A few months ago, Kentucky Heartwood released information and allegations that the Forest Service was selling more timber in the Greenwood project of the Daniel Boone National Forest than what was approved in the 2017 project decision. We also asserted that trees had been marked for harvest in some riparian buffers along stream channels in violation of the Forest Plan. The Forest Service has since released their own data and analysis, insisting that everything (or most everything) is just fine.

So, who’s right? 

​Where reality stands is a bit complicated and muddy, and requires wading through some jargon and technical matters. I hope you’ll read on and get the details. They’re important. In summary though, our originally surveys overestimated the amount of timber being oversold. However, we believe that the data show that the Forest Service is still selling far more trees than approved (including in riparian areas) and, in some respects and locations, high-grading the timber.
​
For any of this to make sense, an explanation of the term “basal area,” or just “BA,” is in order. Basal area is defined as the cross-sectional area of trees at 4.5 feet above ground in a unit area. In American forestry BA is expressed in square feet per acre. In academic research, and internationally, the units are square meters per hectare (a very un-fun unit conversion). Overall, BA provides a measure how much of an area is taken up by trees, and relates directly to the numbers and sizes of trees in the forest. Because measuring every tree in a forest usually isn’t practicable, basal area can be estimated by using a number of different tools and sampling protocols, each with their own limitations. 

Most “mature” and old-growth forests in our area have a BA ranging from around 90 to over 180 square feet per acre, but 110 to 150 is most common. Forest type, age, and disturbance history all play a big role. Several studies of regional old-growth forests have reported densities of trees over 4” (10 cm) in diameter ranging from about 65 trees per acre to around 250 per acre. A lot of small trees can be present in a forest and still contribute very little to overall basal area. On the other end of the management spectrum, most timber harvests on the Daniel Boone National Forest are shelterwood (or “regeneration”) cuts with a target BA of about 10 to 15 square feet per acre, and leave about 10 trees per acre.
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Just under one-third, or 674 acres, of the logging approved in the Greenwood project was ostensibly designed to restore mid-density, fire-mediated upland forest communities through the “Woodland Establishment” prescription. There’s good evidence that this type of forest was historically important in the area. Kentucky Heartwood did object, however, to some of the locations chosen for the Woodland Establishment prescription because site selection seemed to be more about access to large timber than actual restoration potential and need. 

​We strongly advocated for the Forest Service to focus their Woodland Establishment and other management prescriptions in areas with known rare and declining grassland remnants, like those found along the Keno Road and Curt Pond Ridge area in Pulaski County. That particular area was identified in a 1988 Cooperative Inventory of Endangered, Threatened, Sensitive, and Rare Species for Daniel Boone National Forest conducted by the Forest Service, The Nature Conservancy, Kentucky State Nature Preserves Commission, and Kentucky Department of Fish and Wildlife Service. The 1988 report highlighted the Keno Road area and recommended establishing the area “as an experimental demonstration project.” Unfortunately, the site has been largely neglected, resulting in a major decline of this rare “Cumberland Barrens” remnant.
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Despite our efforts, the Forest Service refused to include management of the Keno Road and Curt Pond Ridge areas (and other important sites) in the Greenwood project. The agency did, however, commit in their October 2017 response to our formal administrative objection to the Greenwood project, to working with Kentucky Heartwood and the Kentucky Office of Nature Preserves to develop a management strategy for the site. Unfortunately, other than a couple of on-site meetings in mid-2018, nothing has happened. 

​But let’s get back to talking about basal area.

The formal description for the Action 2: Woodland Establishment prescription in the Environmental Assessment for the Greenwood project is as follows:

“A woodland establishment treatment is proposed on approximately 674 acres in 20 stands. This treatment would retain an overstory canopy of dominant and co-dominant, vigorous, healthy, long-lived, and fire resilient trees, (e. g. shortleaf pine, chestnut oak, and white oak). The target leave basal area would be 30 to 50 square feet per acre.”

The selection of trees to be retained as “dominant and co-dominant, vigorous, healthy, long-lived, and fire resilient trees” is not incidental. While hollow, rotten, and declining trees are important ecological elements (and some must be retained per Forest Plan requirements), most won’t last long after logging. Particularly for structurally compromised trees, the increased exposure to windthrow following the harvest of adjacent canopy trees will hasten their loss from the canopy. And fire-intolerant species, like red maple, scarlet oak, and eastern hemlock, will be injured and decline following repeated applications of prescribed fire.

And it’s worth comparing the language for the Woodland Establishment harvest to that of Action 4: Shelterwood Preperatory Cut (a separate logging prescription in the project). The Shelterwood Preperatory Cut prescription states that:

“Trees favored for retention would be healthy, dominant, codominant, long lived, and fire-resilient species such as shortleaf pine, white oak, chestnut oak, and hickory with the best crowns.” 
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The deliberate use of the word “favored” in the prescription for Action 4: Shelterwood Preperatory Cut, but not in the prescription for Action 2: Woodland Establishment, is important. The Forest Service could have used similar equivocating language in the Woodland Establishment prescription, but didn’t. 

