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Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
General Comments
Plan
Organization Comment Section DNR Repsonse
Of particular interest to me are the sections dealing with
endangered and threatened species, since that is a major part of
Aamazon my own professional practice. I was pleased to see recognition of
Natural the importance of cooperation with MNFI and keeping them
Resoruce updated on new occurrences. I am also pleased to see recognition
Consulting of invasive species management as a critical factor. 4.1.4 Support acknowledged
Circa 1800 conditions are one of several data (others
include current conditions, Kotar Habitat Type/or soils,
There is a sense that the future desired condition of Michigan’s and social and economic uses) that are considered in
Michigan forest is the circa 1800 forest conditions. It seems the plan is trying assessing trends and determining management
Association of to manage for the needs of a past society and not for the needs of direction. There is no intent to manage the State
Timbermen our future generations. 4 Forest using circa 1800 conditions as a template.
The time allotted to this process is not long enough to provide a
well developed plan that has a shared vision from all stakeholders.
This section states “the Department has a vision of the desired
future conditions of DNR-managed forestlands” we feel this should
be a shared vision by all stakeholders otherwise it would seem the In response to public comment the DNR extended the
Michigan DNR is implementing their own agenda. We question the timing public comment period until March 14, 2008 and
Association of planning process of this important document. We feel the delayed a Director's decision by one month to April 10,
Timbermen department is still rushing to get a final document. 4.1 2008.
1 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
General Comments
Support for aspen and red pine management is
acknowledged. With respect to northern hardwoods,
the text is qualified as: "...potentially...one possible
In the Statewide Management Direction section, there are some ...management by conducting inventory, preparing
excellent management objectives, including retention of aspen sales, and monitoring much of the forest on a
stands on sites on which they are well‑suited, balancing the age continual basis... The DNR does not have the
class distribution of red pine, and the recognition that northern resources that would enable a shift to a continual
Michigan hardwood forests would be better managed on a continuous basis management cycle in the near-term, nor would it be
Forest rather than the 10‑year compartment review cycle. These necessarily desirable to do so, but...such a shift may
Products objectives benefit wildlife, forest health, and the forest products be possible in the future."
Council industry which in turn contributes to strong local economies. 4
The Department is asking for approval of the plan one month after
the final draft was released. A plan of this magnitude would benefit
from a Natural Resource Commission review which ensures due In response to public comment the DNR extended the
process. I strongly urge the Commission to refer this plan to the public comment period until March 14, 2008 and
Michigan appropriate subcommittee for a full critical review and analysis of delayed a Director's decision by one month to April 10,
Forest management objectives. This is far too important and far‑reaching 2008. Review of the plan has been scheduled with
Products of a document to approve after just one month of review, with the NRC Policy Committee on Land Management at
Council limited opportunity for review of additional comments. the March 6, 2008 NRC meeting.
Ruffed
Grouse In general, the Ruffed Grouse Society supports the Plan that will
Society guide sustainable management of the State Forest System. Support acknowledged
2 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
General Comments
While the SFMP is an operational plan, it provides
broad strategic direction for forest types which can be
monitored, but it is intentionally less specific than the
Regional State Forest Management Plans (RSFMPs)
will be that are under development in 2008. Specificity
We are also concerned that few measurable management in the RSFMPs will be based upon detailed analysis at
objectives are provided in this expansive document. The Plan the local level, and will provide a focused regional
includes no harvest volumes, acreages to be treated, wildlife picture of managment direction for cover types and
population objectives, or other targets to reach. It will be difficult for other uses. Annual production capacity for timber
such a Plan to be monitored effectively if few targets are provided. harvests in the State Forest are specified in Section
Ruffed It will also be difficult for outside publics (industry, hunters, hikers, 3.1.3 of the plan. Objectives for other uses are also
Grouse auditors, etc.) to ever determine if the Plan is succeeding if there is contained in other DNR plans (e.g. Deer Management
Society nothing to base judgments on. 4 Unit objectives, etc.)
We continue to question the reliance on circa 1800 data as a basis
to compare current forest composition. The amount of references
to that time period is staggering and probably over emphasized in
this document. This inclusion in the Plan infers that what may or
may not have existed in circa 1800 forests in the Michigan
landscape were “natural” forests and a target to strive for. While
historical data can provide valuable insight into what a given locale
supported at a point in time, climate variability, human (ie. Native Circa 1800 conditions are one of several data (others
American) population changes and data biases such as General include current conditions, Kotar Habitat Type/or soils,
Land Office notes all must be taken into account. However, this and social and economic uses) that are considered in
Ruffed data should not be used to chart the course of future management. assessing trends and determining management
Grouse Why not also bring in speculative information from 1600, 200 or direction. There is no intent to manage the State
Society even 10,000 years ago? From several accounts, the 1800 period, Forest using circa 1800 conditions as a template.
I commend you for the plan's focus on ecosystem management
and sustainable practices in furthering the state's goals and
ensuring the long term productivity, conservation, and efficient use
of forest resources. In addition, I support your intent to manage
adaptively, recognizing a level of uncertainty in managing natural
systems and allowig yourself the flexibility to adjust your
Ottawa Natl management practices based on changing conditions and new
Forest information. Support acknowledged
3 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
General Comments
We have the following comments and concerns regarding Section
4.1.61, and Metallic and Nonmetallic Mineral Development, pages
Great Lakes 137-139. We applaud the desired future condition and goal
Council, number 1, with the emphasis on resource protection. How well this
Federation of is accomplished is as always, dependant upon actual management
Fly Fishers standards. 4.1.6.1 Support acknowledged
Great Lakes
Council,
Federation of Throughout this Plan documents are referenced as standards with
Fly Fishers no descriptions or hot links to the referenced documents. We find
and Anglers this unacceptable because it is difficult for the public to find and use The DNR will strive to provide live links to documents
of the AuSable these documents. 4 and 5 in the on-version of the final plan.
More importantly how can sustainability be assured in a forest
system largely maintained in an unnaturally disturbed state? How
can the current structurally and compositionally compromised state The DNR is just beginning to implement the concepts
of the forest be sustainable? After habitat loss, habitat alteration is of ecosystem management and sustainability into
the leading cause of the death of birth, the loss of native forest operations. The SFMP and Regional State
biodiversity. Yet here is a SFMP that calls for massive habitat Forest Management Plans provide a framework for
alteration on a statewide scale. A SFMP that nonsensically claims moving in this direction. The plans provide for areas
it is sustainable, yet offers no analysis contrasting this plan with where natural processes and restoration of natural
native habitat.The tradeoffs must be stated clearly, what do we the communities will be the focus of management (e.g.
people of this state lose by stopping the restoration of our forest? Natural Areas, Biodiversity Stewardship Areas and
Just saying that there will be tradeoffs is very unhelpful. What are Ecological Reference Areas). The plan also provides
the tradeoffs? What is the cost? What pieces of the web of life will areas where other uses and values (such as fiber
we lose? How can you alter the habitat in novel ways and still claim production and recreation) will be the primary focus of
to know your new system is sustainable in the long term? Do you management. These plans are intended to be living
even have a complete list of the components, of how they interact? documents that will be updated when monitoring and
Mackinaw If not, how do you show sustainability in a system you don't management review protocols indicate the necessity
Forest Council understand? of new management direction.
4 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
General Comments
In the DNR response to our comments on monitoring, and allowing
the public to be involved in critiquing the DNR monitoring, we are
told that that is outside the scope of the SFMP and is address in The Biodiversity Conservation Planning Process has
Work Instructions 1.2. As has been previously commented the been and will continue to be a public process. Forest
Work Instructions were never vetted in public, and had no public Certification Work Instructions are internal DNR
involvement. We are dismayed at the continued systematic documents that provide guidance to staff on
exclusion of the public from any real input into planning at early operational processes, for which public review is
stages, when real change and real exchange of ideas would be inappropriate. The DNR has a goal to improve public
possible. This exclusion is continuing with the Cervid team and the involvement processes in many programs. In relation
BCPP, both of which have been meeting and planning for years to planning the Ecoregional Resource Plans will be
Mackinaw with the complete exclusion of public input. This systematic developed using a collaborative public process, which
Forest Council exclusion of real public input must stop. will begin in 2008.
5 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Recreational Comments
Plan
Organization Comment Section DNR Repsonse
Biking is a low‑impact, nonmotorized activity practiced and
enjoyed on many primitive trails in Michigan State Forests. This sentence pertains to the range of
Thus, I am requesting it be added to the following section on accessibility only. Mountain biking is listed
Desired Future Condition: "Recreational trails will include a as a trail type that the State Forest
variety of looped and linear trails that are connected with provides opportunities for in the previous
Michigan recreation resources such as campground trailheads, and will sentence. Therefore, biking is already
Mountain range in accessibility from wheel chair accessible to primitive listed as a trail type that that we would
Biking Assoc hiking AND BIKING trails." 4.1.1.2 consider for the state forest.
