The Forest Service has proposed yet another major logging project on the Daniel Boone National Forest to wrap up 2019. But this time they won’t tell you where they're going to log. 

Comments on the Environmental Assessment for the “Improving Conditions in the Blackwater Watershed” are due this Friday, December 27, by 11:59 pm.  This comment period comes on the tail of the South Redbird comment period and approval of the Pine Creek project. Together these projects would approve about 8,000 acres of logging on the Daniel Boone National Forest. 

The Blackwater project would approve logging on 1,200 acres per decade, forever, on national forest lands on the east side of Cave Run Lake. In a new twist, the Forest Service wants to approve this open-ended logging project without first identifying any specific locations where they will actually sell the timber, build roads, or perform other management. Instead, the Forest Service is attempting a new (and legally problematic) process called “condition-based management.” Under this new system, the Forest Service won’t provide any site-specific information or analyze site-specific effects before determining if there will be any major environmental impacts and, ultimately, approving the project. The Forest Service says that they will involve the public in identifying areas for logging after their formal decision is made to approve project –  despite having worked for over the past three years to develop this proposal. Does this make sense to you?

The Blackwater proposal includes three Proposed Actions: 

The first Proposed Action is logging “to support wildlife by providing a diversity of forest conditions.” Most of this logging will be large, even-aged shelterwood harvests where most of the trees in any given site will be cut. Log landings and skid roads will be constructed. The logging is proposed across large zones totaling about 12,000 acres. Logging could happen just about anywhere in these 12,000 acres with the exception of cliffline and riparian buffers. The Forest Service states that they may build an undisclosed mileage of new roads in undisclosed locations, but that this is not significant because it will be offset by closing a similar mileage of other undisclosed roads.
​
Kentucky Heartwood has been collecting data from sites previously logged on the Cumberland District, and across the Daniel Boone National Forest, demonstrating that the Forest Service’s logging program has resulted in degraded forests – converting them from largely oak and hickory dominated forests to red maple and tulip poplar. The Blackwater proposal includes no management to restore previously logged areas.

The second Proposed Action is to improve access to the national forest “by enhancing parking and upgrading road maintenance to allow for more public motor vehicle use.” The Forest Service only provides one map showing road segments where “enhancements” and “upgrades” might happen. Conveniently, these same road sections will need upgrading to haul timber. The Forest Service also states that some gated roads “may be considered for seasonal opening to motorized traffic.” But they do not say which segments, whether they will open them, when, or what the effects will be. Again, this is the level of detail being provided in the full Environmental Assessment, which is the basis for making a final decision on the project.
​
The third, and last, Proposed Action is “Improving water quality through stream restoration and stream crossing improvements.” This could be great. But it’s really not clear. The Forest Service provides one map showing what we estimate to be about 16.8 miles of streams in nine watersheds where restoration “may” and “could” occur. No specific stream lengths, prioritization of sites, or other benchmarks are provided. But, as with logging, the Forest Service treats this lack of detail and clarity as if it doesn’t matter. The Forest Service could restore 0.5 miles in just one stream, or 16.8 miles across 9 watersheds, and it’s all treated the same in the Environmental Assessment.

​
​Prescribed fire is not included as a Proposed Action in the proposal. However, the Forest Service refers to prescribed fire in one table in the Silviculture Report, where they indicate what returning intervals will be used. And the Hydrology Report describes prescribed fire as part of the proposal, recognizing that firelines will be constructed. However, nowhere else in the Environmental Assessment is prescribed fire discussed. It’s not included among the Proposed Actions, and there are no maps showing where prescribed fire would occur. Prescribed fire could be beneficial. It might not be. Prescribed fire affects forest structure, regeneration, species composition, and wildlife in differential ways. The details matter. Either the Forest Service is proposing to approve prescribed fire, and in specific locations, or they’re not. This mushy, opaque analysis is simply not acceptable. 

It is important for people to submit comments on this proposal. You don’t have to be intimately familiar with this part of the Daniel Boone National Forest to have valid, authentic input on this proposal. These are your public lands. It is especially important that the Forest Service receive comments opposing their use of the “condition based management” approach. The Forest Service needs to provide a specific proposal, with specific management objectives in specific places. If they can’t provide this level of detail then they’re not ready to make an informed decision to approve and implement the project.
​
The reality is that the Forest Service is trying to get out bigger logging projects, and more quickly, without having the fiscal and personnel resources to do a thorough and appropriate analysis. So they’re taking shortcuts to get their numbers up, and not just here in Kentucky. Right now the Forest Service is working to approve 60,000 acres of logging across 160,000 acres of the Chattahoochee National Forest in Georgia under this same “condition based management” system, failing to provide site specific information about what they plan to do and where. The Forest Service is also working to amend their regulations for implementing the National Environmental Policy Act (NEPA) to codify “condition-based management” as the way forward for analyzing timber projects on national forest lands across the country.
 
Comments on the Blackwater need to be submitted to the Forest Service by Friday, December 27th.

Comments can be submitted through the Forest Service’s website portal here.

​Official project documents can be found here.

You can read comments that have been submitted by the public, here.

Comments can also be submitted by postal mail to:
​
District Ranger Jonathan P. Kazmierski
2375 KY 801 South
Morehead, KY 40351
Attn: Improving conditions in the Blackwater Watershed
​

​Feel free to copy kentuckyheartwood@gmail.com on your comment email. 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, please note that commenting on this blog post does not send your comment to the Forest Service.

