Make Your Voice Heard on the Nantahala-Pisgah Forest Management Plan
Comment Deadline: June 29
This public comment period is our last significant opportunity to win better protections and influence how our public lands are managed for the next 15-20 years.
Submit your comments through the Forest Service Portal
or Mail (postmarked by 6/29) to:
ATTN: Plan Revision Team
National Forests in North Carolina
160 Zillicoa St, Suite A
Asheville NC 28801
Tips for Commenting
Fill out the form on the right to submit your public comment. The most effective public comments are substantive, specific and unique. Here are some tips for effective letter writing. Below, we’ve provided detailed analysis of the draft plan and recommendations for your reference.
The most effective public comments are unique and personal. Though we’ve provided sample text in the form, we encourage you to customize it or, better yet, replace it with your own letter.
Reference specific geographic locations and issues in the Forest Plan.
The most effective comments will offer solutions to any issues raised.
Comment as often as you like
There is no limit to the number of times you can comment on the draft plan.
Save your work
We encourage you to compose your letter in your favorite word processing software and to save a copy. Should you experience a disruption to your internet service, you won’t lose all your work.
MountainTrue’s Analysis of the Draft Forest Plan
This is one of the first forest management plans to be drafted under new planning rules that were finalized in 2012, which require all management of National Forest lands to:
- Maintain or increase the ecological integrity of the lands and waters under Forest Service control;
- Provide analysis for climate change impacts and adaptation strategies;
- Include strategies for supporting local economies;
- Make decisions in the context of the broader landscape using an “all lands approach”;
- Include a strong emphasis on collaboration, among other values.
Below, we offer our interpretation of the Draft Forest Plan. We are not able to summarize the entire plan at this time, but we’ve highlighted some of the most important points. We will add to this document as we continue to form our opinions about the draft plan.
Read our issue-specific analysis and sample comment letters here:
The Forest Service’s Need for Change Document and the Draft Environmental Impact Statement document some of the key issues facing the ecosystems of Nantahala and Pisgah, including lack of young forest habitat relative to the optimum natural range, lack of open canopy woodlands of all ages due to fire exclusion, and lack of old-growth forests. Other key issues facing the forest include increasing public use while funding is decreasing, climate change and severe weather events, providing clean and abundant water, wildlife habitat, and expanding pressures from non-native invasive plants, pests, and pathogens. Critical to MountainTrue’s efforts to champion resilient forests, we continue to push for the protection of existing old-growth forests, North Carolina Natural Heritage Natural Areas, and areas that qualified for the potential wilderness inventory during this planning process.
Old-Growth Forests are rare due to historical overexploitation of forests. Some forests escaped logging because they were hard to access, or due to other factors. Since 1994, portions of the Nantahala-Pisgah have been placed into Designated Old-Growth patches for either maintenance or restoration of old-growth forest.
Less than 1% of forests in the Eastern U.S. are believed to be in old-growth condition, but in the Blue Ridge Mountains, up to 3% may be existing old growth. Approximately 9% of Nantahala and Pisgah National Forests is known to be in old-growth condition thanks to decades of field work by the Western North Carolina Alliance, the Wilderness Society, the Southern Appalachian Forests Coalition, and MountainTrue; however, not all of these rare forests are currently protected. Notably, Alternative C in the Draft Plan protects all of the documented existing old growth in designated old-growth patches.
Existing old-growth forests should all be placed in designated old-growth patches at a minimum, and exemplary areas should be considered for Special Interest Area or Research Natural Area management. There also need to be clear plan directions that Forest Service staff can use to identify old-growth forests and protect them from logging during timber management projects.
North Carolina Natural Heritage Program Natural Areas
North Carolina Natural Heritage Program Natural Areas were identified by biologists with the North Carolina Natural Heritage Program, and contain the best examples of natural communities, species diversity, and rare species in North Carolina. Natural Areas are ranked based on their scores for diversity and uniqueness at five levels: Exceptional, Very High, High, Moderate, and General. Natural Areas represent the best examples of ecosystems and biological diversity in our landscape. These are the types of places that should be considered “unsuitable” for timber production, but should have targeted management to restore, maintain, and enhance their natural qualities.
NC Natural Heritage Program Natural Areas should be placed in management areas where they will not be used for timber production. Instead, these areas should be managed to restore, maintain, and enhance their natural beauty.
