Right now, your local Forest Service has a unique opportunity to invest
in recreation, clean water, wildlife, and tourism through National
Forest Management Plans. The Plans for our Southern Appalachian
National Forests will determine what areas will be logged, and what will
be protected for the next 10-15 years.

Unfortunately, these current draft Plans do little to protect ecosystem,
community, and economic values. Instead they drop key water, wildlife
and forest protection, allow increased timber production, and leave some
of our favorite places open to road building, logging and unchecked
disturbance. The Forest Service won't make the necessary changes unless
they hear from you, the taxpayer and owner of the National Forest.

PLEASE WRITE YOUR LOCAL FOREST SERVICE AND TELL THEM OUR NATIONAL
FORESTS NEED MORE PROTECTION. Click here for a Sample Letter (MS Word)

If you live, work or play in the Jefferson (VA) National Forest, please
use the information below to help formulate original and substantive
comments. Don't be intimidated by agency jargon.
You are the person the Forest Service refers to in their motto:
Caring for the Land and SERVING PEOPLE.

*******************************************DEADLINE**********************************************

Our one opportunity to direct future forest management ends on July 3 2003
(OFFICIAL COMMENT PERIOD OVER)

Please take 20 minutes to write a letter to the National Forest Analysis
team and tell them to protect our safe, clean drinking water, places to
fish, hunt, hike and camp, and some of the best fish and wildlife
habitat in the world.

Summary of Problems (more detailed information below):

1. Not enough Wilderness,

2. Roadless areas left unprotected,

3. Streams, lakes, and rivers inadequately protected,

4. Old Growth open to logging,

5. Monitoring program meaningless,

6. Increased logging, and

7. Inappropriate use of fire.

Send comments to any and all of your favorite National Forests (same
address for each):

Forest Supervisor George Washington and Jefferson National Forests
5162 Valleypointe Parkway
Roanoke, Va. 24019

1. Problem: The Jefferson's Forest Management Plans have inadequate
Wilderness recommendations for both stand-alone and Wilderness
additions. (Wilderness offers the highest degree of Forest protection -
maintaining soil and water quality, ecological stability and plant and
animal gene pools, and provides habitat for wildlife and unsurpassed
recreational opportunities.)

Solution: Tell the Forest Service to recommend Wilderness for all of
the areas that qualify as defined by the local Forest watch group or
wilderness campaign.

At the very least they should include:

Stand-Alone Wilderness: Brush Mountain, Brush Mountain East, Little
walker Mountain, Crawfish Valley, Raccoon Branch, Seng Mountain, Long
Spur, Horse Heaven, Brushy Mountain, Panther Knob, and Stone Mountain.

Wilderness Additions: Garden Mountain (partial), Hunting Camp/Little
Wolf Creek, James River Addition, Kimberling Creek Additions (partial),
Little Wilson Creek Additions (partial), Mountain Lake Additions
(partial), Peters Mountain Additions (partial), Shawver's Run Addition
(partial) (28,500 acres).

Substantiating arguments for more Wilderness:

Demand for Wilderness is increasing. The USFS Southern Forests Resource
Assessment (2001) states there is a trend toward increasing demand of
recreation opportunities, and one of the Forest Service's own Management
Plans says that "participation rates and trends in Wilderness indicate a
continued increase in visitation, climbing an estimated 117%".

The Forest Service inconsistently considered demand. Some Forest Plans
don't mention demand, others inadequately, and still others erroneously.
This flies in the face of what the Regional Headquarters called for.

Citizens want more Wilderness! The National Survey on Recreation and
the Environment (2001) found that 69.8% of those surveyed agreed or
strongly agreed with designating more federal lands in their state as
wilderness, and over 96% agreed or strongly agreed with knowing that
future generations will be able to visit and experience wilderness
areas.

The Forest Service used a willy-nilly approach for designating
Wilderness. They used inadequate roadless evaluations and inadequate
and inconsistent reasons for NOT recommending some qualifying areas.

