Kentucky Heartwood
  • Home
  • News and Events
    • Newsletters
    • Forest Blog
    • Music Festival 2022 >
      • Music Festival Pics
    • Past Events >
      • Stonecoal hike
      • Hemlock volunteer days
      • Red Hickory and Herbal Medicine Hike
      • Red Hickory Hike April '22
      • Music Festival 2021
      • Bat Meter Deployment Field Trip 2021
      • Virtual Membership Meeting 2021
      • The Three R's with Davis Mounger
      • White fringeless orchid mural
  • Forest Watch
    • FOIA
    • Jellico >
      • ORG COMMENTS
    • South Redbird Project
    • Blackwater (Cave Run Lake)
    • Red River Gorge
    • Pine Creek Forest Restoration Project
    • Greenwood
    • Pisgah Bay Project
    • Climax & Little Egypt >
      • Crooked Creek Photos 2011
      • Crooked Creek Photos 2010
    • Upper Rock Creek Logging >
      • Rock Creek Hike, November 2009
  • Issues
  • Donate
    • ANNUAL REPORT 2022
  • CONTACT
    • Volunteer
    • SUBSCRIBE
  • Links
  • About
    • Council & Staff

Kentucky Heartwood

We need forests we can get lost in; trees that make us gape; streams we can drink from. 
​Wild places sustain and define us; ​we, in turn, must protect them.

Kentucky Heartwood comments on proposed Forest Plan Amendment

3/25/2018

2 Comments

 
Picture
Indiana bat colony in the Daniel Boone National Forest in Rockcastle county
Kentucky Heartwood has submitted comments to the Daniel Boone National Forest concerning the proposed Forest Plan Amendment. (Scroll down for text or click here for a downloadable PDF of our comment letter).  As of this posting, 24 public comments have been submitted and are available to read on the Daniel Boone National Forest website  here, including comments from the U.S. Fish and Wildlife Service (USFWS) Kentucky Field Office (KFO). 

​Notably, the KFO states in their comment letter, "If the action is carried out as proposed, an increase in adverse effects on federally-listed species is anticipated." The KFO also states, "While the existing standards are more restrictive, it is important to note that they were intended to avoid and minimize the potential for adverse effects and incidental take of Indiana bats on the DBNF that were likely to occur as a result of certain types of tree removal and prescribed fire. In some circumstances, the season restrictions, buffers, and other standards also provided protection for-federally-listed plants and aquatic species. Elimination of these restrictions is, therefore, likely to have the opposite effect and result in increased adverse effects on listed bats, plants, and aquatic species and designated critical habitat, especially in light of the increased amount of forested habitat proposed for treatment under the proposed Forest Plan amendments."


It is very important that the Forest Service receive comments from the public. 
​We need to let them know that protecting endangered species is more important than selling a few more logs from our public forest. Feel free to use Kentucky Heartwood's comments as a point of reference for writing your own. You are also welcome to copy our comments and state to the Forest Service that you agree with them, if that makes it quicker or more likely for you to submit comments.
​
Here is a link to the page on the Daniel Boone National Forest website 
where the public can comment on this proposal. Comments are due by the end of the day on Monday, March 26, 2018. 

Comments can also be emailed to: comments-southern-daniel-boone@fs.fed.us

Or sent by postal mail to:

Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391

Be sure to state "Plan Amendment" in the subject line when providing electronic comments, or on the envelope when replying by mail. ​
​
forest_plan_amendment_indiana_bat_2018_scoping_comments_a.pdf
File Size: 231 kb
File Type: pdf
Download File

Picture
Dan Olsen, Forest Supervisor
Daniel Boone National Forest
1700 Bypass Road
Winchester, Kentucky 40391

March 25, 2018

RE: Forest Plan Amendment

Dear Supervisor Olsen,

Thank you for the opportunity to submit comments on the proposed Forest Plan Amendment with regards to Indiana bats and other federally listed species. The following comments are being submitted on behalf of Kentucky Heartwood and the Center for Biological Diversity. 

To begin with, we have no immediate concerns with the proposal to update definitions in order to bring the Forest Plan in to alignment with current U.S. Fish and Wildlife Service (USFWS) terminology. This is reasonable and prudent. We do have concerns regarding changes to restrictions or parameters in the Forest Plan affecting vegetation management, and logging in particular. The removal or reduction of protective measures with regards to Indiana and northern long-eared bat maternity colonies are particularly worrisome. Both of these species of bats are in sharp decline, and immediately imperiled. The possibility that the Daniel Boone National Forest would change Forest Plan standards in such a way as to increase the probability of impacting or destroying a maternity colony is not something that we find acceptable. The loss of a single maternity colony at this juncture could be catastrophic.

The following are questions and concerns that should be addressed in the environmental analysis for the Plan Amendment:

1) What are the current protocols for identifying maternity colonies or other active roosts? When during planning and harvest operations are surveys made, and by whom? What training is received by personnel to identify active roosts?

2) How often have maternity colonies been found in project areas? Following the identification of Indiana (and northern long-eared) bats, how did the Forest Service modify or delay specific projects and operations in order to comply with Forest Plan Standards? Please be specific. 

3) Please provide ample scientific evidence demonstrating that the newly proposed Forest Plan standards (e.g., changes to basal area standards, snag retention, seasonal harvest restrictions relating to habitat occupancy, etc.) are more or as protective for federally-listed bat species as the current plan standards. It does not appear to us that they are. 


