Wild places sustain and define us; we, in turn, must protect them.
In January the Forest Service published their final decision on the Pine Creek Forest Restoration Project. The final approval of the project comes 4 years after the Forest Service’s first meetings to gather input on this extensive project covering what is, arguably, one of the best parts of the Daniel Boone National Forest. Over these four years, Kentucky Heartwood submitted multiple rounds of formal comments and filed an administrative objection (with the Kentucky Resources Council) challenging portions of the Draft Decision and Finding of No Significant Impact. We covered thousands of acres in the field, documented old-growth and rare plants, exploding user impacts at Pine Island Double Falls, and walked the length of the Sheltowee Trace National Recreation Trail as it traverses the project area. We led field trips, hosted a public forum in Corbin, published numerous articles and blog posts, and shared stories and images of this outstanding piece of Kentucky. We worked hard to spread word about this project, and to help get the public involved.
We think that our efforts had a big impact on the final outcome. There are certainly aspects of the Pine Creek project, and the environmental analysis, that we are not happy with. However, there’s also a lot in this proposal to be pleased with. This is a complicated project – in many ways reflecting the complexity of the landscape, it’s biodiversity, and the myriad of ways that the public connects with it.
First let's talk about the good stuff:
New old-growth designations
For the first time since adoption of the Forest Plan in 2004, the Forest Service expanded official old-growth designations in the Daniel Boone National Forest. This is something that we’ve been advocating for for many years. Initially, the Forest Service proposed adding 500 acres to the Designated Old-Growth Management Prescription in the Forest Plan, including 370 acres adjacent to Rock Creek Research Natural Area and another 130 acres in Angel Hollow. Throughout the analysis process, we pushed for larger old-growth designations, including more upland forest types. In response, the Forest Service expanded the Designated Old-Growth designation around Angel Hollow to 550 acres, for a total 920 new acres in this management prescription. Both areas include a combination of old-growth and older second-growth forests.
Dropping 2,000 acres of shelterwood harvests
The Pine Creek project originally included over 3,200 acres of even-aged shelterwood harvests. Approximately 1,300 acres were proposed to happen over the next 5 to 10 years, with another 2,000 acres to occur after about 10 years in stands initially managed with midstory removal (non-commercial thinning of mostly red maple). We asked the Forest Service to drop the latter 2,000 acres of shelterwood cuts, and they did. Logging in those stands could still be proposed in some future project, but for now they will only be managed with non-commercial midstory thinning and, in some areas, prescribed fire.
Pine Island Double Falls
Over the course of the project’s development, visitation of Pine Island Double Falls exploded. We convinced the Forest Service to drop the shelterwood logging prescription for a 50-acre stand adjacent the falls area, including some gorgeous large black and northern red oaks and some nice old-growth tulip poplars. The Forest Service has also committed to a public process to develop a trail to access the falls and try to limit the expanding and unmanaged user impacts.
Protecting the Sheltowee Trace National Recreation Trail
The Sheltowee Trace National Recreation Trail goes through much of the Pine Creek project area, including several proposed harvest areas. One section of the trail in particular, along Poison Honey road, would have been significantly impacted. We originally asked the Forest Service to drop the shelterwood prescription along the road, and reroute the trail from the road into the forest. The Forest Service modified the proposal to reroute the trail through the forest, but still planned a shelterwood cut that would have significantly affected the experience of trail users and degraded the area’s scenic integrity. During the formal objection process we convinced the Forest Service to change the prescription of this unit to a woodland management prescription. This new prescription will retain much more the forest canopy, remove some of the midstory, and include prescribed fire (already proposed for that section). The Forest Service has committed to working with the Sheltowee Trace Association on trail layout. This new prescription, while still including some timber harvest, should result in an open forest structure with a good amount of remaining canopy and large trees.
Restoration of fire-adapted upland forest and grassland communities
One of the more fascinating aspects of the ecology of the southern Daniel Boone National Forest is the presence of historic grassland and oak and pine savannah remnants existing in an otherwise deeply forested landscape. Indicators of these relict communities, like wood lily, rattlesnake master, blazing stars, and other conservative grassland species, can be found hanging on along some roadsides and powerline corridors. While the earlier Greenwood project on the Stearns District (approved in 2017) was ostensibly aimed at restoring these important natural communities, the Forest Service in that project failed to integrate important botanical indicators into planning – instead relying on general assessments and emphasizing management in locations where there was good timber to cut. In contrast, the London District undertook a detailed assessment of these upland, fire-adapted communities for the Pine Creek project, including input and data from the Kentucky Office of Nature Preserves, Kentucky Heartwood, and botanist Julian Campbell. This collaborative effort helped to identify broad areas and specific sites where comprehensive restoration, including fire, commercial and non-commercial thinning, and other work, would have the most significant benefits for the broadest suite of species. Most of the woodland management in the Pine Creek project will happen in the Pulaski County side of the Rockcastle River.
The Forest Service has also incorporated a novel approach to restoring shortleaf and pitch pine in these areas. These species of pines were decimated during the 1999-2002 southern pine beetle outbreak. Contrasting with previous pine restoration efforts on the Daniel Boone, which have been akin to pine plantations, the Forest Service here plans to plant pine in small groups or clusters (aka “cluster planting”) in suitable microsites. This will help the area develop a more complex, heterogenous structure and species composition that more closely resembles the area’s historic condition.