The second change I am requesting pertains to including
biking as a primary recreational use of Dedicated
Management Areas in Michigan State Forests. Studies have
shown biking to be a low‑impact, minimally invasive and The primary uses allowed in Dedicated
nonintrusive nonmotorized recreational activity with ecological Management Areas are pedestrian related
impact parallel to that of hiking. For these reasons, I request and not wheeled uses. However, biking
it be added to the following section: "The primary uses of may be allowed in a few of these areas.
Michigan these areas include dispersed, nonintrusive recreation, such Users should contact the local Department
Mountain as hunting, trapping, wildlife viewing, hiking, BIKING, cross land manager to verify if Mt. biking is
Biking Assoc country skiing, and snowshoeing." 5.2.6 allowed in that specific area.
Page 68. End of para 2 - What about the Midland to 1) Midland to Mackinac is not a state
Mackinac Riding and Hiking Trail? Beginning of Para 4 - maintained trail. 2)The MCCCT is a
There are five types of trails provided by the ORV Trail motorcycle trail and would fall under the
program. Need to add the MCCCT. Middle of Para 4 - In the motorcycle trail type, 3) At this time county
LP, what about the county road ROW's for which some road ROW are not part of the designated
counties and townships have adopted ordinances to allow system unless they are part of a
MDNR ORV's to ride on county road ROWs? 3.5.3 designated route or trail.
Page 109. Is the Section 4.1.1.1 title meant to include PRD No, this title is not meant to include PRD
sites which are not on the State Forest? If so, a clarification sites and the title should be changed to
MDNR statement may be needed. 4.1.1.1 remove "and Marinas/Harbors"
6 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Recreational Comments
The dispersed camping registration card
states state forest campground, not
designated state forest campground. To
Page 113, Goal 2 - Suggest rewording to "except within one be consistent we will not be adding
MDNR mile of a designated state forest campground". 4.1.1.3 "designated" to the sentence.
Please continue to promote and create Motorcycle only trails.
Single track trails eventually evolve to wider trails, suitable to
a wider variety of ORV vehicles anyway and are how most The Department suppports this position
trails in Michigan began. It makes economic sense to start and, in fact, we are in the process of
with narrow, motorcyle only trails. If you promote wider, more getting a Land Use Order of the Director
all purpose trails, you might as well designate all two tracks approved that will allow us to enforce
None and gravel roads, as ORV Trail. 4.1.1.2 motorcycle only trail designations.
Section 3.5.3 of the draft plan addresses Forest Recreation The Department was in the process of
and Tourism. Generally, much of the information conveyed initiating an economic study on motorized
and observations provided are based on data from reports recreation in 2007 when the State's budget
compiled in the year 2000, and in certain instances earlier. crisis delayed implementing the study. The
Given the fact that tourism is so vital to Michigan's economy, Department agrees that tourism is vital to
I find it disappointing that this section is based largely on this State's ecomomy and will be moving
City of Cadillac antiquated information. 3.5.3 forward with such studies as funding allows.
I am quite concerned with the limitations that are being put
upon the horse back riders. I am afraid that if this continues The SFMP contains contains a desired
to be restricted across the state as much as it is being done future condition in Section 4.1.1.2 for
in the Pigeon River Country the children of today will never providing a variety of recreation trails
get to experience that wonderful feeling of being out in the (including horseback) in the State Forest.
forest with only your friends and your horse. Seeing the elk, Section 4.1.1.3 also provides for dispersed
deer, and other wonderful wildlife adventures on horseback is camping opportunities. Specific comment
a "high" to us as much as it is to the hunter who sees the elk, related to the Concept of Management for
large bucks, and turkeys. Please I beg of you not to let the the Pigeon River County State Forest is not
strict proposals pass and take yet another privilege away specific to the SFMP.
None from the citizens of this beautiful state. 4.1.1.2
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Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Recreational Comments
My comments are regarding section "4.1.1.2 Recreational
Trails" of the management plan. Under Objective #10
Prepare and conduct timber harvest prescriptions in a
manner that attempts to minimize obstructions and maintain
aesthetic values along trails. "to minimize obstructions" was The intent of the objective is to maintain
added. If the meaning of this is to harvest trees so they don't aesthetic values along trails. The phrase
fall down on the trail and cause an obstruction it should be "to minimize obstructions" simply means to
removed. It provides justification for any and all timber not obstruct trails during harvest
removal along a trail. This directly contradicts the objective of operations. A standard was added to
None maintaining aesthetic values. 4.1.1.2 Section 4.1.1.2 for visual management.
Although Objective #1 under 4.1.1.6 Visual Management is
"seeks to establish, maintain or enhance vegetated buffer
zones around campgrounds, access sites, and trails
systems." A specific objective under 4.1.1.2 Recreational
Trails should be added that seeks to maintain and establish a
buffer zone from timber harvesting along the trail. The
Management plan should acknowledge and reflect the fact
that timber harvests along recreational trails have a direct
negative impact for rail users. Instead of only trying to
mitigate that impact of timber harvests the management plan
should promote large buffer areas along trail systems where A standard was added to Section 4.1.1.2
None timber harvesting is not allowed. 4.1.1.2 for visual management.
8 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Wildlife and Habitat Comments
Plan
Organization Comment Section DNR Repsonse
Michigan There is not one state forest compartment that we have Although not described in the SFMP, a wildlife biologist looks at
Wild Turkey reviewed that contains even the minimum habitat each compartment to determine if wildlife values are being
Hunters requirements for the various game species, both avian and considered during the planning of forest management.
Assoc animal. This includes many non game species as well. The Components of the SFMP include quality habitat for wildlife and
revised plan does not acknowledge this. Eco‑system environmentally sensitive species (page 19). Standards for
management? Where? We understand that forest certification sustainable forestry include the conservation of biodiversity and
includes wildlife management. If we challenge the certification promoting the conservation of terrestrial and aquatic fauna and
process would it stand the scrutiny? flora (page 20).
None Does the Michigan State Forest Management Plan include Hunting and fishing (pages 113, 114, 124) and recreation (page
provisions for hunting and fishing within the plan in addition to 110) are articulated as specific management directions within the
other interests such as hiking, wildlife watching, snowmobiling, SFMP. Open land habitat is listed as a specific consideration in
etc.? Specifically, it is my understanding that the Michigan the SFMP management direction (page 142). Objectives for
State Forest Management Plan calls for a concerted effort to habitat that support grassland species such as the Sharp-tailed
maintain certain prairie ecosystems within your district that grouse are addressed in the section 4.1.2.3 of the plan. In addition
would inferentially benefit such species of birds such as the to the SFMP there are other planning processes that are related to
sharptailed grouse. hunting and fishing values (Wildlife Action Plan, State
Comprehensive Outdoor Recreation Plan, 08-12 Off-Road Vehicle
Plan, etc), which are referenced in the SFMP as standards.
4
None I would like to strongly encourage you to continue and even One of the directions of the SFMP is to minimize the loss of the
increase habitat improvement by Aspen clear‑cutting aspen covertype (page 124). Other directions articulated in the
wherever it is feasible. plan are to move towards an even age-class distribution for aspen
(page 119) and to have multiple age-classes in close proximity
4 (page 120).
None I support management planning that increases early Support acknowledged. One of the directions of the SFMP is to
successional forest acreage and promotes aspen/birch type minimize the loss of the aspen covertype (page 124). Other
habitat increases through clear cutting and other methods. directions articulated in the plan are to move towards an even age-
Also, the plan does a nice job laying out alternatives to class distribution for aspen (page 119) and to have multiple age-
reducing the boom/bust cycles in the Aspen acreage. I fully classes in close proximity (page 120). One of the tools the DNR
support some logging in the 30 39 age class as a method to will be using to help balance the aspen age class distributions is
accelerate the process of leveling the age classes. early harvests of the 30-40 year age class . Commercial demand
I also support the establishment of similar plans in the other for such stands will be a major factor in such harvests. As noted in
commercially viable timber types. Oak is noticeably this comment, the SFMP encourages a balanced age class
unbalanced and seems to have a significant acreage. distribution for oak (page 139).
4
9 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Wildlife and Habitat Comments
None I would like to add my support to the management plan that Support acknowledged. One of the directions of the SFMP is to
supports increasing early successional forest acreage and minimize the loss of the aspen covertype (page 124). Other
promotes aspen/birch type habitat increases through directions articulated in the plan are to move towards an even age-
clearcutting and other prescription treatments. class distribution for aspen (page 119) and to have multiple age-
classes in close proximity (page 120).
4
Huron Pines The close link between forest management and wildlife habitat Although not described in the SFMP, wildlife Division biologists
RC&D was made in the plan, although we do think more emphasis are continually evaluating the relationship between proposed
should be placed on this concept. In particular, it would be forest management activities and wildlife habitat. These
beneficial to list more objectives pertaining to habitat relationships are openly discussed at public compartment review
improvement, along with expressing the benefits various meetings. Habitat improvement objectives are very operational
practices for specific species. Mention of working in and the SFMP is more of a strategic document. These objectives
coordination with private landowners to help achieve state will be noted in the Regional State Forest Plans that will be
goals should also be a priority. Along those same lines, at completed later this year. The relationship between private
least some of the public’s misunderstanding of forest landowners and other partners regarding wildlife habitat will be
management practices, which is a continuing if not growing important aspects of the Eco-regional management plans to be
problem, can be minimized by making a stronger connection completed in the near future.
between forest management practices and wildlife benefits.
