Dear Citizens,

Kentucky Heartwood staff is chipping away at comments for the Red River Gorge Management Planning process. After submitting our first electronic comment, we noticed that comments are actually due by July 26, 2021 by 11:59 pm. This gives the public a little more time to get some comments in! 

Please see our comments below concerning the draft Environmental Assessment and Finding of No Significant Impact for the Red River Gorge Management Plan. 

Here are some specific issues you may want to address in your comments:

• The Forest Service should not violate the Wilderness Act by establishing up to 75 campsites in Wilderness. While the conditions in the Clifty Wilderness are declining, trammelling Wilderness is illegal. "Trammelling" refers to harnessing Wilderness, not trampling the Wilderness. These two ideas are distinctly different. The Forest Service is moving too quickly to absolutely last resort options. See our comemnts for more details.
• The Forest Service needs to obtain and provide consultation and/or concurrence letters from the United States Fish and Wildlife Service and the Army Corp of Engineers before signing an Environmental Assessment and Finding of No Significant Impact. Adaptive management does not allow the agency to push consultation off to a post-decisional process. Please provide these letters on the project documents page on the Daniel Boone National Forest website.
• The Forest Service needs to provide site-specific locations for all campsites, trails, bathrooms (mainly out of floodplain and riparian areas), and other various proposed amenities.
• The Forest Service does not adequately discuss the impacts of rock climbing in any of the plans, though we suppprt that they are sticking to the Forest Plan which states no new bolts or anchors shoudl be placed in the Clifty Wilderness.The Forest Servcie needs to create a Climbing Management Plan for the Red River Gorge and extend the plan to the whole Daniel Boone National Forest.

​Please see our full comment below.

If you wish to submit a comment, please use the following options:

Send in a public comment by July 26, 2021 at 11:59 pm.

Submit an electronic comment here:

https://cara.ecosystem-management.org/Public/CommentInput?project=59892

Submit an email to comments-southern-daniel-boone-cumberland@fs.fed.us

Please place “Red River Gorge Management Planning-Administrative Change” in the subject line.

Mail a letter and postmark it by July 23, 2021 to:

Jonathan P. Kazmierski
Cumberland District Ranger
2375 KY 801 South
Morehead, KY 40351

The Forest Service is conducting two management plan overhauls for the Red River Gorge Geological Area and the Red Wild and Scenic River. They are concurrently seeking comment to fix what they call "clerical errors" in the Forest Plan to the boundary of the Red River and changing the Scenic Integriy Objectives of the Red River Gorge. However, the proposed fixes to these clerical errors could change certain aspects of the management of the Red River and the Red River Gorge. 

But first, it's important to review the purpose of the forest plan to understand the implications of the proposed administrative changes. 

What is a Forest Plan?

A Forest Plan is a land management document that sets measurable and enforceable standards to help the Forest Service meet their stated objectives. Every national forest has a plan. Forest Plans are legally binding documents, but the Forest Service is allowed to make administrative changes their forest plan outside of the revision process. However, they must provide notice and a public comment opportunity before altering their plan. 

What is the Forest Service proposing to change in the plan?

The Forest Plan for the Daniel Boone National Forest describes the boundaries and allowable management actions for the Red Wild and Scenic River and the Red River Gorge Geological Area. The Forest Service is proposingn the following administrative changes: 

1) Change the boundary of the Red Wild and Scenic River

2) Downgrade the Scenic Integrity Objective (SIO) of the Red River Gorge Geological Area from ‘Very High’ to ‘High’ 

Boundary change to the Red Wild and Scenic River

The Forest Service is proposing to drop 86 acres from the boundary of the Red Wild and Scenic River. According to the Forest Service this is an acreage drop on the landscape around the river that falls in line with the Kentucky Wild River boundary established by the Commonwealth of Kentucky back in 1973. 

The Red River was federally protected as Wild and Scenic by Bill Clinton in 1993 and used the state legistion to demarcate the boundary. There is also federal legislation that mandates wild and scenic river protections. The Wild and Scenic Rivers Act is federal legislation designed to safeguard the character of our nation’s unique rivers.The Act sets aside certain rivers that possess outstandingly scenic, recreational, geologic, fish and wildlife, historic, cultural or other similar values, to be preserved in free-flowing condition, and protects immediate environments for the benefit and enjoyment of present and future generations.

