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June 25, 2020 Comments on the Nantahala and Pisgah National Forests Proposed Land Management Plan

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June 25, 2020 Comments on the Nantahala and Pisgah National Forests Proposed Land Management Plan A lasting voice for innovative management and investment in the public forests of North Carolina’s mountains. [email protected] June 25, 2020 Comments on the Nantahala and Pisgah National Forests Proposed Land Management Plan Attn: Plan Revision Team Leader National Forests in North Carolina 160 Zillicoa St., Suite A Asheville, NC 28801 Submitted to the CARA Online Portal at: https://cara.ecosystem- management.org/Public/CommentInput?Project=43545 List of Partnership Member and Affiliate Organization Endorsement Member Organizations: • Access Fund • American Whitewater • Back Country Horsemen of North Carolina • Carolina Climbers Coalition • Carolina Land & Lakes Resource Conservation & Development Council • Carolina Mountain Club • Columbia Forest Products • Defenders of Wildlife • EcoForesters • Evergreen Packaging • Graham County, NC Government • International Mountain Bicycling Association • MountainTrue • National Wild Turkey Federation of North Carolina • North Carolina Chapter of The Nature Conservancy • North Carolina Council of Trout Unlimited • North Carolina Horse Council • North Carolina Wildlife Federation • Southern Appalachian Mineral Society • Southern Off-Road Bicycle Association • The Wilderness Society • Wild South Affiliate Organizations: • Audubon North Carolina • North Carolina Chapter of The Sierra Club • Southern Environmental Law Center NPFP Draft Plan Comments i | Page TABLE OF CONTENTS List of Partnership Member and Affiliate Organization Endorsement ...................................... i Introduction ............................................................................................................................... 1 Reader’s Guide.......................................................................................................................... 2 Section 1: Integrated Recommendations, by Issue ................................................................... 5 1. Tiered Objectives for Active Management ................................................................... 7 2. Recreation and Trails .................................................................................................... 9 3. Non-Native Invasive Species (NNIS) ......................................................................... 12 4. Landscape-Level Progress toward NRV (“Condition-based objectives”) .................. 14 5. Existing Old Growth and Patch Network ................................................................... 19 6. Natural Heritage Natural Areas .................................................................................. 22 7. Management Area Allocations ................................................................................... 25 8. Geographic Distribution and Flow of Forest Products ............................................... 31 9. Roads, Soil, and Water................................................................................................ 35 10. Special Use Permits (SUP) ......................................................................................... 41 11. Wild and Scenic Rivers ............................................................................................... 43 12. Terrestrial Wildlife Habitat Considerations ................................................................ 46 Section 2: Economic Development ......................................................................................... 52 Section 3: Climate Change ...................................................................................................... 59 Section 4: Discrete Comments on Plan Components ............................................................. 66 Chapter 1: Introduction to the Nantahala & Pisgah National Forests ............................. 66 Chapter 2: Forestwide Plan Components ........................................................................ 67 Chapter 3: Geographic Areas .......................................................................................... 84 Chapter 4: Management Areas ........................................................................................ 88 Chapter 5: Monitoring and Adaptive Management ......................................................... 92 Section 5. External Partnership Agreement to Support Congressional Designations ............ 94 Tier 1 Agreements to Support Congressional Designations ............................................ 94 Tier 2 Agreements to Support Congressional Designations ............................................ 96 Appendix A ........................................................................................................................... A-1 NPFP Draft Plan Comments ii | Page Introduction We, The Nantahala-Pisgah Forest Partnership (“Partnership”) formed in February of 2013 as a collaborative group of more than 30 organizations representing a diverse cross-section of public lands interests, including recreation, forest products, local government, cultural heritage, conservation, wildlife, hunting, angling, and other forest user groups. The Partnership was created with the goal of working collaboratively and in parallel to the US Forest Service planning process. Representing a diverse spectrum of interests, partners have worked to foster civic engagement, generate positive guidance, and develop recommendations for creating the best possible revised management plan for the Nantahala and Pisgah National Forests. Over the last seven years the Partnership has engaged in robust public dialogue in support of the planning process. The Partnership has utilized a variety of sources including national, regional, tribal, and local community expertise with an emphasis on public participation and information sharing in order to reach consensus. Partnership members and affiliates have volunteered thousands of hours to build consensus around and support for recommendations that will facilitate a Forest Plan which best addresses the interests of our many stakeholders as well as the needs of the environment, local communities, and the countless species that call the Nantahala and Pisgah home. Members and affiliate organizations have developed and vetted proposals, shared concerns, built understanding and developed solutions to accommodate all members’ values and interests. Our approach has been to strive to reach community-supported, science-based methods for forest management, interpretation, and investment. The comments that are provided in this document represent the culmination of this painstaking, intentional, and deliberative process. They have been crafted with the intent of creating a lasting voice for the innovative management of and public investment in the future of our beloved National Forest. While the Partnership was created as a collaborative to inform the planning process, we have committed to continuing our work throughout the plan implementation process and at the project level. In addition, the Partnership has been involved, and will continue to be involved, with issues relating to the National Forest system as a whole as well as on the legislative and federal level. The Partnership has always been and will continue to be an open and transparent collaborative, with membership open to all stakeholders of interest in the plan revision and implementation processes. Our charter is posted online and our monthly meetings are open to anyone who would like to observe. NPFP Draft Plan Comments 1 | Page The vision statement of the Nantahala Pisgah Forest Partnership is as follows: We envision a thriving, resilient forest within its natural range of variation, able to support healthy ecosystems, wildlife populations, local economies, and traditional uses. We envision a forest with the connectivity and integrity to remain resilient in the face of the changes and challenges of the future. Reader’s Guide In accordance with the mission of the Partnership, we have actively worked to achieve broad consensus on a robust set of recommendations for the Revised Nantahala Pisgah Forest Plan, that balances all stakeholder needs to the fullest extent possible. Our process was lengthy, and with the relationships and trust that was built over many years of monthly meetings, the recommendations that we are presenting are substantive and cover almost every aspect of the Draft Plan. On some of the issues, partners successfully negotiated and compromised to an unprecedented degree, and the agreement therefore includes pieces that individual members would not support for their own sake. In other words, we attempted to identify the core set of connected agreements that were necessary to create a critical mass of support, which we believe is imperative to working effectively with each other and the Forest Service throughout plan implementation. Like the Forest Plan itself, all of the recommendations in this document are connected to one another and are inseparable from the whole. Members’ full support is conditional upon these interrelated recommendations moving forward together. According to the Partnership’s charter: “Consensus is defined as a decision that all members can live with. Participants may support an idea fully, partially, or not at all.” For the recommendations presented we achieved consensus and everything is within the Partnership's zone of consent. (See illustration below.) Section 1 includes integrated recommendations, presented by issue. The Partnership’s intent is to merge multiple interests’ needs by highlighting the most difficult and
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