Finally, we would encourage the Department to make greater
use of the many conservation partners that are available to
help.
Ruffed We support the consideration of achieving a more balanced Support acknowledged. One of the directions of the SFMP is to
Grouse age class of aspen age class in the state forests as noted on minimize the loss of the aspen covertype (page 124). Other
Society page 42 of the Plan but feel there are additional issues to directions articulated in the plan are to move towards an even age-
consider other than only addressing the “boom or bust” wildlife class distribution for aspen (page 119) and to have multiple age-
“problem”. Maintaining a variety of ages of aspen habitats are classes in close proximity (page 120).
important across the Michigan landscape to wildlife
populations but also for continuing a consistent supply of
aspen fiber to markets. 4.1.2.2
Ruffed The Society remains concerned with the continuing decline in One of the directions of the SFMP is to minimize the loss of the
Grouse aspen forest communities nationwide, regionally and in the aspen covertype (page 124). Other directions articulated in the
Society Michigan. the state may be the only landowner that can plan are to move towards an even age-class distribution for aspen
maintain a significant aspen component. With a 31,000 acre (page 119) and to have multiple age-classes in close proximity
decrease in aspen acreage projected for the Hiawatha and (page 120).
Ottawa National Forest Plans over the next 10 years, the
Michigan State Forests will play an important role in
addressing the continuing decline in aspen forest communities
and the needs of wildlife associated with these communities,
including several species of greatest conservation need in the
State.
4
10 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Wildlife and Habitat Comments
Ruffed The Society is quite disappointed with the inference (page 34) The point is not large acreages of aspen causing high herbivory
Grouse that a negative effect of continued aspen management is deer by deer, but large harvests of aspen (which is what is required for
Society herbivory. While deer are having a significant effect on forest "maintaining high acreage of aspen into the future") leading to
regeneration in Michigan, the amount of aspen in Michigan larger acreages of young aspen. There are other factors which
should not be blamed for this problem. In fact, aspen levels also influence deer populations, including those identified in the
are currently at the lowest levels they have been in over 70 comment. In some Michigan areas, deer have a significant effect
years, yet the deer population is at an all time high. Obviously on forest regeneration and consequently the health of future forest
other factors, like climate change, baiting, and deer population stands. The statement has been slightly revised.
goals, are having a greater effect than aspen on Michigan’s
deer herd. 3.1.2
Ruffed Michigan is extremely important for migrating bird populations. Waterfowl areas are addressed in Section 5.1.5 of the SFMP.
Grouse Many of its State Forests provide key stopover sites for Large areas of the State forest are intensively managed for the
Society migratory birds including the American woodcock. Stop-over Kirtland's Warbler, which is a migratory species that is addressed
habitat allows migrating species to rapidly refuel their depleted in Section 5.2.5 of the SFMP. Many dedicated wildlife areas are
fat reserves and is essential for the development of also managed for the benefit of wildife species (including
comprehensive conservation strategies and management migratory species), some of which are addressed in Section 5.2.6
plans for migratory birds. We see little mention of this of the SFMP. The SFMP direction to minimize the loss of the
important habitat component for migrating birds in the revised aspen cover type (page 124) and the move towards an even-aged
Plan. class distribution for aspen (page 119) should assist in providing
migration stopover cover for woodcock. The Wildlife Action Plan
also notes the woodcock as a Species in Greatest Conservation
Need related to needed management and preservation of lowland
brush (alder).
5
None I am very concerned when I read that aspen will not be One of the directions of the SFMP is to minimize the loss of the
managed as much as in past years. Is the American aspen covertype (page 124). Other directions articulated in the
Woodcock next to disappear? Or maybe the Ruffed Grouse? It plan are to move towards an even age-class distribution for aspen
is widely known that they require aspen and alder cut in (page 119) and to have multiple age-classes in close proximity
various age classes. Have we learned nothing from the New (page 120). Alder is not currently extensively managed, but local
England states that neglected to manage their forests for the management is reviewed on an as needed basis by local wildlife
past 50 years? They are beginning to reverse that trend. Let's biologists. These local areas are addressed through
not follow the same path in Michigan. After crusing my land in compartment review as need requires and based on habitat
Lake County, one of the MDNR service foresters from objectives. Also, the State Forest must be managed for a wider
northern MI told me: "planting berry shrubs / trees will help, but range of values which is different from more focused
the meat and potatoes stuff is clear cutting your old aspen and management that is possible on private lands.
leaving stands of red, white and pin oak with the white pine
and cedar mixed in." It appears the MDNR like the Ntl. Forest
Service want us private landowners to "do as we say, not as
we do." (We will tell you how to manage your land, but we will
not be managing the state or federal lands).
4.1.2.2
11 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Wildlife and Habitat Comments
None The State needs to aggressively manage its forest for One of the directions of the SFMP is to minimize the loss of the
sustainable habitat. What this means to me is the increased aspen covertype (page 124). Other directions articulated in the
harvest of all trees with additional focus on the harvesting of plan are to move towards an even age-class distribution for aspen
the States aspen stands. Successional harvesting of our (page 119) and to have multiple age-classes in close proximity
aspen forests is critical to this states wildlife with particular (page 120).
importance to Ruffed Grouse, The American Woodcock, and
White‑tailed Deer. Please do all that you can to insure that our
aspen stands are harvested in a manner that supports a
healthy forest. Aspen is maturing beyond prime at an alarming
rate. 4
None As a citizen and hunter of the state of Michigan who utilizes One of the directions of the SFMP is to minimize the loss of the
state lands primarily for grouse and woodcock hunting, I'd like aspen covertype (page 124). Other directions articulated in the
to urge the DNR to consider increasing the aspen harvest in plan are to move towards an even age-class distribution for aspen
an effort to help improve the habitat for grouse and woodcock (page 119) and to have multiple age-classes in close proximity
as well as the many other declining early succession wildlife. (page 120).
4
None I will keep it short, lets clear cut all the Aspen we can. Good One of the directions of the SFMP is to minimize the loss of the
habitat for Grouse, Woodcock and Deer. The State gets some aspen covertype (page 124). Other directions articulated in the
money. Win Win. plan are to move towards an even age-class distribution for aspen
(page 119) and to have multiple age-classes in close proximity
4 (page 120).
Keen Forestry The DNR need to reduce the number of deer on state land The SFMP raises the issue of deer herbivory in Section 3.2.1 and
further because of the damage on state land I'm seeing to the as General Objective 4 in section 4.1.2.2. Deer regulations are
regeneration especially in Northern hardwood stands. The set annually through a separate process which is not appropriate
stands are converting to beech stands and any desirable to include in the SFMP.
species that are being regenerated are browsed to the point at
will effect the future quality of that tree. If QDMA were
implemented across the state with more liberal doe harvests it
would improve the chances for the targeted species to
properly regenerate. 4
12 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Wildlife and Habitat Comments
None Support acknowledged. One of the directions of the SFMP is to
minimize the loss of the aspen covertype (page 124).
I support the draft Plan's Management Objectives for
early‑successional cover types; specifically the objective of
precluding older aspen stands from conversion to other cover
types (yes, I am a grouse hunter!). Managing and preserving
our aspen resources provides a too‑seldom‑available
opportunity to accomplish a number of laudable goals:
Increase in number and diversity of upland species, both birds
and mammals; Generate revenue via pulpwood production;
Preserve and generate employment in the paper and timber
industries. While I appreciate the difficult task of trying to
please diverse interests with respect to forest management, it
would seem that active management of aspen and similar
cover types allow a great opportunity to meet the management
desires of hunters, birders, hikers, and the forest products
industry. I would also encourage continued support of hunting
as a recreational activity on state forest lands, and a mix of
both roaded and roadless areas within the state forest system. 4
The intent of the Natural Rivers Act is reflected in the plans and
We have the following comments and concerns regarding zoning adopted for rivers so designated under that statute. The
Section 4.1.61, and Metallic and Nonmetallic Mineral purpose of the SFMP is to implement existing rules and policy not
Development, pages 137-139. We would urge the inclusion of to impose new standards. The suggestion of a 1250 foot zone for
the Natural Rivers Act and rules a Standard for this plan. In restriction of oil and gas leases is not appropriate to this plan.