The restoration of fire-adapted upland communities, with an intermix of semi-stable grassland, shrubland, and open-canopy forests, is a way to provide for the long-term habitat needs of species that rely on early-seral and related vegetation structures.
Close and rehabilitate user-made OHV and horse trails
The Forest Service used LIDAR to document 23 miles of illegal off-road vehicle and horse trails impacting the state Wild River section of the Rockcastle River. The Forest Service plans to close and rehabilitate these user trails by felling trees, placing boulders, and revegetating areas near the river.
The not-good stuff:
1,150 acres of shelterwood cuts
The Pine Creek project still includes 1,150 acres of shelterwood regeneration cuts, with some really nice sections of forest that will be heavily logged. We have concerns that some local populations of Stewartia ovata (mountain camellia), in particular, will be damaged. To their credit, the Forest Service finally admitted that without additional management, logging these areas will likely result in a transition from oak-dominated forests to forests dominated by red maple and tulip poplar. This species shift is a pattern we’ve documented extensively in previously logged areas across the Daniel Boone National Forest. To address this issue they’ve included additional management, including non-commercial felling and prescribed fire, in areas proposed for shelterwood cuts to help perpetuate oak species in these stands.
It’s true that the proposed shelterwood cuts will provide benefits to some struggling wildlife species, and some migratory bird species in particular. However, unlike the woodland restoration activities described above, the habitat benefits of shelterwood harvests tend to be brief, while the impacts of road building, non-native plant invasions, and loss of large trees persist. Hopefully the Forest Service will provide more care and attention to management in these areas than we’ve seen in recent harvests in the Redbird District.
Indiana and northern long-eared bats
One of the big sticking points for Kentucky Heartwood has been the Forest Service’s refusal to conduct surveys for endangered bats in proposed harvest areas. In particular, we are concerned about impacts to maternity colonies of federally-endangered Indiana bats and federally-threatened northern long-eared bats. The Forest Plan has a requirement that “Tree cutting may not be conducted within 2.5 miles of any Indiana bat maternity colony from May 1 through August 15.” This binding Forest Plan Standard also applies to Northern long-eared bats. However, the Forest Service is relying on limited survey data from more than a decade ago to determine that no maternity colonies are in the project area. The U.S. Fish and Wildlife Service, in comments they submitted last year on a proposed Forest Plan amendment which would limit protections for endangered bats, cited this paucity of survey data in stating that “It appears likely that there are other Indiana bat and northern long-eared bat maternity colonies present that have not been documented.”
We raised this issue in our comments and through the formal, predecisional objection process. The Forest Service refused to budge on this.
The Pine Creek project area covers some of the best parts of the Daniel Boone National Forest. It’s a rugged landscape where the Rockcastle River and its tributaries cut deep gorges through the sandstone of the Pottsville Escarpment of the Cumberland Plateau. It’s a labyrinthine, magical world of cliffline and waterfalls, natural arches and old-growth forests. It’s home to a myriad of rare and endemic species, like Lucy Braun’s white snakeroot and Indiana bats. And it includes some of the most utilized and loved recreational sites in the Daniel Boone. We thank every one of you that sent comments to the Forest Service advocating for this special landscape. Your contributions had a tangible effect on the outcome of this project. Thank you.
You can read more about the project, including Kentucky Heartwood's comments and formal objection here.
If you appreciate this work, and want to see it continue, please consider supporting Kentucky Heartwood with a financial contribution. We are a small, bare-bones organization and really do need your help to keep it up. You can support Kentucky Heartwood by making a donation here.
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.
Comments on the Environmental Assessment for the “Improving Conditions in the Blackwater Watershed” are due this Friday, December 27, by 11:59 pm. This comment period comes on the tail of the South Redbird comment period and approval of the Pine Creek project. Together these projects would approve about 8,000 acres of logging on the Daniel Boone National Forest.
The Blackwater project would approve logging on 1,200 acres per decade, forever, on national forest lands on the east side of Cave Run Lake. In a new twist, the Forest Service wants to approve this open-ended logging project without first identifying any specific locations where they will actually sell the timber, build roads, or perform other management. Instead, the Forest Service is attempting a new (and legally problematic) process called “condition-based management.” Under this new system, the Forest Service won’t provide any site-specific information or analyze site-specific effects before determining if there will be any major environmental impacts and, ultimately, approving the project. The Forest Service says that they will involve the public in identifying areas for logging after their formal decision is made to approve project – despite having worked for over the past three years to develop this proposal. Does this make sense to you?
The Blackwater proposal includes three Proposed Actions:
The first Proposed Action is logging “to support wildlife by providing a diversity of forest conditions.” Most of this logging will be large, even-aged shelterwood harvests where most of the trees in any given site will be cut. Log landings and skid roads will be constructed. The logging is proposed across large zones totaling about 12,000 acres. Logging could happen just about anywhere in these 12,000 acres with the exception of cliffline and riparian buffers. The Forest Service states that they may build an undisclosed mileage of new roads in undisclosed locations, but that this is not significant because it will be offset by closing a similar mileage of other undisclosed roads.
Kentucky Heartwood has been collecting data from sites previously logged on the Cumberland District, and across the Daniel Boone National Forest, demonstrating that the Forest Service’s logging program has resulted in degraded forests – converting them from largely oak and hickory dominated forests to red maple and tulip poplar. The Blackwater proposal includes no management to restore previously logged areas.
The second Proposed Action is to improve access to the national forest “by enhancing parking and upgrading road maintenance to allow for more public motor vehicle use.” The Forest Service only provides one map showing road segments where “enhancements” and “upgrades” might happen. Conveniently, these same road sections will need upgrading to haul timber. The Forest Service also states that some gated roads “may be considered for seasonal opening to motorized traffic.” But they do not say which segments, whether they will open them, when, or what the effects will be. Again, this is the level of detail being provided in the full Environmental Assessment, which is the basis for making a final decision on the project.
The third, and last, Proposed Action is “Improving water quality through stream restoration and stream crossing improvements.” This could be great. But it’s really not clear. The Forest Service provides one map showing what we estimate to be about 16.8 miles of streams in nine watersheds where restoration “may” and “could” occur. No specific stream lengths, prioritization of sites, or other benchmarks are provided. But, as with logging, the Forest Service treats this lack of detail and clarity as if it doesn’t matter. The Forest Service could restore 0.5 miles in just one stream, or 16.8 miles across 9 watersheds, and it’s all treated the same in the Environmental Assessment.
Prescribed fire is not included as a Proposed Action in the proposal. However, the Forest Service refers to prescribed fire in one table in the Silviculture Report, where they indicate what returning intervals will be used. And the Hydrology Report describes prescribed fire as part of the proposal, recognizing that firelines will be constructed. However, nowhere else in the Environmental Assessment is prescribed fire discussed. It’s not included among the Proposed Actions, and there are no maps showing where prescribed fire would occur. Prescribed fire could be beneficial. It might not be. Prescribed fire affects forest structure, regeneration, species composition, and wildlife in differential ways. The details matter. Either the Forest Service is proposing to approve prescribed fire, and in specific locations, or they’re not. This mushy, opaque analysis is simply not acceptable.
It is important for people to submit comments on this proposal. You don’t have to be intimately familiar with this part of the Daniel Boone National Forest to have valid, authentic input on this proposal. These are your public lands. 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 reality is that the Forest Service is trying to get out bigger logging projects, and more quickly, without having the fiscal and personnel resources to do a thorough and appropriate analysis. So they’re taking shortcuts to get their numbers up, and not just here in Kentucky. Right now the Forest Service is working to approve 60,000 acres of logging across 160,000 acres of the Chattahoochee National Forest in Georgia under this same “condition based management” system, failing to provide site specific information about what they plan to do and where. The Forest Service is also working to amend their regulations for implementing the National Environmental Policy Act (NEPA) to codify “condition-based management” as the way forward for analyzing timber projects on national forest lands across the country.
Comments on the Blackwater need to be submitted to the Forest Service by Friday, December 27th.
Comments can be submitted through the Forest Service’s website portal here.
Official project documents can be found here.
You can read comments that have been submitted by the public, here.
Comments can also be submitted by postal mail to:
District Ranger Jonathan P. Kazmierski
2375 KY 801 South
Morehead, KY 40351
Attn: Improving conditions in the Blackwater Watershed
Feel free to copy email@example.com on your comment email. 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, please note that commenting on this blog post does not send your comment to the Forest Service.
If you value this work, please consider donating to Kentucky Heartwood. The Forest Service's decision to release multiple large projects at the end of the year has really hindered our end-of-the-year fundraising efforts. We're a small group, and every bit helps. You can donate on our website here. Thanks!
Action Alert: Comments needed to stop 3,650 acres of logging in the Redbird District of the Daniel Boone National Forest!
The Forest Service is proposing to log 3,650 acres of the Redbird District of the Daniel Boone National Forest in Clay and Leslie Counties. Comments on the Draft Environmental Assessment (EA) of the South Red Bird Wildlife Enhancement Project (South Redbird project) are due this Friday, December 6th. This is a bad one folks, and we really need your help letting the Forest Service know that what they’re planning isn’t acceptable. Directions on how to comment are at the end of this post.
Over the last few years the Forest Service has been logging the nearby Group One Redbird project, implementing the same prescriptions on the same slopes and soils that they’ve proposed for the South Redbird project. And the results? Mountainsides bulldozed into oblivion, landslides, erosion, and severe infestations of invasive species. The purpose? According to the Forest Service, it’s about forest health and habitat improvement.
In this post you’ll see pictures from several recent logging sites in the Group One project. The bulldozed “roads” in the pictures are skid trails. Most of the logging units in the Group One project are about 20 to 50 acres. In South Redbird, some logging areas would be from 200 acres to over 350 acres across. The Forest Service says that they may build up to 91 miles of these “skid trails” to remove timber in the South Redbird project, along with 150 log landings. As much as we'd love to fill this page with more pictures of some beautiful, at risk sites in South Redbird, we think it's important for you to know exactly what the Forest Service is calling "habitat improvement" and "forest health" in the Redbird District.
We’re sending this alert so out late in the comment period because the Daniel Boone National Forest decided to release several major projects to the public at that same time. The Forest Service sent out notice of the 30-day comment period on the Draft EA for South Redbird on November 6th while we were working on our administrative objection to the Pine Creek project, which was due November 18th. And then on November 12th, the Forest Service sent out notice of the 30-day comment period for the Draft EA for Blackwater Project on the Cumberland District. We managed to get a 2 week extension on the Blackwater comment period, and you’ll be seeing information from us on that soon. Together these projects would approve about 8,000 acres of logging across the Daniel Boone National Forest.
