee
318 S Hungry Jack Rd.
Grand Marais, MN 55604

Shari Baker, President
Gunflint Trail Association

RE: Comments on Devil Trout Environmental Assessment
and aspects affecting the Gunflint Trail Scenic Byway

The comments that follow address the U.S. Forest Service proposed forest management activities outlined in the Devil Trout Project Environmental Assessment that would affect the state designated Gunflint Trail Scenic Byway within the Superior National Forest.
These comments were originally submitted on May 20, 2006 as a response to the original Devil Trout Project Preliminary Environmental Assessment. Since that time the original environmental assessment and final decision was released and then withdrawn and replaced with the current Devil Trout Project Environmental Assessment. In response to this action we are resubmitting our previous comments with a few additions and clarifications relating to new information and agency responses to our previous comments.

We appreciate that the scenic byway status of the Gunflint Trail was acknowledged within the environmental assessment. We thank you for meeting with our committee and explaining the agency plans within the scenic byway corridor. If forest management activities within the viewshed of the scenic byway corridor are deemed necessary for forest health reasons, we tend to agree with the agencies general logic of conducting partial cuts coupled with the planting of longer-lived species such as pine. Upon further review of the plan, coupled with on-site inspections of the stands proposed for treatment, we feel that, with some adjustments, the U.S. Forest Service’s "original" proposed action – alternative 2 – could complement our goals and desired future conditions for the scenic byway. The original preliminary environmental assessment stated that alternative 2 was the proposed action, although alternative 3 was added for consideration in response to some comments received during the scoping period. When the original final decision was released it was decided to implement alternative 3 over the forest service preferred alternative. This would add another 1000 acres of clearcutting with most of it to be naturally regenerated into even aged aspen.

The current environmental statement states on page 1-13 in section 1.5, entitled "Proposed Action", that alternative 2 is still the proposed action. In this section is Table 1.4 which lists the "Summary of Primary Treatments", which does not include the extra 1000 acres of clearcutting and even-aged aspen regeneration called for in the "Early Successional" alternative 3. We reiterate our support for alternative 2 with some suggested adjustments. However, should alternative 3 be chosen we request that it be modified to better protect within-stand diversity by leaving more of the existing conifer component and including more pine, spruce, cedar and tamarack planting in the added treatment units. With that in mind we have a number of comments, concerns and suggestions to respectfully offer.

The Gunflint Trail is a state sponsored scenic byway and a major tourism related resource within Cook County, Minnesota. Under the Cook County Land use plan this area is listed as an "extraordinary resource in North America". The scenic byway includes a buffer zone of one mile on each side of the road. Our committee is currently in the process of seeking national scenic byway status. As a requirement to obtaining national status, an initial corridor management plan was developed and adopted in June of 2005. Another requirement for national designation is that certain intrinsic qualities be demonstrated. Among these intrinsic qualities are natural and scenic qualities. Natural qualities are defined within the plan as those that apply to "those features in the visual environment that are in a relatively undisturbed state". It is further stated that these features predate the arrival of human populations and that "there may be evidence of human activity, but the natural features reveal minimal disturbances". The intrinsic scenic quality must include characteristics of the landscape that are "strikingly distinct and offer a pleasing and most memorable visual experience." It is also stated that, among other elements of the landscape, vegetation must "contribute to the quality of the corridor’s visual environment".
The scenic byway committee has recently formed a forestry subcommittee to deal with the natural vegetation intrinsic quality of the Gunflint Trail. We are beginning the process of developing a comprehensive vegetation management plan. There is a consensus that the existing unbroken older forest characteristics along the byway be maintained wherever possible. There is agreement that within-stand age class and species diversity adds to the scenic quality of the road. Also recognized is the need to maintain and increase the amount of longer lived species such as red and white pine, white cedar, tamarack, white spruce and northern hardwoods such as maple and yellow birch where appropriate.

We are concerned with the cumulative impact of natural and human disturbance on the formerly unbroken older forest characteristic of the scenic byway. Under the proposed plan, forest management activities would be conducted on 26 stands within the scenic byway corridor. Seven of these treatments would be directly adjacent to the road. All of these activities would be conducted within a six-mile stretch of the scenic byway. As you know, the 1999 windstorm and the ensuing salvage logging and prescribed fires have left much of the upper half of the scenic byway fragmented with large areas in a much younger age class. When one couples this with proposed Minnesota DNR management activities and previous resource agency activities conducted over the past 10 years, the current proposed activities could, if not conducted with extraordinary consideration to aesthetic values, diminish our stated visual quality goals necessary for national scenic byway designation.

This area is typed as birch-aspen-spruce-fir. However, it once contained a much greater component of white pine. Much of that had been logged in previous years and either allowed to regenerate to the current typing or converted to red pine, white spruce or aspen monocultures. There still exists, however, a fairly large component of white pine intermingled throughout this planning area suggesting that this land once did, and currently could, support more white pine. The forest service acknowledged this fact in its previous "Behind The Ridge" and "Northern Lights" Environmental Assessments dealing with this area.

While the current proposal appears to take many of our concerns into consideration we offer the following general as well as site specific suggestions and requests.

There should be no clearcutting within the viewshed of the road. We feel that any cutting done within the viewshed of the roadway should be partial cuts targeting specific species, such as decadent aspen or dead and dying balsam fir or birch. The objective should be to open the canopy or thin the stand only enough to allow the natural and artificial regeneration of longer lived species such as white pine. The majority of the existing conifer component, whether advanced regeneration or mature, should be retained with the exception of thinning conifers such as balsam fir where they have formed thickets hindering growth rate or planned regeneration. All white pine, white cedar, white spruce and tamarack should be retained. Wherever soils permit, replanting should be conducted without rock racking. Any mechanical site prep should be done so as not to damage the roots of leave trees. Any new access routes viewable from the scenic byway should be discreet and revegetated with tree cover upon completion of management activities. In those areas outside the viewshed of the byway but within its stated corridor any cutting should, at a minimum, retain a higher amount of the existing conifer component to better protect within-stand diversity.

The proposed white pine planting is being called "diversity planting" involving 200 to 400 trees per acres. This could be interpreted that the affected stands will still be typed as aspen. We ask that those stands along the Gunflint Trail to be partial cut and "diversity planted" with white pine be cut at a time appropriate to reduce aspen suckering and that the higher amount of pine be planted. The object of this would be to reduce aspen competition and provide adequate stocking of white pine to ensure its future presence along the trail.