​In the Forest Service’s response to our complaint they report an overall retained BA of 37.5 square feet per acre. This is much higher than what we reported following our initial survey. Based on our subsequent surveys, we think that the Forest Service’s estimate for total, average BA is about right. The differences largely resulted from our use of transects instead of grid-based sampling. Despite our efforts to be non-selective while still collecting data representative of each harvest unit, we clearly missed some portions of stands which contributed substantially to the total basal area. However, reporting only the total BA misses a crucial part of the story.

Their report states that “For all stands sampled, trees with undesirable characteristics will comprise a small, but tolerable, amount of the future stand.”

However, the various data presented in their report, and one of their concluding statements, contradict this interpretation. The Forest Service reports states that:

"For all woodland stands and the shelterwood preparatory stand, the results indicate trees with desired characteristics comprise over 60 percent of the BA to be retained. Specifically, these trees are of a dominant or codominant crown class, a desirable species, and have a tree class of desirable or acceptable."
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The corollary here is that up to 39% of the trees being retained (representing about 14.6 square feet per acre of basal area) do not meet the criteria of being long-lived, healthy, vigorous, and fire tolerant trees, and have a high likelihood of declining or dying within a short period after logging and burning. It is hard to see this as only a “small, but tolerable, amount.” The final BA of trees that actually do meet the criteria for retention, based on the Forest Service’s data, is around 22.9 square feet per acre, or about half of the target BA prescribed in the Environmental Assessment. This value is very close to the 20.5 square feet per acre that we reported in our initial complaint.

Our subsequent surveys suggest that some of the harvest units are in compliance with the prescriptions in the EA. But some are not. To meet the letter and intent of the Woodland Establishment prescription, the Forest Service needs to retain, at a minimum, an additional 7 square feet per acre of the healthy, merchantable trees that they have marked and sold. If the pattern holds across the 674 acres of the Woodland Establishment prescription, that would amount to about 4,500 fourteen-inch diameter trees, or over 2,000 twenty-inch diameter trees. 
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The Forest Service did concur that trees were inappropriately marked for harvesting in at least one of the riparian areas that we brought to their attention. In the Daniel Boone National Forest logging isn’t allowed within 50 feet of streams classified as “intermittent,” but is allowed in and along stream channels classified as “ephemeral.” Differentiating the two can be challenging.  One location we took issue with was a headwaters tributary of Drury Branch, before it drops in to Beaver Creek Wilderness. The Forest Service did determine that the stream segment “confidently fits the definition of an intermittent stream,” but that the error was unintentional and understandable. However, the Forest Service is only reviewing the status of the approximately 300 acres that Kentucky Heartwood surveyed, and not any of the remainder of the more than 2,000 acres of logging in the Greenwood project. 

​We’ve yet to decide how to proceed with the Forest Service. These issues represent serious errors on the part of the government and are a breach of the public trust. It also comes at a time when we know that the Trump administration is putting pressure on the Forest Service to increase the volume of timber being harvested from our national forest lands. Our frustration is even more pronounced given the Forest Service’s foot-dragging on their commitments to manage the rare plant communities in the Keno Road and Curt Pond Ridge area. But the environmental impacts of these overharvests in the Greenwood project are less severe than the ongoing landslides resulting from recent logging in the Redbird District, and the thousands more acres of severe logging nearing approval in the South Redbird project. Given our organizational capacity, we have to be judicious in where we apply our resources. It’s not an easy call.

If you want to support this work, please consider donation to Kentucky Heartwood.
​You can join or donate here. 

I’ve struggled over these past few weeks with whether or not publish a statement on behalf of Kentucky Heartwood in response to the historic Black Lives Matter protests and demonstrations that are happening across the country. And I continue to struggle with it. I’ve found the statements issued by some organizations, businesses, and institutions to be powerful, insightful, and heartening calls to action, both personal and political. However, a great deal have also seemed – at least to me – to be little more than platitudes lacking in substance, dispensed out of concerns over marketing and retaining market share. But I am one to get cynical. 

To be clear, Kentucky Heartwood, including our Board and Staff, oppose racism in any and all forms. And if you know me personally (or follow me on social media) you probably have a sense of my thoughts on structural racism and police violence. These issues are real, and they are unacceptable.
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However, I do want to offer some personal thoughts and observations regarding structural racism and the conspicuous underrepresentation of people of color in conservation and outdoor recreation spaces. I have been involved in public lands protection for 20 years, and have been enjoying and exploring wild places for many years more. Among the hundreds of activists, attorneys, scientists, organizational staff, board members, and volunteers I’ve met in my capacity as a public lands advocate, very few have been people of color. And even fewer (one, maybe two?) have been Black. This hasn’t gone without notice among the groups that I’ve been involved with.  Most public lands advocates that I have known (though certainly not all) are sincerely concerned about issues of racial and social justice. I’ve participated in more than a few conversations about the lack of representation by people of color in our organizations, as well as the conservation movement more broadly. Despite heartfelt and genuine concern, efforts – including my own – have rarely moved beyond conversations and the setting of intentions. 

