- Becky Kalagher
- Paul Lauenstein
- Massachusetts Audubon Society
- Massachusetts Forest Fire Council
- Carl Rosenstein
- The Nature Conservancy
- Wildlife Management Institute
[DFW Remarks: The commenter lists particular concerns with several DCR forest management policies, but does not discuss any DFW lands or policies. Comments relative to FSC certification in general include the following points]
FSC Certification Is An Inappropriate Program For Massachusetts Public Lands.
DFW Response: DFW respectfully disagrees that FSC certification is inappropriate for state wildlife lands and notes that FSC certification for public lands is generally supported in several other states (e.g., Maine, Michigan, Minnesota, New York, Washington, Wisconsin)
Commenter Point 1. FSC standards are designed to promote sustainable commercial timber extraction from industrial-based lands and are not suitable for tracts of public lands held predominantly for preservation, ecological restoration and recreational services…
DFW Response to Above Point: 1. DFW agrees that FSC standards help insure that any commercial timber extraction is done sustainably, but disagrees that the standards are specifically designed to promote commercial extraction. DFW contends that the FSC standards are designed to promote economically, ecologically, and socially sustainable forest management practices, and thus help insure that any commercial timber extraction is done sustainably. DFW has not identified any pressure from FSC relative to commercial timber extraction on state wildlife lands. DFW does not believe that any of the numerous forest certification conditions that FSC (via SCS) placed on DFW during the initial 5-year certification period of 2004-2009 promoted commercial timber extraction on state wildlife lands.
Commenter Point 2. FSC Certification, as a market-based management tool, undermines conservation efforts in Massachusetts public forests where no such commercial imperative exists, and has hindered efforts to give greater preference to biological diversity, ecological restoration, and recreation.
DFW Response to Above Point: 2. DFW respectfully disagrees that FSC certification has hindered DFW efforts at biological diversity conservation, ecological restoration, and recreation on state wildlife lands. FSC (via SCS) has found DFW landscape goals for a diversity of habitat types (e.g., grassland, shrubland, and forest) to be consistent with FSC goals for sustainability. In particular, ecological restoration of fire-adapted pitch pine/scrub oak ecosystems at the DFW Montague Plains and Frances Crane WMA's has been positively reviewed by SCS.
Commenter Point 3. FSC is a private organization in competition with other certification systems with a vested interest in increasing and keeping lands under their certification.
DFW Response to Above Point: 3. In general, DFW maintains that competition among private companies is beneficial to consumers, and observes that all private companies seek to retain customers.
Commenter Point 4. The FSC auditing company, Scientific Certification Systems, benefits financially from keeping FSC in business and keeping clients certified.
DFW Response to Above Point: 4. Provided that sustainability criteria are rigorously and evenly enforced, DFW maintains that this situation is not inappropriate.
Commenter Point 5. SCS does not respect or understand the intent of MGL c. 21 s. 2F which requires full value Resource Management Plans for each DCR park, reservation and forest, and was intended to find balance among competing values on Massachusetts public lands.
DFW Response to Above Point: 5. Comment does not apply to DFW lands.
Commenter Point 6. SCS revised its requirement for site specific forest management plans when the state did not comply.
DFW Response to Above Point: 6. The SCS condition for management planning on DFW lands has consistently required completion of publicly reviewed plans on an ecoregion-based Forest Management Zone (FMZ) basis. DFW also prepares individual, site specific plans, and will post these site plans for public review along with landscape level FMZ plans.
Commenter Point 7. FSC certification also makes no mention of the other economic values state public forests provide, such as preserving aesthetic and scenic areas for the tourism values they provide. Economic value to certification is simply timber value.
DFW Response to Above Point: 7. DFW agrees that aesthetic, scenic, and tourism values are important, and maintains that these values are already reflected in existing FSC standards for socially sustainable forest management practices.
Commenter Point 8. SCS has not questioned why there are so many Freedom Of Information Act requests from citizens with respect to 2 forestry issues.
DFW Response to Above Point: 8. The DFW Forestry Program is aware of only one public records request made to DFW pertaining to FSC certification. That request involved payments to private contractors used by DFW to conduct field inventories, and DFW responded fully to that request.
