Wild places sustain and define us; we, in turn, must protect them.
5,000 acre logging project proposed north of Morehead along the Sheltowee Trace National Recreation Trail.
The Daniel Boone National Forest has proposed a 5,000 acre logging project just north of Morehead along the Sheltowee Trace National Recreation Trail.
While this project is problematic on many levels, most concerning is that the Forest Service plans to approve the Ruffed Grouse Habitat Enhancement project with no environmental analysis and without disclosing exactly where or how much logging is planned. The National Environmental Policy Act (NEPA) requires the Forest Service to assess the potential impacts of logging projects, which includes soliciting public input and consideration of alternatives that could limit environmental impacts. Instead, the Forest Service has decided to get creative to avoid any troublesome analysis or disclosure to fast-track a major logging project in an area that was already heavily logged from 2008 to 2017 in response to a 2003 ice storm.
The Forest Service plans to combine a “categorical exclusion,” which allows them to avoid completing an Environmental Assessment, with a novel management approach called “condition-based management” where the agency leaves decisions about where and how much logging will occur until AFTER the project is approved. This novel approach sidesteps important checkpoints and essentially gives the Forest Service and the Ruffed Grouse Society (its stewardship partner) the greenlight to log wherever, whenever, and how much they want in the 5,000-acre project area.
What’s worse? They are using the decline of a single “game” species, the ruffed grouse, to justify this open-ended commercial logging project. The Forest Service argues that the young forests created by natural disturbance followed by a decade of logging have provided insufficient young forest habitat, with the only course of action being to convert even more of the area’s dwindling mature forests into cut-over young forests. No mention is made of how West Nile Virus has contributed to cyclic population crashes for more than 20 years.
We know you are smart enough to see through the PR spin. Read between the lines and see this for what it really is – a way to get more high-value white oak out of our forests to feed the region’s stave mills.
A public comment period from July 28th to August 28th turned 75 comments from the public with the majority of comments opposing the project because of the lack of environmental assessment which is a direct violation of NEPA. To read all of the submitted comments, click here.
Our concerns and what we asked the Forest Service to do...
1. Issue: Risks to Sheltowee Trace National Recreation Trail – The Forest Service intends to complete commercial logging along the Sheltowee Trace on Big Perry Road, but they haven’t shared details about how this will impact the trail.
2. Issue: This same area was logged in response to the 2003 ice storm. The Forest Service logged thousands of acres in the northern Cumberland District through 2019 to remove trees damaged by ice in 2003. The areas they logged aren’t coming back as oak and are instead converting to maple and poplar stands. While this project proposes managing cut forests where oak regeneration failed, it’s likely that the continued emphasis on shelterwood and seed-tree cutting will similarly result in more loss of oaks rather than oak regeneration as the Forest Service claims.
3. Issue: The Forest Service is trying to sidestep laws intended to protect our forests. A single, 30-day comment period based on a proposal with no site-specific or detailed information is not appropriate for a project of this size and in an area with important recreational uses.
4. Issue: Interior Forest at risk. The proposed logging area includes the majority of the largest block of contiguous national forest north of Cave Run Lake, in an area of otherwise highly fragmented forests. Large blocks of interior forest provide important habitat for a number of species, like the Cerulean Warbler, Kentucky Warbler, and Wood Thrush, listed as “Birds of Conservation Concern by the U.S. Fish and Wildlife Service. Interior forests are also critically important for federally endangered bat species including northern long-eared and Indiana bats.
5. Issue: Mature and old growth forests at risk. Mature and old-growth forests are important for a wide variety of species, keep massive amounts of carbon out of the atmosphere, and are highly valued by a majority of public lands users. But the Forest Service continues to advance a false narrative that the greatest threat facing our forests is that they are too old and need to be “regenerated” by logging most of the timber. Out of the public eye, the Forest Service is planning projects and shaping policy with hunting groups like the Ruffed Grouse Society, which are becoming some of the biggest purchasers of federal timber through various “stewardship agreements.” Under this model, stewardship and habitat work is paid for by selling timber or conveying the timber rights to groups like the Ruffed Grouse Society. To make timber sales attractive to purchasers the Forest Service has pivoted away from “thinning” and instead sells most of the trees in harvest areas – especially high-value white oak destined for the stave market. This often means sacrificing some of our best mature and old-growth forests. But young forest habitats, which are important for many declining species, can be managed for through the restoration of degraded clearcuts (which are abundant in the area), management of edge habitats around powerline corridors and wildlife openings, small group and patch cuts, and other methods. Along with continued logging on private lands, we do not have to sacrifice mature and old-growth forests on our public lands to create habitat for grouse.
6. Issue: The Forest Service is not looking at landscape-level impacts. The Forest Service is ignoring the effects of natural disturbance and the extensive logging happening on private lands. National Forest lands in the project area exist in a wider context of fragmented ownership, heavily cut private forests, and other impacts and disturbances. National Forest lands represent a minority of the landscape and should be protected for habitat needs and resource values that cannot be met otherwise.
Please sign up for our e-newsletter to keep up to date on this project as we have more information. Note: We will not spam you or sell your info. Our e-newsletter correspondence is how we get notice of public comment periods out to our members and donors. Every voice matters when it comes to public participation in these logging projects.
Read our formal organizational objection below.
On July 31st, Kentucky Heartwood filed an objection to a Forest Service decision to implement a new road building project. The project, known as the “Greenwood NFSR 5104 Construction Project” is intended to make it easier for the Forest Service to log an area of the forest near Brush Creek Road in Pulaski and McCreary counties.
And these issues are just the tip of the iceberg. A more detailed analysis can be found by reading our formal objection below.
Do you want to hold our government accountable to its citizens? Help us stop the chop! If you value the knowledge and resources that we put into reviewing these projects, then please consider showing your support by making a donation today!
FOR THE FOREST!
Lauren Kallmeyer, Executive Director
Kentucky Heartwood Formal Notice of Objection
US Forest Service's Final Supplemental Environmental Assessment of the Greenwood "Vegetation Management" project available to read below.
How much old-growth is there in the Daniel Boone National Forest? This is actually a pretty tough question to answer. The short answer is “not much.” But before we can dig in and try to answer that first question, we need to ask another: What is old-growth?
The term “old-growth,” or “old-growth forest,” is often used as a broad, catchall label describing any forest with big or old trees. It can also be a highly technical designation with specific attributes and near-countless variations. In the broadest sense, old-growth forests exhibit structural characteristics that require long periods of without major, stand-replacing disturbance. Usually, this means a forest with trees that are large and old (relative to the site and species present), and with a complex structure. The specific structural characteristics, and the time required for them to develop, can vary considerably for different forest types and regions. For example, old-growth trees on dry ridge sites can be quite small, while trees of similar age just downslope on sites with deeper soils and more water availability can be massive.