All white pine planting needs to have regular follow up and treatment to deal with deer browse, blister rust, tip weevil and white pine aphid as well as suppressive vegetative competition. We request that the majority of the white pine acreage be budgeted for these follow-up activities and not just the 30 percent called for in the current plan. All research indicates that this will need to be done for the long term. We would like to see these follow ups budgeted for and that any white pine plantings maintain an adequate stocking rate over the long term to eventually make a substantial difference to the visual quality of the scenic byway. We ask that these plantings not be certified in the fifth year as proposed. Instead, we request they be monitored for at least 10 years to insure an adequate stocking. As is often stated by Jack Rajala of Rajala Lumber Company, white pine is not a species that can be planted and forgotten. This general philosophy is expressed in publications by the Minnesota DNR as well as corroborated by most research.

Of major concern is the planned clearcutting of stand number 5 in compartment number 148. This 100 acre clear-cut would extend for over three-quarters of a mile from FR1310 northward and involves the headwaters of timber creek. The current plan is to clear-cut all merchantable timber with the exception of 6 to 12 leave trees per acre as well as 5 percent as legacy patches. From the road this stand does not appear to be in an advanced state of decline, as are some stands further south. Instead, this stand, especially those portions towards the north, appears healthy and contributes a positive visual aspect to the road. There is a fair amount of mid and older aged white pine throughout the stand within the viewshed as well as other healthy conifers. We would ask that you reconsider this cut by considering a variable thinning or partial species cut in that portion of the stand viewable from the road. We ask that you leave all viable conifers, especially white pine, throughout the stand. We also request that you consider planting white pine throughout the whole portion ot the stand to be cut, especially in those areas viewable from the road, in addition to the planned planting on the 30 acres to the SW portion of the stand. The current prescription states that the Regeneration Forest Type would be even-aged aspen. While even-aged monocultures of young aspen are appropriate for some areas they tend to have an industrial forest characteristic which would negatively impact the visual quality of the scenic byway. When one views the unit card map for this stand it would appear substantially less than the stated 100 acres are to be cut. Another conflicting aspect of this cut is the GIS map supplied by the forest service to the committee, which shows even less acreage is proposed to be cut. In verbal conversations with the agency it was revealed that the GIS map reflects a proposed cut of less than 40 acres. We support this lesser amount of cutting with a stipulation that the cut line closest to the Gunflint Trail be irregular in shape and not a straight line.

Stand number 3 in compartment 191 is slated for a standard clear-cut and is to be regenerated into a monoculture of even aged aspen. We ask that more of the conifer component, including all white pine, be reserved and consider a partial cut in those areas viewable from the road. In addition, we would like to see white spruce and white pine diversity planting in areas nearest the Gunflint Trail and Trout Lake Road. There had previously been some cutting along the byway adjacent to this stand and an attempt was made to reintroduce white pine on a small portion of it. Our suggestion would be to expand on this previous work.

Stand numbers 55 and 61 in compartment 190 appear to abut one another.

We agree with the prescription of stand 55 but request that at least 400 white pine per acre be planted, that they be protected from deer browse and that a portion of healthy existing conifers be retained. In stand 61 we request that there be enough conifer component retained to add diversity to the stand as it regenerates and that a smaller amount of white pine and white spruce be added as diversity planting.

In stand 45 in compartment 190 and stand 4 in compartment 198 it would be nice to see a higher basal area than 30 percent left. Considering the advanced age of these stands, too high of a reduction in basal area would increase the probability of the remaining trees dying prematurely of moisture stress, disease and wind throw. This fact is acknowledged in the current 10-year forest plan. Please reference that portion of the forest plan dealing with basal area retention when under-planting white pine. Should this occur, the shelter they would provide the regenerating white pine would be lost. This should actually be considered in all partial aspen cuts. Stand 4 in compartment 198 is next to the "Pines" and it is nice to see you attempt to increase white pine in this area. This stand already appears to have a basal area approaching 50-70 percent, which should be adequate for white pine regeneration. We also request that any healthy mid-level conifers by retained to add visual diversity to the stand as it regenerates and that the aspen be cut at a time which would reduce aspen suckering.

While we agree with the proposed treatment of stand 5 in compartment 200 we request that the stated 20 percent of spruce be retained and that some white pine be added to the stand if possible.

In stand number 10 in compartment 200 it would be nice to see the partial cut set up as variable instead of just 30 percent. The aspen in this stand is younger and it would be nice to see a higher basal area left along the road if possible as well as a portion of healthy existing conifer component for structural and visual diversity. We do, however, agree with and appreciate the proposed white pine and white spruce planting in this unit.

Stand 42 in compartment 206 and stand 22 in compartment 200 together comprise what is known as the "George Washington Pines". Stand 42 was thinned a few years back by using horses. We understand the objective of reducing fuels loads within these stands, including balsam fir ladder fuels. We hope that this will be done in a way to achieve an aesthetically pleasing result by allowing a portion of the under-story to remain while under-planting white pine. In stand 22 we suggest that any fuels reduction project be conducted without the use of heavy equipment, as this is an area of high scenic, historic, cultural and recreational value. We also request that any thinning of the red pine be variable to avoid the artificial plantation look of straight rows. The ski trails that run through this stand are also used as birding trails in summer. Even a relatively small amount of understory increases the bird species count. These two units should be treated as one and with a light hand.

Stand 25 in compartment in compartment 200, while not directly adjacent to the Gunflint Trail, is within the byway corridor and is another Red Pine of the same age encompassing a large portion of the ski trail. This stand is slated to be commercially thinned in strips. We would request that it be variable thinned so as not to create an artificial row or strip appearance. At the least we would request that strips or rows are not evident along the ski trail by variable thinning the first few rows as is called for in the Minnesota Forest Resources Council Visual Best Management Practices Guidelines.

Concerning cutting not directly along the road, but within the one-mile buffer zone on each side of the road, all of our initial general comments would apply, especially those dealing with a higher amount of conifer leave trees to achieve better within stand diversity.

The Kimball and Mink Lake area is a high value recreation resource within the scenic byway corridor and is slated for extensive clearcutting. We ask that you consider leaving a higher amount of the conifer component when clearcutting these stands and provide some amount of diversity planting so that this area does not take on the character of even-aged aspen monocultures. The stands in question would be stands numbered 3, 6, 13, 24 and 30 in compartment 191 as well as stand 17 in compartment 192.