Commenter Point 9. Climate change is upon us but not covered by FSC certification. Our state forests play a significant role in mitigating the effects of climate change. FSC certification does not take climate change into consideration in any of its forestry guidelines.
DFW Response to Above Point: 9. DFW agrees that Massachusetts forestlands play a significant role in mitigating the effects of climate change and has an active land acquisition program that conserves substantial acreages of forestland throughout the Commonwealth. DFW landscape composition goals call for the majority of state wildlife lands to occur as closed-canopy forest at any given point in time, which results in DFW lands contributing to net carbon storage. The Department of Fish and Game is actively engaged in several climate change initiatives, and the DFW State Wildlife Action Plan specifically addresses climate change.
Commenter Point 10: FSC Certification has been used to leverage funding from the legislature to facilitate commercial logging on public lands. Scarce funds have been diverted from Massachusetts public land ecological and recreational stewardship goals as a result, for the purposes of constructing logging roads, mapping public forest land for timber production and other expenses to prepare the lands for logging.
DFW Response to Above Point: 10. DFW has not used any capital monies provided for certification to facilitate commercial logging on state wildlife lands. All commercial logging on DFW lands is designed to meet existing landscape goals for a diversity of successional forest habitats, and has proceeded similarly both before and after any involvement with FSC certification. Capital funds provided to DFW during the initial certification period from 2004-2009 were used to: 1) conduct the first comprehensive forest inventory of state wildlife lands, including tree, shrub, and herb composition; 2) locate and assess vernal pool resources throughout DFW lands; 3) locate and map priority natural communities including rich mesic forest on DFW lands; 4) locate and mark property boundaries for DFW lands; 5) map, assess, and repair woods roads to address on-going damage to state wildlife lands from illegal ATV/ORV trespass activity; and 6) develop and maintain geo-databases to facilitate summary and analysis of all field data.
Commenter Point 11. FSC Certification has not provided the oversight and enforcement needed on MA forestry operations.
DFW Response to Above Point: 11. All DFW forestry operations have been found to be in compliance with FSC standards, and DFW operations have been favorably reviewed during public site visits.
Commenter Point 12. FSC Certification is an unnecessary expense, an extra bureaucratic layer, and is not codified in state law, when what we need is stronger state laws and enforcement mechanisms defining a smaller percentage of state lands where exemplary forestry will set an example of performance to the highest standards.
DFW Response to Above Point: 12. DFW agrees that FSC certification is not essential for meeting habitat goals on DFW lands, but maintains that FSC certification is beneficial for providing a third party assessment of DFW management practices. Policy regarding proportions of DFW lands to be actively managed through forestry operations is set by the state Fish & Wildlife Board.
[DFW Remark: Identical content as received from Becky Kalagher, Douglas MA, above]
DFW Response: See DFW Responses to Becky Kalagher, above.
[DFW Remark: Most comments related to DCR lands, but comments relative to DFW lands and to FSC certification in general are addressed below]
Commenter Point 1. These comments are focused primarily on the DCR Division of Parks and Recreation (DSPR) lands, which are the subject of the DCR Forest Vision process. The FSC re-certification review also includes DCR Division of Watershed Management and Division of Fisheries and Wildlife (DFW) lands. Some of the re-certification review report conditions and public comments relate to watershed and/or DFW lands. Mass Audubon supports management of the watershed lands for the water supply protection purposes for which they were acquired. Publicly reviewed management plans for the watershed lands have been in place for many years and are periodically updated. Mass Audubon also supports DFW's application of ecological management and wildlife biology expertise in management of its lands for the benefit of native plants and animals.
DFW Response to Above Point: DFW appreciates support for the management of state wildlife lands for the benefit of native plants and animals, and further appreciates acknowledgement that DFW management practices consider important aspects of forest ecology and wildlife biology.
Commenter Point 2 Considering that this certification has been in place for five years, it is disappointing that so many aspects of compliance with the FSC standards remain unresolved. FSC certification is touted as evidence that an entity has achieved compliance with high standards. As one example, the abuse of public lands by illegal riding of Off- Road Vehicles continues unabated despite the efforts applied to analyzing the issue and proposing legislative improvements.