Many of the Forests didn't follow their own rules. Some Plans
recognized the need for more Wildernesses but then did not recommend any
additional areas.

2. Problem: All five Forest Management Plans inadequately protect
roadless areas, allowing salvage logging and temporary roads in some
roadless areas. Many unroaded areas are totally unprotected. (Roadless
and unroaded areas are some of the last remaining undeveloped places in
our National Forests. Roadless areas are over 2500 acres and would
eventually be protected under the Roadless Area Conservation Rule (if it
is upheld by the President). Unroaded areas are less then 2500 acres
and would not be protected under the Rule.)

Solution: Tell the Forest Service to put ALL Roadless and unroaded
areas into protective management. All
Roadless and unroaded areas should be put into Wilderness recommendation
(1B), Backcountry Non-Motorized (12B or 12C), or Wild & Scenic River
Management. (Numbers reflect Forest Service jargon.)

Substantiating arguments for protecting Roadless areas:

The public wants Roadless Areas protected! 97% of the people from the
Southeast who commented on the Roadless Area Conservation Rule wanted
roadless areas protected.

Roadless areas provide unparalleled recreation and economic
opportunities. With more than half of the U.S. population living within
a day's drive of our Southern Appalachian National Forests, these areas
provide unique recreation opportunities for tourists and locals alike.

All of these areas should be protected under "Regional Consistency".
Over the past 20 years, the nation has lost 2.8 million acres of
roadless areas because of localized Forest Service Management that
focuses on extraction. The Region stated that it would protect these
areas in the Southern Appalachians even without the Roadless Area
Conservation Rule. These plans do not reflect that regional
consistency.

Even if all Roadless areas are protected (either through the plan or the
Roadless Rule), numerous areas with roadless characteristics will not be
protected. The inventory of Roadless areas was inadequate because it
defined "Roadless" under arbitrary rules. The roadless inventories
required a core size of 2500 acres. This core size is meaningless, not
required by law or regulation and should not be the standard for
protecting roadless values.

3. Problem: All five of these Management Plans allow logging in the
areas that protect our water quality. The quality of land around
rivers, lakes, streams and temporary (ephemeral) streams determines the
quality of our fish habitat and drinking water. The drafted Management
Plans fail to protect our water quality, diminish the role of ephemeral
streams and allow salvage and "forest health" logging in areas the
recommend for riparian areas.

Solution: Tell the Forest Service to increase protection for the areas
that protect our water quality. They need to increase the size and
protection of all Riparian areas along lakes, rivers and streams,
include ephemeral stream (streams active in times of high water) and
outline precise provisions around "Forest Health" logging so that it
does not become a loophole for the timber industry.

Substantiating arguments for better riparian protection:
Southern Appalachia relies on these lands for clean drinking water!
2200 communities, serving at least 10 million people in our region
receive their drinking water from National Forest Lands.

Our Wildlife suffers. Many of our native trout streams suffer from
excessive sedimentation caused by erosion form logging and associated
activities.

Scientist show that higher protection is needed. A University of
Georgia study calls for greater protection than is found in the draft
plans.

4. Problem: The draft Management Plans provide inadequate protection
for existing Old Growth. (Old Growth areas contain wildlife and natural
ecosystem resources found nowhere else in the world. They include those
big old trees, from 100 to over 400 years old. Many of our Old Growth
areas are yet to be discovered, and although they escaped devastating
logging at the turn of the 20th Century, if these plans don't change
they could be ravaged at the beginning of the 21st.)

Solution: Tell the Forest Service to protect all Old Growth stands.
Tell the Forest Service to establish standards that put all existing Old
Growth found in the future into old growth patches that will protect the
stands.

Substantiating arguments for protecting Old Growth:

These old stable forests are a temperate rain forest - which accounts
for all of its diversity. Few people realize it but our region is one
of the most species rich areas outside of the tropics - meaning that
when added together we have more types of animals and plants than most
others. Many of our Old Growth areas account for this diversity.

