Wild places sustain and define us; we, in turn, must protect them.
Last week we spent some time in the Redbird District of the Daniel Boone looking at ongoing logging from the Group One Redbird River Project, and forests now proposed for logging under the South Redbird proposal. The Group One project was withdrawn twice after administrative appeals filed by Kentucky Heartwood. The project, though smaller than initially proposed, was ultimately approved in 2008 and included nearly 1,500 acres of logging. The South Redbird project, as currently proposed by the Forest Service, would cut about 3,200 acres of forests in the district.
The Group One site we visited was a shelterwood cut to create early seral habitat (brush, young vegetation) on a steep mountain slope above Ulysses Creek. The logging happened sometime between 2010 and 2013 on a forest that was about 110 years old. The harvest methods used on the Ulysses Creek site are essentially identical to what's now proposed for nearly 3,200 acres of the South Redbird project. Spreading from the "temporary" roads bulldozed across the slope, infestations of invasive species are proliferating. Kudzu, autumn olive, Japanese stiltgrass, multiflora rose, Japanese honeysuckle, and sericea lespedeza are all well-established and expanding. Many of the trees left standing have been badly damaged from poor felling or skidding practices, and tree roots are tore up from dozers. Logging on 50 percent slopes caused a loss of soil duff and the exposure of mineral soil. It's really bad, and bad throughout. The stand that we looked at was 34 acres. The amount proposed for logging in the South Redbird project would be about 100 times that.
On that same day we also visited a site in the South Redbird project that's similarly proposed for a shelterwood cut to create early successional habitat. The forest above Flat Creek near the Redbird River includes high quality, functional secondary old-growth. While second-growth at about 130 years of age, the forest includes very large trees, large-diameter down wood and standing snags, den trees, and large canopy gaps. These are all classic, functional structures of old-growth forests in the region. They are also exceedingly rare in the generally young forests of the Redbird District.
Below are several annotated photos from the two sites. Pictures don't do either site justice, but we are planning a field trip in the near future. If you'd like the opportunity to join us on a field trip, or to be notified of the next comment period for the South Redbird project, please sign up for emails from Kentucky Heartwood. There's still time to save the forest above Flat Creek, and thousands more acres across Redbird.
This image shows a gorgeous stand of secondary old-growth high on the slopes above Flat Creek. The trees in the picture mostly range from about 18 to 30 inches in diameter, and include large black oak, white oak, American beech, yellow buckeye, sugar maple, black gum, and others species. The Forest Service has proposed to cut nearly every tree here, and bulldoze roads throughout to haul out the timber.
The lower slopes of the Flat Creek site are dominated by large American beech (Fagus grandifolia) trees, with just a scattering of oaks. Logging the site doesn't even make sense under conventional forestry systems. American beech trees are also dying across the northeastern U.S. as beech bark disease spreads (a result of the non-native scale insect Cryptococcus fagisuga), though it has yet to reach Kentucky.
This stand has some exceptionally nice, large black oaks (Quercus velutina).
A big, old white oak (Quercus alba). There's a lot of concern being expressed by foresters in Kentucky about the potential loss of white oaks in the future due to problems they're having becoming established in forest understories. However, the types of logging that are happening on the Daniel Boone and elsewhere in eastern Kentucky are largely shifting the forest away from white oak and toward more red maple and tulip poplars. It's a fact that the forest products industry doesn't want to grapple with. Instead, we're getting more and more calls to cut our way out of the problem and just making it worse.
There's nothing quite like a big shagbark hickory (Carya ovata).
Austin and Jim measuring a 30" black oak (Quercus velutina).
This is a bulldozed hillside in the Ulysses Creek site in the Group One project. The road grade was cut down about 5 feet and tore through the roots of oaks that were left standing. The vegetation established on the road in this picture includes some of the most notorious and problematic invasive plant species impacting our forests, including autumn olive, Japanese stiltgrass, and multiflora rose. This site is about midway up the slope.
The loss of forest canopy does create brushy habitat that's useful to a number of species, especially some migratory bird species. But this status lasts only a few years. And unlike the more natural impacts of ice storms, wind, and fire, logging can cause lasting damage that the forest is not adapted to. Beyond changes in forest structure and species composition, the roads bulldozed into the mountainside and infestations of non-native invasive plant species will likely persist for generations.
An awful infestation of Japanese honeysuckle (Lonicera japonica). This wasn't an isolated patch, as honeysuckle and other invasives were found throughout the cut stand.
An infestation of Japanese stiltgrass (Microstegium vimineum) working its way up the mountain slope.
An infestation of kudzu on a logging road bulldozed up the mountain.
A lot of the trees left standing in the Ulysses Creek site were substantially damaged by logging operations.
Remember, it's not too late for the Forest Service to change course, and to see more of the Redbird District protected and preserved as it ought to be. Join our email list, and if you're not already a member please support our work by joining Kentucky Heartwood.