For the purposes of this article, we’re going to narrow our scope to the deciduous forests of eastern North America, and more specifically to those forest communities found in the Daniel Boone National Forest.
Forest Structure and Disturbance
The structure of a forest at any given point in time is a result of the dynamic and ongoing interplay between the growth of trees and the death of trees. The death of trees is an integral part of ecosystem functioning. Trees are killed through a variety of natural disturbances, including wind, ice, fire, pathogens, beavers, and other processes. And the patterns by which trees die can vary dramatically over space and time.
Tree damage from ice storms, for example, can result in a lengthy, uneven decline of trees scattered across the landscape, with particular landscape positions and tree species (like maples and tulip poplar) being more susceptible to ice damage. A line of thunderstorms might result in individual and small groups of trees being blown down across a large area, while a microburst from that same storm system could level all of the trees in a one- or two-acre patch. A wildfire during drought conditions may burn hot, leaving only the most fire-tolerant trees like shortleaf and pitch pine alive. And yet a lower-intensity fire will mostly damage thin-barked trees, like American beech and red maple, leaving them to decline slowly over time.
The predominant types of natural disturbance that shape the forests of eastern Kentucky are of small to intermediate scale and intensity and occur with relatively high frequency. “Stand replacing” natural disturbance events (or “regeneration” events), which kill most trees at larger scales (10s to 100s of acres), like tornados and derechos, are highly impactful but very uncommon. The death of trees can result in immediate changes in a forest’s structure but also cause long-term changes in forest processes and species composition, known as “ecological legacies,” that play out over decades or centuries.
While symbiotic relationships are increasingly recognized as important in forest ecosystems, competition for sunlight remains a predominant factor in forests’ structure and function. And when trees die, surviving neighbors and understory trees often benefit from the increased sunlight and available soil moisture which, in turn, allows them to increase in vigor and growth.
When a canopy gap created by a dead tree or trees is small, adjacent canopy trees will fill in the gap through lateral branch growth. When a gap is so large that the surrounding canopy trees can’t close the gap, the result is a new patch of young forest and dense vegetation (also called early seral habitat) within the older forest matrix.
Models of Forest Development
Classical models of forest development describe four structural stages beginning with a stand-replacing disturbance. The “stand initiation” stage, lasting about 10 years, is characterized by brushy, dense vegetation. The forest then enters the “stem exclusion” stage, with large numbers of densely packed trees and an even-height (codominant) canopy. Competition among the densely growing trees causes some trees to die. As the total number of trees decreases, the size (and volume) of living trees increases.
Somewhere around 60 to 80 years after stand initiation (the threshold is debatable), forests transition into the “stand reinitiation” or “demographic transition” stage. This is the predominant structural stage of most “mature” secondary forests in the Daniel Boone. During this stage trees can be tall, but the canopy is still mostly in a “codominant” arrangement where the upper canopies are all about the same height with a limited number of small gaps allowing light through an otherwise closed-canopy. At this point younger trees may start to show up in the understory.
By around 120 to 150 years, the combination of tree growth and the death of individual and small groups of trees leads to the major structural changes associated with the “old-growth” or “old multi-age” stage of forest development. Some trees have grown very large, with dominant canopies positioned above the prevailing codominant canopy. Large canopy gaps have allowed for the development of small patches of younger trees of various ages. The forest has more large snags, den trees, and down wood. Overall, the forest is much more structurally complex than younger and mature forests.
And Here's Where It Gets Really Complicated...
Small and intermediate scale natural disturbances help to drive old-growth forest structure, while disturbances at larger scales and intensities can act as stand-initiating events that “reset” a forest. But even severe natural disturbances usually leave some trees standing. Tree ring data from old-growth forests reveal patterns of both small-scale (asynchronous) disturbances and larger (synchronous) disturbance events. In the latter case, enough older trees survive so that the forest is still considered “old-growth,” but sufficient canopy was removed to allow for the establishment of young trees (a new “age class”) scattered across the site. Drawing the line between intermediate disturbance and a stand-replacing disturbance, and the effects on old-growth status, isn’t always clear.
But wait! It can get even more complicated! Over centuries, a forest may be subject to a variety of disturbance events with differing effects, at different times, and at different scales. The result can be very complex legacies that defy the simpler models of forest development, and which can only be teased out through detailed study and examination of tree ring patterns and structural data. For practical reasons, that level of investigation has been relegated to just a handful of places. But the information gleaned can help us make better informed assessments based on the data and observations that we do have.
Can We Make This Simple, Please?
A forest can be considered old-growth – from an ecological perspective – where a meaningful number of trees meet a particular age threshold and when the forest exhibits some of the structural characteristics discussed above. The specific numbers depend on the type of forest community and can be debated.
The Forest Plan for the Daniel Boone National Forest incorporates the Forest Service’s 1997 “Guidance for Conserving and Restoring Old-Growth Forest Communities on National Forests in the Southern Region.” The Guidance does a pretty good job of simplifying old-growth definitional criteria for a wide range of forest types found in the southeast and Kentucky. Those criteria start with a minimum age of the oldest age class, and then follow up with a few other criteria (tree size, number of trees, and extent of human modifications). The predominant forest types on the Daniel Boone are considered potential old-growth if the “oldest age class” is over 130 years old, though depending on forest type that threshold can range from 100 to 140 years.
The age thresholds in the Forest Service’s Guidance are reasonable approximations of when forests develop old-growth characteristics and leave room for both “primary” and “secondary” old-growth. Primary old-growth is old-growth forest that has had no (or minimal) human-caused disturbance (like logging), while secondary old-growth is forest that was mostly logged but has had enough time to recover its old-growth characteristics. There is very little primary old-growth in the Daniel Boone, but a large amount of mature forest is poised to transition into a secondary old-growth condition. Some of the more interesting sites are essentially secondary old-growth forests, but where a modest number of primary old-growth trees survived and contribute to both ecology and aesthetics.
So How Much Old-Growth Is There in The Daniel Boone National Forest?
The Forest Service divides the Daniel Boone National Forest into over 27,000 inventoried “stands” of about 20 to 70 acres and assigns a “stand age” to most of these units. Unfortunately, the Forest Service’s age data are highly unreliable for older forests, with notable cases of important old-growth being misclassified as younger forest. Still, these data show about 46,000 acres, or 6.5%, of the Daniel Boone being over 130 years and potentially being old-growth. Only 967 acres are inventoried as being over 200 years old, representing just 0.1% of the Daniel Boone. A lot of this older forest is eastern hemlock forest, which is in sharp decline due to the invasive hemlock woolly adelgid.
