By Jim Scheff, Director, Kentucky Heartwood

Our fight over the Greenwood project came to an underwhelming and, for the most part, disappointing conclusion at the end of October, 2017. Kentucky Heartwood worked for more than three years to see the project turn from a typical timber harvest toward a science-based plan that would support the restoration of relict, fire-adapted open forest communities as well as the recovery of large areas of old-growth. In July 2017, the Forest Service issued their Draft Decision Notice and Finding of No Significant Impact – a preliminary approval of the project. Kentucky Heartwood then filed a detailed, 32 page predecisional objection (a formal administrative objection) detailing a wide range of issues, concerns, and failures in the Forest Service’s analysis. In October, we had a formal meeting with Forest Service officials to seek resolution to the concerns raised in our objection. The meeting was scheduled for two hours but stretched to four hours as we delved deep in to the issues. The meeting was somewhat constructive.
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In the end, the Forest Service did agree to some small changes, and made overtures toward more careful planning in the future. While the Forest Service did not agree to go back and actually survey the project area for rare species and communities, they stated that they planned to receive increased training from the Kentucky State Nature Preserves Commission (KSNPC) on how to identify rare communities, would look for rare communities during project implementation, and adjust management accordingly. They also committed to consulting with KSNPC and Kentucky Heartwood in taking a closer look at management opportunities in the 751 Roadsides/Curt Pond Ridge area – a hotspot for Cumberland barrens remnants that are in desperate need of careful, active management, as well as possible remnant barrens sites in the Blue John area.

Another point of resolution that was addressed was the Forest Service’s prior unwillingness to provide clear targets for native versus non-native plantings in 75 wildlife openings covering 222 acres. The Forest Service has now formally clarified that they will manage for 35% in cool season grasses and grains, 20% in native pollinator mixes, and 45% in native grasses. While we would rather see all of the area managed for native vegetation, this is a clear improvement over the current condition and the vague statements made throughout the analysis. With regard to the proposed broadcast spraying of herbicides in wildlife openings, the Forest Service has agreed to apply herbicides only after vegetation has been cut down or is otherwise out of flowering in order to avoid impacts to native pollinators and birds, and to spray no more than 33% of the total acreage in a given year. Again, this is not what we wanted, but it is a meaningful improvement. 
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These changes are in addition to those that came about between the original 2014 scoping document and publication of the Environmental Assessment in early 2017. Those changes included reducing the amount of logging by about 600 acres (including eliminating logging that was planned at the trailhead to the Three Forks of Beaver Creek overlook) and the elimination of 26 miles of bulldozed firelines. 
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What is most disappointing, however, is that the Forest Service misrepresented forest conditions in many areas in order to promote logging. Several sites covering hundreds of acres that are now largely open-canopied as a result of the 1999-2002 southern pine beetle outbreak, and which have good floristic indicators of barrens or woodland type communities, will not be managed with fire or 
otherwise. Meanwhile, intact, closed-canopy hardwood forests will be cut to “restore” open-canopied and pine forests, with 139 log landings cleared and compacted to facilitate the removal of timber on over 2,000 acres.

Over the coming years we will closely monitor implementation of the project. Some species and forest communities will likely benefit – particularly if the proposed fire management is implemented carefully for appropriate, site-specific ecological responses. However, there will certainly be negative impacts, disruptions, and trade-offs for years to come.
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To learn more about the ecology of the Greenwood area and our efforts to affect change on this project, please see our Summer 2016 and Summer 2017 newsletters, as well as our comments and predecisional objection, all of which are available on our website here.

​This article was published in the Winter 2018 edition of our Newsletter. Here is a link to our Newsletter archives.

Kentucky Heartwood has filed a formal administrative objection (“pre-decisional objection”) challenging the approval of the Greenwood Vegetation Management Project on the Daniel Boone National Forest in McCreary and Pulaski counties. This project would be the largest timber project on the Daniel Boone in 13 years, and would allow commercial timber harvests on over 2,500 acres of public lands, along with a wide range of other management actions including the construction of 139 log landings, planting of shortleaf pine, herbicide use, and over 10,600 acres of prescribed fire.

