Environmental Assessment released for Comment on Greenwood Project

Comments are due by Monday, March 6, 2017
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Directions on how to submit your comments are at the bottom of this post.
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​The Daniel Boone National Forest on February 2nd released for comment the Environmental Assessment (EA) for the Greenwood Vegetation Management Project. This is the largest timber sale proposed on the Daniel Boone in more than a decade. Comments are due by Monday, March 6, 2017.

​The project, first announced in July, 2014, proposes extensive and varied vegetation management on over 12,000 acres of national forest land in the Stearns Ranger District in McCreary and Pulaski Counties. The project is predicated on legitimate goals for the restoration of fire-adapted forest communities, but is regrettably skewed toward commercial timber harvests at the expense of restoring ecosystems.

Large, old chestnut oak in a proposed woodland harvest unit

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.

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​Background

​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.

Example of an area with major pine beetle damage and resulting open canopy on Curt Pond Ridge

​Pine restoration and the southern pine beetle

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. ​

Forest proposed for clearing and pine planting for "pine restoration"

​Woodland establishment harvests

​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.

An example where pine beetle damage and fire has begun to create open woodland conditions on Curt Pond Ridge. Near the site are several interesting or rare "prairie-type" plant species. Over the last several years, absent fire, saplings have begun to fill more open areas.

​​Other logging prescriptions

​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. 

Beautiful mixed forest with sugar maple, white ash, beech, white oak, and hickories with a cane understory near the mouth of Beaver Creek. This area is proposed for harvest to create "woodlands."

​Log Landings and roads

​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. 

Typical log landing in the Brushy Ridge project.

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​Wildlife openings and herbicides

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. 

Wildlife opening in Beaver Creek area.

​Prescribed fire

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.

Sugar maple, shagbark, and cane forest proposed for harvest near the mouth of Beaver Creek.

​Midstory control and crop tree release

​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.

The area on the left has had midstory thinning and some fire, whereas the forest on the right has not. The forest on the left is proposed for some overstory harvest and more fire.

​Hostility toward old-growth

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. 

Old-growth pignut hickory in a proposed harvest unit.

​Comments are due by Monday, March 6, 2017

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