Another approach to estimating the amount of old-growth in the Daniel Boone was recently conducted by the U.S. Departments of Agriculture and Interior. Called “the first-ever initial inventory” of mature and old-growth (MOG) forests on lands administered by the U.S. Forest Service and Bureau of Land Management (BLM), this analysis was conducted in response to President Biden’s 2022 Executive Order on Strengthening the Nation’s Forests, Communities, and Local Economies (E.O. 14072).
The report found that the Daniel Boone has a “low” amount of old-growth and “intermediate” amount of mature forest. A navigable map displaying data from the MOG inventory can be found online. However, it’s important to be clear about what this inventory actually tells us.
The inventory is based on data collected through the U.S. Forest Service’s Forest Inventory and Analysis (FIA) program. Under that program, all forested areas in the U.S. (public and private) are divided into 6,000-acre hexagons, each with a single, permanently established FIA plot. These plots are remeasured every 5-10 years, depending on what region they are in. The FIA data provide a wealth of information on regional and continental-scale forest trends. However, the data are very coarse and therefore limited – even useless – for local-scale analyses.
For the MOG inventory, various measurements captured in the FIA data were associated with “old-growth” and “mature” forest conditions. Plots were then aggregated across 250,000-acre “firesheds” to represent the amount of mature and old-growth forests at a scale with reasonable statistical reliability. The data tell us something about the amount of old-growth on the Daniel Boone, but not very much.
An independent study by Barnett and others, published in 2023, used a more compelling methodology to assess the amount of mature and old-growth forests in North America, but unfortunately does not break out Kentucky forests or the Daniel Boone. However, for the Oak/hickory forest type region (which covers most of Kentucky, Tennessee, parts of West Virginia, and the Missouri and Arkansas Ozarks), the authors estimated that only 0.62% of the forest was old-growth, with 44.88% of forest being “Mature,” 19.99% “Young,” and 34.51% “Early seral.”
Where to Find Old-Growth in the Daniel Boone National Forest
Seeing old-growth is awesome. Small patches of primary old-growth are scattered across the Daniel Boone. But a lot of our best old-growth is difficult to access or in sensitive areas requiring some level of conservatism in sharing information.
Most of our primary old-growth falls into two categories. The first consists of productive forests nestled below clifflines, especially in narrow ravines. These are usually hemlock and mixed mesophytic forests. Eastern hemlock, tulip poplar, white oak, yellow buckeye, pignut hickory, and cucumber magnolia are some of the more common tree species, but these are highly diverse forests. Trees in these locations can get very large, but were likely spared from logging when the costs of accessing the timber outweighed their economic return.
The most notable of these sites are Rock Creek Research Natural Area and Tight Hollow proposed Research Natural Area. Rock Creek has been the subject of several studies, including a botanical survey and an examination of old-growth characteristics using tree ring and other data. Little research has been carried out in Tight Hollow, largely due to access issues. Permitted tree coring in Tight Hollow by this author identified trees over 300 years old, including two tulip poplars that are over 400 years old. Other pockets of this old-growth type are scattered throughout the Daniel Boone, especially in places like Beaver Creek and Clifty Wilderness Areas, Cane Creek, Angel Hollow, and other places with abundant and rugged cliffline.
The other main category of primary old-growth is represented by dry forests on ridges. Trees in these forests rarely get large and are typically gnarly and of short stature – characteristics which probably kept them from getting cut. Chestnut oak, white oak, black gum, and shortleaf and pitch pines tend to be the oldest trees (reaching over 300 years), though it’s not unusual to find old hickories and tulip poplar. Without a discerning eye it can be easy to miss these forests. Kentucky Heartwood has documented outstanding forests of this type in the South Red Bird project area, most notably in the Elisha Creek watershed. Kentucky Heartwood is suing the Forest Service over their decision to log some of these locations, in part due to the agency’s mischaracterization of them as younger forests.
Over time we will lose these higher quality and primary old-growth sites. Whether it’s hemlock woolly adelgid or federal timber sales, or any of the natural disturbances discussed above, these old-growth forests will not last forever. However, there is a significant amount of mature forest across the Daniel Boone that is poised to become old-growth over the coming decades. These future old-growth forests will, in some ways, be different from the old-growth of the past. But if preserved and managed with care, they present a tangible opportunity to recover some of the wild grandeur of Kentucky historic old-growth forests.
- Jim Scheff, Ecologist
Join the local community in voicing opposition to Forest Service's ten thousand acre Jellico Mountain logging project.
INTERACTIVE MAP OF JELLICO PROJECT
You can navigate this map on a touchscreen by panning with a single finger and changing the view angle and zoom with two fingers. To navigate on a desktop, use the cross icon to pan and the rotating arrow icon to change the view angle.
Map and Legend by staff Ecologist, Jim Scheff.
There is hope! Theresa Martin, a Williamsburg community leader, has organized her neighbors to participate in public feedback to the Forest Service. She encourages participation regardless of viewpoints. What has resulted is countless community members from all walks of life standing up to the Forest Service to protect the mountain they cherish. Over 100 people attended the community-organized town hall meeting and the Forest Service was met with dozens of searing comments strongly opposed to the project.
Locals brought up serious concerns about the project causing landslides and heavy erosion into creeks where community members live. Others were worried the Forest Service's logging would intensify flooding that is already causing the destruction of homes around the National Forest. Others questioned the need for so much logging when they value mature and intact forest. Many folks asked where all the money generated from the logging would be going. District Ranger Tim Reed explained it would be going to the "US Treasury '' which was a roundabout way to say it pays a small fraction of the Forest Service's budget.
The Forest Service said they had never seen such a well attended town hall meeting. Several news outlets covered the town hall meeting making an even bigger platform for public's concerns. This included TV Coverage in Knoxville, and the follow newspaper coverage:
Kentucky Heartwood's own concerns align with the community. We are inspired to see people standing up for their public forests. One of the best ways you can stand up for forests is to submit a public comment to the Forest Service, because they are required to incorporate your feedback into their final plans for the Jellico project area.
Comments are due Monday, December 5th by 11:59pm and we are working toward a goal of 100 comments submitted!
We encourage you to read other publicly submitted comments here or even watch the recent town hall meeting with the Forest Service here.
Whether you live in the area or enjoy recreating in the National Forest, let the Forest Service know how logging will affect you and the things you care about. Be specific. It is as simple as following this link and filling out the online form OR calling the Forest Service at (606) 376-5323 and telling them you want to leave a comment on the Jellico project. Thanks for following along on this exciting journey!
Here are some technical details that may be helpful to include in comments:
The Jellico mountains are steep, and the soils are unstable. This has already caused landslides in the area, including landslides on private lands that have been logged. Community members live downhill of high-risk areas. Keeping the trees in the forest is the best way to hold soil in place and lessen the risk of landslides. In addition to destroying property and roads, landslides can dump erosion into streams. Streams in the Jellicos are home to endangered species such as the Cumberland Darter and Blackside Dace which are protected by federal law.
