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The Friends Network Comments Regarding the
DCR Landscape Designations Final Draft
The Forest Futures Visioning Process
In response to concerns about aggressive commercial timber harvesting in state forests and on parkland from Friends groups and other conservation-minded organizations, the Massachusetts Department of Conservation and Recreation (DCR) convened the Forest Futures Visioning Process (FFVP) to develop a new vision for the management of forested public lands in the Commonwealth.
As part of the FFVP, DCR formed the Technical Steering Committee (TSC) and Advisory Group of S holders (AGS). Friends groups representatives had a hand in the selection of the TSC and AGS. Both the TSC and AGS included Friends groups’ representatives. Throughout the process, Friends groups pressed DCR to:
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Develop site-specific Resource Management Plans prior to allowing timber harvesting in state forests and parklands
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Ensure that citizens have a greater role in determining which public lands are logged and what methods are used
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Conserve more land by reducing commercial logging in state forests and parks
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Create patch reserves to protect valuable resources within woodlands and parklands
While progress has been made on these issues, concerns remain. Citizens' comments on the Designations Draft will effect whether specific DCR lands become a woodland, reserve or park, and will drive how those properties are managed for many years to come.
Visit use the links below to learn more about the FFVP and proposed designations for DCR lands.
A full description of the implementation process, including maps and lists of properties and their designations, can be found here: http:www.mass.gov/dcr/ld/landscapedesignations.htm
Landscape Designation for DCR Parks and Forests: Selection Criteria and Management Guidelines Final Draft (pdf) - http:www.mass.gov/dcr/ld/mgmtguidelines.pdf
List of Massachusetts forests and parks with proposed designations - http://www.mass.gov/dcr/ld/ld_list.pdf
What’s Right about the DCR Landscape Designations?
Friends groups applaud the DCR for:
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Carrying out the Forest Futures Visioning Process, opening the door to significant improvements for the future management of public forests and parklands;
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Spending a lot of time and resources on the FFVP, reaching out to the public in ways they have never done before, trying to reconcile competing interests in public lands;
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Moving in the right direction in the conservation and protection of forests;
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Efforts to ensure that parklands, reserves and woodlands are clearly defined and managed in accordance with their predetermined designations;
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Formation of the Forest Reserves Science Advisory Committee, consisting of conservation biologists and forest ecology experts—if the purpose of the Committee is to also review woodlands selection and management and oversee the formation of large reserves, wilderness areas, and wildlife corridors;
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Willingness to offer dead or down trees for the "home fuel wood program" to provide low-income families with firewood, if the program is carefully monitored and the wood is for personal use and not resale;Intention to allow only passive recreation in the reserves;
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New guidelines designed to promote uneven-age management;
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Applying Land Stewardship Zoning to individual properties through the RMP process by incorporating site-specific information;
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Efforts made toward restoring public trust.
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Intention to foster partnerships and encourage volunteer involvement in the care of our forests and parklands;
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The requirement that the Commissioner approve openings greater than 1/3 acre when harvesting timber in woodlands;
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Forestry licenses and the continuing forestry education requirement for all DCR foresters;
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Implementing woodland forestry practices directed at protecting forest productivity through sustainable forestry;
Friends Network comments for your consideration
1. Only 112,019 acres of DCRs’ 311,000 acres of forestlands will be conserved in fragmented Reserves! Do you think that is enough? See the DCR MAP showing how little state land will be designated 'reserves.'
2. No rush with final designations! The TSC said DCR should “solicit expert and broad public input before finalizing the designations.” DCR needs to adjust the current Draft Landscape Designations to reflect public input (received through August 26) and resubmit the Draft for public review before applying the final designations to our forests and parks. The FFVP has been an enormous undertaking that will affect future generations. Premature adoption of designations will undermine the process. We need to make sure that both scientific expertise and public input have made a difference in the final designations!
3. Add in the wishes of the community when designating woodlands. DCR is using “Ecological Land Units” (ELUs) to identify what lands within the various ecological types should become reserves. The decisions are based on similar topography, geology and elevation (Landscape Designations Draft (LDD) p. 4). These three parameters are by no means adequate. The human criterium, i.e., how people feel about the land—our sense of beauty, perception of place—counts too. Already communities are requesting alternative designations for many of the properties slated to become woodlands. So, while science is important, local people who love and value their forests deserve a say in whether their forests become a woodland, reserve, or park.
Additional information: Ecological Land Unit Groups (ELUs) used for Proposed DCR Landscape Designations
4. RMPs first. DCR prepared Forest Resource Management Plans (FRMPs) at the district level, covering the Northern Berkshire, Central Berkshire, and Southern Berkshire District, and also the Western Connecticut Valley District. However, DCR understands that FRMPs are only a component of Resource Management Plans (RMPs). The DCR should not assign designations or change management before it completes RMPs with the public input involved in developing RMPs.
Forest management planning and FRMPs are an important component of the overall
framework of DCR’s Resource Management Planning (RMP) Program. DCR’s RMP
Program is based upon M.G.L. Chapter 21: Section 2F, which requires DCR to develop resource management plans for all agency reservations, parks, and forests…. FRMPs prepared by the Bureau of Forest
Fire Control and Forestry will be integrated into RMPs, as RMPs are prepared and
completed for each DCR reservation, park, or forest.