Stand number 19 in compartment 198, currently typed as a birch, is proposed to be clear-cut and converted to a white spruce plantation. Being that this stand is within the buffer of the corridor we suggest leaving a higher component of leave trees including all pine, cedar and some healthy birch throughout the stand for diversity. White spruce is relatively shade tolerant and should do fine with more leave trees. We also hope that stands 25 and 23 in compartment 111 would respect the Shipstead-Newton-Nolan federal law as the Brule River is navigable water and is a high value recreation resource within the scenic byway corridor.

While we still support the forest service proposed alternative 2 we do have a few questions about alternative 3, should that be the selected alternative. Under this alternative 369 acres of aspen in stands 188-7, 189-7 and 201-28 are to be clear-cut and naturally regenerated into birch. We would request an explanation of how this would be accomplished. It seems to go against all research to suggest this could happen on its own as the aspen would heavily sucker in and once again be an aspen stand. The forest plan calls for a reduction of aspen and an increase in white pine and white birch and should these stands revert back to aspen then alternative three would not meet the forest plan objectives. Also the extra 1000 acres of clearcutting would reduce within-stand diversity which is also contrary to the forest plan. The forest plan states that clear-cutting does reduce diversity and one of the plan objectives is to increase within-stand diversity.

Another aspect of alternative three is the addition of stand 27 in compartment 200. This would be a very large clear-cut within the byway corridor to be converted to even-aged aspen and would connect to a whole series of cuts with the objective of creating an over 300 acre stand of even- aged aspen within and adjacent to the byway corridor. We would ask that if this is done that a high component of conifers be maintained, there be some diversity planting in those portions within the byway corridor, especially nearest the viewshed of the road, and that it be reconfigured so as not to have such straight lines on the southern and eastern portion of the cut.

Please understand that we are not against logging within the corridor for forest health reasons. When logging must take place for such reasons it does provide a number of tangible and positive economic factors such as jobs and revenue. However, the outcome of any activities within the scenic corridor should be to maintain or create natural appearing forests with a high degree of within-stand age class and species diversity, while increasing the future component of longer lived species, as opposed to the creation of monocultures of even aged aspen or conifer plantations.

While we realize that some of our suggestions would likely increase the cost of forest management activities, we feel this is justified by the nature of the area being a high value tourism resource as well as a state designated and federal candidate scenic byway. We are more than willing to do whatever is in our ability to assist you. For example, we may be able to offer voluntary help or locate alternative supplemental funding to achieve what we hope can be mutual and complementing goals.

Once again we thank you for considering our concerns and suggestions, as well as for all of the hard work that you do for us all.

For further information please contact James Raml, Gunflint Trail Scenic Byway Forestry Sub-Committee Chariperson, at: P.O. Box 64, Grand Marais, MN 55604; by phone at 218-388-0606 or 218-387-2620; or by email at delgado@boreal.org.