For years I excused this absence of people of color from our organizations, campaigns, and spaces as a regrettable but understandable reflection of the nature of activism. People tend to pour in the time and energy on issues that are closest to them. For too many people of color, and especially for those in the Black community, that often and unfairly means that people’s energy is taken up by the countless daily, tangible struggles rooted in historical and contemporary systems of racism. Put another way, it’s not fair to expect someone to care very much about logging on a national forest when they’re worried that their son might be shot by the police for pulling out his cell phone.

But this perspective accepts too much exclusion, both within our organizations and in the outdoor spaces that we work to protect. It ignores the gross unfairness of the fact that centuries of white supremacist violence and structural inequities continue to affect so many Black people’s relationships with, and access to, America’s wild outdoor spaces and public lands. My understanding of these issues is at best shallow. What I do know is that there are stories that need to be heard, both of history and lived experience.

I think sometimes about the race riot in Corbin in 1919, just 18 years before the establishment of the Cumberland National Forest (later to be renamed the Daniel Boone National Forest). A vibrant Black community of roughly 200 people was summarily rounded up, forced on to rail cars, and removed from the state to the words “By God we are going to run all Negroes out of this town tonight.” For those families who’s stories and memories include this violent episode, what does it mean to pass Corbin on the way to Cumberland Falls? Does it mean something different today than it did a generation ago? What about the ways that “sundown laws” kept Black families from traveling to visit State and National Parks, National Forests, and other public lands? What is the legacy of the Commonwealth of Kentucky barring Black people, by order of law, from nearly all State Parks until 1955 when the Supreme Court ruled the practice unconstitutional? What does it mean when going to a park or stopping for gas on your way home could mean arrest, or worse? How are the outdoor experiences of a young person of color, today, affected by the stories of their parents or grandparents?

And it would be so easy, perhaps even comfortable, to pretend that the exclusion of Black people from outdoor spaces is some relic of the past. But it’s not. In February of this year, 25 year-old Ahmaud Arbery was shot dead while going for a run by armed vigilantes who assumed that he’d committed a crime. He hadn’t. In May, Audubon Society Board Member and notable comic book author Chris Cooper had his life threatened while birding in New York’s Central Park when a white woman got upset because he asked her to follow the rules and leash her dog. Her response was to call the police, frantic, and telling the lie that a Black man was threatening her. He wasn’t. Or we could talk about North Carolina botanist (and musician and chef), Justin Robinson who was handcuffed while looking at plants in the woods. I know a lot of botanists. All are white. And I’m fairly certain that none have been put in handcuffs while looking at plants.

Or we can talk about the Confederate flags displayed prominently on homes and farms along the road sections of the 333-mile Sheltowee Trace National Recreation Trail. How can a person of color experience the trail as I can, and find the same peace and ease in walking those long miles with so many Kentuckians proudly flying a flag that says “I’d rather you be in chains”?

And even within Kentucky’s outdoor community, racism continues to bubble to the surface. Over the past month, one of the only prominent Black people in Kentucky’s conservation and outdoor recreation community, someone I consider a friend, has been repeatedly attacked through social media with vitriol and accusations of racism for speaking with measured words about… racism. Their repeated message is “Shut up.” Over and again, “Shut up. Your story is not welcome here.”

I don’t know the answers. And I won’t pretend to. But I’m pretty certain that, at least for white people like me, now a time to listen. And it is okay if the voices and stories being lifted challenge your understanding of the world, or even your understanding of your self. But what is not okay is to respond to this moment, to the cries of grief and anger over generations of state-sanctioned violence and exclusion, to the murders of Breonna Taylor, George Floyd, Stephon Clark, Philando Castille, Tamir Rice, and so many others, by dismissing the very real and contemporary effects of structural racism in America. Such denials are lacking in veracity and belie the facts. They are simply not serious.

Our public lands belong to all of us. The experiences they give us should be accessible to all of us. And it will take all of us to protect them in this age of accelerating climate change and biodiversity collapse.

The status quo is not acceptable.

Black Lives Matter.
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Jim Scheff
Kentucky Heartwood

​Kentucky Heartwood has documented multiple ongoing landslides in the Redbird District of the Daniel Boone National forest caused by logging in the Group One project in Clay and Leslie Counties. To date, we’ve identified at least 6 landslides, including two that dumped sediment into streams and one that took out about 200 feet of mountainside. All of the landslides started at “full bench” skid trails that the Forest Service allowed to be bulldozed across the mountainsides for loggers to get at the timber. We also found that the Forest Service had allowed far more of the forest to be bulldozed and scraped clear than is permitted under the Forest Plan. 

