“Improving Conditions in the Blackwater Watershed” Project Proposal
(Formerly Blackwater IRMS/Blackwater Landscape Analysis)
Posted December 27, 2019
The Forest Service has proposed yet another major logging project on the Daniel Boone National Forest to wrap up 2019. But this time they won’t tell you where they're going to log.
The Forest Service wants to approve an open-ended logging project near Cave Run Lake without first identifying any specific locations where they will actually sell the timber, build roads, or perform other management.
Comments on the Blackwater project are due Friday 12-27-19 by 11:59 pm.
Click here, then scroll to bottom of blog post, for detailed directions, links, and mailing address for sending comments.
It is especially important that the Forest Service receive comments opposing their use of the “condition based management” approach. The Forest Service needs to provide a specific proposal, with specific management objectives in specific places. If they can’t provide this level of detail then they’re not ready to make an informed decision to approve and implement the project.
The Forest Service has proposed yet another major logging project on the Daniel Boone National Forest to wrap up 2019. But this time they won’t tell you where they're going to log.
The Forest Service wants to approve an open-ended logging project near Cave Run Lake without first identifying any specific locations where they will actually sell the timber, build roads, or perform other management.
Comments on the Blackwater project are due Friday 12-27-19 by 11:59 pm.
Click here, then scroll to bottom of blog post, for detailed directions, links, and mailing address for sending comments.
It is especially important that the Forest Service receive comments opposing their use of the “condition based management” approach. The Forest Service needs to provide a specific proposal, with specific management objectives in specific places. If they can’t provide this level of detail then they’re not ready to make an informed decision to approve and implement the project.
Forest Service proposes large logging project near Cave Run Lake, is loose on details
Beautiful canopy of Appalachian hardwoods growing in an old growth management prescription area in the Blackwater IRMS watershed.
Originally published June 5, 2019 in our Forest Blog
The Forest Service has released their formal proposal (scoping document) for the “Improving Conditions in the Blackwater Watershed” project, which would approve thousands of acres of logging on the east side of Cave Run Lake.
Comments on the Blackwater project are due by Friday, June 21st, 2019. Directions for commenting are at the end of this alert (comments made on this blog post do not go to the Forest Service).
Despite having held a series of public meetings and conversations during the development of the project, the Forest Service has failed to provide critical information in the proposal - including the actual locations of where they would sell timber. Instead, the agency has provided maps that show nearly 12,000 acres of areas where logging could happen over the next 10 to 30 years if they approve the project.
A breakdown of the confusing information provided in the proposal indicates that the Forest Service plans to log nearly to 1,200 acres per decade under this proposal, with an open-ended timeframe. The actual locations of logging areas won’t be determined or disclosed until after the environmental analysis and final decision approving the project – and well after the public has any meaningful opportunity to provide input or challenge the project. This is a radical change from decades of management and planning on the Daniel Boone National Forest, and follows an alarming trend happening on other national forests.
The Forest Service has released their formal proposal (scoping document) for the “Improving Conditions in the Blackwater Watershed” project, which would approve thousands of acres of logging on the east side of Cave Run Lake.
Comments on the Blackwater project are due by Friday, June 21st, 2019. Directions for commenting are at the end of this alert (comments made on this blog post do not go to the Forest Service).
Despite having held a series of public meetings and conversations during the development of the project, the Forest Service has failed to provide critical information in the proposal - including the actual locations of where they would sell timber. Instead, the agency has provided maps that show nearly 12,000 acres of areas where logging could happen over the next 10 to 30 years if they approve the project.
A breakdown of the confusing information provided in the proposal indicates that the Forest Service plans to log nearly to 1,200 acres per decade under this proposal, with an open-ended timeframe. The actual locations of logging areas won’t be determined or disclosed until after the environmental analysis and final decision approving the project – and well after the public has any meaningful opportunity to provide input or challenge the project. This is a radical change from decades of management and planning on the Daniel Boone National Forest, and follows an alarming trend happening on other national forests.
What we do know is that most of the logging would be in the form even-aged shelterwood cuts, where about 85% of the canopy is cut across units (stands) of 20 to 40 acres. A small amount of the shelterwood cutting (less than 5%) would take place to restore ecologically important limestone and cedar glades. Depending on the specific locations and practices used, some timber harvest to restore these glades could be beneficial.
The Forest Service has also proposed a small amount of uneven-aged management through group selection. However, what the Forest Service is calling “uneven-aged” management would consist of 1 to 2 acre clearcuts, rather than more selective, finer-scale silvicultural approaches that could support the development of true, multi-age forest structure.
The project would also allow for a variety of activities meant to improve streams across the project area, which we support. Stream restoration and improvement work could include reshaping stream channels, adding coarse woody debris, and planting native vegetation, as well as road work replacing culverts, hardening stream crossings, and relocating roads. The proposal also includes upgrading and seasonally opening certain roads in the project area to increase recreational access.
The Forest Service has also proposed a small amount of uneven-aged management through group selection. However, what the Forest Service is calling “uneven-aged” management would consist of 1 to 2 acre clearcuts, rather than more selective, finer-scale silvicultural approaches that could support the development of true, multi-age forest structure.