The Forest Service’s slope data demonstrates the seriousness of this issue. According to the table within the slope data document, the majority of the potential logging sites average 50% slope with some as high as 75%. These steep slopes intersect 2 or 3 coal beds. Coal beds under steep, logged slopes have high landslide risk as trees' roots decay.
Further evidence for landslide risks is provided by USDA soil data, which was created to rate the soils’ suitability for use with timber harvest equipment. The data shows that soils in the proposed harvest area are low strength and almost the entire Jellico region is rated as the poorest suitability level for using timber harvest equipment.
Mature forest helps soak up water. Catastrophic flooding occurred in the Jellicos as recently as July 30th, 2022. If the mountains are made bare with clearcuts, more water will find its way into the valleys where people live worsening flash flooding.
The proposed logging includes hundreds of acres of forest that could qualify as old-growth (over 120 years old). None of this older forest is protected in the area’s “Designated Old Growth” area despite meeting tree size and age requirements according to the Forest Service's own guidance on old growth. According to work done in the area by expert dendrochronologist, Justin Maxwell, tree ages of one stand were found to be even older than the Forest Service estimated, with trees over 200 years old.
Logging mature and old growth forest stands not only creates problems for local community members, but also has negative consequences for the whole nation and even the world. This is because logging releases greenhouse gasses. The Forest Service needs to use the most recent science which shows that logging releases large amounts of greenhouse gasses when considering the environmental impact of this project (source)
Forests in the Jellico area that were logged in the 1990's have become heavily invaded with non-native Tree of Heaven, with some areas having as high as ¾ of the canopy. One of the best ways to control this invasive species is to not log the forest as it thrives on disturbance. Disturbance will also bring in other invasives such as autumn olive, which is already prevalent on private properties in the area.
The image below is from the Stearns Ranger District in the Jellico area. This forest was supposed to be stewarded by the U.S. Forest Service, but after being clearcut this area was all but abandoned and forgotten. These invasive trees are now maturing and dropping seed, only furthering their abundance. If the forest service clearcuts more of this forest, we are sure to see the invasive Tree of Heaven and other invasives dominating the landscape. Clearcuts without stewardship lead to more destruction and herbicide use in the future.
According to U.S. Fish and Wildlife data, the Jellico Mountain area is home to at least 17 endangered species and 12 migratory bird species of concern. One of these endangered species, the Cumberland Darter (Etheostoma susanae) is only found in isolated populations in the upper Cumberland River system of Kentucky and Tennessee, and does not exist anywhere else in the world. In Kentucky, 13 streams in McCreary and Whitley counties, are considered “critical habitat” for this fish, and much of this habitat is in the Jellico project area.
If you have any further questions, feel free to leave a comment on this post or email email@example.com.
Help us reach our goal of 100 public comments by December 5th!
Kentucky Heartwood files lawsuit challenging nearly 3,800 acres of logging in Daniel Boone National Forest
For Immediate Release, September 14, 2022
Contact: Jim Scheff, Kentucky Heartwood Ecologist, (859) 334-0602; firstname.lastname@example.org
Group Challenges Major Timber Project on Kentucky’s Daniel Boone National Forest
Rare Species and Old-growth Forests Take Back Seat to Logging Plans
BEREA, KY – Kentucky Heartwood has filed a lawsuit challenging the U.S. Forest Service’s South Red Bird Wildlife Habitat Enhancement Project on the Daniel Boone National Forest in Leslie and Clay counties. The largest timber project on the Daniel Boone in nearly 20 years would allow commercial logging on over 3,800 acres of public lands, along with the construction of nearly 100 miles of logging roads, herbicide use, and prescribed fire. The Forest Service’s logging plans would remove 80% to 90% of the trees across 2,800 acres and cut nearly one-quarter of all forests over 100 years old. Logging is also planned along approximately 10 miles of Redbird Crest Trail.
You can read the legal complaint at the bottom of this post.
The lawsuit focuses on the Forest Service’s violations of the Endangered Species Act (ESA), the National Environmental Protection Act (NEPA), and the National Forest Management Act (NFMA) pertaining to its use of misleading data to support its logging plans, thus failing to disclose to the public the true environmental impacts of the project.
Among the several issues raised in the lawsuit are how the Forest Service ignored and then downplayed the effects that landslides could have on streams and aquatic species, like the federally-threatened Kentucky arrow darter (Etheostoma spilotum) and endangered snuffbox mussel (Epioblasma spilotum). A large body of evidence, including internal Forest Service documents, show how logging and road building in the Redbird District of the Daniel Boone National Forest has frequently resulted in landslides.
The Kentucky arrow darter is only found in high quality streams in the Upper Kentucky River watershed, making it highly sensitive to landslides and other activities that impact water quality, while the snuffbox is found in the Redbird River in and immediately downstream of the project area and can be seriously impacted by increased sediment in the water.
The agency also used faulty forest inventory methods to claim that there are no old-growth forests in the project area, when in fact the area includes some of the highest quality old-growth in the Daniel Boone National Forest. Kentucky Heartwood has inventoried more than 400 acres of old-growth forests with trees over 200 years-old in the project area, including at least 160 acres of old-growth approved for logging. However, the Forest Service has refused to consider the data submitted by Kentucky Heartwood.
Logging plans could also result in significant harm to endangered bats, including the northern long-eared bat (Myotis septentrionalis) and Indiana bat (Myotis sodalis). Kentucky Heartwood conducted acoustic surveys for bats throughout the project area and found evidence of one or more northern long-eared bat maternity colonies in areas approved for logging. Northern long-eared bats rely on extensive interior and closed-canopy forests. The specific design of the project could result in the removal of maternity roosts and important flight corridors used by the bats.
“Instead of focusing restoration efforts where they’re most needed, the Forest Service is going where the timber is and ignoring significant landslide risks and potential harm to endangered species,” said Jim Scheff, Kentucky Heartwood’s Ecologist.
The project area is also home to the world’s two largest-known Red Hickory trees (Carya ovalis), located by Kentucky Heartwood in an old-growth forest marked for cutting. In another part of the project area where logging has not been approved Kentucky Heartwood identified the world’s oldest documented short leaf pine (Pinus echinata), which dates to 1691.
Kentucky Heartwood actively participated throughout all public opportunities provided by the Forest Service and provided alternatives that would protect old-growth, mature forests, and streams while also supporting young forest and early seral habitat for disturbance-dependent species like ruffed grouse. However, the Forest Service refused to seriously consider these approaches.
“As increasing numbers of people look for outdoor places to experience the beauty of eastern Kentucky’s wildlands, and as the impacts of climate change and habitat loss in the region accelerate, the preservation of mature and old-growth forests on our public lands is all the more urgent. The vast majority of the eastern Kentucky landscape is owned by timber, mining, and oil and gas interests, cut off from the public and managed for investment returns. Our shared national forest lands are different. There are real opportunities to get this right. But the Forest Service needs to take a step back and do the right thing,” said Scheff.
Kentucky Heartwood is represented by Environmental and Animal Defense with support from the Southern Environmental Law Center.
Kentucky Heartwood was founded in 1992, and seeks to protect and restore the integrity, stability, and beauty of Kentucky’s native forests and biotic communities through research, education, advocacy, and community engagement.
On Earth Day President Biden issued an Executive order calling on the Forest Service and Bureau of Land Management to conserve mature and old-growth forests as a climate solution. This was a momentous step toward meaningful protections, but the Forest Service is trying to undermine the executive order by sidestepping its responsibility to put a moratorium on all logging of mature and old-growth forests. Now it’s up to us to ensure that this executive order turns into real and lasting changes in how federal agencies manage older forests.
In response to the President’s Executive Order, the federal agencies have opened an official public comment period to solicit public feedback on how “to define, identify, and complete an inventory of old-growth and mature forests on Federal lands.” It is critical that we demonstrate widespread, overwhelming public support for permanent protections, and we want Kentucky's voice to be loud and strong!
We are working with the Climate Forests Coalition toward the national goal of 100,000 comments submitted by the August 30 deadline. The most important goals of this campaign are to:
Please take action by submitting comments through the Forest Service’s portal.
Comments are more impactful when they are personalized! Please consider personalizing this letter to explain what mature and old-growth forests mean to you.
Thank you for taking the next steps to advance President Biden’s Executive Order on Strengthening the Nation's Forests, Communities, and Local Economies. As you know, protecting our remaining mature and old-growth forests and trees on federal lands represents one of the simplest and most cost-effective climate policies the U.S. can deploy at scale. But time is running short: the climate and biodiversity crises are growing exponentially worse and it is critical that you fulfill the President’s directive to provide lasting protections for these trees.
For the purpose of protecting these climate-critical trees and forests from logging, “mature” should be defined as 80 years and older. By setting logging limits using this definition, federal agencies will establish a safety net that assures minimum protection of the ecological and carbon benefits these older forest elements provide for future generations. These older forests and big trees collectively contain the bulk of the carbon already stored in federal forests and they continue to sequester carbon at high rates far into the future. They also provide, across forest types, vital habitat and biodiversity benefits, and important sources of drinking water for communities. Critically, protecting mature forests and trees today will provide the foundation to recover old-growth ecosystems which have largely been lost to logging across the landscape.
President Biden’s Earth Day Executive Order rightly recognized the critical role mature and old-growth forests play as a climate solution, and the urgent need to confront the threats forests face. If continued logging of these trees is allowed, the very values that let them play a vital role will be eliminated. Losing more of our mature & old-growth trees and forests to logging will only make the climate crisis worse: Scientific research indicates that logging of federal forests is a major source of carbon dioxide emissions to the atmosphere that is at least comparable to, and probably greater than, levels associated with wildfires.
In Kentucky’s Daniel Boone National Forest, there are an estimated 430,000 acres over 80 years old, comprising about 60% of the forest. About 100,000 acres of mature and old-growth forests have been cut since 1980; making up about 15% of the Daniel Boone National Forest. We must preserve what we have left!
Protecting trees in the Daniel Boone National Forest over 80 years old will benefit the many species of conservation concern that depend on the mature and old-growth forests found here, such as:
If the Biden administration is to do all it can — and must — to limit atmospheric carbon levels, and demonstrate international leadership, these protections must be made through binding regulations that will endure in future administrations, much as the Clinton-era Roadless Rule has done. To ensure a rule can be adopted on the necessary urgent time frame, with the opportunity for robust public engagement and environmental review, it is critical for federal agencies to initiate a rule-making process as soon as possible that would prohibit logging in mature and old-growth forests.
In summary, I urge the US Department of Agriculture and US Department of Interior to work together to soon initiate a rulemaking based on a definition of mature forests and trees as 80 years and older, to permanently end the avoidable loss of their critically important carbon, water, and wildlife values to logging.
Map of estimated tree ages in the Daniel Boone National Forest
Click on the arrows in the upper left corner to display the legend.
Forest Service lied about wildfire to approve logging significant conservation site in the Daniel Boone National Forest
Kentucky Heartwood has uncovered that the U.S. Forest Service lied about the location and impacts of a 2016 wildfire to justify logging 170 acres of unaffected forest in Long Hollow, an area of the Daniel Boone National Forest in Leslie County. The logging in Long Hollow is part of the roughly 4,000 acres of logging approved in the Daniel Boone National Forest as part of the South Red Bird Wildlife Enhancement Project.
In the Environmental Assessment for the project, the Forest Service states that “More than 600 acres of forest in the South Red Bird IRMA were badly damaged from wildfire in 2016 and need to be salvaged to prevent insect invasion and disease,” including Long Hollow. The agency added that “The proposed salvage treatment would remove these fire-damaged trees, which are merchantable for about 5 years after the fire, after which their value declines rapidly. A healthy unburned forest of fire-resilient species is needed to regenerate the damaged stand.”
The Forest Service included pictures taken of burned forest adjacent to the Steeltrap surface mine to illustrate the damage. Under the plan approved by the Forest Service, most of the standing trees in the steep and landslide-prone forest will be cut.
The problem is that Long Hollow didn’t burn.
We scouted the area in May, following review of a report from the Office of Kentucky Nature Preserves (OKNP) that described Long Hollow as a significant conservation site. Kentucky Heartwood acquired the report through a Freedom of Information Act (FOIA) request to the Forest Service. The findings of the OKNP report were never included in the Environmental Assessment or other public documents related to the project.
The OKNP report stated that:
“The Steel Trap area (including upper Long Hollow and abutting Jesse Fork) is of significant conservation importance in the project area. The mesic forests within the upper reach of Long Hollow contained the highest density of rare and Conservation Species within the project area including occurrences of butternut, ginseng, American chestnut, Goldie's wood fern, goldenseal, and large-tooth aspen. Additionally, a new population of downy goldenrod was discovered along the disturbed ridgetop that separates Long Hollow from the Steel Trap mining site. According to the Kentucky Plant Atlas project and USDA Plants Database, it is the first time this species has been documented in Leslie County.”
During our survey of Long Hollow we found no evidence recent fire damage. In fact, we found that this north-facing valley consists of predominantly fire-intolerant, mixed-mesophytic species. With the exception of the dry ridges, the forest includes very few oaks or other fire-adapted species. We observed a significant population of Synandra hispidula, also known as Guyandotte Beauty, which is known to be highly sensitive to fire, logging, and other disturbances. The ecological indicators of the site strongly suggest that fire has not been a major factor in shaping the forest community.
Further review of FOIA documents uncovered a Forest Service map showing how the Steeltrap fire didn’t burn Long Hollow. That map was among a variety of documents associated with a private 2019 planning meeting jointly organized by the Forest Service and Rocky Mountain Elk Foundation. That invitation-only meeting was held to explore ways that hunting groups can work together to increase timber harvest in the Daniel Boone National Forest.
While Long Hollow is a relatively small part of an otherwise massive and deeply problematic logging project, the fact that the Forest Service so blatantly lied to the public to justify even more logging in the Redbird District is absolutely shocking. Their actions are dishonest and illegal and provide yet another window into how the Forest Service is rapidly moving to turn the Daniel Boone National Forest over to the timber industry and hunting organizations.
Kentucky Heartwood is continuing our work to stop the South Red Bird project, preparing litigation to protect the endangered species and old-growth forests directly threatened the project. Please consider supporting our efforts to protect these special places and the species that depend on them. You can support our efforts and sign up for emails here.
Kentucky Heartwood files Notice of Intent to Sue the U.S. Forest Service for Violations of the Endangered Species Act in South Redbird
Kentucky Heartwood has been working for a number of years to document our concerns with the logging project known as "South Red Bird," which is located in Clay and Leslie Counties within the Daniel Boone National Forest. We have provided the Forest Service with detailed documentation and data related to our concerns with logging in this area, including:
On April 28, Kentucky Heartwood sent the U.S. Forest Service and U.S. Fish and Wildlife Service (USFWS) a 60-day notice of intent (NOI) to sue over violations of the Endangered Species Act (ESA) in the South Red Bird project in the Daniel Boone National Forest. The NOI is part of our ongoing efforts to protect endangered species and old-growth forests in the Redbird District, and a requirement for litigation under the ESA. The NOI focuses on the agencies’ failure to adequately consider impacts to the Kentucky arrow darter, snuffbox mussel, and Indiana, northern long-eared, and gray bats. The NOI can be found at the end of the post.
Regarding aquatic species and critical habitat, the Forest Service refused to consider the impacts of landslides to the arrow darter and snuffbox, despite our providing overwhelming evidence that landslides were likely to result from the approved logging actions. In addition to our documentation of numerous large landslides in the Group One project (immediately north of the South Red Bird area), we uncovered through the Freedom of Information Act documents that the Forest Service has long known that logging on steep slopes in Redbird frequently results in landslides.
Despite this evidence, Forest Supervisor Scott Ray said during a meeting over our predecisional objection that he considered landslides to be “a non-issue.” Ray argued that an analysis of landslide impacts to imperiled species was unwarranted, as were any changes or limits to the logging proposal that could limit the risk of landslide occurrence.
We also raised issue regarding the analysis and effects to imperiled bat species. Of particular concern are effects to the northern long-eared bat (NLEB). Kentucky Heartwood conducted acoustic surveys in the project area last summer and found evidence of at least two NLEB colonies. The USFWS recently proposed changing the status of the NLEB from “threatened” to “endangered” under the ESA. The specific design of the South Red Bird logging proposal could result in significant effects to the species well beyond those described in the project analysis, including the destruction of occupied maternity roosts and maternity habitat.
Our acoustic surveys also indicated a high probability of Indiana bats in the project area. Further investigation uncovered that the Forest Service may have historical information of a maternity colony in the project area but failed to disclose that information.
Our surveys also indicated gray bat presence at several sites. The Forest Service did not analyze the effects of logging on the gray bat, stating that the project was “outside of the historical range, the species has no documented occurrences, or suitable habitat does not exist.” However, the KY Division of Fish and Wildlife range map for the species includes Clay County, which represents part of the project area.
Submission of the NOI came six weeks after Kentucky Heartwood submitted a 46-page supplemental information letter to the Forest Service with a wide range of new, detailed information and findings relating to the South Red Bird project (letter available at the end of this post). In that letter we insisted that the new findings require a pause to project implementation pending a supplemental analysis.
In addition to the results of our bat surveys and new landslide information, the letter describes our findings of significant old-growth in the project area, with centuries-old forests approved for cutting. Also described in the letter was our documenting of the largest-known Red hickory (Carya ovalis) in existence in a harvest unit.
The Forest Service argued in their analysis of the project that no old-growth existed in the project area, and conservation of old-growth was unneeded. Kentucky Heartwood had a meeting with Redbird District Ranger Bobby Claybrook a month after we sent the letter to discuss our findings and learn the Forest Service’s response. Ranger Claybrook had no comments on any of the information presented in our letter and said that his staff would let him know if they found anything new.
Kentucky Heartwood is working with attorneys from Denver-based Environmental and Animal Defense, with assistance from the Southern Environmental Law Center.
Please consider supporting our efforts by making a financial contribution. Thanks.
What’s going on in Jellico?
Jellico is a part of the Cumberland Mountains on the Kentucky-Tennessee border. Topping out at about 2200 feet, they are more mountainous than the rest of Daniel Boone National Forest. The area provides critical habitat for several threatened and endangered species, including the Cumberland darter (Etheostoma susanae), Blackside dace (Chrosomus cumberlandensis) and Indiana bat ( Myotis sodalis).
Resource extraction has already had a heavy toll on this forest. Nearly 2,700 acres were logged in the 1980s and 1990s. In 2011 the Bureau of Land Management and U.S. Forest Service leased over 3,800 acres for oil and gas development. And legacy impacts from coal mining, along with significant problems with invasive plant species, add to the challenges of protecting and restoring this unique area.
The recent Jellico Virtual Field Trip presented by the Forest Service is part of their Integrated Resource Management Strategy (IRMS) planning process for the Jellico mountains in the southernmost part of the Daniel Boone National Forest. The area that the Forest Service is looking at includes nearly 270 acres of forest that could qualify as secondary old-growth (over 120 years old).. None of this older forest is protected in the area’s “Designated Old Growth” area despite meeting tree size and age requirements.
We know from past experience that these IRMS processes almost always turn into massive logging projects, like South Redbird, Blackwater, and Pine Creek. That’s why Tennesse Heartwood, Tennessee Chapter of the Sierra Club, and Kentucky Heartwood submitted a joint Freedom of Information Act (FOIA) request several months ago to better understand the Forest Service’s plans and inform the public about them. We are happy to have finally received the documents we requested because the Virtual Field Trip does not provide enough information about the Forest Service’s plans. Much of the information discussed below is based on our review of the Freedom of Information Act documents, where we found much more information than the Forest Service has ever shared publicly about their plans for this area of the forest. Much is still in the air though. A lot of the following information is based on which forest stands the Forest Service has been scouting for soil issues associated with logging as revealed by the Freedom of Information Act data. We assume they would not do this unless they were planning on doing commercial logging but the Freedom of Information Act data is not clear on this. Hopefully by being proactive we can prevent them from investing more time and energy into prospecting to log the most problematic forest stands.
