Wild places sustain and define us; we, in turn, must protect them.
What’s going on in Jellico?
Jellico is a part of the Cumberland Mountains on the Kentucky-Tennessee border. Topping out at about 2200 feet, they are more mountainous than the rest of Daniel Boone National Forest. The area provides critical habitat for several threatened and endangered species, including the Cumberland darter (Etheostoma susanae), Blackside dace (Chrosomus cumberlandensis) and Indiana bat ( Myotis sodalis).
Resource extraction has already had a heavy toll on this forest. Nearly 2,700 acres were logged in the 1980s and 1990s. In 2011 the Bureau of Land Management and U.S. Forest Service leased over 3,800 acres for oil and gas development. And legacy impacts from coal mining, along with significant problems with invasive plant species, add to the challenges of protecting and restoring this unique area.
The recent Jellico Virtual Field Trip presented by the Forest Service is part of their Integrated Resource Management Strategy (IRMS) planning process for the Jellico mountains in the southernmost part of the Daniel Boone National Forest. The area that the Forest Service is looking at includes nearly 270 acres of forest that could qualify as secondary old-growth (over 120 years old).. None of this older forest is protected in the area’s “Designated Old Growth” area despite meeting tree size and age requirements.
We know from past experience that these IRMS processes almost always turn into massive logging projects, like South Redbird, Blackwater, and Pine Creek. That’s why Tennesse Heartwood, Tennessee Chapter of the Sierra Club, and Kentucky Heartwood submitted a joint Freedom of Information Act (FOIA) request several months ago to better understand the Forest Service’s plans and inform the public about them. We are happy to have finally received the documents we requested because the Virtual Field Trip does not provide enough information about the Forest Service’s plans. Much of the information discussed below is based on our review of the Freedom of Information Act documents, where we found much more information than the Forest Service has ever shared publicly about their plans for this area of the forest. Much is still in the air though. A lot of the following information is based on which forest stands the Forest Service has been scouting for soil issues associated with logging as revealed by the Freedom of Information Act data. We assume they would not do this unless they were planning on doing commercial logging but the Freedom of Information Act data is not clear on this. Hopefully by being proactive we can prevent them from investing more time and energy into prospecting to log the most problematic forest stands.
There are clearly concerns about soil instability, as evidenced by field notes from Forest Service staff. More of this specific information should have been shared in the virtual field trip but instead it was underplayed with a quick video and generic document. The seriousness of this issue is made clear by the slope data obtained by the Forest Service for forest stands being scouted for logging. According to the table given within the slope data document the majority of the potential logging sites average 50% slope with some as high as 75%. These steep slopes intersect 2 or 3 coal beds. According to the Forest Service's own soil scientist, coal beds under steep logged slopes have high landslide risk as trees' roots decay.
Landslides not only erode precious soils which can leave an area barren for decades to come, but they also damage waterways through sedimentation. This is especially problematic and illegal when streams have threatened and endangered species that are sensitive to sedimentation. Jellico mountain has two such species that are found nowhere else in the world. They are the Cumberland Darter and Blackside Dace, and they are federally protected by the Endangered Species Act. Sadly this has not stopped the Forest Service from logging steep landslide-prone areas in the past.
Figure 1: Coal Beds on Steep Slopes Prone to Landslide into Critical Streams
Wolf Creek - Critical Threatened and Endangered Species Habitat.
Further evidence for this landslide risk is given by U.S.D.A's own publicly available soil data that suggests soils in the proposed harvest area are low strength and therefore not strong enough to support loads. This U.S.D.A. soil data was created to explicitly rate the soils' suitability for use of timber harvest equipment. Almost the entire Jellico mountain region is rated as the poorest suitability level for using timber harvest equipment
Figure 2 and Table 1: Timber Harvest Equipment Suitability.
Red= Poor; Yellow= Moderate
Source USGS Web Soil Survey accessed March 10th 2022
This is how the USDA suggests interpreting "poorly suited":
"Ratings for this interpretation indicate the suitability for use of forestland harvesting equipment. The ratings are based on slope, rock fragments on the surface, plasticity index...