​​Prior to our bringing these landslides to their attention the Forest Service claimed that no landslides or other major erosion was happening as a result of their logging operations. Their position has been that Forest Plan Standards for the Daniel Boone National Forest, as well as Kentucky’s state forestry Best Management Practices, were effectively protecting forest soils and streams. They’re not.

In addition to erosion and landslides, infestations of non-native invasive plant species (NNIPs) is especially bad in the Group One project. We conducted surveys of one logging unit harvested in 2012 and documented 18 species of NNIPs. We sampled twenty-four 25 ft. by 5 ft. plots running perpendicular to skid trails and found that average cover of NNIPs was 39.8%. Thirty-eight percent of plots had more than 50% coverage of NNIPs. The Forest Service contends that all contract provisions for minimizing NNIP infestations were followed.

​The Group One project was approved in 2008 after being withdrawn twice after challenges by Kentucky Heartwood. Over 1,000 acres of logging were ultimately approved for various "forest health" and "habitat improvement" purposes. The Forest Service is now nearing approval of over 3,000 more acres of logging in the nearby South Redbird project. The South Redbird project will allow the same types of logging on the same types of slopes and soils, but at a much larger scale - with individual logging tracts over 300 acres in size (10 times bigger than those in the Group One project). Up to 91 miles of full-bench skid roads could be bulldozed across the mountains. Most of the South Redbird logging will occur in watersheds that provide critical habitat for the federally-threatened Kentucky arrow darter (Etheostoma spilotum), and habitat for the federally-endangered Snuffbox mussel (Epioblasma triquetra).

​In February, Kentucky Heartwood produced a video using drone footage showing logging at several sites in the Group One project. The video shows some of the landslides, along with the astounding amount of bulldozing that the Forest Service has allowed for removing timber. Shortly after we produced the video, we found an even larger landslide in a harvest unit on Ulysses Creek (unfortunately we did not have access to a drone at the time). 

If you think this is valuable information, please consider supporting Kentucky Heartwood's work! We are a small organization anticipating significant shortfalls this year. Any bit helps.
Donate here!

​In January the Forest Service published their final decision on the Pine Creek Forest Restoration Project. The final approval of the project comes 4 years after the Forest Service’s first meetings to gather input on this extensive project covering what is, arguably, one of the best parts of the Daniel Boone National Forest. Over these four years, Kentucky Heartwood submitted multiple rounds of formal comments and filed an administrative objection (with the Kentucky Resources Council) challenging portions of the Draft Decision and Finding of No Significant Impact. We covered thousands of acres in the field, documented old-growth and rare plants, exploding user impacts at Pine Island Double Falls, and walked the length of the Sheltowee Trace National Recreation Trail as it traverses the project area. We led field trips, hosted a public forum in Corbin, published numerous articles and blog posts, and shared stories and images of this outstanding piece of Kentucky. We worked hard to spread word about this project, and to help get the public involved.

​We think that our efforts had a big impact on the final outcome. There are certainly aspects of the Pine Creek project, and the environmental analysis, that we are not happy with. However, there’s also a lot in this proposal to be pleased with. This is a complicated project – in many ways reflecting the complexity of the landscape, it’s biodiversity, and the myriad of ways that the public connects with it. 

​
First let's talk about the good stuff:
 
New old-growth designations
For the first time since adoption of the Forest Plan in 2004, the Forest Service expanded official old-growth designations in the Daniel Boone National Forest. This is something that we’ve been advocating for for many years. Initially, the Forest Service proposed adding 500 acres to the Designated Old-Growth Management Prescription in the Forest Plan, including 370 acres adjacent to Rock Creek Research Natural Area and another 130 acres in Angel Hollow. Throughout the analysis process, we pushed for larger old-growth designations, including more upland forest types. In response, the Forest Service expanded the Designated Old-Growth designation around Angel Hollow to 550 acres, for a total 920 new acres in this management prescription. Both areas include a combination of old-growth and older second-growth forests.
 
Dropping 2,000 acres of shelterwood harvests
The Pine Creek project originally included over 3,200 acres of even-aged shelterwood harvests. Approximately 1,300 acres were proposed to happen over the next 5 to 10 years, with another 2,000 acres to occur after about 10 years in stands initially managed with midstory removal (non-commercial thinning of mostly red maple). We asked the Forest Service to drop the latter 2,000 acres of shelterwood cuts, and they did. Logging in those stands could still be proposed in some future project, but for now they will only be managed with non-commercial midstory thinning and, in some areas, prescribed fire. 

