|Shale gas operations, Tiadaghton State Forest, July 2014,|
Photo, Wendy Lynne Lee
I would strongly suggest the following additional goals with respect to forest fragmentation:
1) No net loss in core forest within the state forest system of land holdings.
2) All management decisions affecting forest connectivity and fragmentation will incorporate a full spatial evaluation of landscape dynamics on forest land (both public and private) adjacent to the state forest system.
3) Shale gas infrastructure shall not be located within core forest patches.
1) Given the long term threat to both biodiversity and forest regeneration - Invasive species suppression and management should have a separate set of goals and objectives.
2) The Guidelines for the Administration of Shale Gas Development on State Forest Lands need to be aggressively updated with respect to invasive species suppression. For instance – the current guidelines only address invasive management within the physical limits of construction. Given the science connecting the creation of edge habitat with the proliferation of invasive species the area of invasive monitoring and suppression should include the 300 foot zone in the forest adjacent to the actual infrastructure footprint.
3) Given that forest edge, by its very nature, promotes biological invasion of undesirable species, edge management should be the responsibility of the entity creating the disturbance conditions and should continue for the entire service life of the infrastructure.
1) As in the DCNR document “Guidelines for Administering Oil & Gas Activity on State Forest Lands” (revised 2013) the State Forest Resource Management Plan should clearly define and delineate the distinctions between ecological restoration and land reclamation. True ecological restoration replaces the full suite of structural and functional values that existed in the biotic community prior to site disturbance. Reclamation, in contrast, merely attempts to stabilize the site against soil erosion by planting an early successional palate of forbs and grasses.
2) According to the DCNR’s 2014 Shale Gas Monitoring Report ecological restoration has not occurred on any shale gas infrastructure site. The report also documented a loss of 9,242 acres of core forest. In order to protect the ecological integrity and future resiliency of our state forest ecological restoration should be a stated goal under the Geologic Resources Management Principle.
3) As an objective under the ecological restoration goal - No shale gas infrastructure should be allowed to be developed within a currently forested system without an approved ecological restoration plan in place. Such a plan must utilize a local reference ecosystem as a template, include detailed projections for budget and implementation, and require active monitoring and maintenance until closed canopy conditions are achieved.
1) The use of the Precautionary Principle should be adopted as a key objective under Geologic Resources Goal #4. Currently not mentioned anywhere within the Draft State Forest Management Plan, the Precautionary Principle places the burden of proof to show an action will result in no significant harm upon the agent wishing to undertake that action. When the scientific data is not available regarding baseline conditions or ecosystem response, the action should not be allowed to occur. For example – no gas infrastructure should be allowed to be placed within watersheds with class A and wilderness trout streams until the Pennsylvania Fish & Boat Commission has completed its statewide assessment of previously unassessed waters.
1) The protection and fostering of forest connectivity should be included as a clear climate change adaptation objective under Goal #1. Forest connectivity is critical to facilitating the migration of animal and plant populations.
2) The development of a carbon budget, one that includes the greenhouse gas emissions associated with shale gas exploitation, for the state forest system should be included as an objective under Goal #2. The development of a carbon budget will help assure that the state forest system is being managed as a carbon sink as opposed to a source of greenhouse gas emissions.
1) In order to assure long term forest sustainability the exploitation of shale gas must be kept to a spatial and temporal scale that does not disrupt the regenerative capacity and biodiversity of our forest resources. Modeling this threshold level of ecological disturbance is a scientific problem, not a political question. Until the ecological carrying capacity of this activity is determined the Precautionary Principle should drive DCNR management decisions regarding the exploitation of geologic resources.I again thank the DCNR for the opportunity to review the Draft State Forest Resource Management Plan. The continued viability of Pennsylvania’s forests, both public and private, is dependent upon the sound application of good ecological science. I sincerely hope my recommendations will assist in this endeavor.