If you value this work, please consider donating to Kentucky Heartwood. The Forest Service's decision to release multiple large projects at the end of the year has really hindered our end-of-the-year fundraising efforts. We're a small group, and every bit helps. You can donate on our website here. Thanks!

The Forest Service is proposing to log 3,650 acres of the Redbird District of the Daniel Boone National Forest in Clay and Leslie Counties. Comments on the Draft Environmental Assessment (EA) of the South Red Bird Wildlife Enhancement Project (South Redbird project) are due this Friday, December 6th. This is a bad one folks, and we really need your help letting the Forest Service know that what they’re planning isn’t acceptable. Directions on how to comment are at the end of this post.

Over the last few years the Forest Service has been logging the nearby Group One Redbird project, implementing the same prescriptions on the same slopes and soils that they’ve proposed for the South Redbird project. And the results? Mountainsides bulldozed into oblivion, landslides, erosion, and  severe infestations of invasive species. The purpose? According to the Forest Service, it’s about forest health and habitat improvement.
​
In this post you’ll see pictures from several recent logging sites in the Group One project. The bulldozed “roads” in the pictures are skid trails. Most of the logging units in the Group One project are about 20 to 50 acres. In South Redbird, some logging areas would be from 200 acres to over 350 acres across. The Forest Service says that they may build up to 91 miles of these “skid trails” to remove timber in the South Redbird project, along with 150 log landings. As much as we'd love to fill this page with more pictures of some beautiful, at risk sites in South Redbird, we think it's important for you to know exactly what the Forest Service is calling "habitat improvement" and "forest health" in the Redbird District.

We’re sending this alert so out late in the comment period because the Daniel Boone National Forest decided to release several major projects to the public at that same time. The Forest Service sent out notice of the 30-day comment period on the Draft EA for South Redbird on November 6th while we were working on our administrative objection to the Pine Creek project, which was due November 18th. And then on November 12th, the Forest Service sent out notice of the 30-day comment period for the Draft EA for Blackwater Project on the Cumberland District. We managed to get a 2 week extension on the Blackwater comment period, and you’ll be seeing information from us on that soon. Together these projects would approve about 8,000 acres of logging across the Daniel Boone National Forest. 

​Most of the streams in the South Redbird project are designated as Critical Habitat for the Kentucky arrow darter (Etheostoma spilotum), which was listed as “threatened” under the Endangered Species Act in 2016. The project area also provides habitat for the federally-endangered snuffbox mussel (Epioblasma triquetra). The Forest Service insists that these species won’t be harmed by logging because of protective standards in the Forest Plan. However, we’ve documented numerous instances in the Redbird District where Forest Plan standards and state best management practices were woefully inadequate, or otherwise completely ignored to strip the mountains of their timber. 

​There is one positive thing. We convinced the Forest Service to drop logging of the old-growth forest that we documented on the 46 acre Little Flat Creek site. You can read about our work on the Little Flat Creek site on page 6 of our Spring 2019 newsletter. Oddly enough, the Forest Service still won’t admit that it’s old-growth, insisting that it’s a young forest about 65 years old. However, our structural and age analysis demonstrates that it’s a multi-aged, old-growth forest, with many canopy trees from 150 to over 300 years old. Sadly, throughout the Draft EA for the South Redbird project the Forest Service demonstrates startling ignorance and hostility toward old-growth forests.

​Young forests and early seral habitat are important. But the Forest Service can manage for these habitat types without bulldozing and destroying whole mountainsides. In May 2017, the Forest Service led a field trip during the development of the South Redbird project to show off successful management for early seral habitat. The site that they chose to highlight was a non-commercial unit in the Group One project, where trees were cut but no skid roads and landings were used to haul out the timber. Clearly this is a viable option.

As part of the South Redbird project, the Forest Service has also proposed harvesting trees along 45 miles of roadways, adding up to 750 acres of logging. For the most part, that management could be done without bulldozing skid roads through forest. It’s not ideal, but does offer a reasonable approach that limits the more severe impacts that are likely to occur. The Forest Service also has the option of creating early seral habitat by managing the nearly 6,000 acres of the project area that were logged in the 1980s and 1990s.

​Our surveys have demonstrated that those forests are dominated by tulip poplar and red maple, despite the Forest Service arguing that big cuts like these are needed to promote oak regeneration. The Forest Service could modify their proposed “crop tree release” on 1,900 acres of these old logging sites to cut back the young tulip poplar and maple more heavily, supporting oaks and hickories while creating and enhancing early seral and young forest habitat, especially for grouse. These are all viable options that the Forest Service can use to meet their goals.  

​Kentucky Heartwood will be submitting detailed comments, where we’ll dig deep on the details. Comments from the public are also needed and very important. Please let the Forest Service know that the commercial logging prescriptions in the South Redbird project are not acceptable. Let them know we’re watching.

Comments need to be submitted this Friday, December 6th by midnight.

Comments can be sent directly on the Forest Service’s project page here or by emailing SM.FS.r8dbredcom@usda.gov.

You can read comments that have been submitted by the public, here.​

Be sure to include “South Red Bird Wildlife Enhancement Project” in the subject line.

Comments can also be postal mailed to:
​
Robert Claybrook, Redbird District Ranger
91 Peabody Road
Big Creek, Kentucky 40914

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, please note that commenting on this blog post does not send your comment to the Forest Service.
​

If you appreciate this information, and the work that we do, please consider supporting Kentucky Heartwood with a contribution!  We've honestly been too busy with these projects to do any end of the year fundraising.

We're a small group and every donation helps.

Please donate via our website here, where you will find options for monthly, online, and mail in donations. 

Thank you!