Sunday, October 31, 2010

Time for Comments on the 2010 Giant Sequoia National Monument Management Plan

Ruth Sandra Sperling
- in Southern California

It is time -- for me to make my public statements regarding the writing of the Management Plan for the Giant Sequoia National Monument (GSNM) as regards to the current Draft Environmental Impact Statement (DEIS) of August 2010. Since 2000, I have been to numerous public meetings discussing the issues surrounding this monumental job of managing the Giant Sequoia ecosystem for resiliency and ecological integrity.

I have written about this a number of different times here on my blog -- see the blog articles under the label of Giant Sequoia National Monument.

If you choose to, you, too, can make comments on the Giant Sequoia National Monument Management Plan before the Comment Period ends on November 3rd, 2010.

-- You can mail comments to (they need to be postmarked November 3, 2010):

Anne Thomas, Team Leader
Giant Sequoia National Monument
1839 South Newcomb Street
Porterville, CA 93257

-- Or Fax them to (559) 781-4744 (which is what I am doing)

-- or go to the Limehouse Portal, join online and make your comments within that format online.

Here are my comments on this matter that is so important to me -- for my blog!!

After attending public meetings regarding the management of the Sequoia National Forest, the establishment of the Giant Sequoia National Monument and the development of its management plan -- and studying various pieces of information that I learned either by listening to discussions and presentations or reading documents regarding managing the Giant Sequoia ecosystem, including regeneration of Giant Sequoias -- and now having reviewed the Alternatives presented in the current Draft Environmental Impact Statement for the GSNM, I have come to my own conclusion on what is best for this Management Plan for the Giant Sequoia National Monument.

This is my own conclusion -- not offered by anyone to me specifically -- and this is a matter of personal integrity for me, as I feel with the options available and the management direction that will get the results I am hoping for -- it is the only choice.

My choice is Alternative C - not the Preferred Alternative of the Forest Service, Alternative B. I am not sure what the Forest Service will do, so in my comments, in addition to stating that I want Alternative C, I am stating some of the specifics of it that I like -- so that these specifics can be incorporated into a modification of Alternative B, if that is what is done.

Here I am going to quote the "Alternative Theme" for Alternative C from the DEIS and several key statements regarding it exactly:

"Alternative C would protect the objects of interest and manage Monument resources to promote resiliency, adaptability to climate change, and heterogeneity across ecosystems. This alternative responds to the issues of managing the Monument like Sequoia and Kings Canyon National Parks and fire spreading to tribal lands. It was developed to manage the Monument similar to SEKI in a manner that is consistent with Forest Service regulation and the direction of the Clinton proclamation. It was determined that some management policies or direction from the SEKI would not be applicable to the Monument because of difference in law, regulation, and policy for the two federal agencies. In this alternative, restoration activities would focus on area that have been affected by human use and occupation."

And here are I am going to quote some specific statements from the Alternative C details - as these details are why I think this will make the best Management Plan for the Giant Sequoia National Monument.

"Protection of Objects of Interest: "Alternative C focuses on allowing natural processes, limiting treatments to areas of human use and influence. To address fuels buildup, it allows limited mechanical treatments, with diameter limits for tree cutting, and subject to the restrictions in the Clinton proclamation and focuses treatments on both prescribed fire and naturally occurring fire. …."

"Promotion of Resiliency: Alternative C would emphasize resource conservation that allows natural processes to prevail and focuses on the restoration of natural processes to areas altered by human use by employing tactics that minimize the tools used for restoration."

"Promotion of Heterogeneity: Alternative C focuses on allowing natural processes, limiting treatments to areas of human use. To promote heterogeneity, it would use both prescribed and naturally occurring fire."

"Recreation Opportunities: …. The alternative proposes to change the current recreation opportunities by focusing on developed recreation sites with new development in recreation opportunity areas."

Here are 2 more quotes from the "Resource Areas" section of the Detail on Alternative C, detailing the perspective of The National Park Service, which is what this Alternative C is based on (from page 89 of the DEIS):
"The National Park Service uses the best available technology, within available
resources, to restore the biological and physical components of these systems, accelerating both their recovery and the recovery of landscape and biological community structure and function. …. When a park development is damaged or destroyed and replacement is necessary, the development will be replaced or relocated so as to promote the restoration of natural resources and processes."

" The [National Park] Service will seek to return human-disturbed areas to the natural conditions and processes characteristic of the ecological zone in which the damaged resources are situated."

My decision is based on the fact that, based on scientific discussions I have heard and read, I feel the following points are extremely important in managing the Giant Sequoia National Monument -- and that Alternative C incorporates them and operates per them the best.

