Jeff Wiegert, Supervising Forester, NYS DEC
21 South Putt Corners Road
New Paltz, NY 12561-1696

Dear Mr. Wiegert,

I am writing this letter to register my strong opposition to the proposed implementation of the DEC unit management plan, and the “model forest” project, on New York State DEC lands at Ninham Mountain in Putnam County. I am sending this notice by email, but will also provide hard copy via regular mail.

Allow me first to offer personal credentials, in support of my presentation of the basis of my opposition. I wear two hats: one as a science teacher at Greenwich (CT) High School; the second as a Field Associate of the American Museum of Natural History, Invertebrate Zoology Division. (The views offered here are not meant to be construed as representative of either of these institutions). I received a Ph.D. in Entomological Sciences from University of California, Berkeley, in 1988. I was a resident of Brewster from 1973-1974, and again continuously since 1991. I have been involved since the early 1980’s in research on biodiversity and invasive species. Though my focus has been on insects, my experience has made me aware of the fact that what occurs in the entomological world is a mere reflection of trends in our biodiversity and invasive species crises spanning broad taxonomic categories.

A major problem posed by a forestry plan encouraging even-aged stand management, coupled with thinning (removal) of “undesireable” species, is that it reduces the inherent biodiversity of the forest by removing resources that are significant (and in the cases of host specificity, essential) for numerous species. Since I am most knowledgeable about Hymenoptera (bees and wasps), I can use these as examples. Many species of Halictidae bees use small-diameter pre-existing cavities in wood as nesting and/or hibernation sites. Such cavities, which we might call microhabitats, are often created by other insects, such as beetles that bore into wood (often wood that is dead or unhealthy). The existence of multitudes of microhabitats in a natural forest of mixed plant species and ages (and yes, even dead! trees allowed to decompose according to nature’s schedule) is what makes a forest healthy. The wood-boring beetles, in addition to providing habitat for bees, might link into the food chain by providing food for certain birds or other animals. Bees, in turn, would be important pollinators of our plants. Other Hymenoptera species are predators and parasites, and are significant, though often under-appreciated, in that they regulate populations of other insects, including forest pests. The diversity of microhabitats, therefore, is important for overall forest health, and is what the proposed plan would reduce.

Biodiversity of natural systems is promoted by the New York State Museum and the New York State Biodiversity Research Institute, and by the occasional “Bioblitz” activities that they sponsor, and to which I sometimes am able to contribute as an expert entomologist. I encourage you to take advantage of these educational opportunities provided by New York State government. The contact person would be Dr. Ronald Gill at the NYS Museum.

A second unfavorable aspect of the proposed logging plan is the likelihood that the forest disruption will provide an avenue for invasive species, especially noxious plants, promoting accelerated degradation of the forest. The DEC, through its management practices (if they are to be construed as such) of the past years has already caused great damage to the Ninham Mountain unit. I have been visiting and studying at Ninham Mountain since 1973. The road to the tower is clearly the avenue for incursion of noxious alien species such as multiflora rose and barberry. Within the last decade, there have also been significant inroads made by garlic mustard and oriental bittersweet. These latter two were definitely not present in 1973! If DEC is serious about forestry, perhaps ecologically sound management of invasive plants would be a good place to start. And vigilant preventive measures are always the best approach to controlling invasive species. The proposed logging projects fly in the face of common sense here; the phenomenon of invasives using logging roads as invasion corridors is so widespread that it is shocking that these plans are not repudiated on this basis alone.

Another troubling aspect of the DEC track record (unfortunately, the track record might be the best indicator for the future) of “management” is the destruction by siltation/sedimentation of the small pond in the vicinity of the gate on the road to the tower. This pond appears on the USGS topographic maps, and was a regular feature in my memory until the late 1990’s, when improvements to the tower road were implemented. Pond destroyed! It would be extremely risky to replicate this small “experiment” in road-improvement/erosion-control on the larger scale proposed, with drainage directly into a NYC reservoir!

I am aware that others have communicated to you the importance of Ninham Mountain as a regional recreational resource. It has value as a scenic, serene refuge allowing people to feel connected with nature, to experience a natural forest environment, even if during a quick retreat up the tower road. I certainly share these sentiments, and have no doubt that the proposed changes in forestry/management practices will constitute an abominable desecration. But I do want to emphasize here that the proposed plans cannot be considered to enjoy widespread support from the scientific community, and that opposition has a basis in the recognition, and hopeful application, of sound ecological principles. I cannot envision an outcome where the benefits of the proposed activities will outweigh their overall environmentally detrimental effects. The public forests of Putnam County should be allowed to become/remain natural forests in whose health we should all rejoice.

Sincerely,

PG,
Southeast

CC: Erin Crotty, NYS DEC
Jeff Green, Plan Putnam