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Stelprdb5157819.Pdf Lynn Cameron To: [email protected] <[email protected]> cc: Subject: Friends of Shenandoah Mountain map correction 01/05/2009 08:19 AM Dear Planning Team, Friends of Shenandoah Mountain submitted comments on October 30, 2008, with an accompanying boundary map of the proposed Shenandoah Mountain NSA and Wilderness areas within. We are submitting the attached map as a boundary adjustment to Lynn Hollow Wilderness. We did not mean to include Puffenbarger Pond and its access road in our proposed Wilderness. Thank you. Lynn Cameron Co-Chair Friends of Shenandoah Mountain -- Lynn Cameron Coordinator of Library Instruction Liaison Librarian for Psychology Carrier Library James Madison University Harrisonburg, VA 22807 (540)568-3826 "I only went out for a walk, and finally concluded to stay out till sundown, for going out, I found, was really going in" - John Muir (1838-1914) "steven krichbaum" To: [email protected] <[email protected] cc: [email protected], [email protected] > Subject: plan revision comments 01/09/2009 11:23 AM happy new year, hope you are all well - attached are comments pertaining to wildlife and vegetation management - please let me know asap if you cannot open this; have sent same document twice, one with .doc extension - thank you - steve krichaum Steven Krichbaum 412 Carter St. Staunton, VA 24401 540 - 886 -1584 [email protected] January 8, 2009 George Washington National Forest - Supervisor’s Office 5162 Valleypointe Pkwy. Roanoke, VA 24019 888-265-0019 540-265-5173 [email protected] to: Supervisor Maureen Hyzer, Kenneth Landgraf, Karen Overcash, Russ MacFarlane, and all whom this concerns re: Comments pertaining to the Draft Comprehensive Evaluation Report (“CER” or “DCER”), Draft Proposed Land Management Plan (“DLMP”), and the revision of the George Washington National Forest Plan - Wildlife management/ Vegetation manipulation Climate Change In response to ongoing and potential climate change a priority goal/objective/desired condition for the revised Plan must be to restore and maintain broad elevational core habitat and corridors throughout the Forest. Identification and mapping of patches and corridors of mature and old-growth forest (contiguous forest containing “core” conditions of mature and/or old-growth forest supplying expansive elevational gradients and anthropogenically unbroken/unfragmented physical links between relatively large patches containing “core” conditions of mature and/or old-growth forest) needs to be accomplished. The retention and restoration of full altitudinal gradients is of crucial importance in order to accommodate faunal and floral population/community shifts upslope to cooler conditions in response to climate change. Clear and explicit prescriptions/objectives/guidelines/standards must provide for this. The DCER and DLMP fail to fully and fairly analyse and consider this significant issue. These cores/corridors must be considered not suitable for logging, road building, drilling, mining, wind turbines, or development. They are priority areas for watershed restoration activities (e.g., decommissioning, recontouring, and revegetating of selected roads). In other words, we must ensure that there is no loss of or degradation of habitat within the broad elevational “corridors”. “It is important to stress once again that no evidence supports the proposition that corridors can mitigate the overall loss of habitat (Harrison 1994, Fahrig 1998, Rosenberg et al. 1997).” (Harrison, S. and E. Bruna. 1999. Habitat fragmentation and large- scale conservation: what do we know for sure? Ecography 22: 225-232.) It is crucial that “corridors” not be narrow so as to avoid being overrun with edge effects. “Effective area modeling” of habitat “provides a tool for assessing the value of habitat corridors for a wide range of species, based on their responses to habitat edges.” Sisk, T.D. and N.M. Haddad. 2002. Incorporating the effects of habitat edges into landscape models: Effective Area Models for cross-boundary management. Pages 208-240 in J. Lui and W. Taylor 1 (eds.), Integrating Landscape Ecology into Natural Resource Management. Cambridge University Press: Cambridge. 500 pp. (emphasis added) Of course, there is an interplay (often confounded) of area effects, edge effects, and landscape context. “Habitat area and edge are key components of landscape structure, yet these components tend to covary within landscapes. Because habitat area and edge describe different aspects of landscape structure, the importance of each suggests different foci for conservation strategies, making it imperative to understand their unique roles in habitat fragmentation.” Fletcher, Jr., R.J., L. Ries, J. Battin, and A.D. Chalfoun. 