Kentucky Heartwood - Projects and Letters

Fred K. Noack, District Ranger
Steans Ranger District
3320 Hwy 27N
Whitley City, KY 42653

Dear Mr. Noack,
We ask that you reconsider your decision to categorically exclude the Lone Pine Habitat Management proposal, as extraordinary circumstances exist. We believe that the human environment may be significantly impacted by the proposal. Such a concern necessitates an EA. We are specifically concerned with environmental impacts to air, soil and water. We are concerned with the cumulative effects of this proposal with preexisting and similar projects within the Stearns District. Moreover, the decision to reestablish pine (193 short leaf pines per acre), forecasts the future application of herbicides, and must be considered in this proposal. The possibility of new pine beetle infestations is another concern.
There is substantial controversy and healthy debate within the environmental, scientific and local communities as to whether fire is a responsible, effective, or necessary management tool within the Daniel Boone National Forest. Lacking necessary data, we all recognize that fire management is an experiment in Kentucky, and the effects may not bring about expected results. How can we categorically exclude experiments that may compromise the forest and significantly impact our human and non-human communities?
The Proposal lacks the necessary information that would facilitate informed public comment. This proposal lacks site-specific information. After reading the proposal, we are uncertain whether cultural, archeological or historical sites exist within the project area. The same holds true with regard to potentially affected species. We are provided with a list of numbers, but no specifics. It’s unclear as to whether appropriate site-specific scoping and scientific studies have been conducted at all. For instance, we don’t know how many Indiana Bat roost trees have been discovered. This is especially problematic since undesignated roost trees may be ignored and destroyed after project implementation. Based on this proposal, it’s unclear whether project managers have taken a good hard look at the project area. Please provide scoping details and findings.
The Forest Plan is illegal; this proposal can not be justified by citing an illegal “plan.” Please see KY Heartwood’s appeal of the Forest Plan.

The proposal lacks a reasonable purpose or need. Reforestation work is unnecessary, as natural processes are already underway. The myopic decision to create pine plantations in the Stearns District resulted in foreseeable devastation in the form of the native pine beetle. Why not allow the natural regeneration, which is currently under way, to hold sway. Why would you state that the hardwoods, which naturally follow the pines, are “interfering?” Please elaborate.
By burning, logging and thinning, you increase sunlight on the forest floor and allow invasives to take hold in the forest. If you plan to address this predictable event with herbicide application, please express this now.
The creation of new roads will increase destructive ORV use, fragment the forest and endanger populations that require intact and unsegmented forests. Cowbirds will benefit from this project, interior species, such as the cerulean warbler, will not.
Beyond creating ORV trails, what recreation opportunities do you imagine will result in the burning and logging of this forest land?
Are funding shortfalls anticipated? If so, how will the forest service pay for this project?

On February 19, 2007 a public hearing was held at the Fiscal Court in Whitley City (McCreary County) to address concerns related to prescribed burn projects. While residents voiced concerns related to human and forest health, those in attendance felt powerless to affect change, since their concerns would “not be taken seriously” by Forest Service officials. The noticeable absence of F.S. officials at this meeting (despite notification of the hearing) was testament to their concerns. “Why aren’t they here?” “Why don’t they respond to my letters?”
Questions like these do not speak well of a fluid line of communication that would facilitate environmental Justice. The fact remains that many people in McCreary County feel “put upon” by the Forest Service. They feel that the interests and well being of the community are not top F.S. priorities. It is a mystery how officials in the Stearns District expect to be taken seriously when they speak of Executive Order 12898.
Approximately 60% of McCreary County is managed by the Forest Service. This management should be beneficial. Properly managed, the forest should act as a filtering safeguard for the human population. Yet, the incidence of cancer in McCreary County is among the highest in the state. Some McCreary Countians point to previous and continuing herbicide application as a significant factor. Concerns as to whether herbicide residues might be released in burn projects remains an unknown. Since no efforts have been made to study this reasonable concern, it cannot be easily dismissed. The public wants their legitimate concerns addressed. They need to be taken seriously. The mere fact that such a significant amount of land in McCreary County is under F.S. “management,” necessitates that the F.S. accept responsibility for the health of the community. Of course, there are other factors that may contribute to cancer, but for the F.S. to dismiss any responsibility is unconscionable. To what degree can the Forest service improve the quality of air and water in McCreary County? Simply following the Forest Plan and or BMP’s is not enough. In a community that’s already suffering from chronic disease, there are no “acceptable” impairments to water, soil and air. We, as a community (this includes the F.S.) should be taking whatever steps necessary to mitigate existing health concerns. Environmental remediation for the benefit of human communities should be the focused goal. The Stearns District is currently focused on burn and logging projects. Even if such projects increase biodiversity in time—a theory which is by no means a site specific fact—is it really appropriate to be releasing carbon, particulates, and potential toxins into the atmosphere of an already suffering community? This conversation needs to take place; however, it can not happen behind closed doors, without the input of McCreary county residents. Hopefully, the F.S. is cognizant of the fact that those most impacted by environmental justice are the least likely to pour over SOPA. What efforts have been made to build a responsible relationship and open the lines of communication with the citizens of McCreary County? Sadly, we already know the answer to this question. The Stearns District has lost the trust and respect of citizens living in McCreary County. Surely this will be evidenced by the lack of input you are likely to receive for this proposal. Why should people take the time to review and comment on this proposal when officials “have already made up their minds”? If the Forest Service is serious about Environmental Justice, they will cease all burning projects in McCreary county and work to establish trust—perhaps for the first time. It is our sincerely recommendation that the Stearns District focus its time and resources toward addressing environmental justice.
Has the F.S. Considered the impacts of this project on climate change? Perhaps you should.

Respectfully yours,

Paul Lovelace
Kentucky Heartwood
PO Box 329
Morehead, KY 40351