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NJ Highlands Coalition Joins Public Debate On DEP Sparta Mountain Logging Plan

Letter To Towns Blasts Professional Foresters’ Scientific Misrepresentations

“… this statement is patently false …”

(this is part seven in our series on DEP’s proposed Sparta Mountain WMA logging plan – see parts 1-6 here.)

"This land has been permanently protected"

“This land has been permanently protected”

Today the NJ Highlands Coalition wrote a scathingly critical letter to local officials that rebuts claims made by private professional foresters in support of NJ DEP’s proposed Sparta Mountain WMA logging plan.

The primary value of the letter is to provide strong and credible arguments from professional ecologists and academic experts. That should be persuasive in convincing State and local officials that there are many legitimate criticisms of the plan.

The letter is focused on and destroys the arguments of a professional forester, but it also serves as a direct critique of very similar NJ Audubon and DEP’s rationales in support of the logging plan.

While I would have made slightly different and broader policy arguments, used a more critical tone, and explicitly included NJ Audubon and NJ DEP, below I share the full text with readers (emphases in original).


Hon. James Oscovitch

Mayor, Byram Township

February 17, 2016

Re: Sparta Mountain Wildlife Management Area Proposed Forest Stewardship Plan

Dear Mayor Oscovitch,

The New Jersey Highlands Coalition Natural Heritage Committee would like to provide some history and respond to two items from the second bullet point in the February 7 letter from Steven Kallesser, Allegheny Society of American Foresters, to Byram Township officials:

Item 1: “...individual tree selection cutting/harvest. This type of system is currently being successfully implemented by every forested Farmland Assessed landowner in your municipality.”

Response: For over fifty years, farmland-assessed landowners with more than 50% forest acreage have had to submit “Woodland Management Plans” in order to receive tax abatement. The requirements for a Woodland Management Plan are now considered rudimentary, as they give virtually no consideration to ecological issues or sensitive natural resources. Recognizing this, many environmental groups worked hard on New Jersey’s Forest Stewardship Act of 2009, in which Senator Smith at first tried to make Forest Stewardship Plans mandatory on private lands.

Forest Stewardship Plans are intended to be better than Woodland Management Plans, with extra requirements regarding habitat considerations, protection of rare animals, and monitoring of results. However, industry and other private-interest groups objected to making Forest Stewardship Plans mandatory on private land, saying that private landowners should not be “forced” to upgrade their plans, because that would involve additional landowner expenses not required under the 1964 Farmland Assessment Act. Senator Smith had hoped to fund those additional expenses with fund from the Regional Greenhouse Gas Initiative (RGGI), but that money was eliminated by the Christie Administration.

As a result, Senator Smith was forced to make the requirements of the 2009 Bill voluntary. Therefore, landowners can now choose to upgrade their Woodland Management Plan to Forest Stewardship Standards, and even focus on rare animal species, habitat improvements, and invasive species—rather than on producing wood—without losing their tax abatement, but they are not required to do so. To our knowledge, in the 6 years since the Bill was passed, not one landowner has submitted a Forest Stewardship Plan that focuses on rare species, ecological issues, and invasive species removal and also avoids producing wood products, as allowed by the Forest Stewardship Act.

This lack of submissions has occurred because the NJDEP has not written the required regulations for the 2009 Act in six years, so even the few foresters and landowners who do want to avoid producing wood products are afraid that without the regulations, they will lose their tax abatement status. The one Forest Stewardship Plan employed at the southwest end of Sparta WMA on private land consists largely of clear-cuts (called seed tree harvest by foresters), not single tree selection. The goal of the 2009 Forest Stewardship Act—to encourage greater use of Forest Stewardship Plans for improving sensitive natural resources and habitats while focusing less on generation of income from wood products—is not being achieved. There has been little or no recent improvement in the quality of stewardship on private land.

Item 2:…privately‐owned woodlands are reservoirs of endangered species because forestry practices have created proper structure, light condition, and species composition (page 1, second bulleted point).

Response: This statement is patently false. The vast majority of healthy populations of rare species, especially plants, occur on public lands in New Jersey. There are indeed rare species on private lands also, but we challenge the author of the letter to provide any instance where a population of a rare species has been shown to increase as a direct result of private lands forestry practices. There is no data and little ecological justification that the standards to which forestry is conducted on private lands have ever significantly benefitted a rare species in New Jersey.

Further, ecologically, there is no such thing as “proper.” Forest structure that maximizes current and future timber production or early successional species is completely different from forest structure that preserves high biological diversity. The NJDEP Natural Heritage Program reports that Sparta Mountain WMA has some of the highest biological diversity and number of plant species with extreme rarity of anywhere yet seen in the NJ Highlands. The proposed Plan for Sparta Mountain WMA is an enormous risk to that diversity and rarity.

Regarding rare species on our public lands as opposed to private lands, the requirements for Forest Stewardship Plans do not come close to protecting the “Natural Heritage of New Jersey that is held in the Public Trust.” For example, Mr. Kallesser also wrote the Forest Stewardship Plan for Weldon Brook WMA, located in Sussex County between Route 15 and Weldon Road, in approximately 2012. That plan designates that logging of one sort or another will eventually occur throughout virtually the entire Weldon Brook WMA. Mr. Kallesser indicated in the Weldon Brook Plan that no rare plants occurred at Weldon WMA. We went there, and found an extremely rare plant species in the first hour (least moonwort, a tiny fern in which the NJ subspecies grows in deep forest along shady stream and spring edges, and cannot tolerate aggressive forestry). We found 2 rare species that day. Upon the urging of the New Jersey Highlands Coalition, the NJDEP Natural Heritage Program sent a qualified botanist to the site and he found around 20 species of rare plants. Concerns regarding rare plant species at both Weldon Brook and Sparta Mountain Wildlife Management Areas are not yet resolved, and this is unacceptable.

The NJDEP has determined that there are over 800 species of rare plants in NJ, including hundreds in the Highlands, but concern for their conservation is being trivialized by many foresters, and others promoting the conversion of maturing forests to “young forests.” Many individuals who have little or no botanical or ecological training repeatedly stated in public that rare plants in NJ do not matter, because many of these plant species are more common far to the south, north, or west of our state. In fact, rarity near the edges of a species’ geographic range is incredibly important from an ecological and evolutionary point of view.

Many rare plants and animals will suffer from implementation of the “Young Forest Initiative.” All rare species must be properly considered before the logging proposed to implement the “Young Forest Initiative” can be carried out without doing irreversible harm to public trust resources.

One cannot compare private land forestry to public land forestry. Public land forestry needs to be held to much higher standards – standards that have yet to be adopted in New Jersey. All of the current standards, even the higher quality U.S. Forest Service (U.S. Department of Agriculture) standards and the Forest Stewardship Council Certification Standards, are basically designed for forest lands that are clearly designated to be “Working Forests,” where it is accepted that the extraction of forest products will be a major driver in the management of those lands.

The thousands of acres of land purchased with Green Acres dollars in New Jersey in the last 50 years were not purchased to prop‐up a logging industry poised to return to New Jersey, nor to implement the “Young Forest Initiative” that is sweeping the eastern U.S. in an attempt to increase early successional species at the expense of deep‐forest species. In the New Jersey Highlands, more deep‐forest species are declining than early successional species, but managing for the imperiled deep‐forest species would not assist in the return of an aggressive timber industry to New Jersey.

The Sparta WMA Plan claims that forestry on public lands will assist the ability of private landowners to implement their logging plans. However, nowhere is this a written or stated objective of the NJ Division of Fish and Wildlife; therefore, it is inexplicable that the authors of the plan have adopted that goal in this plan. Instead, the NJDEP and Division of Fish and Wildlife should be serving as the vigilant stewards of our shared public trust resources, including all rare species, water and wildlife.

Before any more plans for large‐scale logging on public lands are approved and implemented, we must first reach agreement on the big picture. We must settle questions such as: Where will logging be allowed, and where will it be forbidden? What lands shall be “Forever Wild?” What buffers shall be placed around streams, wetlands, reservoirs and other waterbodies? How will the impacts on rare plants that will suffer from high‐intensity sunlight and other microclimate changes be addressed? How will vernal pools and rare natural communities be protected? What are the impacts on scenic and historic resources, and how are they addressed? Are quality recreational experiences protected? Are auditory impacts on both wildlife and humans addressed?

