​The U.S. Forest Service has proposed 3,200 acres of intensive logging on the steep and rugged slopes of the Redbird District of the Daniel Boone National Forest. Comments need to be submitted by Monday, April 2nd. The "South Redbird Wildlife Habitat Enhancement Project" threatens critical habitat for the Kentucky arrow darter (Etheostoma spilotum), which was listed as "threatened" under the Endangered Species Act in 2016. The darter is found only in clean waters of the upper Kentucky River, and has disappeared from 44% of its range since 1990. Nearly 900 acres of proposed logging is in the watershed of Elisha Creek, which is also home to the federally-endangered Snuffbox mussel (Epioblasma triquetra). The snuffbox was protected under the Endangered Species Act in 2012 on account of a 62% rangewide decline. Unlike the mainstem of the Redbird River, which is too polluted by mining runoff, oil and gas development, and sewage for these species to live, the clean tributaries in the project area provide habitat needed for these species' survival. 

​Of the 32,300 acres of national forest land in the South Redbird project area, 27% has been harvested since 1980 and only 15% is over 100 years old. This is a stark contrast to the centuries-old forest at Lilley Cornett Woods, just 25 miles to the east. And yet the Forest Service is proposing to log 23% of all forest over 100 years old in the project area. Several areas ranging from 200 to 350 contiguous acres have been proposed for logging. Combined with previous cuts, some sections of forest, up to 800 acres, will hardly have any trees over 30 years old left standing.

The Forest Service proposed the South Redbird project at the same time as a Forest Plan amendment to loosen logging restrictions designed to protect endangered Indiana bats. And another proposal to log several thousand more acres of the London District (the Pine Creek project) was just posted on the Daniel Boone National Forest website. Expect to see more on that soon.
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The South Redbird project follows a series of public meetings that the Forest Service refers to as “collaborations.” While Kentucky Heartwood is listed as a “collaborator” in the scoping letter, our good-faith input throughout the process was largely ignored. In fact, the project reflects few of the concerns raised by participants – other than those of state and federal agencies pushing for more clearcuts and “regeneration” harvests for ruffed grouse habitat. While the forest has been characterized by some as “too old,” the fact is that less than half the forest is over 70 years old. 

​In 2008, the Forest Service approved 1,200 acres of logging immediately north of the South Redbird project area as part of the Group One Redbird River Project. The Group One project included a Forest Plan amendment that established a 12,000 acre “Ruffed Grouse Emphasis Area” to be maintained under 60 year timber rotations in cooperation with the Kentucky Division of Fish and Wildlife Management. Kentucky Heartwood successfully appealed that project twice before it was approved after a third revision. Despite the specific grouse emphasis, after 10 years neither federal nor state managers can answer questions regarding the success or failure of their grouse management. And yet they insist we need more forests cleared across the district for grouse. Kentucky Heartwood suggested early in the process that the Forest Service consider meeting forage needs for grouse by incorporating small to medium-sized group selection cuts in a matrix of thinning oriented toward old-growth structural development. But this would mean less timber getting cut, and apparently that’s not worthy of serious consideration. 

Despite its rugged beauty and rich diversity, the Redbird District is being treated like a throw-away district by the U.S. Forest Service. There are no hiking trails and no campgrounds – issues that were raised repeatedly during public meetings by members of the public and U.S. Forest Service staff. The only recreational infrastructure is the extensive Redbird Crest ATV trail, which the Forest Service proposes to reroute with 12 new miles of ATV trail construction. National forest lands in the Redbird District are an island in a landscape of vast strip mines and clearcuts. The forest here needs to be protected and nurtured, and we think that the Forest Service can do better. Please help encourage them to do so.

Official documents for the project can be found on the Daniel Boone National Forest website. And more information can be found on our website here.

Comments are due by Monday, April 2, 2018, and should be emailed to:
comments-southern-daniel-boone-redbird@fs.fed.us

Please note in the subject line that the comments are for South Red Bird Project.
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Comments can also be mailed by U.S. Postal Service to:

Robert Claybrook
Redbird District Ranger
91 Peabody Road
Big Creek, KY 40914

Email Address Correction:
We have heard from several people that the Forest Service email address we linked to is invalid. Thanks for letting us know! We tracked down the error in the email address and corrected it on our website. There was an invisible extra dash that was in the email address between the word southern and daniel. This happened because we copied the email address from the scanned pdf provided by the Forest Service, and the optical character recognition must have added this extra dash. Many programs will turn two dashes in a row into one dash, and that is what happened in this case, resulting in an invisible extra dash. I deleted it and now it should work. Sorry about that!!

The correct email is (the one in the post above has been corrected as well): 
comments-southern-daniel-boone-redbird@fs.fed.us

Make sure when you copy/paste that there is no space or period at the end of the email address as well. If you have any issues sending your comment in, please let us know.

Feel free to copy kentuckyheartwood@gmail.com 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 note, if you go to the page for sending comments on the DBNF website, old information for sending comments to Jared Calvert is posted there. The correct instructions for commenting are in the scoping letter, posted on this page of the DBNF website. 

Kentucky Heartwood has submitted comments to the Daniel Boone National Forest concerning the proposed Forest Plan Amendment. (Scroll down for text or click here for a downloadable PDF of our comment letter).  As of this posting, 24 public comments have been submitted and are available to read on the Daniel Boone National Forest website  here, including comments from the U.S. Fish and Wildlife Service (USFWS) Kentucky Field Office (KFO). 