The project would also allow for a variety of activities meant to improve streams across the project area, which we support. Stream restoration and improvement work could include reshaping stream channels, adding coarse woody debris, and planting native vegetation, as well as road work replacing culverts, hardening stream crossings, and relocating roads. The proposal also includes upgrading and seasonally opening certain roads in the project area to increase recreational access.
A summary of our main concerns:
- The Forest Service should not approve any logging projects without first disclosing the specific locations where timber harvests are planned. If the Forest Service hasn’t yet figured this out, then the proposal isn’t ready. A revised proposal should be made available for public comment after specific areas have been identified for specific types of management.
- The Daniel Boone National Forest has a terrible track record of causing infestations of non-native invasive plants in interior forests as a result of their logging operations. Through the bulldozing of “temporary roads,” clearing and compaction of log landings, and creation of networks of skid trails through forest, infestations are regularly established. This is something that the agency has been unwilling to seriously reckon with. And experience shows that the predominantly oak forests being cut in the Daniel Boone National Forest have been coming back in tulip poplar and stump-sprouted red maple. Private lands in Kentucky are providing plenty of timber into the economy. There’s no reason to degrade our public, national forest lands to get logs to the mill.
- While we prefer that logging not occur (other than to support the conservation of rare natural communities), changes could be made to make the prescriptions better. The uneven-aged logging prescription in the current proposal should be modified, with group selection harvests reduced to less than 1 acre (typically 0.25 to 0.5 acres), with tree thinning oriented toward the development of complex, multi-age forest structure. This would better mimic prevailing natural disturbance events and could support the development of old-growth forest structure in some areas. The Forest Service should also avoid using shelterwood or other regeneration cuts. And no “temporary roads” should be constructed to extract timber. These features are ugly, lasting scars on the landscape and are where some of the worst infestations of non-native invasive plants get started. Lower impact timber harvest methods are available.
What we do support:
- We strongly support the proposed stream restoration activities. This is part of the core mission of the U.S. Forest Service, and should move forward.
- The Forest Service has stated that they won’t use regeneration (shelterwood) cuts on forests over 118 years of age, and will not propose any management in forests meeting old-growth criteria that will “diminish old growth characteristics.” This is something we have long advocated for.
- Focused restoration of limestone and cedar glades in the project area could have a significant beneficial impact for a variety of plant and animal species. While using commercial harvest methods, these activities could be beneficial if negative impacts from ground disturbance (especially non-native invasive plant infestations) are appropriately addressed.
- We generally support the use of prescribed fire in the project area, though the specific locations of burn units need to be disclosed. The interaction of specific forest types and natural communities, as well as proposed vegetation management (logging), with fire is not uniform and needs to be carefully looked at.
We’ll post our full comments on our website once we get them submitted.
The official proposal, maps, and other project files can be viewed here.
Comments are due by Friday, June 21st, 2019
Make sure to include the full project title "Improving conditions in the Blackwater Watershed" with your comments.
Documents for the project can be found on the Forest Service’s website here.
Comments can be submitted in the following ways:
The Daniel Boone National Forest Service website has a comment form on their website here.
They have also a reading room, where you can read comments that have been submitted by the public.
Comments can also be sent by postal mail to:
Cumberland Ranger District, DBNF
2375 KY 801 South
Morehead, KY 40351
And if you find this information helpful, please consider supporting Kentucky Heartwood so that we can continue to help connect you with what's going on with your public lands. Join or donate here.
Make sure to include the full project title "Improving conditions in the Blackwater Watershed" with your comments.
Documents for the project can be found on the Forest Service’s website here.
Comments can be submitted in the following ways:
The Daniel Boone National Forest Service website has a comment form on their website here.
They have also a reading room, where you can read comments that have been submitted by the public.
Comments can also be sent by postal mail to:
Cumberland Ranger District, DBNF
2375 KY 801 South
Morehead, KY 40351
And if you find this information helpful, please consider supporting Kentucky Heartwood so that we can continue to help connect you with what's going on with your public lands. Join or donate here.
Blackwater Integrated Resource Management Strategy process under way
Posted 2-17-2017
The Forest Service has begun a landscape assessment of areas to the southeast of Cave Run Lake in Morgan and Rowan counties, called the Blackwater Integrated Resource Management Strategy (IRMS). The first of a series of public meetings was held in West Liberty on October 18, 2017. Public input into the process is important, as future Forest Service proposals addressing recreation, vegetation, watershed health, and other issues will come out of the process. More meetings and outings are expected in the near future. Join our email list to stay up to date.
Posted 2-17-2017
The Forest Service has begun a landscape assessment of areas to the southeast of Cave Run Lake in Morgan and Rowan counties, called the Blackwater Integrated Resource Management Strategy (IRMS). The first of a series of public meetings was held in West Liberty on October 18, 2017. Public input into the process is important, as future Forest Service proposals addressing recreation, vegetation, watershed health, and other issues will come out of the process. More meetings and outings are expected in the near future. Join our email list to stay up to date.
