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Working Group on Ecological Forest Management, Climate Protection, and Sustainable Economies Wayne National Forest Assessment Ph

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Working Group on Ecological Forest Management, Climate Protection, and Sustainable Economies Wayne National Forest Assessment Ph Working Group on Ecological Forest Management, Climate Protection, and Sustainable Economies Wayne National Forest Assessment Phase Comments January 28, 2019 Working Group members: Zachary Bollheimer Heather Cantino Andrea Chu Aimee Delach Connie Gadell-Newton Christine Glaser Roxanne Groff Lea Harper Christine Hughes Paul E. Knoop Jr. Peter Kotses Barbara Lund James Matzorkis Loraine McCosker Robert Morris Greg Pace Randi Pokladnik Becca Pollard Contents: 1. Committee members’ brief bios, below 2. Cover letter (p. 4): problems to be addressed (p. 5) and recommendations (p. 9) 3. Annotated bibliography of references that must be assessed, with table of contents: p. 15 1. Committee members brief bios Zachary Bollheimer: Environmental Consultant, Columbus [email protected] Heather Cantino, Buckeye Environmental Network (formerly Buckeye Forest Council) board member since 2001; Athens County’s Future Action Network (ACFAN, formerly Athens County Fracking Action Network) Steering Committee chair. M.Ed., Education; B.A. in General Studies, Radcliffe College, Harvard University. Heather has lived in Athens since 1981. [email protected] Andrea Chu, Regional Organizer with Food & Water Watch. BS in Enviro Sci, MS in Environmental Planning and Management, [email protected] Aimee Delach holds a Master’s in Plant Ecology from SUNY-ESF and works in wildlife conservation. She lives in Athens, OH. Email: [email protected] Connie Gadell-Newton is an attorney and community activist in Columbus Ohio, with a B.A. in Philosophy and Women's Studies from OSU and a J.D. from Penn State University. Gadell-Newton was the Green party candidate for Governor of Ohio in 2018. [email protected] Christine Glaser, PhD in Economics/Public Affairs, University of Munich, Germany; adjunct professor, School of Public and Environmental Affairs, Indiana University, former partner, GreenFire Consulting Group, LLC. lives in Bloomington, IN. [email protected] Roxanne Groff, M.A., former Athens County Commissioner, Member of Athens County’s Future Action Network; Buckeye Environmental Network Board Chair. She lives in Amesville Ohio. [email protected] Lea Harper, Managing Director, FreshWater Accountability Project PO Box 473, Grand Rapids, OH 43522, Wood County, [email protected] 2 Christine Hughes, An active member of Ohio Ecological Food and Farming Association and Athens County's Future Action Network, co-owner of Village Bakery and Catalyst Cafe, Athens, Ohio. [email protected] Paul E. Knoop, Jr. Teacher and environmental educator. Worked for National Audubon Society for 35 years, retired living in Laurelville and involved with community land trusts, land use planning, and forest management. [email protected] Peter Kotses, business owner in Athens, avid cyclist [email protected] Barbara Lund, B.S Cornell University, former Park Ranger, Naturalist, National Park Service, resides in Adams County, Ohio. [email protected] Loraine McCosker, MS, BSN, RN. Served on the Sierra Club Forests and Public Lands for 14 years with oversight on state and the Wayne National Forest. Currently works as educator at Ohio University in Environmental Studies. [email protected] James Matzorkis, B.A. Keep Wayne Wild, lives in NE Ohio. Robert Morris, B.F.A, Lives on the border of the Wayne National Forest, Woodsfield, Monroe County. Greg Pace, originating member - Columbus Community Bill of Rights; Administrator, ‘Guernsey County Citizens Support on Drilling Issues’ email list, Webmaster/secretary, ‘Clintonville Energy Collaborative’; member, ‘Economic Democracy Advocates’ Randi Pokladnik, BA in Chemistry, MA and PhD in Environmental Studies (research on non timber forest products in Appalachia), lives in Harrison County. [email protected] Becca Pollard, Organizer,Columbus, Ohio. [email protected] 3 2. Cover letter: problems addressed and recommendations Dear Planning Revision Team, The citizen-led Ecological Forest Management, Climate Protection, and Sustainable Economies Working Group presents the following concerns, with references to peer-reviewed and other documents submitted separately by our members. We expect all submitted documents to be evaluated in your planning revision process. Some submissions are re-submissions of testimony, research, and analysis previously submitted by Buckeye Forest Council, Athens County Fracking Action Network, Heartwood, Sierra Club, and other groups as well as by professional biologists and concerned citizens on issues that have yet to be addressed by the Wayne in a NEPA-based evaluation of forest actions. This includes extensive, relevant