Questions by concerned citizens of the Red Lake Nation.Together with Roger Jourdain we fought to protect the Big Bog from peat mining, and to be used for commercial purposes.
Draining the Big Bog for peat mining in the Big Bog will affect the Chippewa National Forest very dramatically according to those employed by the Leech Lake Natural Resources and the Indian Game and Fish Association, yet the Minnesota Environmental Partnership completely ignores this. Why? Is racism a motivating factor for the Minnesota Environmental Partnership?
The Minnesota Environmental Partnership has refused to post the Red Lake Nation Resolution in Opposition to peat mining in the Big Bog on their web site. Why? Is racism the motivating factor?
Note: the 2008 Freeman Forum on the topic of "Water, water everywhere?" was attended by 76 people... ALL white people.
It is very well known that the Minnesota Environmental Partnership was established as a "front" organization of the Minnesota Democratic Farmer-Labor Party in cahoots with the Minnesota Chamber of Commerce in an attempt to "control" and "manipulate" environmental organizations into accepting the MN DFL policy towards the environment as one of being the "loyal opposition" to those destroying our air, water and land... but then, after the corporations make the final decision their "opposition" ceases.
Minnesota Environmental Partnership Sign-On Letter
August 4, 2003
Plan Revision Team
Chippewa National Forest
200 Ash Ave. NW
Cass Lake, MN 56633-8929
Dear Plan Revision Team,
The undersigned members of the Minnesota Environmental Partnership submit these comments on the draft forest plans and draft Environmental Impact Statement for the Superior and Chippewa National Forests. These comments reflect our interest in protecting and restoring the precious natural resources and heritage we enjoy in Minnesota's National Forests.
The Minnesota Environmental Partnership strongly believes that clean, healthy water is part of our heritage as Minnesotans. We are concerned that we may lose this heritage as our waters become ever more polluted. We also know that Minnesota can do a better job of protecting our lakes, rivers, and streams and that our two national forests play a significant role in this effort.
In January, more than twenty MEP member organizations sent a letter to Regional Forester Randy Moore outlining 20 forest management principles which we hoped to see incorporated into the plans. Now we wish to comment on how the draft plans address many of these principles.
1. The Plan Doesn't Acknowledge National Treasures:
While the preferred alternative focuses on economic productivity of assets, it considers an unacceptably narrow and antiquated range of economic factors. The plan completely ignores non-commodity values other than recreation revenue, and focuses recreation development on ATV and motorboat access.
We request that non-commodity values be integrated into planning as well as a more balanced economic analysis of the various recreational opportunities provided by the forest. There should be a more formal analysis of the impacts to, and benefits from, activities such as hiking, cross-country skiing, camping - developed and remote, fishing - both motorized and remote, wildlife watching, photography, biking, horse-back riding etc. incorporated into the final plan.
2. The Plan Acknowledges Nature's Blueprint by Adopting Range of Natural Variation:
We congratulate the Forest Service on adopting a range of natural variation (RNV) as a reference yardstick for the condition of our forests. While we appreciate the vision that went into 100-year calculations of environmental impact, we are concerned that progress toward RNV is adequate during the life of the proposed plan. The plan will guide forest management for the next 15 years, yet in nearly all of the Landscape Ecosystems, progress toward RNV comes only after 20 years.
We request that the plan make MEASURABLE progress toward desired conditions within the first decade. We must restore and protect a higher acreage of white pine, older mature forests, riparian habitat, and all other sensitive habitat for rare and endangered species.
3. The Plan Does Not Adequately Protect Rare Plants & Wildlife:
The proposed plan offers to manage landscape ecosystems that support rare plants and wildlife, rather than specific habitats. Yet most mature forest restoration is not projected to occur for more than 50 years. Wildlife need habitat continuously and restoration needs to start now.
We request that rare plant and wildlife, which are most at risk of viability loss, be provided for immediately in the first decade. We cannot have a dip in habitat needs initially even if in the fifth decade these acres are recovered. Wildlife cannot be put on "hold" to wait for this recovery. All wildlife must be provided for as a first priority.
4. The Plan Contributes to the Loss of Interior Forests:
The fragmentation index will more than double in lowland forests, and stay far higher than natural in uplands. Thirty percent of acres of large patches of mature forests on Superior disappear and will not recover for 100 years. In the Chippewa, fifteen percent is lost and recovered in 50 years. The plan authors admit it will cause reduced spatial diversity, hydrological effects on reforestation attempts, and rare species impacts.