The forest service provided the following information about the Blackwater Landscape Analysis. This information is on the Daniel Boone National Forest website here.
General description: Analysis of various projects in the Blackwater watershed in Menifee, Morgan, and Rowan Counties to implement the Forest Plan. These projects were developed from the Blackwater Project Development collaborative effort.
Lead Management Unit: Cumberland Ranger District
Project Purpose: Recreation management; Forest products; Wildlife, Fish, Rare plants; Watershed management; Road management; Vegetation management (other than forest products)
Project Activity: Road decommissioning; Developed site management; Forest vegetation improvements; Dispersed recreation mgmt.; Species habitat improvements; Heritage resource management; Facility maintenance; Trail management; Noxious weed treatments; Road maintenance; Road improvements/construction; Scenery management; Travel management; Timber sales (green); Watershed improvements
General description: Analysis of various projects in the Blackwater watershed in Menifee, Morgan, and Rowan Counties to implement the Forest Plan. These projects were developed from the Blackwater Project Development collaborative effort.
Lead Management Unit: Cumberland Ranger District
Project Purpose: Recreation management; Forest products; Wildlife, Fish, Rare plants; Watershed management; Road management; Vegetation management (other than forest products)
Project Activity: Road decommissioning; Developed site management; Forest vegetation improvements; Dispersed recreation mgmt.; Species habitat improvements; Heritage resource management; Facility maintenance; Trail management; Noxious weed treatments; Road maintenance; Road improvements/construction; Scenery management; Travel management; Timber sales (green); Watershed improvements
| blackwater_map.pdf |
A public comment submission page, and documents concerning the Blackwater IRMS are on the Daniel Boone National Forest website here.
You can read comments that have been submitted by the public here.
Here's a link to a livestream video from the February, 2017 Blackwater IRMS meeting: https://www.facebook.com/danielboonenf/videos/1649488945066549/
Here is a link to the livestream of the November, 2017 meeting about openlands on the Cumberland district: https://www.facebook.com/danielboonenf/videos/1947105628638211/
Here is a link to a Forest Service document from 2009, describing the IRMS process in general.
You can read comments that have been submitted by the public here.
Here's a link to a livestream video from the February, 2017 Blackwater IRMS meeting: https://www.facebook.com/danielboonenf/videos/1649488945066549/
Here is a link to the livestream of the November, 2017 meeting about openlands on the Cumberland district: https://www.facebook.com/danielboonenf/videos/1947105628638211/
Here is a link to a Forest Service document from 2009, describing the IRMS process in general.
The Daniel Boone has provided the following information about commenting on this project. This information is available on the Daniel Boone National Forest website here.
Blackwater Landscape Analysis #53403
Comments, including anonymous comments, will be accepted at any time. However, comments posted after the close of a designated comment period may not be able to be given full consideration. Anonymous comments and comments submitted after the close of the final designated comment period will not provide the commenter standing for administrative review.
The Forest Service values public participation. Communications from the public regarding this project, including commenter’s names and contact information, will become part of the public record.
Comments, or in some cases other expressions of interest, along with respondent’s contact information, submitted during the comment period may be necessary to establish a respondent’s eligibility to participate in an administrative review for this proposed action. Interested members of the public should review the proposal’s information to determine the applicable administrative review process and the eligibility requirements for that process. The date of the legal notice of opportunity to comment on this proposed action is the exclusive means for calculating the comment period. For proposals to be documented with an Environmental Assessment, the legal notice announcing the comment period appears in the Newspaper of Record . For Draft Environmental Impact Statements, the Notice of Availability announcing the comment period appears in the Federal Register.
Submitting Comments
If you wish to submit a comment, please send it to:
Jeffrey Lewis
Cumberland Ranger District
2375 Kentucky 801 S , Morehead, KY, 40351
jefflewis@fs.fed.us
Blackwater Landscape Analysis #53403
Comments, including anonymous comments, will be accepted at any time. However, comments posted after the close of a designated comment period may not be able to be given full consideration. Anonymous comments and comments submitted after the close of the final designated comment period will not provide the commenter standing for administrative review.
The Forest Service values public participation. Communications from the public regarding this project, including commenter’s names and contact information, will become part of the public record.
Comments, or in some cases other expressions of interest, along with respondent’s contact information, submitted during the comment period may be necessary to establish a respondent’s eligibility to participate in an administrative review for this proposed action. Interested members of the public should review the proposal’s information to determine the applicable administrative review process and the eligibility requirements for that process. The date of the legal notice of opportunity to comment on this proposed action is the exclusive means for calculating the comment period. For proposals to be documented with an Environmental Assessment, the legal notice announcing the comment period appears in the Newspaper of Record . For Draft Environmental Impact Statements, the Notice of Availability announcing the comment period appears in the Federal Register.
Submitting Comments
If you wish to submit a comment, please send it to:
Jeffrey Lewis
Cumberland Ranger District
2375 Kentucky 801 S , Morehead, KY, 40351
jefflewis@fs.fed.us