Most of the streams in the South Redbird project are designated as Critical Habitat for the Kentucky arrow darter (Etheostoma spilotum), which was listed as “threatened” under the Endangered Species Act in 2016. The project area also provides habitat for the federally-endangered snuffbox mussel (Epioblasma triquetra). The Forest Service insists that these species won’t be harmed by logging because of protective standards in the Forest Plan. However, we’ve documented numerous instances in the Redbird District where Forest Plan standards and state best management practices were woefully inadequate, or otherwise completely ignored to strip the mountains of their timber.
There is one positive thing. We convinced the Forest Service to drop logging of the old-growth forest that we documented on the 46 acre Little Flat Creek site. You can read about our work on the Little Flat Creek site on page 6 of our Spring 2019 newsletter. Oddly enough, the Forest Service still won’t admit that it’s old-growth, insisting that it’s a young forest about 65 years old. However, our structural and age analysis demonstrates that it’s a multi-aged, old-growth forest, with many canopy trees from 150 to over 300 years old. Sadly, throughout the Draft EA for the South Redbird project the Forest Service demonstrates startling ignorance and hostility toward old-growth forests.
Young forests and early seral habitat are important. But the Forest Service can manage for these habitat types without bulldozing and destroying whole mountainsides. In May 2017, the Forest Service led a field trip during the development of the South Redbird project to show off successful management for early seral habitat. The site that they chose to highlight was a non-commercial unit in the Group One project, where trees were cut but no skid roads and landings were used to haul out the timber. Clearly this is a viable option.
As part of the South Redbird project, the Forest Service has also proposed harvesting trees along 45 miles of roadways, adding up to 750 acres of logging. For the most part, that management could be done without bulldozing skid roads through forest. It’s not ideal, but does offer a reasonable approach that limits the more severe impacts that are likely to occur. The Forest Service also has the option of creating early seral habitat by managing the nearly 6,000 acres of the project area that were logged in the 1980s and 1990s.
Our surveys have demonstrated that those forests are dominated by tulip poplar and red maple, despite the Forest Service arguing that big cuts like these are needed to promote oak regeneration. The Forest Service could modify their proposed “crop tree release” on 1,900 acres of these old logging sites to cut back the young tulip poplar and maple more heavily, supporting oaks and hickories while creating and enhancing early seral and young forest habitat, especially for grouse. These are all viable options that the Forest Service can use to meet their goals.
Kentucky Heartwood will be submitting detailed comments, where we’ll dig deep on the details. Comments from the public are also needed and very important. Please let the Forest Service know that the commercial logging prescriptions in the South Redbird project are not acceptable. Let them know we’re watching.
Comments need to be submitted this Friday, December 6th by midnight.
Comments can be sent directly on the Forest Service’s project page here or by emailing SM.FS.firstname.lastname@example.org.
You can read comments that have been submitted by the public, here.
Be sure to include “South Red Bird Wildlife Enhancement Project” in the subject line.
Comments can also be postal mailed to:
Robert Claybrook, Redbird District Ranger
91 Peabody Road
Big Creek, Kentucky 40914
Feel free to copy email@example.com 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, please note that commenting on this blog post does not send your comment to the Forest Service.
If you appreciate this information, and the work that we do, please consider supporting Kentucky Heartwood with a contribution! We've honestly been too busy with these projects to do any end of the year fundraising.
We're a small group and every donation helps.
Please donate via our website here, where you will find options for monthly, online, and mail in donations.
Thanks to the generosity of our members and supporters, $10,010.11 has been raised so far for our first ever matching funds campaign, meaning a total of $20,020.22 will go toward our work!
You all are amazing!!
We still have $14,989.89 left to go to take full advantage of this opportunity.
If you have been waiting for a good time to donate to Kentucky Heartwood, this is it! This offer expires at 11:59 pm on Tuesday, September 24, 2019.
This matching fund campaign made has been made possible through an astonishingly generous donation of $25,000 offered to us by Rich Rosen and Anna Marie Pavlik of Frankfort, Kentucky. Their donation, however, comes with one major stipulation – that we ask you, our members and supporters, to match Rich and Anna Marie’s investment in Kentucky Heartwood. They want to know that you support our mission as much as they do.
For 27 years, Kentucky Heartwood has worked continuously to protect and preserve Kentucky’s public lands and native forests. We do it for the old trees and orchids. We do it for the land snails and bats, warblers and darters. We do it for the peace and the beauty. We do it for wildness. And we do it for you.
And now, we need your help. If you can give, please do. It really will make a difference.
Donate online or via postal mail
Kentucky Heartwood is a 501(c)3 nonprofit organization. Donations are tax deductible.
Recurring monthly donations are available and appreciated.
Choose the subscribe option to donate monthly, or use the Donate button to give a one-time donation.
If you prefer to donate via postal mail, you can download our membership form by clicking here.
Mail donation and membership form to Kentucky Heartwood P.O. Box 1486 Berea, KY 40403.
Thank you so much to everyone who has donated so far! We couldn't do it without you!
The Daniel Boone National Forest is currently taking comments on the Draft Environmental Assessment (EA) for the Pine Creek Forest Restoration Project. This is a complicated project, which proposes intensive and damaging logging on thousands of acres of forest, but also includes plans for beneficial restoration and management for rare species and natural communities. Below you will find a breakdown of the main proposed actions to help inform your comments to the Forest Service. Comments are due by Wednesday, September 4th, 2019. Directions on how to submit comments are the end of this post.
You can read our May 2018 comments to the Forest Service on an earlier draft (scoping) of the Pine Creek proposal here. Video of a presentation that we gave in Corbin in January 2019 can be found here.
The Pine Creek project covers 45,700 acres of the Daniel Boone National Forest in Laurel, Pulaski, and Rockcastle counties. The area is centered on the lower Rockcastle River, from near I-75 to the confluence with the Cumberland River. This area includes some of the most popular recreation spots in the Daniel Boone, including Bee Rock, Rockcastle Recreation Area, Little Lick, Scuttle Hole, the Sheltowee Trace National Recreation Trail, Pine Island Double Falls, and the Wild River segment of the Rockcastle River. The area also includes a wide diversity of forest types and rare species, including some of the best old-growth and mature second growth forests in the Daniel Boone. The Forest Service first proposed the Pine Creek project in February 2018. Since the initial proposal the agency has made some improvements, but there are still major problems that need to be addressed.
The Bad Stuff:
Shelterwood logging on 1,300 acres for early seral habitat
Our most significant concern with the Pine Creek project is the Forest Service’s intent to log 1,300 acres for early seral habitat (young forest) using shelterwood methods (Action 1.A: Two-aged shelterwood). A shelterwood cut is a type of “regeneration” harvest where about 90% of the trees are cut. The Forest Service says that individual shelterwood cuts would be limited to 40 acres each, but some of these logging areas would be clustered to create logged areas of several hundred acres. The Forest Service originally proposed to approve an additional 2,000 acres of shelterwood harvests that would occur after 10 years (in stands managed under Action 5: Midstory removal), but has since agreed to drop logging these acres from the proposal.
Early seral habitat is important for a wide range of species. However, there are less impactful ways to create and manage for this type of habitat that are more consistent with prevalent natural disturbance regimes. For example, research from the University of Kentucky has shown that logging small, roughly half-acre patches of trees, along with light thinning around the edges (also known as “femelschlag” or “expanding gap” systems), can result in much better oak regeneration than large even-aged harvests like those proposed in the Pine Creek project. While uneven-aged and lower impact methods like expanding gap management could meet the Forest Service’s habitat and multiple-use goals, these methods don’t produce as much timber.
We strenuously urge the Forest Service to drop the proposed shelterwood harvests and instead manage for early seral habitat and oak regeneration in the following ways:
1) Manage the nearly 5,000 acres of forests harvested in the project area since 1980. Many of these areas are now forests of poor quality, with prior logging resulting in conversion of oak-hickory forests to tulip poplar and red maple. Expansion and modification of “Action 6: Crop tree release” could meet the Forest Service’s goals for early seral habitat;
2) Support the existing proposal for 980 acres of commercial and non-commercial management to restore fire-adapted woodland community types (Action 2: Woodland and wooded grassland/shrubland communities);
3) Support variable thinning along certain roadsides to create early seral and edge habitat and support rare species on 280 acres (Action 9.B: Roadside thinning);
4) Consider uneven-aged management with small group selection using expanding gap or femelschlag prescriptions where the above approaches aren’t sufficient.
The Good Stuff:
The Forest Service is doing a lot in Pine Creek project that we largely support, and have made some changes since their original proposal that make it better. While Kentucky Heartwood generally opposes logging in our national forest lands, this project does include some commercial thinning prescriptions that offer a reasonable approach for restoring and supporting rare and declining species and natural communities.
1) The Pine Creek project proposes using a variety of methods, including non-commercial and commercial tree removal and prescribed fire to restore upland, fire-adapted wooded grassland and shrubland communities (“woodlands”) in areas that were identified through collaborative work with the Kentucky Office of Nature Preserves, Kentucky Heartwood, and The Nature Conservancy (Action 2: Woodland and wooded grassland/shrubland communities). Most of the areas identified in the proposal for woodland management are good, or at least reasonable, choices given the specifics of the existing and historical vegetation.
Integrated with the woodland restoration is the proposed restoration of shortleaf and pitch pine communities (which were decimated by the southern pine beetle 20 years ago) through “cluster planting” of pine seedlings. Unlike prior pine restoration activities on the Daniel Boone that are more akin to plantations, “cluster planting” would restore a pine component in a manner that supports mixed species, spatially diverse stands.
2) The Forest Service added to the proposal, as a response to input from Kentucky Heartwood and others, Action 8.D, which would approve thinning of the forest along the margins of a 1-mile section of powerline right-of-way that contains good quality native grassland remnants (read about the Cumberland Barrens here). Combined with ongoing application of prescribed fire, this management would create a gradient, or “ecotone,” between the native grassland remnants restricted to the right-of-way and the closed-canopy forest adjacent to them. This approach, which leverages existing native grassland flora as indicator species and seed source, offers a viable bridge between the Forest Service’s logging mandate and legitimate ecological restoration efforts. The Draft EA states that “If this activity successfully achieves the desired habitat condition, it may be replicated along other ROWs through separate project planning.” We have been working with the Southeastern Grasslands Initiative to promote a similar emphasis at Land Between the Lakes.
3) In response to our earlier comments, the Forest Service has proposed relocating 1 mile of the Sheltowee Trace National Recreation Trail off of Poison Honey Road and in into the forest, while also buffering trails and recreation areas from logging impacts (Action 9.D).
4) The Forest Service has also added Action 9.C to close and rehabilitate up to 23 miles of user-made trails that are negatively impacting the Rockcastle River.
The “Sounds Good But is Actually Underwhelming” Stuff:
The Forest Service has proposed adding 500 acres of “Designated Old-Growth” in the project area. This is good. However, the Forest Service has restricted these old-growth additions to hemlock mixed mesophytic forests below cliffline (where logging is already restricted), and neglected to allocate any upland forest communities to the old-growth management prescription. While the Draft EA points out the project area already includes 830 acres of an existing “Designated Old-Growth” prescription area, that particular area doesn’t actually include any old-growth or near- old-growth forest. Most of the best upland forests meeting, or nearing, operational old-growth definitions are being left out of the Designated Old-Growth management prescription. We wrote extensively about our old-growth concerns in our previous comments on the project in 2018, which can be read here.
Comments on the Pine Creek project are due by Wednesday, September 4th, 2019.
Comments can be submitted through the Forest Service’s web portal here or emailed to: SM.FS.firstname.lastname@example.org
Comments can also be sent via postal mail to:
Jason Nedlo, District Ranger
761 South Laurel Road
London, KY 40744
Official project documents can be found on the Forest Service’s website here.
More information can be found on the Kentucky Heartwood page here.
If you appreciate this information please consider making a donation to Kentucky Heartwood or becoming a member today. Our work can't happen without the support of people like you.
Forest Service and Trump Administration Propose Eliminating Public Disclosure, Input, and Environmental Review: Comments Urgently Needed by August 12, 2019!
The U.S. Forest Service has extended its comment deadline to Aug. 26. Take action at OurForestsOurVoice.org.
The United States Forest Service and Trump administration have put forward a dangerous new proposal to end longstanding requirements that the Forest Service notify the public, allow for public comment, and analyze environmental impacts when approving logging, road building, pipeline construction, and other activities on 193 million acres of national forest lands across the country, including the Daniel Boone National Forest and Land Between the Lakes National Recreation Area in Kentucky. Comments on the proposal are due by August 12, 2019. Directions on how to comment are at the end of this post.
What are they doing?
The proposed rule would amend the agency’s procedures for implementing the National Environmental Policy Act, commonly known as “NEPA.” The proposed changes fundamentally undermine NEPA’s bedrock principles of government transparency, accountability, public participation, and science-based decision-making.
In more technical terms, the Forest Service’s proposal would allow most land management activities to take place under a “Categorical Exclusion” or “CE,” whereby the Forest Service can approve projects without first conducting an Environmental Assessment (EA) or Environmental Impact Statement (EIS). Traditionally, CEs have been used for minor, non-controversial activities like removing hazard trees from campgrounds and roadsides. The proposal also does away with requirements that the Forest Service notify the public and allow for public comment on projects before a decision is made, whether carried out under a CE or with a full Environmental Assessment or Environmental Impact Statement.
The types of projects that the Forest Service wants to apply Categorical Exclusions to include:
In effect, every single logging project, and nearly all utility and road building projects on the Daniel Boone National Forest and at Land Between the Lakes National Recreation Area could be proposed in secret, with no environmental review and no public input. Adding to the audacity and absurdity of the Forest Service’s proposal, the 4,200 acre logging exemption was created by averaging project sizes from across the country, with the 170,000 acre Land Between the Lakes National Recreation Area treated the same as the 17,000,000 acre Tongass National Forest in Alaska.
And these aren’t the only destructive provisions in the proposal.
Why are they doing this?
According to the Forest service, this radical proposal is about “increase(ing) the pace and scale of work accomplished on the ground.” But the bottom line is that it’s about cutting more timber, building more roads, and allowing more pipelines and utility development without the hassle of public participation, oversight, or environmental analysis.
But NEPA isn’t the problem. The main reason that the Forest Service has trouble getting work done – whether it’s maintaining campsites and trails or selling timber – is that they are severely underfunded by Congress and woefully under-staffed which shockingly high turnover. Over the last 10 years, the Daniel Boone National Forest has had four Forest Supervisors and eleven District Rangers in charge of the four Ranger Districts. Forestry and wildlife personnel – the people that actually plan most land management projects – are often temporary fixtures, coming and going from other national forests and agencies from all over the country. It’s become rare to have consistent Forest Service personnel throughout the development of even a single project on the Daniel Boone National Forest.
Why does this matter?
Public lands belong to the public, and the Forest Service can make some really bad decisions. Whether you care about hiking trails or rare plants, old-growth or clear streams, your voice matters.
Without the currently mandated system of public participation and environmental analysis we never would have identified and saved the forest above Climax Spring and old-growth in Little Egypt from logging in the Crooked Creek project, or stopped thousands of acres of deeply unpopular logging in Land Between the Lakes in the Pisgah Bay project, or saved old-growth “Core Areas” in Land Between the Lakes from getting logged in the Birmingham Ferry Salvage project, gotten hundreds of acres of logging dropped in the Greenwood project (saving the trailhead to the Beaver Creek Wilderness and Three Forks of Beaver Creek Overlook), stopped road building in the Beaver Creek project near Cave Run Lake, or identified old-growth that the Forest Service wants to log in the South Redbird project…the list goes on.