Let’s dig into “immediate environment”. If a river is designated ‘wild’ then development should not be visible from the river. If a river is designated as ‘scenic’ the Act allows for minimal development. It’s meant to protect the character of a federally-designated river. 

Here’s the problem. The Forest Service provided a map of the proposed changes, but they did not provide an adequate map to show the Red River’s current boundary. The public has no way of knowing where the Forest Service wants to drop the 86 acres.
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• How will this boundary change impact the immediate environment?
• Private property surrounds the Daniel Boone National Forest, particularly the Red River in this instance. Will a house pop up in the wild and scenic river viewshed because of the boundary change? We can’t tell from the maps provided. 

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This is the current map in the Forest Plan that the Forest Service references (but does not provide in the project documents) to help the public understand the current boundary of the Red Wild and Scenic River:

​This is the map of the proposed changes to the boundary around the Wild and Scenic River provided in the plans for the Red River:

There is no way to compare these maps. How is the public supposed to submit substantive comments regarding the boundary changes with two maps varying in quality? The Forest Service needs to provide a clear map of the current boundary so citizens can see where the boundary changes may impact the imminent environment around the Red Wild and Scenic River.

Downgrading the Scenic Integrity of the Red River Gorge Geological Area

The Scenic Integrity Objective (SIO) is defined as the desired level of scenic quality and diversity of a landscape based on physical and sociological characteristics of an area. SIO indicates the degree of acceptable visual impact that human activity can have on a landscape. SIO levels include: Very High, High, Moderate, Low, and Very Low. These Scenic Integrity Objectives by prescription areas for the Daniel Boone National Forest are found in the Forest Plan.
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Here’s an example of measuring the SIO of an area:

The Forest Service claims that a typographical error in the 2004 Forest Plan incorrectly categorized the Red River Gorge Geological Area as ‘very high’ when they claim it should be categorized as ‘high’. Curiously, the Forest Service did not propose to downgrade the SIO when they completed the last Limits of Acceptable Change and management plan in the Red River Gorge in 2008.

​Some questions:

• If the Forest Service changes the SIO, will it allow them to develop more in the Red River Gorge?
• How will this downgrade impact the ecological and archeological characteristcs of the Red River Gorge?
• Could this potentially downgrade the SIO even further in the future to ‘moderate’ or ‘low’ without enforcement?
• Is it a sign that the Forest Service abdicated its responsibility for too long and allowed the public to cause irreparable harm to a federally designated landscape? How will they enforce laws in the future?
• If the Forest Service were to close trails, would the Red River Gorge be able to rest and naturally restore itself to a very high SIO?

Keep in mind that a Forest Plan is a legally binding document. The only way the Forest Service can achieve their plan to develop the Red River Gorge is to change their Forest Plan so they don’t violate any standards.

Here is the link to the project page:

https://www.fs.usda.gov/project/?project=59892​

Please submit a public comment and be sure to include the following as well:

• Ask the Forest Service to provide a detailed map of the Red Wild and Scenic River boundary as it exists now so the public can compare the proposed boundary to the actual boundary.

 

• Ask the Forest Service how they will keep the Red River Gorge and the Red River from declining further down the Scenic Integrity Objective scale, especially since the Forest Service is proposing more permanent development, including providing more amenities. 

   

• Also, include your personal experience in the Red River Gorge. The Forest Service cannot rebut an individual’s experience. 

Now is the critical time to ask quetions about the proposed amendments to the Forest Plan. There is no objection process to these administrative changes so we must pressure the Forest Service to explain how seemingly inoccuous these administrative changes really are. 
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The bottom line is the Red River Gorge Geological Area and the Red Wild and Scenic River were given special designations because they exhibit characteristics that are found no where else in the United States. We need to know how the Forest Service’s proposed administrative changes will further impact a well-loved area that is, frankly, taking a beating from our undying affection.

Send in a public comment by July 26, 2021 at 11:59 pm.

Submit an electronic comment here:

https://cara.ecosystem-management.org/Public/CommentInput?project=59892

Submit an email to comments-southern-daniel-boone-cumberland@fs.fed.us

Please place “Red River Gorge Management Planning-Administrative Change” in the subject line.

Mail a letter and postmark it by July 23, 2021 to:

Jonathan P. Kazmierski
Cumberland District Ranger
2375 KY 801 South
Morehead, KY 40351

Kentucky Heartwood submitted these comments to the Forest Service: