5,000 acre logging project proposed north of Morehead along the Sheltowee Trace National Recreation Trail.

The Daniel Boone National Forest has proposed a 5,000 acre logging project just north of Morehead along the Sheltowee Trace National Recreation Trail.

While this project is problematic on many levels, most concerning is that the Forest Service plans to approve the Ruffed Grouse Habitat Enhancement project with no environmental analysis and without disclosing exactly where or how much logging is planned. The National Environmental Policy Act (NEPA) requires the Forest Service to assess the potential impacts of logging projects, which includes soliciting public input and consideration of alternatives that could limit environmental impacts. Instead, the Forest Service has decided to get creative to avoid any troublesome analysis or disclosure to fast-track a major logging project in an area that was already heavily logged from 2008 to 2017 in response to a 2003 ice storm.
 
The Forest Service plans to combine a “categorical exclusion,” which allows them to avoid completing an Environmental Assessment, with a novel management approach called “condition-based management” where the agency leaves decisions about where and how much logging will occur until AFTER the project is approved.  This novel approach sidesteps important checkpoints and essentially gives the Forest Service and the Ruffed Grouse Society (its stewardship partner) the greenlight to log wherever, whenever, and how much they want in the 5,000-acre project area.

Tina Marie in a third-growth forest. The areas that were logged in the 1990s are now dominated by tulip poplar and stump sprouted red maples where oaks previously dominated. Photo from 2016.

When this forest was salvage logged, it created a "third-growth" forest. Meaning, this is the third regeneration of this particular stand of trees. Photo from 2016.

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. 

Read public comments here

Our concerns and what we asked the Forest Service to do...

​1. Issue: Risks to Sheltowee Trace National Recreation Trail – The Forest Service intends to complete commercial logging along the Sheltowee Trace on Big Perry Road, but they haven’t shared details about how this will impact the trail. 

• 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. 

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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.

Map made using ArcGIS and Forest Service data by Jim Scheff, Kentucky Heartwood

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.

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Read our formal organizational objection below.