Friday, February 23, 2007

New Sales Tax Proposal

Commissioner _______________________________ introduced the following Resolution and moved its adoption:
RESOLUTION NO. ____
RESOLUTION RECOMMENDING SPECIAL LEGISLATION REGARDING RE-AUTHORIZATION OF COOK COUNTY’S 1% GENERAL SALES TAX AND AUTHORIZATION OF TOURISM-FOCUSED SALES TAXES
BE IT RESOLVED, by the Board of Commissioners of Cook County as follows:
SECTION 1. RECITALS.
COMMUNITY INFRASTRUCTURE
1.01. The current 1% general sales tax that is paying for capital improvements at Cook County’s North Shore Hospital and Care Center is expected to expire with the full funding of the intended improvements in place by late 2007.
1.02. Cook County has unique needs for additional community capital improvements and community development due to its extremely remote location on the northern border of Minnesota with no nearby infrastructure in an adjacent county for its residents to utilize.
1.03. Cook County’s large geographical area being the size of Rhode Island creates large burdens on the County government that is overly burdensome for its population of approximately 5,000 residents (and non-resident second homeowners) to shoulder.
1.04. The Board recognizes that a re-authorization of the 1% sales tax could be utilized to fund necessary community capital improvements and community development for the benefit of all Cook County residents.
SAFEGUARDING FINANCIAL VIABILITY OF COMMUNITY HOSPITAL
1.05. Due to an abnormality in the initial legislation authorizing the Cook County North Shore Hospital and Care Center (the "Hospital"), the Hospital is the only community hospital in the State with a cap (the "Levy Limit") on its ability to levy additional funds.
1.06. The Cook County Hospital District (the "District") has represented to the Board that, due to the nursing home reimbursement rates, nursing home revenues do not meet operating expenses, and as the tax levy is the available source of funds to cover such shortfall, the Levy Limit creates and will continue to create a problem for the District.
1.07. Recognizing that the Hospital may need to levy additional funds in order to offset present and projected nursing home operating deficits, and in order to help secure the economic viability of Hospital (and the availability of appropriate medical services) for the benefit of Cook County residents and visitors, the Board adopted a resolution on February 13, 2007 recommending that the enabling legislation that created the District be amended to authorize the District to levy taxes consistent with the requirements of the Hospital District Act but without the Levy Limit.
STABILIZING ECONOMY AND ECONOMIC WELL-BEING OF RESIDENTS
1.08. As evidenced in a study produced by the Cook County Economic Analysis Council (the "Council") and discussed throughout 2006 in a series of public meetings and other public forums:
Cook County’s economy is over 80% based upon tourism, and is the most tourism-dependent, by far, of any Minnesota county.
Most of the County’s tourism sales are generated by overnight lodging visitors, and lodging sales have remained stagnant (in constant dollars) since 1998.
Total monthly lodging sales from mid-October through mid-June are approximately 16% to 44% of peak summer levels, and total Cook County sales suffer the same seasonal imbalance, resulting in seasonal unemployment exceeding the State average and too few full time jobs with benefits.
From November through May, the County’s tourism economy depends primarily on visitation for winter recreational activities involving snow (such as skiing or snowmobiling), resulting in low economic activity prior to such snow-dependent recreational activities beginning and after such activities have ended, and making the entire economy uniquely vulnerable to poor-snow years.
With a majority of the County’s workforce employed in tourism and much of the rest of the workforce indirectly dependent on tourism sales, the wages, benefits and economic well-being of Cook County workers and residents are suffering due to the large fall-off in economic activity from mid-October through June.
1.09. Cook County does not have an event/visitors bureau that has enabled other communities in Minnesota (such as Duluth), as well as communities in other states that, like Cook County, depend heavily on tourism, to draw tourists based on a consistent, community-wide implementation of events, festivals and other cultural attractions.
1.10. About one-half of the 3% lodging taxes collected by the three tourism districts (Gunflint Trail Association, Grand Marais Area Tourism Association and Lutsen, Tofte Tourism Association) have been utilized for many years to pay for a County-owned golf course and have not been available for promotion.
1.11. The County’s three tourism associations have passed resolutions representing that:
the entire 3% lodging tax funds are needed to adequately promote tourism for the benefit of the County’s economy, and there is an immediate need to restore the portion of these lodging tax funds currently being utilized to pay for the County-owned golf course.
Neither the tourism businesses nor tourism associations have the resources to fund the events, festivals and cultural activities that are necessary to improve the County’s economy for the benefit of its workers and residents.
1.12. Other Minnesota communities (as well as communities in other states with tourism-dominated economies) collect higher lodging taxes (e.g. 5% to 7% for Duluth, St. Cloud, St. Paul and Bloomington), as well as taxes on other tourism/leisure-related sales such as restaurant/bar sales and recreation/entertainment sales (taxes up to 3% of such sales in Minnesota and higher in other states).
1.13. The County’s three tourism associations have passed resolutions of support for a new Cook County events/visitors bureau to be funded with a combination of an additional lodging tax and new tourism-targeted taxes on restaurant/bar sales and recreation/entertainment sales.
SECTION 2. RECOMMENDATIONS OF THE BOARD.
2.01. Re-Authorization of 1% General Sales Tax. The Board hereby recommends that the 1% sales tax currently being used to fund hospital infrastructure be re-authorized to fund future capital investments in community infrastructure and economic development, with (i) approximately $200,000/year being utilized for approximately four years to pay for the outstanding balance (or make the remaining payments) on the bonds for the County-owned Superior National golf course and (ii) the balance (estimated at approximately $900,000/year initially) being utilized for capital investments approved by the County Board in community infrastructure (such as a new pool, other recreational facilities or a County-wide shuttle bus system) or economic development.
2.02. 1/2/3/% Tourism Taxes for Event and Visitors Bureau. The Board hereby recommends authorization of three tourism-focused sales taxes: (i) a 1% lodging sales tax (comprised of ½% from the existing 3% lodging taxes and a new ½% additional lodging tax , (ii) a new 2% tax on bar/restaurant sales and (iii) a new 3% tax on recreation/entertainment sales (i.e., admissions to ski, golf and other recreation or entertainment facilities and rental of recreation equipment such as skis, canoes and kayaks), to fund a new Cook County Event and Visitors Bureau (CCEVB) that will primarily organize, operate and promote events and festivals during slower tourism periods of the year (currently mainly mid-October through June) to increase tourism visits during such periods for the benefit of economy and residents of Cook County. The Board hereby further recommends that such additional sales taxes (i.e. the new ½% lodging tax), the new 2% bar/restaurant tax and the new 3% recreation/entertainment tax) continue for an initial period of five (5) years and thereafter for successive five (5) year periods in the absence of a vote prior to the end of the fourth (4th) year by any of the three partner tourism associations to not support the continuation of such additional tourism taxes, in which case the taxes shall at the end of such fifth (5th) year and the ½% existing lodging taxes shall be restored for promotional uses by the respective partner tourism associations. Consistent with the resolutions adopted by the three tourism associations, the Board further recommends (i) that the CCEVB be governed by a Board of Directors consisting of thirteen (13) members, four (4) elected by the Grand Marais Area Tourism Association (GMATA), 2 elected by the Gunflint Trail Association (GTA) and seven (7) elected by the Lutsen Tofte Tourism Association (LTTA), such board representation representing the projected tax collections from each such tourism district, and one advisory member (nonvoting) elected by Grand Portage, and (ii) that all budgetary decisions or changes in the structure of the CCEVB require approval by a supermajority vote of at least nine (9) members of the CCEVB Board of Directors.
2.03. Transmission to Legislature. The Board hereby authorizes the Chair and the Clerk of the Board to transmit a copy of this Resolution to Cook County’s state legislators as well as to the House and Senate committees with jurisdictions or purview over sales taxes, tourism, or community or economic development.

Adopted: February ___, 2007


________________________________________
Chair

ATTEST:


_____________________________________
Clerk

Tuesday, May 23, 2006

Comments on USFS Devils Trout Management Plan

DATE: May 20, 2006
TO: Dennis Neitzke, District Ranger
United States Forest Service
Gunflint Ranger District
Grand Marais, MN 55604
FROM: Nancy Seaton, Chairperson

Gunflint Trail Scenic Byway Committee
Shari Baker, President
Gunflint Trail Association

RE: Comments on Devil Trout Preliminary Environmental Assessment
and aspects affecting the Gunflint Trail Scenic Byway

The comments that follow address the U.S. Forest Service proposed forest management activities outlined in the Devil Trout Project Preliminary Environmental Assessment that would affect the state designated Gunflint Trail Scenic Byway within the Superior National Forest.
We appreciate that the scenic byway status of the Gunflint Trail was acknowledged within the environmental assessment. We thank you for meeting with our committee and explaining the agency plans within the scenic byway corridor. If forest management activities within the viewshed of the scenic byway corridor are deemed necessary for forest health reasons, we tend to agree with the agencies general logic of conducting partial cuts coupled with the planting of longer-lived species such as pine. Upon further review of the plan, coupled with on-site inspections of the stands proposed for treatment, we feel that, with some adjustments, the forest service’s proposed action – alternative 2 – could complement our goals and desired future conditions for the scenic byway. With that in mind we have a number of comments, concerns and suggestions to respectfully offer.

The Gunflint Trail is a state sponsored scenic byway and a major tourism related resource within Cook County, Minnesota. Under the Cook County Land use plan this area is listed as an "extraordinary resource in North America". The scenic byway includes a buffer zone of one mile on each side of the road. Our committee is currently in the process of seeking national scenic byway status. As a requirement to obtaining national status an initial corridor management plan was developed and adopted in June of 2005. Another requirement for national designation is that certain intrinsic qualities be demonstrated. Among these intrinsic qualities are natural and scenic qualities. Natural qualities are defined within the plan as those that apply to "those features in the visual environment that are in a relatively undisturbed state". It is further stated that these features predate the arrival of human populations and that "there may be evidence of human activity, but the natural features reveal minimal disturbances". The intrinsic scenic quality must include characteristics of the landscape that are "strikingly distinct and offer a pleasing and most memorable visual experience." It is also stated that, among other elements of the landscape, vegetation must "contribute to the quality of the corridor’s visual environment".