We request the final plan address these issues at the outset. Fragmentation is a leading cause of loss of viability of some species and should be addressed in the first decade. There should be no increase in fragmentation and no loss of large patch mature forests in either national forest. Our future forest plans should not be moving us in a backward direction.
5. National Forests Should Not Be "Tree Farms":
While the Forest Service proposes to move much land into longer-rotation management for saw timber, the draft plan increases total commercial logging and treats more lowland and old-growth forest as suitable for cutting. The plan makes no commitment that artificial plantations will not be used.
We request there be no "conversion" of native forests to plantations. Natural regeneration should be used primarily and mechanical regeneration should use diverse native seed stock rather than single species.
6. The Plan Uses Clear-Cutting as the Dominant Logging Technique:
Clear-cutting focus will irreparably increase forest fragmentation and fail to achieve the multi-aged management goals of the Minnesota Generic Environmental Impact Statement on Timber Management.
We request full implementation of the management goals of the Minnesota Generic Environmental Impact Statement on Timber Management. The use of clear-cutting should be greatly reduced, it should be used cautiously and only after close examination of the effects that such management will have on other forest resources.
7. The Plan Wisely Uses Fire as Management Tool:
We heartily support the plan's recognition of fire as an essential ecological process in forest restoration and the significant acreage reserved for prescribed fire management.
8. The Plan Threatens Water Quality:
The plan's focus on protecting riparian areas and restoring watershed health is not insufficient. We like that timber harvest will be allowed only in those riparian areas with restored or enhanced ecosystems, but we are concerned about road building in riparian areas. Additionally, less than half of the Chippewa, and only 60 percent of the Superior including the Boundary Waters Canoe Area Wilderness, would be managed above basic stewardship level.
We request protection and restoration of riparian areas; the Forest Plan should not encourage activities to the detriment of these areas. There should be no new roads and trails in these areas and only limited stream crossings where no alternatives exist. Finally, no logging should be allowed in sensitive-soil forests.
9. Allowable Sale Quantity (ASQ) Ignores Desired Condition:
ASQ calculations in the proposed plan are improved in that they consider some standards and guidelines, as well as decreased volume per acre which is due to reserves in clear cuts. However, logging rates may actually increase, and the range of natural variance will not be approached in the plan's first 20 years. Young forests generated from natural disturbances are not considered, and special resources are only protected if they are critically rare.
We request inclusion of natural disturbance rates providing young forest be included in overall natural variance calculations, as well as adequate reserves from logging of unique and limited resources prior to them becoming critically rare.
10. The Plan Emphasizes Game Wildlife Over Non-Game Wildlife:
Species depending on mature forests will suffer during the plan's main prescriptive period (15 years).
Again, we request that rare plant and wildlife, which are most at risk of viability loss, be provided for immediately in the first decade. We cannot have a dip in habitat needs initially even if in the fifth decade these acres are recovered. Wildlife cannot be put on "hold" to wait for this recovery. All wildlife must be provided for as a first priority.
11. The Plan Should Reflect the Unique Role the National Forests Have in Minnesota Landscape:
The plan should capitalize on the large unit size of these national forests as well as the resources and expertise of the Forest Service to provide for rare native plant communities in interior and older forests. Much more of this rare habitat should be protected in the final plan.
We request that the Forest Service consider the unique resource that exists in the National Forests of relatively contiguous land ownership under one management. The National Forests are a priceless reservoir of biological diversity and we must provide for a greater protection of rare and older mature forests, reserved from extraction, to counteract the loss of such resources on neighboring forests lands under state, county, and private ownerships.
12. The Plan Needs Stronger Monitoring and Accountability:
The monitoring sections of plan are too vague to ever hold the agency accountable to the plan. Measurable restoration is delayed until after the plan's period of applicability. No mention is made of budget requirements and prospects for implementing plan.
We request measurable standards and guidelines for monitoring of restoration progress be implemented in conjunction with forest management throughout the life of the plan. Restoration should be measurable and given priority within first decades of the plan. The implementation plan should be available and accountable to the public owners of these lands.