Few old growth areas were left after the devastating logging that
occurred at the dawn of the 20th century. All of these remaining old
growth remnants should be protected

5. Problem: All five Forest Management Plans have meaningless
Monitoring Programs with inadequate
Management Indicator Species. (MIS is one of the main tools the Forest
Service uses to take the temperature of the forest's health. The
presence or the absence of certain species should reveal the
consequences of current forest management on forest health.)

Solution: Tell the Forest Service to fulfill their obligations under
the current laws and adopt an adequate MIS program. The Forest Service
should increase the number and quality of their Management Indicator
Species. In addition, they should include obvious communities and
populations like plants, aquatic insects, fish and salamanders.

Substantiating arguments for better MIS:

The Forest Service is ignoring current regulations. National Forest
Management Act regulations requires each forest to adopt an adequate MIS
program

The Forest Service relies heavily on bird species as MIS in the draft
plans. Not only are birds very mobile, but they are also not reliable
or sensitive indicators of forest trends.

The Forest Service doesn't even have a MIS that monitors aquatic
health! None of the Forests have an aquatic MIS.

Only one salamander in one forest is a MIS. The Southern Appalachian
Region is one of the most significant biological centers of salamanders
in the world. Not only do we have a lot of salamanders, but many are
very sensitive to forest health. They would make ideal MIS, but the
Forest Service hardly uses any.

6. Problem: All five Forest Management Plans have allowed logging to
increase. (Logging will increase on areas the Forest Service describes
as suitable timber land. In addition, logging is allowed in areas
deemed unsuitable under thinly veiled excuses such as "Forest Health"
and "Wildlife Management".)

Solution: Tell the Forest Service that logging numbers are way too high
in suitable areas, and that "Forest Health" & "Wildlife Management"
logging in unsuitable areas is too open to interpretation. The
Allowable Sale Quantity for each forest should be lowered to those that
are consistent or below the number of board feet that is actually being
harvested today. In addition, logging in unsuitable areas should have
precise provisions so that they aren't used as a loophole by timber
industries.

Substantiating arguments for less logging:

The draft plans would allow logging on suitable lands to increase to the
kind of logging we saw in the 1980's. USFS publicity maintains that the
plans decreased logging from the previous plans. However, under the last
plans the FS was never able to log at that level because of
environmental constraints. These plans would still allow logging to
increase from what is being harvested today and this level of logging is
still inappropriate.

Wildlife Management logging is superfluous. The models the Forest
Service uses to determine how much logging needs to take place for
"early successional habitat" does not factor in natural occurring early
succession. One to two percent of stable forests are disturbed
naturally each year. Adding unnatural disturbances of 4-5% to our
forests (10-20% in some areas) opens up way too much forest and creates
unnatural conditions.

Intact Forests offer more to local economies that logging. Hunting
brought in $296 million in retail sales to the region in 1996. The Ocoee
River alone brought in more than $3 million a year in commercial and
private user fees. In contrast, timber based annual employment
continues to decrease due things like automation.

7. Problem: All five Forest Management Plans perpetuate unnatural
forest conditions by using Western Fire
models. (The Southern Appalachian Forests are very different then
Western forest. They are more fine grained, and include very wet,
stable forest types in addition to ridges and south slopes where natural
lighting strikes do produce natural fires. The draft Management Plans
do not take this into consideration and insist on managing with
broad-brush strokes.)

Solution: Tell the Forest Service to manage our Southern Appalachian
Forest as Southern Appalachian Forests.
They need to keep fire and logging out of mesic coves and north facing
slopes. Fire and large-scale disturbances are harmful to these forests
and the species that rely on them. Creating more early succession will
perpetuate an unnatural forest that needs continuous management.

Substantiating arguments:

Our Southern Appalachian Forests are finely detailed containing some
fire dependent or fire tolerant communities on ridges and south slopes
in close proximity to fire intolerant communities (e.g. mixed mesophytic
and northern hardwoods). Managing fire in large blocks as proposed in
the draft plans will do irreparable harm to many of our forests.