The objection focuses on the Forest Service’s unwillingness to focus restoration activities in areas most impacted by the severe southern pine beetle outbreak that lasted from 1999 to 2001. The objection also addresses the agency’s failure to survey for many rare, declining, and threatened species, as well as their lack of adequate consideration in the Environmental Assessment for how management could harm or benefit these species.

“Instead of focusing restoration efforts where they’re most needed, the Forest Service is going where the timber is. This is a case of genuine restoration needs getting sidelined by the Forest Service’s continued emphasis on logging,” said Jim Scheff, Kentucky Heartwood’s Director.

National forest lands in the Greenwood project area are home to a wide range of rare and declining species, as well as unusual, rare natural communities including native grassland remnants, sandstone glades, and Appalachian seeps. Fire suppression and past logging have degraded many of these habitats, and appropriate management could help toward the recovery of some species.
Both Kentucky Heartwood and the Kentucky State Nature Preserves Commission repeatedly requested that the Forest Service survey and manage for state-listed threatened and endangered species, including rare wildflowers like Quill flameflower, Eastern wood lily, Appalachian sandwort, and Eastern silvery aster. The Forest Service asserts that they are not required to survey or manage for these species – a contention that Kentucky Heartwood has challenged in the objection.

“There are real opportunities to get this right. But the Forest Service needs to take a step back and re-evaluate their plans,” said Scheff.

The project also includes 222 acres of broadcast spraying of herbicides in wildlife openings, a matter of particular concern to some area residents.

“There are always trade-offs in land management. But we don’t think it’s acceptable to log thousands of acres of our public lands in the name of restoration, all the while ignoring many of the species and sites most in need of help,” Scheff added.

Kentucky Heartwood was joined in their objection by the Center for Biological Diversity and area residents Elizabeth and Michael Loiacono.
 
 Kentucky Heartwood was founded in 1992, and seeks to protect and restore the integrity, stability, and beauty of Kentucky’s native forests and biotic communities through research, education, advocacy, and community engagement.

 Read the entirety of Kentucky Heartwood's formal administrative objection here:

Among the proposed management actions are:
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• Commercial logging on over 2,000 acres
• Broadcast spraying of herbicides across 222 acres of wildlife openings
• 10,627 acres of prescribed fire
• Nearly 6 miles of road construction and reconstruction
• Over 100 log landings
• 37 miles of machine-constructed firelines (and 45 miles of handline)
• Midstory removals on 1,228 acres
• Non-commercial “crop tree” releases on 2,347 acres

​The Forest Service modified the proposal since originally proposed, with about 500 acres less of concerning timber harvests, 1/3 less prescribed fire, and half as many miles of machine-constructed fire lines. Still, this is a very large project that will have significant, long-term impacts. 
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Because of the complex nature and large scope of this project, we’re going to dig deep into the issues here to help you understand what is being proposed by the Forest Service, why restoration efforts can be important, and the problems and shortcomings of the Forest Service’s proposal.

​Between the Cumberland River and the Big South Fork, along U.S. 27 through McCreary and Pulaski Counties, is one of the more extensive areas of national forest in Kentucky. Based on limited historical accounts, occurrences of rare plants and other species, and current natural community structure, it is probable that this area historically had semi-permanent areas of open forest conditions supporting a wide diversity of wildlife and other species. While closed canopy, old-growth forests were no doubt a substantial, even dominant, part of the landscape, sections or corridors with more scattered trees and an understory of grasses and forbs were likely an important part of the landscape. The landscape also likely contained various scrubby, shrub-dominated areas that were referred to as “roughs” and “barrens” by American settlers – terms that have made their way in to modern day place names. 
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These natural communities likely persisted through a combination of fire (both human and lightning-caused) and browsing by bison. U.S. 27 follows what has been called the Great Tellico Trail, an ancient north-south game trail and trade route connecting the salt licks, cane, and grasslands of the Bluegrass with the plains of central Tennessee. This long coevoloution of the landscape was thoroughly disrupted through settlement, homesteading, logging, fire suppression, and the utter annihilation of the immense herds of bison that once ranged through the region. Restoration of what was will never be entirely possible, but some efforts using the tools at hand may be necessary to preserve some of the historic diversity of the landscape. 

But will the Greenwood Project actually restore this landscape in any meaningful way? Or will it just be another timber sale leaving behind a legacy of roads, log landings, and invasive species? Some actions, if done right (like prescribed fire) could have significant benefits. But the Forest Service has not wavered from its emphasis on commercial logging, despite evidence and arguments that some of the most important restoration can, and should, happen without commercial logging.
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Below we describe many of the proposed actions in the Greenwood Project, along with criticisms and concerns to help inform you in writing your comment letter. You can read all the project documents on the Daniel Boone National Forest website here. Directions on how to submit your comments are at the bottom of this post.

One of the main, stated purposed for the Greenwood Project is to restore shortleaf pine on 661 acres through commercial harvest of hardwoods and planting of pine. Between 1999 and 2002, the southern pine beetle (SPB) – a native beetle in southeastern forests – had a massive explosion in population leading to the death of most shortleaf and pitch pines on the southern Daniel Boone NF.

​Across the 32,000 acres of national forest lands in the project area, the Forest Service has estimated that “10,468 acres of the project area lost, at minimum, 30% of their canopy to southern pine beetle mortality” where “stocking has been significantly reduced.” What this means is that there are thousands of acres of naturally thinned forests in the project area with mature hardwoods, like oaks and hickories, remaining in the canopy. Some of these stands lost only scattered pines, while others lost nearly all of their canopy.

The Forest Service’s proposal to “restore pines,” however, misses the mark. While the Forest Service has proposed pine restoration activities at some appropriate sites (where most of the canopy was lost to the southern pine beetle), several areas proposed for "restoration" are in fact mature hardwood stands that formerly had few pines. These mostly mature oak and hickory stands will be heavily logged and planted with pine, while large areas of degraded former pine forests are being left unmanaged. 

​​For more than two years we have been asking the Forest Service to prioritize restoring pine on actual former pine sites instead of clearing mature oak and hickory forests to do so. They insist in the Environmental Assessment that this is impossible. ​

​The Forest Service has proposed harvesting about 50% to 80% of the trees on 674 acres of oak and hickory forests to establish woodlands (woodlands are low density, fire-mediated forests). However, as discussed above, over 10,000 acres of the project area were naturally thinned from the southern pine beetle leaving scattered mature hardwoods in the canopy. We’ve spent extensive time in the field with the Forest Service looking at these stands, and discussing how woodland management can and should focus on these already impacted, thinned areas. Regardless of the facts on the ground, the Forest Service states that “The purpose of the proposed timber sale would be to establish the low to moderate basal area,” insisting that no forests with low-density canopies exist in the project area. This is simply not true, and the Forest Service knows it. The reality is that they are focusing restoration on areas with better timber value.

​Other timber harvests are included in the project, including “Low thinning” on 409 acres to harvest about 30% to 60% of the canopy (focusing on trees lower in the canopy), “Two-aged shelterwood” harvests to cut about 90% of the trees on 74 acres, and “Shelterwood preparatory cuts” to remove about 50% of the canopy on 245 acres. Another 447 acres of moderate, commercial “Pine thinning” are proposed for young, pole-sized pine plantations, though we do not find this prescription objectionable. 

​To facilitate logging, more than 100 log landings will be built in the forest. Log landings are areas that are completely cleared to stockpile and load timber. The soil in landings is heavily disturbed and compacted, and prone to invasive species. While no new permanent roads are planned, the Forest Service will reconstruct 1.6 miles of system road and build 4.1 miles of “temporary road” bulldozed through the forest in 29 segments. While temporary roads are seeded and have erosion controls installed, they are not temporary and are already quite extensive through the forest. The impacts of landings and roads are why restoring the landscape by working with existing natural disturbance is a more sound ecological approach. 