The scenic byway committee has recently formed a forestry subcommittee to deal with the natural vegetation intrinsic quality of the Gunflint Trail. We are beginning the process of developing a comprehensive vegetation management plan. There is a consensus that the existing unbroken older forest characteristics along the byway be maintained wherever possible. There is agreement that within-stand age class and species diversity adds to the scenic quality of the road. Also recognized is the need to maintain and increase the amount of longer lived species such as red and white pine, white cedar, white spruce and northern hardwoods such as maple and yellow birch where appropriate.

We are concerned with the cumulative impact of natural and human disturbance on the formerly unbroken older forest characteristic of the scenic byway. Under the proposed plan forest management activities would be conducted on 26 stands within the scenic byway corridor. Seven of these treatments would be directly adjacent to the road. All of these activities would be conducted within a six-mile stretch of the scenic byway. As you know, the 1999 windstorm and the ensuing salvage logging and prescribed fires have left much of the upper half of the scenic byway fragmented with large areas in a much younger age class. When one couples this with proposed Minnesota DNR management activities and previous resource agency activities conducted over the past 10 years, the current proposed activities could, if not conducted with extraordinary consideration to aesthetic values, diminish our stated visual quality goals necessary for national scenic byway designation. Under the proposed action there would be timber management activities within 20 stands within the corridors buffer zone.
This area is typed as birch-aspen-spruce-fir. However, it once contained a much greater component of white pine. Much of that had been logged in previous years and either allowed to regenerate to the current typing or converted to red pine or white spruce or aspen monocultures. There is still a fairly large component of white pine intermingled throughout this planning area.

While the current proposal appears to take many of our concerns into consideration we offer the following general as well as site specific suggestions and requests.
There should be no clearcutting within the viewshed of the road. We feel that any cutting done within the viewshed of the roadway should be partial cuts targeting specific species, such as decadent aspen or dead and dying balsam fir or birch. The objective should be to open the canopy or thin the stand only enough to allow the natural and artificial regeneration of longer lived species such as white pine. The majority of the existing conifer component, whether advanced regeneration or mature, should be retained with the exception of thinning conifers such as balsam fir where they have formed thickets hindering growth rate or planned regeneration. All white pine, white cedar and white spruce should be retained. Wherever soils permit, replanting should be conducted without rock racking. Any mechanical site prep should be done so as not to damage the roots of leave trees. Any new access routes should discreet and revegetated with tree cover.

Any white pine planting needs to have regular follow up and treatment to deal with deer browse, blister rust, tip weevil and white pine aphid as well as suppressive vegetative competition. We request that the majority of the white pine acreage be budgeted for these follow-up activities and not just the 30 percent called for in the current plan. All research indicates that this will need to be done for the long term. We would like to see these follow ups budgeted for and that any white pine plantings maintain a adequate stocking rate over the long term to eventually make a substantial difference to the visual quality of the scenic byway. We ask that these plantings not be certified in the fifth year as proposed but be monitored for at least 10 years to insure an adequate stocking. As is often stated by Jack Rajala of Rajala Lumber Company, white pine is not a species that can be planted and forgotten. This general philosophy is expressed in publications by the Minnesota DNR as well as corroborated by most research.
Of major concern is the planned clearcutting of stand number 5 in compartment number 148. This 100 acre clear-cut would extend for over three-quarters of a mile from FR1310 northward and involves the headwaters of timber creek. The current plan is to clear-cut all merchantable timber with the exception of 6 to 12 leave trees per acre as well as 5 percent as legacy patches. From the road this stand does not appear to be in an advanced state of decline, as are some stands further south. Instead, this stand, especially those portions towards the north, appears healthy and contributes a positive visual aspect to the road. There is a fair amount of mid and older aged white pine throughout the stand within the viewshed as well as other healthy conifers. We would ask that you reconsider this cut by considering a variable thinning or partial species cut in that portion of the stand viewable from the road. We ask that you leave all viable conifers, especially white pine, throughout the stand and that you consider planting white pine in those areas viewable from the road in addition to the planned planting on the 30 acres to the SW portion of the stand. The current prescription states that the Regeneration Forest Type would be even-aged aspen. While even-aged monocultures of young aspen are appropriate for some areas they tend to have an industrial forest characteristic which would negatively impact the visual quality of the scenic byway.

Stand number 3 in compartment 191 is slated for a standard clear-cut and is to be regenerated into a monoculture of even aged aspen. We ask that more of the conifer component, including all white pine, be reserved and consider a partial cut in those areas viewable from the road.
Stand numbers 55 and 61 in compartment 190 appear to abut one another.
We agree with the prescription of stand 55 but request that in stand 61 there be enough conifer component retained to add diversity to the stand as it regenerates.
In stand 45 in compartment 190 and stand 4 in compartment 198 it would be nice to see a higher basal area than 30 percent left. With the advanced age of these stands if the basal area is reduced too much there is a high probability of the remaining trees dying prematurely of moisture stress and wind throw. Should this occur, the shelter they would provide the regenerating white pine would be lost. This should actually be considered in all partial aspen cuts. Stand 4 in compartment 198 is next to the "Pines" and it is nice to see you attempt to increase white pine in this area. This stand already appears to have a basal area approaching 50-70 percent, which should be adequate for white pine regeneration.

In stand number 10 in compartment 200 it would be nice to see the partial cut set up as variable instead of just 30 percent. The aspen in this stand is younger and it would be nice to see a higher basal area left along the road if possible.

Stand 42 in compartment 206 and stand 22 in compartment 200 together comprise what is known as the "George Washington Pines". Stand 42 was thinned a few years back by using horses. We understand the objective of reducing fuels loads within these stands, including balsam fir ladder fuels. We do hope that this will be done in a way to achieve an aesthetically pleasing result by allowing a portion of the under-story to remain while under-planting white pine. In stand 22 we suggest that any fuels reduction project be conducted without the use of heavy equipment, as this is an area of high scenic, historic, cultural and recreational value. The ski trails that run through this stand are also used as birding trails in summer. Even a relatively small amount of understory increases the bird species count. These two units should be treated as one and with a light hand.

As for cutting not directly along the road, but within the one-mile buffer zone of the corridor all of our initial general comments would apply. Stand number 19 in compartment 198, currently typed as a birch, is proposed to be clear-cut and converted to a white spruce plantation. Being that this stand is within the buffer of the corridor we suggest leaving a higher component of leave trees including all pine, cedar and some healthy birch throughout the stand for diversity. White spruce is relatively shade tolerant and should do fine with more leave trees. We also hope that stands 25 and 23 would respect the Shipstead-Newton-Nolan federal law as the Brule River is navigable water and is a high value recreation resource within the scenic byway corridor.