"Moderately suited" indicates that the soil has features that are moderately favorable for the specified management aspect. One or more soil properties are less than desirable, and fair performance can be expected. "Poorly suited" indicates that the soil has one or more properties that are unfavorable for the specified management aspect. Overcoming the unfavorable properties requires special design, extra maintenance, and costly alteration."
Recommendations to Forest Service
Given the risk to federally protected species as well as violating the National Forest Management Act diversity clause (16 U.S.C. 1600 § 6(g)(3)(B)) and soil protections (16 U.S.C. 1600 § 6(g)(3)(E)), logging should not be done on steep slopes with coal beds.
Appalachian Gentian, or Gentiana decora, is a very rare plant found by Kentucky Heartwood within the project area. It is ranked g4 globally which means it is very vulnerable to extinction. It is ranked s3 for Kentucky which means there are less than 100 occurrences of it and therefore vulnerable. It was found in the cliffline of a designated old-growth area which means it does have protection from logging. There were no records of this sensitive species, and it brings up the question of what else might be out there that the Forest Service doesn't know about, especially given what a biological wonder Jellico Mountain is. It is important the Forest Service refers to the "Cooperative inventory of endangered, threatened, sensitive and rare species, Daniel Boone National Forest, Stearns Ranger District" before conducting any logging operations to ensure it maintains viable populations of sensitive plants in accordance with the diversity requirement of the National Forest Management Act. This is especially important since the areas of Jellico Mountain outside of the National Forest boundary are heavily disturbed due to aggressive logging, mining and industry.
Yellowwood, or Cladrastis kentukea has been found in Jellico Forest Service stands of interest according to the Forest Service's surveys. According to a Forest Service research scientist's report "… it is a North American endemic, an ancient relict with a limited overall range, and it appears to be declining overall in the wild. It could face extirpation in the wild in several states if it is not properly protected." "In addition to species listed as endangered or threatened under the Endangered Species Act (ESA), or species of Concern by U.S. Fish and Wildlife Service, the Forest Service lists species that are Sensitive within each region (RFSS). The National Forest Management Act and U.S. Forest Service policy require that National Forest System land be managed to maintain viable populations of all native plant and animal species. A viable population is one that has the estimated numbers and distribution of reproductive individuals to ensure the continued existence of the entity throughout its range within a given planning area." The report explains it is a listed species by the Forest Service.
Yellowwood grows as an understory tree in mature forests. Therefore the entire stands that they are in should not be logged in order to give them a small buffer of intact forest. Two of the three stands that yellowwood was found by the forest service are being scouted to be logged.
The Freedom of Information Act data revealed that seven of the stands that the Forest Service is planning to log are over 120 years old according to their own stand inventory data. These stands represent the kind of diverse beautiful forest that has some of the highest conservation value. They are also older than what the Cumberland district decided was too old to log in their Blackwater project. In total, this represents hundreds of acres, including at least a hundred acres in landslide-prone areas over critical stream habitat for threatened and endangered species.
Kentucky Heartwood, in collaboration with Dr. Justin Maxwell, a permitted research scientist, cored several trees in the oldest stands being scouted to log and found extremely old oaks, black gum and tulip poplar. Many individuals were well over 150 years old, and one black gum was even pushing 275 years old. In addition the diameter (DBH) of the tulip poplar trunk cored was over 3 feet wide. Not only does this give you an idea of its impressive size, but its width and age qualify it to be considered for old growth designation by the Forest Service and protected from logging.
Not only do stands over 150 years of age act as an disproportionately large carbon store they are also incredibly rare in themselves constituting a fraction of a percent of the total forest.