​Pine Island Double Falls
Over the course of the project’s development, visitation of Pine Island Double Falls exploded. We convinced the Forest Service to drop the shelterwood logging prescription for a 50-acre stand adjacent the falls area, including some gorgeous large black and northern red oaks and some nice old-growth tulip poplars. The Forest Service has also committed to a public process to develop a trail to access the falls and try to limit the expanding and unmanaged user impacts. 
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Protecting the Sheltowee Trace National Recreation Trail
The Sheltowee Trace National Recreation Trail goes through much of the Pine Creek project area, including several proposed harvest areas. One section of the trail in particular, along Poison Honey road, would have been significantly impacted. We originally asked the Forest Service to drop the shelterwood prescription along the road, and reroute the trail from the road into the forest. The Forest Service modified the proposal to reroute the trail through the forest, but still planned a shelterwood cut that would have significantly affected the experience of trail users and degraded the area’s scenic integrity. During the formal objection process we convinced the Forest Service to change the prescription of this unit to a woodland management prescription. This new prescription will retain much more the forest canopy, remove some of the midstory, and include prescribed fire (already proposed for that section). The Forest Service has committed to working with the Sheltowee Trace Association on trail layout. This new prescription, while still including some timber harvest, should result in an open forest structure with a good amount of remaining canopy and large trees. 

​Restoration of fire-adapted upland forest and grassland communities
One of the more fascinating aspects of the ecology of the southern Daniel Boone National Forest is the presence of historic grassland and oak and pine savannah remnants existing in an otherwise deeply forested landscape. Indicators of these relict communities, like wood lily, rattlesnake master, blazing stars, and other conservative grassland species, can be found hanging on along some roadsides and powerline corridors. While the earlier Greenwood project on the Stearns District (approved in 2017) was ostensibly aimed at restoring these important natural communities, the Forest Service in that project failed to integrate important botanical indicators into planning – instead relying on general assessments and emphasizing management in locations where there was good timber to cut.  In contrast, the London District undertook a detailed assessment of these upland, fire-adapted communities for the Pine Creek project, including input and data from the Kentucky Office of Nature Preserves, Kentucky Heartwood, and botanist Julian Campbell. This collaborative effort helped to identify broad areas and specific sites where comprehensive restoration, including fire, commercial and non-commercial thinning, and other work, would have the most significant benefits for the broadest suite of species. Most of the woodland management in the Pine Creek project will happen in the Pulaski County side of the Rockcastle River.

​​The Forest Service has also incorporated a novel approach to restoring shortleaf and pitch pine in these areas. These species of pines were decimated during the 1999-2002 southern pine beetle outbreak. Contrasting with previous pine restoration efforts on the Daniel Boone, which have been akin to pine plantations, the Forest Service here plans to plant pine in small groups or clusters (aka “cluster planting”) in suitable microsites. This will help the area develop a more complex, heterogenous structure and species composition that more closely resembles the area’s historic condition.
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The restoration of fire-adapted upland communities, with an intermix of semi-stable grassland, shrubland, and open-canopy forests, is a way to provide for the long-term habitat needs of species that rely on early-seral and related vegetation structures.  

Close and rehabilitate user-made OHV and horse trails
The Forest Service used LIDAR to document 23 miles of illegal off-road vehicle and horse trails impacting the state Wild River section of the Rockcastle River. The Forest Service plans to close and rehabilitate these user trails by felling trees, placing boulders, and revegetating areas near the river.

​The not-good stuff:

1,150 acres of shelterwood cuts
The Pine Creek project still includes 1,150 acres of shelterwood regeneration cuts, with some really nice sections of forest that will be heavily logged. We have concerns that some local populations of Stewartia ovata (mountain camellia), in particular, will be damaged. To their credit, the Forest Service finally admitted that without additional management, logging these areas will likely result in a transition from oak-dominated forests to forests dominated by red maple and tulip poplar. This species shift is a pattern we’ve documented extensively in previously logged areas across the Daniel Boone National Forest. To address this issue they’ve included additional management, including non-commercial felling and prescribed fire, in areas proposed for shelterwood cuts to help perpetuate oak species in these stands. 

It’s true that the proposed shelterwood cuts will provide benefits to some struggling wildlife species, and some migratory bird species in particular. However, unlike the woodland restoration activities described above, the habitat benefits of shelterwood harvests tend to be brief, while the impacts of road building, non-native plant invasions, and loss of large trees persist. Hopefully the Forest Service will provide more care and attention to management in these areas than we’ve seen in recent harvests in the Redbird District.

