Kinnikinnick Chapter Of The Idaho Native Plant Society

 

May 22, 2003

 

USDA Forest Service

ATTN: KIPZ Revision Team

1101 U.S. Hwy. 2 West

Libby, MT 59923

 

Planning Team:

 

Our organization promotes the conservation of native plants in the Idaho Panhandle. We are a chapter of the Idaho Native Plant Society, with over 100 members in Bonner County. Our Chapter did not exist when the previous Forest Plans were developed, so we represent a public interest focused on the flora of IPNF and KNF new since 1987. This letter is our third correspondence on the KIPZ Forest Planning process. Our priorities remain unchanged. We appreciate that some, like noxious weeds and populations of sensitive plants, are represented in the Technical AMS.

 

1. However, the technical AMS Vegetation section makes no mention of commercial harvesting of huckleberries, mushrooms, beargrass and other living resources. Our literature search on harvesting of beargrass (Xerophylum tenax) reveals a paucity of research on sustainable harvesting methods for this plant. We infer from this lack that other species also require study to ensure sustainability in the face of increasing harvests. We ask you to specifically include management for sustainability of these resources in the Forest Plan. We refer you to: http://www.fs.fed.us/pnw/sciencef/scifi50.pdf At this site is the Forest Services PNW Research Station summary of what is known of sustainable understory harvest. Although our study is incomplete we know that an array of plants (up to 100 species in the Pacific Northwest, according to PNW) are "wildcrafted;" generally without permit on FS lands and with forest managers lacking data to understand what actions are required for a sustainable harvest. It is important to include research and management of this multi-faceted resource in the new forest plans. 

 

2. Noxious weeds are noted in the AMS to be a "daunting," fast spreading problem. They represent a reason for revising the "Vegetation" section as noted in "Possible Strategies in Revising Management Direction for Vegetation." The losing battle against weeds to date on FS lands speaks to instituting innovative strategies, monitoring, research and renewed funding and effort.

3.  The technical AMS "Vegetation" section deals little with populations of sensitive and rare plants. There is no strategy mentioned to ensure survival of these populations, and the opportunity for them to thrive. They exist in a variety of habitats (in the aggregate), as noted, but not throughout those habitats. Because they are scattered, scarce, and limited in their workable habitats, they are more subject to vagaries of natural and introduced variation, and less able to recover from damage. In cases of uncertainty, they should be managed to maximize habitat and population size. This is the time to include a strategy for maintaining and enhancing them in the two forest plans.

 

Once established, these are tough, adaptable, persistent plants. We realize that prevention is difficult and contentious because it deals with all human activity in the forest: machinery (work and play), building and maintaining roads, managing the forest for positive ends – almost any activity can have the unintended consequence of spreading weeds. One element of prevention is replanting disturbed areas with native vegetation; a vigorous native ecology is an important tool in preventing the spread of noxious weeds. Tough as it is to address this dilemma squarely, we cannot contain the spread of noxious weeds while avoiding it. We recommend adding a strategy for preventing the spread of noxious weeds.

 

 

4. Protecting riparian areas from degradation and restoring damaged waterways is called for in the AMS. We wish to support these efforts as many sensitive plants in North Idaho and NW Montana are riparian. Their fate is inextricably tied to the adjoining waterways and their presence supports the viability of those waterways. Road density in IPNF is known to be substantially higher than that recommended for healthy waterways; we support correcting that problem plus other efforts at watershed restoration.

 

5. Consistent with our other concerns, we support the FS goal of restoring seral tree species to their historic habitats. This includes allowing fires to burn naturally when possible.

 

 6. The Kinnikinnick Chapter does not believe the Forest Service needs to provide access for all the recreational machines and transportation modes available today, beyond some of those already open. People always have access to the National Forests by foot.  Sometimes it may be difficult and distant, but we are not fenced out. The limitations are those of individual available time, physical condition, age and the availability of walking trails.

 

The FS is not a transportation department with responsibility for roadway access everywhere. Forest health and that of its wildlife and flora components should be given higher priority. We understand that many do not share this philosophy but feel the biodiversity and botanic integrity of the forest is threatened by the compaction, trampling, weed-spreading and erosion that follow use and overuse by most methods of transport. Boaters are increasingly being required to take courses teaching appropriate use and safety. OHV and snowmobiles using public lands should have the same requirement. Education and recognition of responsible users should accompany a firm policy of road closures. We urge management restraint in recreational access and recognition of its cumulative impacts on the flora of our forests.

 

The lack of road maintenance funds indicates that constructing new roads should be avoided. We support maintaining inventoried roadless areas in their present state and managing them for natural values, with OHV excluded. In evaluating potential wilderness, the rapid population growth around IPNF and KNF indicates that human pressures will accelerate and wilderness will become scarcer and more valued, both for its quiet recreational values and retention of intact ecosystems.

 

7. Some additional comments:

·        Prescribed burning is important for fire control and mimics nature. As such we generally support it as a tool. However, at the February 2003 Idaho Rare Plant Conference in Boise several public land botanists expressed concern that springtime burns may impact sensitive flora adversely. Native plants are adapted to summer and autumn burning, but not springtime. This concern merits research in our specific ecosystem.

·        The Technical AMS talks of natural variability over time. It does not take the next step of quantifying the human-induced variability of the last 220 years and modeling the cumulative impacts. These would be expected to have disproportionate impact on small populations of plants that rely on a particular, relatively undisturbed niche for survival. That implies that sensitive populations should be managed with an exceedingly conservative approach with ample consideration of the dual impacts they face today and in the foreseeable future.   

·        The 1987 ASQ's for timber production have proven unrealistic for a variety of reasons. We support a strategy of identifying realistic, sustainable production in which timber harvest serves "as a tool to achieve desired future (forest) condition." This should promote economic stability in our communities for multiple decades to come as well as providing the optimal environment for native plant populations.

·        The vegetation section of the Technical AMS almost entirely omits discussion of deciduous trees in the forest. (They are noted in charts of riparian vegetation, pp 23-24.) Although lacking in timber value, these trees are important components of our mixed forests. Many are sun-loving species which can be locally extirpated by replanting evergreens and managing primarily for timber. Quaking aspen, paper birch, cottonwood, etc. are important for wildlife, riparian health and forest diversity and health. They and understory trees should be studied and planned for.

 

We appreciate the opportunity to comment and have our input acted upon. Please let us know future deadlines for participation.

 

Sincerely,

 

 

Molly O'Reilly

Chair, Conservation Committee

Att: Comments submitted, November 2002

Cc: Forest Supervisors, IPNF, KNF