Sparta Mountain Update – A Funny Thing Happened On The Way To The Audit

NJ Audubon “De-designates” Sparta Mountain As High Conservation Value Forest

 Private deregulation in action

Brief Update

I’m pleased to report that a lot has happened since we last wrote about the DEP’s proposed logging plan for Sparta Mountain Wildlife Management Area (SMWMA).

In a nutshell: Public and media awareness are growing. A group of expert conservationists have formed to review the DEP’s plan. Grassroots opposition has organized, and local environmental commissions and local governments have raised concerns with DEP.

In response DEP is backpedaling and again extended the public comment period until March 1 and pledged to hold a public hearing.

Professional foresters and NJ Audubon have countered with a propaganda campaign and website to defend their deeply unpopular plan.

I will write in detail about these developments in future posts – for today I want to focus on NJ Audubon’s recent and perhaps their most outrageous move that has angered leading NJ conservationists and, in my view, seriously undermines their credibility and integrity.

NJ Audubon de-designates Sparta Mountain as “High Conservation Value Forest”

NJ Audubon is certified and manages commercial logging on over 12,800 acres of forests in NJ under the private “Forest Stewardship Council” (FSC) program (see: FSC US Forest Management Standard (v1.0) – Forest Stewardship …).

The overwhelming majority of this forested land – 91%  – is located in two publicly owned forests in the Newark Watershed and on Sparta Mountain WMA, which are Audubon’s two largest FSC “Forest Management Units” (FMU’s) (see Appendix VII).

Under FSC standards, NJ Audubon designated both the Newark watershed lands and Sparta Mountain FMU’s as “High Conservation Value Forests” (HVCF) due to exceptional biodiversity (SMWMA) – (not certain of basis for Newark Watershed HCVF designation). HCVF’s are subject to strict management standards that tend to promote preservation and limit the intensity of commercial logging in order to protect those high conservation values. FSC management options for HCVF include preservation and “no cut”.

Intent: High Conservation Value Forests are managed to protect and maintain their identified high conservation value attributes. In some cases, active management is consistent with these attributes, and in other cases (e.g., most old growth forests), active management is specifically precluded.

According to FSC standards, mapping HCVF should be based on a “precautionary approach”, particularly under uncertainty or lack of data, including issues like suitable habitat and presence or absence of species:

2.6.2 | Using the precautionary approach

The Precautionary Approach means that when there is a threat of severe or irreversible damage to the environment or a threat to human welfare, responsible parties need to take explicit and effective measures to prevent the damage and risks, even when the scientific information is incomplete or inconclusive, and when the vulnerability and sensitivity of values are uncertain14. In the context of HCV identification, this means that when there are reasonable indications that an HCV is present, the assessor should assume that it is present.

But, in contradiction of any “precautionary approach”, shockingly, in an FSC audit (2013) of NJ Audubon’s compliance with FSC standards, on page 4 we learn that:

NJA modified its High Conservation Value Forest (HCVF) assessment by removing most of the Sparta Mountain Wildlife Management Area from HCVF status. The prior classification was based on landscape habitat suitability models and not on actual presence/absence data species and ecosystems that would contribute to HCVF classification. This decision was based on stakeholder input and field surveys by NJA confirming that the species predicted by the models did not occur or if present they were not likely to be there in sufficient numbers to indicate HCVF status. See Appendix I.

Got that? But why would NJ Audubon want to do that?

Because it looks really bad for a self described bird conservation group to support commercial logging of HCV forests with significant habitat and/or populations of rare, threatened or endangered species of plants, amphibians, reptiles and birds?

Because it might make the foresters uncomfortable and limit logging?

It is a form of private deregulation. The fox guarding and designing the hen house AND writing the standards for hen house construction!

What’s happening here is like allowing a developer to designate a stream and determine the width of the regulated buffer, or to delineate a wetland and determine the wetland’s classification and transition area and mitigation requirements – all by himself with no DEP or public oversight. If the standards were too restrictive, the builder could simply modify them, e.g. “de-designate” a stream designation if the buffer widths were too big or reclassify the wetland if the transition area or mitigation requirements were too costly. And then, after designating the resource value and setting the standards to protect that resource value, to hire the inspector (auditor) to determine compliance with the standards set by the builder! And all with no public process or local or sate government oversight or approvals.

I contacted FSC’s auditor (Rainforest Alliance, contact info below) to question Audubon’s de-designation by arguing that it conflicts with FSC’s “precautionary policy”, FSC HCVF criteria, and existing field studies that contradict the basis and rationale offered by NJ Audubon in support of the de-designation.

But, I am not an expert and lack the credentials to back that up. But I can rely on experts in USFS who also noted conservation values on Sparta Mountain and he Highlands region, including:

The Highlands serve as a major migratory flyway for many neotropical bird species, many of which populations are in decline. Of particular concern to ornithologists are the 70 to 75 species of interior nesting neotropical migrants such as the red-eyed vireo, American redstart, Kentucky warbler, and eastern pewee. These species require large undisturbed forest patches. NJ/NJ Highlands Regional Study (US Forest Service, 2002)

So, here is the reaction of a prominent expert PhD conservation biologist who is familiar with SMWMA:

Sometime before April 2012, in its Forest Stewardship Council certification process, New Jersey Audubon modified its High Conservation Value 1 (HCV1) assessment for the lands in its collective “Forest Stewardship” planning assemblage, by removing most (perhaps all ?) of the Sparta Mountain Wildlife Management Area from “HCV1” status.

Their prior classification of Sparta Mountain WMA as “HCV1” was based on landscape habitat suitability models and NJ Heritage database reports, not on actual presence/absence data of species and ecosystems that would contribute to a “HCV1” classification. The removal of the “HCV1” classification for Sparta Mountain was based on stakeholder input and field surveys by NJ Audubon, whereby they assert that various species predicted by the landscape models and NJ Heritage database did not occur there, or if present they were not likely to be there in sufficient numbers to indicate “HCV1” status. (See Appendix I.4, starting on the bottom of page 19 of the Rainforest Alliance Audit of the NJA Forest Stewardship Council Certification. The date on this document is 2012. http://fsc.force.com/servlet/servlet.FileDownload?file=00P4000000DX5LzEAL )

Since then, NJDEP Natural Heritage has documented numerous rare plants throughout Sparta Mountain; we also know of bird surveys and reptile surveys from previous periods that have found numerous rare animals. Besides the old (including NJ Audubon bird surveys) and new data spanning over 20 years, the collective conservation community has known for decades that Sparta Mountain contains a regionally and nationally significant concentration of biodiversity values (the definition of “HCV1”).  

It is absolutely unacceptable that Sparta Mountain WMA is not-considered HCV1 in NJ Audubon’s Forest Stewardship Council certification. This audit document is difficult to tease apart to look for additional items of interest/concern, since one has to be familiar with all the jargon. But this deviation from what we all know to be obvious, that Sparta Mountain has high regional biodiversity significance, is a real shock. Many thanks to Bill Wolfe who found this FSC Audit Document and noticed that Sparta WMA had been downgraded. There may be other items in the audit document that we may want to bring up with Rainforest Alliance.

I let Jamie Overton of the Rainforest Alliance aware of this concern at about 4PM today. Her contact info is below, in case any of you would also like to contact her, which I strongly encourage. It also turns out the Rainforest Alliance field person will be at Sparta Mountain tomorrow (Wednesday) to inspect/determine if the logging and other activities that have taken place so far conform to standards (I expect that on-the-ground work probably conforms just fine). Of course, a field visit on a cold February day will reveal nothing about the biodiversity value classification of Sparta Mountain WMA.

Auditor’s contact info: