Wild places sustain and define us; we, in turn, must protect them.
Throughout 2020, Kentucky Heartwood made great strides to protect forests and native communities found around the Daniel Boone National Forest. Staff spent hundreds of hours in the field and covered thousands of acres documenting plants, old-growth and secondary old-growth, and landscape characteristics. Read on for our assessment of 2020 and what we anticipate for 2021!
On Monday, October 5th, Kentucky Heartwood and the Kentucky Resources Council jointly filed an administrative objection (“predecisional objection”) to the South Red Bird Wildlife Enhancement Project on the Daniel Boone National Forest. The project would approve 3,600 acres of logging in the Redbird District of the Daniel Boone in Clay and Leslie Counties. The project also approves the construction of nearly 100 miles of full-bench skid roads across extremely steep and highly erodible mountain slopes for hauling out the timber. Extensive field work by Kentucky Heartwood has demonstrated massive and ongoing landslides resulting from the same types of management in the adjacent Group One project. The Forest Service’s South Red Bird project could degrade or destroy up to 16% of designated critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum), and degrade habitat for the federally-endangered snuffbox mussel (Epioblasma triquetra).
The South Red Bird project could also have major impacts to federally-threatened northern long-eared bats (Myotis septenrionalis) through large-scale habitat fragmentation (some logging units are 200 acres to nearly 400 acres in size) and logging the closed-canopy flight corridors they use to travel in the forest.
Throughout the Forest Service’s analysis, misleading and arbitrary characterizations of the landscape and potential adverse environmental effects – especially to aquatic and interior forest species – were used to excuse the aggressive and inexcusably destructive logging practices in the project. Despite the Forest Service’s lip-service to “collaboration,” the only public that they listened to were organizations like the Rocky Mountain Elk Foundation, which has lobbied the Forest Service to clear more of our native forests to make it easier to hunt introduced Rocky Mountain elk.
Kentucky Heartwood’s advocacy helped to identify and protect the 40 acres of old-growth on Little Flat Creek that the Forest Service had planned to log. However, this isn’t nearly enough. The Forest Service still has an opportunity to drop or make major, substantive changes to the South Red Bird project. But if they aren’t willing to do what’s right, and to fulfill their legal obligations under the Endangered Species Act (ESA), National Environmental Policy Act (NEPA), and other laws and regulations, then we’ll be ready to take them to court.
The critical work that allowed us to develop such a strong, substantive objection, and to demonstrate that the Forest Service was misleading the public (and themselves), included nearly 300 hours in the field. That’s in addition to the hundreds of hours spent on research, analysis, and the drafting of comments and other materials needed to respond to the South Red Bird proposal.
We can’t do this level of work without support. To our members and volunteers who have helped us in this effort: Thank you. You have made a difference. But this isn’t over. We will need your continued support to take this project to court if the Forest Service remains unwavering in their willingness to bury our mountain streams in mud and rock, and destroy that habitat of at-risk species, to sell timber from our public lands.
You can join or donate to Kentucky Heartwood here.
Click the file below to download and read our administrative objection.
Join the virtual public meeting about the Jellico area
Tuesday, October 13, 2020
Read on for details and instructions on how to join the meeting.
The Forest Service has officially announced the beginning of a management planning process for the Jellico mountains in the southernmost part of the Daniel Boone National Forest on the Stearns Ranger District. We know from past experience that these Integrated Resource Management Strategy (IRMS) processes almost always turn in to massive logging projects, like South Redbird, Blackwater, and Pine Creek. And early indications are that this will be no different.
But early public participation usually leads to better outcomes for the ecosystem! Your participation does matter!
The Jellicos are a part of the Cumberland Mountains on the Kentucky-Tennessee border. Topping out at about 2200 feet, and with over 1200 feet in relief, the Jellicos 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) and Blackside dace (Chrosomus cumberlandensis). The Jellico analysis area includes nearly 1,300 acres of forest that could qualify as secondary old-growth (over 130 years old), but much of this older forest isn’t protected in the area’s “Designated Old Growth” area.