Please understand that we are not against logging within the corridor for forest health reasons. When logging must take place for such reasons it does provide a number of tangible and positive economic factors such as jobs and revenue. However, the outcome of any activities within the scenic corridor should be to maintain or create natural appearing forests with a high degree of within-stand age class and species diversity while increasing the future component of longer lived species as opposed to the creation of monocultures of even aged aspen or conifer plantations.

While we realize that some of our suggestions would most likely increase the cost of forest management activities. We feel this is justified by the nature of the area being such a high value tourism resource as well as a state designated and federal candidate scenic byway. We are more than willing to do whatever is in our ability; whether through offering voluntary help or assisting in locating alternative supplemental funding as examples, to achieve what we hope can be mutual and complementing goals.

Once again we thank you for considering our concerns and suggestions, as well as for all of the hard work that you do for us all.
DATE: May 20, 2006
TO: Dennis Neitzke, District Ranger
United States Forest Service
Gunflint Ranger District
Grand Marais, MN 55604
FROM: Nancy Seaton, Chairperson

Gunflint Trail Scenic Byway Committee
Shari Baker, President
Gunflint Trail Association

RE: Comments on Devil Trout Preliminary Environmental Assessment
and aspects affecting the Gunflint Trail Scenic Byway

The comments that follow address the U.S. Forest Service proposed forest management activities outlined in the Devil Trout Project Preliminary Environmental Assessment that would affect the state designated Gunflint Trail Scenic Byway within the Superior National Forest.
We appreciate that the scenic byway status of the Gunflint Trail was acknowledged within the environmental assessment. We thank you for meeting with our committee and explaining the agency plans within the scenic byway corridor. If forest management activities within the viewshed of the scenic byway corridor are deemed necessary for forest health reasons, we tend to agree with the agencies general logic of conducting partial cuts coupled with the planting of longer-lived species such as pine. Upon further review of the plan, coupled with on-site inspections of the stands proposed for treatment, we feel that, with some adjustments, the forest service’s proposed action – alternative 2 – could complement our goals and desired future conditions for the scenic byway. With that in mind we have a number of comments, concerns and suggestions to respectfully offer.

The Gunflint Trail is a state sponsored scenic byway and a major tourism related resource within Cook County, Minnesota. Under the Cook County Land use plan this area is listed as an "extraordinary resource in North America". The scenic byway includes a buffer zone of one mile on each side of the road. Our committee is currently in the process of seeking national scenic byway status. As a requirement to obtaining national status an initial corridor management plan was developed and adopted in June of 2005. Another requirement for national designation is that certain intrinsic qualities be demonstrated. Among these intrinsic qualities are natural and scenic qualities. Natural qualities are defined within the plan as those that apply to "those features in the visual environment that are in a relatively undisturbed state". It is further stated that these features predate the arrival of human populations and that "there may be evidence of human activity, but the natural features reveal minimal disturbances". The intrinsic scenic quality must include characteristics of the landscape that are "strikingly distinct and offer a pleasing and most memorable visual experience." It is also stated that, among other elements of the landscape, vegetation must "contribute to the quality of the corridor’s visual environment".

The scenic byway committee has recently formed a forestry subcommittee to deal with the natural vegetation intrinsic quality of the Gunflint Trail. We are beginning the process of developing a comprehensive vegetation management plan. There is a consensus that the existing unbroken older forest characteristics along the byway be maintained wherever possible. There is agreement that within-stand age class and species diversity adds to the scenic quality of the road. Also recognized is the need to maintain and increase the amount of longer lived species such as red and white pine, white cedar, white spruce and northern hardwoods such as maple and yellow birch where appropriate.

We are concerned with the cumulative impact of natural and human disturbance on the formerly unbroken older forest characteristic of the scenic byway. Under the proposed plan forest management activities would be conducted on 26 stands within the scenic byway corridor. Seven of these treatments would be directly adjacent to the road. All of these activities would be conducted within a six-mile stretch of the scenic byway. As you know, the 1999 windstorm and the ensuing salvage logging and prescribed fires have left much of the upper half of the scenic byway fragmented with large areas in a much younger age class. When one couples this with proposed Minnesota DNR management activities and previous resource agency activities conducted over the past 10 years, the current proposed activities could, if not conducted with extraordinary consideration to aesthetic values, diminish our stated visual quality goals necessary for national scenic byway designation. Under the proposed action there would be timber management activities within 20 stands within the corridors buffer zone.
This area is typed as birch-aspen-spruce-fir. However, it once contained a much greater component of white pine. Much of that had been logged in previous years and either allowed to regenerate to the current typing or converted to red pine or white spruce or aspen monocultures. There is still a fairly large component of white pine intermingled throughout this planning area.

While the current proposal appears to take many of our concerns into consideration we offer the following general as well as site specific suggestions and requests.
There should be no clearcutting within the viewshed of the road. We feel that any cutting done within the viewshed of the roadway should be partial cuts targeting specific species, such as decadent aspen or dead and dying balsam fir or birch. The objective should be to open the canopy or thin the stand only enough to allow the natural and artificial regeneration of longer lived species such as white pine. The majority of the existing conifer component, whether advanced regeneration or mature, should be retained with the exception of thinning conifers such as balsam fir where they have formed thickets hindering growth rate or planned regeneration. All white pine, white cedar and white spruce should be retained. Wherever soils permit, replanting should be conducted without rock racking. Any mechanical site prep should be done so as not to damage the roots of leave trees. Any new access routes should discreet and revegetated with tree cover.

Any white pine planting needs to have regular follow up and treatment to deal with deer browse, blister rust, tip weevil and white pine aphid as well as suppressive vegetative competition. We request that the majority of the white pine acreage be budgeted for these follow-up activities and not just the 30 percent called for in the current plan. All research indicates that this will need to be done for the long term. We would like to see these follow ups budgeted for and that any white pine plantings maintain a adequate stocking rate over the long term to eventually make a substantial difference to the visual quality of the scenic byway. We ask that these plantings not be certified in the fifth year as proposed but be monitored for at least 10 years to insure an adequate stocking. As is often stated by Jack Rajala of Rajala Lumber Company, white pine is not a species that can be planted and forgotten. This general philosophy is expressed in publications by the Minnesota DNR as well as corroborated by most research.
Of major concern is the planned clearcutting of stand number 5 in compartment number 148. This 100 acre clear-cut would extend for over three-quarters of a mile from FR1310 northward and involves the headwaters of timber creek. The current plan is to clear-cut all merchantable timber with the exception of 6 to 12 leave trees per acre as well as 5 percent as legacy patches. From the road this stand does not appear to be in an advanced state of decline, as are some stands further south. Instead, this stand, especially those portions towards the north, appears healthy and contributes a positive visual aspect to the road. There is a fair amount of mid and older aged white pine throughout the stand within the viewshed as well as other healthy conifers. We would ask that you reconsider this cut by considering a variable thinning or partial species cut in that portion of the stand viewable from the road. We ask that you leave all viable conifers, especially white pine, throughout the stand and that you consider planting white pine in those areas viewable from the road in addition to the planned planting on the 30 acres to the SW portion of the stand. The current prescription states that the Regeneration Forest Type would be even-aged aspen. While even-aged monocultures of young aspen are appropriate for some areas they tend to have an industrial forest characteristic which would negatively impact the visual quality of the scenic byway.

