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.
Tuesday, May 23, 2006
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.
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.
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.
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