Resource extraction has already had a heavy toll on the 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.
Now is your chance to be a voice for the Jellicos! The Forest Service is hosting a virtual public meeting about the Jellico area on Tuesday, October 13, 2020, from 5:00-6:30 pm EST via Microsoft Teams. Click here to join the meeting.
Click here for a pdf with instructions from the Forest Service on how to connect to the meeting using a mobile device or computer.
The Forest Service has set up a public Facebook group called Jellico IRMS Assessment, where they have posted information about the IRMS process, and more details about Tuesday's meeting. Click here to join the Forest Service Jellico IRMS Facebook group.
To help spread the word Kentucky Heartwood has created a Facebook event, here, where we will also be posting updates and relevant information as we get closer to the meeting date.
Kentucky Heartwood remains committed to providing a thorough analysis of proposed agency actions using the best available science and the law. Protecting and restoring biological integrity to the Daniel Boone National Forest guides our efforts. As the Jellico IRMS process develops we will be providing analysis, information, and volunteer opportunities to help get to know, and protect, this unique part of the forest. To make sure that you can stay up to date be sure to sign up for our emails here.
If you value this work, please consider donating to Kentucky Heartwood. We're a small group, and every bit helps. You can donate on our website here.
Thank You. We couldn't do it without you!
Kentucky Heartwood is excited to announce that we have hired Ashley Lipscomb to serve as our new Director! We are thrilled to have her on staff, and look forward to everyone meeting her.
As Ashley steps into her new role, we have also promoted two other staff members to new roles. Jim Scheff, our Director since 2008 has stepped into his new role as Staff Ecologist (a lifelong dream of his!), and Tress La'Ree has been promoted from Administrative Associate to Administrator, reflecting her high level of service and leadership within the organization. See everyone's updated info on our Staff page here.
Here's a little more about Ashley:
Ashley joined Kentucky Heartwood as the Director in October 2020. She brings eleven years of forest watch experience learned in the wilds of the Northern Rockies. She started as a volunteer and became the Membership and Development Director for a small, grassroots group called Friends of the Clearwater. In her spare time, she co-led the Palouse Broadband of the Great Old Broads for Wilderness. Ashley gleaned many skills and strategies from some of the best forest activists in Idaho and looks forward to protecting biologically significant public lands in Kentucky through citizen engagement.
Ashley received her Associate of Science in Ecotourism and Adventure Travel from Hocking Technical College in 2009 and proceeded to earn a Bachelor of Science in Resource Recreation and Tourism from the University of Idaho in 2010. Post education, she monitored public lands across Idaho’s Clearwater Basin for ORV abuse, impacts of deforestation, and wildlife movements. Along the way, she made time to identify native flowers and swim in the cool, clear waters of the West.
At Kentucky Heartwood, Ashley is responsible for analyzing land management proposals using sound science and the law, creating communication lines with our supporters, growing a diverse membership base, grant acquisitions, and foundation relations. In her downtime, Ashley enjoys backpacking, drinking coffee, reading the newspaper, and walking her doggy named Akadia.
A few months ago, Kentucky Heartwood released information and allegations that the Forest Service was selling more timber in the Greenwood project of the Daniel Boone National Forest than what was approved in the 2017 project decision. We also asserted that trees had been marked for harvest in some riparian buffers along stream channels in violation of the Forest Plan. The Forest Service has since released their own data and analysis, insisting that everything (or most everything) is just fine.
So, who’s right?
Where reality stands is a bit complicated and muddy, and requires wading through some jargon and technical matters. I hope you’ll read on and get the details. They’re important. In summary though, our originally surveys overestimated the amount of timber being oversold. However, we believe that the data show that the Forest Service is still selling far more trees than approved (including in riparian areas) and, in some respects and locations, high-grading the timber.
