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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




                                                                                  7                                                              DRAFT
                               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.
                                                                                         14                                                                         DRAFT
                                 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




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                                                                                      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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                                                                                       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.




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                                                                                        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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                                                                                      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.




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                                                                    Summary of Public Comments and DNR Resposnes to Draft Michigan SFMP                                                                 8/18/2011
                                                                                       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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              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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Description: Sustainable Forest Management Concept document sample