All this is why we are encouraging the Forest Service to create a 1,449 acres patch of designated old growth in the Kengee Hollow area. This would meet region 8 old growth guidance for creating additional satellite patches of old growth to meet landscape-level conservation needs. It would also prevent landslides and destruction of threatened and endangered aquatic species. In 2020 the Stearns district won the district of the year award for the Southern region. It shouldn't let Cumberland district outperform it in terms of meeting the evolving ecological and social needs of its district.
In 2019, the Daniel Boone National Forest used something called condition-based management for the first time for the Blackwater project near Cave Run Lake. This method undercuts the National Environmental Protection Act’s requirement to get site-specific feedback from the public on logging projects. More recently in 2020, the federal courts in Alaska ruled that logging with condition based management is illegal. We hope the Forest Service will take this ruling seriously and will not try to use condition-based management on the Jellico project.
There are no hiking trails in the entire Jellico region. The Forest Service reports that the area is primarily used for (unauthorized) off-road vehicles, and noted that their extensive use is damaging the forest.
Additionally, there are four beautiful campsites along Jellico creek. If hiking and mountain biking trails could be developed in this area, it could provide economic development opportunities and increase public access to the forest.
Invasive species concerns
The Forest Service acknowledges that there are significant patches of tree of Heaven, multiflora rose, autumn olive, honeysuckle, and Japanese stiltgrass. Opening the tree canopy with logging will only make worse the growth of these difficult to control species, costing the public more money when the Forest Service uses herbicide and staff time to try to treat and remove them. Ultimately the most effective way to manage invasive species is to prevent their establishment in the first place and in this case that means avoiding disturbance and heavy machinery use.
The combination of unique geology, topography and ecology of the Jellico region presents nearly insurmountable hurdles to make a proposed project fit within legal guidelines. The information shared above is just the beginning. Since we did not receive the Freedom of Information Act documents until March 1, we have only had limited time to comb through them before the Jellico field trip comment deadline of March 21. However, this is not an official comment period, so we look forward to the Forest Service’s future public engagement where we can submit our comments as part of the official record. There were simply too many things that jumped out as problematic to give them all the time they deserve. These are all problems that we hope the Forest Service will work with Kentucky Heartwood and the public to remedy.
Without your support a lot of these issues would have gone completely under the radar. By supporting Kentucky Heartwood you are giving a voice to the Cumberland Darter, the Yellowwood tree and countless others so that they may stand up for their legal right to continue to exist on this earth.
Please Take Action and Comment on the Forest Service's website
We greatly appreciate the time you spent reading this and encourage you to write any thoughts or feelings you have that come to mind to submit to the Forest Service through the "Public Input" section of their virtual field trip. The last day to submit comments is this Monday the 21th. The Forest Service wants comments from people of all walks of life and not just specialists. They know very well that they are supposed to work for the public so be a good boss and tell them your perspective no matter how long or short!
The U.S. Forest Service has proposed logging up to 250 acres in areas with extreme landslide risks in the Redbird Ranger District of the Daniel Boone National Forest. Despite these known risks, the Forest Service has proposed the Hector Mountain Salvage project under a Categorical Exclusion (or “CE”), which means that the project will be fast-tracked and exempted from analysis in an Environmental Assessment. The Forest Service proposed the project on February 1, 2022 in response to ice storms that damaged trees in January 2021. The agency failed to include the project in the quarterly Schedule of Proposed Actions (SOPA). The entire announcement was limited to 6 pages and a 30 day comment period.
Logging units in the Hector Mountain Salvage project are just a few miles from the ongoing landslides in the Group One logging project that Kentucky Heartwood has been documenting and reporting on for more than two years. Our examination of LIDAR-derived topographic data and on-the-ground surveys in the Hector Mountain area have found more than a dozen landslides, mostly in stands that were harvested in the 1990s. The Forest Service has mostly downplayed the risks of landslides posed by logging in the Redbird District, and the scoping document fails to make any mention of landslide risks. However, information obtained by Kentucky Heartwood through Freedom of Information Act requests has revealed that the Forest Service has been well-aware of the specific landslide hazards in the Redbird District for a long time.