For any of this to make sense, an explanation of the term “basal area,” or just “BA,” is in order. Basal area is defined as the cross-sectional area of trees at 4.5 feet above ground in a unit area. In American forestry BA is expressed in square feet per acre. In academic research, and internationally, the units are square meters per hectare (a very un-fun unit conversion). Overall, BA provides a measure how much of an area is taken up by trees, and relates directly to the numbers and sizes of trees in the forest. Because measuring every tree in a forest usually isn’t practicable, basal area can be estimated by using a number of different tools and sampling protocols, each with their own limitations.
A big, beautiful white oak marked for cutting.
Most “mature” and old-growth forests in our area have a BA ranging from around 90 to over 180 square feet per acre, but 110 to 150 is most common. Forest type, age, and disturbance history all play a big role. Several studies of regional old-growth forests have reported densities of trees over 4” (10 cm) in diameter ranging from about 65 trees per acre to around 250 per acre. A lot of small trees can be present in a forest and still contribute very little to overall basal area. On the other end of the management spectrum, most timber harvests on the Daniel Boone National Forest are shelterwood (or “regeneration”) cuts with a target BA of about 10 to 15 square feet per acre, and leave about 10 trees per acre.
Just under one-third, or 674 acres, of the logging approved in the Greenwood project was ostensibly designed to restore mid-density, fire-mediated upland forest communities through the “Woodland Establishment” prescription. There’s good evidence that this type of forest was historically important in the area. Kentucky Heartwood did object, however, to some of the locations chosen for the Woodland Establishment prescription because site selection seemed to be more about access to large timber than actual restoration potential and need.
We strongly advocated for the Forest Service to focus their Woodland Establishment and other management prescriptions in areas with known rare and declining grassland remnants, like those found along the Keno Road and Curt Pond Ridge area in Pulaski County. That particular area was identified in a 1988 Cooperative Inventory of Endangered, Threatened, Sensitive, and Rare Species for Daniel Boone National Forest conducted by the Forest Service, The Nature Conservancy, Kentucky State Nature Preserves Commission, and Kentucky Department of Fish and Wildlife Service. The 1988 report highlighted the Keno Road area and recommended establishing the area “as an experimental demonstration project.” Unfortunately, the site has been largely neglected, resulting in a major decline of this rare “Cumberland Barrens” remnant.
Despite our efforts, the Forest Service refused to include management of the Keno Road and Curt Pond Ridge areas (and other important sites) in the Greenwood project. The agency did, however, commit in their October 2017 response to our formal administrative objection to the Greenwood project, to working with Kentucky Heartwood and the Kentucky Office of Nature Preserves to develop a management strategy for the site. Unfortunately, other than a couple of on-site meetings in mid-2018, nothing has happened.
But let’s get back to talking about basal area.
The formal description for the Action 2: Woodland Establishment prescription in the Environmental Assessment for the Greenwood project is as follows:
“A woodland establishment treatment is proposed on approximately 674 acres in 20 stands. This treatment would retain an overstory canopy of dominant and co-dominant, vigorous, healthy, long-lived, and fire resilient trees, (e. g. shortleaf pine, chestnut oak, and white oak). The target leave basal area would be 30 to 50 square feet per acre.”
The selection of trees to be retained as “dominant and co-dominant, vigorous, healthy, long-lived, and fire resilient trees” is not incidental. While hollow, rotten, and declining trees are important ecological elements (and some must be retained per Forest Plan requirements), most won’t last long after logging. Particularly for structurally compromised trees, the increased exposure to windthrow following the harvest of adjacent canopy trees will hasten their loss from the canopy. And fire-intolerant species, like red maple, scarlet oak, and eastern hemlock, will be injured and decline following repeated applications of prescribed fire.
And it’s worth comparing the language for the Woodland Establishment harvest to that of Action 4: Shelterwood Preperatory Cut (a separate logging prescription in the project). The Shelterwood Preperatory Cut prescription states that:
“Trees favored for retention would be healthy, dominant, codominant, long lived, and fire-resilient species such as shortleaf pine, white oak, chestnut oak, and hickory with the best crowns.”
The deliberate use of the word “favored” in the prescription for Action 4: Shelterwood Preperatory Cut, but not in the prescription for Action 2: Woodland Establishment, is important. The Forest Service could have used similar equivocating language in the Woodland Establishment prescription, but didn’t.