​Notably, the KFO states in their comment letter, "If the action is carried out as proposed, an increase in adverse effects on federally-listed species is anticipated." The KFO also states, "While the existing standards are more restrictive, it is important to note that they were intended to avoid and minimize the potential for adverse effects and incidental take of Indiana bats on the DBNF that were likely to occur as a result of certain types of tree removal and prescribed fire. In some circumstances, the season restrictions, buffers, and other standards also provided protection for-federally-listed plants and aquatic species. Elimination of these restrictions is, therefore, likely to have the opposite effect and result in increased adverse effects on listed bats, plants, and aquatic species and designated critical habitat, especially in light of the increased amount of forested habitat proposed for treatment under the proposed Forest Plan amendments."

It is very important that the Forest Service receive comments from the public. 
​We need to let them know that protecting endangered species is more important than selling a few more logs from our public forest. Feel free to use Kentucky Heartwood's comments as a point of reference for writing your own. You are also welcome to copy our comments and state to the Forest Service that you agree with them, if that makes it quicker or more likely for you to submit comments.
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Here is a link to the page on the Daniel Boone National Forest website where the public can comment on this proposal. Comments are due by the end of the day on Monday, March 26, 2018. 

Comments can also be emailed to: comments-southern-daniel-boone@fs.fed.us

Or sent by postal mail to:

Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391

Be sure to state "Plan Amendment" in the subject line when providing electronic comments, or on the envelope when replying by mail. ​
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Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391

March 25, 2018

RE: Forest Plan Amendment

Dear Supervisor Olsen,

Thank you for the opportunity to submit comments on the proposed Forest Plan Amendment with regards to Indiana bats and other federally listed species. The following comments are being submitted on behalf of Kentucky Heartwood and the Center for Biological Diversity. 

To begin with, we have no immediate concerns with the proposal to update definitions in order to bring the Forest Plan in to alignment with current U.S. Fish and Wildlife Service (USFWS) terminology. This is reasonable and prudent. We do have concerns regarding changes to restrictions or parameters in the Forest Plan affecting vegetation management, and logging in particular. The removal or reduction of protective measures with regards to Indiana and northern long-eared bat maternity colonies are particularly worrisome. Both of these species of bats are in sharp decline, and immediately imperiled. The possibility that the Daniel Boone National Forest would change Forest Plan standards in such a way as to increase the probability of impacting or destroying a maternity colony is not something that we find acceptable. The loss of a single maternity colony at this juncture could be catastrophic.

The following are questions and concerns that should be addressed in the environmental analysis for the Plan Amendment:

1) What are the current protocols for identifying maternity colonies or other active roosts? When during planning and harvest operations are surveys made, and by whom? What training is received by personnel to identify active roosts?

2) How often have maternity colonies been found in project areas? Following the identification of Indiana (and northern long-eared) bats, how did the Forest Service modify or delay specific projects and operations in order to comply with Forest Plan Standards? Please be specific. 

3) Please provide ample scientific evidence demonstrating that the newly proposed Forest Plan standards (e.g., changes to basal area standards, snag retention, seasonal harvest restrictions relating to habitat occupancy, etc.) are more or as protective for federally-listed bat species as the current plan standards. It does not appear to us that they are. 


We expect the Forest Service to commit to a thorough, detailed, and reasoned analysis with regards to any changes to Indiana and northern long-eared bat management on the Daniel Boone National Forest. Any changes to the Forest Plan should be firmly rooted in evidence that future management will be as or more protective of Indiana and northern long-eared bats as the current procedures. 

Sincerely, 

Jim Scheff, Director
Kentucky Heartwood
P.O. Box 1486
Berea, KY 40403

(859) 334-0602
jim@kyheartwood.org

The Daniel Boone National Forest has proposed to amend the forest's 2004 management plan with respect to the federally endangered Indiana bat. The Indiana bat (Myotis sodalis) was first listed as an endangered species in 1967, and has been in decline ever since. Since 2006, the spread of the disease White Nose Syndrome (WNS) has caused remaining populations of Indiana bats (as well as other species of bats) to crash. 

Some of the Forest Service's proposed changes simply align terms and criteria with those currently in use by the U.S. Fish and Wildlife Service. However, the Forest Service is also proposing to loosen several protective standards that limit timber harvest near maternity colonies of both Indiana bats and northern long-eared bats (Myotis septentrionalis). Northern long-eared bats are listed as threatened under the Endangered Species Act on account of catastrophic declines from WNS.

One of the reasons provided by the Forest Service of the need for change is that logging restrictions near maternity colonies during the summer roosting season mean that more logging has to take place during the wetter winter months. But over last decade, several aquatic species have been listed as threatened or endangered, meaning that sedimentation of streams from logging has to be taken more seriously. For example, the Forest Service just proposed around 3,000 acres of intensive logging on steep slopes in the Redbird District in designated Critical Habitat for the Kentucky Arrow Darter, which was listed as threatened under the Endangered Species Act in 2015. The Redbird District includes most of the remaining habitat for this species. We'll post more about the South Redbird Project in the near future.

The bottom line is that the only changes the Forest Service should be making with respect to Indiana and northern long-eared bats are those that are demonstrably protective and support their populations. These important, imperiled species cannot afford the loss of a single maternity colony - especially to facilitate logging on our public lands.

For now, the Forest Service is accepting comments on their proposal until Monday, March 26th. The agency will likely prepare an Environmental Assessment sometime in the near future.

Links to project documents can be found on our website here, and the Daniel Boone National Forest website here.

Here is a link to the page on the Daniel Boone National Forest website where the public can comment on this proposal. Comments are due by 3/26/2018.

Comments can be emailed to: comments-southern-daniel-boone@fs.fed.us

Or sent by postal mail to:

Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391

Please state "Plan Amendment" in the subject line when providing electronic comments, or on the envelope when replying by mail. 

Here is where you can read comments that have been submitted by the public.