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Indiana and northern long-eared bats
One of the big sticking points for Kentucky Heartwood has been the Forest Service’s refusal to conduct surveys for endangered bats in proposed harvest areas. In particular, we are concerned about impacts to maternity colonies of federally-endangered Indiana bats and federally-threatened northern long-eared bats. The Forest Plan has a requirement that “Tree cutting may not be conducted within 2.5 miles of any Indiana bat maternity colony from May 1 through August 15.” This binding Forest Plan Standard also applies to Northern long-eared bats. However, the Forest Service is relying on limited survey data from more than a decade ago to determine that no maternity colonies are in the project area. The U.S. Fish and Wildlife Service, in comments they submitted last year on a proposed Forest Plan amendment which would limit protections for endangered bats, cited this paucity of survey data in stating that “It appears likely that there are other Indiana bat and northern long-eared bat maternity colonies present that have not been documented.”
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We raised this issue in our comments and through the formal, predecisional objection process. The Forest Service refused to budge on this. 

​The Pine Creek project area covers some of the best parts of the Daniel Boone National Forest. It’s a rugged landscape where the Rockcastle River and its tributaries cut deep gorges through the sandstone of the Pottsville Escarpment of the Cumberland Plateau. It’s a labyrinthine, magical world of cliffline and waterfalls, natural arches and old-growth forests. It’s home to a myriad of rare and endemic species, like Lucy Braun’s white snakeroot and Indiana bats. And it includes some of the most utilized and loved recreational sites in the Daniel Boone. We thank every one of you that sent comments to the Forest Service advocating for this special landscape. Your contributions had a tangible effect on the outcome of this project. Thank you.

You can read more about the project, including Kentucky Heartwood's comments and formal objection here. 

If you appreciate this work, and want to see it continue, please consider supporting Kentucky Heartwood with a financial contribution. We are a small, bare-bones organization and really do need your help to keep it up. You can support Kentucky Heartwood by making a donation here.

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.
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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.
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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.

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​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.
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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
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​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.
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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:
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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.
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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!

Thanks to the generosity of our members and supporters, $10,010.11 has been raised so far for our first ever matching funds campaign, meaning a total of $20,020.22 will go toward our work!

​You all are amazing!!

We still have $14,989.89 left to go to take full advantage of this opportunity.

If you have been waiting for a good time to donate to Kentucky Heartwood, this is it! This offer expires at 11:59 pm on Tuesday, September 24, 2019.

This matching fund campaign made has been made possible through an astonishingly generous donation of $25,000 offered to us by Rich Rosen and Anna Marie Pavlik of Frankfort, Kentucky. Their donation, however, comes with one major stipulation – that we ask you, our members and supporters, to match Rich and Anna Marie’s investment in Kentucky Heartwood. They want to know that you support our mission as much as they do. 
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For 27 years, Kentucky Heartwood has worked continuously to protect and preserve Kentucky’s public lands and native forests. We do it for the old trees and orchids. We do it for the land snails and bats, warblers and darters. We do it for the peace and the beauty. We do it for wildness. And we do it for you.
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And now, we need your help. If you can give, please do. It really will make a difference. 

​Donate online or via postal mail

Kentucky Heartwood is a 501(c)3 nonprofit organization. Donations are tax deductible. 

​Recurring monthly donations are available and appreciated.​

​Choose the subscribe option to donate monthly, or use the Donate button to give a one-time donation.

​If you prefer to donate via postal mail, you can download our membership form by clicking here.

​Mail donation and membership form to Kentucky Heartwood P.O. Box 1486 Berea, KY 40403.
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Thank you so much to everyone who has donated so far! We couldn't do it without you!

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.
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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.

​Background
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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);
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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.r8dbloncom@usda.gov

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. 

If you appreciate this information please consider making a donation to Kentucky Heartwood or becoming a member today. Our work can't happen without the support of people like you. 

The U.S. Forest Service has extended its comment deadline to Aug. 26. Take action at OurForestsOurVoice.org.

​The United States Forest Service and Trump administration have put forward a dangerous new proposal to end longstanding requirements that the Forest Service notify the public, allow for public comment, and analyze environmental impacts when approving logging, road building, pipeline construction, and other activities on 193 million acres of national forest lands across the country, including the Daniel Boone National Forest and Land Between the Lakes National Recreation Area in Kentucky. Comments on the proposal are due by August 12, 2019. Directions on how to comment are at the end of this post. 

​What are they doing?
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The proposed rule would amend the agency’s procedures for implementing the National Environmental Policy Act, commonly known as “NEPA.” The proposed changes fundamentally undermine NEPA’s bedrock principles of government transparency, accountability, public participation, and science-based decision-making.
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In more technical terms, the Forest Service’s proposal would allow most land management activities to take place under a “Categorical Exclusion” or “CE,” whereby the Forest Service can approve projects without first conducting an Environmental Assessment (EA) or Environmental Impact Statement (EIS). Traditionally, CEs have been used for minor, non-controversial activities like removing hazard trees from campgrounds and roadsides. The proposal also does away with requirements that the Forest Service notify the public and allow for public comment on projects before a decision is made, whether carried out under a CE or with a full Environmental Assessment or Environmental Impact Statement. 