13. The Plan Places Excessive Emphasis on Motorized Recreation:
The proposed plan relegates decisions about restricting OHVs to site-specific projects, protecting only quarter of 1 percent of the Superior outside the wilderness area. We fear the lack of guidance in the management plan will lead to by-passed cumulative impact analysis and local pressure for more motorized recreation.
We request increased acres of non-motorized management. Motorized access should only be considered where appropriate following these guidelines: first, the activity must not harm the forest environment. Activities that harm the forest environment destroy what attracts people to the forest in the first place. Second, the recreational activity must not displace other people who are in the forest, especially when those being displaced are in the majority. Third, the Forest Service, although acknowledging that no trails will be expanded unless there is budget support for maintenance, does not mention enforcement. We request a guideline be established that requires adequate funding for enforcement prior to ATV access. Finally, riparian areas across the state are being substantially impacted from RMV activity, the Forest Service should go to great lengths to keep RMVs out of and away from riparian areas. Following this we also support the "closed unless posted open" policy for trails deemed appropriate.
14. The Plan Will Lead to a Loss of Secret Fishing Holes:
The increased access to lakes for motorboats will also increase pressure on the already-high-demand Boundary Waters Canoe Area Wilderness.
We request designation of some large lakes outside the wilderness as carry-in access only.
15. The Plan Insufficiently Expands Research and Natural Areas:
The plan rejects all but 13 of the 51 qualified Research and Natural Areas for protection on the grounds that they are not rare enough to merit designation. These vulnerable places are only a small portion of the area requested for Special Management Complexes, and could play a similar role. With increased population and tourism pressure on the National Forests, it is inconceivable that the Forest Service would sacrifice the last remaining high-quality natural attractions for commodity production.
We request RNA designation for all 51 qualified areas.
16. The Plan Denies Congress Option to Protect Remaining Wilderness-Quality Areas:
The plan rejects protection for all qualified wilderness areas, and assigns more than half of them to short-rotation General Forest management areas. The Draft Environmental Impact Statement mysteriously does not list decision criteria for finding no need for recommending wilderness study areas. Wilderness is an economic development strategy that works for forest communities.
We request protection to the greatest extent possible all wilderness-quality areas. Potential Wilderness designations should be used for these areas and absolutely not assign them to short-rotation General Forest management.
17. The Plan Real Scenic Quality:
The plan receives low scenic integrity scores except for 'Scenic Class 3'. What a growing tourism industry demands is devoted protection of Class 1 and 2 areas which will allow the forests to be managed as national-stature, natural attractions.
We request Class 1 and 2 areas are provided the highest scenic quality protection.
18. Antiquated Approach to Economic and Social Sustainability:
The proposed plan includes no specific strategy for supporting recreation other than ATV and motorboats. Yet it admits that the forests cannot meet projected demand for roadless area recreation. The social values of non-local constituencies were not reported in the Social Analysis section of the Draft Environmental Impact Statement, leaving decision-makers and citizens uninformed by the draft. An example of this would be the impact of motorized recreation on non-local birders.
Again, we request a larger emphasis on roadless and quiet use recreation. Nationally and in Minnesota we are witnessing a fundamental shift - away from timber production and toward recreation and fish and wildlife sectors - in how the public views the utility of national forest land.
The new plans were an opportunity for the Forest Service to combine science, public values and a new approach. They're an opportunity to show that the past decade's changes within the Forest Service will make a difference out in the woods. We are disappointed that the proposed plans fail to show leadership and innovation to match our state's unique resources and growing recreation industries.
- Alliance for Sustainability
- American Lands Alliance - Upper Midwest
- American P.I.E.
- Audubon Minnesota
- Duluth Audubon Society
- Friends of the Boundary Waters Wilderness
- Kids for Saving Earth
- League of Women Voters - Minnesota
- Leech Lake Area Watershed Foundation
- Mankato Area Environmentalists
- Midwest Assistance Program
- Miss. Corridor Neighborhood Coalition
- MN Catholic Conference
- MN Center for Environmental Advocacy
- MN Ornithologists' Union
- MNs for Responsible Recreation
- NE Minnesotans for Wilderness
- Saint Paul Audubon Society
- Save Lake Superior Association
- Scenic Minnesota
- Sierra Club - St. Croix Valley Interstate Group
- Sierra Club, North Star Chapter
- Superior Wilderness Action Network
- Voyaguers National Park Association