Wild places sustain and define us; we, in turn, must protect them.
The Daniel Boone National Forest is currently taking comments on the Draft Environmental Assessment (EA) for the Pine Creek Forest Restoration Project. This is a complicated project, which proposes intensive and damaging logging on thousands of acres of forest, but also includes plans for beneficial restoration and management for rare species and natural communities. Below you will find a breakdown of the main proposed actions to help inform your comments to the Forest Service. Comments are due by Wednesday, September 4th, 2019. Directions on how to submit comments are the end of this post.
You can read our May 2018 comments to the Forest Service on an earlier draft (scoping) of the Pine Creek proposal here. Video of a presentation that we gave in Corbin in January 2019 can be found here.
The Pine Creek project covers 45,700 acres of the Daniel Boone National Forest in Laurel, Pulaski, and Rockcastle counties. The area is centered on the lower Rockcastle River, from near I-75 to the confluence with the Cumberland River. This area includes some of the most popular recreation spots in the Daniel Boone, including Bee Rock, Rockcastle Recreation Area, Little Lick, Scuttle Hole, the Sheltowee Trace National Recreation Trail, Pine Island Double Falls, and the Wild River segment of the Rockcastle River. The area also includes a wide diversity of forest types and rare species, including some of the best old-growth and mature second growth forests in the Daniel Boone. The Forest Service first proposed the Pine Creek project in February 2018. Since the initial proposal the agency has made some improvements, but there are still major problems that need to be addressed.
The Bad Stuff:
Shelterwood logging on 1,300 acres for early seral habitat
Our most significant concern with the Pine Creek project is the Forest Service’s intent to log 1,300 acres for early seral habitat (young forest) using shelterwood methods (Action 1.A: Two-aged shelterwood). A shelterwood cut is a type of “regeneration” harvest where about 90% of the trees are cut. The Forest Service says that individual shelterwood cuts would be limited to 40 acres each, but some of these logging areas would be clustered to create logged areas of several hundred acres. The Forest Service originally proposed to approve an additional 2,000 acres of shelterwood harvests that would occur after 10 years (in stands managed under Action 5: Midstory removal), but has since agreed to drop logging these acres from the proposal.
Early seral habitat is important for a wide range of species. However, there are less impactful ways to create and manage for this type of habitat that are more consistent with prevalent natural disturbance regimes. For example, research from the University of Kentucky has shown that logging small, roughly half-acre patches of trees, along with light thinning around the edges (also known as “femelschlag” or “expanding gap” systems), can result in much better oak regeneration than large even-aged harvests like those proposed in the Pine Creek project. While uneven-aged and lower impact methods like expanding gap management could meet the Forest Service’s habitat and multiple-use goals, these methods don’t produce as much timber.
We strenuously urge the Forest Service to drop the proposed shelterwood harvests and instead manage for early seral habitat and oak regeneration in the following ways:
1) Manage the nearly 5,000 acres of forests harvested in the project area since 1980. Many of these areas are now forests of poor quality, with prior logging resulting in conversion of oak-hickory forests to tulip poplar and red maple. Expansion and modification of “Action 6: Crop tree release” could meet the Forest Service’s goals for early seral habitat;
2) Support the existing proposal for 980 acres of commercial and non-commercial management to restore fire-adapted woodland community types (Action 2: Woodland and wooded grassland/shrubland communities);
3) Support variable thinning along certain roadsides to create early seral and edge habitat and support rare species on 280 acres (Action 9.B: Roadside thinning);
4) Consider uneven-aged management with small group selection using expanding gap or femelschlag prescriptions where the above approaches aren’t sufficient.
The Good Stuff:
The Forest Service is doing a lot in Pine Creek project that we largely support, and have made some changes since their original proposal that make it better. While Kentucky Heartwood generally opposes logging in our national forest lands, this project does include some commercial thinning prescriptions that offer a reasonable approach for restoring and supporting rare and declining species and natural communities.
1) The Pine Creek project proposes using a variety of methods, including non-commercial and commercial tree removal and prescribed fire to restore upland, fire-adapted wooded grassland and shrubland communities (“woodlands”) in areas that were identified through collaborative work with the Kentucky Office of Nature Preserves, Kentucky Heartwood, and The Nature Conservancy (Action 2: Woodland and wooded grassland/shrubland communities). Most of the areas identified in the proposal for woodland management are good, or at least reasonable, choices given the specifics of the existing and historical vegetation.
Integrated with the woodland restoration is the proposed restoration of shortleaf and pitch pine communities (which were decimated by the southern pine beetle 20 years ago) through “cluster planting” of pine seedlings. Unlike prior pine restoration activities on the Daniel Boone that are more akin to plantations, “cluster planting” would restore a pine component in a manner that supports mixed species, spatially diverse stands.
2) The Forest Service added to the proposal, as a response to input from Kentucky Heartwood and others, Action 8.D, which would approve thinning of the forest along the margins of a 1-mile section of powerline right-of-way that contains good quality native grassland remnants (read about the Cumberland Barrens here). Combined with ongoing application of prescribed fire, this management would create a gradient, or “ecotone,” between the native grassland remnants restricted to the right-of-way and the closed-canopy forest adjacent to them. This approach, which leverages existing native grassland flora as indicator species and seed source, offers a viable bridge between the Forest Service’s logging mandate and legitimate ecological restoration efforts. The Draft EA states that “If this activity successfully achieves the desired habitat condition, it may be replicated along other ROWs through separate project planning.” We have been working with the Southeastern Grasslands Initiative to promote a similar emphasis at Land Between the Lakes.
3) In response to our earlier comments, the Forest Service has proposed relocating 1 mile of the Sheltowee Trace National Recreation Trail off of Poison Honey Road and in into the forest, while also buffering trails and recreation areas from logging impacts (Action 9.D).
4) The Forest Service has also added Action 9.C to close and rehabilitate up to 23 miles of user-made trails that are negatively impacting the Rockcastle River.
The “Sounds Good But is Actually Underwhelming” Stuff:
The Forest Service has proposed adding 500 acres of “Designated Old-Growth” in the project area. This is good. However, the Forest Service has restricted these old-growth additions to hemlock mixed mesophytic forests below cliffline (where logging is already restricted), and neglected to allocate any upland forest communities to the old-growth management prescription. While the Draft EA points out the project area already includes 830 acres of an existing “Designated Old-Growth” prescription area, that particular area doesn’t actually include any old-growth or near- old-growth forest. Most of the best upland forests meeting, or nearing, operational old-growth definitions are being left out of the Designated Old-Growth management prescription. We wrote extensively about our old-growth concerns in our previous comments on the project in 2018, which can be read here.
Comments on the Pine Creek project are due by Wednesday, September 4th, 2019.
Comments can be submitted through the Forest Service’s web portal here or emailed to: SM.FS.firstname.lastname@example.org
Comments can also be sent via postal mail to:
Jason Nedlo, District Ranger
761 South Laurel Road
London, KY 40744
Official project documents can be found on the Forest Service’s website here.
More information can be found on the Kentucky Heartwood page here.
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