Wilderness Inventory Areas
Wilderness Inventory Areas (WIAS) comprise the wildest and most remote places in Nantahala and Pisgah and, by extension, some of the wildest places in the East. WIAS were identified during this planning process because they were large (generally greater than 4,000 acres) and had very few roads. Smaller WIAs are adjacent to existing Wilderness Areas and comprise part of a larger wild landscape.
About 350,000 acres of WIAs were identified in the planning process, which is a testament to the ruggedness of the Blue Ridge Mountains and the wild character of the Nantahala and Pisgah. In the draft plan, the maximum amount of Recommended Wilderness identified from the WIAs is 126,000 acres. The remaining areas are allocated differently in the three Alternatives. To maintain their wild and remote character, WIAs should be placed in Management Areas that are “unsuitable” for timber production, and road construction should be limited.
Wilderness Inventory Areas should be placed in Management Areas that are “unsuitable” for timber production, and road construction should be limited in order to maintain their wild and remote character.
Roads are important for accessing and managing the forest. There are more than 2,200 miles of Forest Service System Roads on the Nantahala-Pisgah. Unfortunately, the Nantahala and Pisgah have over $40 million in deferred maintenance of their road system. The lack of maintenance funding from Congress is leading to erosion and water quality damage, and more roads being gated to motorized use.
Open roads are the primary method people use to enjoy the forest, and the more numerous gated roads are important for forest management. In the absence of more funding and resources, some roads will need to be decommissioned. The Forest Service should prioritize decommissioning roads that are not needed and maintaining roads that are important for public access.
The Forest Service needs to “right-size” its road network unless more funding and resources are made available. Roads that are important for public access must be properly maintained, and those that are not needed should be decommissioned.
Recreation is the most socially and economically important use of the Nantahala and Pisgah. More than 10 million visitors enjoy these forests every year, and for every possible pastime.
Unfortunately, money is as thin for recreation as it is for other uses. The majority of trail maintenance these days is performed by volunteer groups. There is huge demand for new trails and facilities, but barely enough funding to maintain what already exists. The Forest Plan has “Tiered Objectives” that could help expand trails and facilities if more resources become available. The upper end of these tiered objectives should be within the realm of possibility and provide an aspirational goal to reach for.
The Forest Plan should include potential increases in trails and other recreation infrastructure under Tier 2 management.
The Nantahala and Pisgah are the headwaters of seven major river systems. They provide drinking water for millions, provide fish and wildlife habitat for a bewildering array of native species, and get an abundance of rainfall. Unfortunately, the draft plan proposes less protection for the waterways of the Nantahala and Pisgah than other Southern Appalachian National Forests such as the Chattahoochee, the Cherokee, and the Jefferson. The draft plan for the Nantahala and Pisgah includes a 100-foot buffer on perennial streams, only a 15-foot buffer on intermittent streams, and no buffer on ephemeral streams. These buffers are the exclusion zones for heavy equipment during timber harvest. By keeping heavy equipment out of these zones and leaving a tree canopy, water quality is preserved and habitat for aquatic species is maintained.
In contrast to the Nantahala and Pisgah, the Cherokee National Forest in Tennessee has a default riparian buffer of 100 feet on perennial streams and 50 feet on intermittent streams, and buffers can be increased up to 264 feet depending on slopes. Cherokee National Forest gives ephemeral streams a 25-foot buffer of protection.
Water quality protections for the Nantahala and Pisgah should meet or exceed the water quality protections given for other Southern Appalachian National Forests — a riparian buffer of 100 feet on perennial streams, 50 feet on intermittent streams and 25 feet on ephemeral streams — that is protected from from road building, skid trails, log loading areas, waste disposal and other ground disturbing activities.
The Forest Service has emphasized wildlife habitat for years – specifically young forest (early successional) wildlife habitat. This is because a suite of game and non-game species benefit from this habitat type, and many of those species are declining. The Nantahala and Pisgah also has a diverse array of plants and wildlife that specialize on mature and old-growth forests, and in contrast to those that depend on young forest, many of these species are only found in the Southern Blue Ridge.
Young forest species have generally evolved to walk or fly long distances to colonize new habitat. As a result, most young forest habitat species can live in a large swath of North America. In contrast, look at the Carolina northern flying squirrel, the only restricted endemic mammal known to our region. This little critter is restricted to high elevation forests, and studies have shown that it has been severely impacted by historical logging. It is so sensitive to forest fragmentation that it has been documented refusing to cross two-lane roads. Smaller critters like salamanders and snails are even more sensitive to fragmentation.
There is certainly room for more creation of young forest habitat on the Nantahala and Pisgah. The key to doing so without harming the unique values of that Nantahala-Pisgah is to place old-growth forests, Natural Heritage Natural Areas, and Wilderness Inventory Areas into management areas that are “unsuitable” for timber production, and to add Standards and Guides to the plan that ensure their protection.
In some cases, young forest wildlife species and older forest wildlife species can share the same habitat. This often occurs in open woodlands, which have scattered, large trees, but do not have a completely closed canopy. Historical accounts and ecological models indicate that open woodlands were once an important habitat type in pine and oak forests of the Southern Blue Ridge, but they are now few and far between. The draft plan proposes creating and maintaining a maximum 6,000 acres of woodland habitat over the life of the plan, even though the DEIS shows that hundreds of thousands of acres are needed for the ecosystem to thrive.
The final forest plan should place old-growth forests, Natural Heritage Natural Areas, and Wilderness Inventory Areas into management areas that are “unsuitable” for timber production and to add Standards and Guides to the plan that ensure their protection. It should also create more acres of woodland habitat.
Timber harvest levels in the draft plan are similar to the current forest plan, but in keeping with the 2012 planning rule, the rationale for timber harvest is more ecologically-based. Every plan alternative in the draft plan includes more commercially-viable and accessible timber in “suitable” Management Areas than in the current forest plan.
In order for more timber harvest to be socially and ecologically sustainable, the question of “where” is more important than “how much”. The Forest Service must effectively protect old-growth forests, Natural Heritage Natural Areas, and Wilderness Inventory Areas in “unsuitable” Management Areas. The agency must also include Standards and Guides that carefully direct management of these resources for the benefit of their outstanding qualities.
The plan must also have strong protections for soil and water affected by timber harvest. We recommend that the Forest Service require specialized logging equipment on slopes greater than 40% to guard against erosion and landslides. Steep slope equipment should be at least as protective of soil as skyline-cable systems. Additionally, the Forest Service should require that skid roads and temporary roads constructed during timber harvest be obliterated and returned to grade. Finally, the Forest Service should, whenever possible, design and size timber sales to favor local operators and mills.
The Forest Service should require specialized logging equipment on slopes greater than 40% to guard against erosion and landslides, and require that skid roads and temporary roads constructed during timber harvest be obliterated and returned to grade when the project is done. The Forest Service should, whenever possible, design and size timber sales to favor local operators and mills.
Non-Native Invasive Plants
There are more Non-Native Invasive Plants (NNIPs) every year in our National Forests, in both diversity and coverage. NNIPs benefit from a lack of natural herbivores, a warming climate, and land disturbance.
The draft forest plan’s creation of more disturbance, such as timber harvest, will encourage more NNIPs to establish and dominate ecosystems. The draft plan aims to treat 300 acres of NNIPs per year, while planning to harvest 3,700 acres of timber per year.
The final forest plan should have same number of acres allocated for timber harvest as it does for control of Non-Native Invasive Plants (NNIPS). The plan should also require the inventory and treatment of NNIPs along forest roads before timber harvest occurs.
Watch Our Info Session Videos:
Overview of the N-P Forest Plan
Water Issues and Stream Protections
Management Areas in the Forest Plan
Non-native Invasive Plants
Public Policy Network Presenteation
What’s in the Draft Forest Plan
Draft Plan Documents
The draft forest plan is comprised of the following two documents.
The Draft Forest Plan
The Draft Forest Plan is 283-pages-long, and provides directions for managing the forest.The final plan is the set of instructions that Forest Service employees will read and use when developing projects and creating their annual work plans. It includes the Desired Conditions for the lands under Forest Service Management, Objectives for management outputs for all resource areas, Standards that must be met when managing the forest, and Guidelines to be followed when active management occurs. When finalized, the plan will set the management direction for the forest for the next 15-20 years.
The Draft Environmental Impact Statement (DEIS)
The Draft Environmental Impact Statement (DEIS) consists of 610 pages that analyze the range of possible impacts based on each proposed plan Alternative. The DEIS has in-depth analysis, and provides the rationale for the content of the Forest Plan. In addition to the DEIS, there are numerous appendices that provide more detailed analysis.