Stand number 3 in compartment 191 is slated for a standard clear-cut and is to be regenerated into a monoculture of even aged aspen. We ask that more of the conifer component, including all white pine, be reserved and consider a partial cut in those areas viewable from the road.
Stand numbers 55 and 61 in compartment 190 appear to abut one another.
We agree with the prescription of stand 55 but request that in stand 61 there be enough conifer component retained to add diversity to the stand as it regenerates.
In stand 45 in compartment 190 and stand 4 in compartment 198 it would be nice to see a higher basal area than 30 percent left. With the advanced age of these stands if the basal area is reduced too much there is a high probability of the remaining trees dying prematurely of moisture stress and wind throw. Should this occur, the shelter they would provide the regenerating white pine would be lost. This should actually be considered in all partial aspen cuts. Stand 4 in compartment 198 is next to the "Pines" and it is nice to see you attempt to increase white pine in this area. This stand already appears to have a basal area approaching 50-70 percent, which should be adequate for white pine regeneration.

In stand number 10 in compartment 200 it would be nice to see the partial cut set up as variable instead of just 30 percent. The aspen in this stand is younger and it would be nice to see a higher basal area left along the road if possible.

Stand 42 in compartment 206 and stand 22 in compartment 200 together comprise what is known as the "George Washington Pines". Stand 42 was thinned a few years back by using horses. We understand the objective of reducing fuels loads within these stands, including balsam fir ladder fuels. We do hope that this will be done in a way to achieve an aesthetically pleasing result by allowing a portion of the under-story to remain while under-planting white pine. In stand 22 we suggest that any fuels reduction project be conducted without the use of heavy equipment, as this is an area of high scenic, historic, cultural and recreational value. The ski trails that run through this stand are also used as birding trails in summer. Even a relatively small amount of understory increases the bird species count. These two units should be treated as one and with a light hand.

As for cutting not directly along the road, but within the one-mile buffer zone of the corridor all of our initial general comments would apply. Stand number 19 in compartment 198, currently typed as a birch, is proposed to be clear-cut and converted to a white spruce plantation. Being that this stand is within the buffer of the corridor we suggest leaving a higher component of leave trees including all pine, cedar and some healthy birch throughout the stand for diversity. White spruce is relatively shade tolerant and should do fine with more leave trees. We also hope that stands 25 and 23 would respect the Shipstead-Newton-Nolan federal law as the Brule River is navigable water and is a high value recreation resource within the scenic byway corridor.

Please understand that we are not against logging within the corridor for forest health reasons. When logging must take place for such reasons it does provide a number of tangible and positive economic factors such as jobs and revenue. However, the outcome of any activities within the scenic corridor should be to maintain or create natural appearing forests with a high degree of within-stand age class and species diversity while increasing the future component of longer lived species as opposed to the creation of monocultures of even aged aspen or conifer plantations.

While we realize that some of our suggestions would most likely increase the cost of forest management activities. We feel this is justified by the nature of the area being such a high value tourism resource as well as a state designated and federal candidate scenic byway. We are more than willing to do whatever is in our ability; whether through offering voluntary help or assisting in locating alternative supplemental funding as examples, to achieve what we hope can be mutual and complementing goals.

Once again we thank you for considering our concerns and suggestions, as well as for all of the hard work that you do for us all.

Thursday, May 18, 2006

Comments to DNR on Clear Cut

TO: Paul Dubuque DATE: May 16, 2006
Minnesota DNR-Two Harbors
1568 Highway 2
Two Harbors, MN 5561
Email- Paul.Dubuque@state.mn.us

FROM: Nancy Seaton, Chairperson
Gunflint Scenic Byways Committee

Shari Baker, President
Gunflint Trail Association

RE: Comments on 2006-2007 DNR timber sales along the
Gunflint Trail Scenic Byway


The comments that follow deal with proposed fiscal year 2006 timber sales and fiscal year 2007 stand examinations developed through the Two Harbors area office that would affect the designated Gunflint Trail Scenic Byway within the Pat Bayle State Forest.

The Gunflint Trail is a state sponsored scenic byway and is one of the major tourism related resources within Cook County Minnesota. Under the Cook County Land use plan this area is listed as an "extraordinary resource in North America". The areas directly covered by the scenic byway designation include one mile on each side of the road. The Minnesota Department of Natural Resources also classifies the Gunflint Trail as having the highest level of sensitivity under its Visual Guidelines Classification System, which was adopted and incorporated into its site level guidelines. There is also a state memorandum of understanding between the Minnesota Department of Transportation and the Minnesota Department of Natural Resources concerning State sponsored scenic byways.

There are two proposed fiscal year 2006 sales within the scenic byway corridor that involve cutting up to and right along the road edge. These cuts are in two different sections (section 4 and 16) of Township 63 Range 1 East. There are seven cutting blocks within five stands. The stands in question are numbers 16 and 29 in section 4 and 124, 125 and 138 in section 16. The proposal calls for clearcutting all merchantable timber with the exception of the standard reserve of six to twelve aspen per acre and no cutting of white pine, white cedar and tamarack. While less than 40 acres are involved in these planned clearcuts, they would affect more than three-quarters of a mile of the scenic corridor immediately adjacent to the road.

Stands 16 and 29 are typed as upland blackspruce and are immediately adjacent to one another on each side of the road. Stand 127 is typed as jack pine and involves three blocks within the stand on the east side of the road. Stand 125 is typed as aspen and is adjacent to and across the road from the northern portion of Stand 127. Stand 138 is typed as lowland black spruce and is adjacent to and across the road from the middle portion of stand 127.

Our concerns deal with the immediate as well as the long-term visual quality along this State Sponsored Scenic Byway. By setting these units up as standard clearcuts with minimal reserves it would appear that the main consideration providing justification for these sales were economic without adequate consideration to the visual quality of a state sponsored scenic byway.

