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 Since that time the original environmental assessment and final decision was released and then withdrawn and replaced with the current Devil Trout Project Environmental Assessment.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

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