The Forest Service has proposed broadcast spraying of herbicides (glyphosate) on 222 acres across 75 wildlife openings maintained by the Forest Service and Kentucky Department of Fish and Wildlife Resources. The herbicides are proposed to kill non-native grasses like fescue and replant using no-till methods. While no-till agriculture can have benefits with regard to reducing erosion, erosion is not a major issue in these wildlife openings (they are mostly not very large, are in uplands away from stream channels, and are surrounded by forest).  The Forest Service says that some openings will be replanted with non-native forage for game (like clover or corn), while other areas would be replanted with native grasses and pollinator habitat species. The Forest Service does not provide any information about how many openings will be planted with native vegetation, despite our asking this question several times over nearly two and a half years. 
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In another 286 acres surrounding the wildlife openings, more herbicide would be used to control invasive species but be limited to spot treatments and stump applications. The proposal also includes commercial thinning of forest around the openings to create a transitional zone that may include the planting of native soft mast species such as crabapple, persimmon, dogwood and wild plum.
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Removing non-native species and establishing native species in and around openings could have significant ecological benefits. This needs to be balanced with considerations regarding the impacts of herbicide use. The adjacent London Ranger District recently proposed transitioning all 88 wildlife openings on that district to native vegetation without the use of herbicides. We feel that the Stearns Ranger District should consider this option for the Greenwood project. 

An integral part of the Greenwood Project is prescribed fire across 10,627 acres in 37 burn blocks. Several thousand acres of other, previously approved burn units surround the Greenwood project area, and arson is also a common source of forest fire in this are.

​Fire is an important part of this landscape, particularly in the drier upland forests, and we support its use in this project. Our main concerns relate to fire lines and return intervals (how often areas are burned). While the burn managers on the Daniel Boone are very conscientious, the project includes 37.4 miles of machine-constructed fireline. While reduced from the 64 miles originally proposed, it is still substantial. Another 45 miles of handline will be constructed, though those impacts should be minimal. 
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With regard to return intervals, the Forest Service has not provided any information about the intended frequency for fire. While this type of work is still experimental, it is generally agreed that to get a woodland understory that is rich in grasses and forbs (instead of a thicket of saplings and briars) the forest needs to burn every 1-3 years – at least initially. This is also true for natural shortleaf pine regeneration. Other important fire effects can come from more lengthy return intervals, but for the most specialized woodland and pine forest conditions (especially to address sprouting from cut maples), the fires must be somewhat frequent. The nearby, much smaller Freeman Fork Oak Woodland Restoration Project has prescribed two-year fire intervals. But most areas are being burned much less frequently, in large part due to resource limitations. Without the proper attention to sites in the Greenwood project area the results could be little different from a typical timber harvest.

​The Greenwood project includes extensive non-commercial timber cutting with limited impacts and several benefits. Crop tree release is proposed on 2,347 acres to thin dense forests that are recovering from clearcuts in the 1980’s and 1990’s. Many of these stands, which would have been dominated by oaks, hickories, and pines, are instead dominated by tulip poplar and stump-sprouted red maples. Thinning will help give a competitive edge to mostly oaks and hickories in the developing forests. Midstory control is proposed on 1,228 acres, much of which coincides with commercial harvest areas. This is a practice to cut and leave mostly red maples, which dominate the midstory in many stands. This is an important practice in restoring an open, fire-adapted forest structure. No herbicide is proposed for either treatment.

While no old-growth is proposed for harvesting, the Forest Service has made alarming statements against allowing forests to grow older and develop old-growth characteristics. They assert that, without logging, “forest health would deteriorate throughout the project area.” They further insist that unharvested forests will decline in biodiversity, have reduced productivity (contrary to current science), will suffer nutrient loss (again, mostly not true), and suffer “widespread and severe disease.” 
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They also insist that, without logging, the forests across the project area will “become more homogenous” where even-aged forests are “underrepresented” and structural diversity is diminished. Again, this is nonsense. Nearly all of the of the forest in the 32,000 acre Greenwood project area is even-aged. The Forest Service has harvested about 3,600 acres since 1980, and the southern pine beetle created thousands more acres of young and disturbed forest. Nearly 10,000 acres are less than 60 years old. What is alarming about these statements is that they provide a window into an antiquated, commodity-based view of our forests. According to these statements by the Forest Service, the most healthy approach to forest management is rotations of even-aged harvests where forests are harvested before old-growth characteristics redevelop. But timber quality is not the same as ecological health. If old-growth forests like Lilley Cornett Woods and Blanton Forest were under U.S. Forest Service management, and evaluated by these same criteria, they would be considered unhealthy and in need of harvest. We don’t agree. 

Comments should include “Greenwood Vegetation Management Project” in the subject line and be submitted to:
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Tim Reed, District Ranger, 3320 Hwy 27 North, Whitley City, KY 42653
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Email comments to:  comments-southern-daniel-boone-stearns@fs.fed.us