There are clearly concerns about soil instability, as evidenced by field notes from Forest Service staff. More of this specific information should have been shared in the virtual field trip but instead it was underplayed with a quick video and generic document. The seriousness of this issue is made clear by the slope data obtained by the Forest Service for forest stands being scouted for logging. According to the table given within the slope data document the majority of the potential logging sites average 50% slope with some as high as 75%. These steep slopes intersect 2 or 3 coal beds. According to the Forest Service's own soil scientist, coal beds under steep logged slopes have high landslide risk as trees' roots decay.
Landslides not only erode precious soils which can leave an area barren for decades to come, but they also damage waterways through sedimentation. This is especially problematic and illegal when streams have threatened and endangered species that are sensitive to sedimentation. Jellico mountain has two such species that are found nowhere else in the world. They are the Cumberland Darter and Blackside Dace, and they are federally protected by the Endangered Species Act. Sadly this has not stopped the Forest Service from logging steep landslide-prone areas in the past.
Figure 1: Coal Beds on Steep Slopes Prone to Landslide into Critical Streams
Wolf Creek - Critical Threatened and Endangered Species Habitat.
Further evidence for this landslide risk is given by U.S.D.A's own publicly available soil data that suggests soils in the proposed harvest area are low strength and therefore not strong enough to support loads. This U.S.D.A. soil data was created to explicitly rate the soils' suitability for use of timber harvest equipment. Almost the entire Jellico mountain region is rated as the poorest suitability level for using timber harvest equipment
Figure 2 and Table 1: Timber Harvest Equipment Suitability.
Red= Poor; Yellow= Moderate
Source USGS Web Soil Survey accessed March 10th 2022
This is how the USDA suggests interpreting "poorly suited":
"Ratings for this interpretation indicate the suitability for use of forestland harvesting equipment. The ratings are based on slope, rock fragments on the surface, plasticity index...
"Moderately suited" indicates that the soil has features that are moderately favorable for the specified management aspect. One or more soil properties are less than desirable, and fair performance can be expected. "Poorly suited" indicates that the soil has one or more properties that are unfavorable for the specified management aspect. Overcoming the unfavorable properties requires special design, extra maintenance, and costly alteration."
Recommendations to Forest Service
Given the risk to federally protected species as well as violating the National Forest Management Act diversity clause (16 U.S.C. 1600 § 6(g)(3)(B)) and soil protections (16 U.S.C. 1600 § 6(g)(3)(E)), logging should not be done on steep slopes with coal beds.
Appalachian Gentian, or Gentiana decora, is a very rare plant found by Kentucky Heartwood within the project area. It is ranked g4 globally which means it is very vulnerable to extinction. It is ranked s3 for Kentucky which means there are less than 100 occurrences of it and therefore vulnerable. It was found in the cliffline of a designated old-growth area which means it does have protection from logging. There were no records of this sensitive species, and it brings up the question of what else might be out there that the Forest Service doesn't know about, especially given what a biological wonder Jellico Mountain is. It is important the Forest Service refers to the "Cooperative inventory of endangered, threatened, sensitive and rare species, Daniel Boone National Forest, Stearns Ranger District" before conducting any logging operations to ensure it maintains viable populations of sensitive plants in accordance with the diversity requirement of the National Forest Management Act. This is especially important since the areas of Jellico Mountain outside of the National Forest boundary are heavily disturbed due to aggressive logging, mining and industry.
Yellowwood, or Cladrastis kentukea has been found in Jellico Forest Service stands of interest according to the Forest Service's surveys. According to a Forest Service research scientist's report "… it is a North American endemic, an ancient relict with a limited overall range, and it appears to be declining overall in the wild. It could face extirpation in the wild in several states if it is not properly protected." "In addition to species listed as endangered or threatened under the Endangered Species Act (ESA), or species of Concern by U.S. Fish and Wildlife Service, the Forest Service lists species that are Sensitive within each region (RFSS). The National Forest Management Act and U.S. Forest Service policy require that National Forest System land be managed to maintain viable populations of all native plant and animal species. A viable population is one that has the estimated numbers and distribution of reproductive individuals to ensure the continued existence of the entity throughout its range within a given planning area." The report explains it is a listed species by the Forest Service.
Yellowwood grows as an understory tree in mature forests. Therefore the entire stands that they are in should not be logged in order to give them a small buffer of intact forest. Two of the three stands that yellowwood was found by the forest service are being scouted to be logged.
The Freedom of Information Act data revealed that seven of the stands that the Forest Service is planning to log are over 120 years old according to their own stand inventory data. These stands represent the kind of diverse beautiful forest that has some of the highest conservation value. They are also older than what the Cumberland district decided was too old to log in their Blackwater project. In total, this represents hundreds of acres, including at least a hundred acres in landslide-prone areas over critical stream habitat for threatened and endangered species.
Kentucky Heartwood, in collaboration with Dr. Justin Maxwell, a permitted research scientist, cored several trees in the oldest stands being scouted to log and found extremely old oaks, black gum and tulip poplar. Many individuals were well over 150 years old, and one black gum was even pushing 275 years old. In addition the diameter (DBH) of the tulip poplar trunk cored was over 3 feet wide. Not only does this give you an idea of its impressive size, but its width and age qualify it to be considered for old growth designation by the Forest Service and protected from logging.
Not only do stands over 150 years of age act as an disproportionately large carbon store they are also incredibly rare in themselves constituting a fraction of a percent of the total forest.
All this is why we are encouraging the Forest Service to create a 1,449 acres patch of designated old growth in the Kengee Hollow area. This would meet region 8 old growth guidance for creating additional satellite patches of old growth to meet landscape-level conservation needs. It would also prevent landslides and destruction of threatened and endangered aquatic species. In 2020 the Stearns district won the district of the year award for the Southern region. It shouldn't let Cumberland district outperform it in terms of meeting the evolving ecological and social needs of its district.
In 2019, the Daniel Boone National Forest used something called condition-based management for the first time for the Blackwater project near Cave Run Lake. This method undercuts the National Environmental Protection Act’s requirement to get site-specific feedback from the public on logging projects. More recently in 2020, the federal courts in Alaska ruled that logging with condition based management is illegal. We hope the Forest Service will take this ruling seriously and will not try to use condition-based management on the Jellico project.
There are no hiking trails in the entire Jellico region. The Forest Service reports that the area is primarily used for (unauthorized) off-road vehicles, and noted that their extensive use is damaging the forest.
Additionally, there are four beautiful campsites along Jellico creek. If hiking and mountain biking trails could be developed in this area, it could provide economic development opportunities and increase public access to the forest.