Great Lakes Michigan, our highest quality rivers and streams and their
Council, tributaries are protected by the Natural Rivers Act and the Blue
Federation of Ribbon Trout Stream Program. We propose that a Standard
Fly Fishers encompassing all of the waters protected by this act and
and Anglers program include a 1250 foot buffer that is classified as “Non-
of the Leasable” or “Leasable with no surface development” for oil 4.1.6.1
AuSable and gas development. and 5.2.3
13 DRAFT
Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Wildlife and Habitat Comments
Anglers of the Despite the language in the AuSable Natural River Plan, there is
AuSable We urge you to include specific language in the Plan to no NRC policy that “prohibits drilling for gas or oil within ¼ mile of
provide a standard requiring that all lands within 1,320 feet of any major stream". That language is not NRC policy but dates
Natural Rivers, their tributaries, or waters classified as “Blue back to 1970 oil and gas lease language. The intent of the
Ribbon Trout Streams” be classified as “Non-Leasable” or Natural Rivers Act is reflected in the plans and zoning adopted for
Leasable With No Surface Development. Such a requirement rivers so designated under that statute. The intent of the NRC is
is perfectly consistent with current Natural Resources reflected in the approved terms and conditions in state oil and gas
Commission policy which “prohibits drilling for gas or oil within leases. Oil and gas regulations 324.201 2 provide a requirement
¼ mile of any major stream. This prohibition is repeated in the to identify lakes and streams (and other environmental features)
Au Sable Natural Rivers Plan at Section IV. M. That within 1320 feet in the drilling application. This is intended for
requirement is also consistent with the Gas and Oil Operations review purposes, there is no restriction or implied setback in this
Rules at Rules R324.201 (2) (iv) (A) and R324.201 (2) (iv) (D). rule. The suggestion of a 1250 foot zone for restriction of oil and
These Rules require a permit applicant to state, among many gas leases is not appropriate to this plan. The purpose of the
other requirements, what surface waters and other SFMP is to implement existing rules and policy not to impose new
environmentally sensitive areas and Natural Rivers are within 4.1.6.1 standards.
1,320 feet of a proposed well. and 5.2.3
In many areas of the state one can not conduct a small clear-
cut of aspen for fear that the deer will not allow the aspen to re-
populate the site. Aspen regeneration is typically prolific but
can not grow quick enough to escape browsing. If you
incorporate the elk herd in Northern Lower Michigan then the
smallest size of clear-cut is not less than 40 acres. I like to
refer to deer as lawn mowers and elk as the brush hogs.
Aspen is a vital forest type for the timber industry and also Section 3.2.1 Forest Health Conditions and Trends was modified
various wildlife species. In fact, many aspen cuts on the state to specifically identify the issue of cervid herbivory. Section
forest are conducted to provide good winter feeding habitat of 4.1.2.3, Objective 14 addresses the issue of cervid populations
the cervidae species. The continued browsing on aspen and forest biodiversity, regeneration, composition and
Michigan sprouts allows other less desirable tree species to become sustainability. Section 4.1.2.2, General Objective 4 addressed
Association established or in worse case scenarios no tree species come assessment of the severity and effect of cervid herbivory on forest
of Timbermen back. 4 regeneration.
The establishment of baiting regulations is under the purview of
One aspect that has allowed an overabundance of animals is the Natural Resource Commission, and is beyond the scope of
the legalization of baiting in Michigan. Baiting does not allow the Michigan State Forest Management Plan.
nature to run its course by naturally culling the herd. Severe
winters are not having as large of an impact when the deer
herd is supplemented by baiting. Banning the use of bait
would all reverse this and allow nature to run its course. When
a wildlife population exceeds the habitats carrying capacity this
Michigan creates an atmosphere for negative impacts to not only the
Association natural resources but to the herd and association animal
of Timbermen species.
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Summary of Public Comments and DNR Responses to Draft Michigan SFMP 8/18/2011
Wildlife and Habitat Comments
4.1.1.4 p.114. This sentence’s title includes hunting, trapping, Section 4.1.1.4 also addresses dispersed hunting, while Section
fishing, etc., but yet the objectives are all related to fish and 4.1.1.5 addresses more focused areas (such as floodings) that
not the other activities. Sec. 4.1.1.5 discusses hunting. 4.1.1.4 are managed specifically for hunting.
4.1.4.1 Objective 1, p.131. We need to be careful when Concern acknowledged.
identifying or dedicating lands with rare, T & E, and species of
concern because often this results in making it easier for
collectors to know where to go for specimens. Often additional
traffic on sensitive sites creates problems in protecting these
resources. 4.1.4.1
The biodiversity desired future condition incorporates the terms
“conserves, restores, and protects native biodiversity” and “healthy
and sustainable.” A reference to what was or is must be made to
4.1.2 Biodiversity. P.117. I feel that desired future condition address what could and should be with respect to a biodiversity
needs to look forward to changes in biodiversity due to factors desired future condition. It does not state “restore to circa 1800
such as climate change, etc. and perhaps somewhat less conditions” but rather mentions a resilience to disturbances and
emphasis on what was/is. 4.1.2.1 provision of ecological and socio-economic values.
4.1.2. Objective 8, p.117. This objective concerns me, I’m not The mesic conifer restoration flows from objective 7. It is intended
an advocate for trying to establish more mesic conifer into to expand the mesic conifer for those mixed mesic conifer-
some forest types if their presence would encourage larger deciduous communities where the mesic component has been
deer populations in those areas. I suspect Objective 8 could greatly reduced. The intent is to lessen deer impacts in some
have a negative impact on Objectives 7 in some cases. 4.1.2.1 areas by dispersing the herd over more of the landscape
15 DRAFT
Summary of Public Comments and DNR Resposnes to Draft Michigan SFMP 8/18/2011
Vegetation Management Comments
Plan
Organization Comment Section DNR Repsonse
The plan does not mention the rise of wood pellets as a economical
None alternative to home heating. 3.5.1 Revised current Goal 6 in Section 4.1.2.2 to address bio-energy, including wood pellets.
We appreciated the specific objectives outlined in Section 4, Statewide
Management Direction. Among other items, your recognition of the need
for good markets and the importance of the forest products industry is a
Huron Pines key concept for land management and that was expressed clearly in the
RC&D document. 4 Support acknowledged
The four functions provided by the desired future conditions again seem
Michigan light on the economic benefits. The statement “Providing for a variety of Ecological, economic and social uses and values are all considered for sustainable
Association of forest-based products” is a broad and generic statement of which wood management using principles of ecosystem management. The SFMP states that there is
Timbermen based products may or may not be included. 4.1 no explicit order of priority among these uses and values.
In Section 3.1.3, the SFMP does provide a projection for the annual production capability
A major concern is the absence of an annual harvest level in either acres for timber harvest, that being similar or slightly more than the past decades' average level
or volume. The plan indicates an average annual harvest level which of 53,000 acres. This projection is based on trend analysis of cover types presented in the
indicates the state’s production levels will fluctuate. This makes it very same section, known influences on harvest levels, and no dramatic changes in policies or
difficult for an industry to plan on where they will acquire their needed procedures. A goal was added to Section 4.1.2.2 to prepare for harvest a minimum of
fiber. We feel the establishment and documentation of such goals would 53,000 acres per year. The SFMP is intentionally less specific than will be the Regional
play a major role in promoting and encouraging forest product State Forest Management Plans (RSFMPs) that are under development in 2008.
Michigan companies to locate in Michigan. At a minimum, this section should Specificity in the RSFMPs will be based upon detailed analysis at the local level and will
Association of mention the harvest acreage goal identified in state law. Loss to 4.1.2.2, provide a good basis for managment direction for cover types. In aggregate, the annual
Timbermen mortality could be captured if our harvest levels were greater. 3.1.3 compartment review process also provides an annual harvest level.
This plan does not address “Biomass” management. The shift in our
country and states energy needs will put added pressure on the State’s
natural resources. How will this affect our State forests and how will you
manage for “biomass”. As your numbers indicated, the volume lost to
mortality is about equal to that of harvest volumes, so one would think
we should have an ample supply of biomass. However, not having any
referenced “biomass management guidelines” we do not know how
Michigan much of the dying material would be available for biomass harvesting.
Association of Again, having annual numbers of “biomass” availability will help bring Modify 4.1.2.2 Objective 1 to reference biomass? New objective to write biomass
Timbermen new markets to our State. 4.1.2.2 guidelines?
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Summary of Public Comments and DNR Resposnes to Draft Michigan SFMP 8/18/2011
Vegetation Management Comments
It is evident that the forest planning process is being driven by the state’s
recent forest certification. We suspect that during the certification
process that the current management of state forestlands was deficient
in certain areas pertaining to either SFI or FSC certification standards. It
would be helpful to acknowledge or indicate what sections are
addressing these deficiencies within the forest plan. We understand that The SFMP is not driven primarily by forest certification, but rather by Part 525 Sustainable
these deficiencies need to be addressed however; we feel that this draft Forestry on State Forest Lands, of PA 451 which requires the DNR to develop a forest
is weighted too heavily on areas with limited or no management resource management plan and the State Forest to be certified. The SFMP is also part of
activities. A sustainable supply of forest products seems to be a low a 2001 initiative to manage the State Forest using principles of ecosystem management.
priority. It is often viewed as the means to manage vegetation to achieve Many components of the SFMP are consistent with requirements found in both Part 525
Michigan other resource-use goals or viewed as a by-product. The forest plan and the certification standards. Forest products will continue to be significant outputs of
Association of should strike a balance between the social, economic and ecological the State Forest, in concert with other resource uses and values. A major accomplishment
Timbermen benefits for current and future users of Michigan’s forest. 4 of the SFMP is that it organizes many existing programs and initiatives into one document.
