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. 

​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. 

• What we asked the Forest Service: Please conduct a full Environmental Assessment (EA) including an analysis of impacts to the Sheltowee Trace. The Forest Service needs to consult with the Sheltowee Trace Association and address any concerns before approving the project. Please keep your word to preserve high quality user experiences of the Sheltowee Trace, and to not log along the trail or in its viewshed. 

​
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.   

• What we asked the Forest Service: Support upland oak communities by felling of small midstory trees with limited canopy thinning in addition to prescribed fire. Do not continue with failed oak regeneration strategies where most or all of the canopy is logged.

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.    

• What we asked the Forest Service: Please conduct a full Environmental Assessment instead of relying on a Categorical Exclusion. The proposal and analysis need to include site-specific information, including where logging will actually occur. The Forest Service needs to analyze the possible effects of the project on rare species, recreational uses, and other resources and values. The Forest Service also needs to take a hard look at landslide-prone areas, especially at the boundary of the Grundy and Borden formations which shows evidence of significant slope stability issues. Please offer a public comment period on the analysis before making any final decision to approve the project. 

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.

• What we asked the Forest Service: Please protect interior forest habitats, which are increasingly limited in northeastern Kentucky. Prioritize the recovery of endangered species that require mature and interior forests rather than species (like grouse) that benefit from ongoing logging pressures on private lands in the area. The Forest Service should conduct an analysis including private lands in the area to assess deficits in interior forests and consider this in planning of any management in the project area.  

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.

• What we asked the Forest Service: Please consider the amount of mature and old-growth forests in the project area and make management decisions that preserve these forests. The creation of young forest habitats should not rely on the conversion of mature forests, but instead emphasize restoration work on old clearcuts, edge thinning of powerline corridors, wildlife openings, and other permanent openings. The Forest Service needs to consider the carbon sequestration effects of the proposal, including an accounting of carbon lost through proposed timber harvest. 

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.

• What we asked the Forest Service: Please incorporate natural disturbance and landscape-level data into your analysis. This includes a reasonable estimation and assessment of forest conditions across ownerships in the vicinity of the project area.

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. 

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.
​
Key facts: 

• The Forest Service intends to construct approximately 0.96 miles of a 30-foot-wide new permanent system road, NFSR 5014, to access approximately 130 acres of timber that was approved for harvest under the “Greenwood Vegetation Management Project” in 2017. 
• The District’s roads review found that “The current road system… provides adequate access to timber stands needing silvicultural treatment.”
• The Forest Service Roads Analysis directs it to “reduce the number of road/stream crossings and the amount of roads occurring within 100 feet of streams… [PRFP Objective 3.0.C, Objective 12.0.A and PRFP Objective 12.1.A(b)],” and to “Move roads out of areas such as riparian areas… [PRFP Objective 12.0.A and PRFP Objective 12.1A(d)]” (emphasis added)   
• The proposed construction of NFSR 5014 includes building a new system road in a riparian zone and across a stream, directly in opposition to the recommendations of the Roads Analysis. 

Issues: 

• The proposed road construction violates the Forest Plan and the National Forest Management Act (NFMA), which directs the Forest Service to close or modify roads to limit environmental impacts. 
• Building NFSR 5014 runs contrary to the implementation of the Greenwood project, which did  “not propose to construct any new Forest System roads and will not require a commitment of additional future funds for maintenance actions.”  
• The proposed road construction fails to consider financial costs and commitments. When we asked for this information, the response was that “(C)ost-benefit considerations are outside the scope of this road construction project.”
• The current budget of the Daniel Boone National Forest cannot meet maintenance requirements of the existing road system, much less new roads. The Travel Analysis Process Report (TAP/TAR) for the Stearns Ranger District was produced in 2016 and signed in 2017 by District Ranger Reed and Supervisor Olsen. The report states that the Stearns District requires an estimated $248,780 annually to maintain and repair roads, culverts, and bridges, but typically receives only $92,626 to meet those needs.
• The timber is already marked for sale, despite not having an access road to it. We previously raised how unfortunate it is that the Forest Service assumed a road easement acquisition during the development, analysis, and approval of the Greenwood project in 2017. In retrospect, that analysis should have considered what course of action the agency should take if that access was not granted. It is now evident that the Forest Service compounded its problems by continuing to sink resources into the marking, planning, and possibly preparation of the timber sale without having access. ​

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.

​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. 

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. 

Yes.
​
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.

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.”

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

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:

• 'This will destroy this whole region for years,' resident tells U.S. Forest Service  - The News Journal
• Front Page the Times Tribune 
• Front Page The McCreary County Voice 

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: 

Landslide risks
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.

Flooding risks
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. 
​
Old growth
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)
​
Invasive plants
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. 
​

Endangered species
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 whitney@kyheartwood.org. 

Help us reach our goal of 100 public comments by December 5th! ​

For Immediate Release, September 14, 2022
​
Contact: Jim Scheff, Kentucky Heartwood Ecologist, (859) 334-0602; kentuckyheartwood@gmail.com
​

Group Challenges Major Timber Project on Kentucky’s Daniel Boone National Forest​

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:

• Ensure that "mature" forests are defined in a manner that protects the majority of carbon, wildlife habitat, and watersheds on the landscape (we're using 80 years old as a benchmark for this). To us, the mature definition is more important than the definition for old growth. 
• Stress the need for a lasting rule prohibiting logging in mature and old-growth forests - it's not the focus of this federal register notice, but we're not sure how many public comment opportunities we'll get so we want to take advantage. 

​
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. 

Sample comments:
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:

• Threatened and endangered Indiana, northern long-eared, and gray bats
• Numerous species of birds that are suffering from habitat loss such as the Cerulean Warbler, Wood Thrush, and Red-headed woodpecker
• Medicinal and culturally significant plants like ginseng and goldenseal
• The endemic Pine Mountain tigersnail, which is mostly associated with old growth

In addition, the Daniel Boone National Forest is home to old-growth and culturally  significant trees, such as the largest known Red Hickory tree, located in an old-growth forest in an area of the Redbird district that is marked for cutting.

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.

Click on the arrows in the upper left corner to display the legend.

​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.

Summary: 
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:

• Landslide risks and endangered fish and mussels: Landslides can wipe out sections of the forest and leave streams filled with sediment, damaging or destroying the habitat of the endangered snuffbox mussel and Kentucky arrow darter (fish)
• Old-growth trees: With a research scientist from Indiana University, we continue to measure the age of trees that are marked for cutting, finding many that are too old to be logged
• Endangered bat species: In 2021, thanks to our generous donors, we were able to hire a bat biologist and set up listening devices throughout the proposed logging area. We found compelling evidence that at least three species of endangered bats were present in this area that the Forest Service did not fully account for in their plans. This means that logging could damage or destroy endangered bat habitat.

Because of the numerous issues associated with this logging project, as well as the unique species that live in the forests of this area, Kentucky Heartwood intends to sue the Forest Service for violations of the Endangered Species Act. In doing so, we hope to stop this logging project. 

More information: 
​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. ​

​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. 

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.