​The types of projects that the Forest Service wants to apply Categorical Exclusions to include:

• Logging (including clearcutting) on up to 4,200 acres at a time (over 6 square miles) for nearly any purpose
• Building up to 5 miles of new system roads through the forest (and reconstructing old roads up to 10 miles), even though the agency can’t maintain its current road system
• Bulldozing up to 4 miles of pipeline and utility right-of-ways through the forest
• Closing roads and trails used for recreational access
• Adding illegally created roads and trails (especially those created by off-roading) to the official Forest Service road and trail system

​In effect, every single logging project, and nearly all utility and road building projects on the Daniel Boone National Forest and at Land Between the Lakes National Recreation Area could be proposed in secret, with no environmental review and no public input. Adding to the audacity and absurdity of the Forest Service’s proposal, the 4,200 acre logging exemption was created by averaging project sizes from across the country, with the 170,000 acre Land Between the Lakes National Recreation Area treated the same as the 17,000,000 acre Tongass National Forest in Alaska.
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And these aren’t the only destructive provisions in the proposal.

​Why are they doing this?

According to the Forest service, this radical proposal is about “increase(ing) the pace and scale of work accomplished on the ground.” But the bottom line is that it’s about cutting more timber, building more roads, and allowing more pipelines and utility development without the hassle of public participation, oversight, or environmental analysis.
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But NEPA isn’t the problem. The main reason that the Forest Service has trouble getting work done – whether it’s maintaining campsites and trails or selling timber – is that they are severely underfunded by Congress and woefully under-staffed which shockingly high turnover. Over the last 10 years, the Daniel Boone National Forest has had four Forest Supervisors and eleven District Rangers in charge of the four Ranger Districts. Forestry and wildlife personnel – the people that actually plan most land management projects – are often temporary fixtures, coming and going from other national forests and agencies from all over the country. It’s become rare to have consistent Forest Service personnel throughout the development of even a single project on the Daniel Boone National Forest.  

​Why does this matter?
​
Public lands belong to the public, and the Forest Service can make some really bad decisions. Whether you care about hiking trails or rare plants, old-growth or clear streams, your voice matters.

​Without the currently mandated system of public participation and environmental analysis we never would have identified and saved the forest above Climax Spring and old-growth in Little Egypt from logging in the Crooked Creek project, or stopped thousands of acres of deeply unpopular logging in Land Between the Lakes in the Pisgah Bay project, or saved old-growth “Core Areas” in Land Between the Lakes from getting logged in the Birmingham Ferry Salvage project, gotten hundreds of acres of logging dropped in the Greenwood project (saving the trailhead to the Beaver Creek Wilderness and Three Forks of Beaver Creek Overlook), stopped road building in the Beaver Creek project near Cave Run Lake, or identified old-growth that the Forest Service wants to log in the South Redbird project…the list goes on. 

​What can you do?

Send in your comments!
The Forest Service is accepting comments on their proposal through August 12th, 2019. Although  you can submit comments directly through the Forest Service’s website here, we recommend using the web portal set up by our friends at the Southern Environmental Law Center at OurForestsOurVoice.org. This web portal will assist you in submitting unique comments, and help us track the number of comments getting submitted. There have been indications that the federal government has been “losing” comments submitted through federal portals and we want to make sure your voice is heard.

Spread the word!
We need help getting the word out. Our social media feeds and inboxes are all packed these days, and we’re not seeing much about this from many of the big national organizations that have a big reach. By helping to amplify this message you can make a real difference.

Call your members of Congress!
While this proposal is coming from the Trump administration and U.S. Forest Service, make sure your members of Congress know that you strongly oppose the Forest Service taking away public participation and oversight of national forest management. Public opposition has stopped similar proposals in the U.S. House and Senate in recent years.

For more details and a great explainer on why this matters so much, head on over to our friends at Tennessee Heartwood. They’ve done a fantastic job going deep on why NEPA and public participation are critical for protecting our public lands.

You can also read these articles from The Hill and NPR. 

Official documents for the Forest Service's proposal can be found on the Forest Service website here. 

And if you find this useful, please consider supporting our work by donating or joining Kentucky Heartwood here. 

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

To comment, we recommend using the web portal set up by our friends at the Southern Environmental Law Center at OurForestsOurVoice.org.

This web portal will assist you in submitting unique comments, and help us track the number of comments getting submitted. There have been indications that the federal government has been “losing” comments submitted through federal portals and we want to make sure your voice is heard.

The Forest Service has released their formal proposal (scoping document) for the “Improving Conditions in the Blackwater Watershed” project, which would approve thousands of acres of logging on the east side of Cave Run Lake.
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Comments on the Blackwater project are due by Friday, June 21st, 2019. Directions for commenting are at the end of this alert (comments made on this blog post do not go to the Forest Service).

