Sierra Club Comments on Tree Mulching Project in Sam Houston National Forest

In November 2021, the Houston Regional Group and Lone Star Chapter of the Sierra Club (Sierra Club) submitted scoping comments to the U.S. Forest Service (FS), in Sam Houston National Forest (SHNF), about the proposed Compartments 29, 36, and 37 Mulching Project (MP).  This proposal would mulch 5-inch diameter or smaller pine/hardwood trees, using heavy machines, on 2,790 acres, south of FM 1375.

According to the FS, the reason for the proposed mulching is to reduce the size of vegetation so not as much smoke is created during prescribed burning.  The FS states that this will help restore a more fire-adapted ecosystem and facilitate the growth of grasses that burn more quickly and produce less smoke.

The Sierra Club, with its comment letter, initiated public collaboration with the FS to reduce environmental impacts, protect important natural resources, and implement more ecosystem management elements.  The Sierra Club and FS participated in a conference call about the proposal on November 9.  The Sierra Club submitted scoping comments on November 15.

Before submitting scoping comments, the Sierra Club visited Compartments 29 and 37 on November 5 and 11 to walk and view the area proposed for mulching.  Sierra Club comments stated:

1. The Sierra Club requested additional public participation to increase transparency and initiate collaboration earlier in the proposal planning process.

2. The Sierra Club requested clarification about the management areas that will be affected by the proposal.

3. The FS should state what species of wildlife will be featured and what habitat will be improved.

4. Certain soils should not be mulched because they are in floodplains.

5. Some stands of trees should be avoided or mitigation measures should be implemented to reduce environmental impacts of mulching.  Hardwood dominated stands and pine-hardwood stands should be burned and not mulched so they retain their biological diversity.

6. An old growth inventory should be conducted and Stand 13 in Compartment 37 (large Shortleaf and Loblolly Pine and White Oak trees) should not be mulched, but handtools should be used.  This stand should be managed for old growth characteristics.

7. Wider streamside management zones should be placed along the Lake Conroe shoreline, Sand Creek, and ponds to protect floodplain and riparian areas.

8. Compartment 36 should emphasize additional upland hardwood areas.

9. Both the Lone Star Hiking Trail in Compartments 29 and 37 and the Multi-Use Trail in Compartment 37 should have a 50-foot protective buffer zone (management buffer) on both sides of these trails (100-foot total buffer width) to protect trail aesthetics, biological diversity, landscape heterogeneity, scenery, and recreational objectives.

10. The FS should implement a feral hog reduction program focused along the Lake Conroe shoreline and other wet areas.

The Sierra Club will continue its collaboration with the FS and advocate for more environmental protection in SHNF.

Author: Brandt Mannchen