Existing Best Management Practices for forestry are poor at best, and often entirely unsatisfactory or nonexistent, regarding the above-mentioned considerations. Yes, small‐scale endangered-species restoration projects may proceed in advance of the big picture being settled, but we should not be approving any large‐scale forestry plans for large preserved public land holdings, such as this proposal for the Sparta Mountain WMA, until there is broad agreement on an acceptable region‐wide, landscape‐level approach. We need to know what will be forever wild, what will be occasionally managed, and what could be aggressively managed, and for what purposes, before lumping every state conservation holding into the Working Forest and Young Forest Initiatives.

In conclusion, we wish to emphasize that our parklands were conserved at great expense of public dollars and efforts, not to attract a timber industry back to New Jersey. We wish to inform interested stakeholders of an issue involving Hunterdon County parkland in 2010 at the Round Mountain Preserve. A forestry plan was developed there and the trees were marked and ready to be logged without any public input, and the Hunterdon County freeholders had not even informed local municipalities or the County Recreation Commissioners. No rare plants were inventoried or considered in the development of the plan, yet the public found numerous extremely rare plant species in one of the oldest and most undisturbed forest tracts in Hunterdon County. The logging plan was cancelled due to public outcry. The New Jersey Forestry Association responded with the following quote from their President, in a lengthy article in their newsletter, lamenting the fact that the logging at the Hunterdon County Park System’s Round Mountain Preserve was cancelled due to objections by the public:

“A well‐managed forest will go on forever, while a forest left to its own devices will die and become useless to anyone…” Richard M. Conley, President, New Jersey Forestry Association, Spring 2011, Newsletter of the NJFA, No. 120.

In reality, New Jersey’s forests originally grew by themselves, have regenerated by themselves since the peak of deforestation in the mid-19th century—to the point where they now support a diverse suite of forest-dwelling animals and plants—and will continue to grow perfectly well by themselves, especially if we can effectively deal with an overabundant deer population and invasions by alien species, which are the current major threats to maintaining biological diversity.

Thank you for your continued consideration of the Sparta Mountain issue.


Cinny MacGonagle, Chair, New Jersey Highlands Coalition Natural Heritage Committee; NJ Highlands Coalition Trustee

Dr. Emile De Vito, Ph.D., Manager of Science and Stewardship, New Jersey Conservation Foundation

Dr. Edward Kirby, Ph.D., Professor of Biological Sciences, Rutgers University; NJ Highlands Coalition Trustee

Dr. Sara Webb, Ph.D., Professor of Biology and Environmental Studies, Drew University

Dr. Joseph Zurovchak, Ph.D., Professor of Ecology, Orange County Community College

Dr. Sharon Ann Wander, Ph.D., Wander Ecological Consultants

Wade Wander, M.Sc., Wander Ecological Consultants

Blaine Rothauser, President, BR Environmental, LLC

Dwight Hiscano, NJ Highlands Coalition Trustee

Cc: Joseph Sabatini, Byram Township Manager jsabatini@byramtwp.org
Cheryl White, Byram Township Planning Board Secretary cwhite@byramtwp.org
Margaret McGarrity, Byram Township Environmental Commission mmcgarrity@byramtwp.org Hardyston Township Mayor Leslie Hamilton lhamilton@hardyston.com
Marianne Smith, Hardyston Township Manager msmith@hardyston.com
Anne-Marie Wilhelm, Hardyston Planning Board Secretary amwilhelm@hardyston.com Jefferson Township Mayor Russell Felter rfelter@jeffersontownship.net
James Leach, Jefferson Township Manager jleach@jeffersontownship.net
Stephanie McCormack, Jefferson Planning Board Secretary smccormack@jeffersontownship.net Lori Harvin, Jefferson Township Environmental Commission envirocom@jeffersontownship.net Ogdensburg Borough Mayor Steve Ciasullo ogdensburgnj@gmail.com
Sparta Township Mayor Christine Quinn Christine.Quinn@spartanj.org
Sparta Township Council sparta.council@spartanj.org
William Close, Sparta Township Manager William.Close@Spartanj.org
Maureen Donnelly, Sparta Planning Board Secretary maureen.donnelly@spartanj.org
Janice Stevens, Sparta Environmental Commission Janice.Stevens@spartanj.org

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