DFW Response to Above Point: DFW shares the disappointment that many aspects of compliance with FSC certification conditions on DFW lands remain unmet. DFW maintains that it has made a good faith effort towards meeting conditions for inventory, boundary marking, road assessment and mitigation, and management planning, but acknowledges that severe staff limitations prevent DFW from meeting all conditions. While DFW is committed to making progress on all remaining certification conditions, we agree that the on-going damage to state wildlife lands from illegal off-road vehicles is especially upsetting. At the same time, DFW wants to thank the Massachusetts Environmental Police for responding positively and aggressively to specific requests from DFW for law enforcement action on individual wildlife management areas with focused off-road vehicle trespass activity. However, without passage of the proposed legislation relating to off-road vehicles, both the Environmental Police and DFW lack adequate resources to successfully address this ubiquitous problem.
Commenter Point 3. We also recommend that DCR formally adopt the High Conservation Value Forest (HCVF) provisions prepared by the Division of Fisheries and Wildlife (DFW), including designation of all Priority Habitats for rare species associated with closed-canopy forest and all late-seral forests (dominated by trees >150 years in age) as HCVF.
DFW Response to Above Point: The DFW Forestry Program thanks the DFW Natural Heritage and Endangered Species Program for their successful efforts to develop the HCVF provisions.
[The] proposal to certify some state lands which have Forest Management Plans in place, to certify additional forests once their formal FMP's have been completed in the future and to exclude those lands and parks (in name) which are not appropriate for FSC certification makes logical sense and this Council can support you in that regard.
We would be remiss however, if we did not express our concern regarding the DFW's ability to provide adequate fire prevention, control and enforcement throughout these holdings… with the real possibility of delayed detection, lack of (or delayed) specialized equipment and minimal or no strategic/tactical support for local fire officers who are largely untrained in wildfire operations. That said, this Council would like to laud the past partnership your Division has had with Dr. William Patterson of UMass-Amherst, and your work with him to reduce the crown-fire hazard within the Montague Plains area. It is our hope that this partnership will continue, or similar ones will be created, to protect not only the wildlife habitats under your control but also the life and property of your neighboring citizens.
DFW appreciates the support of the MA Forest Fire Council to pursue FSC certification for most state wildlife lands. DFW also agrees that this agency lacks resources to provide adequate fire control throughout all state wildlife lands. DFW notes that even the limited state funding that had been provided to meet certification conditions for mapping, assessment, and repair of existing woods roads on state wildlife lands was eliminated in 2009. Illegal ATV/ORV activities continue to degrade existing woods roads and habitats on state wildlife lands. DFW appreciates the support of its work at the Montague Plains WMA, and intends to continue this important work to both reduce wildfire danger and enhance rare species habitat.
Commenter Point 1. I completely oppose FSC re-certification. Mass Wildlife and DCR have completely mismanaged our state forests over the past several years. [DFW Remark: Mr. Rosenstein lists particular concerns with several DCR properties, but does not provide any examples of alleged mismanagement of DFW lands]
DFW Response to Above Point: DFW respectfully disagrees that this agency has mismanaged state wildlife lands over the past several years. DFW has conducted public site visits to numerous timber sale sites and has received positive responses from members of the general public who attended the site visits. Since no DFW sites are described in this public comment, DFW cannot respond further on a site specific basis.
Commenter Point 2. International foreign bodies have no business in our state. First a complete moratorium should be place on all logging in state lands and then new state law must be passed. Mass Wildlife and DCR have demonstrated a complete abuse of the public trust and used "green certification" to hoodwink the public.
DFW Response to Above Point: 2. DFW is unsure what the commenter means by 'International foreign bodies', but assumes that this is a reference to the Forest Stewardship Council (FSC), which is an international organization. DFW respectfully disagrees that foreign entities have no place in our state. Numerous foreign companies operate businesses here and employ many residents of Massachusetts, and other valued international certification organizations review and support Massachusetts companies (e.g., ISO 9001).