and substantive arguments objecting to: 1. The highly flawed 2006 Wayne National Forest Plan, which was legally contested at the time by Heartwood, Buckeye Forest Council, and Sierra Club (press release attached), 2. USFS permission to the BLM to lease Wayne land for fracking without the USFS ever having conducted a NEPA-based evaluation of fracking, in spite of the current (2006) plan not having evaluated this new technology and its now apparent highly significant impacts on the forest, community, climate, regional air and water quality and public health, 3. Destructive timber sales, prescribed burns, and other mismanagement activities that conflict with USFS's congressional mandate to provide economic benefit to the American people and to take into consideration all potentially significant economic and environmental impacts, including long-term climate impacts, of Wayne Forest actions on the community surrounding the Wayne and on the well-being of the American people in its decision-making for any and all significant actions. 4 In addition to resubmitting previously submitted materials, we have submitted other relevant and up-to-date research addressing USFS's legal responsibility to protect ecosystems and ecosystem services of the highest value for present and future generations, addressing cumulative impacts of all significant actions to be authorized by the new Plan. We look forward to a complete evaluation of all relevant issues raised in the accompanying documents. A. Problems Addressed: 1. The highly flawed 2006 Plan, which was challenged in a lawsuit by Heartwood et al. and heavily critiqued in the 2008 Economic Analysis of the 2006 Wayne National Forest Plan, commissioned by Heartwood, for the Plan’s prioritization of logging, mining, oil and gas drilling, prescribed burning, and ORV use over provision of the much more valuable non-consumptive ecosystem services that are severely degraded by this prioritization. As stated in the introduction to this 2008 analysis, “Under the management of the USDA Forest Service, the WNF has continued to be a sacrifice zone for extractive industries, including logging, strip mining, and oil and gas drilling. Its hills are scarred with clearcuts, crisscrossed with power lines, torn up by ORVs, and the water flowing through its creeks and rivers is tinted orange with mining waste. The WNF, managed for its highest values — water filtration and flow regulation, air purification, tourism, biodiversity and carbon sequestration — could become a great natural asset to the State of Ohio and to the nation. Yet, by implementing the 2006 WNF Plan, the Forest Service continues to degrade and diminish this natural asset. The 2006 WNF Plan has declared 161,752 acres— almost 70 percent of the WNF area—as suitable for timber production and proposes to log 18,441 acres over the next decade— not including salvage logging. In addition, the Forest Service plans to burn 46,215 acres for an unproven ‘Oak regeneration’ program and 21,904 acres to reduce questionable ‘hazardous fuels’ risks. Almost 11,000 acres of forestland may be sprayed with herbicides, 5 1,250 acres opened to surface coal mining, and 121 acres to oil and gas well development. We may see about 180 miles of new temporary and permanent roads. “The sum of extractive and destructive activities proposed in the 2006 Forest Plan will lessen the attractiveness of the forest and will negatively impact tourism. The [proposed activities] will also diminish the capacity of the WNF to deliver ‘ecosystem services’ such as water purification performed by the natural filtration systems of the earth and carbon sequestration provided by the trees and other forest plants. These ecosystem services have a much higher value to society than the timber that is taken out. “In addition, cutting timber, digging for minerals, drilling for natural gas, and building ORV trails costs more in purely financial terms than what the Forest Service receives in revenues from those activities. Consequently, they create a financial loss to the taxpayer. The Forest Service justifies this double–negative with supposed benefits of “ecosystem management,” “oil independence,” and “tourism niche marketing,” as well as benefits to the local economy. However, as our analysis shows, it is questionable whether the 2006 WNF’s Land and Resources Management Plan (LRMP) provides any net benefits to the public….” (2008 Economic Analysis intro) The 2006 Plan did not assess economic impacts or costs of such prioritization, including lost ecosystem service benefits to the regional economy. 2. The 2006 Plan did not address public health benefits of leaving the forest alone to provide critical ecosystem benefits or the public health impacts of its management activities, including water and air pollution from oil and gas extraction, ORV use, forest loss, burning, and NNIS chemical treatments and
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