The Framework Is A Formula For Status Quo Logging And Climate Neglect
Importantly, mechanical thinning results in a substantial net loss of forest carbon storage, and a net increase in carbon emissions that can substantially exceed those of wildfire emissions (Hudiburg et al. 2013, Campbell et al. 2012). Reduced forest protections and increased logging tend to make wildland fires burn more intensely (Bradley et al. 2016). This can also occur with commercial thinning, where mature trees are removed (Cruz et al. 2008, Cruz et al. 2014). As an example, logging in U.S. forests emits 10 times more carbon than fire and native insects combined (Harris et al. 2016). And, unlike logging, fire cycles nutrients and helps increase new forest growth. ~~~~ Letter To Congress By Over 200 Scientists
A full year after it was formed, tomorrow the Senate Environment Committee Chairman Bob Smith appointed co-chairs of Smith’s Forestry Task Force will present their “Framework” recommendations to an unusual joint hearing of the Assembly and Senate Environment and Agriculture Committees.
Keeping with Senator Smith’s tight control of this entire process, Trenton sources tell us that there will even be Smith hand picked invited guests that will testify, but no open public testimony and certainly critics need not apply. Smith is clearly frustrated by his decade long failure to pass controversial pro-logging legislation. He created the Task Force as a vehicle to provide cover for a new package of the same old bills.
Upon its draft release for a few days of public comment during the holidays in December, I bulleted some criticisms, calling the document a “non-starter”, see:
I hate to say it, but I told you this was coming. I initially tried to set guardrails and policy priorities for this runaway train, but my recommendations were not even considered and summarily rejected, see:
So here we are, one year later (and with even more flawed DEP forestry plans and even more PR campaigns underway, including the Pinelands wildfire plan, DEP “Natural Lands”, and a new “Urban Heat Island” initiative.)
So, here’s just a heads up on issues to listen closely to, because the slogans and spin will be overwhelming:
I) Critical Issues The Framework Ignores
1. The Framework applies only to publicly owned forested lands – not private lands where logging may continue unregulated. Public lands are only about one half of NJ’s forests. NJ can not protect forest resources or seriously respond to the climate crisis by ignoring half of NJ’s forests:
Recommendation 1:
The NJDEP should be directed to initiate and conduct a statewide planning and mapping process for forested public land
The same narrow scope and restriction to public lands is applied to afforestation and reforestation:
Recommendation 5:
The NJDEP should be directed to identify areas where afforestation and reforestation should occur on public lands.
2. The Framework explicitly grandfathers all current DEP Forest Management Plans (like Sparta Mountain and other Highlands and Pinelands logging) and programs, including recent scientifically flawed and destructive Statewide forestry policy under the DEP Forest Action Plan and the forestry related issues in the DEP 80X50 Climate Science Report.
The Framework hides this massive loophole under the following caveat, which is presented right up front and not in the body of the recommendations:
None of the recommendations are intended to interfere with current approved forest management plans and their associated activities.
3. The Framework does not recommend that science based carbon storage and sequestration goals, policies, verified quantification methods, and regulatory standards be created and enforced by DEP.
4. The Framework makes no recommendations to regulate forest resources as forests (e.g. like wetlands, streams, wildlife, and groundwater are regulated by DEP as public resources), or to mandate that forestry practice fully comply with existing DEP regulations, like wetlands, Category One waters, Highlands, or stormwater management.
5. The Framework does not recommend: a) creation of a pro-forestation policy, b) preservation of existing forests and large old trees, c) that NJ’s current narrow Reforestation Act “no net loss” law be expanded to all tree removal projects, or d) that a new urban forestry program be created and driven by mitigation offsets from development projects and additional new carbon revenues (not merely current law which provides just 10% of RGGI revenues). For some ideas on that, see:
The only positive recommendation (#6 – DEP to designate carbon reserves) is accompanied by a HUGE “exception” loophole that guts any carbon reserve program before it is even created. DEP is already logging NJ forests based on “forest health” and “wildfire risks” and “carbon defense”:
Carbon reserves should be defined similar to “ecological reserves” in the Natural Areas Program as areas “managed to allow natural processes to proceed with little or no habitat manipulation with the exception that management will occur only to address ecological or safety threats, as approved by an oversight council** that includes a mix of NJDEP representatives and private interests representing appropriate expertise.
Read this excellent article for an overview of exactly what’s coming tomorrow:
II) The Framework Recommends Flawed Status Quo Forestry And Continued Mismanagement
In addition to the above serious flaws of omission, the Framework is equally flawed by what it recommends.
1. The Framework promotes logging and supports the DEP’s current flawed policies:
Recommendation 7:
The NJDEP should be directed to identify areas where active management is needed to promote future carbon sequestration, maintain biodiversity, and to address current and future threats to ecological health.
This is consistent with the carbon sequestration goals identified in the NJDEP Global Warming Response Act 80×50 report,* which discusses proactive management for carbon defense including thinning and burning.
The DEP Forest Action Plan and Pinelands and Highlands forestry plans currently justify “active management’ and “thinning” – which are euphemisms for logging – to promote ecological health, prevent wildfire, and as “carbon defense”. The Framework uncritically accepts these flawed DEP policies (see above letter to Congress).
2. The Framework promotes expansion of current DEP prescribed burn policies and practices and supports the Prescribed Burn Act:
Recommendation 12:
The NJDEP should continue to use fire as an important management tool based upon sound science. The most significant action the agency can take on this issue is to fully implement the Prescribed Burn Act,
In the wake of a major New Mexico wildfire that was started by a prescribed burn, the US Forest Service recognized the need to reform prescribed burn models and practices in light of new science on climate, public safety, and air quality. NJ’s development and population density raise serious safety issues, yet very few people understand that the Prescribed Burn Act provided an ill advised liability exemption for damages from an out of control prescribed burn like New Mexico.
NJ also has serious Clean Air Act non-attainment public health issues for ultra-fine and fine particulates (PM 2.5), which are made much worse by prescribed burns. The framework ignores all this science. See:
3. Bowing to and reflecting the power of the hunting lobby – which controls much of DEP’s Forestry Policy – the Framework recommends creation of a commercial market for the sale of deer meat!
Recommendation 14:
The NJDEP should be directed to measure and reduce deer densities in our public forestlands to ecologically sustainable levels, with guidance from the Science Advisory Panel.* Specifically, the NJDEP should identify and implement new and innovative steps,** such as establishing a pilot program for commercial sale of venison,
How sick is that?
4. Cynically, under the guise of prohibiting commercial logging, the Framework actually promotes commercial logging! The Framework also supports the propaganda and bad science of the forest products industry:
Recommendation 15:
The NJDEP should not include commercial profit as a goal in any forest management plan* on public land.
Commercial timber management should not be a goal for any forest management plan on public land. Wood products can be sold in instances where cutting and removal of wood is a necessary part of an approved plan with ecological health, climate, or other non-commercial goals.
The DEP currently exploits flawed and scientifically false justifications – like wood products sequester carbon and “thinning” promotes ecological health – to justify logging. They allow logging contractors to profit from the sale of wood by giving away timber and logged products for free, thereby masking the real costs of the logging program.
5. The Framework supports creation of carbon markets that would commodify and monetize our forests:
Recommendation 16
funding to include management activities; tapping carbon markets including RGGI funding;
Tomorrow, listen closely to NJ “conservation leaders” as they sell out and support this garbage.
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