We expect the Forest Service to commit to a thorough, detailed, and reasoned analysis with regards to any changes to Indiana and northern long-eared bat management on the Daniel Boone National Forest. Any changes to the Forest Plan should be firmly rooted in evidence that future management will be as or more protective of Indiana and northern long-eared bats as the current procedures. 

Sincerely, 

Jim Scheff, Director
Kentucky Heartwood
P.O. Box 1486
Berea, KY 40403

(859) 334-0602
jim@kyheartwood.org
2 Comments
Lynn Dalton
3/26/2018 01:28:35 pm

RE: Forest Plan Amendment

Dear Supervisor Olsen,

Thank you for the opportunity to submit comments on the proposed Forest Plan Amendment with regards to Indiana bats and other federally listed species.

To begin with, I have no immediate concerns with the proposal to update definitions in order to bring the Forest Plan in to alignment with current U.S. Fish and Wildlife Service (USFWS) terminology. This is reasonable and prudent. I do have concerns regarding changes to restrictions or parameters in the Forest Plan affecting vegetation management, and logging in particular. The removal or reduction of protective measures with regards to Indiana and northern long-eared bat maternity colonies are particularly worrisome. Both of these species of bats are in sharp decline, and immediately imperiled. The possibility that the Daniel Boone National Forest would change Forest Plan standards in such a way as to increase the probability of impacting or destroying a maternity colony is not something that we find acceptable. The loss of a single maternity colony at this juncture could be catastrophic.

The following are questions and concerns that should be addressed in the environmental analysis for the Plan Amendment:

1) What are the current protocols for identifying maternity colonies or other active roosts? When during planning and harvest operations are surveys made, and by whom? What training is received by personnel to identify active roosts?

2) How often have maternity colonies been found in project areas? Following the identification of Indiana (and northern long-eared) bats, how did the Forest Service modify or delay specific projects and operations in order to comply with Forest Plan Standards? Please be specific.

3) Please provide ample scientific evidence demonstrating that the newly proposed Forest Plan standards (e.g., changes to basal area standards, snag retention, seasonal harvest restrictions relating to habitat occupancy, etc.) are more or as protective for federally-listed bat species as the current plan standards. It does not appear to us that they are.

We expect the Forest Service to commit to a thorough, detailed, and reasoned analysis with regards to any changes to Indiana and northern long-eared bat management on the Daniel Boone National Forest. Any changes to the Forest Plan should be firmly rooted in evidence that future management will be as or more protective of Indiana and northern long-eared bats as the current procedures.

Sincerely,
Lynn Dalton

Reply
James Walls
3/26/2018 10:40:57 pm

Please save the forest and the wildlife, the bats are very important to the ecosystem !!!
Thanks

Reply

Your comment will be posted after it is approved.


Leave a Reply.

    Archives

    November 2022
    September 2022
    August 2022
    April 2022
    March 2022
    December 2021
    November 2021
    October 2021
    August 2021
    July 2021
    May 2021
    March 2021
    December 2020
    November 2020
    October 2020
    July 2020
    June 2020
    April 2020
    February 2020
    December 2019
    September 2019
    August 2019
    July 2019
    June 2019
    April 2019
    March 2019
    February 2019
    January 2019
    December 2018
    November 2018
    October 2018
    July 2018
    April 2018
    March 2018
    February 2018
    December 2017
    September 2017
    August 2017
    May 2017
    April 2017
    March 2017
    February 2017
    January 2017
    December 2016
    November 2016
    October 2016
    August 2016
    July 2016
    June 2016
    May 2016
    December 2015
    May 2014
    February 2014
    November 2013
    February 2013
    December 2012
    November 2012
    February 2012
    October 2011
    August 2010
    June 2010
    May 2010
    February 2010
    November 2009
    August 2009
    July 2009
    May 2009
    April 2009

    Categories

    All
    Adventure Tourism
    Bats
    Big South Fork
    Coal
    Comment Letters
    Dance
    Daniel Boone Nf
    Dbnf
    Division Of Forestry
    Event
    Film
    Forest Council
    Forest Plan
    Forest Resource Assessment
    Fundraiser
    Great Places
    Greenwood
    Health
    Heartwood
    Hemlock Woolly Adelgid
    Horses
    Invasive Plants
    Landfill
    Litigation
    Logging
    Mountaintop Removal
    Natural Bridge
    Pipeline
    Redbird
    Robinson Forest
    Rock Creek
    State Nature Preserves
    Thanks
    Website
    White Nose Syndrome
    Ymca

    RSS Feed

  • Home
  • News and Events
    • Newsletters
    • Forest Blog
    • Music Festival 2022 >
      • Music Festival Pics
    • Past Events >
      • Stonecoal hike
      • Hemlock volunteer days
      • Red Hickory and Herbal Medicine Hike
      • Red Hickory Hike April '22
      • Music Festival 2021
      • Bat Meter Deployment Field Trip 2021
      • Virtual Membership Meeting 2021
      • The Three R's with Davis Mounger
      • White fringeless orchid mural
  • Forest Watch
    • FOIA
    • Jellico >
      • ORG COMMENTS
    • South Redbird Project
    • Blackwater (Cave Run Lake)
    • Red River Gorge
    • Pine Creek Forest Restoration Project
    • Greenwood
    • Pisgah Bay Project
    • Climax & Little Egypt >
      • Crooked Creek Photos 2011
      • Crooked Creek Photos 2010
    • Upper Rock Creek Logging >
      • Rock Creek Hike, November 2009
  • Issues
  • Donate
    • ANNUAL REPORT 2022
  • CONTACT
    • Volunteer
    • SUBSCRIBE
  • Links
  • About
    • Council & Staff