What can you do?
Send in your comments!
The Forest Service is accepting comments on their proposal through August 12th, 2019. Although you can submit comments directly through the Forest Service’s website here, we recommend using the web portal set up by our friends at the Southern Environmental Law Center at OurForestsOurVoice.org. This web portal will assist you in submitting unique comments, and help us track the number of comments getting submitted. There have been indications that the federal government has been “losing” comments submitted through federal portals and we want to make sure your voice is heard.
Spread the word!
We need help getting the word out. Our social media feeds and inboxes are all packed these days, and we’re not seeing much about this from many of the big national organizations that have a big reach. By helping to amplify this message you can make a real difference.
Call your members of Congress!
While this proposal is coming from the Trump administration and U.S. Forest Service, make sure your members of Congress know that you strongly oppose the Forest Service taking away public participation and oversight of national forest management. Public opposition has stopped similar proposals in the U.S. House and Senate in recent years.
For more details and a great explainer on why this matters so much, head on over to our friends at Tennessee Heartwood. They’ve done a fantastic job going deep on why NEPA and public participation are critical for protecting our public lands.
You can also read these articles from The Hill and NPR.
Official documents for the Forest Service's proposal can be found on the Forest Service website here.
And if you find this useful, please consider supporting our work by donating or joining Kentucky Heartwood here.
Please note that commenting on this blog post does not send your comment to the Forest Service.
To comment, we recommend using the web portal set up by our friends at the Southern Environmental Law Center at OurForestsOurVoice.org.
This web portal will assist you in submitting unique comments, and help us track the number of comments getting submitted. There have been indications that the federal government has been “losing” comments submitted through federal portals and we want to make sure your voice is heard.
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.
A summary of our main concerns:
What we do support:
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.
The Forest Service has granted an extension for submitting comments on the proposed Forest Plan Amendment. The new deadline is Monday, April 15th at midnight. Several important documents and reports that are incorporated by reference in to the Draft Environmental Assessment had not been made available to the public until recently after requests were made. The extension was granted by Supervisor Olsen to allow the public more time to send comments now that those documents are available on the Daniel Boone National Forest website.
Get more information, links to official documents, and directions for submitting comments on our website here.
Forest Service proposes to weaken protections for endangered bats to increase logging on Daniel Boone National Forest. Comments due by April 8th.
The U.S. Forest Service is proposing to reduce protections for endangered bats in an effort to increase logging on the Daniel Boone National Forest. Comments on the Draft Environmental Assessment (Draft EA) are due by Monday, April 8th. A public meeting is being held by the Forest Service in Berea on Tuesday, March 26th at 4:30 pm. Directions on how to submit comments are at the end of this alert.
The Forest Service is proposing to amend the management plan (Forest Plan) for the Daniel Boone National Forest. The proposed amendments would weaken protections for federally-endangered Indiana bats (Myotis sodalis) and federally-threatened northern long-eared bats (Myotis septentrionalis). The Forest Plan currently includes binding standards that restrict logging in some areas during certain times of the year to reduce risk of harming endangered bats. These restrictions are particularly important in protecting maternity colonies during the especially vulnerable period when young are nonvolant (cannot fly). The restrictions have also contributed to the Forest Service’s inability to log much more than about 1,000 acres per year on the Daniel Boone since the Forest Plan was adopted in 2004. But they want that to change.
The agency, however, is not being honest about why these changes are being proposed. In the Draft Environmental Assessment, the Forest Service states that lifting logging restrictions is needed to shift logging to drier parts of the year, and therefore better limit sedimentation in streams which could impact aquatic species listed under the Endangered Species Act. These species include the Kentucky arrow darter, Cumberland darter, blackside dace, and a wide range of threatened and endangered mussels. That sounds reasonable, until you dig deeper.
In the environmental analysis for each and every timber sale on the Daniel Boone National Forest, the Forest Service states emphatically that the amount of sediment reaching streams from their timber operations is minimal, and will not impact threatened and endangered aquatic species and their habitats. Every. Single. Project. If the Forest Service needs to reduce protections for endangered bats to protect vulnerable aquatic species from logging, does that mean that their logging projects are, in fact, degrading aquatic habitats? If so, will the Forest Service commit to cancelling all active timber sales until the projects can be revised to adequately protect aquatic species? It’s doubtful. But the agency can’t have it both ways.
So what’s this really about?
The need to increase the “pace and scale” of “restoration” (read: logging) has become an ongoing narrative across the U.S. National Forest system. In recent years, we’ve had to respond to a non-stop barrage of legal and regulatory attempts to roll back public participation and environmental protections on our public lands. From the “Resilient Federal Forests Act” to the Forest Service’s proposed revisions of its NEPA procedures to President Trump’s recent Executive Order on national forests, it’s all about getting more logs out of the forest, and faster.