Pipeline Company Kinder Morgan Drops Utica Marcellus Texas Pipeline Project
Hazardous Liquids Conversion Project Held Up Over Opposition in Kentucky
Contacts: Tom Fitzgerald, Kentucky Resources Council, 502-875-2428,firstname.lastname@example.org
Craig Williams, Kentucky Environmental Foundation, 859-302-1103, email@example.com Jim Scheff, Kentucky Heartwood, 859-334-0602, firstname.lastname@example.org
RICHMOND, KY – Pipeline company Kinder Morgan has officially dropped its plans to convert a more than 70 year-old, 2-foot diameter pipeline from natural gas service to transport of hazardous natural gas liquids (NGLs). Natural gas liquids are hydrocarbon byproducts coproduced in fracking operations in Ohio, Pennsylvania, and West Virgina, and pose signficantly greater safety and environmental risks than natural gas.
The Utica Marcellus Texas Pipeline (UMTP) project would have reversed flow direction and converted serivce on the Tennessee Gas Pipeline (TGP), which crosses six states and 18 Kentucky counties. The project drew sharp criticism and vocal opposition from a wide range of Kentucky counties and institutions, including the cities of Danville and Richmond where the existing pipeline passes through dense neighborhoods and over Herrington Lake. Nearly 1,000 comments opposing the project were submitted to the Federal Energy Regulatory Commission (FERC). You can read more about that here.
The pipeline conversion project raised significant concerns over gaps in federal and state regulatory authorities, disclosure of risks to the public and local governments, and the rights of communities to determine whether or not hazardous liquids pipelines are compatible with high density residential areas and drinking water resources.
Kentucky citizens, county governments, and environmental groups worked together for more than three and half years to stop the project. A federal lawsuit by organizations Kentucky Heartwood, Kentucky Resources Council, and the Allegheny Defense Project, challenging the September, 2017 approval of the project by FERC, is pending in the D.C. Circuit Court of Appeals. Other organizations involved in effort to block the pipeline conversion project include the Kentucky Environmental Foundation, Danville’s Citizens Opposed to the Pipeline Conversion, and the Kentucky Student Environmental Coalition.
Following FERCs approval of the project, Kinder Morgan repeatedly filed quarterly extensions for its required Implementation Plan, citing market uncertainty and their need to “confirm the degree of market interest in the project.” The company has said that will maintain the line in natural gas service, and seek to reverse flow to move natural gas from Appalachia to the Gulf of Mexico.
Also on record opposing the project are Boyle, Madison, Clark, Garrard, Marion, and Rowan Counties, the cities of Danvile, Richmond, and Junction City, and Lexington/Fayette County Government. Institutions and economic organzations opposing the project include Eastern Kentucky Universiy, Madison County Schools, Berea College, Blue Grass Area Development District, Danville/Boyle County Economic Development Partnership, and the Richmond Chamber of Commerce.
You can read more about the project here.
Kentucky Heartwood was founded in 1992, with a mission to protect and restore the integrity, stability, and beauty of Kentucky’s native forests and biotic communities through research, education, advocacy, and community engagement.
Calls are urgently needed to U.S. Representative James Comer of Kentucky’s 1st Congressional District to save Land Between the Lakes and other national forests from unrestrained logging. This is especially important if you live in Congressman Comer’s district in western and south-central Kentucky.
Congressman Comer has been selected as a member of the conference committee to reconcile the House and Senate versions of the 2018 Farm Bill. The committee will issue a “conference report” that will go back to the House and Senate for a final vote. The bill passed by the House includes federal forestry provisions that would allow logging on national forests, including clearcutting, on up to 6,000 acres at a time with no environmental analysis and little opportunity for public input. The specific changes would allow these large logging projects to occur under what’s called a “Categorical Exclusion” from the normal analysis and disclosure required under the National Environmental Policy Act (NEPA). The Senate bill contains no such language. Whether or not the devastating House language ends up in the final bill will hinge on conference committee negotiations.
Mr. Comer demonstrated his commitment to protecting Land Between the Lakes, his district’s national forest, when he voted against the Resilient Federal Forests Act of 2017, introduced by Representative Bruce Westerman of Arkansas. The Westerman bill, did not move on to a vote in the Senate, but provides the template for the House federal forests language in the Farm Bill. Mr. Westerman has also been assigned to the conference committee.
Kentuckians, and especially residents of the 1st Congressional District, have a crucial opportunity to help protect our public, national forest lands from perhaps the most audacious giveaway to the timber industry since our national forests were established more than a century ago. This is a phone call that really can make a difference.
Please call Congressman Comer’s Washington, D.C. office today at (202) 225-3115 and ask that he oppose inclusion of the federal forests language in the Farm Bill conference report. You can find contact information for Congressman Comer’s district offices here.