Invasive species concerns
The Forest Service acknowledges that there are significant patches of tree of Heaven, multiflora rose, autumn olive, honeysuckle, and Japanese stiltgrass. Opening the tree canopy with logging will only make worse the growth of these difficult to control species, costing the public more money when the Forest Service uses herbicide and staff time to try to treat and remove them. Ultimately the most effective way to manage invasive species is to prevent their establishment in the first place and in this case that means avoiding disturbance and heavy machinery use.
The combination of unique geology, topography and ecology of the Jellico region presents nearly insurmountable hurdles to make a proposed project fit within legal guidelines. The information shared above is just the beginning. Since we did not receive the Freedom of Information Act documents until March 1, we have only had limited time to comb through them before the Jellico field trip comment deadline of March 21. However, this is not an official comment period, so we look forward to the Forest Service’s future public engagement where we can submit our comments as part of the official record. There were simply too many things that jumped out as problematic to give them all the time they deserve. These are all problems that we hope the Forest Service will work with Kentucky Heartwood and the public to remedy.
Without your support a lot of these issues would have gone completely under the radar. By supporting Kentucky Heartwood you are giving a voice to the Cumberland Darter, the Yellowwood tree and countless others so that they may stand up for their legal right to continue to exist on this earth.
Please Take Action and Comment on the Forest Service's website
We greatly appreciate the time you spent reading this and encourage you to write any thoughts or feelings you have that come to mind to submit to the Forest Service through the "Public Input" section of their virtual field trip. The last day to submit comments is this Monday the 21th. The Forest Service wants comments from people of all walks of life and not just specialists. They know very well that they are supposed to work for the public so be a good boss and tell them your perspective no matter how long or short!
The U.S. Forest Service has proposed logging up to 250 acres in areas with extreme landslide risks in the Redbird Ranger District of the Daniel Boone National Forest. Despite these known risks, the Forest Service has proposed the Hector Mountain Salvage project under a Categorical Exclusion (or “CE”), which means that the project will be fast-tracked and exempted from analysis in an Environmental Assessment. The Forest Service proposed the project on February 1, 2022 in response to ice storms that damaged trees in January 2021. The agency failed to include the project in the quarterly Schedule of Proposed Actions (SOPA). The entire announcement was limited to 6 pages and a 30 day comment period.
Logging units in the Hector Mountain Salvage project are just a few miles from the ongoing landslides in the Group One logging project that Kentucky Heartwood has been documenting and reporting on for more than two years. Our examination of LIDAR-derived topographic data and on-the-ground surveys in the Hector Mountain area have found more than a dozen landslides, mostly in stands that were harvested in the 1990s. The Forest Service has mostly downplayed the risks of landslides posed by logging in the Redbird District, and the scoping document fails to make any mention of landslide risks. However, information obtained by Kentucky Heartwood through Freedom of Information Act requests has revealed that the Forest Service has been well-aware of the specific landslide hazards in the Redbird District for a long time.
An email from a former Daniel Boone National Forest Soil Scientist to the current Forest Soil Scientist, dated November 2020, states:
“I recall inventorying over 20 slides in clear cuts on the Red Bird and all but 3 or so were associated with a coal seam. Most of these occurred around 5 years after harvest. The Fire Clay seams I recall were involved with most. I did write something up on that but I don’t have a clue if it’s still around.”
One of the specific hazards relates to the hydrology of coal seams, like the Fire Clay. The Fire Clay runs through all of the proposed logging units in the Hector Mountain Salvage project. In Redbird, these highly permeable coal layers are often underlain by relatively impermeable clays. This causes moisture to accumulate disproportionately at these specific strata. Where soils are highly erodible and slopes very steep, like across most of the Redbird District, this buildup of soil moisture can trigger landslides or other mass wasting events. Intact forest root systems help hold forest soils and slopes together, limiting the extent of any landslides and ability for sediment to reach stream channels. However, in the years following timber harvest, tree root systems die back, reducing their ability to hold soils together. And the construction of full-bench skid roads – which is common on the Redbird District – further exacerbates the issue by affecting hydrology and slope stability, especially where skid roads cross coal seams. All of this is known to the Forest Service, but has been repeatedly ignored in the Group One, South Red Bird, and now Hector Mountain projects.
Notably, the Forest Service has proposed road reconstruction on Forest Service road 1730 “to stabilize the road… and to facilitate passage of large trucks and heavy equipment.” Currently the road is safely passable by passenger vehicles. However, road reconstruction will be needed to support logging trucks and heavy equipment. What the Forest Service fails to disclose is that the instability of the road and slope is the result of a landslide that occurred when that area was logged in 1994. The landslide runs several hundred feet downslope, and the upper portion (where the road is located) is continuing to slump.
Several other landslides were found by Kentucky Heartwood in this same area of, including a major landslide that recently collapsed and resulted in large amounts of sediment and debris in the stream channel. This continuing instability is occurring nearly three decades after the stand was logged.
In addition to landslide concerns, the Forest Service has failed to provide any information on how trees will be assessed for damage and chosen for harvest, or otherwise how heavily they plan to cut the area. Most of the trees that we’ve been able to examine in the field exhibit moderate damage that is well within the trees’ ability to recover. Studies of growth rings in old-growth trees in Kentucky and elsewhere demonstrate that it is normal for very old trees to go through periods for more rapid growth followed by periods – sometimes lasting decades – of very slow growth as they recover from episodes of canopy damage. It’s unusual to examine tree ring patterns in old-growth trees and not see this pattern.
But the Forest Service’s description of the forests’ condition suggests that any damage to trees is catastrophic. In the scoping document, the Forest Service states that damage from the ice storms “has predisposed the stands to forest pathogens, insect-related diseases, reduced annual growth, reduced quality of the wood itself, and ultimately early mortality.” What is clear is that the Forest Service is primarily concerned with “reduced quality of the wood” and any reduction in annual growth.
Our forests evolved with natural disturbance events, like ice storms, and even depend on them. Most logging in the Daniel Boone National Forest is predicated on the Forest Service’s assertion that there is insufficient natural disturbance to support disturbance-dependent species, like ruffed grouse and white oak. But the impacts of the 2021 ice storm to the trees and forests in the Hector Mountain project area are precisely those that support disturbance-dependent species. And the best available science backs that up.
You can read Kentucky Heartwood’s comments to the Forest Service below. In that letter we provide more information about old-growth and natural disturbance, landslide issues, and errors in how the Forest Service is using their Categorical Exclusion authorities. The Kentucky Resources Council joined Kentucky Heartwood in submitting these comments.
Please consider supporting Kentucky Heartwood's work to respond and challenge projects like this by joining or making an extra donation. Our ability to review these projects and do the necessary on-the-ground work to see what's really happening in the forest is only possible through donations from our members and other supporters. You can donate to Kentucky Heartwood here.