Nowhere in the Draft EA does the Forest Service actually say that they intend to increase the amount of the forest getting cut. But it’s clear that increasing logging is the reason behind this proposal. The Draft EA states only that “The Proposed action will not increase vegetation management volume extracted identified in the 2004 Forest Plan.” What’s left out is that meeting the established Forest Plan timber harvest goals – which were widely opposed during the Forest Plan revision process – would mean nearly tripling of the amount of timber cut on the Daniel Boone National Forest.
Periodically revising management plans based on updated science and evolving conservation strategies can be a responsible thing to do. Amending the Forest Plan with respect to endangered bats or other at-risk species is not necessarily bad. But even the U.S. Fish and Wildlife Service has been critical of the proposal, stating in their early comments that “If the action is carried out as proposed, an increase in adverse effects on federally-listed species is anticipated.” This proposed Plan Amendment is not coming out of concern for protecting endangered bats, or protecting our most imperiled aquatic species. It’s coming from a desire to see more timber cut on more acres, and we think that’s a problem. If you share these concerns, please submit a comment to the Forest Service letting them know.
A public meeting hosted by the Forest Service is scheduled for Tuesday, March 26th from 4:30-6:30 pm at the Boone Tavern Event Center, 100 Main Street, Berea, KY 40404.
Comments need to be submitted to the Forest Service by Monday, April 8th, 2019.
Email comments to: email@example.com
Be sure to include “Plan Amendment” in the subject line of your email.
Comments can also be sent via postal mail to:
1700 Bypass Road
Winchester, Kentucky 40391
Documents for the project can be found on the Forest Service’s website here.
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.
Note: Make sure when you copy/paste that there is no space or period at the end of the email address. 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 a confirmation email, that means they did not get your message.
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.
Sen. Rand Paul introduces legislation to sell off Daniel Boone National Forest land. Calls urgently needed!
UPDATE #2: The Senate voted 92-8 in favor of S. 47 without Sen. Rand Paul's amendments. Thank you to everyone who took time to call our legislators in support of our Daniel Boone National Forest.
UPDATE #1: T he Senate will be addressing the Paul amendment, along with other amendments, TODAY (Feb. 12) at 4:30 pm and then move to a roll call vote on final passage. Keep those calls coming!
U.S. Senator Rand Paul has introduced two amendments to the Senate Natural Resources Management Act (S.47) that could devastate the southern half of the Daniel Boone National Forest in Kentucky. Calls to legislators are urgently needed.
One of Senator Paul’s amendments (S.Amdt.141) would require the U.S. Forest Service to sell an undisclosed acreage of the Daniel Boone National Forest in McCreary and Pulaski Counties. The language directs the Secretary of Agriculture (currently Trump appointee Sonny Purdue) to sell national forest land “along” U.S. 27 from Burnside to the Tennessee border, liquidating a highly biodiverse section of Kentucky’s national forest lands. The bill leaves the acreage and locations solely to the discretion of the Secretary of Agriculture, with no limitations or public input. The sale could be anywhere from 1 acre to 150,000 acres, and could potentially affect Beaver Creek Wilderness, the Sheltowee Trace National Recreation Trail, Barren Fork, and habitat for a large number of state and federally listed endangered species.
While this particular region includes a great deal of public land, there is ample private land in the Burnside, Pine Knot, and Stearns/Whitley City areas – and in between – that are open and situated for development. In fact, less than a third of the section of U.S. 27 identified for land sales passes through or abuts national forest land (see map at the end of this post). And there are plenty of locations with closed businesses and deteriorating structures in the area that are in need of redevelopment.
The other amendment introduced by Senator Paul (S.Amdt.140) would compel the Forest Service to allow the development of roads and utility right of ways through nearly the entire southern half of the Daniel Boone National Forest to reach “the waterways feeding into Lake Cumberland through the Daniel Boone National Forest in Rockcastle County, Pulaski County, Laurel County, Wayne County, McCreary County, and Whitley County, Kentucky, for the purpose of installing docks, boat slips, and marinas.” This covers the entire watersheds of the Rockcastle, Cumberland, and Big South Fork rivers. These waterways, and the forests that surround them, provide habitat for a wide range of federally and state endangered species and include some of the most cherished and popular recreational areas in the forest.
There are already several shuttered docks and marinas on Lake Cumberland, private areas with existing access, and current business owners struggling to sustain and grow their operations. To the extent that roads or other access are needed to reach any specific locations, the Forest Service can already allow access after following the requirements of the National Environmental Policy Act, Endangered Species Act, and other laws and regulations - including allowing for public input into the process. Senator Paul’s amendment would take away authority and discretion from the U.S. Forest Service and completely cuts out public input.
National forest land is not an impediment to economic development in the southern part of the Daniel Boone, however Senator Paul chooses to spin the issue. Our public land is an asset. Whether Senator Paul is trying to curry favors with donors, or just exercise his ideological opposition the very idea of public lands, it doesn’t matter. He’s wrong, and this awful sell-off of our Daniel Boone National Forest needs to be vigorously opposed.
Calls to legislators are urgently needed.
In addition to Senators Paul and McConnell, please take the time to call other members of the Senate Energy and Natural Resources Committee and ask them to oppose Senator Paul’s Amendments 140 and 141 to Senate Bill 47, the Natural Resources Management Act. Let them know that Rand Paul is not representing the interests of the majority of Kentuckians.
Recommended legislators to call:
You can see the full list for the Senate Environment and Natural Resources Committee here.