Natural Lands Trust,
Hildacy Farm,
1031 Palmers Mill Rd.,
Media, PA 19063

www.natlands.org

tel: 610-353-5587
fax: 610-353-0517
members(atsignhere)natlands.org

Dear Trustees,

I have been asked by Dr. Patricia Gibble to review the Pennsylvania Forest Stewardship Plan (Plan) for the Clarence Schock Memorial Park at Governor Dick writtten by Mr. Barry S. Rose, CF and dated February 15, 2005. The background and perspective with which I reviewed the Plan is principally as a 20-year employee of the Natural Lands Trust, a regional land conservancy based in Media, PA. For fifteen years of my tenure at the Trust I was the Director of Land Stewardship and was responsible for the stewardship of the trust's 45 preserves totalling over 15,000 acres. Currently, I am Senior Stewardship Planner fot the Trust and have assessed tens of thousands of acres of public and private natural areas within Pennsylvania that range in size from a few acres to several thousand acres. Properties for which we have written stewardship plans that are of equal size and complexity to the Governor Dick include Hawk Mountain Sanctuary and Winterthur Gardens. I hold a Master of Forest Science degree and am a qualified plan writer under the Pennsylvania Forest Stewardship Program.

General Comments:

The plan was well written according to the guidelines of the Pennsylvania Forest Stewardship Program. It provides a detailed inventory of the site's natural resources (except for the herbaceous plants), highlights stewardship issues and current and potential uses, and provides appropriate reference information for the landowner. The Plan correctly targets the reduction of the deer population and the control of invasive plant species as the highest reccomendations for improving the health of the forest.

In my opinion, however, the significance of the natural resources and the complexity of current and potential use on the Governor Dick property calls for a more detailed analysis - one that goes beyond the guidelines of the Forest Stewardship Program. This should happen before the initiation of any new management activities.

The question that needs to be answered in light of the many ecological, environmental, and recreational benefits highlighted in the Plan is which of these "conservation values" holds the greatest importance. Management recommendations should be driven by the conservation value(s) with the greatest importance, what we call the "conservation priority". Management recommendations should be based first and foremost on how best to protect and enhance the conservation priority of the site.

A determination of which conservation value is the conservation priority for a site should include the relative importance of each conservation value within the regional landscape. While the Plan identifies conservation values (species of special concern, interior forest, high quality water resources) within this context, it does not provide a forum for weighing these values. Again this is a shortcoming of the program guidelines and not necessarily the quality of the plan. In most cases, Forest Stewardship Plans are written for private landowners who individually (or with their spouse or children) determine the goals for the plan. Given that the Governor Dick Park is a public site with significant natural, cultural and recreational resources and educational potential, determination of the conservation priorities and how to protect and enhance them should have a more comprehensive analysis. The discussion should also include a determination of the appropriate types and levels of public use, long-term expenses (operating and capital), revenue sources, and should result in a comprehensive Stewardship Plan.

Specific Comments:

The issue that particularly needs greater attention is the status of species of special concern. The Plan indicates the potential for the Governor Dick property to harbor two federal and seven state species of special concern. In my experience this is an extraordinary number of federal and state "hits" for an individual property in Pennsylvania. I have conferred with Dr. James Thorne, Director of Science at the Trust, who formerly was the Director of Conservation Programs for the Pennsylvania Chapter of the Nature Conservancy. Dr. Thorne concurs that the potential for this number of federal and state species of special concern on one site is quite rare.

There are recommendations within the Plan that could jeopardize the species of special concern. First, they could be directly impacted by logging operations and the use of herbicides. Second, disturbance created by logging or new walking trails will likely spread invasive plants (noted in the Plan as currently confined to road and trail borders) into new areas via logging equipment and the shoes of walkers. Two of the invasive species noted in the Plan - garlic mustard and stiltgrass - are particularly aggressive and capable of quickly displacing native herbaceous species.

Conclusion and Recommendations:

The Forest Stewardship Plan for the Governor Dick property clearly meets the guidelines of the Forest Stewardship Program. However, the ecological, cultural and recreational significance of the site warrants a more comprehensive analysis, one that goes beyond the scope of a forest stewardship plan.

This conclusion should not be viewed as a rejection of the Plan or the recommendations provided by it, nor a case against timber harvesting. Rather it is an opinion based on 20 years of experience with Pennsylvania natural use areas that the Board of Trustees is caring for a very unique property, one with extraordinary plant and animal resources, and a high recreational ond educational potential. In the end, the Plan may be the appropriate way to proceed to protect and enhance the conservation priorities determined by a comprehensive analysis. At this point, I do not believe that sufficient analysis has been completed to make that determination. I would recommend the following course of action.