In the Forest Service’s response to our complaint they report an overall retained BA of 37.5 square feet per acre. This is much higher than what we reported following our initial survey. Based on our subsequent surveys, we think that the Forest Service’s estimate for total, average BA is about right. The differences largely resulted from our use of transects instead of grid-based sampling. Despite our efforts to be non-selective while still collecting data representative of each harvest unit, we clearly missed some portions of stands which contributed substantially to the total basal area. However, reporting only the total BA misses a crucial part of the story.
Their report states that “For all stands sampled, trees with undesirable characteristics will comprise a small, but tolerable, amount of the future stand.”
However, the various data presented in their report, and one of their concluding statements, contradict this interpretation. The Forest Service reports states that:
"For all woodland stands and the shelterwood preparatory stand, the results indicate trees with desired characteristics comprise over 60 percent of the BA to be retained. Specifically, these trees are of a dominant or codominant crown class, a desirable species, and have a tree class of desirable or acceptable."
The corollary here is that up to 39% of the trees being retained (representing about 14.6 square feet per acre of basal area) do not meet the criteria of being long-lived, healthy, vigorous, and fire tolerant trees, and have a high likelihood of declining or dying within a short period after logging and burning. It is hard to see this as only a “small, but tolerable, amount.” The final BA of trees that actually do meet the criteria for retention, based on the Forest Service’s data, is around 22.9 square feet per acre, or about half of the target BA prescribed in the Environmental Assessment. This value is very close to the 20.5 square feet per acre that we reported in our initial complaint.
An astonishing number of hickory nut shells discarded by squirrels under a vary large hickory marked for cutting.
Our subsequent surveys suggest that some of the harvest units are in compliance with the prescriptions in the EA. But some are not. To meet the letter and intent of the Woodland Establishment prescription, the Forest Service needs to retain, at a minimum, an additional 7 square feet per acre of the healthy, merchantable trees that they have marked and sold. If the pattern holds across the 674 acres of the Woodland Establishment prescription, that would amount to about 4,500 fourteen-inch diameter trees, or over 2,000 twenty-inch diameter trees.
The Forest Service did concur that trees were inappropriately marked for harvesting in at least one of the riparian areas that we brought to their attention. In the Daniel Boone National Forest logging isn’t allowed within 50 feet of streams classified as “intermittent,” but is allowed in and along stream channels classified as “ephemeral.” Differentiating the two can be challenging. One location we took issue with was a headwaters tributary of Drury Branch, before it drops in to Beaver Creek Wilderness. The Forest Service did determine that the stream segment “confidently fits the definition of an intermittent stream,” but that the error was unintentional and understandable. However, the Forest Service is only reviewing the status of the approximately 300 acres that Kentucky Heartwood surveyed, and not any of the remainder of the more than 2,000 acres of logging in the Greenwood project.
We’ve yet to decide how to proceed with the Forest Service. These issues represent serious errors on the part of the government and are a breach of the public trust. It also comes at a time when we know that the Trump administration is putting pressure on the Forest Service to increase the volume of timber being harvested from our national forest lands. Our frustration is even more pronounced given the Forest Service’s foot-dragging on their commitments to manage the rare plant communities in the Keno Road and Curt Pond Ridge area. But the environmental impacts of these overharvests in the Greenwood project are less severe than the ongoing landslides resulting from recent logging in the Redbird District, and the thousands more acres of severe logging nearing approval in the South Redbird project. Given our organizational capacity, we have to be judicious in where we apply our resources. It’s not an easy call.
If you want to support this work, please consider donation to Kentucky Heartwood.
You can join or donate here.
I’ve struggled over these past few weeks with whether or not publish a statement on behalf of Kentucky Heartwood in response to the historic Black Lives Matter protests and demonstrations that are happening across the country. And I continue to struggle with it. I’ve found the statements issued by some organizations, businesses, and institutions to be powerful, insightful, and heartening calls to action, both personal and political. However, a great deal have also seemed – at least to me – to be little more than platitudes lacking in substance, dispensed out of concerns over marketing and retaining market share. But I am one to get cynical.