2007. The role of habitat area and edge in fragmented landscapes: definitively distinct or inevitably intertwined? Canadian Journal of Zoology 85: 1017–1030 ***** The DCER fails to fully and fairly consider, evaluate, and disclose effects of climate change upon Brook Trout. Increasingly warm temperatures may significantly diminish Trout populations, habitat, and/or distribution. See Flebbe, P.A., L.D. Roghair, and J.L. Bruggink. 2006. Spatial modeling to project Southern Appalachian Brook Trout distribution in a warmer climate. Transactions of the American Fisheries Society 135: 1371-1382 (lead author is FS researcher based in Virginia). Effects of climate shift may include not only temperature change, but also increasing aridity and concomitant drying out of or lowering of water levels in streams. “Long-term, non- periodic trends, such as global warming, for example, may increase drought frequency (LeBlanc and Foster 1992) and alter species distributions (Iverson et al. 1999).” Rentch, J.S. 2006. “Structure and Functioning of Terrestrial Ecosystems in the Eastern Rivers and Mountains Network: Conceptual Models and Vital Signs Monitoring”. Technical Report NPS/NER/NRR- 2006/007. National Park Service: Philadelphia, PA available at http://www.nps.gov/nero/science/. The cumulative impacts of actions within control of the FS in conjunction with climate change effects are of great concern. ***** The DCER fails to fully and fairly consider, evaluate, and disclose effects of climate change upon Wood Turtles, herpetofauna, and other vulnerable species (such as those at the southern limits of their ranges). Increasingly warm temperatures may significantly diminish Turtle populations, habitat, and/or distribution. Effects may include not only temperature change, but also increasing aridity and concomitant drying out of or lowering of water levels in streams used by the Turtles. “Impacts of global climate change, atmospheric deposition, and air pollution would most likely be apparent in herptofaunal communities before they would in other sectors of the terrestrial ecosystem.” (Rentch, J.S. 2006 id.) I am particularly concerned about the cumulative impacts of management actions allowed in the DLMP (e.g., logging, burning, and road construction/reconstruction/maintenance) in conjunction with the effects of climate change. ***** The FS planners must also fully and fairly consider the potential affect of the warming and drying associated with climate change that can advantage oaks more so than other tree species. The DCER and DLMP do not reflect this consideration. See, e.g., “Swapping forests (Or how we'll lose the beech and learn to love the Southern pine)” by Kevin Mayhood, Tuesday, July 8, 2008, THE COLUMBUS DISPATCH: “Chiang and Brown built their work on a tree atlas of the eastern United States that Iverson and three colleagues built. The atlas shows possible changes in range for 134 tree species. “Trees might not die off completely here, but the range in which they thrive could shift 250 to 500 miles to the northeast, depending on how hot it gets and how much carbon dioxide is added to the atmosphere, said Matthew Peters, one of the atlas creators. 2 “The Ohio atlas suggests a decline in the American beech, and the disappearance of the bigtooth aspen and sugar maple in the next 60 to 100 years.” <http://www.columbusdispatch.com/live/content/science/stories/2008/07/08/sci_hot_fore st.ART_ART_07-08-08_B4_1HAL6NH.html?sid=101> ***** I am particularly concerned about the cumulative impacts of management actions allowed in the DLMP (e.g., logging and road construction/reconstruction/maintenance) in conjunction with the potential harmful effects of climate change as well as acidic deposition, deposition of other air pollutants, ultraviolet radiation, and ozone. For example, the loss of Hemlocks due to the Wooly Adelgid is another factor affecting Trout and other aquatic populations. The supposition (or even fact) that sedimentation in and of itself may not significantly harm aquatic biota does not allay concerns. This is not sufficient consideration. The additional stress, even if insignificant of itself, may in conjunction with other impacts be very significant. The sufficiency of BMPs and their narrowly proscribed stream buffer zones for dealing with these aggregating or accumulating impacts is the concern/issue that needs to be fully addressed. Herbaceous Flora In addition to salamanders (see previous S. Krichbaum comment letters of August 8, October 24, and October 30, 2008), herbaceous flora of the interiors of mature and/or old growth forest are also of significant import in any discussion of management on the GWNF. See, e.g., Gilliam, F.S. 2007. The ecological significance of
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