“I’m calling to ask that Congressman Comer continue to demonstrate his support for Land Between the Lakes by opposing the inclusion of the federal forests language in the House version of the Farm Bill in the final conference report.”
And please let us know that you called and how you were received. It really helps. To let us know that you called, or for more information, please email email@example.com.
The U.S. House Agriculture Committee has released a draft of the 2018 Farm Bill. The Forestry Title begins on page 464. The bill includes some devastating provisions with regards to our national forests and the species that rely on them. Calls to our members of Congress are urgently needed.
Some of the awful provisions in the bill include:
If enacted, massive logging projects on the Daniel Boone National Forest and Land Between the Lakes National Recreation Area, like the 3,200 acres proposed for logging in the South Redbird Project and the 4,000 acres proposed for logging in the Pine Creek project, could happen without public input or environmental review.
The Farm Bill forestry provisions largely mirror those in the Resilient Federal Forests Act of 2017 (the Westerman bill), which passed the U.S. House but did not advance in the Senate. Congress later approved a "fix" to the wildfire spending (aka "fire borrowing") issue in the 2018 Omnibus Appropriations bill, which also included some bad forestry provisions - including a 3,000 acre Categorical Exclusion to eliminate environmental review for logging projects deemed to address "hazardous fuels" issues. While the wildfire issue was supposedly the reason for loosening environmental protections in the Westerman bill, it's now abundantly clear that forest health and wildfire concerns have nothing to do with it. This is, plain and simple, a giveaway of our public lands to the timber industry.
Please take a minute to call your Congressional Representative and ask them to oppose the forestry provisions in in the 2018 Farm Bill. Congressmen Jim Comer (R) and John Yarmuth (D) voted against the Westerman bill. Please thank them, and ask that they continue to vote in support of Kentucky's public lands. Congressmen Barr (R), Massie (R), Rogers (R), and Guthrie (R), all voted in support of the Westerman bill.
You can find your member of Congress here.
If you make a call or send an email to your representative, please let us know!
Four thousand acres of logging proposed in London District of the Daniel Boone. Comments due April 22, 2018.
(UPDATE: The Forest Service has officially extended the comment period to May 14, 2018 after we posted that they had not notified the public about the scoping period)
The Forest Service has proposed yet another new, large logging project, this time proposing over 4,000 acres of timber harvesting in the London District of the Daniel Boone National Forest in Laurel, Pulaski, and Rockcastle Counties. The Pine Creek Forest Restoration Project comes at the same time that the Forest Service proposed 3,200 acres of new logging in the Redbird District, and just weeks after the Forest Service proposed toloosen logging restrictions designed to protect endangered Indiana bats.
Comments on the Pine Creek project are due by Monday, April 23rd. These are your public lands, and your voice matters. Directions on how to submit comments are at the bottom of this alert.
While the Forest Service signed the Pine Creek scoping letter and posted it to their website on March 22nd, they did not send out any notice whatsoever to the public. We only learned about it because we regularly check their project web pages. The Forest Service has promised to increase the scale and pace of new logging projects. But, if they’re too overwhelmed to even send out notice to the public, what does that say about their ability to properly analyze and consider the impacts of logging over 7,000 acres? What does that say about their commitment to public participation?
The Pine Creek project is a complex vegetation management project centered on the lower Rockcastle River, from near I-75 to the confluence with the Cumberland River. The area includes a wide diversity of forests and rare species, the Rockcastle wild river corridor, and some of the most popular hiking and camping areas in the Daniel Boone National Forest. The Forest Service has proposed some good management activities that we support, and some not-so-good management activities that we oppose. While we still need more time to analyze things and check conditions on the ground, below we offer our take on some of the main proposed actions to help you understand the project and submit comments.
Early seral habitat/Shelterwood logging
The Forest Service has proposed an initial 1,300 acres of logging to create early seral habitat (young forest conditions). Most of this logging will be in the form of even-aged shelterwood harvests, leaving 7 to 20 trees per acre in 40 acre patches. They also state that they plan to implement shelterwood harvests on 2,000 additional acres approximately 10 years after implementing the proposed midstory thinnings. Some proposed shelterwood logging is along the Sheltowee Trace National Recreation Trail. The combined 3,300 acres of intensive, even-aged logging represents our greatest concerns with the Pine Creek project.
Some of the most significant and lasting impacts relating to logging come from the log landings, skid trails, and temporary roads used to process and haul logs out of the forest under conventional forestry systems. Large log landings, ranging from about ¼ to 1 acre in size, are cleared in the forest and compacted for logging equipment and trucks. Invasive species frequently become established. The Greenwood project, with about 2,500 acres approved for logging, required 139 log landings. “Temporary roads” are bulldozed from landings through the forest, cutting across slopes and acting as vectors for invasive plant species, while remaining trees can suffer damage from felling and hauling.
