STATE OF NEW HAMPSHIRE DEPARTMENT of RESOURCES and ECONOMIC DEVELOPMENT DIVISION of PARKS and RECREATION 172 Pembroke Road P.O. Box 1856 Concord, New Hampshire 03302-1856 PHONE: (603) 271-3556 FAX: (603) 271-3553 E-MAIL: nhparks@dred.state.nh.us, WEB: www.nhstateparks.org, November 27, 2012 Mr Jack Howard, Manager State and Local Assistance Programs National Park Service US Customs House 200 Chestnut St. 3" Floor Philadelphia, PA 19106 Re: Pisgah State Park Dear Jack, |lam writing to you in response to the letter that attorney Amy Manzelli sent you on October 9, 2012 in ‘which she alleges that DRED has performed a conversion at Pisgah State Park through commercial timber harvesting. The work that attorney Manzelli and her clients are opposed to involve the use of forest management practices to accomplish recreation goals within the park. There has been no conversion resulting from forest management operations at Pisgah State Park. Forestry operations continue to be secondary and complementary to recreation in the park. State Park versus State Reservation Alllands under management authority of DRED are considered by state law to be state reservations. RSA 227-6:2 Definitions. ~ In this ttl. XVI. "Reservation" means public land under the jurisdiction of the department (DRED) including, but not limited to: state forest, state park, natural area, historic site, geological site, recreation trail, memorial ‘area, fire tower, wayside area, heritage park, resource center, agricultural area, state forest nursery, fish pier, administrative facility, information center, demonstration forest, certain islands, and lands under lease to the department. Pisgah is and always has been since state purchase and by state law, a state reservation, Discussions in- house were whether to change the name of Pisgah from state park to state reservation. This is because Pisgah offers no developed recreation facilities. Unlike Bear Brook State Park which has a developed campground, day use facilities, museums, and other facilities that the public expects from a “park”, Pisgah by design is an undeveloped recreation site. The change in name would not affect jurisdiction within the park. Lipase roo Access ReLAYNI soonia56 GB) mocbsnaeJack Howard, Manager November 27, 2012 State reservations are zoned using the current DRED zoning system, According to DRED records from 41988 Pisgah does not and has never had any zoning that would have given primary jurisdiction to the Division of Parks and Recreation. To the contrary, nearly all of Pisgah is and always has been zoned Forestry Land Use. The reason is because only developed recreation sites fall under the primary jurisdiction of the Division of Parks and Recreation, LWCF lands without developed facilities fall within forestry land use because state law gives the director of the division of forests and lands the following responsibilities: 227-H:1 Declaration of Purpose. — itis hereby recognized and declared that state-owned reservations contribute to the conservation of natural resources and distinctive quality of life in the state, The public welfare of this state is served by the prudent acquisition and management of reservations to provide forest benefits and for the purposes of demonstrating sound forestry principles, protecting habitat for plants, animals, and other organisms, conserving forested watersheds, preserving areas of rare and exemplary natural beauty and ecological value, and providing for perpetual public access and use. Forest benefits are defined as RSA 227-G:2 Definitions. ~In this title: Vi, "Forest benefits" include, but are not limited to, forest products, a viable forest-based economy, recreation opportunities, scenic values, healthful surroundings, climate mitigation, clean water, and biologically diverse populations of plonts and animals. {As such, lands with undeveloped recreation are under the primary jurisdiction of the division of forests and lands. Excerpts from documents Please note that in DRED’ original application for LWCF funds for the Pisgah project “nature study” was listed as a proposed use of the park. The application also said that “forestry improvement work will be done in those areas that were heavily logged in earlier days". The second application described the forest management activities more with statements such as “the woodlands will benefit from a sustained yield forest management program” and “a continuous forest management program should result in better distribution of more vigorous and healthy forest stands", emphasizing that “management will concentrate on forest production". That document also said that “wildlife will be encouraged by Fish & Game techniques” and “the New Hampshire Fish and Game Department is planning to use future timber inventory information to conduct modified cutting practices for improving wildlife habitat on ‘existing park land as well as the land proposed in this acquisition’. In the warranty deed from the Friends of Pisgah to the State of New Hampshire" for a 163.2 acre parcel purchased through the LWCF, Cheshire County Registry of Deeds, Book 1274 page 809. 2|PageJack Howard, Manager November 27, 2012 item (d) specifies that “Agriculture and forestry on the property shall be performed to the extent possible in accordance with a coordinated management plan for the sites and soils of the property’ ‘Managing for diverse recreation opportunities DRED has followed through with the work identified above in the LWCF applications in several ways. In the Management Plan for Pisgah State Park three management criteria were established that create three distinct recreational environments: Criteria 1 - Guided by historical documents, maps and field reconnaissance, Criteria 1 boundaries were established to catch much of the acreage which was uncut or lightly cut over the last few centuries. ‘These areas we believe provide a unique set of characteristics for park visitors including floristics (ground plants, shrubs and trees) and wildlife species associated with those floristics. The Criteria 4 lands total 4,723 acres or approximately 35% of the total park area, Active management in the form of forest management projects is not considered for these lands. Criteria 2 & 3 - Lands in Criteria 2 and 3 historically were heavily logged and some were even used in agriculture, The Winter 2012 Friends of Pisgah newsletter acknowledging the logging history of the property wrote on page 2: “Later, his brother, Ansel, joined him and together they hired men to carefully log the forests now within the boundaries of Pisgah with their teams of horses and oxen. Two sawmills cut huge logs into lumber for furniture, railroad ties, shingles and lathe. Hand dug canals kept the mill pond full in the drier summer months, mill & boarding houses kept the workers comfortable ond a huge barn protected the work animols. A blacksmith was always nearby. By 1885, one of their mills was equipped with a steam turbine, employed 35 men and turned out 1,000,000 board feet per year”. Incidentally, planned harvests at Pisgah under the current management plan are estimated to be only about half of those reported historic cutting levels. Forest management maps from the local timber companies as well as information from local people and interpretation of the forest cover provide good testimony to the extent of forest management ‘operations on these acres prior to state ownership. On these lands ORED is conducting forestry improvement work that will enhance recreation opportunities within the park, For example DRED creates forest clearings that regenerate floristic communities that are different than what one would expect in the Criteria 1 lands. These clearings provide recreational opportunities for nature study such as plant, insect and wildlife viewing and identification. They also create an interesting and diverse forest condition for recreationists by providing a range from young to old forests, and hardwood to softwood forests Partial cutting such as thinnings remove trees that exhibit poor health and quality and reallocate growth to trees that are often more capable of producing benefits such as wildlife foods (beech nuts and oak acorns), attractive visual characteristics (large groves of pines), highlight interesting tree forms such as 3|Page