1. Ecosystem management
2. The only way to achieve resiliency for the ecosystem (and sub-ecosystems) that the Giant Sequoia National Monument is, is through constant and current on-going site-specific analysis and research to develop current, new science, as needed -- using the methodology of adaptive management to do actions on the land.
3. Fire is the First Tool of Choice -- and that includes managed wildfire of unplanned ignitions (also called Wildland Fire Use). You can study the characteristics of the Mediterranean Climate that the Giant Sequoia National Monument is part of to understand this more fully.
4. Though there are definitely trade-offs between vegetation management, fire and fuels management and wildlife and plant habitat management, I feel that The National Park Service direction to return human-disturbed areas to the natural conditions and processes is the best and will result in the most optimum balance between all managements and less negative impacts to the Wildlife and Plant (including trees) Habitat on the GSNM.
5. Though Recreation and Scenery are important for Tourism and the people who visit the GSNM, I feel that the Ecological Integrity and Resiliency of the ecosystem is of higher importance overall and that when setting priorities, Ecological needs should outrank Recreation and Scenery -- otherwise, I am afraid we would end up with a trampled forest, not a healthy forest. I suggest reading The Land Ethic by Aldo Leopold in his book, "A Sand County Almanac"!!
6. There definitely needs to be current scientific criteria for determining which trees are to be removed so that the Clinton Presidential Proclamation is complied with: “Removal of trees except for personal use fuel wood, from within the monument area may only take place if clearly needed for ecological restoration and maintenance or public safety (Clinton 2000, p.24097).”
7. Dr. Nathan Stephenson, who has many years of experience in restoration and regeneration, including on-going research, in The Sequoia and Kings Canyon National Park Service, stated during the discussions of the Scientific Advisory
Board Meetings
in March 2003 (I was there personally and heard it and noted it) that gaps for regeneration result in more successful regeneration of Giant Sequoias - if you burn the hole (gap). As Giant Sequoias are “shade-intolerant” species and require a certain amount of light and fire for ecological health, burning the hole (gap) for regeneration accomplishes both - of course, it needs to be done in safe conditions.

Since the 1980’s, I have spent time in what is now the Giant Sequoia National Monument Lands - unfortunately I saw huge trucks with large logs on them from logging operations; I saw a slashed clear-cut on a back road of the Southern Portion of the Giant Sequoia National Monument west of the Western Divide Highway and east of the Tule River Indian Reservation. I have seen and photographed re-planted areas that look like orchards of trees - looking all the same age (even-aged), looking all the same species (homogeneous) - in the vicinity of Nobe Young Meadow on the "Road to Windy Gap" - not too far from the Peyrone Giant Sequoia Grove.

I have been going to forests since I was a child - in early years with my family, in later years on my own or with friends. I know from personal experience what a real forest or woods are. Due to the past history of logging, homogeneous planting and fire suppression in the Sequoia National Forest, there are areas of the Giant Sequoia National Monument that are not, from my own personal observation, "real" forest. With no personal offense to the current managers of the Giant Sequoia National Monument, I am concerned for the health of this forest ecosystem, hence my choices and opinions above.

My fervent wish is that we can "fix" some of the mistakes of the past and restore the whole ecosystem to a level of health in our current climate conditions, so the forest continues to survive, as the scientists and Forest Services calls it - be resilient - for our pleasure and our health!!

The Giant Sequoia National Monument is a vast mix of living organisms that respond to current conditions and require certain conditions to be healthy, just like you and me. I believe that it will come down to a large amount of continued current on-going, on-site, site-specific analysis and research to see what works NOW!!

I feel that managing the Giant Sequoia National Monument as closely as possible like the Sequoia and Kings Canyon National Park -- and collaborating and co-operating with them and their scientists -- is the only proper way to do it. After all -- the Giant Sequoia National Monument and the Sequoia and Kings Canyon National Park are physically "intertwined" and are both part of the whole Giant Sequoia ecosystem.

PLEASE NOTE: The above is not exactly my official Comment Letter on the 2010 DEIS for the Giant Sequoia National Monument Management Plan. Some of the statements in this blog post are duplicated in my Comment Letter or reflect my statements in it.

ALSO: For information on the Giant Sequoia National Monument Management Plan public process - the Science Data including many documents - and the comments of the Science Review Panel with Sequoia National Forest Responses -- click on the linking phrases!!

If you have read all of this -- I hope you have found this informative - and interesting -- this is all the opinion of Ruth Sandra Sperling (no one else and I do not represent any organization). Why??? Because the Giant Sequoias are important to me -- and I want to share it with the world!!