This section identifies several standards and guidelines proposed for use
in management most of which have no scientifically applied research
basis while applied silvicultural guidelines that have been scientifically
developed with over 75 years of proven application are absent. It is
Michigan disingenuous to promote unproven philosophical management strategies Opinion noted. The SFMP includes existing operative standards and guidelines which
Association of as prescribed in this section to achieve sustainable ecosystem have an impact on State Forest management. The first Guidline in Section 4.1.2.2
Timbermen management goals. 4.1.2 specifies the use of DNR Silvicultural Guidelines in developing management prescriptions.
Michigan This section does not mention forest health as a monitoring tool to
Association of determine management success. Forest health monitoring is essential The forest health monitoring program is listed as a monitoring program in Section 6 of the
Timbermen to identifying conditions impacting biological diversity. 4.1.2 SFMP. Section 4.1.2.2 Guidelines 11 and 12 also address this issue.
The special emphasis to restore the mesic conifer component within the Restoration of mesic conifer components in some cover types is consistent with DNR
mesic conifer-deciduous communities. How many acres are going to be Within-Stand Retentions Guidelines and consistent with forest certification standards. In
Michigan restored and what’s the “future desired condition” for this community? many areas, this restoration is a natural process, with diversification of forest species
Association of We would hope you would review past attempts first to see if or how this composition occurring without proactive encouragement. The increasing prevalence of
Timbermen objective could be successfully accomplished. 4.1.2.1 white pine in some oak communities is a good example of this phenomenon.
The treatment of a forest stand depends upon the site, species, and desired future
condition. Even-aged management is not always the appropriate or effective silvicultural
method, particuarly as older trees begin to lose their vigor for coppice reproduction.
Michigan We question Goal 7 managing mid-successional cover types as all aged Shelterwood prescriptions are also an effective method of regeneration, both within current
Association of class distributions across the landscape. The silvics of red and white oak and other cover types. For example, the DNR has documented good oak
Timbermen oak we believe are better suited for even-aged management. 4.1.2.2 regeneration within the understory of current red pine stands.
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Vegetation Management Comments
This section calls for acquisition of large tracts of forest land for public
access. We don’t believe this should be a function of state forest The purpose of this goal is to offset or relieve pressure on state lands (keeps land as
management. While we agree that easements should be pursued for productive forest for timber, habitat and hunting values and uses). Goal 4 has been re-
Michigan access to state forest land for management, public access or trail stated as: "In coordination with planning efforts and/or partners, consider the use of
Association of corridor connectivity, conservation easements beyond those purposes conservation easements on commercial forest lands as one tool for achieving agreed upon
Timbermen should not be included in a state forest plan. 4.1.5.1 social, economic or ecological values."
We support the three goals to inventory and track the maintenance
needs of our forest road infrastructure. A concern of ours is where the Support acknowledged. The SFMP does not specify the funding mechanism for road
Michigan funding comes from to implement or achieve the objectives. We feel any maintenance. Historically, some funding has originated from recreation programs and
Association of permanent improvement to these roads should come at the expense of some maintenance is specified in Timber Sale Contracts. These funding sources are not
Timbermen the Department. 4.1.9.1 likely to change.
To "minimize the number and length of new logging roads and skid
trails." In addition to providing access to manage stands that are Fragmentation of forest resources and unauthorized ORV use are major issues in
prescribed as part of a management plan, these trails provide access for management of the State Forest. Recreational trail and pathway development is also a
Michigan snowmobiling, cross-country skiing, and hiking. Stakeholders often ask part of forest management, but not all logging roads and trails are appropriate for
Association of for more public access to state forests and this can be secured through recreational use. Recreational trails and pathways will be provided where they are
Timbermen road and trail building that is part of forest management activity. 4.1.9.3 appropriate.
As part of the requirement to become certified a provision was included
to establish 4 pilot projects to demonstrate sustainable forestry practices The pilot areas are intended to diversify adminstrative handling of activities and are not a
Michigan and management across our state forestlands; these pilot projects have forest management plan element, nor are they related to research. Pilot areas are not a
Association of been omitted from this plan. We urge the Department to incorporate certification requirement. They are, however, a provision of Part 525, Sustainable Forestry
Timbermen these pilot projects into this section of Research and Education. 4.1.12 on State Forestlands. The areas have been established as required by statute.
Another research tool that we feel is lacking within Michigan’s forest
system is the absence of Continuous Forest Inventory (CFI) Plots. CFI The DNR has proposed, and the Michigan Forest Finance Authority has accepted a
plots can provide valuable information as to how the forests are growing proposal to contract for the design and installation of CFI-like, periodically remeasured,
Michigan and responding to silvicultural prescriptions. These plots could also help plots across the State Forest System. The approval to move ahead is for the design
Association of establish the goals for fiber production and harvest as well as show if the phase only, but the concept was approved for funding up to a specified level. It is
Timbermen forest is moving towards the future desired conditions. 4.1.12 anticipated that the system can be designed and installed in the next 3 years.
18 DRAFT
Summary of Public Comments and DNR Resposnes to Draft Michigan SFMP 8/18/2011
Vegetation Management Comments
This entire section should be condensed to include only those areas that
exclude active management such as ecological reference areas, cultural
and geological sites and specific areas where active forest management
is not feasible. The remainder of the areas should be incorporated into
active management strategies within the vegetative management
section. Identifying specific special areas sends a message that
sustainable forest management does not include the ecological values of
the special management area criteria. We feel that if the current
conditions are a result of past management activities then sustainable
forest management should continue. If the Department deems it
necessary to keep this overabundance of special management areas, Most of the concepts in the categories of section 5 are not new, but rather organize many
we have two recommendations 1) that an intensive forest management existing programs and initiatives into a comprehensive structure. At this time the creation
Michigan classification be designated to demonstrate the economic return from of a Dedicated Timber Management SCA would be redundant to that concept. The
Association of intensive forest management and 2) intensive management on mitigated Management Area (MA) approach to regional forest planning also addresses this issue, as
Timbermen acres to off-set losses of productive acres to these special areas. 5 for many MAs the primary focus of managment direction will be for timber production.
The SFMP provides a projection for the annual production capability for timber harvest in
Section 3.1.3, that is similar or slightly more than the past decades' level of 53,000 acres.
Troubled that the plan does not include a sustainable harvest level, This projection is based on trend analysis of cover types presented in the same section,
despite the Department's recognition of receiving a "large number of known influences on harvest levels, and no dramatic changes in policies or procedures. A
comments" indicating this as a need area in the plan. A sustainable goal was added to Section 4.1.2.2 to prepare for harvest a minimum of 53,000 acres per
harvest level provides the measurable management target to assist in year. Through four forest certification audits, there has been a validation of DNR's
implementing these objectives, and is called for in ISO 14001, SFI, and sustainable management and the scientific basis for projections of harvest levels.
FSC certification standards. "the SFMP incorporates the expectation Maintenance of static acreages of specific cover types is not the sole essence of
Michigan that total sustainable timber harvests will remain close to current levels." sustainablility, which at its core also includes other values and reflects the continued
Forest There is no scientific basis provided for this argument, and in fact, stewardship of forest resources for the future. Also, overall mortality rates have not
Products observed increased mortality rates may indicate that current harvest 4.1.2.2, increased in the last twenty-five years, but rather show a high degree of stability at low
Council levels in some species are too low to be sustainable. 3.1.3 levels relative to other states.
The DNR has accelerated harvests of over-mature jack pine over the past ten to fifteen
Acres of old growth (nearly dead) jack-pine everywhere. Cut it, the deer, years in response to threatened insect mortality. This is reflected in the youngest age
grouse and turkey will use it if it is dense, young growth and mixed with classes showing the greatest amount of acreage. The DNR is also accelerating final
other trees. As for red-pines planted in the 1930's - still around? 4.1.2.2, harvests of red pine using established guidelines for red pine management. These
None PLEASE! 3.1.3 inititatives are referenced in the SFMP.
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Summary of Public Comments and DNR Resposnes to Draft Michigan SFMP 8/18/2011
Vegetation Management Comments
The part that was confusing to me was on page 32, 4th paragraph, third
and second to last sentence in the 4th paragraph. "The volume of cedar
is increasing with growth more than twice the losses from natural
mortality and harvest (Table 3.3). However, some growth is unused with
losses of cedar through natural mortality being more then twice the
Michigan volume that is removed by timber harvest." Can you explain this more in
Association of layman terms? I think maybe some punctuation might be missing,
Timbermen however, grammar is not my strong suit. 3.1.1 SFMP modified to combine sentences
The State Forest Plan has a specific objective in Section 4.1.2.3 to minimize the loss of
early successional habiat, of which aspen is the single largest (22%) cover type. The life
history of other cover types such as northern hardwoods (13% of the state forest) dictates
late successional management. There is a substantial range of public opinion on the
I am emailing you in support of the management of early successional desirability of managing the State Forest for old growth versus early successional forests.
forest by the DNR. This state has entirely too much old growth and While the State Forest Plan addresses both of these, other DNR efforts will impact these
managing for early successional forest will benefit not only the forests issues beyond what is in this plan. These other efforts include ecoregional planning, the
None themselves but countless animal species. 4 Biodiversity Conservation Planning Process, and the Wildlife Action Plan.