An email from a former Daniel Boone National Forest Soil Scientist to the current Forest Soil Scientist, dated November 2020, states:
“I recall inventorying over 20 slides in clear cuts on the Red Bird and all but 3 or so were associated with a coal seam. Most of these occurred around 5 years after harvest. The Fire Clay seams I recall were involved with most. I did write something up on that but I don’t have a clue if it’s still around.”
One of the specific hazards relates to the hydrology of coal seams, like the Fire Clay. The Fire Clay runs through all of the proposed logging units in the Hector Mountain Salvage project. In Redbird, these highly permeable coal layers are often underlain by relatively impermeable clays. This causes moisture to accumulate disproportionately at these specific strata. Where soils are highly erodible and slopes very steep, like across most of the Redbird District, this buildup of soil moisture can trigger landslides or other mass wasting events. Intact forest root systems help hold forest soils and slopes together, limiting the extent of any landslides and ability for sediment to reach stream channels. However, in the years following timber harvest, tree root systems die back, reducing their ability to hold soils together. And the construction of full-bench skid roads – which is common on the Redbird District – further exacerbates the issue by affecting hydrology and slope stability, especially where skid roads cross coal seams. All of this is known to the Forest Service, but has been repeatedly ignored in the Group One, South Red Bird, and now Hector Mountain projects.
Notably, the Forest Service has proposed road reconstruction on Forest Service road 1730 “to stabilize the road… and to facilitate passage of large trucks and heavy equipment.” Currently the road is safely passable by passenger vehicles. However, road reconstruction will be needed to support logging trucks and heavy equipment. What the Forest Service fails to disclose is that the instability of the road and slope is the result of a landslide that occurred when that area was logged in 1994. The landslide runs several hundred feet downslope, and the upper portion (where the road is located) is continuing to slump.
Several other landslides were found by Kentucky Heartwood in this same area of, including a major landslide that recently collapsed and resulted in large amounts of sediment and debris in the stream channel. This continuing instability is occurring nearly three decades after the stand was logged.
In addition to landslide concerns, the Forest Service has failed to provide any information on how trees will be assessed for damage and chosen for harvest, or otherwise how heavily they plan to cut the area. Most of the trees that we’ve been able to examine in the field exhibit moderate damage that is well within the trees’ ability to recover. Studies of growth rings in old-growth trees in Kentucky and elsewhere demonstrate that it is normal for very old trees to go through periods for more rapid growth followed by periods – sometimes lasting decades – of very slow growth as they recover from episodes of canopy damage. It’s unusual to examine tree ring patterns in old-growth trees and not see this pattern.
But the Forest Service’s description of the forests’ condition suggests that any damage to trees is catastrophic. In the scoping document, the Forest Service states that damage from the ice storms “has predisposed the stands to forest pathogens, insect-related diseases, reduced annual growth, reduced quality of the wood itself, and ultimately early mortality.” What is clear is that the Forest Service is primarily concerned with “reduced quality of the wood” and any reduction in annual growth.
Our forests evolved with natural disturbance events, like ice storms, and even depend on them. Most logging in the Daniel Boone National Forest is predicated on the Forest Service’s assertion that there is insufficient natural disturbance to support disturbance-dependent species, like ruffed grouse and white oak. But the impacts of the 2021 ice storm to the trees and forests in the Hector Mountain project area are precisely those that support disturbance-dependent species. And the best available science backs that up.
You can read Kentucky Heartwood’s comments to the Forest Service below. In that letter we provide more information about old-growth and natural disturbance, landslide issues, and errors in how the Forest Service is using their Categorical Exclusion authorities. The Kentucky Resources Council joined Kentucky Heartwood in submitting these comments.
Please consider supporting Kentucky Heartwood's work to respond and challenge projects like this by joining or making an extra donation. Our ability to review these projects and do the necessary on-the-ground work to see what's really happening in the forest is only possible through donations from our members and other supporters. You can donate to Kentucky Heartwood here.