We recognize that portions of these stands are composed of older forest types consisting of relatively short-lived species. We also realize that some type of forest management may eventually be needed for ecological reasons dealing with forest health, as well as long term visual quality. We are, however, concerned about the cumulative impact on the older forest character and immediate impact on visual quality that these sales, as proposed, would render onto the scenic byway.

Concerning cumulative impact we would like to make known that much of the upper 30 miles of the roughly 56 mile Gunflint Trail Scenic Byway was heavily impacted by the 1999 windstorm. When this is combined with the salvage logging and prescribed fires initiated after the storm much of the upper trail has lost its older forest characteristic and is now in a much younger age class. The more southerly portion of the trail still maintains most of its unbroken older forest characteristics. However when one combines the activities now in question with the proposed timber management activities contained within the US Forest Service’s "Devil Trout" Environmental Assessment, much of the older forest characteristics will be lost along this portion of the Gunflint Trail.

As the committee responsible for the Gunflint Trail Scenic Byway, we would like to see that vegetative management activities conducted along the corridor provide for ecological heath and natural appearing forests, while maintaining an appearance of unbroken older forest wherever possible. If timber management practices are deemed necessary for forest health or long term visual quality we would like to see them conducted with the goal of maintaining or creating within-stand age class and species diversity, while adding a higher component of longer lived species such as red and white pine and white cedar wherever appropriate or possible.
We request that these sales be withdrawn and reanalyzed by giving equal weight to aesthetic considerations that seem to have been given to the economic considerations of sale feasibility (dealing with appropriate amount of merchantable timber to make a sale attractive to bidders) and the DNR’s fiduciary responsibility to the state’s school trust fund.

We visited each site and what follows below are our site-specific concerns as well a few suggestions for your consideration.

Upon a close examination it would appear that some of these sites might possibly be mistyped. It is also difficult to apply, as written, the site level visual guidelines to these sites due to the nature of the guidelines being aimed at cutting back from roads and not right up to them. All of these cuts abut the road.

Stand number 16 which is typed as an upland black spruce stand appears to be a mixed pine stand of jack, white and red pine with some black spruce. Behind this stand is a very recently cut stand regenerating into mixed pine and spruce. Stand number 29, which is also typed as upland black spruce, appears to be a relatively healthy jack pine stand with a thick understory of balsam fir and young and suppressed mid-aged black spruce. Both of these stands are within the area with the most extensive white pine stands left along the scenic corridor. If one were to use the visual guideline of staggering cuts to soften the overall effect in the scenic corridor these two sites would likely be candidates to extend their rotation age and defer cutting until a later date.

Stand number 125 is a decadent aspen stand with a mid and understory of black spruce and balsam fir. Behind it is a young stand of even aged aspen and behind that is a hillside of older white pine. There is sound ecological reasoning for this cut, however, it would be preferable if more of the conifer advanced regeneration were reserved and white pine and white spruce were inter-planted afterwards in order to increase the amount of longer lived species. If clear-cut, this stand most probably would become an even-aged aspen stand reducing visual quality.

Stand number 124, which is typed as jack pine, is divided into three cutting blocks. The northern and middle units are very mixed forests with much age- class and species diversity. The northern unit abuts cedar to the north and red pine to the south. There is some nice mixed younger jack pine, red pine, and black spruce tight to the road in portions that should be left if the unit is to be cut. The middle unit abuts red pine to the north and a nearly completely dead tamarack stand to the south. The dead tamarack stand not included is what really needs to be cut and regenerated. There is a stream running through the southern portion of the unit. The southern unit of this stand is breaking up with very little quality-advanced regeneration. There is sound ecological reasoning for cutting the southern portion of this stand though it would be nice to see it replanted into mixed pine and spruce.

Stand number 138, which is typed as lowland black spruce, appears to be a mixed stand of aspen, black spruce, balsam fir and brush. There is a stream running through this stand, which abuts an older black spruce-tamarack stand. There is sound ecological reasoning for this cut. However, we would like to see more of the spruce and fir advanced regeneration retained on site and that there be some planting of white cedar as well as tamarack added to the prescription of reseeding of black spruce.

In general, while we are concerned with clear cutting within the scenic corridor, especially right up to the road, we do see relatively sound ecological and visual quality reasoning for some type of stand improvement activities in stand numbers 125, 138 and the southern portion of 124. However, we feel that there should be a better stand specific prescription for reserve trees (of diverse species) and retention of advanced regeneration. We acknowledge that the current prescription calls for leaving all white pine, white cedar and tamarack. The problem is there are few of these trees on the sites and in some of the sites there are no examples of these species. The same goes for the prescription of 6 to 12 aspen leave trees. Some of these sites do not have close to 6 aspen per acre. It is stated that all black spruce will be cut including all advanced regeneration to control mistletoe infestations and yet we see no evidence of mistletoe in these sites.

We also would ask that the prescription of natural regeneration be reconsidered and that a combination of natural and artificial regeneration be considered. We would suggest the inter and underplanting of red and white pine be undertaken where appropriate and possible without conducting the site preparation activity of rock raking. The goal should be to soften the visual effect of these cuts while maintaining age class and species diversity across the sites and adding longer lived pine species.

We feel that stand numbers 16, 29, and the northern and middle portions of stand number 124 should either be withdrawn and reserved until a later date by extending the rotation age or re-evaluated in order to leave a much more diverse and higher quantity of leave trees and advanced regeneration while providing for the planting of longer lived pine.

Concerning fiscal year 2007, we have identified two units that would affect the scenic corridor. The units are stand numbers 13 and 19 in township 64 range 1 west. These stands appear to include blown down aspen that is already regenerating into mixed spruce-fir-birch-aspen. If any management activities occur on these sites, or any others we have missed within the corridor, we request that all of our general comments apply to them as well. We hope that this would apply to any future timber management activities.

We acknowledge the state’s fiduciary responsibility to the school trust fund, as well as the need to eventually conduct well thought out vegetative management activities for forest health within the scenic byway corridor. However, we feel it is inappropriate to conduct clearcutting along the scenic byway and any management activities along and within the scenic byway corridor should meet a higher level of visual and aesthetic considerations.

We offer these suggestions and requests with utmost respect and thank you for your timely consideration. As these sales are scheduled for auction in June we would request and hope that you could respond before June.

For further information please feel free to contact: James Raml, Gunflint Trail Scenic Byway Forestry Committee, at 388-0606 or 387-2620 or by email at delgado@boreal.org.