The NYS DEC is soliciting comments on their proposed regulations of invasive species through today (12/23/2013). I'll share my perspective on black locust that I sent in response to the request for input. I offer this here in case (1) someone can expand on what I've argued or (2) someone notes a shortcoming of my argument in which case I'm especially interested.
A link to the report http://www.dec.ny.gov/animals/63402.html
A link to the proposed regulation http://www.dec.ny.gov/regulations/2359.html
my comments...
I am writing to express my concern that black locust (Robinia pseudoacacia) is listed as a “regulated” species, in fact that it is listed at all. My arguments for this perspective are numerous, but I frame them below in an ecological and economic context. I appreciate the sensitivity that surrounds this discussion, but feel strongly that the negative attitudes towards black locust are unwarranted. I offer these observations based on my Karner Blue butterfly habitat research in the Albany pine bush in the early 1990’s, my training as a forest ecologist, and my work with NY woodlot owners and farmers as the NYS Extension Forester. Even knowing what I know about its role in the sand plains and impact on Karner Blue butterfly habitat, I feel it is one of our most important hardwood trees. The classification of black locust seems unjustified, and more generally the listing of black locust of “invasive” is questionable.
I understand that black locust lacks explicitly documented historical record from within the state, which forms the primary basis to argue that it be considered non-native. I also am familiar with its potential to frustrate land and habitat managers in the area of the Hudson River sand belt that corresponds to habitat for the Karner blue butterfly. I suspect that the strongest argument for listing black locust as an invasive species is based on the observations and experiences of land managers/conservations who work with the Karner blue butterfly. In my experience and research in this area (Smallidge, Leopold, and Allen 1996. J. Appl. Ecol. 33:1405-1419), black locust could be effectively managed. Past land uses have exacerbated the abundance of black locust, but this has relevance and bearing only as a human artifact not as a condition of the species. As I illustrate below, the arguments for black locust as an invasive species are insufficient in consideration of its life history and the given the burden placed on those who work with and benefit from black locust.
Ecological
Economic
Black Locust is back in the news, making the new DEC list of regulated "invasive" plants. Of particular concern to me as a forester and agroforester is the language copied below from the document:
What is the difference between prohibited and regulated invasive species? Prohibited invasive species cannot be knowingly possessed with the intent to sell, import, purchase, transport or introduce. In addition, no person shall sell, import, purchase, transport, introduce or propagate prohibited invasive species. Regulated invasive species, on the other hand, are species which cannot be knowingly introduced into a free-living state, or introduced by a means that one should have known would lead to such an introduction, although such species shall be legal to possess, sell, buy, propagate and transport. What species have grace periods established in the regulations? A one-year grace period is included in the regulations for Japanese Barberry
Complete list: http://www.dec.ny.gov/docs/lands_forests_pdf/isprohibitedplants2.pdf
I interpret this as meaning that it's not illegal to plant Black Locust in NYS. Thoughts?
Copied below are some earlier email discussions with other foresters that never made it on to the forum:
Forester #1: I’m a cooperating forester and am commenting on the inclusion of black locust trees as a “regulated” invasive species. For the record, I do not agree that this species should be regulated. It is a native species of the USA and some sources have it as native to the Alleghenies, which, if not in NY, then damn close.
I’ve been around this species all my life; first in central New Jersey where I grew up, and now in NY for the past 20+ years. This species was one included in my college education for Dendrology. There was never any mention of it being a serious problem in any manner. I’ve seen some small stands (an acre) or less, usually around old agricultural or abandoned lands, where it had spread as an early successional species; as would poplars, birches and many other species. However, I have never heard of or seen any situation where this species is problematic in a broad sense. To the contrary, I recently (2 months ago) had a local wood buyer inquire if I new of any black locust that was available for logging. The wood of this species is one of the best ever for natural resistance to wood decay. As such, it is highly regarded and sought for many uses. It’s much better than cedar for structural strength and I’ve used it myself for a number of building projects over the past 30 years. I could show you a some black locust pilings I buried for supporting a deck I built 30 years ago in NJ that remain rock-solid to this day, whereas parts of the deck supported by these pilings made of pressure treated wood (with the old arsenic recipe no less) have had to be replaced – and these treated parts were not in contact with the ground, like the locust is. Not far from this site, I could also show you the remains of a summer bungalow that used black locust as supports and some of them remain solid and in the ground, since they were installed over 100 years ago. It’s also excellent firewood and has a long history of other uses where a hard, durable wood was required.
Black locust is not shade tolerant like Norway Maple and will not invade an established woodland. In addition to the useful wood, the roots fix nitrogen in the ground and the seeds are eaten by many species including quail, dove, squirrels, and rabbits. Deer also eat the young shoots and bees make a high grade honey from its nectar.
Invasive? As a forester, I can tell you our native American beech is much more a problem in our forests than black locust will ever be. If you are going to include species on your invasive species list based solely on this characteristic, you have to include the beech (and see what kind of broad-based reaction you get then!!!). To the contrary, this characteristic of the black locust is valued for reclaiming “wasteland”. I’ve seen it planted to reclaim strip-mined areas in PA because it is tolerant to poor and dry soils.