Kentucky Heartwood often supports (or does not oppose) non-commercial midstory thinning, particularly in order to restore fire-adapted forest structure. However, most of the midstory thinning in the Pine Creek project aims to promote oak establishment in the understory in preparation for the next round of logging. The Forest Service could choose to approve a midstory reduction without subsequent logging, and allow turnover in the canopy to result from natural disturbance. Doing so could promote oak establishment over time while avoiding the damage caused by conventional logging. Early seral habitat is important for a wide range of species. However, this type of habitat is more sustainably created through the restoration of fire-adapted uplands and an acceptance of the role of natural disturbance in our forests.
Establishment of woodland and wooded grassland communities
The Forest Service is proposing to create or restore fire-adapted open forest and forest-grassland communities in the Pine Creek project area. Historical and botanical evidence suggest that these community types were important, and even extensive, in some parts of the project area. They plan to do this through 730 acres of commercial logging that would leave 5 to 40 trees per acre, along with another 160 acres of non-commercial felling. Implemented in the right locations with the right long-term management (particularly short fire return intervals), these natural communities can help support a variety of rare and declining plant and animal species. Most of the woodland and wooded grassland management is proposed for the southwestern section of the project area in Pulaski County, in an area that is generally appropriate for this type of management, and follows detailed discussions and field trips that included the Kentucky Heartwood, the Forest Service, Kentucky State Nature Preserves Commission, and The Nature Conservancy. Kentucky Heartwood prefers that the Forest Service rely on natural disturbance, non-commercial felling, and prescribed fire to manage for these community types. We will need more time to examine the specific stands proposed for logging for woodland restoration in order to assess whether or not the sites chosen for logging are reasonable.
Kentucky Heartwood has been urging the Forest Service for several years to incorporate good data, surveys, and site-specific information into projects to conserve and enhance declining and rare botanical communities that rely on open, upland conditions. Many of these specific plants and natural communities are relegated to roadsides and powerline corridors, and do not benefit from typical timber harvests. While such information was largely ignored throughout the planning and analysis of the Greenwood project on the Stearns District, there appears to be a genuine effort in the Pine Creek project to support these remnants of the Cumberland Barrens through cooperative work that includes Kentucky Heartwood and the Kentucky State Nature Preserves Commissions.
The Pine Creek project area includes 830 acres of a roughly 2,200 acre Designated Old-Growth management area. However, like most Designated Old-Growth management areas in the forest, there’s little in the way of genuinely old woods included. The project area also includes another 11,000 acres of riparian and cliffline corridors that are largely excluded from logging, but represent narrow, linear features and not large blocks of forest. Kentucky Heartwood has urged the Forest Service for many years to delineate more old-growth prescription areas in an effort to conserve large sections of older secondary forest that could develop landscape-scale old-growth characteristics in coming decades. The Forest Service has proposed adding 500 acres of Designated Old-Growth in two areas within the Pine Creek project area, near Rock Creek and Angel Hollow. Both areas are good candidates, and should be designated for an old-growth emphasis in the Forest Plan. However, the additions are largely narrow zones in lower landscape positions supporting hemlock-mixed mesophytic forests, and do not include appreciable upland forests. We think that the Forest Service should expand the new Old-Growth Management areas to include appreciable upland forests. It is important to note that the Designated Old-Growth management prescription in the Forest Plan does not preclude the implementation of management activities. What is does mean is that any management that is done should be to support the development of old-growth forest ecosystems.
Shortleaf pine stand improvement
The Forest Service has proposed to restore shortleaf pine on 1,500 acres utilizing what we deem as some progressive and ecologically appropriate methods. Shortleaf pine was decimated by the southern pine beetle between 1999 and 2001. Previous approaches to shortleaf pine restoration, particularly those in the Greenwood project in the Stearns District, have relied heavily on logging healthy hardwood stands and planting pines in dense monocultures. The proposed action in the Pine Creek project would rely on noncommercial methods and planting trees in groups and interspersed with existing vegetation, better mimicking natural patterns.
The project area includes 9,300 acres of existing prescribed fire units that were approved in 2014. We believe that the evidence supports the use of prescribed fire in most of these areas. The Pine Creek proposal would add another 2,400 acres of prescribed fire in the project area. Some of the new areas we already know, and we support them being added to the prescribed fire program. Some areas we still need to evaluate, but generally do not have major concerns.
Comments on the Pine Creek project are due by Monday, April 23rd and should be emailed to:
or sent by postal mail to:
Jason E. Nedlo
London District Ranger
761 South Laurel Road
London, Kentucky 40744
Be sure to include “Pine Creek Forest Restoration Project” in the subject line of any comments.