I am disappointed that the plan does not set any targets to implement
these objectives. The SFI Standard in Performance Measure 1.1,
Indicator 1.f states that forest management plans will have
recommended sustainable harvest levels and Indicator 4 mentions that
these harvest levels will be recalculated periodically. Under FSC The DNR has gone through a forest certification scoping, a full audit and three surveillance
Principle 7- Management Plans, item 7.1.d is the "Rationale for the audits and has been found to be in compliance with FSC and SFI certification standards.
annual harvest and species selection". FSC measure 7.1.d.1 states that With respect to a recommended sustainable harvest level, the text states that we expect
"Calculations for the harvest of both timber and non timber products are the annual production capability to be similar to or slightly incrase from the past decade's
detailed or referenced in the management plan...". The current draft level. This is a annual capacity as noted in our certification audit reports. A goal was
does not meet these requirements of specifying harvest levels. Industry added to Section 4.1.2.2 to prepare for harvest a minimum of 53,000 acres per year. The
needs to have an idea of the levels of managment to be expected from standards also very explicitly note acceptance of multiple plans and the Timber Harvest
the State Forests. Existing industry and potential new industry need Trends report provides additional background and specifies realistic harvest forecasts.
realistic output forecasts. As the largest forst landowner, the State We currently achieve about 95% of the prescriptions that are proposed under our open,
Weyerhaeuser should be willing to commit to increasing outputs to approach the public forest planning process. The greatest impediment to expanded treatments in recent
Co. sustainable level that our forests are capable of. 4 years has been lackluster markets and the extent of no bids on timber proposals.
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Summary of Public Comments and DNR Resposnes to Draft Michigan SFMP 8/18/2011
Vegetation Management Comments
Support for the aspen and red pine management is acknowledged. With respect to
My comments are regarding the Statewide Management Direction northern hardwoods, the text is highly qualified: "...potentially...one possible ...management
section of the plan. In this section some very good objectives were set by conducting inventory, preparing sales, and monitoring much of the forest on a continual
forth including: the regulation of age classes of aspen; the desire to basis... The DNR does not have the resources that would enable a shift to a continual
minimize the losses of the aspen forest type where it is well suited to the management cycle in the near-term, nor would it be necessarily desirable to do so, but
site; the objective to balance age class distribution of the red pine such a shift may be possible in the future."
resource; and the recognition that our northern hardwood forests would
be better managed on a continuous basis rather than the 10 year
Weyerhaeuser compartment review process. These objectives have a multitude of
Co. benefits to foresthealth, wildlife, and to the forest products industry. 4
Keen Forestry
I'm concerned at the states willingness to give in to environments such
as the Sierra Club. Specifically I'm concerned about several issues such
as the long term management of Red Pine instead of Clear‑cutting some
of the stands at the end of the rotation; some areas are just cut heavily
and are allowed to have nature take its course. In most cases the
stands that I have seen will convert to low quality hardwood stands,
which the state has more than enough of. I think these stands should be
planted back to red pine it is a great source of income for the state but
also creates jobs within the state processing the logs/power
poles/pulp/posts/etc. The state should be aggressively managing these The DNR has a specific initiative to address the management of red pine (Guidelines for
stands for red pine and looking to convert other stands to pine stands. 4.1.2.2 Red Pine Management), which is referenced for use in Section 4.1.2.2.
Keen Forestry
The DNR is spending money to plant Hemlock/white pine if I'm not
mistaken in the UP of Michigan. I think this is a great waste of money.
These habitats on private ground they are planting will switch hands and
probably never be managed into a stand viable timber to help the future
of Michigan's Economy. This money should be used to plant red pine
plantations on private ground which if you look at the result of the CCC
camps which planted thousands acres of red pine created a jobs in Planting activities on private lands are out of the scope of the SFMP. The SFMP does
Michigan. First when they were planted but in the future when these provide a guideline in Section 4.1.2.1 for restoring mesic conifers for purposes of
stands needed to be thinned there are several sawmills and thousands 4.1.2.1, biodiversity. The DNR has a specific initiative to address the management of red pine
of jobs including some in the DNR because of what was done years ago. 4.1.2.2 (Guidelines for Red Pine Management), which is referenced for use in Section 4.1.2.2.
21 DRAFT
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Vegetation Management Comments
We feel that the language used throughout the plan does not reflect
strongly enough the impact the cervidae species are having on the state
forest. We believe the current deer population is too high and if it is not
reduced they will continue to have a significant impact on whether the
“future desired conditions” will be meet by the forest management plan.
One reason for the failure of establishing the Mesic Conifer forest type is
the amount of deer browse on the planted seedlings and/or regeneration.
We are concerned with the effort to seek the Mesic Conifer forest type
as a future desired conditions when deer populations in the region are
high. Northern hardwood stands in areas where the deer population is
high are void of any regeneration. This can lead to a stand conversion to
a forest type that may not be desirable for other wildlife species. Our Section 3.2.1 Forest Health Conditions and Trends was modified to specifically identify the
beech and ash resources are not highly palatable to the deer and other issue of cervid herbivory. Section 4.1.2.3, Objective 14 addresses the issue of cervid
Michigan cervidae and are starting to become a strong presence in our forest 4.1.2.2 populations and forest biodiversity, regeneration, composition and sustainability. Section
Association of understory. Theting of toxicity in cyanobacteria by cellular assays; A and 4.1.2.2, General Objective 4 addresses an assessment of the severity and effect of cervid
Timbermen sensitive bioscreen for detection of cyclic peptide toxins 4.1.2.3 herbivory an forest regeneration.
In every instance where age-class data was presented, it was presented
in 10-year increments, with a final class of “100+”. Most tree species in
Michigan have a natural ecological maturity and life span well over 100
years. The data as presented seems to indicate that this is the natural
limit for these trees’ life. In essence, this is presenting an artificially
truncated age-class distribution. The Department should not present
even distribution across an artificially truncated age class, encompassing
a minority of the natural life span of the species, as “evenly distributed”.
We would ask that in future drafts, the actual age classes for each
species be described. If the Department wishes to manage longer-lived
species for less than 1/3 - 1/2 of the species’ natural life span, the
Department should describe this and make the case to justify it. This
type of classification is especially troubling in the context of goals such
as Goal 1 under 4.1.2.1 Biodiversity. This goal includes “balanced age 4.1.2.1 Age class distribution tables in the SFMP do not truncate age class distributions, but rather
class” in the goal. This implies balance across all age classes, not and sum age classes greater than 99 years into one 100+ year category. Where cover types
Sierra Club across an artificially truncated set of age classes. 4.1.2.2 exist as uneven-aged stands (e.g. northern hardwoods) this data is provided as well.
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Vegetation Management Comments
Rather than describing the Standard, the Draft simply cites another
document. This makes it very difficult for the reader to have any idea
what actions will actually be taken to implement the Goals, Objectives,
and Standards. Many of these documents are available on the
Department web site. However, many of them are not available on the
Department web site, nor any other web site. Nor are the documents hot
linked in the .pdf file. Most of the documents cited as Standards are
relevant to the Goals and Objectives, but also contain large portions
which are not within the scope of the Goals and Objective. It would be
both easier for the readers (including managers who will need to
implement this Plan) to understand, as well as more accurate, to replace Where possible, the DNR will strive to provide links to referenced documents once the
Sierra Club the citation with the relevant language from the citation. 4 and 5 plan is approved and posted on the internet.
We applaud the Department’s direction in determining suitability for
species based on site conditions. However, we have concerns about the
Kotar system, which relies far too heavily on vegetative communities and
past management to determine site-specific suitability. Instead, we
strongly suggest using the Barnes-Albert-Denton system, which much
more significantly takes into account factors such as landforms, soils,
slope, aspect, and other factors which are less dependent on past
management to produce suitability determinations. That said, the general
tone of the discussions regarding over type distribution clearly indicates
an intent to keep cover type distribution very similar to existing The DNR has invested a substantial amount of funding to complete the Kotar
distribution. This is particularly troubling in the case of early successional Classification system for Michigan, and to train field staff on its field application. The DNR
species such as aspen, which do not naturally replace themselves on also utilizes Albert's Regional Landscape Ecosystems of Michigan in forest and
Sierra Club most upland sites. 4.1.2.2 biodiversity planning.
Given that past management has striven to unnaturally perpetuate early
successional species, the current composition and distribution of species
across state forest lands is skewed strongly toward these species. This,
however, is in conflict with #1 in the Desired Future Condition in 4.1 of
the Statewide Management Direction, which indicates that the goal is to
“Sustain fundamental ecological processes”. Since on of the most
fundamental ecological processes on forest in Michigan, especially in a
system skewed as far towards early successional species as is currently
the case. Native biological diversity, natural ecological processes, and In the context of ecosystem management, the issues for maintenance of early
balanced age class and seral stage distribution all argue against successional species (particularly aspen) is not exclusively a matter of ecological
maintenance of early successional species on the same sites where they processes. Values for economic (fiber) and social (habitat) pruposes are also factors that
Sierra Club now exist. This is the very nature of succession. 4.1 have bearing upon the maintenance of early successional cover types.