5. No broad-brush approach when assigning designations. All DCR lands will end up in one of the three categories: reserves, parks, or woodlands. However, the TSC found that many properties fit criteria for more than one designation. Best practices dictate that properties qualifying for more than one designation should default to the most protective category. The DCR should acknowledge that some properties are suitable for mixed designations and let science rather than public pressure, dictate the designations. Why not take a careful look at each property and assign mixed designations as appropriate, including patch reserves for woodlands and parks?
6. Protected vs. non-protected—why a 60/40 percent split? The Patrick Administration promised at least 60% of DCR forested lands to become protected from commercial logging, and the TSC recommended “adoption of an Ecosystem Services Model to guide forest protection.” Neither requested that these designations conform to exact percentages. The exact 60/40 spit and locations for some of the designations suggest that some decisions were made arbitrarily. We need a thorough evaluation of each property before assigning the designations.
7. Ten years is too long to reclassify lands. Ten years is too much time to wait before DCR reviews and assesses the landscape designations and the management guidelines included in the Draft! (LDD p. 9) DCR needs to reevaluate designations immediately when information runs contrary to the landscape designations implemented through the FFVP.
8. Where are the large reserves of the desired 15,000-acre size? The TSC stated:
Large permanently protected forest reserves of 15,000 acres or more in the state‘s major ecological settings will be a prominent feature of the DCR forests. Initial designations of reserves may include areas smaller than 15,000 acres depending upon available land, but it is anticipated that these will be added to at a later time. In regions where no block is of the desired size, the largest available should be selected. ( Recommendations of the TSC, p. 8)
The Landscape Designations Draft does not have any Reserves as large as 15,000 acres. While there is great potential for creating large reserves, several of the largest properties have been placed into the Woodlands category or are divided into Reserves and Woodlands. DCR needs to work harder to delineate the recommended larger reserves.
9. Lack of a plan for building connections of core and critical habitats. DCR used the guidance provided by the BioMap2 in evaluating forests. However, DCR ignored Biomap2 calculations for Core Habitat and Critical Natural Landscape conservation, which calls for preserving 861,000 acres that are "essential to safeguard the diversity of species and their habitats, intact ecosystems, and resilient natural landscapes across Massachusetts ." Bio Map2 Summary, p. 4 (http://www.mass.gov/dfwele/dfw/nhesp/land_protection/biomap/biomap2_summary_report.pdf).
If ensuring biodiversity is the goal, DCR needs to consider the potential for incorporating privately held lands with conservation value when designating reserves. DCR should form a plan to create wildlife corridors throughout the state and look for opportunities to connect conservation lands in Massachusetts to reserves in neighboring states.
10. No wilderness in our future. DCR is proposing not to designate any wilderness areas at this time, but to review reserves every five years for identification of areas that are suitable for the wilderness designation. Wilderness areas and old-growth forests can be created. Forests can be managed to create both. Why not identify areas now where altering management strategies within woodlands and reserves will one day result in creation of wilderness?
11. No provisions for an equivalent of patch reserves. The TSC recommended “Level 1” silvicultural management “for protecting ecologically sensitive or culturally significant patch reserves.” The Designation Draft confuses things by stating that DCR “will identify sensitive resources and apply specific management guidelines to protect them [patch reserves] by categorizing them as Zone 1 in the LSZ (Landscape Stewardship Zoning) system during the RMP (Resource Management Planning) process.” (LDD, p. 6) Patch reserves should be included in the initial Landscape Designations, as recommended, to define known special areas within parklands and woodlands in need of greatest protection.
Comparison of Landscape Stewardship Zoning Guidelines with BioMap2 conservation strategies prepared by Mike Ryan is available here: http://networkingfriends.net/graphics/zone1vspatchreserves.pdf
12. Director of Forest Stewardship needs help. The TSC recommended that the DCR Commissioner appoint a Director of Forest Stewardship (DFS), which he has done. However, the DFS’s position was supposed to be given to a conservation biologist. Since DCR is not following the directive of the TSC in this matter, we suggest that the duties of the proposed Forest Reserves Science Advisory Committee, consisting of conservation biologists and forest ecology experts, be expanded to include advice on woodlands and assistance with the selection and management of reserves.
13. Lack of plan for off-highway vehicle (OHV) regulations enforcement. The DCR’s sustainable forestry certification was jeopardized because of illegal OHVs rampaging through lands where they don’t belong, degrading huge swaths of open space, prime forestland, and beaches. While the Draft indicates that DCR will use the OHV coarse and fine filter criteria it developed in 2007 for siteing OHV trails to minimize impact on natural resources and confllicts between different user groups, this is not enough. We need a statewide, comprehensive OHV regulation enforcement plan to control illegal OHV riding. See the Friends Network Off-Highway Vehicle Regulations Enforcement and Management Plan Recommendations.
14. How will demonstration forests benefit the public? The Designations Draft does not provide enough information about how demonstration forests will benefit private landowners or the public. We need to know what kind of interpretation program DCR will develop for the model forests it proposes. Will it include a history of land use, benefits to wildlife, negative aspects of overpopulation of wildlife, changes in wildlife with habitat change, need to protect certain resources, impact and control of invasive plants, etc.? What form will interpretation take? Is it going to be just signage, or will demo forests include interpretive tours where people can intract and ask questions? We need to know.
Thank you for taking the time to speak up for our forests and parks!
The Friends Network Facilitators
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