You can review the Forest Service's proposal and documents on our website here or on the Daniel Boone National Forest website here.
And if you find this information useful, please consider supporting our work by donating to or joining Kentucky Heartwood. We are a small, 501(c)3 non-profit organization, and your membership and tax-deductible donations really matter. Thanks!
The U.S. Forest Service has proposed 3,200 acres of intensive logging on the steep and rugged slopes of the Redbird District of the Daniel Boone National Forest. Comments need to be submitted by Monday, April 2nd. The "South Redbird Wildlife Habitat Enhancement Project" threatens critical habitat for the Kentucky arrow darter (Etheostoma spilotum), which was listed as "threatened" under the Endangered Species Act in 2016. The darter is found only in clean waters of the upper Kentucky River, and has disappeared from 44% of its range since 1990. Nearly 900 acres of proposed logging is in the watershed of Elisha Creek, which is also home to the federally-endangered Snuffbox mussel (Epioblasma triquetra). The snuffbox was protected under the Endangered Species Act in 2012 on account of a 62% rangewide decline. Unlike the mainstem of the Redbird River, which is too polluted by mining runoff, oil and gas development, and sewage for these species to live, the clean tributaries in the project area provide habitat needed for these species' survival.
Of the 32,300 acres of national forest land in the South Redbird project area, 27% has been harvested since 1980 and only 15% is over 100 years old. This is a stark contrast to the centuries-old forest at Lilley Cornett Woods, just 25 miles to the east. And yet the Forest Service is proposing to log 23% of all forest over 100 years old in the project area. Several areas ranging from 200 to 350 contiguous acres have been proposed for logging. Combined with previous cuts, some sections of forest, up to 800 acres, will hardly have any trees over 30 years old left standing.
The Forest Service proposed the South Redbird project at the same time as a Forest Plan amendment to loosen logging restrictions designed to protect endangered Indiana bats. And another proposal to log several thousand more acres of the London District (the Pine Creek project) was just posted on the Daniel Boone National Forest website. Expect to see more on that soon.
The South Redbird project follows a series of public meetings that the Forest Service refers to as “collaborations.” While Kentucky Heartwood is listed as a “collaborator” in the scoping letter, our good-faith input throughout the process was largely ignored. In fact, the project reflects few of the concerns raised by participants – other than those of state and federal agencies pushing for more clearcuts and “regeneration” harvests for ruffed grouse habitat. While the forest has been characterized by some as “too old,” the fact is that less than half the forest is over 70 years old.
In 2008, the Forest Service approved 1,200 acres of logging immediately north of the South Redbird project area as part of the Group One Redbird River Project. The Group One project included a Forest Plan amendment that established a 12,000 acre “Ruffed Grouse Emphasis Area” to be maintained under 60 year timber rotations in cooperation with the Kentucky Division of Fish and Wildlife Management. Kentucky Heartwood successfully appealed that project twice before it was approved after a third revision. Despite the specific grouse emphasis, after 10 years neither federal nor state managers can answer questions regarding the success or failure of their grouse management. And yet they insist we need more forests cleared across the district for grouse. Kentucky Heartwood suggested early in the process that the Forest Service consider meeting forage needs for grouse by incorporating small to medium-sized group selection cuts in a matrix of thinning oriented toward old-growth structural development. But this would mean less timber getting cut, and apparently that’s not worthy of serious consideration.
Despite its rugged beauty and rich diversity, the Redbird District is being treated like a throw-away district by the U.S. Forest Service. There are no hiking trails and no campgrounds – issues that were raised repeatedly during public meetings by members of the public and U.S. Forest Service staff. The only recreational infrastructure is the extensive Redbird Crest ATV trail, which the Forest Service proposes to reroute with 12 new miles of ATV trail construction. National forest lands in the Redbird District are an island in a landscape of vast strip mines and clearcuts. The forest here needs to be protected and nurtured, and we think that the Forest Service can do better. Please help encourage them to do so.
Official documents for the project can be found on the Daniel Boone National Forest website. And more information can be found on our website here.
Comments are due by Monday, April 2, 2018, and should be emailed to:
Please note in the subject line that the comments are for South Red Bird Project.
Comments can also be mailed by U.S. Postal Service to:
Redbird District Ranger
91 Peabody Road
Big Creek, KY 40914
Email Address Correction:
We have heard from several people that the Forest Service email address we linked to is invalid. Thanks for letting us know! We tracked down the error in the email address and corrected it on our website. There was an invisible extra dash that was in the email address between the word southern and daniel. This happened because we copied the email address from the scanned pdf provided by the Forest Service, and the optical character recognition must have added this extra dash. Many programs will turn two dashes in a row into one dash, and that is what happened in this case, resulting in an invisible extra dash. I deleted it and now it should work. Sorry about that!!