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Vegetation Management Comments
P. 1 - The groups whose interests are solicited include local communities The text in this case refelects the language of Part 525, Sustainable Forestry on State
and 3 industry groups. No mention is made of the general public or other Forest Lands, of the Natural Resource and Environmental Protection Act, 1994 PA 451, as
Sierra Club interest groups. amended.
P. 117 - 4.1.2.1 - Biodiversity - We applaud Goals 1 and 2, and note that
they require significant movement in the direction of larger amounts of
late successional species, and away from the current “aspen uber alles”
Sierra Club management direction. 4.1.2.1 Support acknowledged.
P. 119 - 4.1.2.2 - Forest Resources - when describing stakeholders, it is
inappropriate to singe out one stakeholder, the timber industry, at the
Sierra Club expense of all others. 4.1.2.2 DFC modified to only refer to stakeholders in general.
P. 120 - 124 - Objectives for Specific Cover Types . 2. Aspen - The
objective describes management for aspen on sites where aspen is well
suited, without any analysis (using Kotar or others) of what other species The objective retains aspen on sites where it is well suited and specifies succession to
are also well suited for the site. This analysis needs to be done, in the other cover types where it is poorly suited and where the site is succeeding to another
context of 4.1.2.1 Goals 1 and 2, which preclude retaining aspen on cover type. The DNR believes that this is consistent with Section 4.1.2.1 goals to maintain
Sierra Club current aspen sites. 4.1.2.2 a variety of succssional states - in this case for aspen.
P. 120 - 124 - Objectives for Specific Cover Types. 7. Red Pine -
Balancing the age class distribution at 25-30,000 acres per class would
require 625,000 acres of red pine in the 25 10-year age classes
appropriate to red pine. We advocate converting aspen acreage to make The SFMP is not intended to be that prescriptive. Such details will be in Regional State
Sierra Club up the difference. 4.1.2.2 Forest Management Plans.
The 100-year roational age reflects market demand for stands that have been primarily
P. 120 - 124 - Objectives for Specific Cover Types. 21. White Pine - we managed for timber value. The DNR recognozes that not all white pine stands are
find specification of a statewide rotational age to be inappropriate. We managed for this purpose. Objective modified as follows: “Where biodiversity goals to not
strongly find a rotational age which is less than 1/3 the life span of a preclude, increase regeneration harvests of the white pine cover type as planted stands
Sierra Club white pine. 4.1.2.2 reach the 100+ year rotational age class over the next decade.”
Sierra Club P. 123 - 7 - Early successional species sequester virtually no carbon. 4.1.2.2 The DNR believes that all trees sequester some carbon as living biomass.
P. 123 - 8 - The measure of sustainability described is perhaps the
Sierra Club poorest measure known if attempting to meet Goals 1 and 2 in 4.1.2.1. 4.1.2.2 The statement is but one measure of sustainability.
Section 4.1.6.1 - Oil, Gas, and Metallic and Nonmetallic Mineral
Development, pages 137-139. We applaud the Desired Future Condition
and Goal #1, with the emphasis on resource protection. In addition, we
would urge that the Plan include a Standard requiring that all lands within
1250' of Natural Rivers, their tributaries, or Blue-Ribbon Trout Streams Support acknowledged. The purpose of the SFMP is to implement existing rules and
be classified as "Non-Leasable" or "Leasable with no surface policy not to impose new standards. The suggestion of a 1250 foot zone for restriction of
Sierra Club development" for oil & gas development. 4.1.6.1 oil and gas leases is not appropriate to this plan.
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P. 139 - 4.1.6.2 Unique Geologic Formations. Goal 1 is laudable. It is
unfortunate that the Department felt free to disregard this Goal in the Support for the goal is acknowledged. The SFMP is not intended to be prescriptive
case of Eagle Rock, the only exposed bedrock on the entire Yellow Dog regarding the designation of specific features. Such details will be in Regional State
Sierra Club Plains. 4.1.6.2 Forest Management Plans.
In Section 3.1.3, the SFMP does provide a projection for the annual production capacity for
timber harvest, that being similar or slightly more than the past decades' average level of
53,000 acres. This projection is based on trend analysis of cover types presented in the
same section, known influences on harvest levels, and no dramatic changes in policies or
procedures. A goal was added to Section 4.1.2.2 to prepare for harvest a minimum of
53,000 acres per year. The SFMP is intentionally less specific than will be the Regional
Numbers to express annual capability and productivity are not stated; State Forest Management Plans (RSFMPs) that are under development in 2008.
BUT, if trying to encourage investment in the forest products industry Specificity in the RSFMPs will be based upon detailed analysis at the local level and will
including production capacity i.e. loggers, wouldn’t some numbers be of provide a good basis for managment direction for cover types. In aggregate, the annual
value to prospective investors? compartment review process also provides an annual harvest level.
Noted that expected acres to harvest will remain at about 52,000 acres.
But I suspect that volumes per acre may decrease and more higher
quality product may be harvested in the future in at least the hardwood Volumes per acre for red pine and some other species are expected to increase, as
and red pine types. 3.1.3 discussed on Page 41 of the SFMP.
Does/should the plan indicate that management objectives may be
somewhat different on tax-reverted lands than on lands acquired for Section 4.1.1.5 of the plan is intended to address these areas. Many of these areas are
other purposes with dedicated funds? also addressed in Section 5.2.6 of the plan.
p.60 Aspen. I like the increased harvest in the 30-39 year age-class as
that is when a lot of “natural” mortality occurs in many stands. Perhaps
some sort of “thinning” strategy should be investigated that would
increase the rate of growth and the volume of higher value product than
pulp. Utilization of biomass harvesting may make this more feasible than Support acknowledged. Goals and/or Guidelines for biomass utilization were added to
in the past. Section 4.1.2.1, 4.1.2.2 and 4.1.2.3 of the plan.
4.1.1.2 Recreational trail objectives. P.111 Add an objective that would
create harsh economic penalties for damage and destruction of trails
and other attributes of the forest community, e.g. penalties be
commensurate with game law penalties. 4.1.1.2 The establishment of enforceable law is beyond the scope of the SFMP.
Objective 10, p.111 Would “visual sensitivity” be a better term than
“aesthetic values”? Visual quality is more measurable than is aesthetic
value. This would also make a connection to visual sensitivity in the
Right to Forest law. 4.1.1.2 Public values are a consistent term used throughout the plan.
Standards p.112. Should the Right to Forest law’s Generally Accepted Added new objective to Section 4.1.12 to promote Generally Accepted Forest
Forest Management Practices be considered as standards? 4.1.12 Management Practices.
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The intent of designating “all areas managed primarily for hunting as special conservation
areas where hunting is the overriding resource management value” is NOT to exclude
4.1.1.5 Objective 1, p.115. Depending on the acreage involved, I feel that other management opportunities, but rather to bring more clarity internally and externally
this objective may be too exclusive of other management opportunities. 4.1.1.5 where such places exist. A SCA does not preclude other management.
4.1.1.5 Guideline, p.115 Add a guideline that would encourage
cooperation with DEQ to consider wetland diversity when engaged in
wetland mitigation projects and some state land could be used for The DNR does not have the resources become involved in the DEQ commerical wetland
mitigation projects. 4.1.1.5 mitigation banking program.
4.1.1.6 p.116. I would prefer this section to be couched in terms of visual The DNR prefers to retain the word aesthetic. The right to forest Generally Accepted
sensitivity rather than “aesthetic character”. The Right to Forest GAFMPs Forestry Management Practices are voluntary guidelines for private lands, whereas
should be included in the standards. I feel that the criteria for visual standards specify mandatory policies. The intent of the GAFMPs are already contained in
sensitivity are more measurable than is aesthetic character. 4.1.1.6 other DNR guidelines.
Timber sale contracts already implement prescription decisions made through the
4.1.2 Guideline 9, p.119. Modify timber sale contracts to encourage tip- compartment review process, which include measures from Within-Stand Retention
up mounds where visual sensitivity is not an over-riding concern. 4.1.2.1 Guidelines.
At this time, “a stable revenue source to the state” is not a DNR statutory or mission goal
and could be construed to be in conflict with an emphasis on sustainability, markets,
4.1.2.2. Forest Resource Goals, p.119. Add a goal which states that the responsiveness to stakeholders, and forest certification. In contrast, the stated second
forest resource will be managed to produce a stable revenue source to goal in this section states, “Actively manage the state forest for stable, long-term,
the State which reflects the increased production of higher value sustainable timber production.” Two additional goals were added to address timber
products and increased fiber utilization. 4.1.2.2 production, which is the basis for the revenue source.
