To the Editor:
This letter was shared with the editor, and sent to officials at the state Department of Conservation and Recreation (DCR).
We are writing to ask that you initiate a pause on the logging project proposed for Manuel Correllus State Forest on Martha’s Vineyard, the home of the signatories. Our concern is the lack of a comprehensive business and financial plan for the proposed activity.
The proposal for plantation clearing and “restoration” of 175 acres of the State Forest lacks 1) background data, 2) operational details for each phase of the project — plantation removal, restoration, and perpetual management, 3) assessment of financial costs and environmental impacts, and 4) community and stakeholder engagement.
No reputable institution or business would consider proceeding with the expenditure of hundreds of thousands of dollars in the absence of this kind of thorough planning information.
We therefore request that DCR pause its plan, develop the appropriate background information, engage sincerely with the Vineyard community, and then formulate a comprehensive decadal plan that is fiscally and environmentally sound.
Our detailed planning and budgeting concerns include the following:
Lack of background information
DCR has affirmed that little data exist on the forest to be logged: no basic timber inventory, no ecological survey of the flora and fauna, and no assessment of the biomass/carbon stored above and below ground.
No forestry project should proceed in the absence of these basic data and of plans for controls and resurveys to assess the impacts of management and success in reaching management goals.
Lack of operational details on all phases of the project
- Harvesting the white pine forests. Little to no information is available on: the rationale for clear-cutting versus other approaches to forest management, including ones that could engage local harvesters and yield local products over many years; a plan for the harvested material beyond chipping and transporting it from the Island.
- Restoration after clear-cutting. No information has been provided on: the specific nature of the vegetation to be “restored”; equipment to be used and duration of the restoration period; plans to control invasive and undesirable species, including the potential use of herbicides; how restoration success is defined.
iii. Perpetual management. DCR information represents “barrens” (an extremely vague term) as the desired future condition, and indicates that the area will be managed in perpetuity to prevent natural forest succession. No management plan has been presented. Such a plan should describe, in detail:
- Desired long-term condition of the vegetation
- Frequency and type of management
- Staffing and equipment needed
- Projected costs and source of funds
- Future projects. DCR has indicated the future intention to “restore” 800-plus acres of plantations, but has provided no details on the scope, timing, and costs of these activities. If this is the first of many projects to eliminate the plantations, why is the entire scope of the project not presented, as required under the Massachusetts Endangered Species Act?
Assessment of financial and environmental costs
- Financial costs. Only vague verbal cost estimates (“$10,000 per acre”; “more than $1 million total”) have been provided for the logging phase of the project. Currently no estimates exist for:
- “Restoration” activities
- Remediation of environmental damage
- Ongoing perpetual management to maintain the “restored” condition
- The sources of funding for each phase of the project
- Long-term staffing to address chronic shortages and the new management responsibility
- Environmental impacts. In the absence of the information discussed above, the potential environmental impacts remain vague, but include:
- Reduction in climate mitigation. How much stored carbon will be lost to the atmosphere through clearing carbon-dense forests? How much carbon sequestration will be forgone by replacing rapidly growing mature forests with a nonforested condition in perpetuity? How much carbon emissions will be generated over the next two decades through restoration and management by burning and mowing?
- Damage to the soils. Despite recommendations to leave the soils intact (see Foster and Motzkin, 1999) the plan calls for removal of the organic soil layers through mechanical means and fire. What are the climate mitigation, biodiversity, and ecosystem impacts of this action?
- Impacts to the watershed and sole-source aquifer of M.V. What are the potential consequences of nutrient leaching, herbicide application, and possible fuel spills to this critical resource?
Stakeholder engagement
Correllus State Forest is central to the Island’s water supply, recreation, conservation, and history, and yet planning for its long-term management has proceeded with no engagement of the Island community beyond unrepresentative members of an unofficial task force. The voices and input of individuals with decades of experience working on the State Forest, recreating in it, studying it, and drawing from its many resources have neither been sought by DCR, nor attended to. The lack of genuine public debate has also, in effect, canceled out the interests and concerns of residents and officials of the towns whose borders comprise the State Forest and of members of the Wampanoag tribe, which has occupied these lands continuously for the past 10,000 years.
The responsibility lies with the Secretary of Energy and Environmental Affairs and the Commissioner of the Department of Conservation and Recreation to rectify the lack of planning and foresight reflected in the current proposal.
We therefore ask you to pause this activity. We also invite you to visit the Island, to join us in a walk in our State Forest, and to join with the community in further discussion.
Jon Previant, James A. Athearn, Nat Benjamin, Steve Bernier, NaDaizja Bolling, Prudy Burt, Michael Blanchard, Tess Bramhall, Chas De Geofroy, Eric Glasgow, Brad Lopes, Chris Murphy, Megan Ottens-Sargent, Bea Phear, Ben Robinson, Tom Robinson, Katherine Scott, Phil Wallis, David Foster
Martha’s Vineyard