To be clear, Kentucky Heartwood, including our Board and Staff, oppose racism in any and all forms. And if you know me personally (or follow me on social media) you probably have a sense of my thoughts on structural racism and police violence. These issues are real, and they are unacceptable.
However, I do want to offer some personal thoughts and observations regarding structural racism and the conspicuous underrepresentation of people of color in conservation and outdoor recreation spaces. I have been involved in public lands protection for 20 years, and have been enjoying and exploring wild places for many years more. Among the hundreds of activists, attorneys, scientists, organizational staff, board members, and volunteers I’ve met in my capacity as a public lands advocate, very few have been people of color. And even fewer (one, maybe two?) have been Black. This hasn’t gone without notice among the groups that I’ve been involved with. Most public lands advocates that I have known (though certainly not all) are sincerely concerned about issues of racial and social justice. I’ve participated in more than a few conversations about the lack of representation by people of color in our organizations, as well as the conservation movement more broadly. Despite heartfelt and genuine concern, efforts – including my own – have rarely moved beyond conversations and the setting of intentions.
For years I excused this absence of people of color from our organizations, campaigns, and spaces as a regrettable but understandable reflection of the nature of activism. People tend to pour in the time and energy on issues that are closest to them. For too many people of color, and especially for those in the Black community, that often and unfairly means that people’s energy is taken up by the countless daily, tangible struggles rooted in historical and contemporary systems of racism. Put another way, it’s not fair to expect someone to care very much about logging on a national forest when they’re worried that their son might be shot by the police for pulling out his cell phone.
But this perspective accepts too much exclusion, both within our organizations and in the outdoor spaces that we work to protect. It ignores the gross unfairness of the fact that centuries of white supremacist violence and structural inequities continue to affect so many Black people’s relationships with, and access to, America’s wild outdoor spaces and public lands. My understanding of these issues is at best shallow. What I do know is that there are stories that need to be heard, both of history and lived experience.
I think sometimes about the race riot in Corbin in 1919, just 18 years before the establishment of the Cumberland National Forest (later to be renamed the Daniel Boone National Forest). A vibrant Black community of roughly 200 people was summarily rounded up, forced on to rail cars, and removed from the state to the words “By God we are going to run all Negroes out of this town tonight.” For those families who’s stories and memories include this violent episode, what does it mean to pass Corbin on the way to Cumberland Falls? Does it mean something different today than it did a generation ago? What about the ways that “sundown laws” kept Black families from traveling to visit State and National Parks, National Forests, and other public lands? What is the legacy of the Commonwealth of Kentucky barring Black people, by order of law, from nearly all State Parks until 1955 when the Supreme Court ruled the practice unconstitutional? What does it mean when going to a park or stopping for gas on your way home could mean arrest, or worse? How are the outdoor experiences of a young person of color, today, affected by the stories of their parents or grandparents?
And it would be so easy, perhaps even comfortable, to pretend that the exclusion of Black people from outdoor spaces is some relic of the past. But it’s not. In February of this year, 25 year-old Ahmaud Arbery was shot dead while going for a run by armed vigilantes who assumed that he’d committed a crime. He hadn’t. In May, Audubon Society Board Member and notable comic book author Chris Cooper had his life threatened while birding in New York’s Central Park when a white woman got upset because he asked her to follow the rules and leash her dog. Her response was to call the police, frantic, and telling the lie that a Black man was threatening her. He wasn’t. Or we could talk about North Carolina botanist (and musician and chef), Justin Robinson who was handcuffed while looking at plants in the woods. I know a lot of botanists. All are white. And I’m fairly certain that none have been put in handcuffs while looking at plants.
Or we can talk about the Confederate flags displayed prominently on homes and farms along the road sections of the 333-mile Sheltowee Trace National Recreation Trail. How can a person of color experience the trail as I can, and find the same peace and ease in walking those long miles with so many Kentuckians proudly flying a flag that says “I’d rather you be in chains”?
