Please write to the address below with your own letter of use this as a sample. The deadline is August 26, 2011.
John Heffernan
99 North Hill Drive
Conway, MA 01341
7/27/2011
DCR Designation Comments
designation.comments@state.ma.us
Department of Conservation and Recreation
251 Causeway Street, Suite 900
Boston, MA 02114-2104
Dear Sir or Madam:
I urge the DCR to change the designation of the Conway State Forest (CSF) from Woodland to Reserve for the following reasons. Mr. William Hill and Mr. Paul Lyons, of the DCR, were kind enough to recently attend a Conway Conservation Committee and share the GIS map developed for the CSF. I believe the Designation Process to be a significant and positive step forward for the DCR. However, this new information caused me to write a second letter concerning the CSF specifically since it was not available at the time of my first letter.
1. The DCR should preserve the heart (1758 acres) of this very large forested area. It is part of a 9000 acres forest if you define it as being bounded by paved roads. That figure could be increased by 50% (13500 acres) if you consider the border as state highways and other major roads. Mass DEP, using the Massachusetts Conservation Assessment and Prioritization System (CAPS) as a tool to trigger detailed review under the Wetland Protection Act, has designated the CSF as a “Habitat of Potential Regional or Statewide Importance” [http://www.umass.edu/landeco/research/caps/data/dep/dep.html#maps]. The CAPS system itself designates much of the CSF at its highest level of ecological integrity [http://www.umass.edu/landeco/research/caps/data/iei/iei.html#Maps].
2. This land can be used to recreate old growth; logging is still allowed all around the CSF. We should provide a balance in this large forest of managed and unmanaged areas. Those of us that have been in old growth forest, for example, in the Savoy area or in the Western states, know firsthand the special spiritual, ecological, and aesthetic value of such lands.
3. We are hopeful that the DCR will be improving its management practices as shown in the Water and Soil Resource Guidelines section of the document. However, we favor permanent protection of this area since changes in DCR personnel, states politics, and DCR funding can change over time. I am concerned that the DCR state forester responsible for the area is still in place. He refused to move a problem plagued (with petrochemical spills) landing in a recent Conway Town Farm logging project and referred the spills as “so-called oil spills” despite the lab report , numerous photographs, and acknowledgment of the town’s forester of the issues. The improved guidelines are also just that and do not appear to regulations at this time. Also, there is no apparent restriction on placing landings close to wetland systems and no requirement that spills less than 10 gallons be remediated. Though DCR claims logging is good for water supplies, logging operations have posed a risk to Deerfield, Conway, and Northampton water supplies in the past with numerous petrochemical spills within 50 feet and uphill from a wetland system that is part of the Town of Deerfield watershed. The DCR itself, states that [reserves have ] “the dominant ecosystem service objectives are biodiversity maintenance and the underlying supporting services of nutrient cycling and soil formation, watershed protection [my emphasis], and long-term carbon sequestration; important secondary services include provision of wilderness/spiritual values and recreation.” At this time, we have no guarantee that the same landing will not be reused with the oil spills coming to the surface again, as occurred during the subsequent ice storm salvage operation at the Conway Town Farm.
4. Designation results in less land available for forestry. This may produce additional pressure to heavily log the CSF with a change in administration, economic need, or renewed biomass activity. It will alter the landscape for years to come and cause noise, traffic, and pollution and it loses money for the taxpayer, according the MA Forest Watch. Though local wood production is an admirable goal, much of our local logged wood goes to Quebec.
5. It appears that the high Woodlands rating for CSF is due to proximity to sawmills, access to roads, and proximity to Northampton and Deerfield water supply lands. Besides the fact that DCR itself lists Reserves as having a high value for watershed protection (was this not reflected in the computer models?), I feel that ecological needs are more important in this case for this special area. The CSF rated very high for biodiversity and plants and animals. It rated low for wetlands in the Reserve model. However, it is readily apparent from walking the area or looking at a topographical map, that there are huge wetland systems adjacent to the CSF, most notably on the Cowls Lumber property. The rating as medium for contiguous forest block must not have taken into account all the adjacent forest and private and protected land. DCR models should have taken into account adjacent areas.
6. Cricket Hill residents have experienced many logging operations during the last 10 years (Deane Lee – 2, Joanie Schwartz – 2, Town Farm-2). We all need wood but haven’t Cricket Hill and Conway residents done their part? No one at the DCR looks at the big picture of the combined logging operations and their impact on a particular area such as Cricket Hill Road, a historic and special area, that has been highlighted as such, with the DCR Deane Lee Trust Conservation Restriction.
7. It appears that a Reserve designation will not change traditional recreation uses and the maintenance of existing trails. We support traditional uses of the CSF, including dirt bikes and ATVs, of which the latter may be looked at the future by the DCR.
Sincerely,
John S Heffernan