Objective 1, for aspen, p.120. Perhaps we need to look at aspen as a
biomass source and also lumber and composite material and not
primarily as a pulpwood, i.e. paper, source. This could better utilize the
fiber currently lost in many stands beginning in mid-age and could help
reach sawlog size quicker. This might be a tool to use in balancing age- An objective was added to Section 4.1.3.1 to develop biomass harvesting guidance to
class distribution. 4.1.2.2 silvicultural prescriptions. Goal 5 in Section 4.1.2.2 was also modified to address biomass.
Objective 5, p.120. I’m not an advocate for encouraging hemlock in high
quality hardwood stands. I also question nurse logs for regeneration
purposes as in my experience it is quite rare to see a good quality tree Within-stand species diversity and downed woody debris are objectives of DNR Within-
survive very long when it had its beginnings on a nurse log or stump, i.e. Stand Retention Guidance. Nurse logs are part of the natural life history of many hemlock
stilted trees. 4.1.2.2 trees.
Oak management does differ depending upon the species and site. Further research and
guidance on this is forthcoming which will enable oak objectives to be more elaborate in
the future; at this time, the general direction is to attempt to retain oak and balance age
Objective 8, Oak, p.121. Perhaps the Objectives need to distinguish classes through more regeneration cuts in the 70-90 years old oak. Opportunities for
between the oak species somewhat, e.g. the way one manages for differentiation of oak management will be presented in Regional State Forest Management
Northern Red Oak vs. Pin Oak might be quite different. 4.1.2.2 Plans.
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Objectives 13-14, p.121. I’m concerned about Fir. To me it is a relatively Opinion acknowledged. Fir is a codominant species in many forest stands and present in
short-lived weed and can out-compete other plant community species. I the understory of many others. Fir is also a component of within-stand species diversity
do feel it should be managed as important species. 4.1.2.2 that is addressed in DNR Within-Stand Retention Guidance.
Objective 18, p.121. Black Spruce---should we look at the role of tip-ups As descibed in the objective vegetative reproduction through layering would be achieved
as a tool for regeneration? 4.1.2.2 by soil contact of branches, which may involve "tip-ups".
Objective 20, Swamp conifers, p.121. My experience indicates that
swamp conifers regenerate quite well and quickly following strip Opinion acknowledged. The DNR acknowledges that there are multiple means of
regeneration harvests and fire may not be necessary to get good stand regenerating swamp conifers, and the judicious use of fire and vegetative reproduction are
replacement. Even cedar regenerates well until the deer find it. 4.1.2.2 but two.
Objective for Stake Holder Relations, p.122. Add an Objective that would
support the Master Logger Certification process as a tool to assist in This specific suggestion is beyond the scope of the plan, but Stakeholder Relation
improved private non-industrial landowner management of small Objective 3 provides that the DNR will “Participate in forest certification, wood product use,
ownerships, i.e. <100 acres. 4.1.2.2 and marketing programs and meetings.”
This specific suggestion is beyond the scope of the plan, but Stakeholder Relation
Standards, p122. Add a Standard that references the Michigan Master Objective 3 provides that the DNR will “Participate in forest certification, wood product use,
Logger Certification Program. 4.1.2.2 and marketing programs and meetings.”
The broad array of considerations and multitude of ecological constraints on timber
harvests make ongoing management activities socially and economically acceptable. This
Plan does indeed emphasize the ecological sensitivity which is applied in our management
Guideline, p.123. The Guidelines seem to be heavily skewed toward activities, which in turn enables ongoing positive social and economic impacts. The latter
ecological considerations. I feel more emphasis needs to be placed on are addressed more in the “Goals” and “Objectives for Stakeholder Relations”
recognizing the impact of management activities on sustainable human subsections. They will also be major considerations in the Management Area designations
communities at local, regional and state levels. 4.1.2.2 of the ecoregional planning efforts.
Guidelines 9 & 11, p.123. I would prefer to use the terms “regeneration”, Clearcut is the most commonly understood term; even the Sustainable Forestry Initiative
“salvage” and “sanitation” instead of “clearcut”. 4.1.2.2 with its ties to industry uses this terminology in its annual reporting.
4.1.2.3 Objective 12, p 125. Don’t be afraid to harvest cedar to keep the Comment acknowledged. Greater treatments in cedar will be dependent upon a common
resource healthy. I have seen an awful lot of real junky cedar on various perception of the desireability of such treatments. In turn, that will be dependent upon
ownerships that people were attempting “saving”. 4.1.2.3 markets, allaying wildlife concerns, and social acceptability.
4.1.3.2 Objective 9, p129. Also manage for water production. 4.1.3.2 Attenuated flow of water is an implied product of managing functional wetland resources.
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The focus of the plan seem to be an “emphasis on balancing age
classes” which will perpetuate a disturbed, compositionally and
structurally simplified landscape that is not reflective of Michigan’s native
forest habitat (again see section 3.3.1). Creating a forest landscape Section 4.1.2.2 Objective 2 retains aspen on sites where it is well suited and specifies
based primarily on an even distribution of acres to each age class up to succession to other cover types where it is poorly suited and where the site is succeeding
economic rotation age, and focusing on cutting stands older than this to another cover type. The objective strives to address competing desires for maintenance
Mackinaw age will have a very negative effect on the continued recovery of our of early successional forests for fiber and habitat and also provision of later succession
Forest Council state forests. 4 forests for purposes of landscape diversity.
Mimicking natural processes (disturbance) and maintaining composition Goal 1 and Guideline 9 of Section 4.1.2.1 addresses the encouragement of natural
and structure of native ecosystems, is not specified in a concrete way, disturbance processes. Guidelines are also provided in Sections 4.1.2.1 and 4.1.2.2 to
although it is a directly conflicting DFC in section 4.1.2.1. The DFC in implement Within-Stand Retention Guidelines for increased structural and compositional
4.1.2.1 seem to call for restoring, enhancing composition, structure and diversity of forest stands. Area regulation is not the goal for all acreages and age classess
process, yet the deliverable objective statements in 4.1.2.2 make it clear of forest types, and several goals in Section 4.1.2.2 provide qualifications (e.g. for habitat)
that area regulation at short time frames will drive the future condition of 4.1.2.1 upon the balancing of age classes. With the exception of some SCA, HCVA categories
Mackinaw the forest. Natural processes will be truncated and the landscape will be and and the ERA categories there is no expressed goal to maintain the entire State Forest in
Forest Council held in a disturbed unnatural condition across most of the State Forest. 4.1.2.2 an undisturbed natural condition.
The desired future conditions (DFCs) that are supposed to guide
management of the State Forest system are vague and so non-specific
as to be meaningless. They are just feel good bromides, that give little if
any guidance. DFC’s for MNFI or Kotar communities types are non-
Mackinaw existent. There needs to be DFCs that tie together landscapes, natural
Forest Council communities and this plan into a coherent whole. 4 Opinion noted.
1.4.2 Strategic Goals, SFMP pg 7. This strategic goal is just unintelligent!
A plan must set priorities, or it's not a plan, you can not have equal
emphasis. The forest, and it's ecology, and it survivability, make
possible any social or economic values that are sustainable. Ecological
viability is the foundation of sustainable society, not an equal element to
be balanced with short term social or economic use. (see your own
definition of ecosystem management) The DNR seems to fundamentally
lack an understanding of ecosystem management, which leads to a
SFMP that is 1) not sustainable, and 2) is full of unspecified tradeoffs The DNR agrees that under the concept of ecosystem management the condition of the
that are not qualified, nor quantified. The DNR claims that tradeoffs are ecosystem sustains the production of all uses and values. However, ecosystem
Mackinaw inevitable, but never explains in detail what they are. For more details management doesn't mean that social and economic uses and values are over-ridden by
Forest Council see our previous comments that have received no substantial response. 1.4.2 ecological values.
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Further the DNR claims that Michigan's forest's can not be allowed to
continue their recovery from first spasm of uncontrolled logging. You
claim that social and economic forces require that the State Forest be
largely maintained in it's current heavily disturbed second growth
condition. The all mighty "balanced aged classes" (on very short
rotations) is your over riding mantra for management. What is the basis
of this claim? Can you offer actual data proving this assertion that
recovery is precluded? Do you have data showing that the people of
Michigan do not want their forest fully restored? (the social element) Did
our original forest have less biomass per acre? Were they less healthy? The DNR received a substantial number of public comments against restoration of the
Mackinaw or resilient? (economic element) What is the basis for this claim that full State Forest to "circa 1800" conditions. The DNR also received a substantial number of
Forest Council recovery is precluded by current social and economic realities? 4 comments advocating restoration. There is no public consensus on this issue.
Lastly, in response to comments, and on page 109 of the SFMP, it is
stated that the DFC's were developed using an iterative process
involving the public. We are unaware of any such process! The first
knowledge of the SFMP was the release of the "draft" plan of over 200
pages and nearly complete. There was no process where the public had
a chance to iterate on DFC. The only public meeting was a facilitated
(controlled) meeting without any real chance to debate the DFC or any
other part of the plan. There was no response to our comments on the
disjointed nature and lack of vision in the DFC's included in the draft
Mackinaw SFMP. Therefore these statements are false, and disingenuous. Please
Forest Council remove or clarify these assertions. 4.1 Sentence revised to simply reflect public review of DFCs.
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