Some content from the web:
Of course, leave it to the bureaucrats (no offense intended . . . ) to come out with contradicting information. The content below (bulleted) is from the USDA Forest Service (http://www.na.fs.fed.us/pubs/silvics_manual/volume_2/robinia/pseudo... ) This site also will show you with a map that it is native in the Allegheny Mtns.
(Not commercial? Since when were fuelwood and pulp classified as not commercial? I’ve also seen hardware stores with sawn and shaped black locust for sale as fencing.)
Also from the USDA FS site (with my highlights):
Forester #2: Here are my quick two cents regarding Black Locust. From a pragmatic financial point of view Black Locust has the potential to produce more forest income per acre than a lot of other species currently tracked on the stumpage report. Here are the reasons.
1. The species can and does replace exotic tropical hardwoods such as Ipe for upscale outdoor applications in a vastly more sustainable manner.
2. As previously mentioned by Mr. Statts it is also more viable than pressure treated for longevity plus it is a far more environmentally benign option than pressure treated lumber.
3. It grows much faster than other higher value species based on stumpage price. I recently measured a 21inch diameter Black Locust stump on my property that was only 33 years old. A comparable sugar maple would be at least 100 years.
4. Mills specializing in Black Locust are rumored to be paying up to $400 per thousand for high quality logs at the landing.
Based on this information one could grow 3 equal aged harvestings of Black Locust in the time it takes to grow one equal aged harvesting of Sugar Maple. The Sugar Maple would have to be sold at $1200 per thousand to equal the value of the Black Locust produced over the same time period and because of the time value of money the comparison would be even more in favor of Black Locust. While it is currently possible to obtain these prices for premium Sugar Maple other species such as Ash and Birch, to name a couple, can’t match the value of Black Locust.
In my opinion the value of Black Locust in the marketplace is likely to increase significantly going forward as its environmental advantages become more widely recognized. Other more traditional species are unlikely to experience a general continued market improvement because of their historical uses and are instead subject to the well known “in and out of favor” traditional pricing.
I do not know what the upshot of the “invasive” classification would mean but it is clear to me that limiting a landowner’s potential forest based income is probably not the best alternative.
I asked Nicole Horowitz from NY Farm Bureau's Public Policy department for some clarification on this. Her response is below (phew!)
A “free living state” would not mean a farm or technically anywhere else in NYS. The Adirondacks are the best example because they are the essence of free-living and the need for non-introduction of a potential invasive species. A free living state would not be a farm as it is technically a controlled environment as are people’s yards and communities (as anything planted in a town or city is done by/with a landscaper to choose plants and trees that would provide a benefit to the area). Essentially the goal of regulating is to educate the customer on purchasing the product and what it would potentially do to the environment if they planted it in an inappropriate place.
I don't know how I missed this when it was first posted. What was the result of the proposed legislation? Is Black Locust now regulated?
I think it is a vastly under-rated species by many foresters. There is a reason that many old farms had a planted stand of Black Locust - it's an incredibly useful wood. If I had found the stand of it on my property sooner, my deck would be made out of it. The structural members of the shade pavilion we recently constructed are Black Locust harvested from about 100' from where the pavilion stands. We've used Black Locust logs for parts of the obstacle course we built in our woods. The leftovers from these projects make good firewood. Finally, as others have noted, it's great having a natural alternative to pressure-treated lumber (the Red Cedar growing on our property lacks the form and strength for many of our projects).
I have been observing different stands of black locust now for many years. The characteristics of individual trees, straightness, growth rate, smoothness of the bark, resistance to the locust borer, etc. are all no doubt affected by soil type, drainage, soil organic matter and soil pH. If one is interested in starting a black locust plantation for timber production plant on the best soil you can find. Preferred would be a well-drained soil, high in fertility and organic matter levels with a pH around 6.5. In my opinion, timber characteristics are also very much influenced by genetics and if you look at different stands you will notice lots of variation in straightness, diameter growth, and how rough the bark is. The latter is important because you can't make bark into boards. So seed should be collected from isolated stands with superior timber-type characteristics. I think it may make sense to establish black locust plantations in mixture with some other fast growing hardwoods, to shade the trunks and shade the ground early in the season as a way to discourage invasive shrubs - black locust leafs out late. I don't know which hardwoods would work best? Some ideas would be red oak, basswood, butternut and black walnut. Butternut should only be planted on upland sites with good air drainage/circulation/movement as these are the only conditions that allow this species to fight off butternut canker long enough to produce timber. Kenworthy is a butternut-Japanese walnut hybrid that is known to have good resistance to the butternut canker - don't know about timber form. Butternut seedlings can be purchased from the Clements State Tree Nursery, WV Division of Forestry. When collecting black locust seed from superior stands it is also a good idea to collect some of the soil from around these trees so that you can inoculate the seedlings with the Rhizobia bacteria that allows black locust to fix nitrogen.
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