And even within Kentucky’s outdoor community, racism continues to bubble to the surface. Over the past month, one of the only prominent Black people in Kentucky’s conservation and outdoor recreation community, someone I consider a friend, has been repeatedly attacked through social media with vitriol and accusations of racism for speaking with measured words about… racism. Their repeated message is “Shut up.” Over and again, “Shut up. Your story is not welcome here.”
I don’t know the answers. And I won’t pretend to. But I’m pretty certain that, at least for white people like me, now a time to listen. And it is okay if the voices and stories being lifted challenge your understanding of the world, or even your understanding of your self. But what is not okay is to respond to this moment, to the cries of grief and anger over generations of state-sanctioned violence and exclusion, to the murders of Breonna Taylor, George Floyd, Stephon Clark, Philando Castille, Tamir Rice, and so many others, by dismissing the very real and contemporary effects of structural racism in America. Such denials are lacking in veracity and belie the facts. They are simply not serious.
Our public lands belong to all of us. The experiences they give us should be accessible to all of us. And it will take all of us to protect them in this age of accelerating climate change and biodiversity collapse.
The status quo is not acceptable.
Black Lives Matter.
Kentucky Heartwood has documented multiple ongoing landslides in the Redbird District of the Daniel Boone National forest caused by logging in the Group One project in Clay and Leslie Counties. To date, we’ve identified at least 6 landslides, including two that dumped sediment into streams and one that took out about 200 feet of mountainside. All of the landslides started at “full bench” skid trails that the Forest Service allowed to be bulldozed across the mountainsides for loggers to get at the timber. We also found that the Forest Service had allowed far more of the forest to be bulldozed and scraped clear than is permitted under the Forest Plan.
Prior to our bringing these landslides to their attention the Forest Service claimed that no landslides or other major erosion was happening as a result of their logging operations. Their position has been that Forest Plan Standards for the Daniel Boone National Forest, as well as Kentucky’s state forestry Best Management Practices, were effectively protecting forest soils and streams. They’re not.
In addition to erosion and landslides, infestations of non-native invasive plant species (NNIPs) is especially bad in the Group One project. We conducted surveys of one logging unit harvested in 2012 and documented 18 species of NNIPs. We sampled twenty-four 25 ft. by 5 ft. plots running perpendicular to skid trails and found that average cover of NNIPs was 39.8%. Thirty-eight percent of plots had more than 50% coverage of NNIPs. The Forest Service contends that all contract provisions for minimizing NNIP infestations were followed.
The Group One project was approved in 2008 after being withdrawn twice after challenges by Kentucky Heartwood. Over 1,000 acres of logging were ultimately approved for various "forest health" and "habitat improvement" purposes. The Forest Service is now nearing approval of over 3,000 more acres of logging in the nearby South Redbird project. The South Redbird project will allow the same types of logging on the same types of slopes and soils, but at a much larger scale - with individual logging tracts over 300 acres in size (10 times bigger than those in the Group One project). Up to 91 miles of full-bench skid roads could be bulldozed across the mountains. Most of the South Redbird logging will occur in watersheds that provide critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum), and habitat for the federally-endangered Snuffbox mussel (Epioblasma triquetra).
In February, Kentucky Heartwood produced a video using drone footage showing logging at several sites in the Group One project. The video shows some of the landslides, along with the astounding amount of bulldozing that the Forest Service has allowed for removing timber. Shortly after we produced the video, we found an even larger landslide in a harvest unit on Ulysses Creek (unfortunately we did not have access to a drone at the time).
If you think this is valuable information, please consider supporting Kentucky Heartwood's work! We are a small organization anticipating significant shortfalls this year. Any bit helps.
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 firstname.lastname@example.org 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.email@example.com.
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 firstname.lastname@example.org on your comment email. Also, you should receive a confirmation reply from the Forest Service letting you know your message was received. Sometimes it takes a few hours to receive the notice. If you do not receive one, that means they did not get your message.
Also, 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.