The correct email is (the one in the post above has been corrected as well):
Make sure when you copy/paste that there is no space or period at the end of the email address as well. If you have any issues sending your comment in, please let us know.
Feel free to copy firstname.lastname@example.org on your comment email.
Also, you should receive a confirmation reply from the Forest Service letting you know your message was received. Sometimes it takes a few hours to receive the notice. If you do not receive one, that means they did not get your message.
Also note, if you go to the page for sending comments on the DBNF website, old information for sending comments to Jared Calvert is posted there. The correct instructions for commenting are in the scoping letter, posted on this page of the DBNF website.
Kentucky Heartwood has submitted comments to the Daniel Boone National Forest concerning the proposed Forest Plan Amendment. (Scroll down for text or click here for a downloadable PDF of our comment letter). As of this posting, 24 public comments have been submitted and are available to read on the Daniel Boone National Forest website here, including comments from the U.S. Fish and Wildlife Service (USFWS) Kentucky Field Office (KFO).
Notably, the KFO states in their comment letter, "If the action is carried out as proposed, an increase in adverse effects on federally-listed species is anticipated." The KFO also states, "While the existing standards are more restrictive, it is important to note that they were intended to avoid and minimize the potential for adverse effects and incidental take of Indiana bats on the DBNF that were likely to occur as a result of certain types of tree removal and prescribed fire. In some circumstances, the season restrictions, buffers, and other standards also provided protection for-federally-listed plants and aquatic species. Elimination of these restrictions is, therefore, likely to have the opposite effect and result in increased adverse effects on listed bats, plants, and aquatic species and designated critical habitat, especially in light of the increased amount of forested habitat proposed for treatment under the proposed Forest Plan amendments."
It is very important that the Forest Service receive comments from the public.
We need to let them know that protecting endangered species is more important than selling a few more logs from our public forest. Feel free to use Kentucky Heartwood's comments as a point of reference for writing your own. You are also welcome to copy our comments and state to the Forest Service that you agree with them, if that makes it quicker or more likely for you to submit comments.
Here is a link to the page on the Daniel Boone National Forest website where the public can comment on this proposal. Comments are due by the end of the day on Monday, March 26, 2018.
Comments can also be emailed to: email@example.com
Or sent by postal mail to:
Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391
Be sure to state "Plan Amendment" in the subject line when providing electronic comments, or on the envelope when replying by mail.
Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391
March 25, 2018
RE: Forest Plan Amendment
Dear Supervisor Olsen,
Thank you for the opportunity to submit comments on the proposed Forest Plan Amendment with regards to Indiana bats and other federally listed species. The following comments are being submitted on behalf of Kentucky Heartwood and the Center for Biological Diversity.
To begin with, we have no immediate concerns with the proposal to update definitions in order to bring the Forest Plan in to alignment with current U.S. Fish and Wildlife Service (USFWS) terminology. This is reasonable and prudent. We do have concerns regarding changes to restrictions or parameters in the Forest Plan affecting vegetation management, and logging in particular. The removal or reduction of protective measures with regards to Indiana and northern long-eared bat maternity colonies are particularly worrisome. Both of these species of bats are in sharp decline, and immediately imperiled. The possibility that the Daniel Boone National Forest would change Forest Plan standards in such a way as to increase the probability of impacting or destroying a maternity colony is not something that we find acceptable. The loss of a single maternity colony at this juncture could be catastrophic.
The following are questions and concerns that should be addressed in the environmental analysis for the Plan Amendment:
1) What are the current protocols for identifying maternity colonies or other active roosts? When during planning and harvest operations are surveys made, and by whom? What training is received by personnel to identify active roosts?
2) How often have maternity colonies been found in project areas? Following the identification of Indiana (and northern long-eared) bats, how did the Forest Service modify or delay specific projects and operations in order to comply with Forest Plan Standards? Please be specific.
3) Please provide ample scientific evidence demonstrating that the newly proposed Forest Plan standards (e.g., changes to basal area standards, snag retention, seasonal harvest restrictions relating to habitat occupancy, etc.) are more or as protective for federally-listed bat species as the current plan standards. It does not appear to us that they are.
We expect the Forest Service to commit to a thorough, detailed, and reasoned analysis with regards to any changes to Indiana and northern long-eared bat management on the Daniel Boone National Forest. Any changes to the Forest Plan should be firmly rooted in evidence that future management will be as or more protective of Indiana and northern long-eared bats as the current procedures.
Jim Scheff, Director
P.O. Box 1486
Berea, KY 40403
The Daniel Boone National Forest has proposed to amend the forest's 2004 management plan with respect to the federally endangered Indiana bat. The Indiana bat (Myotis sodalis) was first listed as an endangered species in 1967, and has been in decline ever since. Since 2006, the spread of the disease White Nose Syndrome (WNS) has caused remaining populations of Indiana bats (as well as other species of bats) to crash.
