Advocates For the Oak Ridge Reservation
136 West Revere Circle, Oak Ridge, Tennessee 37830                         www.aforr.org/

September 16, 2003

Marsha White
Tennessee Department of Environment and Conservation
11th Floor, L&C Tower
401 Church Street
Nashville, TN 37243

Dear Ms. White:

Comments on Management Plan for 3,073-acre Conservation Easement
On the US Department of Energy (DOE) Oak Ridge Reservation

Thank you for providing the public with the opportunity to comment on the future management of this area. Advocates for the Oak Ridge Reservation (AFORR) was established to support both the continued preservation of DOE Oak Ridge Reservation lands and a continuing public role in planning for these lands. We are pleased that the State of Tennessee is helping to advance both of these objectives, first by securing a conservation easement over 3,073 acres on Black Oak and McKinney Ridges, and second by involving the public in developing the management plan for this tract.

AFORR encourages the Tennessee Department of Environment and Conservation (TDEC) to develop a management plan for this tract that supports conservation and low-impact recreation, while retaining the potential for continued use for ecological and other environmental research by TDEC, Oak Ridge National Laboratory and others.

AFORR has several specific recommendations for managing this area, as outlined below.

1. Our preferred designation for this property would be as a State Natural Area. This would assure that the property would be managed primarily for conservation. This area has substantial value for wildlife, particularly breeding songbird species. Native plant communities also should be protected, including rare species.

2. Avoid interior ecological fragmentation -- by not building new roads, widening existing roads , or creating new clearings (with the possible exception of small trailhead parking areas on the perimeter). This is important to protect nesting songbirds that require forest interior habitat, as well as to limit opportunities for incursion of invasive exotic plant species that colonize disturbed sites. Limit the width of any newly established trails so as not to create a break in the forest canopy.

3. Allow and encourage low impact public recreational uses compatible with conservation, including hiking, birdwatching and other wildlife viewing, regulated hunting (for deer, turkey, and other wildlife as deemed appropriate), and bicycling on designated trails. Recreational access is important to ensure that the public appreciates and benefits from this area. Also, continued regulated deer hunting is important to control the deer population and thus reduce the number of deer-vehicle collisions and reduce browsing of native plants. Public use of the North Boundary patrol road (which follows part of the perimeter of the property) as a public greenway should continue, and other roads and trails should be designated for pedestrian use, as appropriate. Measures to encourage recreational use should include placement of signage to direct the public to trailheads and other access points and distribution of maps of trails and access points.

4. Prohibit motorized vehicles, except for use of existing roads for maintenance access, fire control, emergencies, and hunter access during regulated hunts. Establish and maintain physical access controls to prevent vehicular access.

5. Limit hunting to specified weekends, as is currently done on the DOE lands in Oak Ridge. The limited hunting program apparently has been successful in controlling deer populations and providing hunters with an enjoyable experience. Limiting hunting to specified dates also reduces the risk of adverse encounters between hunters and other recreational users.

6. Do not permit horseback riding, or restrict it to a few principal roads. Restriction of horses is needed to reduce conflicts between users and to avoid introducing non-native plants whose seeds are present in horse droppings.

7. Explore opportunities to preserve remaining pre-World War II cultural resources and to commemorate the heritage of the Wheat Community and other people who lived on this land before the federal government facilities were built.

8. Do not rule out the possibility of future use for ecological and other environmental research by Oak Ridge National Laboratory, state agencies, or other researchers. Any research activities should, however, be compatible with conservation.

9. The agreement between the State of Tennessee and DOE regarding this tract should assure that the City of Oak Ridge and Roane County continue to receive Payment in Lieu of Taxes for this land. This is important to ensure that the local governments do not realize an economic loss from the establishment of this area. However, in the long term AFORR expects that the local communities will receive substantial economic benefits as a result of the existence of this area , because the area will become an attractive amenity for residents and visitors and will bring visitors to the community for recreational opportunities.

In addition, please note that AFORR has been engaged in discussions with DOE, the Community Reuse Organization of East Tennessee (CROET), and local government officials concerning the possibility of revising the boundaries of the Horizon Center property (also known Parcel ED-1) that DOE conveyed to CROET earlier this year. The proposed revision to the boundaries would result in additional lands adjacent to the conservation tract becoming available for conservation, including a portion of the East Fork Poplar Creek floodplain between Black Oak and McKinney Ridges. AFORR believes that adding this land to the conservation tract would enhance the area's conservation value and facilitate management as a natural area, and we hope that (if our discussions are successful) the State of Tennessee will accept this addition to the conservation easement area.         


Sincerely,




Gail Stakes, President




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