Desired Conditions describe the vision in the plan for the condition of the forest, now and in the future. Desired conditions are aspirational.
Objectives are the concrete goals the Forest Service sets over the life of the plan for topics like restoration, wildlife habitat, non-native invasive plant management, timber harvest, trails and recreation, and more. One of the innovations of this Forest Plan is the presence of Tiered Objectives. Tier 1 includes what the Forest Service can accomplish with existing resources, and Tier 2 conveys what the Forest Service could accomplish with additional resources.
Standards and Guides are the rules in the plan that the Forest Service must follow to protect sensitive resources like clean water, soils, rare species, and recreational settings.
Geographic Areas are one of the innovations in the draft Forest Plan. The Forest Service has divided the landscape into 12 Geographic Areas that each have similar ecological character and human use patterns. Geographic Areas have narratives that describe the area, the desired conditions of the area, and the type of activities that will be emphasized in that area.
Management Areas are specific zones that emphasize certain types of management. These are more influential and specific than Geographic Areas, and come with their own set of Standards and Guides. The simplest way to look at management areas is to divide them into categories that are either “suitable” or “unsuitable” for “timber production.” The Matrix and Interface Management Areas are considered “suitable” for timber production, meaning that they “have a regularly scheduled timber harvest program” (Draft Plan p. 61). Other Management Areas, such as Backcountry, Ecological Interest Area, Appalachian Trail, and Roan Mountain, allow tree cutting for ecosystem management purposes. The trees can be sold as long as there is a primary ecological need for tree cutting. Special Interest Areas also allow ecologically based tree cutting, but that is unlikely in this Management Area. Recommended Wilderness would be managed consistently with the Wilderness Act and prohibit mechanized tools and the transport and removal of wood, except under very dire circumstances.
The draft plan offers three new alternatives, which are potential management models the Forest Service is considering for the final plan. The plan also includes Alternative A — the current forest plan. Alternative B has the most land available for commercial timber production, at 620,000 acres, and also recommends 124,000 acres of new Wilderness, but does not include the Ecological Interest Area Management Area. Alternative C has the smallest footprint for timber production and the least recommended new Wilderness (11,193 acres), while having the largest allocation to the Ecological Interest Area Management Area (79,550 acres). Alternative D is similar to Alternative B with 618,000 acres allocated to timber production, but has less recommended new Wilderness (74,173 acres) and 26,000 acres of Ecological Interest Area.
When analyzing how well each alternative treats sensitive ecological resources like existing old-growth forest, North Carolina Natural Heritage Program Natural Areas, and Wilderness Inventory areas, none of the alternatives go far enough. And because none of the Alternatives give blanket protection to existing old growth or Natural Areas, it will be important that the final plan either puts those sensitive places into compatible Management Areas (like Special Interest Areas), creates guidelines for how the Forest Service should protect those areas, or both.
|Alternative||Acres In Suitable MAs||Commercially Viable Timber Harvest Acres*||Recommended Wilderness Acres||Acres of WIAs in Suitable MAs||Acres of Natural areas in Suitable MAs|
*These are the acres the draft plan has deemed to be commercially viable and potentially accessible in the next 20 years. The actual acreage over a longer time horizon would be larger. Note that the maximum timber harvest per decade in the plan is about 38,000 acres per decade, so only a fraction of these lands would be needed to meet the timber and habitat objectives of the Draft Plan. Information from Plan Appendix B.
**These numbers take into account the 2001 Roadless Rule, which removed about 81,000 acres from the suitable timber base in the 1994 Amendment to the 1987 Forest Plan.
One thing the Forest Plan and DEIS do well is to demonstrate that timber harvest goals, Wilderness, and Natural Area management do not need to be in conflict. The acres that are available for Wilderness Designation are not accessible for timber harvest. Likewise, Alternative C, which does a much better job of protecting backcountry areas and Natural Areas than the other two alternatives, has a comparable amount of land available for timber harvest, and more than the current plan.
An important point to understand when commenting is that you are not required to choose one alternative, nor are you required to endorse any Alternative in its current form. You may wish to choose an Alternative as a starting point and then suggest modifications based on your own values and knowledge.
We recommend viewing the Management Area allocations of the various Alternatives using the story map provided by the Forest Service: https://www.arcgis.com/apps/Cascade/index.html?appid=5927abbc564c488ea67eefc54c70beaf