Some of the Forest Service's proposed changes simply align terms and criteria with those currently in use by the U.S. Fish and Wildlife Service. However, the Forest Service is also proposing to loosen several protective standards that limit timber harvest near maternity colonies of both Indiana bats and northern long-eared bats (Myotis septentrionalis). Northern long-eared bats are listed as threatened under the Endangered Species Act on account of catastrophic declines from WNS.
One of the reasons provided by the Forest Service of the need for change is that logging restrictions near maternity colonies during the summer roosting season mean that more logging has to take place during the wetter winter months. But over last decade, several aquatic species have been listed as threatened or endangered, meaning that sedimentation of streams from logging has to be taken more seriously. For example, the Forest Service just proposed around 3,000 acres of intensive logging on steep slopes in the Redbird District in designated Critical Habitat for the Kentucky Arrow Darter, which was listed as threatened under the Endangered Species Act in 2015. The Redbird District includes most of the remaining habitat for this species. We'll post more about the South Redbird Project in the near future.
The bottom line is that the only changes the Forest Service should be making with respect to Indiana and northern long-eared bats are those that are demonstrably protective and support their populations. These important, imperiled species cannot afford the loss of a single maternity colony - especially to facilitate logging on our public lands.
For now, the Forest Service is accepting comments on their proposal until Monday, March 26th. The agency will likely prepare an Environmental Assessment sometime in the near future.
Links to project documents can be found on our website here, and the Daniel Boone National Forest website here.
Here is a link to the page on the Daniel Boone National Forest website where the public can comment on this proposal. Comments are due by 3/26/2018.
Comments can be emailed to: firstname.lastname@example.org
Or sent by postal mail to:
Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391
Please state "Plan Amendment" in the subject line when providing electronic comments, or on the envelope when replying by mail.
Here is where you can read comments that have been submitted by the public.
By Jim Scheff, Director, Kentucky Heartwood
Our fight over the Greenwood project came to an underwhelming and, for the most part, disappointing conclusion at the end of October, 2017. Kentucky Heartwood worked for more than three years to see the project turn from a typical timber harvest toward a science-based plan that would support the restoration of relict, fire-adapted open forest communities as well as the recovery of large areas of old-growth. In July 2017, the Forest Service issued their Draft Decision Notice and Finding of No Significant Impact – a preliminary approval of the project. Kentucky Heartwood then filed a detailed, 32 page predecisional objection (a formal administrative objection) detailing a wide range of issues, concerns, and failures in the Forest Service’s analysis. In October, we had a formal meeting with Forest Service officials to seek resolution to the concerns raised in our objection. The meeting was scheduled for two hours but stretched to four hours as we delved deep in to the issues. The meeting was somewhat constructive.
In the end, the Forest Service did agree to some small changes, and made overtures toward more careful planning in the future. While the Forest Service did not agree to go back and actually survey the project area for rare species and communities, they stated that they planned to receive increased training from the Kentucky State Nature Preserves Commission (KSNPC) on how to identify rare communities, would look for rare communities during project implementation, and adjust management accordingly. They also committed to consulting with KSNPC and Kentucky Heartwood in taking a closer look at management opportunities in the 751 Roadsides/Curt Pond Ridge area – a hotspot for Cumberland barrens remnants that are in desperate need of careful, active management, as well as possible remnant barrens sites in the Blue John area.
Another point of resolution that was addressed was the Forest Service’s prior unwillingness to provide clear targets for native versus non-native plantings in 75 wildlife openings covering 222 acres. The Forest Service has now formally clarified that they will manage for 35% in cool season grasses and grains, 20% in native pollinator mixes, and 45% in native grasses. While we would rather see all of the area managed for native vegetation, this is a clear improvement over the current condition and the vague statements made throughout the analysis. With regard to the proposed broadcast spraying of herbicides in wildlife openings, the Forest Service has agreed to apply herbicides only after vegetation has been cut down or is otherwise out of flowering in order to avoid impacts to native pollinators and birds, and to spray no more than 33% of the total acreage in a given year. Again, this is not what we wanted, but it is a meaningful improvement.
These changes are in addition to those that came about between the original 2014 scoping document and publication of the Environmental Assessment in early 2017. Those changes included reducing the amount of logging by about 600 acres (including eliminating logging that was planned at the trailhead to the Three Forks of Beaver Creek overlook) and the elimination of 26 miles of bulldozed firelines.
What is most disappointing, however, is that the Forest Service misrepresented forest conditions in many areas in order to promote logging. Several sites covering hundreds of acres that are now largely open-canopied as a result of the 1999-2002 southern pine beetle outbreak, and which have good floristic indicators of barrens or woodland type communities, will not be managed with fire or
otherwise. Meanwhile, intact, closed-canopy hardwood forests will be cut to “restore” open-canopied and pine forests, with 139 log landings cleared and compacted to facilitate the removal of timber on over 2,000 acres.
