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

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

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