I am for recertification of all these areas and I'm sure there are more areas that should be included.
DFW appreciates the support for recertification of all the areas proposed in Table 2, and agrees that the areas in Table 3 should be included for recertification upon the completion of a publicly-reviewed management plan. DFW maintains, however, that non-forested saltmarsh, coastal beaches, and other areas in Table 4, are not appropriate for forest certification.
Commenter Point 1. The Massachusetts Chapter of The Nature Conservancy believes that carefully planned and implemented harvesting operations can be compatible with biodiversity conservation and social objectives. Independent third-party certification of forest management practices is a means to verify and improve such compatibility, and FSC is the only system that consistently meets the requirements set forth in the World Bank's 2002 Operational Policy on Forests. The Nature Conservancy has supported FSC certification of the Massachusetts DCR and DFW forest lands since first certified in 2004.
DFW Response to Above Point: 1. DFW appreciates the Conservancy's position that carefully planned and implemented harvesting operations can be compatible with biodiversity conservation and social objectives. DFW maintains that harvesting operations conducted on state wildlife lands have been beneficial for biodiversity conservation because they provide new habitats for declining native wildlife species. DFW also maintains that harvesting operations conducted on state wildlife lands have social benefits because they provide enhanced opportunities for hunting and wildlife observation (e.g., bird watching).
Commenter Point 2. We appreciate the Commonwealth's continuing commitment to green certification and its effort to re-certify land for which FSC certification has expired. As part of this re-certification effort, DCR and DFW are required to justify which lands they will exclude from any re-certification, in order to comply with FSC Criterion 1.6, "Long-term commitment to adhere to FSC". It is our understanding that this is an FSC safeguard, designed to ensure that landowners do not game the system -- green certifying only those lands on which they plan to do responsible forest management, while excluding lands where they will continue to do harvesting that violates the rules of FSC. DFW has provided clear justification for why they will not seek re-certification for properties that have been developed as boat ramps, are not forests, or are managed by the US Department of Defense.
DFW Response to Above Point: 2. DFW appreciates support for re-certification of state wildlife lands, and remains committed to conducting timber sales only on lands that are covered by a publicly reviewed Forest Management Zone (FMZ) plan. While the great majority of DFW lands will ultimately be submitted for re-certification, only those lands presently covered by a publicly reviewed plan will be submitted in the near term, with additional lands to be submitted (perhaps at subsequent annual certification audits) after completion of publicly reviewed plans. We anticipate that this approach should alleviate any fears that DFW might attempt to 'game the system' by certifying only a subset of lands for which responsible forest management is planned.
The state of Massachusetts is to be commended for its effort to have the majority of public forest lands and wildlife management areas third party certified under the Forest Stewardship Council (FSC) standards. In addition, the staff of DFW has completed the inclusive Massachusetts Wildlife Action Plan as directed by the U.S. Congress. This exceptional 750 page document includes a list of Species of Greatest Conservation Need (SGCN). Twenty-one animal species with declining or vulnerable populations associated with young forests and shrublands have been identified as SGCN. We support the emphasis of DFW on increasing regeneration cutting to meet landscape wildlife habitat goals. The U.S. Forest Service Forest Inventory and Analysis (2005) documents that there has been a long term decline in seedling and sapling forests in Massachusetts. Currently, young stands comprise only three percent of the forest in the state, whereas published wildlife researchers recommends that approximately twenty-five percent of a forest in New England should be in young size classes to support indigenous vertebrate wildlife populations. The data are clear. The forests of Massachusetts are getting older and the suite of wildlife species that utilize young forests are declining. Regeneration cutting by DFW and DCR should be encouraged to fulfill FSC Principle 6: Environmental Impact which states, in part, that "Forest management shall conserve biological diversity and its associated values…".
DFW appreciates WMI's support of FSC certification for state wildlife lands, their recognition of the extensive effort that went into producing the Massachusetts Wildlife Action Plan, and their support for establishing a range of forest successional conditions on DFW lands to secure biological diversity and its associated values. DFW maintains that its landscape composition goals for wildlife habitat are supported by current scientific literature.