​Despite having held a series of public meetings and conversations during the development of the project, the Forest Service has failed to provide critical information in the proposal - including the actual locations of where they would sell timber. Instead, the agency has provided maps that show nearly 12,000 acres of areas where logging could happen over the next 10 to 30 years if they approve the project.

​A breakdown of the confusing information provided in the proposal indicates that the Forest Service plans to log nearly to 1,200 acres per decade under this proposal, with an open-ended timeframe. The actual locations of logging areas won’t be determined or disclosed until after the environmental analysis and final decision approving the project – and well after the public has any meaningful opportunity to provide input or challenge the project. This is a radical change from decades of management and planning on the Daniel Boone National Forest, and follows an alarming trend happening on other national forests. 

​What we do know is that most of the logging would be in the form even-aged shelterwood cuts, where about 85% of the canopy is cut across units (stands) of 20 to 40 acres. A small amount of the shelterwood cutting (less than 5%) would take place to restore ecologically important limestone and cedar glades. Depending on the specific locations and practices used, some timber harvest to restore these glades could be beneficial.

The Forest Service has also proposed a small amount of uneven-aged management through group selection. However, what the Forest Service is calling “uneven-aged” management would consist of 1 to 2 acre clearcuts, rather than more selective, finer-scale silvicultural approaches that could support the development of true, multi-age forest structure.
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The project would also allow for a variety of activities meant to improve streams across the project area, which we support. Stream restoration and improvement work could include reshaping stream channels, adding coarse woody debris, and planting native vegetation, as well as road work replacing culverts, hardening stream crossings, and relocating roads. The proposal also includes upgrading and seasonally opening certain roads in the project area to increase recreational access. 

A summary of our main concerns:

• The Forest Service should not approve any logging projects without first disclosing the specific locations where timber harvests are planned. If the Forest Service hasn’t yet figured this out, then the proposal isn’t ready. A revised proposal should be made available for public comment after specific areas have been identified for specific types of management.

 

• The Daniel Boone National Forest has a terrible track record of causing infestations of non-native invasive plants in interior forests as a result of their logging operations. Through the bulldozing of “temporary roads,” clearing and compaction of log landings, and creation of networks of skid trails through forest, infestations are regularly established. This is something that the agency has been unwilling to seriously reckon with. And experience shows that the predominantly oak forests being cut in the Daniel Boone National Forest have been coming back in tulip poplar and stump-sprouted red maple. Private lands in Kentucky are providing plenty of timber into the economy. There’s no reason to degrade our public, national forest lands to get logs to the mill.

 

• While we prefer that logging not occur (other than to support the conservation of rare natural communities), changes could be made to make the prescriptions better. The uneven-aged logging prescription in the current proposal should be modified, with group selection harvests reduced to less than 1 acre (typically 0.25 to 0.5 acres), with tree thinning oriented toward the development of complex, multi-age forest structure. This would better mimic prevailing natural disturbance events and could support the development of old-growth forest structure in some areas. The Forest Service should also avoid using shelterwood or other regeneration cuts. And no “temporary roads” should be constructed to extract timber. These features are ugly, lasting scars on the landscape and are where some of the worst infestations of non-native invasive plants get started. Lower impact timber harvest methods are available. 

​What we do support:

• We strongly support the proposed stream restoration activities. This is part of the core mission of the U.S. Forest Service, and should move forward.

 

• The Forest Service has stated that they won’t use regeneration (shelterwood) cuts on forests over 118 years of age, and will not propose any management in forests meeting old-growth criteria that will “diminish old growth characteristics.” This is something we have long advocated for.

 

• Focused restoration of limestone and cedar glades in the project area could have a significant beneficial impact for a variety of plant and animal species. While using commercial harvest methods, these activities could be beneficial if negative impacts from ground disturbance (especially non-native invasive plant infestations) are appropriately addressed.

 

• We generally support the use of prescribed fire in the project area, though the specific locations of burn units need to be disclosed. The interaction of specific forest types and natural communities, as well as proposed vegetation management (logging), with fire is not uniform and needs to be carefully looked at.

 
We’ll post our full comments on our website once we get them submitted.

The official proposal, maps, and other project files can be viewed here.

Comments are due by Friday, June 21st, 2019

Make sure to include the full project title "Improving conditions in the Blackwater Watershed" with your comments.

Documents for the project can be found on the Forest Service’s website here.
 
Comments can be submitted in the following ways:

The Daniel Boone National Forest Service website has a comment form on their website here.

They have also a reading room, where you can read comments that have been submitted by the public. 
 
Comments can also be sent by postal mail to:
 
Cumberland Ranger District, DBNF
2375 KY 801 South
Morehead, KY 40351
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And if you find this information helpful, please consider supporting Kentucky Heartwood so that we can continue to help connect you with what's going on with your public lands. Join or donate here.