“Protecting Indiana’s Public Forests”
P.O. Box 1074, Bloomington, IN 47402
http://www.indianaforestalliance.org
To whom it may concern:
Please accept these comments on behalf of Hoosier Forest Watch and the Indiana Forest Alliance in regards to the
management of Indiana’s state forests.
Since 2002 logging in Indiana’s state forests has increased by 1,000%, from 1.4 million board feet sold in 2002 up to
14.2 million board feet sold in 2012. This dramatic increase in logging has come at the expense of public recreation
and habitat diversity in our state forests and, according to a report in “The Hardwood Ecosystem Experiment: A
Framework for Studying Responses to Forest Management,” is occurring in spite of the public’s general opposition to
timber harvests from state forests. (pg. 270)
The Division of Forestry (DOF) claims to use a mixed-use management policy to best manage Indiana’s state forests to
benefit recreation, habitat and wildlife diversity, and timber production, but in practice the DOF has made timber
production the top priority at the expense of the other two. Considering the fact that nearly every Draft Resource
Management Guide that has been posted for public comment since 2008 recommends a commercial timber harvest, it
is clear that timber production is the primary mission of the DOF, supported by selective science and “educational
interventions” to persuade public opinion.
All the “educational intervention” campaigns in the world cannot deny hikers and other state forest users what they
actually see happening in our state forests. In the past year alone, large sections of the Knobstone Trail and the
Tecumseh Trail have been closed for logging activities in addition to several shorter horse, hiking, and mountain
biking trails throughout the state forest system. Indiana’s trail system draws recreationists from across the Midwest,
bolstering the local economies of communities near state forests, particularly in the Yellowwood/Morgan-Monroe
complex and in Clark State Forest near the Louisville metropolitan area. This sustainable economic activity is severely
threatened when commercial timber harvests lead to trail closures as well as habitat and aesthetic degradation. We
believe that recreational users of Indiana’s state forests should be given an equal voice as commercial timber interests
in the management of these public forests. Therefore, we are calling for an end to any current or proposed timber
harvests along the Knobstone and Tecumseh Trails, as these two trails are the longest in the state forest system and
also two of the most popular.
According to the science used to justify commercial logging of public forests, drastic human intervention is essential to
a forest’s health. We believe this logic to be fundamentally flawed. Forests have proven to be remarkably resilient if
left to mature on their own. The type of forest most desired by the DOF is one dominated by the oak-hickory forest
community, mostly due to the higher timber value of that forest type than that of a beech-maple forest. However,
maps of pre-settlement Indiana show that the vast majority of Indiana’s forests were dominated by old-growth beech
and maple forests, including much of what is now DOF-managed property. In order to maintain an oak-hickory
dominant forest in these areas, the DOF must arrest the natural succession and maturation of the forest in the
desired—and most profitable—stage.
Indiana’s public forests are unique in that they can provide the sort of deep, mature forests that are necessary for
many threatened and endangered species to maintain stable, long-term populations. This kind of habitat cannot be
found in private forests, the average size of which is a mere twenty acres, or in our state parks, which serve as a sort of
public playground and are subject to development of infrastructure and visitor facilities. Such threatened and
endangered species as the eastern box turtle, cerulean warbler, timber rattlesnake, and the gray bat rely on deep, wild
and contiguous forests, as well as the critically endangered Indiana bat. The DOF has chosen to act in complete
disregard for the recovery efforts of the Indiana bat, operating without an approved Habitat Conservation Plan and
blatantly ignoring forest management guidelines issued by the US Fish and Wildlife Service Bloomington Field Office
(BFO) that would significantly reduce the adverse impacts of the DOF’s logging operations on the Indiana bat and its
chances of recovery.
The DOF has been posting Draft Resource Management Guides (DRMG) on the internet since 2008 as a means of
soliciting public comment. Almost everyone one of these guides prescribes commercial timber harvest as part of the
silvicultural prescription. Unless one is to search specifically for these DRMGs using the right search terms on the
DOF’s website, it is nearly impossible for the average citizen to find where these guides are posted. For management
purposes, each state forest is divided into compartments, which are further divided into tracts, and each DRMG is
created for a particular tract. However, compartment and tract maps for each state forest can only be obtained by
submitting a special request from the IDNR’s headquarters in Indianapolis. It is unreasonable to expect the public to
make informed public comments if the basic materials necessary to understanding what a DRMG is proposing are not
easily obtained.
Further, we believe that the DOF should make a more concerted effort to publicize proposed state forest timber
harvests to the public-at-large and not just the private timber industry. Through our outreach efforts we’ve learned
that the much of the public does not even know that commercial logging happens in Indiana’s state forests. We believe
it is the right of the public to know how their public lands are being managed, and it is the responsibility of the DOF
and IDNR to make every reasonable effort to notify the public of their practices. The Wisconsin Division of Forestry is
required by state law to publish all proposed state forest timber sales in the newspaper with the highest circulation in
the affected county. While Indiana law does not require the DOF to do so in this state, the transparency added by such
a procedure easily justify the minimal cost. We ask the IDNR to issue official press releases on its website for each new
DOF timber sale, and we believe that all proposed timber sales that are up for public comment should be posted on
the notice boards at each state forest office and that each upcoming timber sale be posted at state forest offices at least
thirty (30) days before the sale is scheduled to occur.
Finally, we are calling for the DOF to abide by all state and federal laws pertaining to the management of public
forests. We have seen violations of the Clean Water Act at sites that were recently logged, with treetops and other
slash piled in ravines and perennial creeks. These violations were witnessed in Clark State Forest on the east side of
Deam Lake and in the Panther Creek area of Yellowwood State Forest. There continues to be explicit violations of the
Endangered Species Act in regards to the Indiana bat. This issue is especially urgent considering the havoc being
wreaked upon Indiana bat populations throughout its range due to white nose syndrome. And we believe that the
DOF’s exemption from the Indiana Environmental Policy Act (IEPA) is unjust and was done in bad faith. It is absolutely
essential for an agency that has such a significant impact on the environment to complete a thorough Draft
Environmental Impact Statement for each proposed timber sale that includes a comprehensive analysis of
environmental impact, mitigation efforts, and alternatives to the proposed action.
Hoosier Forest Watch and the Indiana Forest Alliance believe that Indiana’s state forests should be preserved for
natural diversity and dispersed recreation, and the current commercial logging program of the DOF is in direct
conflict with those two priorities.
Thank you for your time, and I look forward to your response.
Sincerely,
Myke Luurtsema
Coordinator, Hoosier Forest Watch
Hoosierforestwatch@gmail.com
(812) 361-9167