Over the coming years we will closely monitor implementation of the project. Some species and forest communities will likely benefit – particularly if the proposed fire management is implemented carefully for appropriate, site-specific ecological responses. However, there will certainly be negative impacts, disruptions, and trade-offs for years to come.
To learn more about the ecology of the Greenwood area and our efforts to affect change on this project, please see our Summer 2016 and Summer 2017 newsletters, as well as our comments and predecisional objection, all of which are available on our website here.
This article was published in the Winter 2018 edition of our Newsletter. Here is a link to our Newsletter archives.
Kentucky Heartwood files in U.S. Court of Appeals to block Kinder Morgan/Tennessee Gas Pipeline conversion project
For Immediate Release, February 6, 2018
Contact: Ryan Talbott, Allegheny Defense Project, (503) 329-9162
Tom Fitzgerald, Kentucky Resources Council, (502) 875 2428
Jim Scheff, Kentucky Heartwood, (859) 334-0602, email@example.com
Groups petition U.S. Court of Appeals in D.C. for review of Federal Energy Regulatory Commission Order Approving “Abandonment” and “Repurposing” of Tennessee Gas Pipeline
Federal agency failed to consider unique safety and environmental hazards posed by conversion of aging natural gas pipeline to transporting hazardous liquids
BEREA, KY – Three environmental groups filed a Petition for Review with the D.C. Circuit Court of Appeals on January 31st asking the Court to review a decision by the Federal Energy Regulatory Commission (FERC) approving the abandonment and repurposing of the Tennessee Gas Pipeline (TGP), owned by energy infrastructure company Kinder Morgan. The petitioning organizations, Kentucky Resources Council, Allegheny Defense Project, and Kentucky Heartwood, argue that the FERC failed to give adequate consideration to the unique safety and environmental risks posed by approving the repurposing of a 24” diameter, 70+ year-old natural gas pipeline for transporting heavier, more volatile natural gas liquids (NGLs).
Natural gas liquids are hydrocarbon byproducts of oil and gas extraction. The “fracking boom” in the Marcellus Shale region of Pennsylvania, Ohio, and West Virginia has created a glut of these materials, which are used in the plastics and other industries. FERC approved the “abandonment in place” of one of Tennessee Gas’ natural gas pipelines; the first step in Kinder Morgan’s plan to reverse the flow in order to transport NGLs to processing and export facilities on the Gulf Coast. The pipeline traverses 6 states and 18 Kentucky counties.
Particular concerns have been raised in Kentucky, with the pipeline passing through populated areas of Richmond in Madison County and Danville and Herrington Lake in Boyle County. Both counties have passed zoning requirements relating to hazardous liquids pipelines in order to have some say in whether or not hazardous liquids pipelines are compatible with existing land uses.
The pipeline also poses risks to the exceptional biodiversity of the Green River upstream and through Mammoth Cave National Park. The river provides habitat for 151 species of fish, with 29 mussel and fish species that are considered imperiled or vulnerable, and 7 listed as endangered under the Endangered Species Act. Unlike natural gas, a portion of the NGLs can leak or spill into surface and groundwater and soil, causing serious and lasting environmental impacts.
The petitioners filed a Request for Rehearing with FERC last October. FERC failed to issue a decision on the Petition for Rehearing, instead issuing a “tolling order,” stating that the request was being reviewed but not decided upon. FERC-issued tolling orders allow pipeline projects to move forward while delaying citizens timely access to judicial review. The Petitioners believe that the failure of FERC to act within the time allowed for a decision on rehearing, set by Congress, made the underlying decision to approve the pipeline abandonment immediately subject to judicial review.
Over the course of FERCs environmental analysis, more than 900 comments were submitted, almost entirely opposed to the project. Among those expressing concern were the Madison County Fiscal Court, the Clark County Fiscal Court, the Boyle County Fiscal Court, the Marion County Fiscal Court, the Barren County Fiscal Court, Kentucky State Senate Majority Whip Jimmy Higdon, the Bluegrass Areas Development District, the Danville-Boyle County Chamber of Commerce, the City of Danville, the Danville Independent School District and Danville Schools Board of Education, and the Rowan County Board of Education.
“The reversal and conversion of this pipeline to transport NGLs will further induce fracking in Pennsylvania, fragmenting our forested watersheds with more roads and well pads,” said Ryan Talbott, executive director of the Allegheny Defense Project. “FERC, however, refused to even consider those impacts before approving Kinder Morgan’s proposal. Such a short-sighted, industry-friendly review may benefit Kinder Morgan’s bottom line but it comes at the expense of Pennsylvanians’ right to clean water and intact forests.”
More information on the fight against the pipeline can be found on our Forest Blog here.