Friday, November 20, 2015

Draft 2015 State Forest Resource Management Plan Professional Comments & Recommendations Kevin Heatley Restoration Ecologist

Shale gas operations, Tiadaghton State Forest, July 2014,
Photo, Wendy Lynne Lee

Introductory note:

The following are the comments and recommendations of professional restoration ecologist Kevin Heatley concerning the ecological impacts of continuing natural gas industrial expansion in the forestlands of Pennsylvania. His analysis is as precise as it is substantive and should be taken very seriously, as it would not only dramatically curtail current gas extraction operations in the state, but alter the way we comprehend the value of these woodland ecosystems. 
Kevin Heatley:

As a professional restoration ecologist who has worked on conservation planning and habitat enhancement projects nationwide, I want to thank the DCNR for the opportunity to submit comments concerning the Draft State Forest Resource Management Plan. I recognize that, due to political pressure from Harrisburg and the shale gas industry, the natural resource professionals within the DCNR have been put in a difficult position attempting to meet their mission of, “...ensuring the long-term health, viability, and productivity of the Commonwealth’s forests and to conserve native wild plants."

Shale gas development of both our public and private forestlands constitutes a transformative existential threat. It requires dispersed industrialization of the landscape on a level that insures widespread negative impacts to both ecological structure and function. It is important to recognize that landscape-level disruption and forest fragmentation is an intrinsic component of this industry. The extraction and transmission technologies currently utilized to exploit shale gas require infrastructure that directly and dramatically undermines both forest resilience and sustainability.

Shale gas exploitation poses a serious challenge for the DCNR. The peer-reviewed scientific literature is clear: forest fragmentation (the dissection of the forest into smaller parcels) reduces biodiversity by 13% to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles (Haddad et al. Science Advances. 2015). It contributes substantially to forest degradation and species extinction worldwide. Forest fragmentation increases the amount of forest “edge” (the interface between forest and non-forest). 

This transitional zone is fundamentally different in structure and function from interior forest. Edge is characterized by increasing light levels on the forest floor, reduced soil moisture, and a high degree of biological invasion from non-native invasive organisms. These impacts can extend up to 300 feet into the adjacent forest and have direct economic implications for forest landowners. Invasive species, for instance, have been estimated to cost the US economy over $120 billion dollars per year (Pimentel,D., R. Zuniga, D. Morrison. Ecological Economics. 2005).

Interior forest (forest that is at least 300 feet from non-forest) is an increasingly rare habitat. As a species we are quite adept at creating edge with roads, shopping malls, utility ROW, etc. Edge habitat can be created overnight, whereas interior forest takes decades to create. As a central component of unconventional oil and gas extraction, dispersed industrialization is proceeding across vast areas of the US without consideration of the cumulative impacts to forest connectivity. In our region the USGS, using spatial analysis with GIS software, has recently demonstrated that natural gas infrastructure is being placed disproportionally within interior forest systems. 

Penn’s woods are rapidly being 
converted into Penn’s woodlots.

As a specialist in terrestrial ecology and invasive species, I have performed a professional review of the Draft State Forest Resource Management Plan and submit the following observations and recommendations;


The listed goal – “Forest fragmentation, connectivity and patch distribution will be considered in management decisions affecting state forest resources” is a soft target and inadequate to stem the escalation of fragmentation that is currently occurring. While I applaud the DCNR for its efforts to undertake a core forest analysis, this type of baseline information should have been collected prior to the initiation of shale gas infrastructure placement.


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.


The threat of biological invasion by non-native organisms is inadequately addressed within the plan. We know from the science that invasive species and biological invasion is facilitated by both disturbance and physical vectoring mechanisms. It is also directly tied to the increase in edge that accompanies the expansion of both ROW and hardscape. Shale gas exploitation, by its very nature, requires the movement of vast amounts of soil and stone, along with the importation of labor and equipment from various areas across the United States. This is a clear recipe for biological invasion.


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.

The current draft is substantially inadequate with respect to addressing the ecological restoration of degraded lands. It is logically inconsistent that the DCNR has effectively halted the extraction of coal and other minerals from land that has not previously been degraded due to the difficulty in restoring these sites yet it allows the development of shale gas infrastructure without full restoration planning in advance. Given the spatial distribution of the shale exploitation it is critical that ecological restoration and the promotion of an eventual closed canopy be fully budgeted for prior to any site disruption.


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.

The DCNR relies heavily on the concept of adaptive management - monitoring the impacts of shale gas development and subsequently adjusting management guidelines based upon the results of this monitoring (Geologic Resources, Goal #4, Objectives 4.2, 4.4, 4.5) Unfortunately adaptive management is inadequate when dealing with non-linear systems that may be subject to threshold levels of change. An ecological system may respond to a disturbance with a sudden, catastrophic shift to a new baseline state without displaying gradual and detectable indicators of change. After breaching the threshold the energy inputs required to reestablish the original conditions may be so high as to preclude correction. Adaptive management is ill-suited to this type of non-linear dynamics.

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.


The climatic change associated with anthropogenic greenhouse gas emissions threatens to radically complicate the science of natural resource management. Cascading ecological impacts are likely as the phenology of both plant and animal lifecycles is disrupted. Spatial shifts in the natural range of forest species should be anticipated, as should be the challenges associated with increasing incursions of invasive species. The DCNR is to be applauded for incorporating goals and objectives with respect to climate change in the Draft State Forest Management Plan.


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.

While the DCNR has made important strides over the last several years in shifting overall management goals and objectives towards an ecosystem-based perspective, the agency should embrace a central component of ecological science that has direct managerial implications – the concept of Carrying Capacity. Carrying capacity can be defined as the number of individuals or the amount of an activity that an environment can support without significant negative impacts to the given organism and/or its environment. While natural resource and land managers have long successfully utilized this concept in modeling harvest levels of wildlife and other forest resources, it also has direct relevance to the exploitation of non-renewable resources such as shale gas.


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.
Sincerely, Kevin Heatley Restoration Ecologist Bloomsburg, Pa.

Literature Cited:

Haddad, N.M., L.A. Brudvig, J. Clobert, K.F. Davies, A. Gonzalez, R.D. Holt, T.E. Lovejoy, J.O. Sexton, M.P. Austin, C.D. Collins, W.M. Cook, E.I. Damschen, R.M. Ewers, B.L. Foster, C.N. Jenkins, A.J. King, W.F. Laurance, D.J. Levey, C.R. Margules, B.A. Melbourne, A.O. Nicholls, J.L. Orrock, D.-X. Song, and J.R. Townshend. 2015. 

Habitat fragmentation and its lasting impact on Earth’s ecosystems. Science Advances 1, e1500052.
Pimentel, D., D. Morrison, R. Zuniga. (2005).

Update on the environmental and economic costs associated with alien-invasive species in the United States. 

In: Ecological Economics. RePEc:eee:ecolec:v:52:y:2005:i:3:p:273-288.